Question 4

Object

Representation ID: 1410

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support policy DS1 – Green Belt and in particular reference is made in the supporting text at paragraph 4.4 of the Local Plan to securing compensatory improvements following Green Belt release which relate to environmental quality and accessibility of remaining Green Belt.
The facilities should be identified and planned for and then included in an Infrastructure Delivery Plan. By providing a range of examples, the PPG is clear that these improvements could be wide ranging, and as such do not all need to relate to both environmental quality and accessibility of remaining Green Belt. PPG (Reference ID: 64-002-20190722).

Support

Representation ID: 1426

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Support

Representation ID: 1432

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

We do not oppose the proposed requirement to provide compensatory improvements but consider that any requirement should accord with the wording of the Planning Practice Guidance (‘PPG’) (Reference ID: 64-002-20190722).
We support the provision of a Green Belt Supplementary Planning Document which we consider should include
more guidance on the provision of compensatory improvements and costs for calculating off-site contributions if improvements cannot be met on-site.

Support

Representation ID: 1442

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Support

Representation ID: 1461

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Do not oppose the proposed requirement to provide compensatory improvements but consider that any requirement should accord with the wording of the Planning Practice Guidance.

Support

Representation ID: 1483

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

In general, we support the approach of Policy DS1 - Green Belt, in so far as it reflects the guidance in the Framework. This is, however, on the basis that the Plan will be amended to remove additional land from the Green Belt to accommodate South Staffordshire’s and the conurbations’ housing and employment needs in accordance with our response to question 5, and land is removed from the Green Belt and safeguarded for future development.

Object

Representation ID: 1484

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Insufficient land released from the Green Belt to meet para 140 of NPPF. Additional land needs to be released for development now, and the omission of the identification of further safeguarded is significant and should be rectified.
Policy DS1 – penultimate paragraph is inappropriate and more restrictive than NPPF. No policy justification for limited infilling and control of building heights. Other forms of inappropriate development as per para 150 of NPPF have been omitted. Penultimate paragraph of policy should be removed and policy should refer back to NPPF.

Support

Representation ID: 1527

Received: 10/12/2021

Respondent: Mr - Yeomans & Messrs Law

Agent: PlanIt

In general, we support the approach of Policy DS1 - Green Belt. This is, however, on the basis that the Plan will be amended to remove additional land from the Green Belt to
accommodate South Staffordshire’s housing and employment needs in accordance with our response to question 5.

Object

Representation ID: 1529

Received: 10/12/2021

Respondent: Mr - Yeomans & Messrs Law

Agent: PlanIt

Insufficient land released from the Green Belt to meet para 140 of NPPF. Additional land needs to be released for development now, and the omission of the identification of further safeguarded is significant and should be rectified.
Policy DS1 – penultimate paragraph is inappropriate and more restrictive than NPPF. No policy justification for limited infilling and control of building heights. Other forms of inappropriate development as per para 150 of NPPF have been omitted. Penultimate paragraph of policy should be removed and policy should refer back to NPPF.
Policy DS2 - Open Countryside, identifies forms of development that will be supported
in the open countryside. No reference is made to the provision of rural exception sites.
Limited affordable housing for local community needs can be an appropriate form of development within the Green Belt (Framework paragraph 149F). Rural exception sites should, therefore, also be recognised as an appropriate form of development within
the open countryside.

Object

Representation ID: 1559

Received: 13/12/2021

Respondent: Mr Nigel Babb

The whole policy, starting from the Green Belt search for sites has an in-built bias in favour of building in the Green Belt (which is supposed to be the last resort) as opposed to Open Countryside.
The council’s policy HC2 has watered down the 35 dwelling per hectare requirements in the GBMHA report.
The majority of sites in the Local Plan are in the low twenties – this does not make sense as it means bigger settlements and hence more Green Belt land lost!
k) If Green Belt land must be used, the search for sites was too heavily influenced by the GBHMA report, which is openly acknowledged as being geared to the needs of the conurbation.
The search for sites in the Local Plan should have considered the needs of the District not the conurbation
The search for sites in the GBHMA survey is described as desk-based and doesn’t use local knowledge.
Identified areas are specifically related to the conurbation, and don’t necessarily reflect the needs of South Staffordshire.

Object

Representation ID: 1565

Received: 13/12/2021

Respondent: Mr Nigel Babb

You should build in the Green Belt as a last resort, this is the other way round, favouring preservation of Open Countryside.
The council will remove land from Green Belt, and therefore the protections afforded to Open Countryside are effectively greater than those for the Green Belt.
The area of search was copied from the GL Hearn Survey, which was only related to the needs of the conurbation.

Support

Representation ID: 1607

Received: 06/01/2022

Respondent: Four Ashes Road LTD

Agent: Miss Rebecca Allen

FAR Ltd supports the policy approach in Policy DS1 (Green Belt) and Policy DS2 (Open Countryside).

Object

Representation ID: 1617

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

Policy DS2 is in conflict with national policy by affording the same level of GB protection to the Open Countryside. Policy DS2 should be amended to align with national policy and recongnise opportunities for sustainable development in non-GB locations which is important due to the extent of the district covered by GB, limited supply of brownfield sites, and the national requirement for 10% of housing growth to be delivered on sites less than 1ha.

Support

Representation ID: 1619

Received: 07/12/2021

Respondent: Mr Andrew Jones

The land to the East of Essington has seen a number of promoted sites and these have been collected together under the SL62 assessment area in the study. ) This has been reclassified into a sub parcel named S20H which includes land rear of Snyd Lane, promoted area under consideration has an agricultural land quality of
Grade 3. It is primarily used for grazing horses and sheep. The proposed land is free from constraints and has a Green Belt Ratings of "moderate".

