Question 5

Object

Representation ID: 1090

Received: 13/12/2021

Respondent: Lilactame Ltd

Agent: Pegasus Group

W'ton airport represents a large brownfield site which would be used to meet growth requirements. Focusing residential development around existing edge or adjoining neighboring conurbations does not reflect the benefits that can accrue from residential development on certain previously developed sites, which could be utilised to fund improvements to key employment sectors. The Airport is in need of capital investment which could
come about as a result of enabling residential development.

Object

Representation ID: 1118

Received: 11/02/2022

Respondent: Lower Penn Parish Council

The addition of 4,000 homes from the Black Country is not supported because the evidence is not clear and the Black Country Plan is still in development. Housing supply has improved across the conurbation but South Staffordshire’s contribution has not reduced to reflect this. Black Country unmet needs can be considered through a plan review. The approach to settlement Tiers is supported, which would suggest removing all sites within the Lower Penn parish boundary. Housing for Locality 5 more than doubles need figures in the 2018 Locality Profile. A moratorium on Green Belt urban fringe should be imposed until all sites in the GBHMA have been delivered. Black Country housing supply is being underestimated, including through exclusion of large site windfalls and the arbitrary 35% uplift.

A comprehensive assessment of vacant dwellings in South Staffordshire should be undertaken. The windfall allowance should be increased to provide 1500 dwellings over the plan period and the 1153 dwellings over-allocation should be removed. SSDC have declared a climate emergency but govt. statements acknowledge Green Belt housing leads to a greater reliance on public transport and turns a carbon sink into a carbon source. There is no analysis of the climate change impact of the plan or strategy to reduce these impacts.

Object

Representation ID: 1126

Received: 11/02/2022

Respondent: Wombourne Parish Council

Wombourne has no railway station unlike Tier 1 villages, has grown larger than other settlements in these Tiers and is underserved by public transport (particularly on its western side) despite consistent historic development. Demands on the infrastructure from satellite villages will exacerbate this. Traffic and pedestrian infrastructure is inadequate with road traffic accidents around proposed sites. The HECA 2011 has not been considered. Increased wastewater capacity is required. The village centre has not been a focus for investment. Contact with local GP surgeries and schools suggests capacity issues. Dentists and local policing teams capacity are also general concerns.

Questions why the Black Country has only focused on growth corridors, has not released more Green Belt and pushed demolished housing stock into South Staffordshire. A higher minimum density should be used in Black Country. South Staffordshire’s housing contribution should be reduced in light of its employment contribution. South Staffordshire Council should re-consider the actual need for the additional housing from GBHMA.

Object

Representation ID: 1133

Received: 13/12/2021

Respondent: Mr & Mrs N Machin

Agent: AJM Planning Associates Ltd

Large allocations put the delivery of majority of housing requirement in hands of large developers who could dictate supply. Strategy should deliver more growth around the edge of settlements in sustainable and deliverable locations. Codsall/Bilbrook (Tier 1 settlements) ideal for this more balanced and national GB policy consistent approach.
Strategy should provide for further GB release as safeguarded land within higher tier settlements to meet requirements post-2038 in accordance with NPPF Paragraph 140.

Object

Representation ID: 1136

Received: 13/12/2021

Respondent: Mr D Conn

Agent: AJM Planning Associates Ltd

Large allocations put the delivery of majority of housing requirement in hands of large developers who could dictate supply. Strategy should deliver more growth around the edge of settlements in sustainable and deliverable locations. Brewood (Tier 1 settlements) ideal for this more balanced and national GB policy consistent approach.
Strategy should provide for further GB release as safeguarded land within higher tier settlements to meet requirements post-2038 in accordance with NPPF Paragraph 140.

Object

Representation ID: 1141

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth adjacent to the Black Country and in the most sustainable villages is supported. This aligns growth to Tier 1 settlements and the proposed employment strategy in an area more connected to major road and rail infrastructure.

Object

Representation ID: 1150

Received: 12/12/2021

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth to the most sustainable villages is supported. This aligns growth to Tier 1 & 2 settlements providing an opportunity to address locally arising housing needs and providing community benefits for residents.

Object

Representation ID: 1158

Received: 13/12/2021

Respondent: Mr N Waugh

Agent: AJM Planning Associates Ltd

Large allocations put the delivery of majority of housing requirement in hands of large developers who could dictate supply. Strategy should deliver more growth around the edge of settlements in sustainable and deliverable locations. Codsall Wood is ideal for this more balanced and national GB policy consistent approach.
Strategy should provide for further GB release as safeguarded land within higher tier settlements to meet requirements post-2038 in accordance with NPPF Paragraph 140.
Disagree with the flawed approach to not considering Tier 4 settlements for development. Sites less than 1ha in size should be included to accord with NPPF Paragraph 69.
Infrastructure related needs should only be one consideration of the site selection strategy and be supplemented by all material considerations.

Object

Representation ID: 1168

Received: 13/12/2021

Respondent: Mr C Moreton

Agent: AJM Planning Associates Ltd

Large allocations put the delivery of majority of housing requirement in hands of large developers who could dictate supply. Strategy should deliver more growth around the edge of settlements in sustainable and deliverable locations. Codsall Wood is ideal for this more balanced and national GB policy consistent approach.
Strategy should provide for further GB release as safeguarded land within higher tier settlements to meet requirements post-2038 in accordance with NPPF Paragraph 140.
Disagree with the flawed approach to not considering sites less than 1ha in size should be included to accord with NPPF Paragraph 69.

