Question 5

Object

Representation ID: 3575

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Birmingham Overspill
There is clear evidence to suggest that South Staffordshire should be taking a greater proportion of development than other authorities within the HMA given the level of shortfall identified. This further supports an increase in the 4000 dwellings proposed to reflect this relationship and South Staffordshire’s ability to deliver homes in a location closest to where the need is derived.

The number of homes being planned to contribute to addressing the shortfall should be increased significantly

Object

Representation ID: 3576

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The housing allocations included within the Plan to support the growth of the conurbation should be directed to locations close to where the need arises. The Plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation
to meet its need, or within a sustainable commuting distance, to help reduce the need to travel. The housing requirement should be increased and redistributed so that further allocations are made adjacent to the built-up edge of the Black Country.

the GBHMA Strategic Growth Study is not a relevant evidence base against which to assess the suitability of sites or formulate a housing distribution strategy.

A sequence of smaller sites in appropriate locations, such Heyford’s site at Wall Heath, would not only make a positive and sensitive contribution to meeting the overspill, but would also provide sites that can be delivered in the short term.

Object

Representation ID: 3609

Received: 08/12/2021

Respondent: Mrs Georgina King

Objects to proposed developments in Wombourne.
Loss of village status.
Impact on infrastructure.
Highways issues: already a traffic issue at peak times in Wombourne, roads aren't suitable for buses, people use the village as a cut through, increased traffic.
Wombourne will become urban sprawl.
Loss of village character.
Brownfield sites should be utilised first.
Flooding: Gilberts land is know to flood - will these homes get insurance?
Lack of police - increase in crime.
Impact on GP services, schools and local conveniences - will more be built and where.

Object

Representation ID: 3639

Received: 15/11/2021

Respondent: Mrs Helen Stanley

Number of people: 5

Objects to the proposed developments in Wombourne.
Objects to building on the green belt.
Loss of village status.
Increased traffic.
Increased air pollution.
Impact on wildlife.
Derelict lands should be built on and turned into affordable housing.

Object

Representation ID: 3647

Received: 13/12/2021

Respondent: Mr V Kelly

Spatial strategy needs re-examination with regard to the WMI whihc will increase traffic on the A449.
Penkridge has the land available to sustain growth with improvements to parking, safer crossings and use of the A449 by cyclists and local traffic.

Object

Representation ID: 3662

Received: 09/12/2021

Respondent: Mr & Mrs R Jukes

Object to the proposed developments in Wombourne.
Object to developing the green belt.
Impact and loss of wildlife, habitat and environment.

Object

Representation ID: 3669

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

The approach to The Spatial Strategy 2038 is viewed as inappropriate as the emerging plan should pan for the minimum standard method housing requirement from the start of the plan period as a baseline, which the SSHMA advises is 5,068 dwellings.

South Staffordshire Council has not correctly factored in affordable housing need and whether an uplift to the District housing requirement is required and not considered uplifting the minimum Standard Method housing figure to take account of economic growth aspirations and the fact that the age profile of South Staffordshire is increasing.


The emerging Local Plan needs to be consider with how the needs of South Staffordshire and the overspill of the Black Country are considered and presented, to make sure that all the relevant housing needs are being met.

Object

Representation ID: 3670

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

Economic Growth

It is not clear from the information available and further
consideration should be given to whether an uplift in the housing requirement would ensure that sufficient houses are available to support the local workforce

Object

Representation ID: 3671

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

Black Country Overspill and Combined shortfall

South Staffordshire draft proposed 4,000 dwellings to contribute toward the shortfall. Consequently, there is clear evidence to suggest that South Staffordshire should be taking a greater proportion of development than other authorities within the HMA given the level of shortfall identified.

The number of homes being planned to contribute to addressing the shortfall should be increased significantly.

Object

Representation ID: 3672

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

Spatial Strategy for Housing

Concerns about the number of dwellings being proposed to meet the identified shortfall, Table 8 of the draft Plan advises that only 2,958 of the 4000 dwellings are
proposed adjacent to the edge of the Black Country conurbation.

