Publication Plan November 2022

Object

Representation ID: 5009

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey is concerned that Policy HC1 as it is drafted is unsound.

In summary, whilst Taylor Wimpey would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically derived District-wide housing mix. Indeed, the Housing Market Assessment is clear that the “profile set out is a guide to the overall mix of accommodation required in South Staffordshire although it is acknowledged that the Council may wish to divert away from this profile in particular instances” (Para 8.12). A degree of flexibility is encouraged by Taylor Wimpey.

Taylor Wimpey therefore recommends that Policy HC1 be amended to allow for housing mixes to be justified based upon up-to-date market evidence of housing need and demand at the point of decision making. This would ensure that the PP is sound and compliant with paragraphs 62 and 82d of the NPPF.

Object

Representation ID: 5010

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey fully supports emerging policies seeking to tackle climate change with proactive sustainable measures. However, policies must be sufficiently flexible and fit for purpose and factor in the viability appraisal of proposed planning policies.

Until Future Home Standard and the supporting SAP software finalised (Government due to consult 2023) the industry will be unable to confirm it building specification and carbon reduction over Building Regulations 2013 or 2021 when this policy is targeted for adoption or Future Homes Standard becomes legislation in 2025. Therefore the proposed policy should be flexible to allow developers to utilise the most appropriate technology available at that time.
The costs of introducing proposed policy requirements must be included within the Plan viability assessment and viability assessment of strategic sites. This should include the cost of utility network upgrades to support proposed technologies.
The Council’s proposed strategy aims to seek carbon reduction standards above those introduced by the Government in June 2022. Taylor Wimpey does not accept the proposed direction of travel within draft Policy NB6 as there is no evidence to support the departure from the latest changes to the building regulations (Part L).
Taylor Wimpey, where possible, practical and viable, support the use of onsite renewable energy generation and/or connection to near site renewable low carbon energy networks. However, Taylor Wimpey considers that the words ‘possible, practical & viable’ would need to be included within the proposed policy wording.
Importantly, Taylor Wimpey considers that this is far beyond what is being planned in the regulations and will be an unknown on every site and will come at a risk.
Taylor Wimpey recognises the importance of reducing embodied carbon within the development process. However, embodied carbon emissions are unregulated in the UK. Current policy and regulation focus solely on operational energy use, as distinct from embodied carbon. There currently does not exist a nationally approved regulator or national recognised standard, national planning policy or building regulation requirement to assess and report embodied carbon emissions or whole life cycle carbon assessments.
Taylor Wimpey supports responding to climate change and reducing carbon emissions. However, the proposed draft Policy NB6 is ambiguous and ineffective without the supportive national guidance, regulation, regulator and agree monitoring approach and does not have the flexibility to respond to an unknown future government regulation or viability.
Taylor Wimpey therefore considers that this policy is unsound and does not comply with national planning policy and legislation.
Overall, the proposed draft Policy NB6 is ambiguous and ineffective without the supportive national guidance, regulation, regulator and agree monitoring approach and does not have the flexibility to respond to an unknown future government regulation or viability.

Comment

Representation ID: 5011

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

The Council’s settlement hierarchy, as presented within the PP, identifies Wombourne as a tier 2 settlement and is recognised as having a wider range of services and facilities when compared to the other smaller settlements in the district’s rural area. And thus, the PP supports the sustainable growth of the tier 2 settlements through appropriate allocations made within the Local Plan. To this end, draft Policy SA5 (Housing Allocations) allocates Land at Pool House Road, Wombourne for 82 dwellings (site reference: 285).
In this context, Taylor Wimpey is highly supportive of the Council's decision to allocate Site 285 within land at Pool House Road within the PP.
Taylor Wimpey would also note that the Site is located in the highly sustainable settlement of Wombourne. Wombourne is ranked second in the proposed settlement hierarchy and is the largest of the settlements that have been designated within Tier 2.
The Site will therefore make a valuable contribution to meeting the housing needs of the District and its neighbouring local authorities. It represents the opportunity to help worsening affordability pressures in Wombourne, promotes sustainable patterns of
development, and capitalise on a settlement which is well-placed to accommodate growth. In this instance, Taylor Wimpey therefore strongly supports the Council's decision to allocate the Site and the overall soundness of the PP.

