Question 11

Object

Representation ID: 3234

Received: 12/12/2021

Respondent: Mrs Stephanie Norton

There are significant numbers of houses for sale in Wombourne including many new builds - shows these houses are neither affordable or desirable.
Should create a town like Perton and include all the necessary services and amenities.

Object

Representation ID: 3305

Received: 12/12/2021

Respondent: Mrs P Farrier

HC3- Affordable housing. Doesn't see that the proportion of affordable houses in development will sufficiently meet the areas requirements

Object

Representation ID: 3360

Received: 12/12/2021

Respondent: Mr Nicholas Greenwood

HC1 – I would prefer 80% of properties on major development to be 3 beds or fewer.

HC2, the 35 dph minimum should be extended. There are ways of doing this without going to high-rise. The council’s current 21% norm is wasteful of greenbelt.

HC3, Given that developers are being given the privilege of building on agricultural land they should provide a higher proportion of social rent homes. Starter homes are only affordable for the first buyer.

Object

Representation ID: 3441

Received: 18/11/2021

Respondent: Mrs Lauren Liggett

Already many empty homes in Wombourne - Signiant number of these are new builds proving they are neither affordable or desirable.
New proposed housing is not affordable.

Object

Representation ID: 3490

Received: 12/07/2022

Respondent: Suan Lawson

HC1 - 80% of properties on major development.
HC2 - 35 dph minimum should be extended.
HC3 - Due to developing on agricultural land there should be a higher proportion of social rent homes and starter homes.
Most is not affordable housing - only 15% of recent Beggers Bush development was for social rent.

Object

Representation ID: 3577

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The Draft Plan does not include the proposed wording of the various Development Management Policies, and instead identifies “directions of travel”. The Preferred Options version of the Plan should set out the full proposed policy wording, as opposed to leave this
matter to the pre-submission stage.

The Sustainability Appraisal
Concerns with they way in which the Plan's Sustainability Appraisal is used to inform the site selection process as it is incomplete and fails to properly consider mitigation, and the advantages of making particular allocations.

Example site: Wall Heath shown in Vision Document.

Omission Site – Wall Heath

The land at Wall Heath should be removed from the Green Belt and allocated for residential led development. The site can provide 148 new homes at a
density of 37 dph alongside supporting infrastructure, including 4 hectares of multifunctional open space and the incorporation and enhancements of the existing public rights of way within the site.

Object

Representation ID: 3653

Received: 13/12/2021

Respondent: Mr V Kelly

IDP - requires re-examination of Penkridge.
H2C - 35dw/ha should be lower - density of houses to too high.
HC11, HC17, EC10 - 0.006ha/dwelling is a 25% reduction to the previous provision - not acceptable.
The use of River Penk Flood plains should not be used to offset provision of open space around dwellings.
S106 agreements HC11 -charge developers £65000/ha to pass open space to LA once new homes are built?
S106 agreement - provides the option for developers to maintain ownership of POS and play area -maintenance will be passed onto new residents as an extra charge in addition to council tax?
West Penkridge growth - opportunities for new businesses and community activities which aren't shown in the PLR.

Object

Representation ID: 3657

Received: 13/12/2021

Respondent: Chantal Kelly

There are significant numbers of unsold new development properties in Wombourne already - they are not affordable or desirable.
Proposed housing is not truly affordable first time buyers.

Object

Representation ID: 3660

Received: 13/12/2021

Respondent: Mr Adam Kelly

There are significant numbers of unsold new development properties in Wombourne already - they are not affordable or desirable.
Proposed housing is not truly affordable first time buyers.

Object

Representation ID: 3718

Received: 22/11/2021

Respondent: Sylvia Jones

Windfall housing has not been taken into consideration.

Object

Representation ID: 3720

Received: 22/11/2021

Respondent: Robert Jones

Windfall housing has not been taken into consideration.

Object

Representation ID: 3766

Received: 14/12/2021

Respondent: Iain Parkes

Target fails to take windfall housing into consideration at these sites.

Object

Representation ID: 3769

Received: 23/11/2021

Respondent: Carol Hyatt

The proposed housing is not low cost housing.

Object

Representation ID: 3771

Received: 14/11/2021

Respondent: Mrs Carol Hurley

New development are not truly affordable houses like previous development in Wombourne.

Object

Representation ID: 3856

Received: 13/12/2022

Respondent: Mr D E Marsh

Windfall housing has been vastly understated.
11,193 empty houses across the Black Country should be utilised before green belt is built on.

Object

Representation ID: 3857

Received: 15/11/2021

Respondent: Mrs Jillian Ward

No strategy outlined for use of empty/abandoned homes will be used in the PO.
Houses should be grouped ensuing no one area has increased pressure on services (schools, hospitals ect).
Housing density should be revisited to favour more gardens/ green spaces to support wellbeing.
% of housing should have disability access.
Protection of affordable housing especially if they are going to local young people.
All housing should have green opportunities installed.
South Staffs should develop own areas of natural beauty to ease pressure on Cannock Chase.
Naturally re-wilded development land banks should be protected instead of developed.
Nature based flood protection.

Object

Representation ID: 3879

Received: 14/12/2021

Respondent: Save the Seven Cornfields Campaign Group

Amount of windfall housing has been underestimated.
More affordable housing is needed. Not just housing.
Lack of regard for affordable housing for younger people.

