Preferred Options November 2021

Object

Representation ID: 1351

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

There are a number of elements contained therein which are incorrect or inaccurate. As such, the use of the current evidence base is inappropriate without such errors being corrected and duly considered in full. Particular concerns relate to:
• Rural Services and Facilities Audit 2021 (in relation to the study not considering the capacity of existing facilities and not considering facilities in settlements close to the district).
• Black Country and South Staffordshire Green Belt Study and Landscape Sensitivity Study 2019 (also
referred to as the Green Belt Review 2019 and Landscape Study 2019); In particular, the Council consider releasing and/or safeguarding further
land adjacent to the urban edge of Wolverhampton to meet potential development needs now and beyond the
current plan period (see appendix 2).
• Strategic Housing & Economic Land Availability Assessment 2021;
• Sustainability Appraisal (SA) including Strategic Environmental Assessment (SEA) 2021 (disputes the scoring of sites 494a and 494b including on education (see appendix 3));
• Strategic Housing Market Assessment (SHMA) 2021;
• Housing Site Selection Topic Paper 2021 (sets out a range of points regarding the consideration of sites 494a and 494b).
• Duty to Cooperate Topic Paper 2021.

Support

Representation ID: 1353

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

2a - YES – The correct infrastructure and mechanisms to ensure it is delivered has been identified within the IDP.

2b - NO – There is no other elements of infrastructure which need to be considered at this stage given that it will be based on the individual site allocations and their associated constraints and opportunities.

Support

Representation ID: 1355

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

3a - YES – The correct vision and strategic objectives have been identified but our client does not believe this is
accurately reflected within the proposed site allocations contained within the Preferred Options consultation
documents.

Object

Representation ID: 1356

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

NO – insufficient sites have been identified along the western edge of Wolverhampton and Dudley to achieve
the identified Strategic Objectives. Furthermore, in accordance with the National Planning Policy Framework, the Council should be seeking to safeguard further sites to meet potential development needs now and beyond the
current plan period.

Object

Representation ID: 1357

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

NO – Policy DS1 (Green Belt); the alterations to the Green Belt boundary should be amended to both
accommodate the proposed site allocations as well as safeguarding further sites to meet potential development
needs now and beyond the current plan period. This approach would accord with National Planning Policy as
outlined below.
Our client raises no comment with regard to proposed Policy DS2 (Open Countryside).

Object

Representation ID: 1359

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

NO – the proposed Spatial Strategy within the Preferred Options consultation does not reflect that which was identified within Option G of the previous Spatial Housing Strategy & Infrastructure Delivery consultation. Option
G previously identified that 8.5% of the housing need (c. 750 units) should be provided along the western edge
of the Black Country urban areas (Wolverhampton and Dudley).
Whilst there is a reduced unmet need from the adjoining Dudley area, this reduction is not reflective of the
unmet housing needs associated with, and allocations needed to support, the Wolverhampton authority area.
Further sites should either be allocated or safeguarded along the western edge of the Wolverhampton urban
area to ensure housing needs are met now and beyond the current plan period.

Object

Representation ID: 1360

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

7a - YES – However, in accordance with the Council’s own evidence base, further smaller non-strategic sites should be identified for allocation and/or safeguarding along the urban edge of Wolverhampton to support housing
needs now and beyond the plan period.

7b - YES – no further comment.

Object

Representation ID: 1361

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

NO – The Council has failed to identify sufficient housing sites to the west of Wolverhampton and Dudley to
achieve the Housing Spatial Strategy previously identified. At present the Preferred Options currently identifies only site 582 on the western edge of Wolverhampton and none along the edge of Dudley. The Spatial Strategy sought to provide approximately 8.5% of the housing need (c. 750 units) within this area of search and, as such, further sites should either be allocated, or at a minimum safeguarded, along this urban edge.