Object
Preferred Options November 2021
Representation ID: 1013
Received: 13/12/2021
Respondent: Hallam Land Management
Agent: Acres Land & Planning
No evidence of cross-authority agreements through DtC.
The 2014 LUC GB Review is fundamentally flawed as it concluded that Parcels 1, 2 and 4 of Codsall perform the 4th purpose of GB, however case law has since identified that this purpose of GB only applies to historic towns such as Oxford, York etc.
The 2019 LUC GB review stage 1 assessment is based on inconsistent parcel sizes with some being of 'odd' shape and so large meaning character assessment is flawed. As such, GB study is unfit for purpose. Within stage 2, Site Specific Assessments, Site 222 - Sandy Lane - has not been updated to reflect completion of Watery Lane site.
The interpretation and reflection of the GB study is incorrect as strategic Bilbrook/Codsall extension was defined as making important contribution to GB. This proposal allows coalescence of Wolverhampton and Codsall/Bilbrook - contrary to purposes of GB. The contribution of a First School is irrelevant in GB terms.
Disagree with 2015 Landscape Sensitivity Report and 2019 GB and Landscape Sensitivity Study conclusions that Site 222 Sandy Lane has 'high' GB impact as it has been aggregated with areas to the north and west of Codsall. Consideration should be had to Watery Lane development and smaller parcel assessment sizes. Do not agree that land east of Bilbrook is 'low' impact by comparison.
2019 GB Study should be described as Landscape Sensitivity Study on its cover. It does not address landscape impact other than GB harm within Stage 2 process. Landscape should not be considered within GB assessment as it is not a consideration of the purposes of GB. Site S41A (inc. Sandy Lane, Codsall) is shown in Figure 7.3a as having Moderate/High harm whereas site S46C (linc. land east of Bilbrook) has mixtire of High and Very High harm and should be ruled out for development on VSC grounds.
The submitted Heritage Statement shows that the indirect impacts on heritage assets identified in the 2019 Historic Environment Site Assessment II can be mitigated despite negative assessment of this within the SA.