Policy SA5: Housing Allocations

Support

Representation ID: 4844

Received: 20/12/2022

Respondent: Mr Peter Wilkes

Agent: Berrys

This policy is supported insofar as it relates to housing allocation 119a (Cheslyn Hay) for land adjoining Saredon Road for a minimum capacity of 60 dwellings. This allocated site will be encompassed within the development boundary of Cheslyn Hay which is identified as a Tier 1 settlement offering a sustainable location for housing development. The development of this land for housing is viable and deliverable within the plan period and active liaison is currently ongoing to bring the site forwards early in the plan period. Therefore, this housing allocation will be delivered to meet the districts housing target up to 2039.

Object

Representation ID: 4849

Received: 21/12/2022

Respondent: John Davies Farms ltd.

Agent: Berrys

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy SA5 of the Publication Plan proposes a number of site allocations that, as detailed in the Green Belt Study (2019) (table 7.1), would result in ‘moderate-high’, ‘high’ or ‘very high’ levels of harm to the Green Belt.
Such sites include sites 224 Codsall, 523 Cheslyn Hay, 536a Great Wyrley and 582 West of Wolverhampton. The release of these sites will therefore result in a weakening of the Green Belt, for example by leaving a narrow
gap between towns, increasing its containment by urban areas or by isolating an area of Green Belt that makes a stronger contribution (as detailed in paragraph 6.23 of the Green Belt Study).
Given the above, it is considered that growth proposed on allocations that would result in significant levels of harm (moderate-high and above) to the Green Belt, should be directed to sites where a lesser degree of harm
would arise and where the level of growth would ensure that the Plan:
- plans positively for the provision of housing sites of less than one hectare through the allocation of land (in accordance with paragraph 69 of the NPPF), as detailed in the representor’s objection to policy DS5;
- meets housing needs of lower tier (tier 4) settlements (in accordance with paragraph 78 of the NPPF), as detailed in the representor’s objection
to policy DS5; and
- maintains and enhances the vitality of rural communities and their local services (in accordance with paragraph 79 of the NPPF), as detailed in the representor’s objection to policy DS5.

The Plan is therefore considered to be unsound as it not justified (is an appropriate strategy, taking into account the reasonable alternatives).

Object

Representation ID: 4856

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, the Plan fails to ensure that housing development needs will be met and it is inconsistent with national planning policy. As a consequence, the Plan is considered to be unsound as it is not positively
prepared (meets the area’s objectively assessed needs), justified (is an appropriate strategy, taking into account the reasonable alternatives), effective (deliverable over the Plan period) or consistent with national policy.

Object

Representation ID: 4861

Received: 22/12/2022

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

‘Site 096, Land off Offoxey Road and Ivetsey Bank Road’ should be allocated and the development boundary for Bishops Wood redrawn, as the site has no key constraints to development with the exception of Green Belt that will apply to the majority of site options. Green Belt review findings for the parcel within which site 096 sits is incorrect. On re-evaluation the site should have a moderate harm score if all of the site was developed, and a low-moderate score if only partly developed. An initial assessment has been undertaken by the site promoter for highways, sustainable travel, ecology, drainage, flooding that confirms appropriate mitigation can be secured and there is no unmitigable constraints. The site can deliver some key community benefits including a convenience store to serve the village and drop off parking for the school.

Object

Representation ID: 4863

Received: 22/12/2022

Respondent: Croft Development Consultancy UK Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 474, land at Longford House, A5 Cannock Road.

The part of the site located within Cannock Chase administrative boundary is now proposed to be removed from the Green Belt and allocated in their Reg 19 plan as a strategic housing allocation. The same justifications which Cannock DC have applied can also be applied in South Staffordshire. More weight should be given to a comprehensive development with Cannock DC allocation.

This site is strategic site in a sustainable location that can meet the needs of Cannock and the Black Country. Development of the site would not impact upon the openness or character of the area. It will relate well to the existing built area, is PDL, and is well served by public transport and community facilities.

Object

Representation ID: 4865

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Land North of B4176 and East of A449, Himley should be allocated for housing and added as a site at in Policy SA5/Appendix C. The representation sets out a number of site specific factors to show that the site is suitable and deliverable.

The site is in a sustainable location and is very well located to meet housing requirements for the plan area and the overspill needs of the Black Country being in close proximity to the conurbation and wider range of higher order employment, services and facilities. The site is a medium size site with minimal infrastructure required, ensuring hosing will be delivered early in the plan period.

