Publication Plan November 2022

Object

Representation ID: 4198

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Table 1 – Stages of Plan Making, of the consultation draft Plan advises that it is expected that the Plan will be adopted in “winter 2023/24”. There is, therefore, no scope for the plan making process to slip. In our experience the plan making process is often delayed, and there is a real danger that the emerging Plan will not have a minimum 15 year plan period.

The Plan period should be increased by a further 2 years in order to ensure that the Plan has a 15 years time horizon. The housing requirement should be increased on a pro-rata basis and additional allocations made in the Plan.

Object

Representation ID: 4199

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is an identified mismatch between the potential size of the employment pool from those who reside in the district and the new job opportunities which will be created.The housing pressures and need to support economic growth should be recognised as an opportunity for the local economy. Whilst this may result in land being removed from the open countryside and the Green Belt, this should be fully supported. ‘The Issues and Challenges for South Staffordshire’ section of the Plan should be re-drafted to reflect the fact that the housing and employment requirements are an opportunity for the local economy.

Object

Representation ID: 4200

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The emerging Plan fails the NPPF para 140 requirement for identifying safeguarded land in order to ensure the permanence of Green Belt boundaries. The Plan is inflexible and could result in significant delays in the delivery of much needed market and affordable housing.

Policy DS1 should confirm that land has been removed from the Green Belt and safeguarded for future development in accordance with provisions of paragraph 140 of the Framework. Sites should be safeguarded accordingly.

Object

Representation ID: 4201

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement proposed in the consultation draft Plan is below the Standard Method figure derived from the Council’s own SHMA. The SHMA fails to correctly factor in affordable housing need. The draft plans seeks to rely upon affordable housing delivery from the 4,000 dwellings proposed to meet the growth requirements of the conurbation to support the South Staffordshire affordable housing need. This is inappropriate given that these 4,000 dwellings are proposed to meet the growth requirements of the conurbation which has its own affordable housing needs.
No consideration has been given to increasing the minimum Standard Method housing figure to take into account the local authority’s economic growth aspirations and the fact that the age profile of South Staffordshire is increasing resulting in a decrease in the ‘pool’ of working age demographic. It may be necessary for the Council to allocate additional land for residential development ad safeguard land for future development.

Object

Representation ID: 4266

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No particular concern with the majority of development being directed to the larger settlements, but a significant increase to the overall housing requirement is required. The distribution development set out in Table 8 should be reconsidered in light of the need to increase the housing requirement. Additional development should be directed towards locations which are adjacent to settlements including the urban edge of the conurbation.

Object

Representation ID: 4267

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is our view that the housing requirement suggested by policy DS4 is inadequate.The Plan makes insufficient provision to meet the growth requirements of South Staffordshire and helping to address the unmet housing need arising from the conurbation.The housing requirement in the Plan should be based upon the minimum Standard Method housing figure, upwardly adjusted to take account of affordability factors and economic growth objectives.

Object

Representation ID: 4268

Received: 16/12/2022

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Two parcels of land to the west of Yew Tree Lane should be removed from the Green Belt and allocated for residential development to deliver much needed market and affordable housing. The site is a logical location for development with strong defensible Green Belt boundaries and would provide public open space and create pubic access to surrounding Green Belt. The land is capable of delivering 120-140 dwellings and would make a significant contribution to the district’s overall housing requirement. The site is in a sustainable location a short distance from a number of services and facilities. Policy SA5 should be amended to include the additional land off Yew Tree Lane for a minimum capacity of 120 homes.