Publication Plan November 2022

Support

Representation ID: 4910

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Gladman support Policy DS4 commitment to a 4,000-dwelling contribution towards unmet housing needs of neighbouring authorities. The Council’s approach to accommodate a meaningful proportion of unmet needs through this Plan is pragmatic, justified and necessary to address needs that exist now

Object

Representation ID: 4911

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman at present do not consider that a 13% buffer is sufficient to ensure the Local Plan Review remains robust over the plan period. It is noted that the future supply of housing in the district is heavily predicated on the successful delivery of the two large sustainable extensions allocated on the edge of the Black Country (SA2: Land at Cross Green and SA3: Land North of Linthouse Lane). Together, these sites are anticipated to deliver approximately 46% of housing growth from new allocations in the Plan. If these sites deliver at a slower rate than forecast there will be little prospect of the District’s housing needs being satisfied, even with the 13% cushion the Council is proposing to build in.

Gladman contend that the uplift in flexibility should be increased to 20%. Gladman consider this can be achieved, in the first instance, by maximising development at non-Green Belt locations. one such opportunity clearly exists at ‘Land at Weeping Cross (036c).

Object

Representation ID: 4912

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman broadly supports the spatial strategy to 2039 as detailed through Policy DS5 which recognises that growth adjacent to the southern edge of Stafford can facilitate sustainable growth at a non-Green Belt location.

However, Gladman query the decision of the Council to reduce the scale of growth at ‘Land at Weeping Cross’ from a minimum of 168 dwellings in the Preferred Options Plan to a minimum of 81 dwellings as detailed in the Publication Plan.This runs contrary to paragraph 141 of the NPPF which is explicit that all reasonable non-Green Belt options should be first considered for meeting identified needs for development.

‘Land at Weeping Cross’ represents one of the few opportunities to deliver development in a non-Green Belt location in the authority at a sustainable location on the existing edge of a main settlement. Thus, the potential for development here should be maximised,

Object

Representation ID: 4913

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman agree with the justification for the chosen area of search, as it is clearly the most sustainable location in the district for a strategic site of this scale (recognising the potential of the strategic road network and rail links to support new development in this area).

Gladman however consider that there is merit in expanding Policy DS6 further to consider a more focussed ‘broad location for growth’ to deliver the NPPF’s aspiration and make this policy effective.

Given the Council’s clear longer term growth aspiration and the current stage of plan-making, this approach would give greater certainty for the next plan period, without necessitating significant changes to the Plan. It would also give a developer the confidence and time to invest in the site to ensure that it can be delivered within the next local plan cycle.

Object

Representation ID: 4914

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Gladman consider Policy SA5(036c) as proposed in the Plan to be sound. That said, Gladman do not consider the decision to reduce the allocation boundary from 8ha in the preceding Preferred Options Plan (which proposed to allocate the site for a minimum of 168 dwellings) to 3.85ha in the Publication Plan (which allocates the site for a minimum of 81 dwellings) is entirely appropriate.

It is acknowledged that the site is located within the historic extent of Acton Hill Park, the heritage interest of which principally derives from it being the designed grounds to Acton Hill House, itself a non-designated heritage asset. Gladman question whether the interest of the historic park warrants this proposed level of mitigation and consider that a smaller set-back would be more proportionate.

The Site represents one of the few opportunities to deliver development in a non-Green Belt location in the authority and thus the potential for development here should be maximised, as to reduce the extent of Green Belt release required to meet the proposed housing requirement. Gladman contend that the new allocation boundary does not reflect the full, natural and logical extent of the available development site and suggest to make effective use of land, that the allocation for a minimum of 168 dwellings, as set out in the preceding Preferred Options Plan, is reinstated.

The Site can deliver a wide range of market and affordable homes as well as new open space and green infrastructure which could be provided in greater quantum with increased benefits for landscaping and net gains in biodiversity if a larger area within the site boundary is considered for allocation. The site is not at flood risk and access has been demonstrated as ok in principle.

Object

Representation ID: 4919

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The housing mix as identified in the Council’s latest evidence base will only provide a snapshot in time in relation to the current housing needs.The requirement for 70% of market housing to have 3 bedrooms or less should be removed as it is overly prescriptive. Furthermore, the policy should also refer to other evidence, not just the latest Housing Market Assessment, and should include consideration of elements such as the demand/need at the time of the application.

Object

Representation ID: 4920

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In order for the policy to be considered sound, further evidence is required to justify the approach taken in relation to the requirement for 100% of both the market and affordable housing to meet M4(2). If appropriate evidence cannot demonstrate a need for this level of M4(2) dwellings this policy requirement should be removed.

Object

Representation ID: 4921

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman broadly support the inclusion of Policy HC8 relating to self-build and custom-build housing in line with current government objectives. That said, Gladman do not consider that a blanket requirement for major developments to provide self and custom build plots is justified, and thus consider that element of the policy should be deleted as there may not be necessary demand in all locations.

Object

Representation ID: 4922

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Design should be considered at the most appropriate stage of the planning process, either through full applications or reserved matter stages. Without this being referenced in the policy, design matters may be the cause of unnecessary delay at outline stage.

As proposed the policy requires all developments to meet the eighteen listed criteria. Given the Council is allocating a range of different site sizes and types, it may not be possible for all forthcoming proposals to meet all the listed criteria. Therefore, the policy needs an additional layer of flexibility which recognises that good design measures will vary from site to site.

Object

Representation ID: 4924

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

If the Government had expected all properties to be built to NDSS then they would have made these standards mandatory not optional. Therefore, if the Council wishes to adopt this optional standard, it should be justified by meeting the criteria set out in the national policy, including need, viability and impact on affordability. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Gladman do not consider that the requirement for all dwellings to be built to at least NDSS has been robustly justified by the Council at this stage.