Question 1

Object

Representation ID: 931

Received: 01/02/2022

Respondent: Dan Kinsey

The housing contribution to the Black Country and GBHMA is out-of-date and these should be reassessed. South Staffordshire has already had 300 hectares of Green Belt removed in the Strategic Rail Freight Interchange (SRFI) at Gailey. This should create surplus employment land in the Black Country which can be reallocated for housing needs, particularly given the substantial central government assistance the Black Country receives in terms of brownfield funding.

Object

Representation ID: 933

Received: 13/12/2021

Respondent: Essington Parish Council

Evidence base in some cases outdated, especially in light of the trends accelerated by Covid. In terms of Site 486c the Sustainability Appraisal does allow some assessment of the site but it appears to me to underestimate the potential for negative impacts in some areas, particularly in relation to transport and traffic congestion, landscape and access to the countryside. Appendix A is also limited in the documents it includes. There are serious concerns about the weight being placed on housing numbers,

Object

Representation ID: 944

Received: 13/12/2021

Respondent: Gavin Williamson CBE MP

Several evidence documents raise a number of key issues present throughout the Preferred Options Plan: firstly, that the district council’s current housing target numbers are too high and inappropriate for South Staffordshire in both a practical and historical context; secondly, that the council’s current approach to meeting the housing need for Gypsy, Traveller, and Travelling Showpeople risks legitimising illegal behaviour and does not represent a positive use of the Duty to Co-operate mechanism.

Support

Representation ID: 962

Received: 01/02/2022

Respondent: Highways England

The Secretary of State's decision regarding the M54/M6 link road is expected in April 2022, not October 2021 as set out in the IDP.

Support

Representation ID: 974

Received: 01/02/2022

Respondent: Stafford Borough Council

Habitat Regulation Assessment of future housing growth will need to address Cannock Chase SAC mitigation measures and implications for the Cannock Chase AONB. The Borough will continue to work alongside South Staffordshire through the Cannock Chase SAC Partnership.

The Borough Council would welcome the opportunity to enter into a Duty to Co-operate Statement with South Staffordshire District Council as part of preparing the new Local Plan to support delivery of housing and employment requirements in the context of the wider area.

Object

Representation ID: 975

Received: 01/12/2021

Respondent: Kinver Parish Council

Evidence should inform a clear policy on windfall allowance and adjustment in calculations, and during the Plan. Should provide a clear policy on maximum build densities to limit over development.

Support

Representation ID: 982

Received: 10/12/2021

Respondent: Lichfield District Council

Agree with the commitment to provide homes for wider HMA unmet needs under the Duty to Cooperate. Agree that Black Country Plan (BCP) shows there will be significant unmet needs post 2031, although it is noted that the evidence underpinning this has not been tested at through examination.

Support

Representation ID: 985

Received: 08/12/2021

Respondent: Redditch Borugh Council

Redditch BC does not consider to be in a position to raise any specific matters regarding housing distribution in the GBHMA or to comment upon the appropriateness of your level of contribution to the unmet need. Redditch BC are preparing a HEDNA currently, and once complete, hope to be able to offer a more specific opinion on housing matters in the GBHMA.

Support

Representation ID: 994

Received: 13/12/2021

Respondent: Wolverhampton City Council

Welcome to commitment of the Plan to update the 2018 EDNA. This should have regard to the West Midlands Interchange Apportionment Study and West Midlands Strategic Employment Sites Study, both published in 2021.

Support

Representation ID: 1002

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Evidence in App A generally considered comprehensive but GBHMA Strategic Growth Study, SHELAA and self build register should also be included. Support scoring in the SA for the site 'Land East of School Lane'.

Support

Representation ID: 1009

Received: 07/02/2022

Respondent: Solihull Council

Welcome the contribution being made towards the HMA shortfall, particularly as this is likely to result in Green Belt release (as it does in Solihull).

Whilst SSDC may presently believe the emerging shortfall from the Black Country contributes towards exceptional circumstances for Green Belt release, but an alternative strategy would be to plan on the basis of confirmed shortfalls and review the local plan every five years.

SMBC believes SSDC's reliance on the Strategic Growth Study may not be appropriate in all other areas of the HMA as the proposals may not be capable of being accommodated. SSDC's approach should recognise that some additional flexibility may be required if there is emerging evidence that is starting to demonstrate that some of the GL Hearn recommended options may not be suitable, achievable or deliverable and/or other strategic options may be available.

Support

Representation ID: 1011

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman recognise that Appendix A lists over 30 robust evidence based studies, which are most up-to-date which has been prepared during the past 18 months. Gladman reserve the rights to comment on the evidence based documents at further stages of the publication consultation, should considered necessary.

