Object

Representation ID: 4976

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RPS does not consider the findings against a number of SA objectives to be soundly-based.

Under SA Objective 4, RPS would question the relevance of including consideration of Green Belt under this objective, given the fact that Green Belt is a strategic designation based on five purposes, none of which relate to landscape factors. RPS does not consider the Council’s conclusion that development on this site would cause ‘moderate harm’ to the Green Belt purposes soundly-based. In relation to landscape sensitivity, a previous Planning Inspector for application 06/00638/OUT would not have a material effect on the landscape character of the area.

Under SA Objective 5, the effects are over stated when taking into account the potential for mitigation. Air and noise effects from the M54 were considered in the earlier planning application where both the Planning Inspector and the Secretary of State concluded that this would not represent a barrier to development. The assessment has also not taken account of the decision made the Government in April 2022 to allow the construction of a new M54/M6/M6 Toll/ A460 link road that will reduce traffic flows. For water, RPS highlights that the illustrative masterplan shows that any bult development would set back from existing watercourses in the vicinity and within the site and, notably, a sustainable urban drainage system will be designed and installed as part of development on the site.

Under SA Objective 6,RPS disputes the score given for the site. Firstly, the site has been used for cultivation more many years and so, for the vast majority of the site, it is disputed whether the soils are, in fact, of ‘ecologically valuable’ given its current use. No evidence is presented by the Council which shows the site to be of Grade 3a value, and thus classed as ‘BMV’ land. In light of the above, RPS contends that the site should not be scored ‘minor negative’ under this objective without sufficient evidence to support the Council’s claim.

Under SA Objective 10, RPS disputes the assertion that the site would have a minor negative impact with respect to access to bus stops. 800 meter threshold is used in Manual for Streets and there are a number of bus services within this distance. Furthermore, the use of a 400m threshold differs from those used by the Council as part of its rural services audit. Specifically, the Rural Services and Facilities Audit (RSFA), which applies a proximity ‘range’ of between 800 to 2,000m (see paragraph 3.17 of that report). RPS contends the SA methodology for this objective is not fit for purpose as a reasonable measure of significant effects. Consequently, when applying the national standards and those used elsewhere in the Council’s evidence base, as a measure of access to local services, site 170 would clearly score ‘minor positive’. RPS also disputes the Council’s suggestion that site 170 is located beyond 2km of a convenience store, and thus would score ‘minor negative’.RPS contends that site 170 would, in overall terms, have a ‘minor positive’ impact on access to transport and accessibility.

Under SA Objective 11 RPS disputes the basis for the criteria identified in the SA methodology for distance to education. The 1.5km threshold applied under this objective equates to a distance of less than one mile (0.9 miles). However, both national and local guidance applies a wider distance threshold (3 miles) in measuring appropriate distances between home and school locations. RPS considers the distance thresholds applied under this SA objective to be arbitrary in nature and are not based on any local assessment of what would constitute an appropriate distance. Consequently, the score for Site 170 under this objective should be adjusted to ‘minor positive’.

Under SA Objective 12, it is wrong to suggest the site has unreasonable access to local employment opportunities when the RSFA using the same Hansen scores identified site 170 as having ‘medium access to employment’. RPS contends that the SA has wrongly applied the findings of the RSFA in light of Featherstone’s accessibility to local employment. Accordingly, the Council should identify the correct effect consistent with the SA methodology. The correct score in RPS’ view, as defined in the methodology, is ‘minor positive’.

It is unclear how the SA has informed the site selection process given that the reasons for why sites have been rejected have been inserted into the SA from elsewhere in the evidence base. This approach is therefore contrary to the approach required in national policy.

The SA should therefore be updated in response to the issues raised and Site 170 (Land east of Brookhouse Lane) allocated.