Support

Representation ID: 3981

Received: 12/12/2021

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

We have not considered in detail the Homes and Communities Policies which determine how development is considered.

Although we agree with policy H13 we note that H13 Health and Wellbeing isn’t being complied with when taking into consideration the wellbeing of the residents adjacent to the proposed development at Site 582. There will be increased noise, air pollution and light pollution in the vicinity of where they live.

HC14 and HC15 specifically consider the impact on health and education. HC15 refers to the Staffordshire Education Infrastructure Contributions Policy and this policy notes that when ensuring the sufficient supply of school places (as discussed in paragraph 94 of the NPPF), Staffordshire County Council has duties to “secure diversity in the provision of schools and to
increase opportunities for parental choice” (Education and Inspections Act 2006 Part 1 Section 2(3A)).

To understand the impact of a development on education infrastructure in publicly funded schools, an analysis would need to be undertaken using:
• pupil number on roll
• school capacity
• pupil projections during Local Plan period or otherwise
• committed developments and housing allocations in an emerging Local Plan as advised by LPAs on an annual basis
• any other relevant factors

Although we support policy H15 the education infrastructure analysis has not been carried out
pertaining to site 582. During the consultation process we were informed by South Staffs planner Ed Fox that a desk top study only had been carried out looking purely at the vicinity to local schools and not their ability to provide places.

The standard pupil product ratio (PPR) for calculating the number of mainstream pupils attributable from new housing development is 0.03 children per school year group per dwelling. Our group’s analysis of the local schools to site 582 is that there are insufficient places within the local schools adjacent to Site 582 to accommodate this number of additional children. Even
if the local primary school Bhylls Acre can be extended to increase the pupil capacity there is no room for the additional teacher/staff parking that would be required.

We have not considered in detail all of the EC Policies which address community services, facilities and infrastructure.

EC4 -Rural employment. We support this policy in that it retains the existing policy approach of supporting rural diversification with a preference for development within existing development boundaries. Development outside existing villages to be primarily restricted to opportunities
relating to reusing existing buildings. We do however note that a significant proportion of Site 582 is arable land that this is currently farmed and the development of Site 582 will be contrary to policy EC4.

Policy EC11 seeks to: ‘Ensure development is designed to promote high quality walking and cycling, both within sites and to links to nearby services and facilities’ however your policy is without any clear guidance as to how this will happen.

With regards to the NB Policies which address protecting and enhancing the natural environment we note that in NB1 there is an intention to protect, enhance and expanding natural assets however removing Site 582 from the green belt and developing it would be completely
against the proposed Direction of Travel as stated in NB1.
The NB policies which deal with climate change should be linked to policies on the location of development and the corresponding location of amenities and employment. The SSDC approach to climate change is considered too weak when accounting for the long-term impacts
on climate change of such unsustainable development patterns.

Policy NB9 states that ‘’ Proposals for enabling development will be considered and assessed to
determine if the benefits of securing the future conservation of the heritage asset outweigh the
departure from adopted plan policies.’’ This comment appears to place the adopted plan policy higher than the need to protect heritage assets and puts the reliance on the heritage asset to have a higher benefit that the adopted plan in order to save the heritage asset. This appears to undermine the rest of policy NB9 which is the safeguarding of heritage assets and their setting.
This is of particular relevance to the heritage asset on Site 582 which is the Word War II Gun Battery Site.