Question 1

Support

Representation ID: 692

Received: 13/12/2021

Respondent: Grade Planning

The use of the ‘Housing Site Selection Topic Paper 2021’ is supported for the purpose of assessing and allocating housing site options to meet the proposed housing target. Paragraph 5.9.1 of the Paper is supported which recognises Huntington’s level of facilities and public transport links in allocating additional growth. The proposed allocation of Site 016 (Land at Pear Tree Farm) for ‘minimum delivery of approximately 39 dwellings’ is supported (in line with the proposed housing allocation at Appendix C of the Preferred Options document).

Support

Representation ID: 693

Received: 13/12/2021

Respondent: Mr Lee Penrose

Agent: Mr John Baggott

Yes, as a suite of documents and studies, the evidence base appears appropriately thorough and wide ranging. However, please see specific comments below regarding the reliance upon the Rural Services and Facilities Audit and the categorisation of settlements into 5 tiers.

Object

Representation ID: 716

Received: 13/12/2021

Respondent: Home Builders Federation

Please refer to detailed comments.

Object

Representation ID: 723

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Define Planning and Design Ltd (on behalf of Bloor Homes Ltd)

Whilst the evidence base appears to be broadly robust and proportionate, BHL has concerns in relation to the Black Country and South Staffordshire Landscape Sensitivity Assessment (LSA) and the Council’s Strategic Housing Market Assessment (SHMA).

As a result of its methodology, the LSA's findings do not always relate directly to subtleties in a site's landscape sensitivity, which should be considered in assessing sites.

The SHMA should be revisited to consider what level of uplift above SSC's LHN would be appropriate to reflect the economic context in the plan period, which is likely to create an uplift in housing demand.

Object

Representation ID: 732

Received: 13/12/2021

Respondent: Nurton Developments Ltd

Agent: JLL

Please find attached a response. This includes a bullet point summary

Object

Representation ID: 734

Received: 13/12/2021

Respondent: Mrs Parmjit Crosby

15 of the documents in the evidence base are pre 2021 - some as old as 2018. The information contained in the documents is out of date and don't take account of newer trends introduced as a result of for example, Brexit and Covid, where less housing is required due a decrease in population and more green space is needed for mental health and wellbeing.

Object

Representation ID: 736

Received: 13/12/2021

Respondent: Mrs R Groom

I do not believe that the South Staffordshire Council have gathered together all the evidence to make an informed decision.

Object

Representation ID: 759

Received: 13/12/2021

Respondent: Mr John Ellis

Are the projections for increased housing based on the latest 'post-Brexit' population trends. It is estimated that 1 million people have left the country (www.bbc.co.uk/news/uk-56435100) which if true must have an effect on housing demand.

Object

Representation ID: 775

Received: 13/12/2021

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

We have fully set out our position in our separate representation document attached in relation to the evidence base where is relates to the need and associated land allocation for specialist accommodation.

In short, we consider the Specialist Housing: Local Need & Site Allocations Topic Paper (September 2021) and the Housing Site Selection Topic Paper (September 2021) woefully inadequate to address the needs established in the South Staffordshire Housing Market Assessment 2021, as well as the built-up deficit from the Core Strategy 2012.

No discussion or allocation for Registered Care is also a huge gap in the overall assessment.

Object

Representation ID: 781

Received: 13/12/2021

Respondent: L&Q Estates

Agent: Barton Willmore

Please refer to our Representations to the Preferred Options Consultation, on behalf of L&Q Estates, in relation to land at Yieldfields, Bloxwich. The Representations include the below reports:

• Site Boundary Plan (Drawing RG-M-30)
• Extract from Draft Policy WSA4 of the Draft Black Country Plan 2039
• Illustrative Concept Masterplan (Drawing BM-M-14C)
• Illustrative Concept Masterplan with Phasing (Drawing BM-M-15A)
• Review of Sustainability Appraisal (December 2021)
• Green Belt Advice Note (November 2019)
• Landscape, Visual and Green Belt Appraisal (December 2019)
• Transport Technical Note (October 2021)
• Preliminary Ecological Review: Constraints and Opportunities (July 2019)

Object

Representation ID: 791

Received: 13/12/2021

Respondent: National Trust

The plan will need to demonstrate that the release of green belt land for development is justified with regard to national planning policy.

Support

Representation ID: 794

Received: 13/12/2021

Respondent: Land Fund Limited

Agent: Turley

Land Fund consider that the scope of the evidence base prepared to inform the emerging plan is robust and proportionate.

