Publication Plan November 2022

Support

Representation ID: 4837

Received: 22/12/2022

Respondent: David Wilson Homes

Given the significant remaining shortfall arising in the GBBCHMA and South Staffordshire’s clear functional relationship with the wider HMA (demonstrated by its travel to work patterns, and transport links with Birmingham and the Black Country), the plan’s proposed contribution to the GBBCHMA’s unmet need seem reasonable.

Nearly all of South Staffordshire’s villages are surrounded by Green Belt, therefore it is inevitable that the district will need to release Green Belt to meet its needs and those of the wider GBBCHMA. As such exceptional circumstances have been demonstrated to alter Green Belt boundaries through the draft plan, in accordance with NPPF paragraph 140.

Object

Representation ID: 4838

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The spatial strategy, seeking to meet the District’s own needs and make a 4,000 home contribution to the GBBCHMA’s wider unmet needs seems appropriate.

However there is a clear inconsistency in the proposed new settlement hierarchy, particularly with regard to Featherstone. Featherstone has a strong offering of services and facilities which are commensurate with that offered by Tier 2 settlements. The Rural Services and Facilities Audit 2019 makes a clear case for Featherstone being identified as a Tier 2 settlement, rather than a Tier 3 settlement, especially as the facilities offered by Featherstone. Featherstone should be a Tier 2 settlement, and as such could make a greater contribution to delivering the new homes required within the District.

Comment

Representation ID: 4839

Received: 22/12/2022

Respondent: David Wilson Homes

Concerns regarding ROF Featherstone road access and its impact on Cross Green's viability and deliverability trajectory given the funding estimate for the road set out in the IDP.

In the context of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the anticipated number of homes to be delivered before 2039.

Lichfields’ Start to Finish report (February 2022) indicates it is reasonable to assume 160 dwellings per annum (dpa) to be delivered on sites of Cross Green’s scale. In total, it is therefore likely that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore prepare further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,000 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District.

Object

Representation ID: 4840

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 396 to the west of Featherstone Lane, Featherstone site scores ‘major negative’ for landscape and townscape in the most recent Sustainability Appraisal, despite the Landscape Study (2019) scoring the site’s landscape sensitivity as ‘Low Moderate’.Site 396 should score ‘minor negative’ for landscape and townscape.

The site scores ‘major negative’ for education, however no justification is provided for this. Indeed,
there is no justification for this as the site is within an acceptable walking distance of the Featherstone
Academy Primary School. Site 396 should therefore score ‘minor negative’ for education.

The Council’s evidence base, including the IDP, demonstrates there is currently a lack of highway capacity at Featherstone (particularly in regard to the A460). This capacity issue will be resolved through the delivery of the M54 / M6 / M6 Toll link road, the Development Consent Order.

Site 396’s constraints have been overplayed in the Council’s evidence and given the timing of the
significant infrastructure improvements in the area growth should be directed to Featherstone given
its sustainability. As such, land west of Featherstone should be a proposed allocation in the plan to
accommodate this or, as a minimum, safeguarded. It is accepted that policy proposing to allocate or safeguard land to the west of Featherstone might be subject to a clause that it should not come forward until the link road has been delivered.

Object

Representation ID: 4841

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy should be more flexible, recognising that housing needs vary within different areas and on a site-by-site basis. Housing requirements constantly evolves and as such there should be flexibility embedded in policies to enable them to respond to changing demands and context.

Policy HC1 should therefore more closely reflect the flexibility of the existing Core Strategy policy H1 which requires:
“A mix of housing sizes, types and tenures within both market and affordable sectors, particularly the
needs of an ageing population, informed by the Housing Market Assessment, which meet the needs
and aspirations of all sections of the local community.”

The Strategic Housing Market Assessment (October 2022) does not identify a significant predicted
change in the projected household type proportions in South Staffordshire between 2018 figures and
2040. As such, it is not clear why a highly prescriptive housing mix is included within Policy HC1.

Object

Representation ID: 4842

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach. Impact on scheme viability is referenced in the existing policy H2, and there should also be an allowance for a consideration of site viability, including whether there is a need for new infrastructure etc. which could impact on delivery of the allocated sites. The proposed tenure split for affordable housing is broadly in line with the need evidenced in the Housing Market Assessment Update 2022. However, this may change over time and location-specific flexibility should be provided.

Comment

Representation ID: 4843

Received: 22/12/2022

Respondent: David Wilson Homes

Regarding the proposals for requiring M4(2) building regulations, The Council should provide localised evidence making the specific case for South Staffordshire which justifies the inclusion of optional higher standards for accessible and adaptable homes in this policy. If the Council can provide the appropriate evidence and this policy is to be included, then a transition period being included within the policy could be supported, as appropriate.

There is a need for policy to be consistent with national standards unless a specific evidenced reason exists for a higher standard to be applied in South Staffordshire.

Object

Representation ID: 4845

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

External space standards and amenity spaces should not be explicitly stated within the policy. Planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to
achieve suitable quality residential environments.

Object

Representation ID: 4846

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now taken effect and provides guidance on the installation and location of electric vehicle charge points (EVCPs). The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Object

Representation ID: 4847

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirements for carbon emission reductions in Part 1 of NB6, go beyond the Government’s Future Homes Standard roadmap that most developers are working to and on which they have based their future plans.

The approach, based on the Future Homes target roadmap, takes a more gradual approach which is
the right approach.There are a number of reasons why building ahead of the Future Homes Standard now may not actually be the best solution. Principally, because of the potentially detrimental local impact on delivery through a lack of sufficiently skilled labour available to implement these new technologies at scale.

Regarding Part (b), in principle additional onsite renewable energy should be provided to assist in
meeting net zero regulated energy targets. However, South Staffordshire should to be flexible in the
application of this policy to take account of site-specific constraints which may constrain the onsite
provision of, or offsite connection to, renewable/low carbon energy generation.

Whilst in principle we do not object to a Whole Life Carbon Assessment (WLCA) there are issues surrounding data collection to be able to undertake a proper WLCA. Principally, many manufacturers are still lacking the creation and verification of data for
Environmental Product Declarations (EPDs). Though there are UK based EPDs, these are often generic values which will not accurately reflect a completed property, so it is important that South Staffordshire allow some tolerance when assessing any submitted WLCA.

If a WLCA is to be submitted, then it should be required as part of the planning conditions attached to a grant of detailed planning permission as it would prove difficult for applicants to submit a robust WLCA based on
Outline application parameters.

Regarding the requirement for a as built performance assessment, South Staffordshire should reconsider the requirement for immediate implementation of built assessments in the Local Plan and instead consider rolling out this requirement at a later date, once the Government undertake further national scale research projects into their implementation. If the policy is carried through to EiP stage, South Staffordshire will need to adequately demonstrate as part of their evidence base that the current as built assessment sector will be able to meet the resultant demand should all allocations in the Local Plan come forward for delivery on expected timescales.