Object

Representation ID: 5012

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Land at Pool House Road (site reference 285) is included within SA5 as a draft allocation and is proposed to be delivered throughout the upcoming Plan period in order to help meet the District’s housing target. Draft Policy SA5 implies that the additional housing allocations at Wombourne will deliver a minimum of 223 dwellings up until 2039. Taylor Wimpey considers this to be a sound strategy as Wombourne is identified as a tier 2
settlement within the PP and is assessed as being a sustainable location capable of accommodating further growth within the upcoming Plan period. The detailed representations submitted have raised key matters relating to the soundness and legal compliance of the PP in relation to the proposed allocation at Land at Pool House Road. It is essential that we are able to appear at the Examination to put forward evidence on
the delivery of the site to its most effective degree and respond to any matters raised and clarifications required by the Inspector.
In addition to the above, it should be noted by the Council that the entirety of the land between site 285 and site 459 is third party land, and thus presents a constraint in terms of achieving connectivity between the two sites. Taylor Wimpey acknowledges that the PROW runs from north to south between the two sites but believes that it does not cover the whole width of the land between site 285 and site 459. However, Therefore, it is not legally possible to provide a pedestrian link between site 285 and site 459, across the existing PROW. Taylor Wimpey is only capable of providing a pedestrian link from site 285 to the
western edge of the PROW.
Taylor Wimpey therefore requests that the site proforma be amended to remove reference to vehicular connectivity and revise the wording in relation to pedestrian connectivity between site 285 and site 459. This would ensure that the draft Policy SA5 is legally compliant in accordance with national planning policy, specifically NPPF paragraphs 16 and 100.
Taylor Wimpey requests that the policy, with specific reference to the site proforma, be amended to acknowledge the above and accept that if a pedestrian link between site 285 and site 459 is to be achieved, it must be via Pool House Road and not over the PROW. This would ensure a robust policy that is legally compliant with the NPPF and PPG.

Object

Representation ID: 5013

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In summary, whilst Taylor Wimpey would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically derived District-wide housing mix. Indeed, the Housing Market Assessment is clear that the “profile set out is a guide to the overall mix of accommodation required in South Staffordshire although it is acknowledged that the Council may wish to divert away from this profile in particular instances” (Para 8.12). A degree of flexibility is encouraged by Taylor Wimpey
Taylor Wimpey therefore recommends that Policy HC1 be amended to allow for housing mixes to be justified based upon up-to-date market evidence of housing need and demand at the point of decision making. This would ensure that the PP is sound and compliant with paragraphs 62 and 82d of the NPPF.

Object

Representation ID: 5014

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In summary, Taylor Wimpey recommends that the draft Policy HC4 is amended so that the need for each housing type is reflected within the policy and that the on-site provision is determined on a site-by-site basis. This would better address the demographic differences between local areas opposed to implementing a District-wide requirement. Additionally, the Policy should be amended so that the requirement for new homes to meet the M4(2) accessibility standards is reduced to reflect the actual need. Taylor Wimpey notes that the specific needs of each of the housing types listed within draft Policy HC4 is not reflected within draft Policy HC4. And thus, is not clear how individual developments are expected to contribute towards the needs of older people, as well as groups with specific requirements.
In order to comply with NPPF paragraph 62, Taylor Wimpey recommends that the draft Policy HC4 is amended so that the need for each housing type is reflected within the policy and that the on-site provision is determined on a site-by-site basis.
Additionally, the Policy should be amended so that the requirement for new homes to meet the M4(2) accessibility standards is reduced to reflect the actual need opposed to 100% of dwellings which is considered to be unjustified.

Object

Representation ID: 5015

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey supports, in principle, the direction of travel for draft Policy HC12 (Space about dwellings and internal space standards), particularly given that it is fairly consistent with the space standards set out in Appendix 6 of the adopted Core Strategy (2012).
However, whilst similar space standards are already adopted, Taylor Wimpey considers that it is important to acknowledge Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” As set out under paragraph 31, all policies should be “underpinned by relevant and up-to-date evidence”, and “should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned.”
In addition, the PPG4 sets out:
“Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of [need, viability and timing”
On the basis of the above, Taylor Wimpey would advise the Council that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. This would be essential evidence to underpinning the Council’s proposed policy approach and will be necessary to ensure the policy can be found sound.
In order to ensure a sound a robust policy, Taylor Wimpey recommends that the Council should provide a local assessment evidencing the case for the District in accordance with NPPF paragraph 31.

