Object

Representation ID: 4959

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RPS contends that the Council has, through its evidence base, sought to underscore the potential for Featherstone to support higher levels of growth as a basis for limiting any further development opportunities in the SSLP.

The level of growth is most influenced by the Rural Services and Facilities Audit that has used Hansen scores to assess access to employment. The analysis has identified two ‘employment sites’ in close proximity to Featherstone, when four should have been identified (Hilton Main, Hilton Cross, HMP Featherstone, ROF Featherstone). When taking into account the provision of existing employment at Hilton Cross Business Park, and the emerging provision at ROF Featherstone, this would, in RPS opinion, lead to a different score for Featherstone in terms of access to employment. RPS suggest that a score of ‘Good’, and not ‘medium’, is more appropriate in this regard.

Featherstone is also accessible to the West Midlands conurbation via public transport so is ideally placed to accommodate additional housing to help balance the provision of employment currently provided. This 'balanced approach' to homes and jobs can assist in reducing the level of out-commuting, which the Council has identified as a key challenge for the District.

The strategy which seeks to limit growth at Featherstone does reflect the available evidence and so is not soundly-based (not justified). The Land east of Brookhouse Lane, being promoted by Persimmon Homes, represents an ideal opportunity to help deliver this.

The importance being placed on the SGS as the basis for allocating SA2: Land at Cross Green to address the needs of the Black Country raises concerns regarding the soundness of this approach. Specifically, the SGS does not take into account the relative affordability of housing in this area and its ability to meet the needs of black country residents. The data shows that house prices within the area where the Land at Cross Green site is allocated are nearly 60% higher than the average house price across the Black Country. This further supports the case for housing needs from the Black Country to be directed to Featherstone, where a broader mix of households already exists and where a mix of market and affordable housing can be easily integrated into the settlement. this brings into question the soundness of the approach in respect to the strategic location at Cross Green and specially whether households from the Black Country will be able to access housing. his problem is most likely going to be exacerbated due to the significant infrastructure needed to support a 'new village' at Cross Green.

A more appropriate response would be to allocate additional land at Featherstone, Land east of Brookhouse where affordability is more consistent with that of the Black Country.