Policy SA1 – Strategic development location: Land East of Bilbrook

Object

Representation ID: 3986

Received: 22/11/2022

Respondent: Mr D Kalra

Legally compliant? No

Sound? No

Duty to co-operate? No

This 'consultation' is anything but a consultation. I'm a Bilbrook resident for 35 years and I find it difficult to identify exactly where you propose the new build area. The map showing the position does not have any road markings to help this. This is a token consultation and it's a shame that I, as a resident and tax player living in Bilbrook, is not given opportunity to properly comment.

Object

Representation ID: 4018

Received: 02/12/2022

Respondent: Mr Michael Westhead MBE

Legally compliant? No

Sound? No

Duty to co-operate? No

The roads listed are not fit for purpose now BARNHURST LANE is a death trap and the other roads are no better they are B roads and only just holding up to the current traffic we don’t have enough infrastructure to facilitate 900 plus homes the trains are very unreliable and we should revamp what we have not build more

Object

Representation ID: 4040

Received: 03/12/2022

Respondent: Mr Louie Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

Refers to National Planning Policy paragraphs 137-151.

Development of Green Belt is unkind, unlawful and completely unfair as no residents of Bilbrook welcome this. Action needs to be taken on previously developed land around the uk. There is no need for these houses in Bilbrook as the demand is not there. This development would drive this village to abandonment. Green Belt is one of the most important reasons residents live here.

Object

Representation ID: 4125

Received: 20/12/2022

Respondent: Mrs N Turner

Legally compliant? No

Sound? No

Duty to co-operate? No

I disagree with the huge number of houses planned for a
Small area. Main objection is lane green road is not suitable for access to other roads. Already lots of traffic, both ends of the roads are difficult junctions, parked cars down the length of the road often mean driving on opposite side of the road while not being able to see oncoming traffic. I drive down this road almost everyday during school run, the additional traffic created from proposed plan would be unsafe and cause major traffic issues.

Object

Representation ID: 4152

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 and DS5

Object

Representation ID: 4238

Received: 23/12/2022

Respondent: Bilbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Bilbrook Parish Council recognises that Bilbrook needs new houses however the 848 proposed for land East of Bilbrook (allocation 519 of the emerging local plan) is excessive. The Parish Council's emerging Neighbourhood plan support this.

Although the plan fulfils to duty to co-operate, the Parish Council does not agree with it as it sacrifices Bilbrook Green Belt when there are Brownfield sites in the Black County which could be used instead.

Object

Representation ID: 4282

Received: 22/12/2022

Respondent: Member of Parliament for South Staffordshire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

National policy has changed significantly, especially in December 2022, and significant updates should be made to the plan. The written statement made on 6th December by the Secretary of State announced several changes, including a move to make housing need targets advisory. The district council should take advantage of these material changes to ensure that the character of our communities and our Green Belt are properly protected. A commitment was also given to allow a two year period for plans to be revised for plans at an advanced stage of preparation.

The Local Plan should be paused while these changes take effect, revise down its housing numbers in line with new proposed guidance and ensure it can protect as much Green Belt as possible.

Object

Representation ID: 4331

Received: 21/12/2022

Respondent: Mr M Sedgemore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to Site 519 as it is contrary to paragraphs 137 to 151 of the NPPF.

Comment

Representation ID: 4334

Received: 23/12/2022

Respondent: The British Horse Society

Walking and cycling routes are included with no mention of equestrian access. ‘Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users’ (NPPF, s100).

Object

Representation ID: 4364

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council is seeking an excessive area of land for new housing development in this location. Gross site areas are at unduly low densities and no detail is given of net developable areas, maximum numbers of dwellings or land requirements for other uses. No detail is given of infrastructure needs such as highways, drainage/sewerage, playing fields and associated facilities. No information is provided on funding, phasing or thresholds for provision of facilities and services.

Land East of Bilbrook only requires 24.2ha of land at the Council's minimum density of 35dph.

Object

Representation ID: 4391

Received: 22/12/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Clause within policy relating to historic environment needs to be site specific rather than referring to a separate document - this is not a sound approach. We would require any application to be supported by archaeological investigations (pre-determination) so that the design of the scheme and archaeological mitigation can address the significance and importance of remains. We would require this to be set out in policy.

