Question 1

Object

Representation ID: 3566

Received: 14/12/2021

Respondent: Mrs Emma Hill

Goes against NPPF and its pledge to use Green belt to protect against urban sprawl

Object

Representation ID: 3568

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Disagree. 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 and should be included.

The housing requirement proposed by the draft Plan is unsound as evidence is dated and does not reflect current data.

Object

Representation ID: 3643

Received: 13/12/2021

Respondent: Mr V Kelly

All evidence outlined in Appendix 1 are not applicable for Penkridge- should be re-examined.
The Black Country Local Plan is not yet complete - who decides weather overspill housing is acceptable and appropriate?
Local plan for Penkridge is not factual on the land north of Penkridge.
Open Space Strategy - open countryside is no less valuable that green belt.
West Midlands Interchange - advanced works are already having an effect on traffic and use of local Penkridge infrastructure - further local consultation required.
Housing Strategy and delivery of sites - concept of housing in the west of Penkridge needs further consultation and examination of policy and strategy.
Environmental Protection - Possible inclusion of River Penk Flood plains - needs examination.
Local Plan is short term.
Penkridge requires a neighbourhood plan.

Object

Representation ID: 3664

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

No. The housing evidence base which underpins the draft Plan’s housing strategy is lacking detail. The housing requirement proposed by the draft Plan is unsound. It fails to reflect the most recent information available on the extent of the housing shortfall arising from the conurbation and fails to acknowledge the important role South Staffordshire needs to play in supporting housing growth to meet the development needs of the Black Country and Birmingham.

Object

Representation ID: 3757

Received: 13/12/2022

Respondent: Mr D E Marsh

All the supporting evidence has been taken from before the pandemic (March 2020). So therefore does evidence the current needs of communities or take into account the severe economic impact of one of the worst economic recessions of the last 300 years.
Evidence base is un-sound and no longer fit for purpose.
Local Plan does not conform with Paragraph 31, 35b, 35c and 82d of Revised NPPF.
There is no Urban Capacity Study background technical base document.

Object

Representation ID: 3861

Received: 15/11/2021

Respondent: Mrs Jillian Ward

No reference to green or conservancy policy.

Object

Representation ID: 3874

Received: 14/12/2021

Respondent: Save the Seven Cornfields Campaign Group

Housing forecast model is not fit for purpose.

Object

Representation ID: 3881

Received: 10/12/2021

Respondent: Deborah Adkins

Government regulation states that the greenbelt shouldn't be used unless there are no other options
This local plan in Wombourne goes against this

Object

Representation ID: 3892

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

Summary: The housing evidence base which underpins the draft Plan’s housing strategy is deficient. 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 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, as detailed in our response to Question 5, 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.

Object

Representation ID: 3907

Received: 13/12/2021

Respondent: Tarmac

In line with paragraph 20 of the NPPF. An aspect which does not appear to be considered as part of the preferred options consultation is the provision of minerals. Mineral operations across the area have an important role to play
in the delivery of the strategic growth aims of the plan and the allocation of new sites for development. Tarmac would therefore welcome the opportunity for further consultation regarding an appropriately worded policy (including spatial policy options) in relation to the
safeguarding of mineral resource and infrastructure. It is essential that further consideration be given to this as the plan progresses.

Object

Representation ID: 3973

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Contrary to paragraph 31 of the NPPF (2021) which confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…”, the evidence base is in some cases outdated, especially in the light of trends accelerated by COVID and Brexit. This is likely to have a significant impact for example on the Economic Development
Needs Assessment (EDNA). The Strategic Housing Market Assessment (SHMA) suggests the current policy approach would encourage significant, and potentially unsustainable, out migration from the Black Country thereby undermining South Staffordshire’s Climate Change Strategy 2020 (strategic planning responsibilities) pertaining to reducing car use. The current policy of encouraging out-migration into South Staffordshire is not supported.

In terms of Site 582, as set out in this document, there are a number of concerns with the Sustainability Appraisal, both the limitations of the evidence about flooding, ecology and heritage but also the potential over-statement of the case in relation to education provision.
Appendix A is also limited in the documents it includes. There are concerns about the weight being placed on housing numbers, both in terms of Supply and Need. As set out in this document, there are concerns that the over-spill from the Black Country is over-stated in the
Joint Statement of 2020, and therefore the need for South Staffordshire to accommodate it. Equally there are concerns about the level of supply in South Staffordshire, in particular the significant understatement of windfall assumptions, which would suggest South Staffordshire
can provide 850 homes for the Black Country without any new allocations.