Object

Representation ID: 1174

Received: 12/12/2021

Respondent: Keon Homes

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth adjacent to the Black Country and in the most sustainable villages is supported. This reflects Tier 1 - 3 settlements' role as sustainable locations for growth. Sites over 1ha should not be excluded from the site assessment process in Wheaton Aston.

Object

Representation ID: 1205

Received: 11/12/2021

Respondent: Mr & Mrs B & S Ashmead

Areas of growth should be selected in settlements with wider range of facilities, public transport and rail links.
4000 Duty to Cooperate allocation should be deferred.

Object

Representation ID: 1212

Received: 15/02/2022

Respondent: Historic England

Para 4.12 - Ensure historic environment, heritage assets and setting are protected and enhanced.
Para 4.21 - No reference to heritage in this section. Difficult therefore to assess how historic environment has been considered in relation to cumulative impact of proposed housing development.
Para 4.58 - We await findings of updated EDNA.
Policy DS3 - Strengthen the wording of this clause relating to heritage.

Object

Representation ID: 1223

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Perton is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site

Object

Representation ID: 1235

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth adjacent to the Black Country and in the most sustainable villages is supported. This aligns growth to Tier 1 settlements and the proposed employment strategy in an area more connected to major road and rail infrastructure.

Object

Representation ID: 1251

Received: 06/12/2021

Respondent: John and Wendy Ashwood

The release of this land is purely to fulfil the unmet housing needs of the Black Country Plan. The figure of 4,000 has been chosen by South Staffs District Council based on outdated ONS figures taken from 2014. This figure has not been forced upon them and should be revisited and significantly reduced or even taken out of the local plan altogether. The reasoning behind this is:
The office of national statistics figures are outdated and more recent ones should be used. 2018 or 2020.

The main unmet need is in Sandwell or further afield in the Birmingham area. These authorities are not adjacent to us.

The Black Country plan is at least a year behind the south staffs plan. A better approach would be to wait to see if their is a housing need instead of offering up our greenbelt.

Object

Representation ID: 1261

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth adjacent to the Black Country and in the most sustainable villages is supported. This aligns growth to Tier 1 and 2 settlements and the proposed employment strategy in an area more connected to major road and rail infrastructure. Concerns are raised that insufficient growth has been allocated in Tier 3 settlements to support existing services and facilities.

Insufficient growth is delivered on the western edge of the Black Country (390 dwellings) compared to the GBHMA Strategic Growth Study recommendations (500-2500 dwellings). Due to constraints within Cannock Chase District, future unmet needs may need to be accommodated on the edge of Cannock.

Object

Representation ID: 1269

Received: 13/12/2021

Respondent: Joshua Atkinson

We are picking up the shortfall in houses for the Black Country plan and North Birmingham. More needs to be done to source and evaluate Brown field sites (as which there are many) in the local area before using the convenience of our green belt.

Object

Representation ID: 1271

Received: 13/12/2021

Respondent: Lisa Atkinson

We are picking up the shortfall in houses for the Black Country plan and North Birmingham. More needs to be done to source and evaluate Brown field sites (as which there are many) in the local area before using the convenience of our green belt.

Object

Representation ID: 1273

Received: 13/12/2021

Respondent: Robert Atkinson

We are picking up the shortfall in houses for the Black Country plan and North Birmingham. More needs to be done to source and evaluate Brown field sites (as which there are many) in the local area before using the convenience of our green belt.

Object

Representation ID: 1278

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Pattingham is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1279

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Pattingham is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1289

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policy DS3 - The Spatial Strategy to 2038 are developed through out of date data and insufficient technical evidence.

Support

Representation ID: 1296

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

We welcome the fact that Cheslyn Hay/ Great Wyrley is now proposed for some additional growth and allocations (including site 536a south of Holly Lane), reflecting its status as one of the highest performing settlements in sustainability terms

Object

Representation ID: 1297

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

Cheslyn Hay/ Great Wyrley is still underrepresented compared to the other Tier 1 Villages and this is not supported by the evidence base. Miller consider a further allocation (Option 2) is justified as if the wider land parcel (Option 3), which as a minimum should identified as safeguarded land. New Safeguarded land in line with NPPF 2021 is justified with 15 years worth - 3645 dwellings based on standard method or over 10000 homes if a higher proportion of unmet need is accounted for.

Support

Representation ID: 1312

Received: 13/12/2021

Respondent: J Holt & Sons

Agent: Spawforths

Concerned that Policy DS3 does not seek to establish a total requirement for employment land or establish an appropriate framework for the whole Plan period to support
the delivery of objectively assessed employment land requirements and any unmet need arising from outside South Staffordshire.

Object

Representation ID: 1316

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Wombourne is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1323

Received: 13/12/2021

Respondent: Mr - Lacon

Agent: Mr William Dale

It is considered that allocations should be made at Perton in accordance with the Councils spatial strategy and other strategic objectives.

Object

Representation ID: 1328

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1337

Received: 13/12/2021

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Wombourne is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1345

Received: 09/12/2021

Respondent: Seven Homes

Agent: RCA Regeneration

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable areas and is over reliant on urban extensions which require significant infrastructure to be made sustainable.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.