Preferred Options November 2021

Object

Representation ID: 1220

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Sustainability Appraisal: Identifies site 238 as having a major negative impact on education. Strongly disagree with the methodology used by the SA. Cumulative development if the site were allocated could provide a new primary school. The site selection topic paper notes the site is 2km from the nearest primary school which is within the walking distance defined by the Education Act.

The Green Belt Study effectively confirms that Perton is already merged with Wolverhampton, which undermines the role and function of the slim strategic slip of Green Belt to the east and south of the site. The SHMA 2021 confirms strong commuting and migration links to Wolverhampton and is functionally part of Wolverhampton’s urban area, supporting the principle of allocating part of Wolverhampton’s housing needs within Perton.

The Strategic Growth Study 2018 shows a significant shortfall in housing is likely to remain in the GBHMA despite the 4,000 dwelling contribution so this should be increased and it would be helpful to understand how the Black Country Authorities feel about the 4,000 units. Concerned that Duty to Cooperate discussions have not taken place regarding a small site allocation proposed by Wolverhampton City Council to the south-east of the site.

Additional detailed Green Belt and landscape rebuttal and highways evidence regarding the A41 junction is also submitted.

Object

Representation ID: 1221

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Strategic Objective 1: Concerned at the lack of clarity of how this objective will be delivered; unlikely that most developers will have control over other land parcels. Do not consider this objective deliverable.

Strategic Objective 2: It is unclear how this contribution is disaggregated across the HMA. Details of agreements made under the Duty to Co-operate should be included in the evidence base.

Strategic Objective 9: Strategy relies on new rail stations but rail is not mentioned in the objective – suggest this is mentioned. The importance placed upon rail does not reflect some of the sites selected (e.g. Linthouse Lane).

Object

Representation ID: 1222

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Policy DS1 repeats the Framework and could be – in part – removed. On-site green infrastructure can be delivered but compensatory improvements create uncertainties for landowners and developers and are unlikely to be deliverable. It is unclear how development in the Green Belt could maintain its character and openness. Encourage the Council to set out the exceptional circumstances required to remove sites from the Green Belt.

Policy DS2 – It is unclear what forms of development would or would not be acceptable in open countryside. DS2(A) should refer to ‘building(s)’. The policy wording as a whole should be revisited.

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: 1224

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Why is the policy included when it applies to a time period outside the scope of the plan -why not extend the plan period instead?

Object

Representation ID: 1225

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

Policy SA2 – Delivery of the site is heavily reliant on the ‘Land at Cross Green SPD’ and there is no clear justification to demonstrate that this allocation can be implemented. As there is no clear timeline for delivery the plan should allocate further sites to ensure it can meet the 8,881 dwelling housing target.

Object

Representation ID: 1226

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous .
HC11 – Suggest flexibility to indicate most development should meet NDSS
HC14 – Amend policy to clarify that development should not solve existing infrastructure problems.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.