Publication Plan November 2022

Object

Representation ID: 4627

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to Policy DS1 as written, because it is not justified. SSDC is not proposing to safeguard any land for development.the plan is not consistent with national policy (NPPF Paragraph 35), and safeguarding of Green Belt land is likely to be required given the significant shortfalls arising from the Greater Birmingham and Black Country Housing Market Area (‘GBBCHMA’) and the uncertainty surrounding how they will be dealt with. Therefore the plan should be modified to include Green Belt Safeguarding to meet this existing and emerging need.

Object

Representation ID: 4628

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes object to Policy DS2 as written, because it does not align with national policy. The policy requirement should accord with the wording of the Planning Practice Guidance (PPG Reference ID: 64-00220190722). Compensatory improvements should not necessarily have to improve access, landscape AND biodiversity. The policy should therefore be reworded to allow the level of flexibility prescribed by the PPG, and to ensure that the policy is consistent with national policy and meets paragraph 35 of the NPPF.

Object

Representation ID: 4629

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Object to Policy DS4 as written, because it is not justified, effective or positively prepared. South Staffordshire’s local housing need has been calculated by using the figure derived using the standard methodology for calculating housing need. The PPG is clear that this sets the minimum housing need and does not produce a housing requirement figure (PPG Reference ID: 2a-002-20190220). The Council should therefore produce evidence as to why this figure does not require any additional uplift or buffering, due to economic growth for example.

It is unclear what the rationale is for the 4,000 HMA contribution figure is, having stayed the same since the issues and options version of the Local Plan review on 2018. We consider that in order to demonstrate on-going and effective joint working with the HMA authorities, that a single SoCG with all authorities should be produced to set out the agreed distribution of the shortfall across the HMA that takes into account latest evidence which points to a significantly increased shortfall. This is required in order to make the plan sound and to meet the legal duty to cooperate.

Object

Representation ID: 4630

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Greater consideration should be given for the spatial context surrounding the site which includes connections to sustainable settlements in the Black Country such as Wordsley, and should support extensions to sustainable settlements such as this.

The spatial strategy of the Plan should be modified to take greater account of the shops and services located in the Black Country which can serve South Staffordshire and support sustainable development.

Object

Representation ID: 4631

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We object to the housing allocations in policy SA5, because it is not justified, We consider that this policy should be amended to include land at Lawnswood Road (site 654). Do not agree with findings of the Green Belt Review 2019. Land at Lawnswood Road performs as well as the site off the Langley Road when assessed against the 5 purposes of the Green Belt. Meanwhile the harm assessment in the Green Belt Study was not undertaken at the site specific level. An assessment provided for the site promoter identifies the parcels as 'moderate' and 'low moderate' rather than 'very high' for land, and for landscape sensitivity 'moderate' and 'low moderate' rather than 'high'. Furthermore, the Council appear to have not considered the opportunities afforded by the existing facilities and services available in neighboring authorities.

Object to the consideration of access to education in the SA and the site having a double negative rating. This assessment should be re-run considering that a site of such a size would reach the critical mass of residents that would ensure the viability of delivery of a primary school on site.it should also be considered that of the 4 primary schools within 1.5 miles of the centre of the site, 2 are under capacity.

Evidence by site promoter suggests heritage led design principles means that heritage impacts can be successfully mitigated to a large degree. Evidence by site promoter suggests that due to the low-quality habitats currently present at the site development at the site has the potential to provide and enhance overall biodiversity within the green infrastructure. Flood risk evidence prepared for the site promoter indicates development of the site can be delivered sustainably without increasing flood risk or having a detrimental effect on water quality.

Desktop research undertaken by Savills indicates that 8 shops / newsagents are within 1.5 miles of the centre of the site.The development could see significant public benefit including creating significant areas of new public open space, including the potential to create a new woodland link. We consider that there is suitable evidence to justify the reassessment of site 654 at Lawnswood.

The site should be reassessed taking into account this evidence, which we assert shows the site in an improved position in terms of sustainability and provides adequate evidence for it to be considered as a draft allocation for residential development.

Object

Representation ID: 4632

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is important that housing mix is determined on a site by site basis and takes account of market signals at the time (PPG Reference ID: 61-038-20190315). It would be appropriate for the Council to refer to other evidence not just the latest Housing Market Assessment and consider other elements such as the current demand.
Reference is made in the policy to: “any development that fails to make efficient use of land by providing a disproportionate amount of large, 4+ bedroom homes compared with local housing need will be refused”. “disproportionate” is not defined in the policy, so it is therefore unclear how this is measured or how a developer should respond to this. This policy should be reworded in order to evidence it has been positively prepared as required by paragraph 35 of the NPPF.

Object

Representation ID: 4633

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to Policy HC2 as written, as it is not justified. This policy looks for housing developments to achieve a minimum net density of 35 dwellings per net developable hectare within or adjoining Tier 1 settlements, in infill locations with the development boundaries of other settlements or in urban extensions to neighbouring towns and cities.

Clowes does not support this blanket approach, and consider that the determination of appropriate residential density to be a lot more nuanced than the proposed blanket designation taken by the Council. Greater flexibility is required to allow developers to take account of the evidence in relation to market aspirations, deliverability and viability and accessibility. There is a need for low to medium density housing to provide a balanced portfolio of sites to meet all market need, including executive style housing. As written this is not something that policy HC2 seeks to do and is therefore contrary to national policy and guidance.

Object

Representation ID: 4634

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to policy HC3 as written because it is not justified.Paragraph 8.10 of the SHMA 2022 sets out that 50% of the affordable housing requirement should be both affordable rent / social rent. Greater clarity is required regarding the justification for the requirement for 50% social rent only in policy HC3, and why it makes no reference to affordable rent.

Furthermore we consider that Policy HC3 should be amended to state ‘where viable’ in order to provide sufficient flexibility and allow tenures to be agreed between SSDC and the applicant on a site by site basis and determined on local need at the time of the application.

Object

Representation ID: 4635

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to the policy HC4, as written because it is not justified, effective, not is it accordance with national policy The PPG states that Councils have the option
to“set additional technical requirements exceeding the
minimum standards required by Building Regulations in respect of access” where there is a justified need
for this requirement (Reference ID: 56-002-20160519).

The PPG (Reference ID: 56-005-20150327 to 56-011-20150327) sets out the evidence necessary to justifying a policy requirement for optional standards.Therefore,
Policy HC4 should be supported by a detailed analysis of how the Council consider these criteria have been adequately addressed and evidenced.

Support

Representation ID: 4636

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Clowes supports Policy HC8, which states that major developments will be required to have regard to the need on the council’s self-build register, and make provision of self and custom build plots to reflect this. Clowes supports the flexible approach being proposed in this policy.