Preferred Options November 2021

Support

Representation ID: 1551

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

The scope of the evidence base prepared to inform the emerging plan is generally robust and proportionate. However, it is noted that the transport modelling work has yet to be published (expected in 2022). This will be critical to informing the new plan and may require changes to the preferred options consultation plan to reflect its findings.

Object

Representation ID: 1552

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

Notwithstanding the wider, general robustness of the evidence base, there are a number of site specific
inconsistencies regarding the evidence base and the conclusions that have been drawn from it.

Landscape and visual / SA
Site 576 was assessed as a ‘moderate-high’ sensitivity. No justification for this score is provided beyond its location with the parcel. Post mitigation development at the site is capable of scoring ‘neutral’ in terms of landscape and townscape.
Site 576 scores ‘minor negative’ for GP surgery based on it being located wholly or partially outside the target distance to the GP surgery. There is the potential to provide land for a surgery at the site, which
would assist with mitigating the identified capacity concerns at the current GP surgery in Kinver and
would represent a ‘major positive’ for the SA scoring matrix.

Support

Representation ID: 1553

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

We have no objection to the potential junction improvements at White Hill / Meddins Lane and Meddins
Lane / Enville Road, indeed the need for these improvements were first identified as part of the adopted Site Allocation Plan. Land at Hyde Lane (west) could make a proportionate contribution to these off-site highway improvements.

Object

Representation ID: 1573

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

Bellway's proposals for land at Hyde Lane (576) includes the potential to provide land for a new doctor’s surgery to serve Kinver.

Raised some concerns regarding the impact of the access road to ROF Featherstone and the associate costs on the viability and the potential delivery trajectory for the proposed Cross Green allocation (draft policy SA2). The IDP now estimates the cost of delivering this access road at £20m, to be funded via public sector funding and developer contributions. There remains a circa £18.5m gap. It is unlikely that development of the scale proposed at Cross Green (a minimum of 1,200 new homes) would viably be able to meet this gap in funding, particularly given the other significant infrastructure requirements of that site. The access road could potentially compromise when this proposed allocation starts delivering new homes unless the necessary funding is sourced.

Object

Representation ID: 1574

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

The objectives rightly reflect the District’s need for new homes, as well as the contribution to the unmet needs of the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA), and that new development should be focused in sustainable locations either in or around the District’s key villages, or through urban extensions. However, there is no explanation as to which settlements constitute ‘key villages’. It has to be presumed that Tier 2 settlements are included within this definition. In terms of strategic objective 9 it should acknowledge that new development will also maintain and enhance the vitality of South Staffordshire’s rural communities, as recognised by NPPF paragraph 79.

Support

Representation ID: 1575

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

South Staffordshire’s overall spatial strategy to 2038 is supported insofar as it seeks to deliver a minimum of 4,881 dwellings for the district’s own needs, plus a contribution of 4,000 dwellings towards meeting the GBBCHMA shortfall.

The key strand underpinning the spatial strategy that growth is distributed to the South Staffordshire’s most sustainable locations to avoid a disproportionate level of growth in the less sustainable settlements is also supported. This reflects the requirements of the NPPF.

Approach to small and medium sites
10% of housing growth is to be delivered on sites of less than one hectare. This is reflected in Kinver being identified to accommodate 2.5% of the District’s total need. This includes two new proposed allocations (beyond the existing safeguarded site), both of which total 1ha in area. Firstly, we welcome the proposed release of land at Hyde Lane (west) (site 576 under draft policy SA5) from the Green Belt and allocation for housing growth. However, there needs to be some flexibility in the Council’s application of NPPF paragraph 69a) and the 10% provision of sites of 1ha.

Object

Representation ID: 1576

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

The plan period should therefore be extended to reflect that NPPF paragraph 22 states that strategic policies should look ahead over a minimum 15 year period from adoption.

In response to Q2 we have identified some concerns regarding the potential delivery of infrastructure required to support the Cross Green (draft policy SA2) and that this could impact any trajectory for housing delivery at the site. he Council should therefore consider whether there would be merit in identifying a greater quantum of development on allocations or safeguarded land to provide a ‘fail safe’ option.

Support

Representation ID: 1578

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

We have no in principle objection to the proposed allocation at Cross Green (draft policy SA2), although there remain a number of concerns regarding timescales for its delivery. In summary:
There is currently no evidence available as to how the access road will be funded, which is estimated to cost just £20m.
There is no evidence regarding the delivery trajectory for Cross Green. In order to de-risk the plan, there is merit in considering either increasing the quantum of development identified on existing allocations where there is additional capacity. there is the potential to safeguard additional land to the north of land west of Hyde Lane for circa 65 homes.

Support

Representation ID: 1580

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

Wholly support the principle of the proposed release of land at Hyde Lane (west), Kinver (site 576) from the Green Belt and allocation for housing growth. The Council’s evidence base is clear it performs better than other options at Kinver.

In response to Q5 we advocate for a more flexible approach to the area of land being proposed for release from the Green Belt and allocated for housing growth.

Whilst Option 3 does represent a site area greater than 1 hectare, the increase is not considered to be so significant as to represent a departure from the plan’s strategy to provide a minimum 10% of smaller sites, and will ultimately deliver a better designed response to creating a new Green Belt edge in this location.

Support

Representation ID: 1582

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

Policy HC1 (housing mix) – we have no objection to any housing mix reflecting that in the latest Housing Market Assessment. Any policy should however allow for some flexibility in the mix.
Policy HC17 (open space) – whilst there is no objection in principle to open space being provided centrally, the policy should allow some flexibility if the design rationale for a site justifies locating it elsewhere.