Question 1

Object

Representation ID: 1194

Received: 09/12/2021

Respondent: Mr Steve Anderson

Cannot see how the case is made out for the acceptance of 4000 homes under the ‘duty to cooperate’. At this stage the Black Country local plan is slightly more advanced in its consultation, but is still some way off from being adopted.
At the very least the plan should identify which sites are being included to satisfy the duty to cooperate, and any development of them should only commence when the Black Country has exhausted its own available sites.

Lack any real strategic coordination between neighbouring authorities especially in the south part of the district.

The decision not to seek Community Infrastructure Levy funding from developers appears flawed.

Overall I cannot see how the exceptional circumstances test for the release of green belt land is met.

Support

Representation ID: 1197

Received: 10/12/2021

Respondent: Mr - Cox & Jenks

Agent: PlanIt

Support general interpretation of evidence base documents and the need to confirm the allocation of Safeguarded Sites set out in the SAD. Sites 419 A/B will make an important contribution to the district's housing needs; support the site's allocation.

Object

Representation ID: 1198

Received: 10/12/2021

Respondent: Mr - Cox & Jenks

Agent: PlanIt

Concerns that the size of the housing requirement may be understated. The proposed housing requirement fails to reflect the most recent information which is available on the extent of the housing shortfall arising from the conurbation and, in particular, it fails to acknowledge the important role South Staffordshire must play to support the development needs of the Black Country. There would appear to be a requirement to identify housing sites in addition to the sites which are currently
proposed for allocation in the Preferred Options Plan. We have set out the scale of the under provision in our answer to Q5.

Object

Representation ID: 1202

Received: 15/02/2022

Respondent: Historic England

Evidence base needs strengthening. Link needs to be made between evidence base recommendation and policy text.

Object

Representation ID: 1214

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

Unclear that the need for elderly accommodation of the scale proposed is justified by the evidence at this current time. Object to HESA methodology and conclusions relating to assessment of site 436b and its potential impact on Landywood Farmhouse- an amber score would be more appropriate.Concerns regarding the 2019 Green Belt assessment methodology as well as the site specific findings - the wider site does not make a meaningful contribution to the purposes of the Green Belt. Highways - dispute the conclusions of SCC highways - development of up to 250 homes could be secured from the 3 proposed accesses without impacting on the local network or Holly Lane Bridge. Question reliance on GBHMA Growth Study to support plan target and should be uplifted considering; Standard Method number is a minimum starting point and recent employment growth and new infrastructure justifies an uplift, as does previous SHMA and past recent past delivery. Wider unmet need show significant shortfall from the Black Country that only be met by 6 authorities, suggesting South Staffordshire contribution may need to increase by 3000-5000 homes. The apportionment of unmet need across the relevant LPAs should be based on a robust capacity study. Plan flexibility of 12.9% is insufficient, should be 20%,and the windfall allowance too optimistic.

Object

Representation ID: 1220

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Sustainability Appraisal: Identifies site 238 as having a major negative impact on education. Strongly disagree with the methodology used by the SA. Cumulative development if the site were allocated could provide a new primary school. The site selection topic paper notes the site is 2km from the nearest primary school which is within the walking distance defined by the Education Act.

The Green Belt Study effectively confirms that Perton is already merged with Wolverhampton, which undermines the role and function of the slim strategic slip of Green Belt to the east and south of the site. The SHMA 2021 confirms strong commuting and migration links to Wolverhampton and is functionally part of Wolverhampton’s urban area, supporting the principle of allocating part of Wolverhampton’s housing needs within Perton.

The Strategic Growth Study 2018 shows a significant shortfall in housing is likely to remain in the GBHMA despite the 4,000 dwelling contribution so this should be increased and it would be helpful to understand how the Black Country Authorities feel about the 4,000 units. Concerned that Duty to Cooperate discussions have not taken place regarding a small site allocation proposed by Wolverhampton City Council to the south-east of the site.

Additional detailed Green Belt and landscape rebuttal and highways evidence regarding the A41 junction is also submitted.

Object

Representation ID: 1231

Received: 13/12/2021

Respondent: Cameron Homes 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.

The Nature Recovery Network mapping incorrectly identifies Site 136/136a as an area of high habitat distinctiveness, which is contradicted by site surveys showing semi-improved grassland on the site. Transport statement site SAD Site 136 indicates junction on Landywood Lane can comfortably accommodate up to 200 dwellings. Highways comments for Site 136a should be revisited to reflect the opportunity for sustainable trips.

