Publication Plan November 2022

Comment

Representation ID: 4876

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Whilst we have no in principle concern with draft policy DS1, the LPR should be drafted as though it is being read once the plan is adopted. The fifth paragraph may therefore
need amendment to reflect that the Green Belt boundaries have already been altered, rather than ‘will be’.

We would recommend the following modification at draft policy DS1 paragraph 5 to reflect this:
“The Green Belt boundary will be has been altered through this Plan to accommodate development allocations set out in Policies SA1, SA2, SA3, SA5 and SA7”…

Comment

Representation ID: 4877

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

NPPF paragraph 142 states that the removal of land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. Planning practice guidance clarifies that this could include
new or enhanced green infrastructure, woodland planting, landscape and visual enhancements, improvements to biodiversity and habitats, new or enhanced walking
and cycling routes, and improved access to new or existing recreational and playing field provision.

Policy DS2 reflects this approach and provides sufficient flexibility to agree a contribution if no specific scheme can be identified.

Bellway intend to engage with Kinver Parish Council to agree a suitable compensatory scheme for the land identified as part of the Hyde Lane (west) proposed allocation.

Comment

Representation ID: 4878

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Given the significant remaining shortfall arising in the GBBCHMA and South Staffordshire’s clear functional relationship with the wider HMA (demonstrated by its
travel to work patterns, and transport links with Birmingham and the Black Country), Bellway are therefore supportive of the plan’s proposed contribution to the GBBCHMA’s unmet need. The scale of the contribution and the Council’s approach is justified by the Greater Birmingham and Black Country Strategic Growth Study (February 2018).

Nearly all of South Staffordshire’s villages are surrounded by Green Belt, therefore it is inevitable that the District will need to release Green Belt to meet its needs and those
of the wider GBBCHMA. As such exceptional circumstances have been clearly demonstrated to alter Green Belt boundaries through the draft plan, in accordance with NPPF paragraph 140.

The ongoing work with neighbouring authorities to agree the contribution to the shortfall is well evidenced, as such the Council has satisfied the duty to cooperate.

The approach to making a contribution to the wider GBBCHMA unmet needs is therefore positively prepared, based on effective joint working, and is consistent with
national policy.

Comment

Representation ID: 4879

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Kinver is identified as a ‘Tier 2 Settlement’ within the policy. The village benefits from several bus services providing routes to Kidderminster, Stourbridge, Hagley,
Wolverhampton and some local routes. These settlements also include a number of train stations providing regional, as well as national connections. Stourbridge Junction station is the nearest, located approximately 7km to the east of Kinver. This station
provides direct and regular rail services to Birmingham, Kidderminster, Solihull and London.

As such, there are options available to reduce car use for residents. The village also benefits from a range of local facilities, for instance, a infants, primary and secondary
school, public houses and restaurants, shops and services, including a GP and dental surgery, further limiting the need for residents to travel for their day to day needs. On this basis, Kinver is considered to be a highly sustainable and accessible ‘Tier 2 Village’.

Bellway do however have some concerns regarding the spatial strategy’s reliance on land at Cross Green, which we comment on in response to draft policy SA2. There are also concerns regarding the locations of where growth in Kinver is proposed, which we comment on in response to draft policy SA5.

Object

Representation ID: 4880

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We have no objection in principle to the proposed allocation at Cross Green, however we have some concerns regarding the scale of delivery anticipated for the proposed plan period given infrastructure delivery.

Firstly, there are concerns regarding the access road to ROF Featherstone and the associate costs and the potential impacts on Cross Green’s viability and delivery
trajectory. The IDP now estimates the cost of delivering the access road at £14.4m-£19m, to be funded via Staffordshire County Council and developer contributions. Evidence should be provided as to how this will be funded. The only funding evidence to date is reference to £1.5m of Growth Deal funding being made available via the Stoke-on-Trent and Staffordshire Local Enterprise Partnership.