Exceptional circumstances exist to release the site from the Green Belt which is in a sustainable location close to the Black Country, particularly as South Staffordshire is failing to meet its Standard Method housing requirement and the 4000 home contribution represents a insufficient contribution towards unmet needs, and fails to have regard to the proper provision for affordable housing.The Duty to cooperate has therefore not been addressed in any meaningful way.

There will be no “unrestricted sprawl” of a large built up area from the site or a material impact on coalescence. There are no reasonable options for meeting the identified needs other than the release of greenfield sites in the Green Belt in South Staffordshire and therefore the
policy tests of paragraph 141 of the Framework is met. For these reasons it is considered that exceptional circumstances exist and that the omission site is well placed to help to meet some of the overspill requirements from the Black Country and also South Staffordshire’s own needs. As drafted the plan fails the tests of soundness.

Object

Representation ID: 4867

Received: 23/12/2022

Respondent: Bruton Knowles

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Omission Site 094, land at Primrose Close, Wheaton Aston, is a logical and sustainable extension to the village - without encroaching towards any settlement - and can provide a residential development in complimentary scale and character to the existing built form. Development would deliver affordable housing, contribute to local infrastructure and community services, and improve access to the adjacent school.

The SHELAA 2022 identifies the site as suitable subject to access, the landowner and Shropshire Homes (promotional partner) are in discussion with a third-party to identify a developable access.

The site is located in Open Countryside, and there are no significant physical features preventing development - including the land being flat - and technical work has identified that any development would have minimal landscape, environmental, and heritage impacts. The site is located in Flood Zone 1, and there are no remediation or contamination issues.

The site is sustainably located in close proximity to village services. The village is serviced by public transport with buses to Stafford, Brewood, and Wolverhampton.

Development would increase the safety of the playing field by providing enhanced surveillance and active frontages.

Comment

Representation ID: 4881

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Hyde Lane (west) (Housing Allocation 576)

We continue to support the principle of the proposed release of land at Hyde Lane (west) from the Green Belt and allocation for housing growth. The Council’s evidence base is clear it performs better than other options at Kinver.
The southern and western edges of Kinver are significantly constrained by the Canal Conservation Area; Kinver Hillfort scheduled ancient monument and the Rock houses, as well as Flood Zones 2 and 3. Land to the north west is constrained by highway capacity and access. In this context, land west of Hyde Lane (as well as land to the east of Dunsley Drive) represents a sustainable location for accommodating future growth
in Kinver village.
The increase in the minimum housing allocation to 44 homes and the associated amended allocation boundary is welcomed, it reflects Option 3 of the Vision Document.
Bellway also support the provision of green infrastructure to the east, which will allow the provision of new open space, biodiversity enhancements and Green Belt
compensatory improvements.

Object

Representation ID: 4883

Received: 20/12/2022

Respondent: Mr Andrew Jones

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Omission sites 163 and 163a, land off Sneyd Lane.

Insufficient consideration has been had to this proposal to create a new road that would relieve the traffic from Upper Sneyd Road and Sneyd Lane and take traffic off Bursnips Road and Essington Road. The proposal is to prevent through traffic using Upper Sneyd Road and Sneyd Lane.

Sites 163 and 163a should be allocated for residential use as 361 dwellings, to facilitate the construction of a new east-west link road between Kitchen Lane and Vernon Way. This would provide access to the new dwellings and protect Sneyd Lane and Crab Lane as direct access to Bursnips Road would be through Vernon Way, creating less of an impact upon local roads.

The site would be able to provide for DtC unmet needs, and Walsall Housing Group.

The site would make a significant contribution to the regeneration of Bloxwich and Walsall under the Willenhall Framework Plan. Development may also provide an opportunity for the former Sneyd School and Sneyd Local Nature Reserve.

The site is of lower agricultural grade quality than the Linthouse Lane proposal.

The site is well connected to the immediate locality and wider district, and is the same proximity to Essington as the proposed Linthouse Lane allocation. It is a short walk to local schools and the public transport network.

The site is not visible from Essington, and the M6 provides a visual barrier from the east. Although the SHELAA indicates this proximity as a noise issue, the introduction of electric vehicles will decrease the level of noise. A masterplan would design a sound mound adjacent to the motorway which could be used for public open space.

