3.8

Object

Representation ID: 4209

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No evidence of SPD, infrastructure delivery strategy or masterplan in evidence base for Langley Road. Lack of an urban capacity study to show how SSDC has examined all other reasonable alternatives. Lack of evidence from Local Health Authorities, Social Services, LEA, Highways Authority, Emergency Services. No up to date Air Quality Study.

Comment

Representation ID: 4221

Received: 22/12/2022

Respondent: Connectivity and Sustainability, Staffordshire County Council

Appendix A, pg171 – Key evidence base and topic papers. South Staffordshire Integrated Transport Strategy – this will be updated by SCC and will be ready before Submission of the Local Plan. Since the previous comments were made at Preferred Option stage, government guidance has changed, and Local Authorities will now be required to update and review their respective Local Transport Plans. A new Staffordshire County Council Local Transport Plan is expected to be produced by March 2024, which will encompass the South Staffordshire Integrated Transport Strategy and other strategy/policy documents.

Local Transport Note 1/20 should also be included.

Object

Representation ID: 4265

Received: 21/12/2022

Respondent: Mrs Vicky Barnes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Local Plan process is difficult to understand, the District Council website is not user friendly and difficult to navigate the documents, links and interactive map which is not helpful to the older demographic.

Many residents not aware of the Local Plan review due to insufficient attempts to inform residents of the Local Plan review. The information and evidence to be out of date which does not comply with the UK legislation, therefore questions the decisions were made to consider a sound plan for South Staffordshire in the principle with chapter 35 in the NPPF.

Object

Representation ID: 4344

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

The employment land needs for South Staffordshire and the wider FEMA authorities are queried, due to the inconsistencies between the methodologies used for individual EDNAs. Additionally, it is considered that all of the FEMA EDNAs under-forecast employment requirements. The methodology used should be reviewed, as per Savills recommendations in its Industrial and Logistics Need Assessment. This variance in approach mainly stems from the EDNAs being statistical constructs that do not consider market conditions which influence demand. Suppression demand is not dealt with other than apply arbitrary flexibility margins. The Savills Industrial and Logistics Need Assessment identifies a shortfall within South Staffordshire specifically, to be of 76ha - 257 ha.

It is essential that the employment evidence base provides a true representation of the future requirements of the area. As such an updated EDNA should be produced which addresses the methodology points raised.

The landscape sensitivity of the land now being promoted (17.6ha) is less than the wider site .

Comment

Representation ID: 4497

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Cameron Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.

The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.

Comment

Representation ID: 4518

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Bloor Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews. This
evidence has been subject to scrutiny as supporting evidence at the North Warwickshire and Solihull Local Plan EiPs and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.
Bloor Homes has worked collaboratively with the Council, the City of Wolverhampton Council, other key stakeholders and the Council’s masterplanning consultant to progress the Strategic Development Location proposal for Bilbrook.

Comment

Representation ID: 4527

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Cameron Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.

The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.

Comment

Representation ID: 4553

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Cameron Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.

Comment

Representation ID: 4578

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews. This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.
Taylor Wimpey has worked collaboratively with the Council, the City of Wolverhampton Council, other key stakeholders and the Council’s masterplanning consultant to progress the Strategic Development Location proposal for Cross Green. This has been informed by the preparation of evidence prepared by Taylor Wimpey to supplement the Council’s evidence base, including the preparation of an updated Strategic Transport Assessment attached at Appendix 2.

Comment

Representation ID: 4610

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. The identification
of the Greater Birmingham HMA Growth Study (2018) and the SHELAA, which were absent in the Preferred Options document, is supported.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified
housing shortfall.

Comment

Representation ID: 4666

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Keon Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.

Comment

Representation ID: 4691

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Welcome the commitment for GBBCHMA authorities to update the 2018 housing shortfall position.

Housing Site Selection Topic Paper 2022
Failing to consider areas identified as having major negative impacts against the landscape criteria may result in an unsustainable pattern of development and would be contrary to ABCAs proposed use of Green Belt/landscape evidence base as identified in the Duty to Cooperate. The reference to the ABCA evidence base is odd, and the council has failed to provide a cogent justification for this; ABCA should not be involved with SSDC site selection.

Comment

Representation ID: 4706

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

The Publication Plan is supported by a broad range of evidence documents to be relied upon by the Council in formulating the Local Plan. Lovell Homes supports the identification of the Greater Birmingham HMA Growth Study (2018) and the SHELAA which were absent in the Preferred Options document.
The Greater Birmingham HMA Strategic Growth Study remains the latest comprehensive consideration of housing needs across the Greater Birmingham
and Black Country HMA and provides a range of recommended options for meeting these needs, to be tested through individual LPA Local Plan reviews.
This evidence has been subject to scrutiny as supporting evidence at the North Warwickshire Local Plan EiP and provides justification for the Council’s intended contribution of 4,000 homes to assist in meeting the identified housing shortfall.