Secondly, mindful of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the site’s proposed quantum of housing growth
(1,200 new homes).

The Lichfields Start to finish report shows that the lead in times and delivery rate are ambitious.

In total, it is therefore assumed that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore consider preparing further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,200 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District (such as additional land available at the land off Hyde Lane (west) and Dunsley Drive, both at Kinver).

If the delivery rates cannot be evidenced than the following modification to draft policy SA2 at part a) will be necessary: “a) A minimum of 1,000 homes”

Comment

Representation ID: 4881

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Hyde Lane (west) (Housing Allocation 576)

We continue to support the principle of the proposed release of land at Hyde Lane (west) from the Green Belt and allocation for housing growth. The Council’s evidence base is clear it performs better than other options at Kinver.
The southern and western edges of Kinver are significantly constrained by the Canal Conservation Area; Kinver Hillfort scheduled ancient monument and the Rock houses, as well as Flood Zones 2 and 3. Land to the north west is constrained by highway capacity and access. In this context, land west of Hyde Lane (as well as land to the east of Dunsley Drive) represents a sustainable location for accommodating future growth
in Kinver village.
The increase in the minimum housing allocation to 44 homes and the associated amended allocation boundary is welcomed, it reflects Option 3 of the Vision Document.
Bellway also support the provision of green infrastructure to the east, which will allow the provision of new open space, biodiversity enhancements and Green Belt
compensatory improvements.

Comment

Representation ID: 4884

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land south of White Hill (Housing Allocation 274)

Bellway has concerns regarding the likely impacts of developing this site.
As demonstrated by the EDP Heritage and Landscape Technical Note enclosed at Appendix 2, in terms of heritage impact, although the site’s ‘less than substantial
harm’ to the Kinver Camp Scheduled Monument is not an in-principle issue, NPPF paragraph 199 requires the Council to afford the ‘greatest weight’ to the conservation
of the monument as a designated heritage asset of the highest significance. NPPF paragraph 200 states that ‘clear and convincing’ justification should be provided for
that harm, public benefits notwithstanding. There are other sites available in Kinver such as the additional land to the north of the Hyde Lane proposed allocation or the
de-allocated Dunsley Drive site which do not result in this level of harm and should therefore be preferable in the site selection process.
In landscape terms, EDP’s note states that to accord with the local planning authority's evidence base and the prevailing landscape and visual character of the site, the extent of residential development currently illustrated is deemed to be unacceptable. It is considered to represent an over-estimation of the site’s development capacity in
landscape and visual terms. The design response to the Staffordshire Way would result in a major permanent and irreversible adverse effect, a point reiterated in Kinver Parish Council’s minutes of the meeting held on 14 December 2022. The Council should therefore carefully consider alternative sites at Kinver such as Bellway’s additional land at Hyde Lane (west) discussed above and land east of Dunsley Drive discussed below which could come forward and deliver the same public benefits
(in terms of delivering much needed housing) with less harm to designated heritage assets and which will provide a better landscape and visual response.

Comment

Representation ID: 4885

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land east of Dunsley Drive (Omitted site)