Object

Representation ID: 1257

Received: 13/12/2021

Respondent: Bloor 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.

The Green Belt Study parcels S71Cs2 and S71Bs2 should be amended to a ‘moderate’ harm rating to reflect site specific evidence. Land at Royal Farm has a lower score in Cannock’s Green Belt Study – the site’s ‘very high’ harm rating is disputed.

The Landscape Assessment parcel SL15 should be amended to ‘low-moderate’ to reflect scores under majority of assessment criteria.

Technical note provided which indicates that Land at Grange Farm, Coven could achieve a suitable access for up to 200 dwellings onto School Road, contradicting highways authority site comments.

Object

Representation ID: 1284

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

There are inconsistencies with the wording of the Preferred Options Report and questions which lead to confusion of the document. The public consultation approach is expressed by Goldfinch Town Planning Services, to be confusing and not effective in achieving clear engagements from members of the public and key stakeholders. Overall the document does not conform with NPPF/PPG. Goldfinch TPS express the adopted Local Plan and part of the spatial planning policy origins have been taken from South Staffordshire's Core Strategy (2012) and Site Allocations Document (2018) therefore, the data is expressed to be out of date. Initial work for plan preparation for the Local Plan Review was taken before the economic circumstances before
Covid-19. Goldfinch TPS views following the Covid-19 pandemic causes implications on future housing delivery and employment land delivery across the District and the lifespan of the Local Plan therefore, evidence base is
considered no longer fit to inform future plan preparation work on the emerging Local Plan Review which overall does not conform to with NPPF/PPG.

Goldfinch Town Planning Service comments there is missing evidence on Urban Capacity Study supporting any background technical evidence base for future proposed spatial distribution of new housing sites across the District. Expressed the need for potential new housing sites to be considered within more sustainable site locations to enhance or maintain the vitality of rural communities.

Support

Representation ID: 1302

Received: 13/12/2021

Respondent: Taylor Wimpy

Agent: Pegasus Group

Generally, the documents listed in Appendix A are considered to represent comprehensive evidence base necessary to support a local plan.

Object

Representation ID: 1303

Received: 13/12/2021

Respondent: Taylor Wimpy

Agent: Pegasus Group

concern raised that Greater Birmingham HMA Strategic Growth Study, SSDC's Self Build & Custom Build Register and the Strategic Housing & Employment Land Availability Assessment ('SHELAA') are not included,

Object

Representation ID: 1309

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

EDNA
Concerned that the EDNA Stage 1, does not reflect the full potential for the growth in demand for industrial and logistics land, the scenarios for Employment Growth appear to be unduly pessimistic. Sets out drivers for increased market demand. A higher margin than that currently proposed by the EDNA should be used.

In regards to the EDNA 2 - Site E30, land at Junction 13 of the M6 Motorway should be scored 'best' rather than 'good'. Land at Junction 13 of the M6 should be identified to meet the emerging needs.
It is not reasonable to include that Site E33 (interchange) can contribute 297 hectares to the supply of employment land. This is not consistent with the DCO, it is not
consistent with the proposals to remove 232 hectares from the Green Belt.

Duty to Cooperate/ Sustainability Appraisal
The Duty To Cooperate Topic Paper should also highlight the need to engage with the Greater Birmingham Authorities, to fully consider the ability of South Staffordshire to meet some of the unmet needs for employment land arising from these authorities. It is not clear from the Sustainability Appraisal of the
Preferred Options Plan, what reasonable alternatives to the quantum of employment land have been assessed. Issue taken with the Sustainability Appraisal’s assessment of the Site E30.

Object

Representation ID: 1320

Received: 13/12/2021

Respondent: Mr - Lacon

Agent: Mr William Dale

The evidence base should be updated to reflect the most recent findings from the Black Country’s Draft Plan consultation (August 2021).

Object

Representation ID: 1351

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

There are a number of elements contained therein which are incorrect or inaccurate. As such, the use of the current evidence base is inappropriate without such errors being corrected and duly considered in full. Particular concerns relate to:
• Rural Services and Facilities Audit 2021 (in relation to the study not considering the capacity of existing facilities and not considering facilities in settlements close to the district).
• Black Country and South Staffordshire Green Belt Study and Landscape Sensitivity Study 2019 (also
referred to as the Green Belt Review 2019 and Landscape Study 2019); In particular, the Council consider releasing and/or safeguarding further
land adjacent to the urban edge of Wolverhampton to meet potential development needs now and beyond the
current plan period (see appendix 2).
• Strategic Housing & Economic Land Availability Assessment 2021;
• Sustainability Appraisal (SA) including Strategic Environmental Assessment (SEA) 2021 (disputes the scoring of sites 494a and 494b including on education (see appendix 3));
• Strategic Housing Market Assessment (SHMA) 2021;
• Housing Site Selection Topic Paper 2021 (sets out a range of points regarding the consideration of sites 494a and 494b).
• Duty to Cooperate Topic Paper 2021.

