Publication Plan November 2022

Object

Representation ID: 4979

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).

In order to be found sound, a plan should be positively prepared and “seek to meet the area’s objective assessed needs and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development” (NPPF paragraph 35). Barratt therefore supports the proposed approach to contribute towards the GBBCHMA shortfall but objects to the 4,000 dwelling figure.

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.
Reference is made in paragraph 5.13 of the plan to the GBBCHMA position statement from July 2020. Notwithstanding the fact that Barratt has significant concerns with the most recent Position Statement (December 2021) and its unevidenced claim that the existing Birmingham shortfall (circa 38,000 dwellings) has reduced to just 6,302 dwellings, this work is now outdated given the release of Birmingham’s Issues and Options Plan which identifies a significant shortfall of circa 78,000 dwellings across the plan period and demonstrates how woefully inaccurate the Position Statement was.
Table 8 in the local plan sets out how housing growth is proposed to be distributed across the District. Whereas 40.5% of the District’s growth is being directed to the Tier 1 villages, only 16.5% of growth is being directed to the sustainable Tier 2 settlements. Barratt considers that more growth should be directed to the Tier 2 settlements as these have been assessed by SSDC as being sustainable and suitable for growth.
Barratt continue to strongly object to the assessment of Kinver as a Tier 2 settlement and the limited growth being directed to Kinver in particular. Barratt does not consider that the approach being taken to amending the adopted hierarchy is justified (NPPF paragraph 25). It is considered that the modified Main Service Village settlements, which currently includes the settlement of Kinver, should remain as Main Service Villages as they are sustainable settlements which are capable of supporting significant residential growth. The approach being taken has the risk of constraining the growth of some Main Service Villages by not supporting growth, thereby constraining their potential to deliver more services.
Challenge windfall

Object

Representation ID: 4981

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 objects to this approach not being taken in relation to the Tier 2 settlements and Kinver.
As stated in our response to Policy DS4, we do not consider that the designation of Kinver as a Tier 2 settlement and the limited amount of growth being directed to this settlement is justified (NPPF paragraph 35). The approach being taken by the Council is leading to the majority of housing growth being directed to the north of the District which is not justified.

Comment

Representation ID: 4982

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.

Object

Representation ID: 4983

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Omission site: Dunsley Road, Kinver (revised boundary)

Barratt is promoting land to the north and south of Dunsley Road, Kinver (both parcels are shown within the submitted Vision Document). The northern parcel (SHELAA reference 549) is approximately 13 hectares (32 acres) and is bound by Dunsley Road to the south, Dunsley Hall to the east, the Staffordshire and Worcestershire Canal to the north and residential dwellings to the west. The southern parcel (SHELAA reference 550) is approximately 3.5ha (9 acres) and is bound by Dunsley Road to the north, residential dwellings and the Staffordshire and Worcestershire Canal to the west and agricultural fields to the east and south. The Sites could deliver circa 350 market and affordable dwellings as well as a potential community use and public open space.
The key constraint identified within the SHELAA 2021 for Site 550 was that it is ‘disassociated from any village development boundary’. Although the site is not immediately adjacent to the adopted settlement boundary, the site is adjacent to existing residential properties so it is not disassociated from development. Additionally, site reference 272 (land east of Dunsley Drive) is proposed to be allocated in the plan for 22 dwellings. Site 550 is immediately adjacent to Site 272 therefore it will no longer be disassociated from the settlement boundary when Site 272 is delivered.
In addition to the above, the Housing Site Selection Topic Paper has been updated. The 2022 Topic Paper’s assessment of the site is identical apart from where the 2021 Topic Paper stated that that the site could “have the capacity to deliver a small site of up to 1 hectare”, the 2022 Topic Paper now states “more recent monitoring evidence suggests that the Council can meet its small sites duty without additional allocations”. We do not consider that this amendment fundamentally changes the points previously made to SSDC and in this representation on the suitability of the site for residential development.
Heritage assessment does not take into account the revised boundary.
In summary, the Sites are located on the edge of Kinver’s settlement boundary and it is considered that they are easily accessible to the shops, services and facilities provided within Kinver as well as the wider transport network linking the site to Stourbridge. A range of technical work has been undertaken to support the promotion of the sites and assess the impact of any future development on the landscape, local highways network, ecology, trees and adjacent heritage assets. The submitted Vision Document sets out further information on the development proposals.

Object

Representation ID: 4984

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: 4985

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: 4986

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.

Object

Representation ID: 4987

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy requires for all dwellings delivered on major developments to meet M4(2) standards. 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 NPPF also requires all policies to be underpinned by relevant and up to date evidence which should be adequate, proportionate and focused on supporting and justifying planning policies (paragraph 31). The PPG (Reference ID: 56-005-20150327 to 56-011-20150327) sets out the evidence necessary to justifying a policy requirement for optional standards which includes:
• the likely future need;
• the size, location, type and quality of dwellings needed;
• the accessibility and adaptability of the existing stock;
• variations in needs across different housing tenures: and
• viability.
The PPG (Reference ID: 56-008-20160519) also states that when adopting accessibility standards, “Local Plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable, neither of the Optional Requirements in Part M should be applied” [Savills emphasis]. Policy HC4 makes no provision for the PPG exceptions.

Support

Representation ID: 4988

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Policy HC8 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. Barratt supports the flexible approach being proposed in this policy.

Object

Representation ID: 4989

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Part c of Policy HC10 states that all developments will be required to incorporate tree lined streets. We consider that the policy should be worded as set out in the NPPF. Paragraph 131 states that “planning policies…should ensure that new streets are tree-lined” with footnote 50 adding “unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate”. In order to be consistent with national policy (NPPF paragraph 35), Policy HC10 should be amended to refer to situations where tree-lined streets may not be appropriate. Barratt’s experience on a number of current housing developments is that Highways Authorities are not always supportive of tree-lined streets particularly in relation to the long-term management of the highways trees.
Part e states that proposals should use “bespoke house types to avoid a monotonous visual appearance”. It is unclear what is meant from that but on major development schemes delivered by national housebuilders, providing all bespoke house types is not achievable or reasonable.