Publication Plan November 2022

Object

Representation ID: 4795

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The plan period should be extended to 2041 to allow for the examination process and to reflect the requirements of the Framework. Given the 28,239 dwelling shortfall from the Black Country's 2021 Plan consultation and the 78,415 dwelling shortfall arising from the emerging Birmingham Local Plan, further consideration needs to be given to contributing to unmet needs. A 20% buffer should be added to the housing requirement to reflect the recommendations of the government's 2016 LPEG. A 10% discount should be applied to planning permissions in housing supply commitments. There is no evidence to justify the windfall allowance and this should be removed. These issues result in a significant shortfall that should be rectified through the allocation of additional sites, including Land off Bridgnorth Road, Wightwick.

Object

Representation ID: 4796

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A disproportionately low level of growth is directed to the edge of Wolverhampton, as only 2,790 dwellings are adjacent to the edge of Wolverhampton's administrative boundary despite a 4,000 contribution to GBBCHMA unmet needs being proposed. There is a lack of diversity in the scale of allocations directed towards the edge of Wolverhampton, which will mean contributions to unmet needs are not delivered for a number of years. No detailed housing trajectory is proposed, but evidence of national build rates and lead-in times from the Lichfields Start to Finish report indicates that sites between 1,000 and 1,500 dwellings in scale will not commence until 6.9 years after permission is granted and will only then build out at 107 dwellings per annum. As a result it is considered that only 963 dwellings can be delivered at each of Land at Cross Green and Land north of Linthouse Lane in the proposed plan period. Clear delivery evidence should be provided to support the allocation of Land at Cross Green and Land north of Linthouse Lane, including a detailed delivery programme.

Further growth should be allocated on the edge of Wolverhampton including smaller sites which are deliverable in the early part of the plan period, including Land off Bridgnorth Road, Wightwick.

Object

Representation ID: 4797

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered inappropriate to include Policy DS6 as it is not making any contribution to the development needs of the Plan period set out in the SSLPR. The next Local Plan Review will be subject to the Local Plan process, and contemplation of growth options will have to be considered in the context of the growth requirements identified and in line with an up-to-date Sustainability Appraisal.

Object

Representation ID: 4799

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Draft Policy SA5 omits Land off Bridgnorth Road, Wightwick as an allocation. There are no technical or environmental reasons why Land off Bridgnorth Road cannot be allocated, with the only concerns raised in the assessment of the site in the Housing Site Selection Paper either considered to be unfounded or able to be dealt with through detailed design and masterplanning.
Having reconsidered Green Belt purposes of Land off Bridgnorth Road against the site itself, the contribution of the site to Green belt purposes is far more limited than the wider parcel S59C. Similarly the individual assessment of landscape sensitivity of the site is lower than the Landscape Study suggests for the wider parcel. The site could be developed via an existing access for the dwelling named Cherringham with minimal impact on the tree belt.

Land off Bridgnorth Road is developable and easily deliverable within the early part of the SSLPR Plan period.

Object

Representation ID: 4801

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The requirement for a minimum of 70% of dwellings to be 3 bedrooms or less would not deliver mixed, sustainable and inclusive communities and does not provide sufficient flexibility.

Object

Representation ID: 4802

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is unduly onerous. In some cases a lower density than 35 dwellings per net developable hectare will be appropriate when considering any on-site or off-site constraints, such as the historic environment, or where the related settlement character requires a lower density, particularly given the policy measures proposed in Policies HC8 and HC12.

Object

Representation ID: 4803

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is an absence of evidence to justify requiring all major residential developments to fully comply with Part M4(2) standards, despite the viability study concluding such measures would not have an impact on development viability.

Object

Representation ID: 4805

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is ambiguous and does not provide sufficient clarity for what is expected on major developments, particularly given that the Self-Build and Custom Housebuilding Register or data from it is not published publicly. The register can't be relied upon as evidence for a policy as individuals can enter their details on multiple registers, skewing the data. Delivery of self and custom build plots on major development schemes are unlikely to be desirable to those on the Council's register as most self and custom builders seek standalone plots in the countryside. This approach also raises practical issues and potential for impact on development viability. Marketing the plot at a reasonable price for a period of 12 months is considered unreasonable and could cause delay in bringing forward supply.

Object

Representation ID: 4806

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There may be instances when greater flexibility is required in application of NDSS, The introduction of such standards is contrary to the Framework, which is clear that these standards should only be introduced where this will address an identified need for such properties.

Object

Representation ID: 4808

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy is considered unnecessary given it seeks to go further than current Building Regulations and given the Future Homes Standard which is due to be implemented in 2025. Building regulations require all new dwellings to achieve a mandatory level of water efficiency of 125 litres per day per person, which is a higher standard than that achieved by the existing housing stock. This mandatory standard represents an effective demand management measure and no robust and proportionate evidence has been provided to justify the Optional Technical Housing Standard.