Publication Plan November 2022

Object

Representation ID: 4659

Received: 22/12/2022

Respondent: Keon 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, Keon 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: 4660

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Keon 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. Keon 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: 4661

Received: 22/12/2022

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

Object

Representation ID: 4662

Received: 22/12/2022

Respondent: Keon 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: 4663

Received: 22/12/2022

Respondent: Keon 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.
See supporting representations for further details.

Object

Representation ID: 4664

Received: 22/12/2022

Respondent: Keon 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
See supporting representations for further details.

Comment

Representation ID: 4665

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Site 426a is sound, It should however be noted
that the site currently has the benefit of detailed planning consent for 21 dwellings and is currently under construction.
Site 426b is suitable, available and achievable and should be considered if omission sites are necessary to make the Local Plan sound.
Concern is raised that Site 426b appears to have been ruled out through the site selection process due to the site being in excess of 1ha. This should not be a determining factor in the site selection process for Tier 3 settlements such as Wheaton Aston. In addition, Site 426b is considered by Keon Homes to perform well and this is explored further in Chapter 12 to these representations.

Comment

Representation ID: 4666

Received: 22/12/2022

Respondent: Keon 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. Keon 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: 4667

Received: 22/12/2022

Respondent: Keon 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.
Keon 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: 4668

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes supports the proposed spatial strategy to 2039 which recognises environmental capacity and seeks to make best use of existing infrastructure whilst recognising opportunities to delivery new infrastructure.
The settlement hierarchy also recognises that the Tier 3 settlements also provide a sustainable location to accommodate growth, including Wheaton Aston which contains a wide range of services and facilities. Proportionate growth within the Tier 3 settlements would
assist in supporting existing and proposed services and facilities and deliver new and improved infrastructure in line with community aspirations.
Smaller sites in sustainable settlements such as Wheaton Aston, that can make best use of and improve existing infrastructure, would support growth in the early years of the plan period, prior to delivery on the identified strategic housing allocations given the inevitable delays in getting to the delivery stage of those sites.