Preferred Options November 2021

Object

Representation ID: 1013

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

No evidence of cross-authority agreements through DtC.
The 2014 LUC GB Review is fundamentally flawed as it concluded that Parcels 1, 2 and 4 of Codsall perform the 4th purpose of GB, however case law has since identified that this purpose of GB only applies to historic towns such as Oxford, York etc.
The 2019 LUC GB review stage 1 assessment is based on inconsistent parcel sizes with some being of 'odd' shape and so large meaning character assessment is flawed. As such, GB study is unfit for purpose. Within stage 2, Site Specific Assessments, Site 222 - Sandy Lane - has not been updated to reflect completion of Watery Lane site.
The interpretation and reflection of the GB study is incorrect as strategic Bilbrook/Codsall extension was defined as making important contribution to GB. This proposal allows coalescence of Wolverhampton and Codsall/Bilbrook - contrary to purposes of GB. The contribution of a First School is irrelevant in GB terms.
Disagree with 2015 Landscape Sensitivity Report and 2019 GB and Landscape Sensitivity Study conclusions that Site 222 Sandy Lane has 'high' GB impact as it has been aggregated with areas to the north and west of Codsall. Consideration should be had to Watery Lane development and smaller parcel assessment sizes. Do not agree that land east of Bilbrook is 'low' impact by comparison.
2019 GB Study should be described as Landscape Sensitivity Study on its cover. It does not address landscape impact other than GB harm within Stage 2 process. Landscape should not be considered within GB assessment as it is not a consideration of the purposes of GB. Site S41A (inc. Sandy Lane, Codsall) is shown in Figure 7.3a as having Moderate/High harm whereas site S46C (linc. land east of Bilbrook) has mixtire of High and Very High harm and should be ruled out for development on VSC grounds.
The submitted Heritage Statement shows that the indirect impacts on heritage assets identified in the 2019 Historic Environment Site Assessment II can be mitigated despite negative assessment of this within the SA.

Object

Representation ID: 1019

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Not currently a need for First School places and so land East of Bilbrook is generating its own school place needs - the infrastructure is being generated out of the development when it should be the other way around. This method is also established in the 2019 IDP, and such a justification is contrary to planning and GB policy.
It is disagreed that Site 222 (Sandy Lane, Codsall) could not deliver a First School for 3 reasons: Firstly, no approach to the landowner (Hallam Land) has been made. Secondly there is not need for the school as there is sufficient nearby provision. Thirdly the provision of infrastructure is an inappropriate methodology for the selection of GB release.
Site 519 fails the GB purposes 1 and 3 as set out n the 2019 GB Study. It is not understood how Site 519 does not fail GB purpose 2.
The issue of providing infrastructure is not specifically mentioned in the Issues and Challenges section of the PO.
Site 224 (land off Station Road, Codsall) has been justified by its ability to provide railway station car park when this has already been provided this is an illogical justification.
Site 222 (Sandy Lane, Codsall) could provide recreation/open space.

Support

Representation ID: 1020

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

The vision is sufficiently broad to be acceptable to everyone.

Object

Representation ID: 1024

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Sites like Site 274 (land south of White Hill, Kinver) represents a major incursion into GB and near to Kinver Edge SSI. Site 419 (land at Keepers Lane, Codsall) is prominent with no clear, definable urban edge. Site 519 (land east of Bilbrook) is contrary to GB policy due to coalescence with Wolverhampton - something specifically highlighted as integral for protection in GL Hearn GBBCHMA Study.
(Former) Sites 443 and 209 of the 2018 SAD already seriously breached GB policy and further extension to this is unacceptable. Proposed dwellings in this 'extension' should be redistributed around multiple sites within Codsall including Site 222 (Sandy Lane, Codsall) and Policy DS1 should be amended to reflect this position.

Object

Representation ID: 1029

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

It would be more logical to use 2018 GL Hearn/Wood report for starting point to choosing sites as this has been prepared at a strategic level using objective criteria for entire conurbation thus removing elements of subjectivity.
Concerns that the infrastructure led strategy is driving choice of GB sites over more sensitive sites with the consequence that more sensitive, logical GB sites that align better with GB policy are omitted.
The Strategy is over-reliant on a small number of large sites such as Strategic Allocations at Cross Green (Policy SA2), Linthouse Lane (SA3) and land east of Bilbrook which may be slow to delivery and thus undermine targets.
GBBCHMA shortfall appears to have increased since shortfallw as initially identified. Recent studies by Barton Willmore and Turley have shown much higher levels of housing shortfall that has not been tested by the Council. 4,000 homes offered may not be enough.
The offer of 4,000 is minimal and there should be discussion as to varying levels of housing provision. The Standard method is also set to be reviewed with housing provision diverted to areas promoted for "levelling up" such as the midlands - thus increasing housing targets. This should be kept under review and change if necessary.
Consent for SRFI at Four Ashes and growth of i54 is likely to boost housing need beyond Standard Method target. Greater pressure for larger (and higher quantity of) homes due to working from home patterns continued post-Covid.
Assessment for permission lapses (eg. 5-10%) needs to be had and an allowance for sites granted/delivered outside of plan period.
Not content with level of housing allocated for Codsall/Bilbrook as its level of provision has fallen back proportionately compared to Penkridge and some other settlements since the Issues and Options plan.
Do not support the proposed direction of growth on the edge of Bilbrook/Codsall which does not conform to advice in Greater Birmingham HMA Study where growth would occur to the north of Codsall. The Council's proposed distribution conflicts with the technical advice on GB criteria.