Object

Representation ID: 3891

Received: 10/12/2021

Respondent: Mr - Yeomans & Messrs Law

Agent: PlanIt

Summary: HC1 - do not support direction of travel for HC1. 75% of houses to be 3 bedrooms or less is too prescriptive, policy needs to more flexible.
Object to the principle of refusal of schemes with a disproportionate amount of larger homes. Disproportionate is not clear and disregards the demand for executive style housing in South Staffordshire to retain and attract higher income households.
HC11 - there is no evidence to support the proposal to meet nationally described space standards.
The imposition cannot be justified in policy terms and are not appropriate in South Staffordshire

Object

Representation ID: 3902

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

HC1 - do not support direction of travel for HC1. 75% of houses to be 3 bedrooms or less is too prescriptive, policy needs to more flexible.
Object to the principle of refusal of schemes with a disproportionate amount of larger homes. Disproportionate is not clear and disregards the demand for executive style housing in South Staffordshire to retain and attract higher income households.
HC11 - there is no evidence to support the proposal to meet nationally described space standards.
The imposition cannot be justified in policy terms and are not appropriate in South Staffordshire

Support

Representation ID: 3904

Received: 13/12/2021

Respondent: South Staffordshire College

Agent: Carter Jonas

HC16 - Support for proposed Policy HC16
which seeks to retain the existing policy wording of adopted Policy EV4. A policy which aims to support the ongoing use of Rodbaston for educational and training purposes whilst recognising that appropriate business start up activities on the site will complement the primary use of the site for education and training purposes is welcomed. It is important for Rodbaston to be recognised as such in a distinct policy within the emerging Local Plan

Support

Representation ID: 3940

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

HC7 – Consider the policy direction proportionate to the level of evidence.
HC9 – Support the introduction of new requirements, any design requirements should not be deferred to an SPD.
HC12 – Support EV charging, subject to conformity with Building Regulations.
HC19 – Support as part of strategic development

Support

Representation ID: 3941

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

HC9 – Support the introduction of new requirements.
HC12 –Support the proposed approach.
HC19 – Support as part of housing development
NB6 – Support the direction of travel, Cameron Homes already apply a 'fabric first' approach to design.

Support

Representation ID: 3942

Received: 13/12/2021

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Support Policy HC5.

Support

Representation ID: 3943

Received: 12/12/2021

Respondent: Keon Homes

Agent: Evolve Planning & Design

HC19 – Support as part of housing development
NB6 – Support the direction of travel, Keon already apply a 'fabric first' approach to design.

Support

Representation ID: 3944

Received: 12/12/2021

Respondent: Lovell Homes

Agent: Evolve Planning & Design

HC9 – Support the introduction of new requirements.
HC12 –Support the requirement for electric vehicle charging.
HC19 – Support as part of development
NB6 – Lovell support the approach and already apply a fabric-first approach.

Support

Representation ID: 3981

Received: 12/12/2021

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

We have not considered in detail the Homes and Communities Policies which determine how development is considered.

Although we agree with policy H13 we note that H13 Health and Wellbeing isn’t being complied with when taking into consideration the wellbeing of the residents adjacent to the proposed development at Site 582. There will be increased noise, air pollution and light pollution in the vicinity of where they live.

HC14 and HC15 specifically consider the impact on health and education. HC15 refers to the Staffordshire Education Infrastructure Contributions Policy and this policy notes that when ensuring the sufficient supply of school places (as discussed in paragraph 94 of the NPPF), Staffordshire County Council has duties to “secure diversity in the provision of schools and to
increase opportunities for parental choice” (Education and Inspections Act 2006 Part 1 Section 2(3A)).

To understand the impact of a development on education infrastructure in publicly funded schools, an analysis would need to be undertaken using:
• pupil number on roll
• school capacity
• pupil projections during Local Plan period or otherwise
• committed developments and housing allocations in an emerging Local Plan as advised by LPAs on an annual basis
• any other relevant factors

Although we support policy H15 the education infrastructure analysis has not been carried out
pertaining to site 582. During the consultation process we were informed by South Staffs planner Ed Fox that a desk top study only had been carried out looking purely at the vicinity to local schools and not their ability to provide places.

The standard pupil product ratio (PPR) for calculating the number of mainstream pupils attributable from new housing development is 0.03 children per school year group per dwelling. Our group’s analysis of the local schools to site 582 is that there are insufficient places within the local schools adjacent to Site 582 to accommodate this number of additional children. Even
if the local primary school Bhylls Acre can be extended to increase the pupil capacity there is no room for the additional teacher/staff parking that would be required.

We have not considered in detail all of the EC Policies which address community services, facilities and infrastructure.

EC4 -Rural employment. We support this policy in that it retains the existing policy approach of supporting rural diversification with a preference for development within existing development boundaries. Development outside existing villages to be primarily restricted to opportunities
relating to reusing existing buildings. We do however note that a significant proportion of Site 582 is arable land that this is currently farmed and the development of Site 582 will be contrary to policy EC4.

Policy EC11 seeks to: ‘Ensure development is designed to promote high quality walking and cycling, both within sites and to links to nearby services and facilities’ however your policy is without any clear guidance as to how this will happen.

With regards to the NB Policies which address protecting and enhancing the natural environment we note that in NB1 there is an intention to protect, enhance and expanding natural assets however removing Site 582 from the green belt and developing it would be completely
against the proposed Direction of Travel as stated in NB1.
The NB policies which deal with climate change should be linked to policies on the location of development and the corresponding location of amenities and employment. The SSDC approach to climate change is considered too weak when accounting for the long-term impacts
on climate change of such unsustainable development patterns.

Policy NB9 states that ‘’ Proposals for enabling development will be considered and assessed to
determine if the benefits of securing the future conservation of the heritage asset outweigh the
departure from adopted plan policies.’’ This comment appears to place the adopted plan policy higher than the need to protect heritage assets and puts the reliance on the heritage asset to have a higher benefit that the adopted plan in order to save the heritage asset. This appears to undermine the rest of policy NB9 which is the safeguarding of heritage assets and their setting.
This is of particular relevance to the heritage asset on Site 582 which is the Word War II Gun Battery Site.