Publication Plan November 2022

Object

Representation ID: 4936

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Paragraph 143 of the National Planning Policy Framework (‘NPPF’) requires plans to demonstrate that that the revised Green Belt boundaries will not need to be altered at the end of the plan period. SSDC is not proposing to safeguard any land for development and given the significant shortfalls arising from the Greater Birmingham and Black Country Housing Market Area (‘GBBCHMA’) (discussed further in our response to Policy DS4), we consider it is very likely that SSDC will need to review their Local Plan in the short term to accommodate more growth for the GBBCHMA. 80% of the District is Green Belt (Table 5 of the Publication Plan) and so future Green Belt release is considered to be inevitable to meet housing needs as required in this plan period. Barratt therefore considers that the plan is not consistent with national policy (NPPF Paragraph 35c).

Object

Representation ID: 4937

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS2 states that Green Belt compensatory improvements will be delivered as part of future applications on development sites which have been removed from the Green Belt and allocated in the plan. This aligns with the requirements of NPPF paragraph 142. However, Policy DS2 does not provide any detail on the type or scale of compensatory improvements required. Any requirement should accord with the wording of the Planning Practice Guidance (‘PPG’) which states that policies for green belt compensatory improvements should be “informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities” [Savills emphasis] (Reference ID: 64-002-20190722). Compensatory improvements should not necessarily have to improve access, landscape and biodiversity.

The Policy states that compensatory improvements will be delivered in accordance with a hierarchy, with the preferred approach being on land adjacent to or in close proximity to the development site. National policy requires plans and decision making to make effective use of land (chapter 11 of the NPPF) and NPPF paragraph 143 requires plans to demonstrate that the Green Belt boundaries will not need to be altered at the end of the plan period. Most Green Belt release is on land immediately adjacent to settlement boundaries and primarily in highly sustainable and accessible locations. Therefore, it is important that the provision of Green Belt compensation near these sites should not be proposed on land which could be more suitable for development in the future.

Object

Representation ID: 4938

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The PPG is clear that the standard method sets the minimum housing need and does not produce a housing requirement figure (Reference ID: 2a-002-20190220); and there may be circumstances where a higher requirement figure is appropriate, for example, meeting unmet HMA needs or previous levels of housing under-delivery (Reference ID: 2a-010-20201216). Although the plan does include a contribution towards the HMA shortfall which the Council may consider is a suitable buffer, the Council has not proposed an uplift to the minimum standard method figure to meet local needs nor has the Strategic Housing Market Assessment (‘SHMA’) May 2021 and update October 2022 assessed the requirement for an uplift for economic growth aspirations. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraphs 16 and 35) nor does it support the Government’s objective of significantly boosting the supply of homes (NPPF paragraph 60).

Barratt therefore supports the proposed approach to contribute towards the GBBCHMA shortfall but objects to the 4,000 dwelling figure.

Paragraph 5.15 of the plan states that there is emerging evidence demonstrating a significant shortfall across the GBBCHMA but the “exact extent is not currently known”. Barratt agrees that the distribution of the housing shortfall across the HMA authorities has not been agreed, nor is it known when it will be so the Council cannot fully justify that 4,000 dwellings is a reasonable contribution. Particularly given that there are now additional significant housing shortfalls arising from the Black Country (circa 28,000 dwellings) and Birmingham (circa 78,000 dwellings) and yet the 4,000 dwelling contribution has not been increased from the Preferred Options Stage to reflect the changing circumstances. It is also unclear how SSDC propose to distribute the 4,000 dwellings with the authorities generating the shortfall. The District has a strong connectivity with the GBBCHMA and the Birmingham conurbation so is well placed to accommodate more of the shortfall than other authorities in the GBBCHMA. Barratt therefore considers that in order for the plan to be positively prepared (NPPF paragraph 35), SSDC should be proposing more than 4,000 dwellings towards the significant HMA shortfall.
Table 8 in the local plan sets out how housing growth is proposed to be distributed across the District. Circa 16.8% of the total housing growth proposed is to be delivered in Codsall / Bilbrook (679 new dwellings proposed, 584 dwellings from safeguarded land and 462 dwellings from existing permissions). As arguably the most sustainable settlements in the District, it is considered that more growth should be directed to these settlements. Additionally, the train stations within the settlements make this location highly accessible to the GBBCHMA.

Challenge windfall allowance.

Within the Housing Growth in Locality 4 (Codsall / Bilbrook) section of the plan, it states that “the level of growth to be delivered is also aligned to the level of growth advised by the Education Authority to deliver an appropriately sized First School in this location whilst avoiding creating capacity issues at the Middle and High School level”. The NPPF (paragraphs 20 and 34) requires plans to set out the level of infrastructure (including education) that is required to support the amount of growth planned. Barratt therefore do not support SSDC’s approach that education capacity should limit the amount of growth being target to the most sustainable settlements in the District as it is not consistent with national policy. If school capacity issues have been identified then this should be addressed now through plans for expansion of the existing schools or the allocation land for education within the plan.

Object

Representation ID: 4939

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy states that “an integral part of the Strategy will be to ensure that growth is distributed to the district’s most sustainable locations, avoiding a disproportionate level of growth in the district’s less sustainable settlements”. Barratt supports this approach, however, it is considered that more housing growth should be directed to Codsall / Bilbrook.

