Preferred Options November 2021

Object

Representation ID: 1808

Received: 10/12/2021

Respondent: IM Land

Agent: RPS Group

Ongoing discussions between the site promoter for Site 705 Perton and the County Highways Authority have reached an agreement that proposed improvements to the A41 Wrottesley Park Road junction could mitigate cumulative traffic impacts. A contribution to secondary education transport could also be provided. There is therefore no transport or highways reasons the site should not be allocated for development,

Object

Representation ID: 1811

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Sustainability Appraisal (SA):
The Sustainability Appraisal fails to separately assess the allocated part of site 591 from the wider site. This could affect the sites score and should be remedied in the next iteration of the SA.

The major negative score for Site 591 against landscape should be changed, as 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.

Site 591 should score ‘neutral’ or ‘uncertain’ natural resources, as the site is not agricultural land and has no designated habitats.

Site 591 should be a ‘minor positive’ under health and wellbeing as it is unclear why non-A&E hospitals, such as Cannock Chase Hospital, have not been included.

Site 591 should be a ‘minor positive’ against transport and accessibility, as access to Hednesford Railway Station is still reasonable in the context of a rural district and it is unclear what weighting has been given to different scoring criteria.

Threshold for secondary education under education criteria should be increased to reflect the 3 mile distance used in national and local guidance, and Site 591 re-scored as ‘minor positive’ accordingly.

Economy criteria should be amended to ‘minor positive’ to reflect the employment sites in Huntington within close proximity of the site.

The site selection topic paper and SHELAA contains no constraints that suggests the site cannot be allocated.

Support

Representation ID: 1812

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

The plan period should be made consistent with others at a similar stage (e.g. the Black Country) and should use a 2039 end date. Vision and objectives are broadly supported and align with the allocation of land at Limepit Lane.

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: 1814

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Paragraph 4.25 should be amended to allow for design-led approaches that can demonstrate increased levels of housing growth are suitable and deliverable. The RSFA fails to take account of the close proximity to facilities in Cannock via walkable routes. If these facilities are taken into account Huntington would score ‘green’ rather than ‘amber’ on criteria B.1.

Support

Representation ID: 1815

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Support allocation of Site 591 but the scale of housing shortfalls across the GBHMA and relative under-provision in Huntington provide a clear justification for increasing the level of housing provided in Huntington. This can be achieved by increasing the size of Site 591 or by increasing its capacity. The latter approach could achieve a capacity of 54 dwellings.

Object

Representation ID: 1855

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Sustainability Appraisal (SA):

The major negative score for Site 591/592 against landscape should be changed. Green Belt is a strategic designation unrelated to landscape and assessed parcels are far larger than the actual sites. A separate Green Belt and landscape analysis of the site provided by Tyler Grange suggests the sites is moderate landscape sensitivity and moderate Green Belt harm.

Site 591/592 should score ‘neutral’ or ‘uncertain’ under natural resources, as the site would not represent an inefficient use of land and has no designated habitats.

Site 591/592 should be a ‘minor positive’ under health and wellbeing as it is unclear why non-A&E hospitals, such as Cannock Chase Hospital, have not been included.

Site 591/592 should be a ‘minor positive’ against transport and accessibility, as access to Hednesford Railway Station is still reasonable in the context of a rural district and it is unclear what weighting has been given to different scoring criteria.

Threshold for secondary education under education criteria should be increased to reflect the 3 mile distance used in national and local guidance, and Site 591/592 re-scored as ‘minor positive’ accordingly.

Huntington has ‘medium’ access to employment in RSFA, but the SA scores it as having ‘unreasonable’ access to employment. Economy criteria should be amended to ‘minor positive’ to reflect the employment sites in Huntington within close proximity of the site.

The site selection topic paper and SHELAA contains no constraints that suggests the site cannot be allocated. Land south of Limepit Lane is equally deliverable and developable to land north of Limepit Lane, which has been allocated.

Support

Representation ID: 1856

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

The plan period should be made consistent with others at a similar stage (e.g. the Black Country) and should use a 2039 end date. Strategic objectives support allocation of larger Limepit Lane land parcels for additional housing and GB compensatory land, contributions to nearby rugby clubs, links to nearby larger settlements (Cannock/Hednesford) and comprehensive landscape and biodiversity design.

Object

Representation ID: 1857

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

The contribution towards unmet needs should be revisited to account for the August 2021 Black Country Plan consultation. The release of Green Belt land on Sites 591/592 is therefore an appropriate strategy.

Given the disparity in size between Parcel S4 in the Green Belt Study and Sites 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. The site is a small proportion of the wider parcel. The site boundaries used in the Green Belt Study don’t reflect the site submission and include land within the AONB. A separate Green Belt and landscape analysis of the site provided by Tyler Grange suggests the site is 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: 1858

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

The local assessment of housing need should be revisited to account for 8,550 jobs growth provided for by WMI and the potential employment land oversupply of 254-273 hectares in the District.

Events have moved on since the Strategic Growth Study (SGS) was published in 2018, with the Black Country’s need increasing and supply diminishing over a different timescale to the SGS’s preparation. The Black Country’s unmet need has not been appropriately factored into the housing requirement or the strategic locations in the SGS.

The RSFA fails to take account of the close proximity to facilities in Cannock via walkable routes. If these facilities are taken into account Huntington would score ‘green’ rather than ‘amber’ on criteria B.1. Huntington has a disproportionately low amount of growth compared to other Tier 2 settlements with insufficient explanation given to justify this approach. As there will be no remaining safeguarded land in Huntington once Site 016 is released, further safeguarding land should be identified, in order to provide a continued and available release of land to meet future needs beyond the plan period.