Policy SA2 – Strategic development location: Land at Cross Green

Comment

Representation ID: 3989

Received: 23/11/2022

Respondent: Inland Waterways Association (IWA)

Requirement e) includes active travel links to “the nearby canal towpath network”. However, the canal towpath is on the opposite (west) side of the Staffordshire & Worcestershire Canal from the allocation site with the only bridges at Cross Green Bridge 71 and Brinsford Bridge 70 being outside the allocation boundary, so it is not clear how this will be achieved. Any proposal for a new foot/cycle bridge crossing of the canal should be of high quality design to respect the canal’s Conservation Area status and be subject to early consultation with CRT and IWA.

Object

Representation ID: 4118

Received: 14/12/2022

Respondent: D Morgan PLC

Agent: Peacock and Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Sustainable development should utilise public transport, provide a genuine choice of transport modes - Site SA2 fails to achieve this. Allocated in a rural location for significant growth despite being in Tier 3 Coven. Site is remote from any railway stations, not within Cannock Town Centre Catchment Area or Travel Zone, and only served by a very limited bus service. Does not meet NPPF para 142 requirements for Green Belt release.

Object

Representation ID: 4153

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 & DS5

Comment

Representation ID: 4205

Received: 22/12/2022

Respondent: Connectivity and Sustainability, Staffordshire County Council

E) This could be read as only providing connections to external cycle / walking routes and not necessarily providing new external routes or enhancements. e.g. a link to the canal towpath rather than upgrading towpath to ensure it is fit for purpose. Suggest it is reworded.
K) This references infrastructure requirements and does include education. Does infrastructure include Home to School Travel, as this may also be required for this site.
Suggest Policy is changed to read:
K) Necessary contributions towards offsite infrastructure, including highways and active travel mitigation measures, education including school transport, leisure and health provision.

Object

Representation ID: 4283

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: 4306

Received: 21/12/2022

Respondent: Brewood and Coven Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Street signs indicate Coven Heath starts at the junction of the Old Stafford Road and A449 and continues southwards to the M54 Junction 2. This includes Sites 646a&b.

On page 57 (map): change name to “Land at Coven Heath”.
On page 64: change headline to “Land at Coven Heath”.
In page 64 para. 6.12 and Policy SA2: change all “Cross Green” to “Coven Heath”
In page 65 para. 6.13: change “Cross Green” to “Coven Heath”
In Appendix B, on page 176 (map): change name to “Land at Coven Heath”.

Comment

Representation ID: 4335

Received: 23/12/2022

Respondent: The British Horse Society

Active travel 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: 4365

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.

No neighbourhood centre is shown on concept plan and no land requirements are given. At 35 dph only 34.3ha of land is required, leaving 20ha for other uses. Includes a primary school despite a three tier system being in operation here. Unclear where secondary school children will be accommodated. Have Education Authorities in Wolverhampton and Staffordshire agreed education provision and funding? No explanation given around areas for development or sports pitches. New rail station and neighbourhood centre are not located centrally. Only Site 646b has a frontage to the A449. Site access to 646a is unsatisfactory, what have the highways authority said? No evidence from Network Rail of agreement to new station on this aprt of the West Coast Main Line, no feasbility or viability assessments or information such as funding. Unclear how station will be supported by development. No indication of public transport services (bus). How has the Duty to Coopearte been met in relation to the new road crossing the railway?

Object

Representation ID: 4392

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. Request that the specific mitigation measures are incorporated into the policy wording and amend existing wording from 'preserving and potentially enhancing tree and hedge boundaries' to 'conserve existing tree and hedge boundaries and enhance their provision to...'

Comment

Representation ID: 4502

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: 4532

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: 4558

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.

