Publication Plan November 2022

Comment

Representation ID: 4501

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4502

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4503

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4504

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4505

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron 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.
Nevertheless, due to the size of the site at Wolverhampton Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of approximately 35dph. However, this would be achieved through the provision
of areas of varying density and reflective of the character of surrounding development.

Comment

Representation ID: 4506

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron 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 the 2021 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.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, Cameron 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.

Object

Representation ID: 4507

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The proposed policy requires a range of specialist housing to be delivered on site, both within market and affordable sectors. It is not clear whether this is a continuation of the Council’s current approach of requiring 10% of all homes to
be delivered as bungalows or other ground floor accommodation.
It is considered that a specific requirement for bungalows is not appropriate if instead the Council pursues a policy of requiring 100% of all homes to meet optional M4(2) requirements.
The Policy should be amended to require a maximum of 30% of all new homes to be delivered to meet the optional M4(2) standards, especially where this could be in addition to other homes for older people and others with special housing requirements required by Policy HC4.

Comment

Representation ID: 4508

Received: 22/12/2022

Respondent: Cameron Homes Ltd

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.
Cameron 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.

Comment

Representation ID: 4509

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron 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 Cameron Homes has entered into pre-application discussions to inform the emerging proposal for the proposed allocation at Land East of Wolverhampton Road.

Comment

Representation ID: 4510

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron 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.