Support

Representation ID: 1038

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Generally supportive of the need for longer term growth aspirations and the responsibility of the Council to look beyond the current plan period.
A new settlement should not been seen as a once and for all golden bullet to overcome the development pressures within the District.
It is welcomed that the Council has taken a pragmatic approach in seeking to identify a new settlement site through an area of search and not by allocating a large site and hope development will come forward.
Meanwhile, and alongside this, the Council must ensure they continue to provide a wide portfolio of different sizes sites throughout the District.

Object

Representation ID: 1041

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Approach adopted by the Council for its 4 strategic allocations seems to 'change the rules' for identifying housing sites. Sites SA1 - SA4 adopt different principles and it is suggested that due to their size and infrastructure requirements they may need to be immune to certain s106 contributions, yet the purpose of their allocation is to pay for infrastructure.
Site 519 (land east of Codsall/Bilbrook) runs counter to GB Policy by coalescing Codsall/Bilbrook and Wolverhampton. GL Hearn report identified such an area as localised restraint to protect this. The Council's approach contradicts this advice.
Greater Birmingham HMA Strategic Growth Study highlights an area of GB release (Location PD2, land north of Codsall/Bilbrook) as one of their choices for development. The Council has ignored the advice that growth should be in the north and not east of the settlement in the PO Local Plan.
Shortcomings in the 2015 Landscape Sensitivity Study have ben reflected in the Sustainability Appraisal and GB Review.
Land to the east of Codsall/Bilbrook is also High Quality BMV Agricultural Land - Grade 2.
2019 GB Review highlights Site 519 (area to the east of Codsall/Bilbrook) as Very High or High in terms of harm, whereas land to the north of Codsall is Moderate/High harm.
The evidence base is inconsistent. It is noted that Appendix 5 (Policy and Physical Constraints Paper) of the 2019 Spatial Housing Strategy and Infrastructure Deliver Report has been ignored the fact that the land which is High and Very High harm is east where the strategic site has been selected. Also, it fails to explicitly set out the implications of the Moderate/High harm rating of the land north of Codsall.
The Council has contradicted it's consultants advice and evidence base by choosing an area of High or Very High harm in selecting its choice of strategic sites in particular land to the east of Codsall/Bilbrook. Appendix 5 of the Spatial Housing document identifies there should be growth to the north of Codsall/Bilbrook (Area PD2).
The Council has not made a reasoned case for land east of Codsall/Bilbrook, it simply explains the purpose of the allocation and facilities to be provided. For site SA1: it appears that the new community would integrate into the existing community but so would any strategic location. It would deliver a new First School, but this is only justified through the scale of proposed development and would apply to such a development elsewhere. It would be master-planned according to a SPD which applies to any urban extension. Sites 443 and 219 of 2018 SAD already extend Bilbrook to the east and the Council may feel the "damage has been done", however site SA1 is more damaging to fragile GB location.
Any site chosen as a Strategic Development location should be supported by a site-specific masterplan and design code as per 2021 NPPF requirement.

Object

Representation ID: 1042

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Some allocations (especially those in GB) are more sensitive than the land north of Codsall/Bilbrook - specifically site 222 (Sandy Lane, Codsall).
Allocation 419 (Keepers Lane/Wergs Hall Road) is a prominent site without clear and logical boundary to extend to.
Site 224 (Station Road, Codsall) has been selected on ability to provide railway car park, but this is not a purpose to override GB policy and unlikely to demonstrate exceptional circumstances test.
Site 228 (Histons Hill, Codsall) is an undeveloped 2018 SAD site and might be better allocated for employment use.
Allocation of Site 222 (Sandy Lane, Codsall) would complement development at adjacent Taylor Wimpey site and would be consistent with conclusions with GL Hearn to development Location PD2 to the north of Codsall.
Stage 1 of 2019 GB report is flawed due to the extent of assessed land parcels (S41) whilst Stage 2 is flawed by aggregating all land to the east, north and west of Codsall Conservation Area so potential impact of future development is all areas has been judged together. This has exaggerated harm by combining with more sensitive sites. A more fine-grained assessment is required.
As Watery Lane site has been developed. the context of the Sensitivity Assessment as altered, and Sandy Lane is now effectively surrounded by development on three sides.
Site 222 (Sandy Lane, Codsall) has clear potential for development due to easy access to local facilities/services.

Support

Representation ID: 1043

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

General support for the formalisation of WMI.
The policy will need to consider its impact upon housing demand and emerging need for affordable housing.

Object

Representation ID: 1044

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Policy HC1: level of prescriptiveness may turn out to be counter-productive. No justification for all development to have mixture of property sizes, types and tenures - smaller schemes or specialist development more suitable to singular type/tenure. Onset of Covid-19 justifies larger percentage of large properties to accommodate home-working. Flexibility in the interpretation of the requirement for affordable housing to conform to Housing Market Assessment depending upon prevailing economic circumstances.
Policy HC2: proposes relatively high density for suburban/rural district. Density should be determined to reflect local circumstances with no 'target' or 'limit'.
Policy HC3: level of AH provision should reflect local circumstances and viability studies and should be negotiated from this.
Policy HC7: Do not agree with proposed approach - allocation of a number of smaller scale self-build sites should be preferred over quotas of plots upon allocated sites where self-build doesn't fit with management, security and timescales.
Policy HC9: policy needs to be applied flexibly to ensure scope for variety and avoid mediocrity.