Publication Plan November 2022

Support

Representation ID: 5168

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support the principle of making a contribution to meeting needs of wider GBBCHMA.

Object

Representation ID: 5169

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is unclear how the Council have concluded that the flexibility allowance should be 13%, request clarification.

In relation to housing needs the council have allocated the minimum figure derived from the Standard Model. PPG identifies examples where additional growth beyond the minimum requirement may be appropriate. It is considered that there is scope to increase the District’s housing allocation to address the following matters:
-increase proportionately the contribution towards GBBCHMA shortfall given emerging evidence from the Black Country and Birmingham on the true extent of the shortfall. Commitment to contribution should be set out in a Joint Statement of Common Ground with other GBBCHMA authorities.
- to take account of impact of the 35% uplift applied to Birmingham and Wolverhampton
-improve affordability and choice and improve reliability of supply.
- Housing Market Assessment 2021 fails to consider the impact of the committed economic development at WMI in association with the increasing shortfall emerging across the GBBCHMA.
-updated HMA 2022 does not consider the impact of committed WMI and employment developments at i54 & ROF.

The Council should Identify safeguarded land to ensure that anticipated housing and development needs beyond 2039 are considered and to fully maximise the District’s capability to assist the GBBCHMA.

Support

Representation ID: 5170

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support the objective of developing a new settlement. The land North of the A5, Gailey is recommended. This site has a proposed minimum capacity of 1870 dwellings and can dovetail with the consented WMI utilising and contributing towards infrastructure improvements. Should the site not be required at the present time the land should be safeguarded for use beyond the plan period.

Object

Representation ID: 5171

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Requirement that 70% of properties should be 3 bed or less is restrictive and inflexible, contrary to NPPF para 62 requirement to provide a range of size, type and tenure. The use of the phrase ‘disproportionate’ in the penultimate paragraph lacks precision and clarity. Needs and demands will vary from site to site, requirements should be subject to a viability assessment thus allowing for flexibility.

Clarify the definition of ‘major’ development. This should reference the DMPO definition for the avoidance of doubt.

Support

Representation ID: 5172

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support the recognition that a blanket approach is unlikely to be effective.

Object

Representation ID: 5173

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Definition required of ‘major residential development’.

Policy needs to ensure that evidence is provided when considering viability particularly on brownfield sites.

Affordable housing policies should take account of viability and deliverability as well as need. A differentiated policy approach should be used as set out in the viability study.

If requirements for implementing policy are known now then these should be included within the plan, the SPD is not the appropriate document for setting new policy and or burdens on delivery. The Plan should provide clarity at the point of adoption as to what it requires.

Support

Representation ID: 5174

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Pepper pot approach to affordable housing generally supported but should recognise that for management purposes Registered Providers do require a degree of clustering.

Support the use of s106 agreements to secure necessary infrastructure and the removal of the suggestion re: grant funding for homes.

Object

Representation ID: 5175

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No definition of older people therefore unclear who the policy is targeting and who would be eligible. The council do not define what ages will be restricted to single storey development.

Specialist housing often needs minimum critical mass (e.g. critical care and retirement living often require 60+ rooms to be viable). Evidence therefore required to support minimum site size capable of supporting such provision. Need clarity on when such housing types will be required as part of a major development and what types may be required on any given site.

Requirement for all housing to be M4(2) compliant may cause affordability issues. This is not yet a statutory requirement and therefore needs to be justified with reference to both need and cost.

Object

Representation ID: 5176

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Clarify the requirement about having regard to the self build register that this applies only to part 1 of the register. Policy should also recognise that delivery of self build successfully occurs when there is a distinct phasing or grouping of plots.

Whilst supporting the principle of self build, this is best delivered on smaller more bespoke sites.

Support

Representation ID: 5177

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support the provision for developer to build a standard housing unit on any un-sold self-build plot after twelve months.