Publication Plan November 2022

Object

Representation ID: 5098

Received: 22/12/2022

Respondent: Redrow Homes

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. As a
consequence, the South Staffordshire Local Plan must be adopted in 2024 at the latest in order for this requirement to be met.
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.
order for the Council’s timetable to be met, if the Plan is submitted for examination in “spring 2023”, which is likely to be optimistic depending upon the number of objections, there will be approximately 9 months for:
- an Inspector to be appointed
- hearing sessions to be timetabled and completed
- the Inspector to produce their report
- the completion of Main Modification consultation
- The Inspector to report back following the completion of Main Modification consultation; and
- the Plan to be formally adopted by the Council.
From our experience with other Local Plan examinations this is unrealistic.

Object

Representation ID: 5105

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Table 2 – SWAT Analysis, confirms that there is a demographic imbalance in South Staffordshire. This is coupled with continued development at a series of significant strategic employment sites in South Staffordshire, including I54, FAO Featherstone and the West Midlands Interchange leading to greater investment and prosperity. There is, therefore, an identified mismatch between the potential size of the workforce and job opportunities.
Table 3 – Homes and Communities – Issues and Challenges, advises that there is also a mismatch between existing housing stock and future housing need. There is a requirement to provide smaller residential properties for younger families and older people wishing to downsize and free up family sized accommodation. House prices in the district have continued to increase, making properties less affordable.
There is also a requirement to help to deliver a proportion of the significant amount of housing need arising from the Black Country and Birmingham.
Within this context, it is advised that there is pressure on the South Staffordshire to release land for housing, particularly in the Green Belt and open countryside, which is “acute”.
The housing pressures and need to support economic growth are an opportunity more so than a constraint. While this may result in land being removed from the open countryside and Green Belt, this should be fully supported by the local authority in the most suitable and sustainable locations.

Object

Representation ID: 5106

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As detailed in our representations in respect of the Plans housing requirement, it is our view that the housing requirement is insufficient. Additional land needs to be
removed from the Green Belt to accommodate the housing target. Land at Castlecroft should be removed from the Green Belt and allocated for development.#
In accordance with para 140 of the NPPF - local authorities are required to remove land from the Green Belt and safeguard it for development in order to ensure that the Green Belt is not continually reviewed through each Local Plan review. The emerging Plan fails this requirement.
The amount of land removed from the Green Belt and allocated for development is insufficient. Regardless, there are no safeguarded development opportunities within the Plan. No rationale has been provided for this approach, there is direct conflict with the provisions of the Framework.
Redrow’s land interest at Castlecroft 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.
If any of the allocations do not deliver as expected and a five year housing land supply shortfall occurs, or the Council fails the Housing Delivery Test, it may be necessary for the Council to grant planning permission for unallocated sites in order to ensure a sufficient supply of housing is delivered. This will, however, prove difficult if the development opportunities available to the Council are within the Green Belt.
Removing land from the Green Belt and safeguarding it for future development will help avoid this situation arising.
The Plan is inflexible and could result in significant delays in the delivery of much needed market and affordable housing.

Object

Representation ID: 5110

Received: 22/12/2022

Respondent: Redrow Homes

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.

The Framework advises at paragraph 1.2 that Local Plans should set out ways in which the impact of removing land from the Green Belt can be offset through
compensatory improvements to the environmental quality and accessibility of the remaining Green Belt land. This is not achieved by policy DS2. Policy DS2 is ambiguous and simply suggests that S.106 agreements will be used to secure “compensatory improvements” to the environmental quality. What constitutes a
“compensatory improvement” is not clear, which provides no certainty to developers.
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. If the land is not in the control of an applicant, it cannot be subject to a S.106 agreement.
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: 5112

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

there are three matters that the Plan fails to address in
establishing the South Staffordshire element of the housing requirement:
- The housing requirement proposed in the consultation draft Plan is below the Standard Method figure derived from the Council’s own SSHMA.
- The SSHMA 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 who have their own affordable housing needs.
- No consideration has been given to uplifting the minimum Standard Method housing figure to support the economic growth aspirations and the fact that changes in age profile of South Staffordshire means there is a decrease in residents of a working age.
If the housing shortfall figures identified in policy PG1 of the BDP and the emerging Black Country Plan Preferred Options document are added together, there is a total
housing shortfall of 66,139 dwellings. This should be considered as an absolute minimum, given that the emerging Birmingham City housing shortfall is significantly greater than this combined figure. The 4,000 dwellings proposed by South Staffordshire Local Plan to meet the growth requirements of the conurbation is
approximately 6% of the conservative shortfall figure. South Staffordshire, given its functional relationship
to the Black Country and for the reasons previously mentioned, should be accommodating a significantly greater amount of development than this to support
the growth requirements of the conurbation.

