Preferred Options November 2021

Object

Representation ID: 723

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Define Planning and Design Ltd (on behalf of Bloor Homes Ltd)

Whilst the evidence base appears to be broadly robust and proportionate, BHL has concerns in relation to the Black Country and South Staffordshire Landscape Sensitivity Assessment (LSA) and the Council’s Strategic Housing Market Assessment (SHMA).

As a result of its methodology, the LSA's findings do not always relate directly to subtleties in a site's landscape sensitivity, which should be considered in assessing sites.

The SHMA should be revisited to consider what level of uplift above SSC's LHN would be appropriate to reflect the economic context in the plan period, which is likely to create an uplift in housing demand.

Object

Representation ID: 1816

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Land North of Bridgnorth Road, Wombourne (Site Reference 283)

Representation made on behalf of Bloor Homes Limited in relation to promoting land for residential development. Representations were submitted to the previous Spatial Housing Strategy & Infrastructure Delivery consultation in December 2019. Site to be considered as part of the Spatial Strategy that should be reviewed, to elevate the settlement status of Wombourne, as sustainable location, which provides a proportionate amount of homes relative to its size. The housing requirement should
be increased to further address unmet needs given the availability of other suitable and deliverable sites not currently allocated.

Concerns raised that the site is not considered in the Preferred Options.

Object

Representation ID: 1817

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Concerns raised of the start date of the Local Plan being based on anticipated timescale for publication of the plan, rather than written, suggests the start date being 2022 or 2023. Suggestion for the Local Housing Need to be kept under review and altered where necessary through the plan making process until the point of submissions for examination.

Object

Representation ID: 1818

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Concerns into a disconnect between the Plan's identification of a local housing need of 4,881 dwellings over the Plan period of 2018-2038 and the Council's SHMA during May 2021, which notes LHN of 5,068 additional dwellings over the plan period.

No exercise undertaken to be able to consider what unmet need could accommodate the lands or whether there are any other reasons to go above the standard method to meet it's own housing needs.

Object

Representation ID: 1819

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

The Plan notes that neighboring authorities have not explicitly objected to the level of proposed contribution, however the absence of objections is not the test to demonstrate a sound plan has been prepared. There is lack of evidence of how the remaining HMA shortfall will be addressed. The shortfall of homes should be exported to neighboring LPA's through Duty to Co-Operate.

It is noted that the iteration of the Sustainability Appraisal (SA) accompanying the Preferred Options has not tested the effects of accommodating different levels of unmet needs. Local Plan should require a robust evidence to demonstrate the unmet housing needs from neighboring areas which could not be met in within it's area.

In the context of a Plan area that has substantial Green Belt constraint, will continue to generate development needs in the long term (either its own or neighboring areas), consideration should also be given to identifying safeguarded land to meet future development needs beyond the plan period.

Object

Representation ID: 1820

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Concerns raised due to the limitations and lack of information on the Hansen mapping exercise which was undertaken. Assessments should recognise the availability of employment opportunities within an area that may be accessible by sustainable means other than by public transport and also opportunities to develop or provide additional public sustainable transport.

Object

Representation ID: 1821

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

NPPG requires consideration to the appropriateness and likely market attractiveness for the type of development proposed. Bloor Homes puts emphasis that Wombourne has a very strong demand for development in high values areas and the Council's Viability Study 2021 identifies the market values in Locality 5 to be amongst the higher in the Plan area making the site viable. Suggestion on this basis, it is readily apparent that Wombourne should be considered a Tier 1 settlement, commensurate with the Plan’s infrastructure led strategy, and further growth directed towards it accordingly

Object

Representation ID: 1822

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

The proposed allocation of site 463 & 284 (Land off Billy Buns Lane and Gilbert Lane) in Wombourne, is not sound. It is not an appropriate strategy in light of alternative options for housing delivery within village and since the Framework requires plans to allocate land with the least environmental or amenity value. In particular the Council’s evidence identifies it has a greater landscape sensitivity compared to Site 283 and would require significant highway works.

Site 283 would require limited additional highway works since it benefits from a newly established access.

Object

Representation ID: 1824

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Site 283, the key determinant in the Sustainability Appraisal and Site Assessment is the potential for major negative impacts in relation to landscape criteria due to Green Belt harm.

Concerns raised into why the Green Belt assessment has been used as a criteria for the sustainability appraisal rather than the Landscape Sensitivity assessment.

Bloor Homes finds that the site affords less of a contribution to the Green Belt than the wider land parcel of S72.

The release of this land from the Green Belt for a
proposed development would have an effect on spatial openness, but it is unlikely to have a harmful effect on the visual openness of the Green Belt. Additionally, the
landscape of the site would enable ecological betterment and bio-diversity net gain through habitat creation, formal and informal landscaping.

Additionally, the landscape of the site would enable ecological betterment and bio-diversity net gain through habitat creation, formal and informal landscaping.

The site adjoins, and can seamlessly integrate with, an existing sustainable settlement. It is well connected and is within walking distance of the village services and facilities. It also offers a substantial amount of
green infrastructure and landscape enhancements.