Object

Representation ID: 1013

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

No evidence of cross-authority agreements through DtC.
The 2014 LUC GB Review is fundamentally flawed as it concluded that Parcels 1, 2 and 4 of Codsall perform the 4th purpose of GB, however case law has since identified that this purpose of GB only applies to historic towns such as Oxford, York etc.
The 2019 LUC GB review stage 1 assessment is based on inconsistent parcel sizes with some being of 'odd' shape and so large meaning character assessment is flawed. As such, GB study is unfit for purpose. Within stage 2, Site Specific Assessments, Site 222 - Sandy Lane - has not been updated to reflect completion of Watery Lane site.
The interpretation and reflection of the GB study is incorrect as strategic Bilbrook/Codsall extension was defined as making important contribution to GB. This proposal allows coalescence of Wolverhampton and Codsall/Bilbrook - contrary to purposes of GB. The contribution of a First School is irrelevant in GB terms.
Disagree with 2015 Landscape Sensitivity Report and 2019 GB and Landscape Sensitivity Study conclusions that Site 222 Sandy Lane has 'high' GB impact as it has been aggregated with areas to the north and west of Codsall. Consideration should be had to Watery Lane development and smaller parcel assessment sizes. Do not agree that land east of Bilbrook is 'low' impact by comparison.
2019 GB Study should be described as Landscape Sensitivity Study on its cover. It does not address landscape impact other than GB harm within Stage 2 process. Landscape should not be considered within GB assessment as it is not a consideration of the purposes of GB. Site S41A (inc. Sandy Lane, Codsall) is shown in Figure 7.3a as having Moderate/High harm whereas site S46C (linc. land east of Bilbrook) has mixtire of High and Very High harm and should be ruled out for development on VSC grounds.
The submitted Heritage Statement shows that the indirect impacts on heritage assets identified in the 2019 Historic Environment Site Assessment II can be mitigated despite negative assessment of this within the SA.

Support

Representation ID: 1045

Received: 08/02/2022

Respondent: Staffordshire County Council

P2; Include District Integrated transport Strategy, Brinsford Parkway Station Strategic Outline Business Case, Staffordshire Freight Strategy 2019 and Transport Impacts 2022 (yet to be completed) in evidence base
P3-6: Provides an updated summary of Site Accessibility, Connectivity and Potential Highways Impact evidence provided for the District Council through the consultation response.
P39: Provides a ‘South Staffordshire Heath Needs Outcomes’ document to assist in ensuring key health issues are captured and evidenced.
P46: Indicates plan should have considered ‘Spatial Planning for Health: Evidence Review’
P49: Specialist Housing policy should be supported by July 2021 govt. National Disability Strategy, National strategiy for autistic children, young people and adults & Supported housing: national statement of expectations.
P50: The evidence base for natural environment is appropriate
P51: Support the Historic Environment Site Assessment, which has been developed in consultation with Historic England and the Historic Environment Team

Support

Representation ID: 1060

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

No in principle objection to the scope of evidence in Appendix A but is incomplete against the documents on the Council website. GBHMA Strategic Growth Study and SHELAA are omissions.

Object

Representation ID: 1061

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

SA has some anomalies in assessment. Relating to Bratch Common Rd: Regarding distance to education, the minor distance outside the recommended distances are not considered to amount to a minor negative impact, rather the distance would be a minor positive impact or at worst a neutral impact when considered against Objective 11 of the SA.The Council's Sustainability Appraisal (SA) identified that the Site would have a Major Negative Impact on Climate Change Adaptation as it is in part in an area at high risk of surface water flooding. However, the existing surface water flows can be accommodated on the site and ground re-profiling can mitigate surface water flooding concerns and will ensure that the drainage design for the proposed development provides betterment in terms of surface water management. This need not be a major
negative impact and could be a neutral impact.

Object

Representation ID: 1083

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Underlying consistency with the wording and layout of the overall Preferred Options Report (November 2021) which created confusion and clarity. Unusual approach to the public consultation system which lead to unclear community engagement, The existing adopted Local Plan comprised of the Core Strategy (adopted in 2012) an the Site Allocations Document (adopted in 2018) which seeks to deliver the spatial planning framework for the future distribution of new development across the South Staffordshire District within the Local Plan Review 2021. Therefore, concerns arise that South Staffordshire Council's Core Strategy and Site Allocations which are being used for the new Local Plan Review are based on out of date data. Any initial work on the plan preparation for the Council's emerging Local Plan Review was undertaken pre-Covid19 Pandemic which implicates the Local Plan Review viability and deliverability. The future recession can impact on the community within South Staffordshire which will implicate the planning policies therefore the foundation for the draft of the preferred options are based on out- of - date data.

Object

Representation ID: 1086

Received: 13/12/2021

Respondent: Lilactame Ltd

Agent: Pegasus Group

EDNA process did not consider W'ton Airport in more detail and a descrpency in site size in that document and the Employment Site Assessment Topic Paper 2021. This economic evidence along with the SHELAA does not properly reflect or assesses the Airport's significance. SA of Policy EC8 - unclear how has the policy is pro development to a limited extent, all but one of the 12 objectives would score 0, and this assessment is contested.

Object

Representation ID: 1107

Received: 13/12/2021

Respondent: Mr Mark Stephens

Agent: Advance Land & Planning Limited

Disagree with approach to use Greater Birmingham Strategic Growth Study focused on opportunities for large urban developments / extensions and did not consider more moderate development opportunities. This is spurious evidence to not allow more growth in Cheslyn Hay / Great Wyrley.