Object

Representation ID: 5113

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Table 8
The Spatial Housing Strategy identified in Table 8 is flawed. Whilst we have no particular concern with the majority of development being directed to the larger
settlements, a significant increase to the overall housing requirement is required, as detailed elsewhere in our representations. Additional development is required across the settlements to meet the increased housing target.
Table 8 of the draft Plan advises that only 2,958 dwellings are proposed adjacent to the edge of the conurbation. The 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 housing requirement should be increased and redistributed so that further allocations are made adjacent to the built-up edge of the Black Country.
The land adjacent to the Black Country provides some of the most sustainable locations for development within South Staffordshire. The Black Country provides a wide variety of services and facilities.
paragraph 5.23 of the Draft Plan refers to the GBHMA
Strategic Growth Study 2018 as being an evidence based document that has been used to inform the settlement hierarchy and the distribution of growth. The Strategic Growth Study advises at paragraph 1.38 that given the strategic nature of the study it does not consider development options of less than 1,500 dwellings. There are no allocations of this size included within the Draft Plan. The GBHMA Strategic Growth
Study is not a relevant evidence base against which to assess the suitability of sites or formulate a housing distribution strategy.
Our representations propose that Redrow site adjacent to the Castlecroft area of Wolverhampton is removed from the Green Belt and allocated for residential led
development.

Object

Representation ID: 5114

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy SA5 identifies the various sites that are allocated for development by the Plan. The policy advises that the allocated sites should be brought forward in accordance
with the site’s specific policies included in the Plan.
Policy SA5 therefore achieves relatively little. It is simply a list of allocated sites. It is our view that this would be better addressed in the supporting text as it does not form a policy role.

Object

Representation ID: 5115

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan has been prepared to have a 15 year time period. The demand for property types could change over time. As such, policy HC1 should not be prescriptive and
restrict the number of larger properties at this stage as there may be demand for larger properties later in the plan period.
The demand for different property types is likely to change across the plan area. For example, housing sites
allocated adjacent to the edge of the urban area to meet the growth requirements of Birmingham and the Black Country should meet Birmingham and Black Country’s
housing mix requirements, not South Staffordshire. The Council’s HMA considers the mix requirements for the South Staffordshire element of the housing requirement
only, not the Black Country and Birmingham’s. Similarly for ageing population and affordable housing.
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 as and when planning applications are determined. If at that stage it is decided that a mix condition is “necessary” it can be
applied.

Object

Representation ID: 5116

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 is fundamentally flawed. Density should be a product of good design. It is not appropriate for the policy to refer to 35dph being a “minimum” requirement, it should be a target.
The policy advises that developments with a net density below 35 dph will only be supported if developing sites at 35 dph would “result in significant adverse impacts to the surrounding area or historic environment, settlement pattern or landscape character”. As drafted, this means it would be accepted for the scheme to deliver at 35dph if it had an “adverse”, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate.
In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework.
In addition, if the Council pursues NDSS standards this will restrict the ability to deliver the proposed minimum density requirements particularly on smaller brownfield
sites that may be constrained.

Object

Representation ID: 5117

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC3 requires 30% affordable housing provision. This approach is flawed. We comment on this matter in detail in our response to Table 7. In short, the 30%
affordable housing provision target does not reflect the affordable housing needs of the district. It is based upon the Birmingham and Black Country element of the
housing requirement delivering affordable housing support of the growth of South Staffordshire. Clearly any affordable housing delivered as part of the Birmingham and Black Country element of the housing target should be to support affordable housing needs to Birmingham and the Black Country.
As detailed in our response to Table 7, in order to meet the annual affordable housing requirement it would necessitate 50% affordable housing provision on the South Staffordshire element of the housing requirement. This is likely to make development unviable and has not been tested as part of the plan making process.
Furthermore, policy HC3 should set an affordable housing requirement for the South Staffordshire element of the Plan’s housing requirement and separately for the
conurbation’s affordable housing need. These are two separate requirements and should be treated as such.