Work undertaken by Land Fund to inform the outline planning permission (Ref. 18/00436/OUT) for residential development on phase one of the development also considered the technical baseline of the future potential residential development on the safeguarded site which now forms a proposed allocation (Site Ref. 239). This technical baseline for the Site (Ref.239) together with the technical support for the site to the south demonstrated that the combined development can be delivered without significant mitigation requirements.

Object

Representation ID: 797

Received: 13/12/2021

Respondent: Harris Lamb Property Consultancy

No. The housing evidence base which underpins the draft Plan’s housing strategy is lacking. Paragraphs 4.6 to 4.12 of the Preferred Option consultation draft Plan refer to various evidence base documents that have been used to help identify the quantum of development South Staffordshire should provide to assist in accommodating the unmet housing requirements of the conurbation. None of the documents referred to in these paragraphs are referred to in the evidence base in Appendix A. They have, however, been fundamental in shaping the Plan’s housing strategy.

Object

Representation ID: 813

Received: 13/12/2021

Respondent: Mrs Karen Daker

I am objecting to Site 519 in Bilbrook.
-The proposal is to build on High Grade Agricultural land. This is not shown in the proposal
- No traffic impact assessment has been undertaken for the junctions around the development.
- A housing Needs Assessment has not be undertaken to assess the housing requirements for Bilbrook

Object

Representation ID: 814

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

There are a number of additional elements that would enable the plan to deliver the requirements of national policy, and better achieve environmental net gain.

Further ecological evidence base on particular ecological assets and accessible natural greenspace, a Local Nature Recovery Strategy, GI strategy and further evidence base to support measurable biodiversity net gain.

Object

Representation ID: 822

Received: 13/12/2021

Respondent: Mr Richard Williams

Just not appropriate

Object

Representation ID: 833

Received: 13/12/2021

Respondent: Mr Graeme Lockey

Undervaluation of the impact development of the sites listed will have on existing infrastructure - schools, doctors, roads, traffic, carbon footprint with particular bottlenecks around the A449 traffic island at busy times of the day by traffic entering/leaving Wombourne

Object

Representation ID: 854

Received: 13/12/2021

Respondent: Mr J Ball

Plan has already changed numerous times without regular updates, plan is not fit for purpose in village.

Support

Representation ID: 872

Received: 27/01/2022

Respondent: Association of Black Country Authorities

BCA and SSDC have been working constructively on DtC for development needs, infrastructure and delivery, with aim to reach agreement in draft Statements of Common Ground by Summer 2022. Support preferred housing growth option of own needs + 4,000 to HMA up to 2038 and request that the full 4,000 home contribution is allocated to the Black Country. Support longer term aspiration for new settlement with sustainable transport links to Black Country and request that updated EDNA is shared with the BLack Country at earliest opportunity to inform SSLP contribution to Black Country employment needs.

Object

Representation ID: 873

Received: 27/01/2022

Respondent: Association of Black Country Authorities

Request that EDNA update is progressed as quickly as possible to inform Duty to Cooperate engagement on Black Country unmet employment needs, having regard to West Midlands Interchange apportionment and West Midlands Strategic Employment Sites Study 2021. Black Country is engaging with other emerging Local Plans including Bromsgrove, Lichfield, Cannock, Telford & Wrekin, Solihull and Stafford on this issue. The WMSESS 2021 identifies a shortfall of strategic sites against past market trends and recommends areas for future work. Request that South Staffordshire engage with the Black Country and other West Midlands local authorities to undertake this follow up work and reflect this in the EDNA.

Object

Representation ID: 889

Received: 10/12/2021

Respondent: Bilbrook Parish Council

Currently, the evidence base to support this growth strategy fails to demonstrate the wider transport and natural environment impacts. Do not support decision to build 4000 homes on behalf of the Black Country under the Duty to Cooperate. It is not right that the Green Belt of South Staffordshire should be sacrificed to save the Green Belt of the West Midlands. Brownfield sites in the Black Country should be considered first. Empty properties should be used before releasing Green Belt. Further evidence on brownfield site options is required including investigating options at the Grange Pub, Bilbrook House. Do not agree with Bilbrook's classification as a Tier 1 settlement with infrastructure, including Bilbrook train station,is not within walking distance of the proposed new development. No data available on highways impacts. Climate Change study disappointing as does not include site specific mapping to inform design. Plan should make provision for semi natural habitats and the green corridor along the Shropshire Union Canal is too narrow and should be extended to the East of Barnhurst Lane (which is proposed for housing as site 519).

