Publication Plan November 2022

Object

Representation ID: 5101

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In order for the different needs to be met, this require the mix of houses to vary between the sites to meet South Staffordshire’s needs and that to meet the conurbations needs.By contrast, the requirements of Policy HC1 are based sole on the need arising from South Staffordshire. Policy HC1 should, therefore, be amended to set out the different mix requirements for the different sites.

We also object to the suggestion that S.106 agreements will be used to secure the mix of outline planning applications. This is a matter that can be addressed by a condition, and as such a S.106 should not be used. Furthermore, conditions should only be applied where there is evidence that this approach is “necessary”. This should be determined on a site-by-site basis. If at that stage, it is decided that a mix condition is “necessary” it can be applied.

Object

Representation ID: 5102

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS2 puts in place a series of potentially undeliverable requirements for Green Belt compensation. Policy DS2 is ambiguous and simply suggests that S.106 agreements will be used to secure “compensatory improvements” to the environmental quality of land that remains in the Green Belt. What constitutes a “compensatory improvement” is not clear, which provides no certainty to developers.

Similarly, it is also unclear how the local authority can be sure that the applicants have control over any adjoining land required to deliver the compensatory improvements.

A simpler approach would be to use the “key requirements” of the various allocation proformas to identify the specific Green Belt compensatory measures for each relevant allocation. This will negate the need for policy DS2 and provide clarity for developers.

Object

Representation ID: 5103

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst the plan suggests that 4,000 units are required to support the growth of Birmingham and the Black Country, only 2,958 dwellings of these are allocated for development adjacent to the conurbation. 4000 dwellings to the shortfall from the conurbation is not enough.

In increasing this number and seeking additional sites to meet the additional requirement, it is our view that the most logical location to allocate these sites is through the removal of additional sites from the Green Belt adjacent to the Black Country to ensure it is provided in the right location to support the growth of the conurbation.

Object

Representation ID: 5104

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The suggested housing requirement included in the Plan of 9,089 dwellings, is fundamentally flawed.

Now that the Plan period has been extended to 21 years this would increase the need for South Staffordshire on a pro rata basis to 5,322 dwellings based on the Standard Method (SM) calculation. The plan target at Table 7 is therefore not based on the SM.

The 4000 figure is based on the 2018 SGS which is out of date and not based on the SM. Shortfalls have increased significantly since the SGS including the circa 78000 shortfall identified in the Birmingham Issues and Options consultation. The 4,000 dwellings proposed to meet the growth requirements of the conurbation is woefully inadequate and needs to be increased significantly.

Completions to date from the start of the plan period are used as a proxy for housing need for the period 2018 to 2022. There have been 992 completions during this period. There is no evidence to suggest that the 992 completions were sufficient to meet the housing requirements of the district during this period. Housing schemes have been restricted to windfall schemes within settlement boundaries due to the restrictive Green Belt policies that are in place. Consequently, using a constrained figure as a proxy is flawed.

Furthermore, we have identified in our other submissions that the plan period should be extended by at least 2 years to ensure that the plan covers 15 years from the date of adoption. This would add a further 507 dwellings to the housing target, and means the plan is current planning for 740 dwellings less than it should be.

The South Staffordshire Standard Method housing requirement is 254dpa according to the SSHMA. As a consequence, an affordable housing requirement of 128dpa is approximately 50% of South Staffordshire’s minimum Standard Method housing requirement. By contrast, the figure in Paragraph 8.7 of the SSHMA is skewed, as the total housing requirement proposed by the Plan is used (9,068 dwellings), which includes the 4,000 dwellings the plan proposes to deliver to meet the growth requirements of the conurbation. The 4,000 dwellings proposed to meet the growth requirements of the conurbation cannot be considered as a source of affordable housing supply to support the affordable housing delivery needs of South Staffordshire. Any affordable housing provided as part of the delivery of these 4,000 units will be to support the affordable housing needs arising from the conurbation, not South Staffordshire.

Table 2 references the demographic imbalance. • No consideration has been given to uplifting the minimum Standard Method housing figure to support the economic growth aspirations or the fact that changes in age profile of South Staffordshire means there is a decrease in residents of a working age.

Object

Representation ID: 5107

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed plan period is 2018 to 2039. Paragraph 22 of the Framework requires Local Plans to have a “minimum” 15 year plan period from the point of adoption. Consequently, the South Staffordshire Local Plan must be adopted in March 2024 at the latest for this requirement to be met, which is very unlikely.

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

Object

Representation ID: 5108

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Green Belt, provides guidance on the approach the local authority has taken to removing land from the Green Belt. It also identifies the changes being made to the Green Belt boundary in the Plan to accommodate the identified development requirements.As detailed in our representations in respect of the Plans housing requirement, it is our view that the housing requirement is insufficient.

Not only is the amount of land proposed to be removed insufficient to meet the needs arising from South Staffordshire and the conurbation during the current plan period, but there are no safeguarded development opportunities within the Plan. No rationale has been provided for this approach and this approach conflicts with the Framework.

Heywood Developments land interest at Enville Road, Wall Heath should be removed from the Green Belt and allocated for development. However, if this position is not supported the site should be safeguarded as a longer-term development opportunity.

Object

Representation ID: 5109

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is our view that housing allocations included within the Plan to support the growth of the conurbation should be directed to locations close to where the need arises. The Plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation to meet its need, or within a sustainable commuting distance, to help reduce the need to travel. The housing requirement should be increased and redistributed so that further allocations are made adjacent to the built-up edge of the Black Country.

The distribution of development set out in Table 8 should be revised. Additional development should be directed to the built up edge of the conurbation. Land at Enville Road, Wall Heath should be removed from the Green Belt and allocated for development.

Object

Representation ID: 5111

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? Yes

Duty to co-operate? No

The land at Enville Road in Wall Heath should be removed from the Green Belt and allocated for residential development. This site is a sustainable location to deliver housing on the edge of the conurbation representations are accompanied by a Vision Document that highlights the opportunities.