The housing allocations included within the Plan to support the growth of the conurbation should be directed to locations close to where the need arises. The Plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation
to meet its need, or within a sustainable commuting distance, to help reduce the need to travel.
The housing requirement should be increased and redistributed so that further allocations are made adjacent to the built-up edge of the Black Country.

Policy DS3 advises that development will be located at the most accessible and sustainable locations in accordance with the settlement hierarchy included within the policy.

Piper Homes’ site at Springhill Lane, would not only make a positive and sensitive contribution to meeting the overspill, but would also provide sites that can be delivered in the short term and assist in meeting the full
spectrum of need identified.

Support

Representation ID: 3673

Received: 13/12/2021

Respondent: Piper Homes PLC

Agent: Harris Lamb Property Consultancy

The land at Springhill Lane should be removed from the Green Belt and allocated for residential led development to provide much need executive homes to assist in
meeting the economic growth aspirations of the Black Country and South Staffordshire.

The Site has not been assessed by the Council to date. It is also a new opportunity for Piper Homes.The site measures approximately 5.4 hectares. 3.7 hectares is grassland and would be the
focus of the residential development. The remaining 1.7 hectares is treed, and these would be retained and provide a very attractive environment for future residents.
The site is in the Green Belt at the current time, but it is extremely well contained, with built development and sports facilities to the north and south, and dense tree belts to the west.

Object

Representation ID: 3708

Received: 09/12/2021

Respondent: Ms Olivia Jones

4000 homes duty to cooperate is too much.
Most unmet need is from Sandwell which is not neighbouring.
10,000 empty homes in West Midlands.
Need to take COIV and brexit into account.
Should wait for BCP to be finished.

Object

Representation ID: 3756

Received: 07/12/2021

Respondent: Bev Purchase

Community needs should be met before increasing it's volume.
Roads, footpaths and signs need repairing.
Schools need help.
Disabled people need help.
Facilities for teenagers are needed.
Pedestrian safety
Flooding
Hedges and grids
Extra policing
Crime safety.
Parish Councillors effectiveness questioned.

Object

Representation ID: 3770

Received: 14/11/2021

Respondent: Mrs Carol Hurley

Objects to proposed developments in Wombourne and surrounding area.

Objects to developing the green belt.
PO does not address climatic effects of development.
Increased traffic, increased speeding, poor state of roads.
Impact on wildlife.
Wombourne current infrastructure does not have capacity for residents needs.
Impact in already oversubscribed doctors surgeries.
Impact on schools - at capacity.
Lack of parking facilities (schools and village centre).
Lack of police station - increase in crime.
Wombourne has to service smaller surrounding villages as well.
Some sites are on the flood plain.
Increase in surface water run off.
Brownfield sites such as Copart should be explored.
Loss of green recreational spaces.

Object

Representation ID: 3814

Received: 15/12/2021

Respondent: Mr D A Hudson

Agrees with points raised by Save Kinver Greenbelt.

Object

Representation ID: 3837

Received: 13/12/2021

Respondent: Sarah L Hovington

Objects to proposed developments In Kinver, Wombourne, Trysull and Swindon.
Objects to developing the green belt.
Impact on already strained doctors, police and schools.
Loss of green recreational spaces - effecting mental health.
Increased traffic and congestion on already busy roads.
Loss of village status and identity.
Loss of boundaries between Wombourne and Wolverhampton - urban sprawl.
Increase in local flooding.

Object

Representation ID: 3845

Received: 11/12/2021

Respondent: Mrs D Hughes

Black Country Housing need overstated and duty to cooperate figure is too high plus is due to be removed.
Many empty homes in region.
Brownfield land should be used instead.

Object

Representation ID: 3847

Received: 25/07/2022

Respondent: Mr Martin Holland

The latest CPRE report on the state of brownfield sites in England states that it could
accommodate over 1.3 million new homes. So there is no need to build on green belt.
The Black Country already has 11000 empty houses which should be used first.
The housing numbers derived to meet the duty to cooperate for the Black country is
based on old data and is grossly overestimated. This must be reviewed.