Support

Representation ID: 4577

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey recognises the importance of the four proposed strategic housing allocations in delivering the spatial strategy for the District to 2039. Due to the scale of the four sites, Taylor Wimpey supports the inclusion of site-specific policies to establish a vision for each site, alongside a requirement for a detailed masterplan and design code.
Taylor Wimpey supports this Vision, Objectives and the resultant indicative Concept Plan contained within the Publication Plan. This will form the basis of further technical work and the preparation of a comprehensive masterplan and design code to inform a future planning application.
In light of the required Strategic Masterplanning process progressing it is requested that Policy SA2 refers to the delivery of approximately 1,200 homes rather than specifying this as a minimum requirement. The appropriate number of homes to be delivered and density achieved on site will be considered further through the required masterplanning process outlined within the Local Plan.

Comment

Representation ID: 4615

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: 4671

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.

Comment

Representation ID: 4711

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: 4726

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.

SA2 includes safeguarded land for a parkway station, which will require early consultation with National Highways to ensure the appropriate assessments are carried out in accordance with DfT 02/2013 and the DMRB. This is to identify the need for and form of mitigation required for the SRN. The northern part of SA2 is separated from the south by green infrastructure, suggesting traffic in this area will use the existing road network. The southern parcel sits in close proximity to the M54 and is likely to use the existing Local Road network and A449 Trunk Road junctions (i.e. Brewood Road from the southern Coven roundabout and Old Stafford Road approx 500m to the south). These junctions will need to be assessed for safety and capacity, with appropriate improvements identified as necessary. In addition, the need for land for noise mitigation will need to be considered. Land considerations for traffic capacity improvements to the adjacent M54 will also need to be considered, along with land for environmental mitigation (e.g. noise attenuation). National Highways surface water drainage assets exist close to the site boundary and it will need to be shown that these benefit from protection from site surface water discharge.

Comment

Representation ID: 4745

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: 4776

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.

Comment

Representation ID: 4839

Received: 22/12/2022

Respondent: David Wilson Homes

Concerns regarding ROF Featherstone road access and its impact on Cross Green's viability and deliverability trajectory given the funding estimate for the road set out in the IDP.

In the context of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the anticipated number of homes to be delivered before 2039.

Lichfields’ Start to Finish report (February 2022) indicates it is reasonable to assume 160 dwellings per annum (dpa) to be delivered on sites of Cross Green’s scale. In total, it is therefore likely that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore prepare further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,000 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District.

Object

Representation ID: 4851

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).

Object

Representation ID: 4880

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We have no objection in principle to the proposed allocation at Cross Green, however we have some concerns regarding the scale of delivery anticipated for the proposed plan period given infrastructure delivery.

Firstly, there are concerns regarding the access road to ROF Featherstone and the associate costs and the potential impacts on Cross Green’s viability and delivery
trajectory. The IDP now estimates the cost of delivering the access road at £14.4m-£19m, to be funded via Staffordshire County Council and developer contributions. Evidence should be provided as to how this will be funded. The only funding evidence to date is reference to £1.5m of Growth Deal funding being made available via the Stoke-on-Trent and Staffordshire Local Enterprise Partnership.

Secondly, mindful of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the site’s proposed quantum of housing growth
(1,200 new homes).

The Lichfields Start to finish report shows that the lead in times and delivery rate are ambitious.

In total, it is therefore assumed that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore consider preparing further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,200 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District (such as additional land available at the land off Hyde Lane (west) and Dunsley Drive, both at Kinver).

If the delivery rates cannot be evidenced than the following modification to draft policy SA2 at part a) will be necessary: “a) A minimum of 1,000 homes”

Comment

Representation ID: 4917

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

We have no objection in principle to the proposed allocation at Cross Green, however we have some concerns regarding the scale of delivery anticipated for the proposed plan period given infrastructure delivery.

Firstly, there are concerns regarding the access road to ROF Featherstone and the associate costs and the potential impacts on Cross Green’s viability and delivery
trajectory. The IDP now estimates the cost of delivering the access road at £14.4m-£19m, to be funded via Staffordshire County Council and developer contributions. Evidence should be provided as to how this will be funded. The only funding evidence to date is reference to £1.5m of Growth Deal funding being made available via the Stoke-on-Trent and Staffordshire Local Enterprise Partnership.

