Publication Plan November 2022

Object

Representation ID: 5371

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS2 (Green Belt Compensatory Improvements) is a new policy included within the Publication Plan. The Policy provides additional detail on expected compensatory improvements for Green Belt released sites when compared to the Preferred Options Document. However, the policy still leaves elements of ambiguity.
The policy should be clarified by identifying and naming which particular sites it is specifically intended to apply to, or alternatively, the individual site allocation proformas should identify when it is expected this policy would apply. For the avoidance of doubt, Persimmon Homes interest at Cherry Brook, Penkridge, is safeguarded land which was removed from the Green Belt in 1996, and it is not expected to be subject to this policy.

Comment

Representation ID: 5372

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The recent collapse of the Black Country Plan process has led to further instability within the Black Country area regarding the delivery of unmet housing need. The pro-active approach taken to providing a contribution of homes as set out in Policy DS4 towards the GBBCHMA is welcomed along with providing approximately 13% additional homes to ensure plan flexibility.
The Council recognise at paragraph 5.10 that the two most significant sources of potential unmet needs are currently Birmingham City and the Black Country, with the adopted Birmingham Development Plan suggesting a significant unmet need is arising across the GBBCHMA, driven by limited housing in these urban areas.

Comment

Representation ID: 5373

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Policy DS5 sets out that SSDC will deliver a minimum of 9,089 dwellings, comprising 5,089 dwellings to meet South Staffordshire’s own housing need using the Government’s standard method across the 18-year plan period 2021-2038 and a further 4,000 dwellings to contribute towards the unmet needs of the GBBCHMA.
Persimmon Homes support the Council's strategy of as set out in Policy DS5 to distribute growth to sustainable locations. The policy defines a settlement hierarchy of five 'tiers', across which the housing target will be distributed. The identification of Penkridge as a Tier 1 settlement to accommodate 17.8% of the Council’s housing growth, and the recognition that the village has a greater level of services and facilities thus endorsing its sustainability credentials, is welcomed.

Comment

Representation ID: 5374

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Penkridge 005 - Residential – Land at Cherry Brook – Min 88 homes
It is recognised that Penkridge benefits from an excellent level of essential community services and access to a wide range of public transport and supporting infrastructure.
The Cherry Brook site is capable of early development in the first five years of the plan period and will complement the larger, strategic scale allocations within the Plan.
From the technical work previously undertaken which remains valid, it has been demonstrated that the site has both the capacity and qualities to be suitable for residential development. Persimmon Homes supports the principle of the proposed allocation of Land at Cherry Brook Drive for development and also the allocation of Penkridge as a Tier 1 settlement.

Object

Representation ID: 5375

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing mix should be guided by market signals as reflected in the most up-to-date assessment of needs. Such assessments will need to be updated over the course of the Plan period. The requirement that 70% of properties comprise of three-bedrooms or less is restrictive and does not afford the flexibility expected by NPPF ¶62 in order to meet the need to provide for a range of size, type, and tenure for different groups.
The use of the phrase ‘disproportionate’ in the penultimate paragraph, when describing the quantum of 4+ bedroom houses, lacks the precision and clarity needed for a Plan policy.
The policy should also comment that all is subject to viability assessment, thus allowing for flexibility in its application.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5376

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The use of the phrase ‘major residential development’ in this context requires a definition to save confusion as to what size of development affordable housing becomes a requirement, it is presumed to be the same as that within the NPPF Glossary. The policy also needs to ensure that evidence is provided when considering viability, especially when looking at brownfield sites.
The frequent reference to further guidance being provided by the Affordable Housing SPD is noted. The SPD should do no more than clarify the Local Plan policy, and it is suggested that if the requirements for implementing the policy are known to need explanation now, then these should either be included within the Plan now or set out within the explanatory text. The SPD is not the appropriate vehicle for setting new policy and or burdens on delivery which may not have been included in the Plan’s Viability Appraisal, and the Plan should provide clarity at the point of adoption as to what it requires.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5377

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It stipulates that all major development should provide bungalows, age restricted single storey accommodation, sheltered/retirement living and extra care housing.
needs a minimum critical mass to be viable (for example, extra care units typically require 60+ bedrooms to be viable). Taking the allocated site at Cherry Brook as an example, proposed for circa 88 homes, this is simply not at a size or scale which could support all these forms of specialist housing.
The policy needs to provide much greater clarity on when such housing will be required as part of a major development, and to make clear that some (possibly not all) housing types may be required on any given site.
It is further noted that since the preferred options consultation, the plan has moved from expecting 30% all homes to be Building Regulation M4(2) compliant, it now requires 100% of all housing to be M4(2) compliant. This brings with it significant additional issues of affordability, in a context where the access and affordability of housing is an area of wider concern. Whilst the principle of provision of a percentage of M4(2) accessible is agreed, it is not a requirement of the whole population to have such provision.
The Plan, therefore, is building in unnecessary cost and expense into the delivery of new housing, which ultimately will be paid for by the purchaser. It will be reflected in unnecessarily more expensive (ie less affordable) housing for all, and the necessity for the requirement is questioned. Moreover, the Council’s Viability Assessment work is underpinned by an assumption that only 30% of the Housing delivered is to M4(2) standard (Draft Stage 1 Report ¶27. This is an error in the viability baseline work, and must be revisited to ensure robustness in the Plan’s delivery assumptions.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5378

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The second paragraph of the policy should be clear that in having regard to the Council’s self-build register, it is only part 1 of the register which needs to be taken into account. The policy should also recognise, that delivery of self-build housing on new residential sites, successfully occurs when there is a distinct phasing or grouping of plots, secured for such delivery. On sites of limited scale, such as Cherry Brook, this is unlikely to be a feasible delivery option, especially where there is a much larger allocation opportunity at Penkridge, where such sub-division is more capable of delivery.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5379

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The provision of tree lined streets (item c) should be identified within policy as being subject to highway authority agreement, and where appropriate, their adoption.
Item l) regarding house types and tenures is a repetition of policy material discussed in Policies HC1 – Housing Mix and HC3 – Affordable Housing and is therefore unnecessary.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5380

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy requirement to comply with the implementation of the Nationally Described Space Standards (NDSS) is generally supported. However, some flexibility must be allowed in its application as occasionally a small minority of dwellings on larger sites may require non-compliance with NDSS for sound urban design reasons. This flexibility should be applied to limited exceptions that are thoroughly reasoned, the policy she be amended to reflect this.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.