Preferred Options November 2021

Object

Representation ID: 1802

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

Duty to Co-operate Statements: The Council has failed to prepare a Statement of Common Ground (draft or finalised) contrary to PPG requirements. Unclear how legal test of ‘constructive and on-going’ engagement has been met.

Sustainability Appraisal (SA):
Reasoning behind post-mitigation scores is not clear. Question the relevance of Green Belt in landscape objective as it is not a landscape designation. Previous proposals and inspectors decisions (06/00638/OUT) indicate Site 170 would not have significant landscape impacts and score should be ‘neutral’.

Any potential noise, air and water quality effects can be mitigated through design on Site 170, so the sites score against pollution and waste should be ‘neutral’.

Site 170 is incorrectly classified as BMV agricultural land, with no evidence that it is Grade 3a. No score should be applied against natural resources given errors in methodology.

Under health and well-being, dispute the finding that Site 170 is over 800m from a GP surgery due to distance indicated on Google maps measurement tool (710m).

Transport and accessibility: 800m is a more appropriate catchment for a bus stop, in accordance with Manual for Streets and the national definition of walkable neighbourhoods. The SA incorrectly concludes Site 170 is over 2km from a convenience store.

For education a higher threshold of 3 miles should be applied for secondary education to reflect Department of Education guidance.

The Hansen scores in the RSFA indicate Featherstone is in the upper half of Hansen scores (i.e. ‘medium’ access to employment), and this has not been correctly reflected against Site 170 in the SA.

Object

Representation ID: 1803

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

The IDP should be amended to reflect the presence of a health centre in Featherstone and the potential opportunities to maximise the future viability of this infrastructure. Emerging infrastructure opportunities should be considered alongside existing ones in the Featherstone area. There is significant uncertainty about the delivery of the Cross Green road link, park and ride and primary school, making it difficult to determine if this allocation is deliverable. In light of this uncertainty, greater consideration should be given to additional allocations to act as contingency sites should strategic allocations not come forward as expected.

Support

Representation ID: 1804

Received: 06/12/2021

Respondent: Persimmon Homes

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.

Object

Representation ID: 1805

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

Agree that lack of other options to accommodate the District’s growth needs as well as helping neighbouring authorities address their housing needs are exceptional circumstances justifying Green Belt release. The 4,000 dwelling contribution should be revisited in light of the Black Country’s increasing unmet needs. Extra Green Belt should be released, including Site 170. Parcel S20G of the Green Belt Study fails to assess Site 170 separately despite differences between the parcel and site. A separate Green Belt assessment undertaken for the site indicates that the site has a lower harm rating than indicated in the 2019 Green Belt Study. If the site is not released for housing development now it should be considered for safeguarded land to meet housing needs beyond the plan period to 2038.

Object

Representation ID: 1806

Received: 06/12/2021

Respondent: Persimmon Homes

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 rural services and facilities audit fails to take into account Hilton Cross and ROF Featherstone in assessing access to employment. The spatial strategy fails to give sufficient consideration to co-locating jobs and housing, particularly in the Featherstone area. As the SGS may have underestimated unmet housing needs the employment-led area of search should be widened to include Featherstone.

Object

Representation ID: 1807

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

Object to County Highways comments regarding initial concerns on Site 170. A transport strategy has been prepared showing how the M54/M6 link road will release capacity to accommodate new development.

The HESA’s assessment of Site 170’s setting is arbitrary in nature and not robust. The potential to accommodate a stand off of 330m to Moseley Old Hall should be reflected in the assessment. Loss of agricultural land, development within mineral safeguarding areas and coal authority high risk areas, requirements for flood risk assessments should not be recorded as constraints as they would not prevent development. Reference to a large area of TPOs in the centre of the site is erroneous.