Preferred Options November 2021

Object

Representation ID: 1114

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Sustainability Appraisal – concerns over lack of flooding, ecology and heritage evidence and over-statement of case in relation to education
Rural Services and Facilities Audit – Lower Penn has been omitted until the 2021 version, which treated outlying areas differently to the village centre and the Council has not provided documentation of how this approach was decided upon. The whole parish should be designated as a Tier 5 village as it was in the 2012 local plan. The 2019 spatial strategy clearly states small villages will get a maximum of 10% of homes on small sites, which Site 582 exceeds.
Green Belt Review – Site 582 is given a lower harm rating than surrounding land but is not separated from it.
Population growth in the Local Plan is expected to outstrip national population growth rates and is not justified or supported by sufficient infrastructure.
Duty to Co-operate – there is no requirement in law to accept overspill from neighbouring authorities and insufficient regard has been given to brownfield land funding and sites or vacant properties in the Black Country

Object

Representation ID: 1115

Received: 11/02/2022

Respondent: Lower Penn Parish Council

No assessment has taken place of how the homes will be accommodated in Wolverhampton’s infrastructure. Wolverhampton primary schools & GPs have limited capacity. Limited public transport from Merry Hill and limited shops in walking distance. Catchment high school is Wombourne High and can only be accessed by car via unsuitable road network, contrary to climate emergency. The report itself indicates no surveys of cross-boundary infrastructure have been undertaken.

Object

Representation ID: 1116

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Strategic objective 1 – Compensatory Green Belt will not ameliorate loss and there are not exceptional circumstances to release it
Strategic objective 2 – 4,000 houses for the Black Country and urban extensions should be removed and reviewed following the adoption of the Black Country Plan.
Strategic objectives 3-5 – should only relate to housing needs in South Staffordshire, not the Black Country
Strategic objective 12 – is wholly inadequate, this objective should be much higher up in the plan. As well as mitigation of sites, the overall approach to development location should reduce climate change emissions and accepting large numbers of housing from the Black Country undermines this goal. South Staffordshire has committed to a climate emergency but has not addressed these issues in its planning framework.

Support

Representation ID: 1117

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Policy DS1 is supported but the removal of sites from the Green Belt in SA1-7 is not supported.

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: 1119

Received: 11/02/2022

Respondent: Lower Penn Parish Council

The need for a new settlement is far from proven and the current inclusion of 4,000 homes for the Black Country is not justified or consistent with climate goals.

Support

Representation ID: 1120

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Support the need for a masterplan and design code.

Object

Representation ID: 1121

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Site 582 should not be released:
- the 4,000 dwelling contribution is unjustified
- the 35% uplift to the Black Country’s housing needs is arbitrary and hasn’t been targeted at brownfield regeneration
- changes to retail and office provision may increase Black Country housing supply
- South Staffordshire is over providing against its target by 1153 homes
- Impact on Green Belt purposes
- Heavily car dependant increasing CO2 emissions
- Impacts on amenity and landscape
- Flooding and water issues (including photos of local floods)
- Is in a Groundwater Source Protection Zone
- Inadequate drainage; site given a ‘red rating’ for sewerage capacity by STW, saying that connections to sewer network should be ‘discouraged’ and connections to foul ‘prevented’
- Highways safety issues (including Community Speed Watch Data and Road Traffic Acceidents)
- Wlidlife including habitats linking into a nature reserve (including Ecological Report)
- Inadequate local services (including schools and education)
- Distance from employment
- Heritage assets (World War II battery) yet to be examined

Object

Representation ID: 1122

Received: 11/02/2022

Respondent: Lower Penn Parish Council

EQ1 – Green Belt removal is non-complaint with this
EQ3 – Undesignated heritage assets make site 582 non-compliant
EC11 – Policy not followed in site selection
HC14 – Health impacts not examined in any depth
HC1 – 95% of properties should be 3 bedrooms or less
HC3 – Affordable housing should be increased to 40%
HC4 – All developments should include 30% minimum older persons housing
NB5 – Battery Storage Sites and other renewable energy generation sites needed to facilitate decarbonisation should be integrated into the Local Plan
NB6 – The 31% reduction in regulated emissions will not address significant embodied carbon emissions or the performance gap in ‘as built’ dwellings. Low carbon heating systems should be built into the Local Plan.

Object

Representation ID: 1123

Received: 11/02/2022

Respondent: Lower Penn Parish Council

Agree that policies are strategic, but another strategic policy is required to limit the impact of development of Climate Change, including its location and impact on development in more sustainable locations