Publication Plan November 2022

Object

Representation ID: 4603

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At present the SHMA assumes that the projected growth of the working age population in South Staffordshire will grow by 6,618 people between 2020-2040. Whilst this is in excess of the forecast jobs growth outlined in the EDNA, Four Ashes Road Ltd is concerned that the EDNA fails to realistically consider additional jobs created at WMI. Further consideration should therefore be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth, even taking into consideration the 4,000 additional homes to meet unmet needs in the wider housing market area.

Object

Representation ID: 4604

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Four Ashes Road Ltd would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Four Ashes Road Ltd would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District.

Object

Representation ID: 4605

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered that a specific requirement for bungalows is not appropriate if instead the Council pursues a policy of requiring 100% of all homes to meet optional M4(2) requirements.
The Government has consulted on raising accessibility standards for new homes but the requirement for all homes to meet M4(2) standards is yet to be mandated. If the Council intends to pursue a policy in respect of M4(2) standards this must be evidenced. Four Ashes Road Ltd considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.

Object

Representation ID: 4606

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Object

Representation ID: 4607

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.

Object

Representation ID: 4608

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A locally specific CO2 reduction requirement is unnecessary and without justification for deviation from Government emerging Future Homes standards to be considered through building regulations

Support

Representation ID: 4609

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

This representation relates to Land at Four Ashes Road which is a proposed allocation for a minimum of 63 dwellings. This is supported as ‘sound’.
Four Ashes Road Ltd would question whether site the yield of 63 dwellings
underestimates the capacity of the site. The illustrative masterplan included at
Appendix 1 demonstrates that a yield of around 80 dwellings is more accurate. It is however noted that the yield of 63 dwellings is expressed as a minimum
requirement.

Comment

Representation ID: 4610

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. The identification
of the Greater Birmingham HMA Growth Study (2018) and the SHELAA, which were absent in the Preferred Options document, is supported.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified
housing shortfall.

Comment

Representation ID: 4611

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The Vision is clear and succinct, however as presently drafted it doesn’t appear locally relevant and contains no spatially specific elements.
Support is offered to the strategic objectives identified. These are considered succinct, locally relevant and relate to the most important areas of change or protection within the District.

Comment

Representation ID: 4612

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd supports the settlement hierarchy which considers the relative sustainability of villages within South Staffordshire District. The Tier 1 and Tier 2 settlements identified contain the widest range of services and facilities and by focusing new homes to these settlements would provide an opportunity to increase sustainability and self-containment.
Four Ashes Road Ltd considers that the proposed development strategy has due regard to where housing needs exist, including within the top tier sustainable villages and locations close to jobs growth.