Object

Representation ID: 1041

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Approach adopted by the Council for its 4 strategic allocations seems to 'change the rules' for identifying housing sites. Sites SA1 - SA4 adopt different principles and it is suggested that due to their size and infrastructure requirements they may need to be immune to certain s106 contributions, yet the purpose of their allocation is to pay for infrastructure.
Site 519 (land east of Codsall/Bilbrook) runs counter to GB Policy by coalescing Codsall/Bilbrook and Wolverhampton. GL Hearn report identified such an area as localised restraint to protect this. The Council's approach contradicts this advice.
Greater Birmingham HMA Strategic Growth Study highlights an area of GB release (Location PD2, land north of Codsall/Bilbrook) as one of their choices for development. The Council has ignored the advice that growth should be in the north and not east of the settlement in the PO Local Plan.
Shortcomings in the 2015 Landscape Sensitivity Study have ben reflected in the Sustainability Appraisal and GB Review.
Land to the east of Codsall/Bilbrook is also High Quality BMV Agricultural Land - Grade 2.
2019 GB Review highlights Site 519 (area to the east of Codsall/Bilbrook) as Very High or High in terms of harm, whereas land to the north of Codsall is Moderate/High harm.
The evidence base is inconsistent. It is noted that Appendix 5 (Policy and Physical Constraints Paper) of the 2019 Spatial Housing Strategy and Infrastructure Deliver Report has been ignored the fact that the land which is High and Very High harm is east where the strategic site has been selected. Also, it fails to explicitly set out the implications of the Moderate/High harm rating of the land north of Codsall.
The Council has contradicted it's consultants advice and evidence base by choosing an area of High or Very High harm in selecting its choice of strategic sites in particular land to the east of Codsall/Bilbrook. Appendix 5 of the Spatial Housing document identifies there should be growth to the north of Codsall/Bilbrook (Area PD2).
The Council has not made a reasoned case for land east of Codsall/Bilbrook, it simply explains the purpose of the allocation and facilities to be provided. For site SA1: it appears that the new community would integrate into the existing community but so would any strategic location. It would deliver a new First School, but this is only justified through the scale of proposed development and would apply to such a development elsewhere. It would be master-planned according to a SPD which applies to any urban extension. Sites 443 and 219 of 2018 SAD already extend Bilbrook to the east and the Council may feel the "damage has been done", however site SA1 is more damaging to fragile GB location.
Any site chosen as a Strategic Development location should be supported by a site-specific masterplan and design code as per 2021 NPPF requirement.