Comment

Representation ID: 4884

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land south of White Hill (Housing Allocation 274)

Bellway has concerns regarding the likely impacts of developing this site.
As demonstrated by the EDP Heritage and Landscape Technical Note enclosed at Appendix 2, in terms of heritage impact, although the site’s ‘less than substantial
harm’ to the Kinver Camp Scheduled Monument is not an in-principle issue, NPPF paragraph 199 requires the Council to afford the ‘greatest weight’ to the conservation
of the monument as a designated heritage asset of the highest significance. NPPF paragraph 200 states that ‘clear and convincing’ justification should be provided for
that harm, public benefits notwithstanding. There are other sites available in Kinver such as the additional land to the north of the Hyde Lane proposed allocation or the
de-allocated Dunsley Drive site which do not result in this level of harm and should therefore be preferable in the site selection process.
In landscape terms, EDP’s note states that to accord with the local planning authority's evidence base and the prevailing landscape and visual character of the site, the extent of residential development currently illustrated is deemed to be unacceptable. It is considered to represent an over-estimation of the site’s development capacity in
landscape and visual terms. The design response to the Staffordshire Way would result in a major permanent and irreversible adverse effect, a point reiterated in Kinver Parish Council’s minutes of the meeting held on 14 December 2022. The Council should therefore carefully consider alternative sites at Kinver such as Bellway’s additional land at Hyde Lane (west) discussed above and land east of Dunsley Drive discussed below which could come forward and deliver the same public benefits
(in terms of delivering much needed housing) with less harm to designated heritage assets and which will provide a better landscape and visual response.

Comment

Representation ID: 4885

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land east of Dunsley Drive (Omitted site)

Land east of Dunsley Drive was initially included proposed to be removed from the Green Belt and allocated for development up to an including the Preferred Options stage of the Local Plan Review, as housing site allocation 272 (Figure 2).
The allocation was for a minimum of 22 dwellings on a site featuring good access and a natural extension to Kinver. The 2021 Housing Site Selection Topic Paper stated that, unlike some of the other potential Green Belt sites around Kinver, the Dunsley Drive site is free from ’significant constraints’ (e.g. Highways Authority concerns, potentially significant impact upon the historic environment). Paragraph 5.7.8 noted that the site is of a similar landscape sensitivity to most other land around the village but is of lesser Green Belt harm than other sites in this area.
The HESA states that development on the site would not in itself compromise the cultural heritage value of the overall Conservation Area to the extent that the values
that led to its designation would be diminished. The Assessment contends however, that it would inevitably compromise the setting of the small character zone within the Conservation Area that is defined by Dunsley House and its hilltop position, as well asthe setting of the non-designated asset itself. The HESA states that mitigation is unlikely to be possible and therefore a high (red) impact is predicted.
The site does adjoin the Conservation Area in the far east (where it extends to include Dunsley House – a ‘positive’ building within the Conservation Area). The site does form part of Dunsley House’s setting, however in the context of the Conservation Area as a whole, its contribution to Dunsley House’s significance (the Conservation Area’s special interest) is likely to be very small and so the ‘harm’ arising from its development would also be ‘very small’. In terms of the NPPF this harm would, at worst, be less than substantial harm towards the lowest end of that broad spectrum.
The evidence base enclosed with these representations also demonstrates the site is not subject to any constraints which cannot be overcome. As such the evidence base does not justify the omission of land east of Dunsley Drive as a proposed allocation.
Policy SA5 should therefore be modified to reduce the capacity of land south of White Hill or delete it completely, to reflect its constraints (in particular heritage) and the additional land north of the proposed Hyde Lane allocation and / or the omitted Dunsley Drive site should be added into the policy for a minimum capacity of around 40 homes each.

Object

Representation ID: 4902

Received: 23/12/2022

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of Sites 463 and 284 are not sound. The NPPF (para 175) requires plans to allocate land with the least environmental or amenity value. There would be significant landscape and visual harm from the sites as identified in the accompanying assessment by ZLA. This also identifies impacts to the Wombourne Conservation Area. Release of the land is considered more detrimental to Green Belt purposes than Site 283 due to the accompanying ZLA assessments. The plan does not address whether the highways works to deliver the site are feasible and deliverable or their affect on viability. Site 283 would require no additional highway works to Bridgnorth Road and it performs better than other proposed allocations around Wombourne.

