Object

Representation ID: 1900

Received: 10/12/2021

Respondent: Vistry Group

Agent: Miss Zarina Ali

Duty to Cooperate Topic Paper indicates no SoCG have been prepared with neighbouring authorities and some are taking a different approach in respect of unmet needs, so there is no certainty that the 4,000 dwelling contribution is sufficient. Until a SoCG signed by all GBHMA authorities is in place then South Staffordshire’s plan will be found unsound as it is not positively prepared.

The SHMA does not reflect the correct annual housing requirement (243 dwellings per annum) and the SHMA offers no explanation as to why the 4,000 dwelling contribution is robust.

The approach to highways modelling set out in the IDP risks identifying sites without mitigation and is contrary to the PPG, which requires the capacity of infrastructure to be assessed with the relevant providers from an early stage in the plan process.

The Green Belt Study should score land south of Pendeford Hall Lane as ‘moderate-high’ in Green Belt harm once the assessment criteria are reconsidered and the proposed masterplan is taken into account. This would be consistent with the findings of the Strategic Growth Study 2018 for the area.

The SHELAA has unjustifiably dismissed Sites 217/218 as ‘not suitable’, when pedestrian footways could be inserted along Watery Lane and via the existing PRoW running through the site. This results in a failure to consider alternatives. The SHELAA should be reviewed in light of this.

The Housing Site Selection Topic Paper is based on a an unrobust housing target. The 2018 Strategic Growth Study identified north of Codsall/Bilbrook as an area of search for proportionate dispersal. Site opportunities should be updated to take into account vision document opportunities.

The Sustainability Appraisal fails to consider all reasonable alternatives, failing to include sites 217/218 due to an incorrect assessment in the SHELAA.