Comment

Representation ID: 4739

Received: 21/12/2022

Respondent: Environment Agency

The Phase 1 Scoping Water Cycle Study, undertaken by JBA in February 2020 has not been updated since our previous comments in relation to this plan which highlighted where assessments were out of date. What discussions the Council has had with the water companies regarding timescales for development and how Severn Trent Water and South Staffs Water will meet the new demand arising from development in the South Staffs area? As no Detailed WCS published, we trust that this matter has been discussed between your Authority and Severn Trent Water to ensure the implications of the proposed growth on this resource has been fully explored.

Object

Representation ID: 5062

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Green Belt Assessment

Anomalies identified, particularly at Codsall, which need to be addressed. SHEELA site 515 is located in parcel S46Bs2 which is assessed as being moderate-high. The site 515 should be categorised as ‘moderate harm rating’ the same as the adjacent land parcel to the east (Parcel S50A). Conversations with officers has suggested that this anomaly would be corrected.

Object

Representation ID: 5069

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Ongoing concerns about the continued poor quality of the background technical evidence base being used by South Staffordshire District Council to support Local Plan preparation and justify spatial planning policy decisions relating to the spatial distribution of new housing development. For example, the emerging Local Plan Review is not even supported by a robust and up-to-date Green Infrastructure Study (GI Study), and therefore the approach taken towards Local Plan making by the Local Planning Authority (LPA) is in direct conflict with paragraphs 174 (indents a and d), 175 and 179 of the Revised NPPF (2021).
The South Staffordshire District Nature Recovery Network (NRN) Mapping (2020) is a highly aspirational document which provides very weak, not fit-for-purpose and insufficiently robust background technical evidence from which to make planning policy assumptions, and from which to inform critically important land use spatial planning policy considerations, to inform the future spatial distribution of new housing development across the district. Particularly those housing sites coming forward alongside landscape-scale wildlife corridors, such as the South Staffordshire Railway Walk dismantled railway line within the Lower Penn area of the district.
Alarmed that the Council is relying on this weak evidence base to inform Local Plan preparation and critically important spatial planning policy considerations. In accordance with paragraph’s 174 (indent d) and 179 of the Revised NPPF (2021) the Council should have used a sufficiently robust and up-to-date Green Infrastructure Study (GI Study) to inform the Publication Stage Report (November 2022) (Regulation 19) Local Plan document.

Object

Representation ID: 5070

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council’s existing ‘Open Space Audit Assessment Report’ (adopted October 2019) (Open Space Needs Assessment) (the Green Space Audit) forms insufficiently robust background technical evidence and fails to robustly respond to requirements of paragraphs 31 and 98 of the Revised NPPF (2021).
Put quite simply, the Council’s existing Green Space Audit (adopted 2019) does not give sufficiently clear and meaningful steer and direction, and does not provide robust recommendations to help inform Local Plan-preparation work going forward. In respect of the identification future open space needs required for the local area. These are critically important issues which should inform open space policy direction within the emerging Local Plan Review, and help inform the approach taken towards spatial planning across the district.
These future public open space supply issues (e.g. what are the future needs for open space provision required by a significantly expanded new residential population (aswell as existing residents living within long established residential communities) over the lifespan of the new Local Plan, extending up until the year 2039) are critically important, in order to help promote the future delivery of more sustainable residential communities. Which are well-served and have good access to a range of conveniently located different types of public open space provision. This is important to help support community well-being, community cohesion and integration, help support more physically active healthy lifestyles, as well as support biodiversity.
Highlights health benefits linked with open space. These were made even more apparent during the pandemic.
The Council is allowing insufficiently robust Green Space background technical evidence to be taken forward to inform Local Plan-preparation work.
By taking forward an insufficiently robust evidence base as referred to above, the Council is failing in its duty to protect the health of its existing and future new local residents by ensuring that there is a sufficient supply of important public open space areas, close to heavily populated residential areas and within easy reach of the various major new housing site allocations being proposed within the emerging Local Plan Review.

Object

Representation ID: 5190

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

EDNA underestimates job growth.

Object

Representation ID: 5194

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 006 Boscomoor Lane
Green Belt Study
Change P3 rating from Strong to Moderate as the site is surrounded on three sides by the built envelope,
Change P5 rating from strong to moderate, site and immediate area does not contain brownfield land, allocation would not therefore significantly prevent the recycling of derelict land.

Support

Representation ID: 5195

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Site 006 Boscomoor Lane
Support the overall Green Belt harm conclusion of ‘low-moderate’ harm. However the Green Belt boundary should be amended to follow the line of Boscomoor Lane.