Object

Representation ID: 5016

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey recommends that the Council acknowledges the diversity of different charging speeds depending on the type of vehicle and charging location. At present, there are many different types of EVCP infrastructure depending on the manufacture of the EV. As such, one EVCP may not suit the EV demands of all future residents. This reflects the fact that the EV market is still at a relatively early stage but is becoming increasingly diverse. Moreover, one disadvantage of installing EVCPs across an entire development is that there is a significant level of uncertainty over how much infrastructure will be required by when.
In consideration, Taylor Wimpey considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is put in place. This would allow for the proportional expansion of the charging network in the future as demand grows, with minimal disruption and additional cost for excavation and labour. This would allow residents to easily install the necessary EVCP required to meet their needs as when this is required; a process that does not require planning permission and can be done through Permitted Development Rights (Part 2 Class D & E). Such modified wording would ensure the Policy is justified as per NPPF paragraph 35(b), and “aspirational but deliverable” as per NPPF paragraph 16(b).Taylor Wimpey considers that it would be more appropriate for developments to make provision for appropriate cabling/infrastructure rather than installation of EVCP themselves. This is because this allows future residents to ensure vehicle specific EVCP are installed at the relevant time they take occupation of the house. Fundamentally, it ensures a consistent approach to future-proofing the housing stock and allows the policy to be more flexible as demand and technologies change and improve over time.
It has been acknowledged that the cost of EVCPs has been included within the Council’s Viability Assessment which includes an allowance of £500 per dwelling for an EVCP. However, neither the Viability Assessment nor its Appendix 1 justify this cost. Taylor Wimpey notes that the Government’s estimated cost for the installation of EVCPs is £976 per car parking space for an average home

Object

Representation ID: 5017

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey welcomes the proposed policy to reduce carbon emissions on proposed developments. However, Until Future Home Standard and the supporting SAP software finalised (Government due to consult 2023) the industry will be unable to confirm it building specification and carbon reduction over Building Regulations 2013 or 2021 when this policy is targeted for adoption or Future Homes Standard becomes legislation in 2025. Therefore the proposed policy should be flexible to allow developers to utilise the most appropriate technology available at that time. The Government’s approach “remains technology-neutral and designers will retain the flexibility they need to use the materials and technologies that suit the circumstances of a site and their business”. (MHCLG Summary Response to the FHS (2019 Consultation Changes to Part L and F).
Reference should be made to those matters that are yet to be finalised by Government. The Government’s proposals set out in both part 1 of its Future Home Standards Consultation and the 10 points for a green industrial revolution have set a target for homes to be ‘zero carbon ready’ from 2025 rather than necessarily achieving ‘zero carbon’ from 2025.
The costs of introducing proposed policy requirements must be included within the Plan viability assessment and viability assessment of strategic sites. This should include the cost of utility network upgrades to support proposed technologies. Where a viability assessment is submitted to accompany a planning application, this should be based upon and refer back to the viability assessment that informed the plan, with evidence of what has changed since then.
Following a review of the 2022 Sustainable Construction and Renewable Energy Study (SCRE) submitted in support of the PP, Taylor Wimpey considers that the 63% reduction in carbon emissions against the 2022 Building Regulations Part L is not justified. The SCRE only refers to legal acts such as the Energy Act 2008 when justifying departure from the 2022 building regulations (Part L) but does not provide supporting evidence to deem this direction of travel as being necessary. As draft Policy NB6 has not been justified by sufficient evidence, Taylor Wimpey considers that this policy is not legally compliant with national policy. The District’s departure from the national standards could have damaging impacts on the market without the support of evidence, and should therefore aim to achieve a nationally shared net zero goal. Taylor Wimpey recognises the importance of reducing embodied carbon within the development process. However, embodied carbon emissions are unregulated in the UK. Current policy and regulation focus solely on operational energy use, as distinct from embodied carbon. There currently does not exist a nationally approved regulator or national recognised standard, national planning policy or building regulation requirement to assess and report embodied carbon emissions or whole life cycle carbon assessments.
Taylor Wimpey supports responding to climate change and reducing carbon emissions. However, the proposed draft Policy NB6 is ambiguous and ineffective without the supportive national guidance, regulation, regulator and agree monitoring approach and does not have the flexibility to respond to an unknown future government regulation or viability.

Object

Representation ID: 5272

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The vision should be reworded to include South Staffordshire’s declared climate emergency.