Publication Plan November 2022

Comment

Representation ID: 4544

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The intention of Policy NB2 is recognised, however, the Government policy and guidance does not yet require 10% biodiversity net gain. Any policy should require a net gain in line with latest Government legislation, policy or guidance.

Comment

Representation ID: 4545

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes further evidence in respect of Cannock Chase SAC, including a review of mitigation measures and visitor survey. This evidence has informed the current mitigation measures as Policy NB3 to address any impact arising from development within a 15km radius of Cannock Chase SAC.

Cameron Homes recognises that Land adjoining Saredon Road is within a 15km Zone of Influence of Cannock Chase SAC.

Object

Representation ID: 4546

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At present the SHMA assumes that the projected growth of the working age population in South Staffordshire will grow by 6,618 people between 2020-2040. Whilst this is in excess of the forecast jobs growth outlined in the EDNA, Cameron Homes is concerned that the EDNA fails to realistically consider additional jobs created at WMI. Further consideration should therefore be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth, even taking into consideration the 4,000 additional homes to meet unmet needs in the wider housing market area.

Object

Representation ID: 4547

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Cameron Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Cameron Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District.

Object

Representation ID: 4548

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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 Government has consulted on raising accessibility standards for new homes but the requirement for all homes to meet M4(2) standards is yet to be mandated. If the Council intends to pursue a policy in respect of M4(2) standards this must be evidenced. Cameron Homes considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.

Object

Representation ID: 4549

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Object

Representation ID: 4550

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.

Object

Representation ID: 4551

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A locally specific CO2 reduction requirement is unnecessary and without justification for deviation from Government emerging Future Homes standards to be considered through building regulations

Support

Representation ID: 4552

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

This representation relates to Land at Landywood Lane which is a proposed allocation for 155 dwellings. This is supported as ‘sound’ by Cameron Homes.
However, it appears unnecessary to include the existing SAD allocation for Landywood Lane within the proposed allocation on the basis it has the benefit of full planning permission for 50 dwellings. This seems inconsistent with the approach taken on other sites within the Publication Local Plan.
Cameron Homes considers that the identified yield of 155 dwellings underestimates the likely capacity of the site, having regard to the proposed policies in respect of housing density and mix. It is however recognised that the yield is expressed as a minimum requirement. The Sketch Layout attached at Appendix 1 demonstrates a scheme of approximately 177 dwellings can be
delivered including the 50 dwellings with the benefit of planning permission.
Further comments in respect of the proposed housing allocations contained within Policy SA5 are set out in other representations submitted on behalf of Cameron Homes.

Comment

Representation ID: 4553

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Cameron Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.