Object

Representation ID: 1111

Received: 04/02/2022

Respondent: Environment Agency

Include River Basin Management Plans. Policies should commit to supporting the objectives of these plans.
Water Cycle Study - Abstraction Licensing Strategies have been updated since WCS was published. Water stress section out of date, classification now 'serious water stress'.
Support recommendation in study for standard of 110 lpd, this should be included in policies.

Object

Representation ID: 1114

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Sustainability Appraisal – concerns over lack of flooding, ecology and heritage evidence and over-statement of case in relation to education
Rural Services and Facilities Audit – Lower Penn has been omitted until the 2021 version, which treated outlying areas differently to the village centre and the Council has not provided documentation of how this approach was decided upon. The whole parish should be designated as a Tier 5 village as it was in the 2012 local plan. The 2019 spatial strategy clearly states small villages will get a maximum of 10% of homes on small sites, which Site 582 exceeds.
Green Belt Review – Site 582 is given a lower harm rating than surrounding land but is not separated from it.
Population growth in the Local Plan is expected to outstrip national population growth rates and is not justified or supported by sufficient infrastructure.
Duty to Co-operate – there is no requirement in law to accept overspill from neighbouring authorities and insufficient regard has been given to brownfield land funding and sites or vacant properties in the Black Country

Object

Representation ID: 1125

Received: 11/02/2022

Respondent: Wombourne Parish Council

Provides background information on importance of local gaps between village and A449, the age profile of the village, deprivation in the south-west ward and unaffordability in the village.
Goes against the NPPF

Support

Representation ID: 1137

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Raises concerns that GBHMA Strategic Growth Study and Strategic Housing & Employment Land Availability Assessment aren’t included in evidence base.

The GBHMA Strategic Growth Study remains the latest comprehensive consideration of housing needs and locations to meet this need. It has been subject to scrutiny through the North Warwickshire Local Plan EiP and provides justification for the intended contribution of 4,000 homes to meet the identified housing shortfall. The SHELAA establishes a broad range of site options to be tested by the Council in establishing housing and employment allocations. The Self & Custom Build Register should be included to inform emerging housing need and mix policies.

Support

Representation ID: 1146

Received: 12/12/2021

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Raises concerns that GBHMA Strategic Growth Study and Strategic Housing & Employment Land Availability Assessment aren’t included in evidence base.

The GBHMA Strategic Growth Study remains the latest comprehensive consideration of housing needs and locations to meet this need. It has been subject to scrutiny through the North Warwickshire Local Plan EiP and provides justification for the intended contribution of 4,000 homes to meet the identified housing shortfall. The SHELAA establishes a broad range of site options to be tested by the Council in establishing housing and employment allocations. The Self & Custom Build Register should be included to inform emerging housing need and mix policies.

Object

Representation ID: 1161

Received: 13/12/2021

Respondent: Mr N Waugh

Agent: AJM Planning Associates Ltd

Object to Codsall Wood being categorised as Tier 5 in Rural Services and Facilities Audit 2021. The village has community-owned pub, events facility, golf-course, and is within reach of public transport.

Object

Representation ID: 1162

Received: 12/12/2021

Respondent: Keon Homes

Agent: Evolve Planning & Design

Raises concerns that GBHMA Strategic Growth Study and Strategic Housing & Employment Land Availability Assessment aren’t included in evidence base.

The GBHMA Strategic Growth Study remains the latest comprehensive consideration of housing needs and locations to meet this need. It has been subject to scrutiny through the North Warwickshire Local Plan EiP and provides justification for the intended contribution of 4,000 homes to meet the identified housing shortfall. The SHELAA establishes a broad range of site options to be tested by the Council in establishing housing and employment allocations. The Self & Custom Build Register should be included to inform emerging housing need and mix policies.

Object

Representation ID: 1169

Received: 13/12/2021

Respondent: Mr & Mrs N Machin

Agent: AJM Planning Associates Ltd

GB Assessment and Landscape Sensitivity Assessment use far too large land parcels to provide meaningful conclusions as to harm on a site by site basis/scale.

Object

Representation ID: 1170

Received: 13/12/2021

Respondent: Mr D Conn

Agent: AJM Planning Associates Ltd

GB Assessment and Landscape Sensitivity Assessment use far too large land parcels to provide meaningful conclusions as to harm on a site by site basis/scale.

Object

Representation ID: 1171

Received: 13/12/2021

Respondent: Mr N Waugh

Agent: AJM Planning Associates Ltd

GB Assessment and Landscape Sensitivity Assessment use far too large land parcels to provide meaningful conclusions as to harm on a site by site basis/scale.

Object

Representation ID: 1172

Received: 13/12/2021

Respondent: Mr C Moreton

Agent: AJM Planning Associates Ltd

GB Assessment and Landscape Sensitivity Assessment use far too large land parcels to provide meaningful conclusions as to harm on a site by site basis/scale.