Object

Representation ID: 4914

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Gladman consider Policy SA5(036c) as proposed in the Plan to be sound. That said, Gladman do not consider the decision to reduce the allocation boundary from 8ha in the preceding Preferred Options Plan (which proposed to allocate the site for a minimum of 168 dwellings) to 3.85ha in the Publication Plan (which allocates the site for a minimum of 81 dwellings) is entirely appropriate.

It is acknowledged that the site is located within the historic extent of Acton Hill Park, the heritage interest of which principally derives from it being the designed grounds to Acton Hill House, itself a non-designated heritage asset. Gladman question whether the interest of the historic park warrants this proposed level of mitigation and consider that a smaller set-back would be more proportionate.

The Site represents one of the few opportunities to deliver development in a non-Green Belt location in the authority and thus the potential for development here should be maximised, as to reduce the extent of Green Belt release required to meet the proposed housing requirement. Gladman contend that the new allocation boundary does not reflect the full, natural and logical extent of the available development site and suggest to make effective use of land, that the allocation for a minimum of 168 dwellings, as set out in the preceding Preferred Options Plan, is reinstated.

The Site can deliver a wide range of market and affordable homes as well as new open space and green infrastructure which could be provided in greater quantum with increased benefits for landscaping and net gains in biodiversity if a larger area within the site boundary is considered for allocation. The site is not at flood risk and access has been demonstrated as ok in principle.

Comment

Representation ID: 4918

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Orton Lane (Housing Allocation 416)

We continue to support the principle of the release of the safeguarded land at Orton Lane for allocation for housing growth. The site remains suitable, available and
achievable, in accordance with Paragraph 68 of the NPPF. It was confirmed through the Housing Site Selection Topic Paper (2021) that the “site’s assessment process has revealed no unmitigable constraints to the delivery of the safeguarded land in Wombourne”. This was also confirmed through the examination of the SAD as recently as 2018.

Initial baseline technical work has demonstrated that the site can come forward for development in the short term, so can contribute to the Council being able to maintain
their five year housing land supply, and there are no constraints which would limit this. The enclosed framework plan (Appendix 2) demonstrates how the site can be delivered, responding to its constraints.

It is Bellway’s intention to commence pre-application discussions with the Council early in 2023 with a view to submitting an application before summer.

Bellway control the southern extent of the proposed allocation, St Phillips control the northern extent. Although there will be separate applications made by each party, we are committed to continuing to work together to ensure there is a coordinated approach to delivery.

Comment

Representation ID: 4923

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Billy Buns Lane and Gilbert Lane (Site Refs: 462 and 284) are proposed as allocations for a minimum of 223 dwellings. Bellway consider that their additional land
to the west of Strathmore Crescent (Site Ref: 708) is a more sustainable and suitable option for meeting Wombourne’s (and the wider District’s) housing needs.

Firstly, the Council’s own evidence (LUC Landscape Sensitivity Study (2019)) demonstrates that land west of Strathmore Crescent is less visually sensitive. EDP’s Landscape and Green Belt Review (2021) (Appendix 4) shows that the site has no landscape features of note and there are features present which limit the site’s sensitivity.

Secondly, the Council’s Green Belt Review (LUC Green Belt Study (2019) also shows that land west of Strathmore Crescent is located in a parcel which represents less Green Belt harm.
Land west of Strathmore Crescent’s lower Green Belt harm is influenced by fact it is visually and physically well contained being bound along its western edge by the
railway walk, residential development to the east and south.
In addition, there are clear synergies of delivering land west of Strathmore Crescent given its location adjacent to the proposed allocation and already safeguarded site at Orton Lane – it would support sustainable patterns of development as per NPPF paragraph 142.
Policy SA5 should therefore be modified to reduce the capacity of land off Billy Buns Lane and Gilbert Lane to reflect its constraints and land west of Strathmore Crescent should be added into the policy for a minimum capacity of around 40 homes.

Comment

Representation ID: 4935

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Omission site: Land west of Strathmore Crescent, Wombourne

Bellway controls additional land beyond Orton Lane at Wombourne, to the west of Strathmore Crescent (Site Ref: 708), it adjoins the western boundary of the Orton Lane site (Site Ref: 416). The site has the potential to deliver and additional 40-50 homes, forming an extension of the proposed allocation off Orton Lane. The site would be accessed via the proposed Orton Lane allocation and could offer a new link through to the adjacent railway walk, a site location plan enclosed at Appendix 3.

the small scale nature of this site represents a more suitable and sustainable opportunity for growth at Wombourne than the land off Billy Buns Lane
and Gilbert Lane (Site Ref: 463 and 284) proposed allocation. It has a more limited impact on the Green Belt given its scale alongside its physical and visual self containment.
The South Staffordshire Railway Walk situated to the west and which provides a permanent, defensible boundary for the site, and further development to
the east.

