Policy SA4 – Strategic development location: Land North of Penkridge

Comment

Representation ID: 4023

Received: 17/11/2022

Respondent: Ms P Hughes

Roads can't support increased traffic, particularly during the construction stage. After new development, 5 new primary schools will be feeding into 1 middle school and 2 secondary schools, creating extreme pressure on existing services.It is incredibly difficult to get a doctors appointment in the village. There is no nursing home/care facilities in the village beyond the existing sheltered/supported living facilities. Rather than planning for new leisure and community facilities development should improve existing facilities in the village. The village needs a large supermarket, not small scale out of centre shops. The new development will create a separate and isolated community without necessary services to support it.

Comment

Representation ID: 4063

Received: 11/12/2022

Respondent: Mr A Bradley

Very concerned about Land North of Penkridge. No increase in medical or educational provision in village despite two large developments recently. Can't get appointment with doctors and schools are already full. Long waiting list for NHS dental care. What is proposed to address these issues? A449 is already extremely busy at peak times and is affected when there is an accident between M6 junction 12 and 13. Proposal for Rail Hub at Four Ashes also affects traffic. What plans are there to protect village quality of life?

Object

Representation ID: 4129

Received: 20/12/2022

Respondent: Bloor Homes Ltd and St Philips

Agent: Define Planning and Design Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The approach to directing growth to Land North of Penkridge, a suitable, available and deliverable site to the north of a sustainable settlement, is sound. The amendment to the site allocation boundary, and the resultant impact on site capacity, should be considered given that the emerging Masterplan robustly demonstrates a capacity of c. 1,000 dwellings. To ensure that the policy is sound, a number of tweaks are required to the policy requirements as set out in Policy SA4, which are set out in full above.

Comment

Representation ID: 4146

Received: 20/12/2022

Respondent: Cannock Chase AONB

Part (g) of the policy should make reference to considering and implementing mitigation for impacts on views from the AONB, e.g. through enhancing woodland on the eastern parts of the site and strengthening the north-south green corridor with tree and woodland planting. Also request a sensitive approach to lighting and control light spillage.

Object

Representation ID: 4202

Received: 22/12/2022

Respondent: Staffordshire County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan has not been positively prepared to consider how the West or Penkridge public land holdings can improve Penkridge and support the delivery of the North of Penkridge land. It does not take into account of how the scale of unmet housing need from the Birmingham and Black Country HMA will impact on the medium and long term sustainable growth of Penkridge by sterilising a large strategic public land holding West of Penkridge. Significant technical and masterplanning work for the West of Penkridge (and inc. North) have not been properly considered in Plan making process.

Object

Representation ID: 4216

Received: 22/12/2022

Respondent: Connectivity and Sustainability, Staffordshire County Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

At the preferred options stage, SCC undertook high-level traffic modelling concluding there should be no insurmountable transport problems. Following that, South Staffordshire Council requested developers produce more detailed Strategic Transport Assessments (STA) to demonstrate what transport infrastructure would be required to bring their sites forward.
SCC had concerns over some of the schemes and their deliverability within the Penkridge STA, though believe there will be a solution to bring this site forward.
It is understood the developers are updating the STA and SCC will continue to work with them and is confident that agreement can be achieved prior to examination.

Comment

Representation ID: 4224

Received: 20/12/2022

Respondent: Penkridge Parish Council

Bloor and Cameron sites are piecemeal development with no masterplan to incorporate developments and provide community benefit. Future housing developments should provide safe access to and adequate cohesion with the Village Centre. The design of any masterplan should reserve part of the spine road route necessary to support future housing to the west of Penkridge. Any new housing should connect to the village with alternative routes. There is the possibility for a new link across the River Penk and flood plain to the Teddesley Road. Concerns raised that the development on the west side of the A449 will not have safe and adequate crossings. Provision for extra car parking near the rail station and village centre is also required. The local plan review does not show any other small scale commercial sites or address concerns about adequate Doctors services. A Community Hub will only deflect from the use of existing services. There is capacity and land for an extension to the Middle school or even space for another first school at this site. The Local Plan review does not take seriously the opportunity to allocate the river flood plain areas both sides of the river connected by a new river bridge.

Object

Representation ID: 4285

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.