Codsall/Bilbrook is identified as a Tier 1 settlement which are the most sustainable settlements in the District (evidenced within the Rural Services and Facilities Audit 2021). Barratt therefore supports growth being directed to these settlements, however we consider that more growth should be accommodated than the proposed 16.8%. The settlements scored the same as Penkridge in the Rural Services and Facilities Audit, yet 17.8% of growth is being directed to Penkridge. This demonstrates an inconsistent approach being applied in the growth strategy. In order to accord with the proposed spatial strategy, additional housing should be allocated in Codsall/Bilbrook. Barratt is promoting land immediately adjacent to Proposed Allocation SA1 to the east of Bilbrook (SHELAA site reference 500). The allocation of this site would ensure that growth is being directed to the most sustainable settlements in the District and will accord with SSDC’s spatial strategy.

Comment

Representation ID: 4940

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Barratt acknowledges that it is a key longer-term aspiration of the council to explore potential options within the district for a sustainable independent new settlement, which has the capacity to accommodate the future housing and economic needs of the district. Given the limited evidence to support a new settlement at this stage, we support SSDC’s approach to exclude the new settlement from the housing trajectory.

Comment

Representation ID: 4960

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Barratt has no objection to the allocation of land to the east of Bilbrook. Consider that the development of Site Reference 500 forms a logical extension to Strategic Allocation SA1 and pedestrian and green infrastructure links could be provided to strengthen the accessibility and environmental net gain of the overall allocation. It is not considered that the ‘constraints’ identified within the SHELAA hinder the site’s potential to deliver housing. The proposed Concept Plan for Site SA1 also shows that the proposed school and community hub within Site SA1 is in close proximity to site 500 so although it is currently detached, the provision of these facilities will make the east of Bilbrook even more sustainable than it already is. The extension of Site SA1 to include Barratt’s land (Site 500) will also mean that more housing is being directed to the most sustainable settlement in the District which accords with SSDC’s proposed spatial strategy.

The SHELAA 2022 states that the key constraints are that the ‘site is disassociated from any village development boundary’ and that a small part of the site is within Flood Zone 3. The SHELAA states that small part of the site (ref 500) within Flood Zone 3 has been removed from the overall area which Barratt supports and considers is not a constraint that would impact on the site being delivered for housing. Proposed built development can be directed to Flood Zone 1 areas within the site.

Challenges transport and landscape / green belt assumptions made on the site.

Comment

Representation ID: 4961

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Barratt has no objection to the allocation of land to the east of Bilbrook. Consider that the development of Site Reference 500 forms a logical extension to Strategic Allocation SA1 and pedestrian and green infrastructure links could be provided to strengthen the accessibility and environmental net gain of the overall allocation. It is not considered that the ‘constraints’ identified within the SHELAA hinder the site’s potential to deliver housing. The proposed Concept Plan for Site SA1 also shows that the proposed school and community hub within Site SA1 is in close proximity to site 500 so although it is currently detached, the provision of these facilities will make the east of Bilbrook even more sustainable than it already is. The extension of Site SA1 to include Barratt’s land (Site 500) will also mean that more housing is being directed to the most sustainable settlement in the District which accords with SSDC’s proposed spatial strategy.

The SHELAA 2022 states that the key constraints are that the ‘site is disassociated from any village development boundary’ and that a small part of the site is within Flood Zone 3. The SHELAA states that small part of the site (ref 500) within Flood Zone 3 has been removed from the overall area which Barratt supports and considers is not a constraint that would impact on the site being delivered for housing. Proposed built development can be directed to Flood Zone 1 areas within the site.

Challenges transport and landscape / green belt assumptions made on the site.

Object

Representation ID: 4962

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

This policy seeks to increase the supply of 2 and 3 bedroom homes which Barratt supports. However, the policy then seeks for all major development housing sites to provide a minimum of 70% of properties to be 3 bedrooms or less. We note that this requirement has reduced from the 75% previously proposed in the Preferred Options plan. However, Barratt do not support applying a blanket requirement across the District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site (e.g. stating that ‘a greater amount of 1, 2 and 3 bed dwellings is encouraged’), it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals (Planning Practice Guidance (PPG) Reference ID: 61-038-20190315), site location and needs assessments at the time of the application in to account.

The Policy also states that “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”. When stating ‘disproportionate’ does the Council mean anything above the 30% required under this policy? If it is, then we are not sure what benefit this part of the policy provides. The wording is negative and we therefore do not consider that it has been ‘positively prepared’ (NPPF paragraph 35).

Object

Representation ID: 4963

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy proposes a minimum density of 35dph in developments within or adjoining Tier 1 settlements, in infill locations within the development boundaries of other settlements in the district or in urban extensions to neighbouring towns and cities. As set out in our response to Policy HC1, Barratt objects to a blanket approach to density being taken as it should be agreed on a site by site basis. However, it is appreciated that wording has been added to the policy to state that site context could be a consideration to deliver a lower density.

Object

Representation ID: 4964

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy proposes specific percentages for each affordable tenure. Barratt objects to this requirement. Paragraph 8.10 of the SHMA 2022 sets out that 50% of the affordable housing requirement of the affordable housing provision to be both affordable rent/ social rent. A distinction needs to be made between affordable and social rent, and this should be reflected in the policy.