Publication Plan November 2022

Comment

Representation ID: 5350

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Cameron Homes generally supports the proposed spatial strategy which builds on the District’s existing infrastructure and environmental capacity whilst recognising opportunities to deliver new infrastructure.
The identification of Coven as a Tier 3 settlement where growth will come forward through appropriate allocation is generally supported. Land between A449 Stafford Road & School Lane (site reference: 082) is identified as an allocation and acknowledged to deliver the
Council’s preferred strategy. This is supported and the allocation clearly accords with the spatial strategy as set out in this policy.

Comment

Representation ID: 5351

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy DS6 sets out an aspiration for SSDC to deliver a new settlement beyond the plan period. It is noted that such an option would not contribute to housing growth during the
proposed plan period to 2039 which is agreed.

Comment

Representation ID: 5352

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Land between A449 Stafford Road & School Lane (site
reference: 082)

This representation relates to Land between A449 Stafford Road & School Lane (site reference: 082) which is a proposed allocation for a minimum of 48 dwellings. This is supported as ‘sound’ by Cameron Homes. The site is also dealt with in the site proforma in Appendix C. This is discussed in greater detail at Section Five of this representation. It should be noted that the site was previously designated as safeguarded land in the adopted Site Allocations Document to deliver residential development. This Plan was fully examined and
found sound. There is nothing that has materially changed to affect this conclusion and the
identification of previously safeguarded land as full allocation represents continuity and good planning practice.

Object

Representation ID: 5353

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Housing mix should be guided by market signals as reflected in the most up to date assessment needs. Such assessments will need to be updated over the course of the plan period and as such this policy requires flexibility.
The requirement that 70% of properties comprise of 3 bedrooms or less is restrictive and does not afford the flexibility expected by NPPF paragraph 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 requires clarification.

Comment

Representation ID: 5354

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Cameron Homes supports the the addition to the policy (set out below) which recognises that a blanket approach to density is unlikely to be effective stating:
'Where it would help to support the delivery of local services and facilities, sites will be encouraged to exceed this minimum density standard where this could be done in a manner consistent with other development plan policies, particularly those relevant to the character
of the surrounding area.
The net density on a site may go below the minimum density standard set above if to do otherwise would result in significant adverse impacts to the surrounding area’s historic environment, settlement pattern or landscape character.’
Cameron Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance and supports the flexibility to allow sites to be considered on a case by- case basis.

Comment

Representation ID: 5355

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy HC3 requires proposal for major residential development to provide 30% of all dwellings as affordable housing. The use of the term '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 requirement for 30% affordable housing appears to be supported by the Viability Study Stage 2 Report 2022 (VA) which confirms at paragraph 3.2.7 that the proposed affordable housing figure can be appropriate for South Staffordshire, but it does highlight the challenges
in delivering such a requirement and the need for higher site values to be achieved to deliver this across the board. Viability is dynamic and can change across the plan period therefore Cameron Homes support the inclusion of a mechanism in Policy HC3 to submit a viability assessment at application stage if it is demonstrated that circumstances have changed.
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 approach for setting new policy and or burdens on delivery, and the Plan should provide clarity at the point of adoption as to what it requires.

Object

Representation ID: 5356

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HC4 notes major development should:
‘…clearly contributes to meeting the needs of older and disabled people.’
The above policy wording does not define 'older people', so it is unclear as to exactly who this Policy is targeting or who would be eligible to occupy such dwellings. It stipulates that all major development should provide bungalows, age restricted single storey accommodation,
sheltered/retirement living and extra care housing. The Council do not define what ages will be restricted for single storey development and as such, the policy requires clarification on this matter.
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. It is also clear that if 100% M4(2) dwellings is being pursued then the requirement for bungalows is not appropriate.
Questions viability of the policy.
Furthermore, the HMA identifies a need for 1,793 accessible and adaptable general homes for those over 65 years and 1,235 for those under 65 years, across the Plan Period. This equates to less than 30% of the overall housing requirement to be delivered by this Plan. The updated SHMA 2022 at paragraph 8.14 concludes that it is calculated that adapted housing M4(2) will be required for 3,978 households by 2040 in South Staffordshire. It is therefore not clear how the 100% requirement within the Policy has been arrived at or how this is justified.
At the present time, the requirement for M4(2) dwellings is not mandatory and if the Council wish to pursue a policy requirement of 100% M4(2) dwellings then this needs to be justified, with reference to both need and cost. The policy as currently drafted is not justified and
therefore not sound and should be amended to address this.

Comment

Representation ID: 5357

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy HC8 requires sites for major residential development to "… have regard to the need on the council's self-build register and make provision of self and custom build plots to reflect this". 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 considered.
In general this policy provides a suitable approach to self-build and custom housing, requiring the consideration of the Council’s self-build register (subject to above clarification) but does not require a specific percentage of provision. This element is supported.

Comment

Representation ID: 5358

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

The introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance is generally supported.

Object

Representation ID: 5359

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The continuity of existing external space and dwellings standards is generally supported although there should be a recognition that certain house types, for example Part M4(2) dwellings, should have smaller, more manageable gardens.Cameron Homes do however object to the internal floorspace policy requirement for all
homes to meet the Nationally Described Space Standards (NDSS). In order to pursue the NDSS requirement, the Council need to provide additional evidence for the Local Plan Examination to demonstrate that the policy is sound. National Planning Guidance Housing: optional technical standards (paragraph 020) clearly states this.
It is clear that the introduction of the NDSS requires a Local Plan policy which has been fully evidenced, justified and viability tested. The South Staffordshire Housing Market Assessment Update 2022 (HMA) refers to the NDSS (paragraph 7.32) only in the context of assessing the need for accessible and adaptable homes. The HMA does not provide any justification or evidence for requiring NDSS in the District.