Publication Plan November 2022

Comment

Representation ID: 4925

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 Wombourne 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: 4926

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.

Comment

Representation ID: 4927

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: 4928

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: 4929

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: 4930

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: 4932

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.

Comment

Representation ID: 4933

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 Building Regulations require all new
dwellings to achieve a mandatory level of water efficiency of 125 litres per day per person, which is a higher standard than that achieved by much of the existing housing stock. This mandatory standard represents an effective demand management measure. 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: 4934

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: 4935

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Omission site: Land west of Strathmore Crescent, Wombourne

Bellway controls additional land beyond Orton Lane at Wombourne, to the west of Strathmore Crescent (Site Ref: 708), it adjoins the western boundary of the Orton Lane site (Site Ref: 416). The site has the potential to deliver and additional 40-50 homes, forming an extension of the proposed allocation off Orton Lane. The site would be accessed via the proposed Orton Lane allocation and could offer a new link through to the adjacent railway walk, a site location plan enclosed at Appendix 3.

the small scale nature of this site represents a more suitable and sustainable opportunity for growth at Wombourne than the land off Billy Buns Lane
and Gilbert Lane (Site Ref: 463 and 284) proposed allocation. It has a more limited impact on the Green Belt given its scale alongside its physical and visual self containment.
The South Staffordshire Railway Walk situated to the west and which provides a permanent, defensible boundary for the site, and further development to
the east.

Together with the land to the proposed off Orton Lane, the land represents a comprehensive solution to meeting Wombourne’s needs in a single location, which is
very well defined by its boundaries.