Together with the land to the proposed off Orton Lane, the land represents a comprehensive solution to meeting Wombourne’s needs in a single location, which is
very well defined by its boundaries.

Object

Representation ID: 4946

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 616 Land at rear of Melwood Lane, Brewood should be allocated for future housing development in the Review, particularly in view of how it “reads” as part of the village; the minimal harm to Green Belt considerations that would result from built development, and its limited visual sensitivity.It is confirmed that the land is available for development without any ownership or known technical constraints.

Object

Representation ID: 4947

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 065 to the rear of St Mary's Row, Brewood should be allocated for future housing development in the Review or, at the very least, identified as “safeguarded”, particularly in view of how it “reads” as part of the village; the minimal harm to Green Belt considerations that would result from built development, its limited visual sensitivity and sustainability credentials.

Object

Representation ID: 4948

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 221 Land at Dam Mill, Codsall should be allocated for future housing development in the Review or, at the very least, identified as “safeguarded” for longer term development. Development of the site would have limited visual and green belt impact and is well served by public transport and local facilities in a location in proximity to the conurbation edge and thereby close to the source of unmet need.

Object

Representation ID: 4952

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Sites 236/237, Land at the Wergs should be allocated for future housing development or removed from the green belt and safeguarded for longer term development in the Review. This would provide more flexibility in meeting current and future housing needs than the current approach. The site is close to bus routes and has other locational advantages including proximity to schools and the shops and other services in Tettenhall village.

Object

Representation ID: 4954

Received: 20/12/2022

Respondent: IM Land

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

In December 2021 IM Land submitted details of the latest modelling work undertaken by DTA which shows how the potential highway constraints can be resolved.

An agreement has been reached between the Highways Authority and IM Land that the proposed improvements at the A41-Wrottesley Park Road junction would mitigate the additional forecast traffic generated by the proposals. It has also been confirmed that the developer would need to provide financial contributions in accordance with the Council’s school transport contribution policy.

There is no reference in the latest (and final) version of the Plan, or the evidence base, which refers or even acknowledges that this information has been considered by the Council. The Council’s assessment and eventually decision to exclude the site on highway ground is not justified and so is not soundly-based.

The evidence base and site assessment of Land at Perton Golf Club should be revised to reflect the evidence on highway issues prepared by DTA and the site allocated.

Object

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

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.

Object

Representation ID: 4974

Received: 19/12/2022

Respondent: FGD Ltd

Agent: Savills

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Omission site: Land at Mile Flat, Kingswinford

The Site has been assessed in the SHELAA 2022 (site reference 577) as ‘NCD1’ which the Housing Site
Selection Topic Papers (2021 & 2022) state that this means the site is “potentially suitable for housing but not
currently developable because of a policy designation”. The supporting table of the SHELAA notes that site
577 is “potentially suitable but subject to policy constraints – Green Belt & Core Policy 1”. The site assessment summary states “north eastern corner of the site is directly adjacent the urban edge of the Black Country.
Promoter indicates 4ha of employment land could be accommodated on site. Urban edge site modelled at 35
dwellings per hectare.” We support the positive assessment of the site in the SHELAA.
The Site is considered to be too far from primary and secondary education and it is located within an area of
High Green Belt harm. In regards to education, the site is of a scale where land for a primary school and / or
community facilities could be provided to support residential development on the site and elsewhere in the
District / Kingswinford if required.
Although the Site is in an area of ‘high’ Green Belt harm, all of the land to the west of the Black Country has
either been assessed as ‘high’ or ‘very high’ and the Site has ‘low-moderate’ landscape sensitivity. It is
considered that suitable Green Belt compensatory and landscape improvements could be provided on the Site
if it was allocated for residential and / or employment uses. We also consider that if the Site was released from
the Green Belt, then Mile Flat offers a clear physical and permanent revised Green Belt boundary (National
Planning Policy Framework (NPPF) paragraph 143f).
Subject to a sensitive design and proposed mitigation for any potential heritage and landscape impacts, it is
considered that the Site is suitable for residential and / or employment uses, is available for development and
could be delivered within the next 5 years if required.

