Publication Plan November 2022

Object

Representation ID: 4699

Received: 22/12/2022

Respondent: Lovell Homes

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, Lovell 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: 4700

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Lovell 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. Lovell 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: 4701

Received: 22/12/2022

Respondent: Lovell Homes

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. Lovell Homes considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.

Object

Representation ID: 4702

Received: 22/12/2022

Respondent: Lovell Homes

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: 4703

Received: 22/12/2022

Respondent: Lovell Homes

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: 4704

Received: 22/12/2022

Respondent: Lovell Homes

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: 4705

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

This representation relates to Land at Pool House Road which is a proposed allocation for 223 dwellings. This is supported as ‘sound’ by Lovell Homes.
should be noted that highway and pedestrian connectivity between sites 459 and 285 may be difficult to achieve due to third party land ownership between these parcels and topographical constraints. Such connectivity can be provided to secure connection to existing routes to the south of Pool House Road which would facilitate connectivity between parcels and provide access to
services and facilities within the village.
In addition, Lovell Homes would question whether site 459 would be capable of delivering a minimum of 97 dwellings, as set out in the site proforma at Appendix C due to the presence of electricity pylons and associated
easements. A more realistic assumption would be in the region of 75 to 80 dwellings.

Comment

Representation ID: 4706

Received: 22/12/2022

Respondent: Lovell Homes

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. Lovell 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.

Comment

Representation ID: 4707

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

The Vision is clear and succinct, however as presently drafted it doesn’t appear locally relevant and contains no spatially specific elements.
Lovell Homes supports the strategic objectives identified. These are considered succinct, locally relevant and relate to the most important areas of change or protection within the District.

Comment

Representation ID: 4708

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Wombourne achieved one of the highest services/facilities rankings of all villages within the District despite it not benefiting from a railway station and Lovell Homes supports the identification of Wombourne as a Tier 2 settlement and a sustainable location for additional housing growth.
This strategy, which focuses growth to top tier settlements provides an opportunity to ensure that the necessary homes, along with supporting infrastructure, would be delivered in a timely and coordinated manner, to meet both the local needs arising from within the District.