Object

Representation ID: 1364

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

The SHELAA 2021, GBHMA Strategic Growth Study and Self and Custom Build Register should be identified as part of the evidence base. The GBHMA Strategic Growth Study is a key aspect of the evidence base informing the 4,000 home contribution to housing shortfalls and has been subject to scrutiny as part of the supporting evidence at the North Warwickshire Local Plan examination.

Sustainability appraisal should score non-Green Belt sites better than Green Belt sites by default under the landscape criteria (leading to minor negative scores).

Support

Representation ID: 1372

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Generally, the documents listed in Appendix A are considered to represent comprehensive evidence base necessary to support a local plan.

Object

Representation ID: 1373

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Concern that the Greater Birmingham HMA Strategic Growth Study,Self Build Register and 'SHELAA are not
included, SA assertion that the Linthouse Lane site would result in major negative affect against the 'landscape and townscape' criteria is contested - implies that Green Belt carries greater weight than other landscape considerations. Site only has a moderate impact on purposes 1 and 3 of the Green Belt. Dispute SA minor negative score for education given new education provision. Site should be major positive against housing objective as would lead to well over 100 dwellings.

Object

Representation ID: 1379

Received: 13/12/2021

Respondent: Roundleaf Limited

Agent: Cerda Planning

Despite being submitted to the call for sites, the site (Hatherton House Hotel) was not assessed in the Council’s current Strategic Housing & Economic Land Availability Assessment (SHELAA), nor on the relevant map of those sites that have been considered in the immediate vicinity of Penkridge.

Submit that South Staffs should be taking 8% of the GBBCHMA unmet need - an additional 1,600 homes.

The windfall allowance of 450 units is too optimistic.

Green Belt review - The assessment is not reflective of the site’s strategic Green Belt performance and should not therefore be used as a basis to discount its potential suitability for allocation for new housing in the Local Plan
Review.

Object

Representation ID: 1382

Received: 09/12/2021

Respondent: Mrs Pamela Aust

DTC does not require that neighbouring authorities take a specific number of the allocation but rather that they co-operate.

Object

Representation ID: 1395

Received: 13/12/2021

Respondent: Offoxey Road Limited

Agent: Cerda Planning

South Staffs should take a higher proportion of the GBBCHMA unmet housing need. Recommended a 5,600 home contribution, an additional 1,600 than that currently proposed.
Criticises the SHELAAs assessment of ‘Site 096, Land off Offoxey Road and Ivetsey Bank Road’. The site should logically be moved into the NCD1 category given that the only apparent imposition upon it being allocated is that land designation.

Green Belt Study in relation to the area around Bishops Wood and site 096 is flawed. Consider that the
site performs better in Green Belt terms than the Council’s own evidence would suggest (see appendix for their own assessment).

Object

Representation ID: 1400

Received: 13/12/2021

Respondent: Mr D Parton

Number of people: 2

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: 1408

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

The Council should review the documents to ensure that they have been produced in line with, and make appropriate reference to NPPF (2021).

Duty to Cooperate Paper (2021)
South Staffs should take a greater share of the Birmingham and Black Countries unmet housing need. Recommending a contribution of 8,212 based on their analysis. SoCGs should be drafted now and updated regularly. Greater Birmingham HMA shortfall is likely to be larger than that stated by the evidence base.

Green Belt Review
Disagree with the findings presented by the Green Belt Review (2019) in relation to Lawnswood Road (site 654). Their own assessment shows that undertaken by FPCR concludes the site is between low and moderate harm.

Object

Representation ID: 1423

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

The SHELAA 2021, GBHMA Strategic Growth Study and Self and Custom Build Register should be identified as part of the evidence base. Concerns also raised over the age of the Economic Development Needs Assessment.

Sustainability appraisal should consider Site 585 as an employment opportunity as well as residential-led. Site 585 should not be identified as a major negative due to Green Belt, as other landscape factors have lesser scores.