Object

Representation ID: 4983

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Omission site: Dunsley Road, Kinver (revised boundary)

Barratt is promoting land to the north and south of Dunsley Road, Kinver (both parcels are shown within the submitted Vision Document). The northern parcel (SHELAA reference 549) is approximately 13 hectares (32 acres) and is bound by Dunsley Road to the south, Dunsley Hall to the east, the Staffordshire and Worcestershire Canal to the north and residential dwellings to the west. The southern parcel (SHELAA reference 550) is approximately 3.5ha (9 acres) and is bound by Dunsley Road to the north, residential dwellings and the Staffordshire and Worcestershire Canal to the west and agricultural fields to the east and south. The Sites could deliver circa 350 market and affordable dwellings as well as a potential community use and public open space.
The key constraint identified within the SHELAA 2021 for Site 550 was that it is ‘disassociated from any village development boundary’. Although the site is not immediately adjacent to the adopted settlement boundary, the site is adjacent to existing residential properties so it is not disassociated from development. Additionally, site reference 272 (land east of Dunsley Drive) is proposed to be allocated in the plan for 22 dwellings. Site 550 is immediately adjacent to Site 272 therefore it will no longer be disassociated from the settlement boundary when Site 272 is delivered.
In addition to the above, the Housing Site Selection Topic Paper has been updated. The 2022 Topic Paper’s assessment of the site is identical apart from where the 2021 Topic Paper stated that that the site could “have the capacity to deliver a small site of up to 1 hectare”, the 2022 Topic Paper now states “more recent monitoring evidence suggests that the Council can meet its small sites duty without additional allocations”. We do not consider that this amendment fundamentally changes the points previously made to SSDC and in this representation on the suitability of the site for residential development.
Heritage assessment does not take into account the revised boundary.
In summary, the Sites are located on the edge of Kinver’s settlement boundary and it is considered that they are easily accessible to the shops, services and facilities provided within Kinver as well as the wider transport network linking the site to Stourbridge. A range of technical work has been undertaken to support the promotion of the sites and assess the impact of any future development on the landscape, local highways network, ecology, trees and adjacent heritage assets. The submitted Vision Document sets out further information on the development proposals.

Object

Representation ID: 5005

Received: 15/12/2022

Respondent: St Philips

Agent: Lichfields

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Omission site: Wolverhampton Road, Wedges Mills (Site ref: 529)

It is evident that there are opportunities to allocate additional ‘suitable, available and achievable’ land and sites in sustainable locations across the District.

Indeed, St Philips site at Wolverhampton Road, Wedges Mills (Site ref: 529) is one of these opportunities.

Object

Representation ID: 5006

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Omission Site: Clent View Road (site reference 285).

Taylor Wimpey welcomes the Council’s recognition of the need to review the Green Belt to ensure that its housing need can be met, and a contribution to the GBBCHMA’s unmet need can be provided. Critically, Taylor Wimpey supports the Council’s judgement that the acuteness of unmet housing needs across the GBBCHMA constitutes exceptional circumstances for the release of land from the Green Belt. However, Taylor Wimpey has some concerns regarding the site selection process carried out and considers the methodology and assessment of individual sites to be flawed with regards to their land
interests at Clent View Road, Stourbridge.
However, it is important to note that the HSSTP identifies the total site area as 29.05ha, whereas, and as previously noted above, the proposed site area for Clent View Road is a much smaller 19.6ha. And thus, Taylor Wimpey considers that the site has been inappropriately assessed within both the 2021 SHELAA and the HSSTP.
Challenge the Green Belt assessment for the site.
Overall, It is evident that there are opportunities to allocate additional ‘suitable, available and achievable’ land and sites in sustainable locations across the District, in particular along the western edge of the Black Country. This location is a suitable option for growth that is capable of contributing towards the housing need emerging through the Local Plan Review. Specifically, Taylor Wimpey recommends that Clent View Road should be allocated for residential development as it is a sustainable and appropriate opportunity to provide much needed housing within the upcoming Plan period. Importantly, the Council has identified exceptional circumstances for reviewing the Green Belt, and thus Taylor Wimpey encourages the Council to consider Clent View Road as a suitable opportunity for residential development.

