Object

Representation ID: 3980

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

As set out in this document we do not believe Site 582 should be released. This is because:
Housing Numbers

1. The justification for the housing numbers proposed in South Staffordshire relies on 4,000 from overspill from the Black Country that is untested. Without them no new allocations are needed.
2. The Government’s arbitrary 35% uplift of housing in Wolverhampton is being added to general housing need when it should be targeted at brownfield regeneration.
3. The level of housing supply both in the Black Country (and wider conurbation) and in South Staffordshire is being under-estimated. In the case of the Black Country this could amount to over 5,000 homes and in South Staffordshire another 1,000 homes from windfall sites.
4. Accelerated changes to retail and office provision, particularly in centres following COVID may increase housing land available in the Black Country.
5. Even if the level of housing is required from the Black Country South Staffordshire is overproviding by 1153 homes, so does not need this housing allocation.
Sustainability
6. The location of the site suggests it would, along with other allocations in South Staffordshire, encourage people to move out of the Black Country and then commute back in.

7. The site is located in the Green Belt without a clear boundary beyond it. The impact could be significant on the purposes of the Green Belt, in particular encroachment into the countryside, urban sprawl and impact on regeneration.
8. The site is poorly located for public transport access and is likely to be heavily car dependent, increasing climate change emissions.
9. The site would impact on the landscape and amenity of people round the site.
10. There are potential flooding and water issues that need further investigation.
11. The site is used by a variety of wildlife and includes important habitats which link into a wildlife corridor along the South Staffordshire Railway Walk Local Nature Reserve and the Smestow Nature Reserve.
12. It is not clear that the site is adequately served by local services, and although there is a nearby Primary School, it is unclear how educational services would be improved to cater for the site.
13. There are English heritage assets in terms of a World War II battery which have yet to be properly examined.