Object

Publication Plan November 2022

Representation ID: 4973

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Having reviewed the Housing Site Selection Topic Paper (HSSTP) with respect to the sites assessed at Featherstone, including site 170, RPS disputes the conclusions of the Council’s site assessment for site 170.

Firstly, it is clear, on the Council’s own evidence, that site 170 performs well in terms of Green Belt harm (‘moderate’) and Landscape sensitivity (low-moderate’).

Secondly, RPS contends the highways concerns raised by the County Highways Authority (CHA) has been over-stated and result in an unduly negative assessment for the Site. An initial transport strategy prepared by PJA, on behalf of Persimmon Homes, outlines how these concerns can be mitigated in order to facilitate suitable development on the Site. RPS therefore disputes the CHA view further assessments are required at this stage to justify allocating the site on highway capacity grounds. The reasons for excluding the site on highways grounds are therefore not justified.

The assessment for site 170 in the HESA (specifically the amber score for indirect impacts on designated heritage assets) is arbitrary in nature and does not represent a robust assessment. The vision document demonstrates that built development would be significantly set back from the edge of the site that would increase the stand off to more that double the Council's estimate.

The 'Known constraints' relating to site 170 are not justifiable. RPS does not agree with overall conclusions drawn by the Council in relation to site 170 which has resulted in its exclusion from the SSLP. Whilst some constraints may impact on the Site, none of them preclude residential development on the Site, nor do they prevent the Site from being allocated in the local plan for residential use. RPS does not consider the reasons for excluding the site to be soundly-based.