Publication Plan November 2022

Object

Representation ID: 5118

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC8 is flawed. It advises that major developments should include self build plots. In our experience the demand for self build plots cannot be met by individual
plots within PLC housebuilder schemes. They are not attractive to individuals who require self build plots, who tend to require larger plots in more rural locations. In
this regard, given that the Council require a minimum of 35dph to be achieved in development sites, the size of any self build plot will naturally be restricted.
This approach will also have an adverse effect on housing delivery. As the details of the self build plot will not be known, it means that full planning application cannot be submitted for any major site within the district. The self build plot element will necessitate the preparation of hybrid planning applications. This will complicate tiggers in conditions and the S.106 agreements.
The policy is not practically implementable. The policy should be re-drafted to support the delivery of self build and custom build housing and the Plan should put in
place criteria to direct development to appropriate sites, rather than to work under the incorrect assumption that self build plots are attractive to home builders on
commercial housing sites.

Object

Representation ID: 5119

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policies should only be included where the standards can be “justified” (NPPF footnoted 49).
The Internal Space Standards Topic Paper does not justify the requirement for use of space standards. It identifies a series of generic matters that are relevant throughout the country. There is no information to suggest that the existing stock of housing cannot meet the requirements for NDDS housing.
Furthermore, Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDDS and the policies should seek to deliver this amount. The policy should work in a similar fashion to the affordable housing policy and require, for example, 30% of all
properties to meet NDDS if that meets the identified level of provision.
Requiring all properties to meet NDDS will make smaller properties more expensive, as they will be larger and more expensive to construct. It could also adversely affect density requirements as these properties will take up more space than smaller properties. The Council needs to recognise that if they require all properties to be
NDSS compliant, it will have a direct impact on densities and viability, due to potentially increased building costs.
We also note that the policy requires set spacing distances between dwellings. This will be difficult to achieve on small brownfield sites that are unusually shaped, which could adversely affect the Council’s windfall delivery aspirations from infilling.
The requirements of policy HC12 and should be properly factored into the Council’s density assumption calculations. They should also be fully explored in the Viability Appraisal. We are not aware of any evidence that this is the case.

Object

Representation ID: 5120

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The provisions identified in policy NB6 should be dealt with under building regulations, the policy is unnecessary. There is no justification for including a policy within the plan that sets standards above building regulation requirements.
It is also unclear how the costs of any additional provisions have been included in the plan’s Viability Assessment and what impact these are expected to have on site delivery.

Object

Representation ID: 5121

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The land at Castlecroft should be removed from the Green Belt and allocated for residential led development. These representations are accompanied by a Vision Document that highlights the opportunities presented by the site. The site can provide 600-655 new homes at a density of 35-38 dph alongside supporting infrastructure.
The site is within the Green Belt, as is the majority of the land in the southern and
western section of South Staffordshire. Any development within the Green Belt will have some impact on its aim and purposes. However, Green Belt land release is required in South Staffordshire, and land at Castlecroft will have an acceptable impact on the Green Belt.
As detailed in these Representations and the Vision Document, there are a number of significant benefits to the proposed allocation of the site. The benefits of development far outweigh any harm. The site can play a valuable contribution towards meeting the housing requirement. It is within the control of a housebuilder and can be brought forward for development promptly if it is allocated.