Publication Plan November 2022

Comment

Representation ID: 4888

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the provision of accessible homes that are suitable to meet the needs of older people and others with special housing requirements. However, if the Council is to adopt the higher optional standards within the Building Regulations (Part M4(2) Category 2) for accessible and adaptable homes, it should only do so by applying the criteria set out in PPG.
The PPG identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability. The Council should provide localised
evidence making the specific case for South Staffordshire which justifies the inclusion of optional higher standards for accessible and adaptable homes in this policy. If the
Council can provide the appropriate evidence and this policy is to be included, then Bellway would support a transition period included within the policy, as appropriate.
The Council should also note that the Government proposes to mandate the current M4(2) requirement in Building Regulations as a minimum for all new homes, with M4(1) applying in exceptional circumstances. This will be subject to a further consultation on the technical details and will be implemented in due course through
the Building Regulations. M4(3) would continue to apply as now where there is a local planning policy is in place and where a need has been identified and evidenced.
There is a need for policy to be consistent with national standards unless a specific evidenced reason exists for a higher standard to be applied in South Staffordshire.

Comment

Representation ID: 4889

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The requirement to meet the Nationally Described Space Standard is considered reasonable. External space standards and amenity spaces should not be explicitly
stated within the policy. Whilst there are caveats contained within which state an allowance for flexibility “depending upon the site orientation and the individual merits of the development proposal”, planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to achieve suitable quality residential environments. It must be ensured that specific criteria do not result in ‘planning by numbers’ and an unintentional lack of flexibility in assessing future planning applications.

Comment

Representation ID: 4890

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Part (e) of the Policy references Appendix I of the Plan which sets out parking standards, in relation to electric vehicles. Bellway support the Council’s endeavours to
encourage electric vehicle uptake.
Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now taken effect and provides guidance on the installation and location of electric vehicle charge points (EVCPs). It states that a new residential building with associated parking must have access to EVCPs and that their total number must be equal to the number of parking spaces if there are fewer parking spaces than dwellings, or the equal
to the number of dwellings where there are more parking spaces. The Regulations also set technical requirements for the charging points these include having a nominal
output of 7kW and being fitted with a universal socket.
The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Comment

Representation ID: 4891

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The approach of this policy is welcomed, which provides flexibility in terms of the location of any open space – to respond to a site’s characteristics to ensure any
development maximises recreational use. This is a more appropriate approach than being specific about the potential location of open space, as had been previously
proposed by the preferred options consultation.

Comment

Representation ID: 4892

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The policy will require that all development proposals maximise on-site green infrastructure. The aim of the policy and for the maximisation of on-site green infrastructure is to enhance biodiversity, improve connectivity to existing habitats and enhance the quality of the area for the benefit of residents.
An enhancement in the provision of green infrastructure can be achieved on both sites with buffers to the Green Belt to the north and west.
Whilst the broad themes of the policy are understood and achievable, the policy is not clear on whether this requirement will be triggered where sites are also providing compensatory green infrastructure on sites which have been taken out of the Green Belt. There is uncertainty over whether green infrastructure requirements can be combined with the compensatory measures and be provided off site. This should be
clarified within the policy or supporting text. In this regard, there is a need for the policy wording to be revised to ensure that it is unambiguous (as required by NPPF paragraph 16) so that it is evident how a decision
maker should react to development proposals.

Comment

Representation ID: 4894

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The proposed policy approach represents repetition of the 2021 Part L Interim Uplift and the Future Homes Standard. It is the Government’s intention to set standards for energy efficiency through the Building Regulations. The higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and proposals for the 2025 Future Homes Standard negate any need for local energy efficiency standards to achieve the shared net zero goal because of the higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and
proposals for the 2025 Future Homes Standard.

The Optional Technical Housing Standard is 110 litres per day per person. The higher standard proposed within the draft policy has not been justified in accordance with the standard required by the NPPF. If the Council wishes to adopt the optional standard for water efficiency of 110 litres per person per day, it should justify doing so by applying the criteria set out in the PPG.
Given the above the policy does not serve a clear purpose. Whilst the policy will require the calculation of the whole life cycle carbon emissions and actions to reduce life cycle carbon emissions, it is not clear how determination will be made as to what is an appropriate level of emissions or reductions. There are also concerns in relation to the elements of the policy regarding performance and monitoring. It is not clear what
the Council would do with the information in relation to performance information or the monitoring information once the development is completed.
For the above reasons the policy is not considered to be justified and should be deleted.

Comment

Representation ID: 4895

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway will work to provide modern and future-proof infrastructure provision within sites to be delivered, including broadband connectivity. This reflects Bellway’s ambition to provide contemporary, attractive places to live which provide a high-level of connectivity.

Comment

Representation ID: 4896

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Comment

Representation ID: 4897

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Support

Representation ID: 4898

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the vision and strategic objectives set out. Strategic Objective 2 in particular references the need to meet the housing and employment needs of the District whilst making a proportionate contribution towards the unmet needs of the GBBCHMA.
The objectives for high quality housing to meet a wide range of needs and provide beautiful and sustainable places where people want to live are welcomed. The LPR notes the lack of brownfield development sites available within the District, and the requirement for a careful release of suitable Green Belt land to meet housing need.
The strategic objectives of the LPR are sound.