Preferred Options 2025

Yes

Representation ID: 108179

Received: 05/03/2025

Respondent: Bellway Homes (West Midlands)

Agent: Cerda Planning

We support the requirement that all new development should comply with the NDSS.
However, we make detailed objections to the provisions of Policy A.
It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing achieving this standard.

No

Representation ID: 108180

Received: 05/03/2025

Respondent: Bellway Homes (West Midlands)

Agent: Cerda Planning

We object in principle to this policy.
Self-build plots meets a specific need within the SWLP area, and it is appropriate to plan for the delivery of self-build properties, however the provision of 5% of all sites of 100 houses or more is a wholly unacceptable approach to delivering on need.
Self-build plots set within spatial growth sites will result in sites becoming piecemeal, it will be more challenging to first development and then implement Design Coding, our experience is that self-build demand is low where such plots are set within a much larger strategic scale development, the servicing of individual plots becomes problematic, and given the inherent risk associated with the set aside and delivery of self-build plots it makes the commitment to infrastructure more difficult.
The alternative approach is for the SWLP to expressly allocate sites specifically for the delivery of self-build plots and no other purposes. In this way Design Codes can be prepared reflective of the specifics of the delivery of self-build plots, planning permissions can be granted with site specific conditions and obligations which are bespoke to the nature of self-building, and infrastructure requirements and delivery triggers drafted in a manner reflective of the timing issues around self-build delivery.

Yes

Representation ID: 108181

Received: 05/03/2025

Respondent: Bellway Homes (West Midlands)

Agent: Cerda Planning

We broadly support the provisions of policy G.

Yes

Representation ID: 108182

Received: 05/03/2025

Respondent: Bellway Homes (West Midlands)

Agent: Cerda Planning

We broadly support the provisions of policy H.

Yes

Representation ID: 108183

Received: 05/03/2025

Respondent: Bellway Homes (West Midlands)

Agent: Cerda Planning

We broadly support the provisions of Policy J and the objective of reducing flood risk.
However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.
The NPPF continues to apply the sequential test to locate development outside flood zones 2 and 3, including in relation to pluvial flooding, and this includes all parts of a development site. Policy J refers to applying an ‘internal’ sequential test, by first accepting a development site which is in flood zones 2 or 3 and then designing out vulnerable parts of a development to locate this in lower flood zone areas – which could include locating vulnerable uses in flood zone 2. This is not the approach required by the NPPF (or PPG in respect of undertaking sequential tests). The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage.
This approach should be applied to both plan making and development management.