Publication Plan November 2022

Comment

Representation ID: 4417

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes recognises that the Local Plan should set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land as required by para 142 of the NPPF.
The proposal for land to the east of Bilbrook identifies adjacent land, to remain in the Green Belt, to provide compensatory improvements. Such improvements will include the provision of public access as part of an overall green infrastructure strategy that will also secure improvements to environmental quality of this land.

Support

Representation ID: 4420

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the settlement hierarchy which considers the relative sustainability of villages within South Staffordshire District. Bloor Homes supports the distribution of housing growth through the identification of strategic sites close to the Black Country and proportionate growth focused to the villages, with the most sustainable villages, including Codsall/Bilbrook to deliver a higher amount of growth.
Housing growth also appears to be focused to the north of the District which aligns to the location of the Tier 1 settlements and the proposed employment strategy, that seeks to deliver thousands of new jobs in the northern extent of the District, including the freestanding and expanding employment site of i54 South Staffordshire within close proximity to Bilbrook.

Comment

Representation ID: 4421

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes notes Policy DS6, which recognises the Council’s aspiration to explore the potential for a sustainable, independent new settlement.
Policy DS6 recognises that such an option would not contribute to housing growth during the proposed plan period to 2039 which is agreed. A new settlement proposal, even if a suitable and viable option were to be identified, would take a long time to masterplan and facilitate and would need to be delivered alongside infrastructure on a scale much larger than a usual development.

Support

Representation ID: 4470

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the Council’s masterplanning approach to ensure high quality design. Bloor Homes confirms that a comprehensive and deliverable sitewide
Strategic Master Plan will be prepared in respect of the Strategic Development Location at Bilbrook. This will be prepared in conjunction with the Council and informed through pre-application discussions.
It is the intention of Bloor Homes to prepare this site-wide Strategic Master Plan to inform a future planning application, recognising that this Masterplan will be
adopted prior to the determination of any planning application.

Comment

Representation ID: 4471

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2
to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Due to the size of the site at Land East of Bilbrook and the lack of identified constraints, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of 35-40dph. However, this would be achieved through the provision of character areas of varying densities and would be reflective of the character of surrounding development, including
higher density development close to centrally located community facilities.

Comment

Representation ID: 4472

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs. The Stage 1 Viability Study confirmed that affordable housing within the range of 20-30% is potentially relevant to strategic housing sites overall, assuming a maximum of £9,200/dwelling S106 costs and no additional CIL contribution. For Land East of Bilbrook the appraisal appears to assume approximately £14,000/dwelling S106 costs and no additional CIL contribution, although this is not clear within the site appraisals. Bloor Homes recognises that S106 costs will be subject to change at the planning application stage.
Viability is dynamic and the Council’s evidence relates to a snapshot in time. Therefore, Bloor Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Support

Representation ID: 4473

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The 2022 SHMA identifies 30 applicants on the self-build register as of Spring 2022, recognising that 10 of these applicants are also on a register within another LPA. This demonstrates a very low level of demand. Bloor Homes considers Policy HC8 provides a justified and proportionate approach to meeting this specific need, which requires the consideration of the Council’s Self Build Register on major developments but falls short of requiring a specific percentage of provision.

Support

Representation ID: 4474

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance.
It should be noted that the proposal at Land East of Bilbrook has already been subject to significant discussion with stakeholders and further consultation will
be undertaken in line with the provisions of Policy MA1 in the preparation of a strategic masterplan.

Comment

Representation ID: 4475

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response: Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings (with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per
EVCP. This cost is below the Government’s cost estimate and excludes any costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4476

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes recognises the need for development to address unacceptable impact on health infrastructure. At present the policy is restricted to seeking a proportionate financial contribution where it is demonstrated that existing facilities do not have capacity to accommodate patients. Bloor Homes considers this policy should provide additional flexibility by recognising on-site provision of health infrastructure may represent a more
appropriate solution to meeting health needs.