Object

Representation ID: 5008

Received: 21/12/2022

Respondent: St Philips

Agent: St Philips

Legally compliant? No

Sound? No

Duty to co-operate? Yes

St Philips is highly supportive of the Council's decision to allocate Site 416a within the Land off Orton Lane allocation within the PP. St Philips would also note that the Site is located in the highly sustainable settlement of Wombourne. Wombourne is ranked second in the proposed settlement hierarchy and is the largest of the settlements that have been designated within Tier 2. The Site will therefore make a valuable contribution to meeting the housing needs of the District and its neighbouring local authorities. However, whilst broadly supportive of the PP, St Philips has some concerns regarding draft Policy HC1 and NB6 covered in separate representations.

Object

Representation ID: 5012

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Land at Pool House Road (site reference 285) is included within SA5 as a draft allocation and is proposed to be delivered throughout the upcoming Plan period in order to help meet the District’s housing target. Draft Policy SA5 implies that the additional housing allocations at Wombourne will deliver a minimum of 223 dwellings up until 2039. Taylor Wimpey considers this to be a sound strategy as Wombourne is identified as a tier 2
settlement within the PP and is assessed as being a sustainable location capable of accommodating further growth within the upcoming Plan period. The detailed representations submitted have raised key matters relating to the soundness and legal compliance of the PP in relation to the proposed allocation at Land at Pool House Road. It is essential that we are able to appear at the Examination to put forward evidence on
the delivery of the site to its most effective degree and respond to any matters raised and clarifications required by the Inspector.
In addition to the above, it should be noted by the Council that the entirety of the land between site 285 and site 459 is third party land, and thus presents a constraint in terms of achieving connectivity between the two sites. Taylor Wimpey acknowledges that the PROW runs from north to south between the two sites but believes that it does not cover the whole width of the land between site 285 and site 459. However, Therefore, it is not legally possible to provide a pedestrian link between site 285 and site 459, across the existing PROW. Taylor Wimpey is only capable of providing a pedestrian link from site 285 to the
western edge of the PROW.
Taylor Wimpey therefore requests that the site proforma be amended to remove reference to vehicular connectivity and revise the wording in relation to pedestrian connectivity between site 285 and site 459. This would ensure that the draft Policy SA5 is legally compliant in accordance with national planning policy, specifically NPPF paragraphs 16 and 100.
Taylor Wimpey requests that the policy, with specific reference to the site proforma, be amended to acknowledge the above and accept that if a pedestrian link between site 285 and site 459 is to be achieved, it must be via Pool House Road and not over the PROW. This would ensure a robust policy that is legally compliant with the NPPF and PPG.

Comment

Representation ID: 5018

Received: 15/12/2022

Respondent: Payne Hicks Beach Trust Corporation Limited

Agent: Stansgate Planning

The site (Housing Allocation Sites 284 & 463), known as land off Billy Buns Lane/Gilbert Lane, Wombourne, is located to the eastern edge of Wombourne in a highly sustainable and easily accessible position. Wombourne is appropriately recognised as the largest Tier 2 settlement within the District, as well as the largest settlement within the south of the District, and is therefore identified for growth both on safeguarded land and also additional growth around the village.
The allocation of the site necessitates its removal from the Green Belt. It has been evidenced that there is insufficient non Green Belt land available within the District to accommodate the anticipated housing needs over the Plan period.
The allocation at Billy Buns Lane/Gilbert Lane will allow for an appropriate extension to Wombourne to greatly assist in the delivery of the assessed housing need for the District. The Plan has been appropriately positively prepared and has duly met the required duty to cooperate with neighbouring authorities in order to meet the overall housing need for the Housing Market Area. The Plan is therefore considered to be sound and meet the necessary legal tests.
There are no impediments to the delivery of development at the site for its allocated purpose within the Plan Period and it is anticipated that an application for planning permission would be made shortly after the site achieves formal allocation in an adopted Development Plan.

Comment

Representation ID: 5024

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

The site at Langley Road, (site reference 582), is proposed to accommodate 390 houses presumably as part of the GBBCHMA unmet need as it abuts the GBBCHMA boundary (specifically Dudley). A large portion of the site appears to contain surface water/ponds. There are also large areas of overgrown scrub. Furthermore, the site sits adjacent to an electric substation and it is highly likely that any housing development will be required to leave a buffer around the electric substation for safety purposes. When these constraints are considered, along with the WW2 gun battery, the developable area is likely to be significantly reduced, impacting on the overall site capacity.