Support

Representation ID: 4413

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes has worked collaboratively with the Council, the City of Wolverhampton City Council, other stakeholders, infrastructure providers and the Council’s masterplanning consultants in developing a shared Vision and set of Objectives for the new neighbourhood east of Bilbrook.
In respect of Land East of Bilbrook, the proposed strategic housing allocation, provides an opportunity to deliver up to 800 dwellings alongside new infrastructure as identified in Policy SA1. The key infrastructure and design requirements set out in Policy SA1 are supported by Bloor Homes.
Bloor Homes’ land interests extend to all land within the proposed East of Bilbrook allocation, with agreements in place between the landowners and Bloor Homes, providing confidence that a comprehensive and co-ordinated approach to development can be achieved in its delivery. Bloor Homes can demonstrate the site is suitable, available and achievable, with further information provided within Chapter 12 of this representation (see attachments) and the Development Framework document attached at Appendix 2 (see attachments).

Comment

Representation ID: 4501

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4531

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4557

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4614

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. It is considered a more detailed housing trajectory should be
included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4670

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. Keon Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Object

Representation ID: 4695

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

It is illogical to determine the number of houses in a strategic location to meet the ambitions of the LEA to build a new first school. Further, it is the view of Bilbrook PC that the current school is adequate to serve requirements without the addition to the urban extension. The willingness of the developer to provide a first school should be irrelevant and unjustified; this would need to be done anyway for a scheme of its size.

Paragraph 8.39 of the Strategic Growth Study identifies the strategic separation between Wolverhampton and Codsall/Bilbrook as 'notable'. This allocation will remove this gap, and be compounded by local employment development.

The 2018 Green Belt review does not point to the allocation of SA1 (land east of Bilbrook). Further, the 2014 LUC Method Statement identified that Parcels 1 and 3 to the east of Bilbrook made a considerable contribution to the purposes of Green Belt: they had a 'strong' impact upon purpose a, and a 'moderate' impact upon purpose b. This harm is acknowledged in the Housing Site Selection Topic Paper, whilst the illustration in paragraph 5.41 does not indicate the true impact upon the Green Belt.

The site conflicts with the recommendations and findings of the Strategic Growth Study 2018 (where development to the east of Codsall/Bilbrook was warned against), and the Green Belt Study identified as having a 'strong' purpose.

Comment

Representation ID: 4696

Received: 23/12/2022

Respondent: National Highways

With regard to policies SA1 to SA4 we have south to agree a methodology with Staffordshire County Council (as local highways authority). This uses the SATURN model for the M54 - M6 link road proposal to inform site promoters' own technical assessments. This will inform the need for any form of highway mitigation works on the SRN, which is still to be determined.

Comment

Representation ID: 4710

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. Lovell Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4744

Received: 21/12/2022

Respondent: Environment Agency

We welcome the addition of a Level 2 SFRA. The Level 2 SFRA shows that the critical 1 in 100 year plus climate change flood extent encroaches (albeit largely into public open space) on sites 119a, 284, 139, Land North of Penkridge, SA1 and SA4. The SFRA confirms that for the majority of these sites the encroachment is only minor.

All these sites will therefore require a site specific FRA which shows development laid out as to avoid the floodplain and finished floor levels 600mm above the 1 in 100 plus climate change flood level. This should be detailed within the allocation requirements. In addition, the quantum of development should be reviewed to ensure that it can fit onto the area outside the 1 in 100 plus climate change flood event, with particular note of 119a which shows about a third of the site affected by flooding.

Although referenced within the Sustainability Appraisal it is unclear where the evidence sits to clearly demonstrate how the proposed site allocations have had the Sequential Test applied as is required by Paragraphs 161 and 162 of the NPPF. We recommend however given the proximity of the fluvial floodplain, residual risk should be mitigated for by it being required that finished floor levels are set at or in excess of 600mm above the 1in 100 year plus climate change for that specific location.
• Site Ref 617
• Site Ref 646a.
• Site Ref 646b

Comment

Representation ID: 4746

Received: 21/12/2022

Respondent: Environment Agency

Sun Valley Foods Billbrook, located on the Balliol Business Park is regulated by the Environment Agency. The site is currently surrounded by agricultural land and industrial development but the proposals under site Ref 519 would bring the large housing development approximately 75m from the facility. Food production operates 24/7 which includes the use of ovens and fryers to cook the food and chiller units to freeze the product before it leaves site in refrigerated trailers. The facility also has effluent treatment, external storage of waste product and of course incoming and outgoing vehicle movements with audible alarms, therefore there is a possibility that amenity issues could be experienced. Bilbrook HWRC, a small well run site currently owned by Amey Highways is also nearby. There does remain potential for this to be a problem if residential receptors are brought closer to the site than at present.