Support

Representation ID: 1638

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Support

Representation ID: 1649

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Object

Representation ID: 1677

Received: 13/12/2021

Respondent: Mr J Barnes

The selected site does not actually reflect the policy which is advocated.

Object

Representation ID: 1686

Received: 13/12/2021

Respondent: Mrs Vicky Barnes

The selected site does not actually reflect the policy which is advocated.

Support

Representation ID: 1698

Received: 14/03/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Policy DS1 is broadly in line with national policy. The recognition within the supporting text that exceptional circumstances exist for Green Belt release within the District to allow for sustainable development within the plan period is also supported. However, this recognition should also be included within Policy DS1, with cross reference made to the relevant sites where Green Belt release is proposed.

Support

Representation ID: 1710

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Object

Representation ID: 1718

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

t Philips do not support the development strategy contained within draft Policy DS1. The text implies that a Green Belt designation directly contributes to the ‘district's rural character’, which suggests Green Belt is a landscape designation. Green Belt is a policy designation, and its purposes is to prevent urban sprawl as opposed to providing protection for rural character and
landscape. It is therefore imperative that the Local Plan
comprises a detailed Green Belt review, to ensure that development needs beyond the Plan period can be met.

Support

Representation ID: 1722

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Support

Representation ID: 1741

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.

Object

Representation ID: 1771

Received: 13/12/2021

Respondent: St Philips

Do not support DS1. The district’s rural character is not relevant to Green Belt. Paragraphs 4.2 – 4.3 fail to specify that exceptional circumstances are required to alter Green Belt boundaries. The policy should have regard to the need to release further Green Belt to address the GBBCHMA unmet housing need over the plan period and beyond.

Object

Representation ID: 1783

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

Policy DS4 - definition of "limited infilling" fails to recognise the interpretation of should be made having regard to local circumstances.
Policy DS4 - should be amended to omit reference to "small gaps (1 or 2 buildings)" and "exceed the height of existing buildings" as these limit the scale of development regardless of GB impact. These matters should be left to application stage.

Support

Representation ID: 1790

Received: 13/12/2021

Respondent: WM Housing Associations

Agent: Tetlow King Planning

Balanced and objective perspective on Green Belt. Recognising important role of Green Belt but also restriction it places on delivering new homes. Amending Green Belt will help to ensure a sufficient supply of deliverable and developable land - support for removal of sites from Green Belt to deliver housing and maximise affordable housing provision. Support for limited affordable housing through rural exception sites and amendments to Green Belt boundaries for development allocations. Support for Green Belt compensatory measures.
Support for clear breakdown of distribution of housing growth across 5 localities, but flexible approach needed specifically for the delivery of affordable housing. What is set out in each of the localities should be guidleline rather than policy.

Object

Representation ID: 1805

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

Agree that lack of other options to accommodate the District’s growth needs as well as helping neighbouring authorities address their housing needs are exceptional circumstances justifying Green Belt release. The 4,000 dwelling contribution should be revisited in light of the Black Country’s increasing unmet needs. Extra Green Belt should be released, including Site 170. Parcel S20G of the Green Belt Study fails to assess Site 170 separately despite differences between the parcel and site. A separate Green Belt assessment undertaken for the site indicates that the site has a lower harm rating than indicated in the 2019 Green Belt Study. If the site is not released for housing development now it should be considered for safeguarded land to meet housing needs beyond the plan period to 2038.

Object

Representation ID: 1813

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Given the disparity in size between Parcel S4 in the Green Belt Study and Site 591, Parcel S4 should not be used to assess Green Belt purposes. Parcel S4B is too large to reflect the site’s actual Green Belt harm and some of the commentary justifying the parcel’s harm score does not apply to the site. A separate Green Belt and landscape analysis of the site provided by Tyler Grange suggests the site is moderate landscape sensitivity and moderate Green Belt harm. The site offers a chance for compensatory Green Belt improvements through landscape planting and preserving the openness of surrounding Green Belt.

Object

Representation ID: 1824

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Site 283, the key determinant in the Sustainability Appraisal and Site Assessment is the potential for major negative impacts in relation to landscape criteria due to Green Belt harm.

Concerns raised into why the Green Belt assessment has been used as a criteria for the sustainability appraisal rather than the Landscape Sensitivity assessment.

Bloor Homes finds that the site affords less of a contribution to the Green Belt than the wider land parcel of S72.

The release of this land from the Green Belt for a
proposed development would have an effect on spatial openness, but it is unlikely to have a harmful effect on the visual openness of the Green Belt. Additionally, the
landscape of the site would enable ecological betterment and bio-diversity net gain through habitat creation, formal and informal landscaping.

Additionally, the landscape of the site would enable ecological betterment and bio-diversity net gain through habitat creation, formal and informal landscaping.

The site adjoins, and can seamlessly integrate with, an existing sustainable settlement. It is well connected and is within walking distance of the village services and facilities. It also offers a substantial amount of
green infrastructure and landscape enhancements.

Support

Representation ID: 1830

Received: 10/12/2021

Respondent: Wollaston Properties Ltd

Agent: First City Limited

Policy DS1 – Green Belt is similar to both National and the current planning policy for Green Belt.

Welcome the proposal for a separate GB SPD to be prepared which will take into consideration the latest updates in the NPPF. Acknowledge sustainability should
be factored into the suitability of sites for future development. A site located on the edge of a built-up area should be considered more favorably than a site located in a rural area.

Support the inclusion of Codsall/ Bilbrook as a tier 1 settlement due to the high sustainability of the settlement and the range of services and facilities which the
settlement has to offer.