Secondly, mindful of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the site’s proposed quantum of housing growth
(1,200 new homes).

The Lichfields Start to finish report shows that the lead in times and delivery rate are ambitious.

In total, it is therefore assumed that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore consider preparing further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,200 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District (such as (such as Bellway’s site at Strathmore Crescent).

If the delivery rates cannot be evidenced than the following modification to draft policy SA2 at part a) will be necessary: “a) A minimum of 1,000 homes”

Comment

Representation ID: 4945

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

It now appears that SA2 only “safeguards” the land for the potential rail-based parkway with no requirement for it to be provided (in contrast to previous Infrastructure Delivery Plan’s implicit indications). The release of green belt with assessed “very high” harm in this location appears to have far less justification now in the context of the proposed “infrastructure led” approach.

Object

Representation ID: 5021

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

Land at Cross Green is proposed as an ‘employment led new settlement/site,’ rather than an urban extension. Such a classification is rather strange, given that the allocation does not actually include any employment provision within it. Vistry consider that the specific allocation at Cross Green, through the polies MA1 and SA2 is unsound. This is because there is no certainty of its delivery within the plan period arising from:
• The anticipated timescales of key transport infrastructure directly affecting, and required for the site, and the lack of transparent evidence around this,
• Uncertainty on the actual yield of the site, and
• Resulting design, layout and severance issues which lead to a less than sustainable development.
The aforementioned permission, and its Transport Assessment, inevitably because of the timing of the application submission, does not include any allowance or assumptions for a development of 1,200 houses and/or a 500 space rail based park and ride station now required by the Local Plan. The planning permission requires development to commence within the standard 3year timescale, and although this access was submitted in full, conditions still require considerable detailed submission to be agreed with the highway Authority, and presumably Network Rail in respect of the overbridge to the mainline railway.
From a Property perspective there is no evidence that (i) the costs associated with the ‘shared’ value (ransom) payment that will be needed to be agreed with Network Rail to cross the mainline, has been accounted for in any viability study, (ii) that the cost of the on-site infrastructure necessary to cross the railway (and underground existing power supplies) has been accounted for including (a) the payment of an ‘Easement Fee’ which has to be negotiated by the Developer (whilst Network Rail will not fetter the delivery of employment or housing, they are obliged, as a public entity, to get best value from granting rights over the railway), and (b) a ‘maintenance payment’ which is compensation for ongoing monitoring for future maintenance usually sought from the Developer for a considerable period of time – there will be a cost to the housing development notwithstanding the separate permission for the access road over the railway.
It is Vistry’s submission that these master planning requirements cannot start to be progressed at least until there is confirmation that the rail park and ride, and main access infrastructure has been confirmed. Without this, the delivery of , 1,200 dwellings through comprehensive and co-ordinated place making is compromised.

Comment

Representation ID: 5079

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: 5411

Received: 08/06/2023

Respondent: Coven Heath Community Association

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site inaccurately identified, the site is predominantly within Coven Heath and not Cross Green. All reference in the plan document to Cross Green should be changed to Coven Heath.

Object

Representation ID: 5516

Received: 22/12/2022

Respondent: Victoria Barns Residents

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The existing Strategic Transport Assessment has been undertaken by the site developers which creates a conflict of interest. No other developer will be able to facilitate this development.
Brinsford Lane – study projections seem insignificant however this will be a proposed main access for the development and travel to the proposed park and ride. The study suggests that the railway bridge would be a pinch point, this bridge has space for one vehicle and a low height restriction. The study downplays what is likely cause multiple traffic issues.
Widening Brinsford Lane would not be an option as Victoria Barns is situated directly on the lane with no footpath or border.
Proposal would have a negative impact on a local sporting club (Wolverhampton Casuals) whose supporters use the lane for parking during fixtures.
Brownfield sites should be released before Green Belt
Changes within Central Government policy are now scrapping housing targets which destroy the character of villages and towns.
Responses from local residents have not been taken into account, this is an unsound planning approach.
Negative impact on wildlife, environmental landmarks and will increase pollution levels.