Object

Representation ID: 5196

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 006 Boscomoor Lane
Landscape Sensitivity Study
Sensitivity of the site should be reduced to ‘low-moderate’, the site is enveloped on three sides by built form thus reducing sensitivity. The site comprises two irregular fields separated by a gappy hedgerow.

Support

Representation ID: 5197

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Site 006 Boscomoor Lane
Rural Services and Facilities Audit
Support the findings of the Rural Services and Facilities Audit in relation to Penkridge.

Support

Representation ID: 5204

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Land West of Fenton House Lane WA
Rural Services and Facilities Audit
Support findings of Rural Services and Facilities Audit in relation to Wheaton Aston.

Object

Representation ID: 5205

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Land West of Fenton House Lane
Landscape Sensitivity Study
The wider land parcel is suitable for safeguarded site i.e. 610 & 619. This would allow for greater POS and a buffer for Mottey Meadows.

Object

Representation ID: 5208

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Land North of A5 Gailey
Green Belt Study
Safeguarding assessment flawed. Fail to recognise the recent consent of WMI. This consent will fundamentally change the Green Belt baseline in this location and is a significant material consideration when assessing Green Belt impact of this site.

Object

Representation ID: 5212

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Langley Road
Green Belt Study
Sprawl - The site is enveloped by existed built features on three sides and would serve to consolidate and round-off the existing settlement edge. An existing substation adjacent to the western boundary represents an existing urbanising feature. It is suggested site makes a ‘moderate’ contribution to checking unrestricted sprawl.
Safeguarding - The site is strongly influenced by existing urbanised features and has durable defensible boundaries. Site development would present opportunity to further strengthen these boundaries. Therefore considered that the site makes a ‘moderate’ contribution to assisting safeguarding from encroachment.
Regeneration - Site does not contain significant brownfield areas and would therefore not prejudice the redevelopment of urban land. Therefore it is considered that the site makes a moderate contribution to this purpose.
In conclusion it is suggested that the Green Belt assessment harm rating be reduced to ‘low-moderate’.

Object

Representation ID: 5216

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

North of New Road, FS
Rural Services and Facilities Audit
Featherstone benefits from ‘good’ access to employment opportunities rather then ‘medium’. Featherstone is located in immediate proximity to i54 and ROF.

Object

Representation ID: 5217

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

North of New Road FS
Green Belt Study
Sprawl - Featherstone is physically separate from the West Midlands conurbation by 2km. The site is situated to the north of the village. As such the development would not risk contributing to the unrestricted sprawl of the conurbation. This should be reassessed as ‘moderate’ rather than ‘strong’.
Encroachment - Site has durable defensible boundaries that provide clear physical closure from the wider Green Belt. Considered therefore that the site makes a ‘moderate’ not a ‘strong’ contribution in relation to countryside encroachment.
Regeneration - Site does not contain significant brownfield areas and would therefore not prejudice the redevelopment of urban land. Therefore it is considered that the site makes a moderate contribution to this purpose.
In conclusion it is suggested that the Green Belt assessment harm rating be reduced to ‘moderate’. Release of the site would constitute a limited weakening of the Green Belt.

Object

Representation ID: 5220

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Land adj Station Road, Codsall
Green Belt Study
Unrestricted sprawl: site is not part of the conurbation, is located in west of Codsall and will remain enclosed along southern and western boundaries by GI and along eastern and northern boundaries by Codsall. Therefore considered the parcel makes a weak/no contribution to this purpose.
Encroachment: Durable defensible boundaries. Development would prevent further encroachment, site makes a moderate and not a strong contribution to this purpose.
Considered therefore that the site makes a ‘moderate’ not a ‘strong’ contribution in relation to countryside encroachment.
Regeneration: Site does not contain significant brownfield areas and would therefore not prejudice the redevelopment of urban land. Therefore it is considered that the site makes a moderate contribution to this purpose.
Summary – Green Belt impact should be amended to ‘low-moderate’.

Object

Representation ID: 5225

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Land off Strawmoor Lane, Codsall
Green Belt Study
Unrestricted sprawl: site is not part of the conurbation and it is not understood how it therefore contributes to preventing sprawl. Therefore considered the parcel makes a weak/no contribution to this purpose.
Encroachment: There are urbanising features surrounding the site. Residential development offers the opportunity to strengthen the western site boundary. Therefore considered that site makes a ‘moderate’ contribution to this purpose.
Regeneration: Site does not contain significant brownfield areas and would therefore not prejudice the redevelopment of urban land. Therefore it is considered that the site makes a moderate contribution to this purpose.
Summary – Green Belt impact should be amended to ‘low-moderate’.