Green Belt study (parcel S32Es1) is flawed as it does not recognise the recent consent of WMI or its allocation, which would fundamentally change the baseline Green Belt score.

Object

Representation ID: 1430

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

In addition to those evidence documents listed, we consider that an Urban Capacity Report to highlight the
limited number of deliverable sites within the urban area and outside of the Green Belt may be beneficial to
justify why Green Belt sites are being allocated for development. A Green Belt Topic Paper setting out the
exceptional circumstances which the Council consider exist to justify the release of Green Belt could also be
appropriate to support the Council’s strategy at Examination.

Object

Representation ID: 1431

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Duty to Cooperate Paper (November 2021)
South Staffs should take a higher proportion of the unmet need from the Greater Birmingham Housing Market Area. They recommend a 8,212 dwelling contribution towards meeting the unmet need.
Housing Site Selection Topic Paper (September 2021)
Our client’s land to the east of Bilbrook (site reference 500) has been incorrectly assessed as ‘NS’ and should be included as part of Strategic Allocation SA1.

Viability Appraisal 2021
We consider that it is imperative for the Council to engage with infrastructure providers to confirm
financial contributions that they will require from allocations, these should then be factored into the Viability Appraisal.

Object

Representation ID: 1437

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

The housing evidence base which underpins the draft Plan’s housing strategy is deficient. Paragraphs 4.6 to 4.12 of the Preferred Options refers to various evidence base documents that have been used to help identify the
quantum of development for South Staffordshire which will 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 of the draft
Plan. They have, however, been fundamental in shaping the Plan’s housing strategy.
Notwithstanding this omission the proposed housing requirement is unsound. It fails to reflect the most
recent information which is available on the extent of the housing shortfall arising from the conurbation and, in particular, it fails to acknowledge the important role South
Staffordshire must play to support the development needs of the Black Country.

Support

Representation ID: 1439

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

The SHELAA 2021, GBHMA Strategic Growth Study and Self and Custom Build Register should be identified as part of the evidence base. The GBHMA Strategic Growth Study is a key aspect of the evidence base informing the 4,000 home contribution to housing shortfalls and has been subject to scrutiny as part of the supporting evidence at the North Warwickshire Local Plan examination.

Landscape sensitivity study SL36S1 should be amended to score the area of Site 006 as ‘low-moderate’ sensitivity, as it is enclosed on three sides, is closely related to urban influences and is well contained by hedgerow field boundaries.

Object

Representation ID: 1459

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

In addition to those evidence documents listed, we consider that an Urban Capacity Report to highlight the
limited number of deliverable sites within the urban area and outside of the Green Belt may be beneficial to
justify why Green Belt sites are being allocated for development. A Green Belt Topic Paper setting out the
exceptional circumstances which the Council consider exist to justify the release of Green Belt could also be
appropriate to support the Council’s strategy at Examination.

Object

Representation ID: 1460

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Duty to Cooperate Paper (November 2021)
South Staffs should take a higher proportion of the unmet need from the Greater Birmingham Housing Market Area. They recommend a 8,212 dwelling contribution towards meeting the unmet need.

Rural Services and Facilities Audit (‘RSFA’)
Object to the proposed revised Rural Settlement Hierarchy and the categorisation of the village of Kinver as a proposed Tier 2 Settlement. Kinver provides a greater range of shops and services than some of the proposed Tier 1 settlements (Appendix 4 of the RSFA). . It is considered that the modified Main Service Village settlements, which currently includes the settlement of Kinver, should remain as Main Service Villages as they are sustainable settlements which are capable of supporting significant residential growth.

Housing Site Selection Topic Paper (September 2021)
Barratt is promoting land to the north (site reference 549) and south of Dunsley Road (site reference 550), Kinver. They consider that the sites should be allocated.

Viability Appraisal 2021
We consider that it is imperative for the Council to engage with infrastructure providers to confirm financial contributions that they will require from allocations, these should then be factored into the Viability Appraisal.

Object

Representation ID: 1475

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Savills

No - Update the employment land needs attributable to South Staffordshire including local and strategic
needs and accurately identify the cross boundary unmet needs which the SSLPR has a role to play in
providing for.
Update the understanding of the unmet housing needs both quantitively and qualitatively, arising from
the Black Country, Birmingham and other LPA within the housing market area.
Consider the Green Belt Review alongside the green belt review for the Black Country and the green
belt review for Shropshire to enable appropriate assessment of the land most beneficial to release
from green belt to meet identified needs arising across the LPA areas for unmet needs