Comment

Representation ID: 4337

Received: 23/12/2022

Respondent: The British Horse Society

Active travel is referred to in terms of walkers and cyclists and is therefore not ‘inclusive’ as it purports to be. New developments and infrastructure design should provide opportunities to improve and extend the bridleway and byway network for the shared enjoyment of all vulnerable road users. ‘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: 4367

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.

At 35dph the area required for housing development would be 32.3ha.

Object

Representation ID: 4395

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. Clause (h) should include specific mitigation measures, there is no reference to historic environment in the reasoned justification text attached to the policy.

Comment

Representation ID: 4504

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: 4534

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: 4560

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: 4617

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: 4673

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: 4713

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: 4728

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.

Design of green infrastructure adjacent River Penk will need to consider environmental mitigation measures (e.g. noise) to address requirements of paragraph 45 of the Departmnet for Transport Circular 02/2013. The green infrastructure is also close to an AQMA (1 Woodbank).

Comment

Representation ID: 4743

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: 4747

Received: 21/12/2022

Respondent: Environment Agency

Lower Drayton Farm Anaerobic Digestion facility is permitted and regulated by the Environment Agency. The proposals put forward under site ref 420, 584 and 010 will bring housing development adjacent to the permitted area and potentially expose new residents to amenity issues such as odour and noise either from the permitted facility or waste haulage vehicles entering and exiting the site. We still have concerns about the indicative concept plan which includes a community park and other potential development site/sport pitches adjacent to the AD site. Development in these areas could place unreasonable restrictions or expectations on this existing facility as a result of development permitted after they were established.

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 SA4 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: 4778

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: 4812

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is important that the masterplan prepared for the site does not prejudice the fair delivery of development on Site 420, which is a key link between the exisitng built form of Penkridge and the main bulk of the strategic allocation north of Penkridge.

In terms of the requirements for a Transport Strategy for the site to be developed the plan appears to be supported by a Strategic Transport Assessment for Land North of Penkridge prepared by PJA and included within the Council's evidence base. We raise concerns regarding the status of this document given that we as one of the site promoters have not been provided with the opportunity to feed in to either its scope or contents.The current indicative masterplan does not include direct access to Trine's land from the A449 which should not be assumed as a previous planning application to the Council showed that this was achievable with no objections from the highways authorities.

In regard to the provision of a Community Hub within the development, this element of the proposed allocation should be supported by evidence. Evidence of the need for such uses must be presented for that requirement to be justified. Should appropriate evidence be provided, and the requirement retained, the policy should be updated to give specific guidance in relation to the floorspaces and use classes being sought, so that the policy requirement is clearly written and unambiguous in accordance with the NPPF.

The principles of part g) of the policy are supported. However, the requirement to provide compensatory Green Belt Improvements are somewhat confusing as they do not appear to apply to this site. The site is outwith the defined Green Belt and when cross referenced with the requirements of Policy DS2: Green Belt Compensatory Improvements the development of the site falls outside of the scope of this policy. The need for the riverside linear park is understood but this should not be a compensatory requirement for the removal of other sites within the District or Penkridge from the Green Belt and in any event any compensatory improvements should be undertaken within the Green Belt. As such reference to compensatory Green Belt improvements should be removed from the policy.

Object

Representation ID: 4853

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: 5022

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

This site is 51ha in size and sits to the north of Penkridge, which is a tier one town. Whilst a tier one town, there are limited facilities within Penkridge with just local convenience store.
The digestion plant was first approved in 2016 and revised in 2019. These facilities are subject to stringent safety precautions and large buffer areas (cordon sanitaire) due to their operations which can generate odour, noise and significant HGV movements. When permitted, the LPA noted the rural nature of the surrounding and this fed into the reason for approval.
It is also important to note, that Penkridge is almost entirely reliant on the A449 for access. This is a single carriageway road running north south through the centre of Penkridge. It is noted that the site is located in close proximity to the M6, however junctions 12 and 13 are both located in the region of 4km away to the south and north. This would result in all vehicles utilising the A449 single carriageway road for access.
Based on the above, and given the number of uncertainties, Vistry maintain that it is not possible to determine the level of housing and development that the allocation can provide and deliver by 2039. It is highly likely that the total capacity will be far below the 1,129 currently proposed.

Comment

Representation ID: 5081

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.