We recommend your planning policies ensure that appropriate assessment and mitigation can be carried out by the agent of change (ie residential allocations). Where any mitigation is not practical, properties should not perhaps be built close to the site perimeter. We recommend strategic policy SA1 references the risks associated with their proximity to such facilities, and the need for assessment and/or mitigation measures in order to inform and steer the masterplanning process.

Comment

Representation ID: 4770

Received: 19/12/2022

Respondent: Sport England

Sport England welcomes the site requirement for enhancement of and provision of additional playing pitches and associated facilities. However the scope of work is not clear. The policy is also not consistent with Future Playing Pitch Requirement 2022 Topic Paper which states that the strategic sites would contain on site playing pitch and changing provision.

Comment

Representation ID: 4775

Received: 23/12/2022

Respondent: Terra Strategic

The Council should ensure that the proposed timescales for the delivery of their larger strategic sites are
realistic. The strategic allocations should also be supported by a sufficient supply of smaller sites which
are readily available and deliverable to ensure the Council has a robust supply, in line with paragraph 69
of the NPPF. Land available for housing delivery within the District is restricted by the Green Belt. Therefore, the Council should consider allocating additional sites outside of the Green Belt which are available, deliverable and achievable within the Plan period, such as Land at Penkridge Road, Acton Trussell.

Object

Representation ID: 4850

Received: 21/12/2022

Respondent: John Davies Farms ltd.

Agent: Berrys

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In summary, there is significant reliance on the delivery of housing on four strategic sites where considerable uncertainty remains over the potential rates of housing delivery. In addition, these sites will result in ‘high’ or ‘very high’ levels of harm to the Green Belt that could potentially be avoided by allocating land in other areas, such as land in Tier 4 settlements.

As a consequence, the Plan is considered to be unsound as it is not justified (is an appropriate strategy, taking into account the reasonable alternatives) nor effective (deliverable over the Plan period).

Comment

Representation ID: 4961

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Barratt has no objection to the allocation of land to the east of Bilbrook. Consider that the development of Site Reference 500 forms a logical extension to Strategic Allocation SA1 and pedestrian and green infrastructure links could be provided to strengthen the accessibility and environmental net gain of the overall allocation. It is not considered that the ‘constraints’ identified within the SHELAA hinder the site’s potential to deliver housing. The proposed Concept Plan for Site SA1 also shows that the proposed school and community hub within Site SA1 is in close proximity to site 500 so although it is currently detached, the provision of these facilities will make the east of Bilbrook even more sustainable than it already is. The extension of Site SA1 to include Barratt’s land (Site 500) will also mean that more housing is being directed to the most sustainable settlement in the District which accords with SSDC’s proposed spatial strategy.

The SHELAA 2022 states that the key constraints are that the ‘site is disassociated from any village development boundary’ and that a small part of the site is within Flood Zone 3. The SHELAA states that small part of the site (ref 500) within Flood Zone 3 has been removed from the overall area which Barratt supports and considers is not a constraint that would impact on the site being delivered for housing. Proposed built development can be directed to Flood Zone 1 areas within the site.

Challenges transport and landscape / green belt assumptions made on the site.

Comment

Representation ID: 5078

Received: 23/12/2023

Respondent: Living Space Housing

The Council should ensure that the proposed timescales for the delivery of their larger strategic sites are realistic in light of Lichfield's Start to Finish report. The strategic allocations should also be supported by a sufficient supply of smaller sites which are readily available and deliverable to ensure the Council has a robust supply, in line with paragraph 69 of the NPPF.

Object

Representation ID: 5087

Received: 17/12/2022

Respondent: Mr D Bodley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bilbrook and Codsall have already been detrimentally impacted by previous development.
More cars will lead to increased emissions, congestion, and damage to roads.
Medical facilities have not been expanded; getting access to them along with parking spaces, school places and leisure facilities will be even more difficult.
Local people should be informed of whether the site is acting as Birmingham 'over-spill'.
This site should be rejected as a further development opportunity.

Object

Representation ID: 5415

Received: 22/12/2022

Respondent: Mr R Draisey

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object, number of houses exceeds requirements. Loss of Green Belt. Contrary to paragraphs 137-151 of NPPF.

Object

Representation ID: 5419

Received: 17/12/2022

Respondent: Mr A Duggan

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to site 519. Increase in traffic in and around Bilbrook/Codsall. Need to modify following three existing junctions to address traffic issues including minimising accidents and prevent bottlenecks
Lane Green Road to the offset junction with Birches Road
Lane Green Road to the Woodman Junction
Barnhurst Lane T junction to Pedeford Mill Lane.
Would costs be bourne by the developers?