Object

Representation ID: 3853

Received: 12/12/2021

Respondent: Mr Steve Holden

Should create new settlement rather than urban expansion e.g. at Gailey.
Black Country housing need is over stated.
Duty to cooperate figure 4000 is too high, soon to be scrapped.
Should be brownfield first.

Object

Representation ID: 3858

Received: 15/11/2021

Respondent: Mrs Jillian Ward

The town/village locations will make it difficult for residents to access local amenities.
Disability/higher care needs residents need to have walking access to a hub of local amenities as these groups have limited access/ability to access transport options.
Number of village do not have access to sports/leisure/greenspace within walking distance.
Impact on wildlife and habitats.
Lack of public transport.
Loss of green spaces.
Roads/transport network can not support proposed housing.
Urban wildlife corridors should be maintained.
Broadband access should be improved across Souths Staffs.
Village heritages lost.

Object

Representation ID: 3885

Received: 12/12/2021

Respondent: Mrs J Sadler

Disagrees with policy approach

Object

Representation ID: 3888

Received: 10/12/2021

Respondent: Mr - Yeomans & Messrs Law

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA. HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire. No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population. Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall. Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country. Insufficient capacity in other GBHMA authorities to absorb shortfall and South Staffordshire should be taking a greater proportion given its functional relationship with the Black Country.
Policy DS3 is unsound as it fails to make sufficient contribution to meet the growth requirements. Pattingham can and should accommodate additional development due to its suitable location.

Object

Representation ID: 3898

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA. HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire. No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population. Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall. Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country. Insufficient capacity in other GBHMA authorities to absorb shortfall and South Staffordshire should be taking a greater proportion given its functional relationship with the Black Country.
Policy DS3 is unsound as it fails to make sufficient contribution to meet the growth requirements. Pattingham can and should accommodate additional development due to its suitable location.

Support

Representation ID: 3899

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

Support the recognition of Codsall/Bilbrook as a Tier 1 settlement which are suitable to make a significant and proportionate contribution towards housing needs. These settlements have excellent access to local services.

Object

Representation ID: 3977

Received: 12/12/2021

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

Paragraph 31 of the NPPF (2021) expects Plans to be informed and “…underpinned by relevant and up-to-date evidence…” Paragraph 35 (indent b) of the NPPF confirms that Plans should be: “…Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence…”

Initial work on Local Plan preparation for the Council’s emerging Site Allocations Document (SAD) was undertaken under a significant and entirely different set of economic circumstances. Essentially, a significant and substantial amount of Plan Preparation work has already been undertaken on the emerging SAD before the year 2020 coronavirus (covid-19) pandemic. Which is likely to cause one of the worst United Kingdom (UK) economic recessions in living memory. The huge modelling assumptions being used to underpin, form and force through the Local Plan are flawed and no longer forms a credible, reliable or sound evidence.

We maintain our view that the potentially massive implications of the forthcoming severe UK economic recession on future housing delivery across the District going forward (and how the recession will affect new housing delivery within the District going forward over the lifespan of the new Local Plan once it has been adopted) has been given an insufficient level of planning policy weight, or seemingly no planning policy weight at all (See Appendix 11 Issue 2).

The addition of 4,000 homes to meet the needs of the Black Country is not supported because the evidence is not clear, the housing numbers used are out of date and the Black Country Plan is still in development. This would result in the removal of the named sites adjacent to the Urban Area and in particular Site 582. Given that SSDC planners themselves (see Appendix 10) view the Duty to Co-operate as ‘a fundamentally flawed instrument’, a review of whether any of the needs of the Black Country should be accommodated in South Staffordshire might be
considered in a review of the plan.

Support

Representation ID: 3978

Received: 12/12/2021

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

The approach to the various Tiers is supported, including specifically in relation to Tier 5 and Lower Penn. This would suggest excluding all sites currently being promoted within the Parish Boundary including Site 582.