Object

Representation ID: 895

Received: 13/12/2021

Respondent: Cllr Gary Burnett

Road Impact Survey for Bilbrook is required.

Support

Representation ID: 897

Received: 13/12/2021

Respondent: Coal Authority

As you will be aware we provide the LPA with downloadable GIS data in respect of Development Risk, and Surface Coal Resource plans. We would expect any sites being considered for allocation to be assessed against this data. Specifically the Development Risk plans as this should enable any constraints and/or issues affecting the site to be identified at as early as possible stage in the process. Where mine entries are present on a site this may impact on the quantum of development which can be accommodated, in order to ensure that these features are not built over, or close to.

Support

Representation ID: 899

Received: 28/01/2022

Respondent: Birmingham City Council

Indicates that latest housing shortfall up to 2031 across GBHMA is 6,302 homes. Emerging Black Country Plan identifies 28,239 home shortfall also, impacting on housing shortfalls experienced across the HMA up to and beyond 2031. Shortfalls partially examined through GBHMA Strategic Growth Study 2018 but the City Council views this as needing to be updated to identify further solutions to strategic housing shortfalls. Birmingham Development Plan is underway and is likely to conclude there are significant housing shortfalls up to 2042. South Staffordshire have been a proactive participant in HMA discussions and the City Council welcomes the 4,000 dwelling contribution to unmet needs.

The West Midlands Interchange and other strategic employment sites are closely related to Birmingham and the Black Country. Birmingham's emerging HEDNA indicate challenges in meeting the city's employment land needs. The role of these sites should be captured in a Statement of Common Ground with Birmingham.

Object

Representation ID: 901

Received: 28/01/2022

Respondent: Brewood and Coven Parish Council

The duty of cooperation is one way traffic and lacking in evidence of the West Midlands Conurbation's brownfield land and other suitable sites.

Support

Representation ID: 903

Received: 28/01/2022

Respondent: Bromsgrove District Council

No comment to make on location of development other than to say the locations chosen and site selection seems robust. The level of housing appears consistent with the standard method and the 4,000 dwelling contribution to the GBBCHMA is welcomed. Bromsgrove does not object to this, but does not specifically endorse the method by which it has been derived and views the GBHMA Strategic Growth Study 2018 as one of a number of pieces of evidence.

Bromsgrove note the surplus in employment land proposed and will work with South Staffordshire through updates to the FEMA to identify the most appropriate approach to defining the FEMA for both Districts.

The approach taken to the Duty to Co-operate (DtC) has been explained in full in the supporting DtC statement and is an accurate representation of discussions.

Object

Representation ID: 905

Received: 28/01/2022

Respondent: Cheslyn Hay Parish Council

The contribution of 4,000 dwellings under the Duty to Cooperate should be reduced to the legal minimum to protect the Green Belt land in South Staffordshire and the environment.

Object

Representation ID: 909

Received: 28/01/2022

Respondent: Barry Bond

The 4,000 dwelling contribution under the Duty to Co-operate is far too high, Circumstances have changed and the approved RFI will provide employment land allowing employment land in the Black Country to be redeveloped in line with the West Midlands Mayor's plans.

Object

Representation ID: 910

Received: 10/12/2021

Respondent: Codsall Parish Council

Identification of Codsall as Tier 1 settlement in Rural Services and Facilities Audit does not take account of current capacity of these service and facilities. High school is at capacity, leisure centre well used with restricted opening hours and parking. Limited parking at station and trains with limited carriages that are often full - Codsall railway station is essentially a branch line with no evidence that it can sustain the level of growth proposed. Car parking at shops is at capacity between 11am and 2pm. No evidence has been provided on traffic capacity, with regards to patterns of movement, streets & parking also environmental impacts.There is no evidence base for the highway assessment to demonstrate the modelling scenarios of the proposed development impacting on the existing highway network

Object

Representation ID: 912

Received: 22/12/2021

Respondent: Natural England

Evidence base not complete - additional information sources identified.
In combination effects of impact on designated sites of air quality will need to be assessed across authority boundaries.
HRA - Air quality impacts should be identified as risks for Mottey Meadows SAC and Midland Meres & Mosses Phase 2.
SA - Why was site 610 selected instead of site 614.
SA - What is the council's justification for allocating on the Best and Most Versatile Agricultural Land.