Land east of Dunsley Drive was initially included proposed to be removed from the Green Belt and allocated for development up to an including the Preferred Options stage of the Local Plan Review, as housing site allocation 272 (Figure 2).
The allocation was for a minimum of 22 dwellings on a site featuring good access and a natural extension to Kinver. The 2021 Housing Site Selection Topic Paper stated that, unlike some of the other potential Green Belt sites around Kinver, the Dunsley Drive site is free from ’significant constraints’ (e.g. Highways Authority concerns, potentially significant impact upon the historic environment). Paragraph 5.7.8 noted that the site is of a similar landscape sensitivity to most other land around the village but is of lesser Green Belt harm than other sites in this area.
The HESA states that development on the site would not in itself compromise the cultural heritage value of the overall Conservation Area to the extent that the values
that led to its designation would be diminished. The Assessment contends however, that it would inevitably compromise the setting of the small character zone within the Conservation Area that is defined by Dunsley House and its hilltop position, as well asthe setting of the non-designated asset itself. The HESA states that mitigation is unlikely to be possible and therefore a high (red) impact is predicted.
The site does adjoin the Conservation Area in the far east (where it extends to include Dunsley House – a ‘positive’ building within the Conservation Area). The site does form part of Dunsley House’s setting, however in the context of the Conservation Area as a whole, its contribution to Dunsley House’s significance (the Conservation Area’s special interest) is likely to be very small and so the ‘harm’ arising from its development would also be ‘very small’. In terms of the NPPF this harm would, at worst, be less than substantial harm towards the lowest end of that broad spectrum.
The evidence base enclosed with these representations also demonstrates the site is not subject to any constraints which cannot be overcome. As such the evidence base does not justify the omission of land east of Dunsley Drive as a proposed allocation.
Policy SA5 should therefore be modified to reduce the capacity of land south of White Hill or delete it completely, to reflect its constraints (in particular heritage) and the additional land north of the proposed Hyde Lane allocation and / or the omitted Dunsley Drive site should be added into the policy for a minimum capacity of around 40 homes each.

Comment

Representation ID: 4886

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the core principle of these policies, to create ‘mixed, sustainable and inclusive communities’. However, the prescriptive minimum housing requirements
may risk providing the wrong type of housing for Kinver residents and potentially impact on development viability and delivery.
As such, the policy should be reconsidered to ensure it accords with paragraph 82 of the NPPF and the need for policies to “be flexible enough to accommodate needs not
anticipated in the plan” and to “enable a rapid response to changes in economic circumstances.”
The policy should take a more flexible approach on housing mix to ensure it is
consistent with NPPF paragraph 82’s need for policies to “be flexible enough to
accommodate needs not anticipated in the plan” and to “enable a rapid response to
changes in economic circumstances.” It also needs to recognise that housing needs vary within different areas and on a site-by-site basis. The policy must ensure that the viability of development proposals is protected whilst providing an appropriate housing mix for the site location and local market. In addition to evidence such as the latest Housing Market Assessment, it would be appropriate for the Council to refer to other evidence including current demand. We would recommend the following modifications to the third paragraph of policy HC1 to ensure it is consistent with NPPF paragraph 82:
“On major development housing sites (excluding sites exclusively provided for self-build or custom housebuilding), the market housing should include a minimum of 70%of properties with 3 bedrooms or less, with the specific mix breakdown to be determined on a site-by-site basis and reflective of need identified in the council’s latest Housing Market Assessment, unless evidence is submitted to demonstrate otherwise”.

Comment

Representation ID: 4887

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The latest Housing Market Assessment Update (2022) identifies a net affordable housing need of between 67 dpa and 156 dpa, dependent on the proportion of
household income used spent on housing costs. The Viability Study (2022) clearly highlights the challenges in delivering the 30% affordable housing requirement, and highlights that without higher sales values the sites would not necessarily be viable. As such, affordable housing policy should take full account of all evidence in terms of both affordable housing need and viability, and ensure that sufficient flexibility remains.
PPG states that a minimum of 25% of all affordable housing units secured through developer contributions should be First Homes. The NPPF states that planning policies should expect at least 10% of the total number of homes to be available for affordable home ownership. The proposed policy is consistent with these requirements.
However, in relation to affordable housing tenure, existing Core Strategy policy H2 states that the precise proportion of affordable housing tenure split will be agreed with
the Council “having regard to local housing needs within the locality of the development, exceptional circumstances and the effects on the viability of a scheme.”
The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach.
Impact on scheme viability is referenced in the existing policy H2, and there should also be an allowance for a consideration of site viability, including whether there is a need for new infrastructure etc. which could impact on delivery of the allocated sites. The proposed tenure split for affordable housing is broadly in line with the need evidenced in the Housing Market Assessment Update 2022. However, this may change over time and location-specific flexibility should be provided.