Object

Representation ID: 4692

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The council is implementing 3 of the 4 Strategic Growth Study recommendations, the fourth - not being proposed - is a housing allocation north of Codsall/Bilbrook. This is contradictory to the council's own position in paragraph 5.15 of the GBBCHMA Development Needs Group Draft Statement of Common Ground August 2022.

The council has been misleading in it's references to 'north of Codsall/Bilbrook', as what is really being referred to is the extension to the previous allocation at 'land east of Bilbrook'. The council have in reality not accepted the Strategic Growth Study recommendations, and should provide an explanation as to why it has deviated from this approach.

The council should implement the Strategic Growth Study recommendations and locate growth to the north of Codsall/Bilbrook where Green Belt is less sensitive and would not have a 'significant impact'. This would be more consistent with NPPF Green Belt policy. The Growth Study also identifies this area as having potential for accommodating strategic growth.

The council should also: deliver a wider range of smaller sites which are more likely to deliver the range of homes needed to meet varying house type requirements. Help more smaller SME builders enter the market and not cater to volume housebuilders. Spread development to a wider range of locations which are likely to be more consistent with Green Belt policy and less likely to create coalescence with the Black Country. Review the council's housing provision in Codsall/Bilbrook as a stronger focus for development as a Tier 1 settlement and main administrative area of the district.

In terms of Green Belt boundary review, the Publication Plan fails to meet development needs and cater for the local economy and is therefore unsound.

The 'infrastructure led' plan appears to be an approach whereby sites are allocated where infrastructure can be more easily sought from developers by virtue of their size. This is not sound planning practice because: it introduces a new financially led criterion which conflicts with the objectives of achieving sustainable development where money steers the choice of sites. The selection methodology is being influenced by whether a developer is willing to offer a school (or not), which could be misinterpreted as a bidding process. It steers allocations towards large sites which favours volume housebuilders. And more critical planning issues are being traded off against an offer of infrastructure provision which is contrary to planning policy. E.g. Site 224 (Station Road, Codsall) has been selected due to the provision of a rail station car park despite high Green Belt harm.

Too much reliance has been placed on strategic sites which; are slow to come forward, focus more on volume builders providing similar product types, monopolises land release, create a danger of housing land supply shortages later in the plan period. The choice of alternative locations for allocations, or the distribution of the same level of housing across more locations, has not been sufficiently or thoroughly explored.