Preferred Options November 2021

Object

Representation ID: 1475

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Savills

No - Update the employment land needs attributable to South Staffordshire including local and strategic
needs and accurately identify the cross boundary unmet needs which the SSLPR has a role to play in
providing for.
Update the understanding of the unmet housing needs both quantitively and qualitatively, arising from
the Black Country, Birmingham and other LPA within the housing market area.
Consider the Green Belt Review alongside the green belt review for the Black Country and the green
belt review for Shropshire to enable appropriate assessment of the land most beneficial to release
from green belt to meet identified needs arising across the LPA areas for unmet needs

Object

Representation ID: 1476

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Savills

The evidence base includes a duty to cooperate (DTC) topic paper but not a statement of common ground of
progress to date with an agreed strategy going forward. The plan does not currently comply with the duty to
cooperate as a result and there is evidence within the Preferred Options Plan (POP) and the DTC Topic
Paper, that cross boundary needs have not been adequately defined. Lack of evidence of South Staffordshire’s employment land needs and lack of proper engagement with all neighbouring authorities.

Object

Representation ID: 1477

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Savills

The principle of giving consideration to the need for a new settlement is supported, but the process by which that consideration is undertaken should be wider than just to South Staffordshire’s administrative area only
and should also have regard to wider cross boundary strategic objectives and needs. A strategic green belt review as proposed would enable the relative merits of sites in different LPA to be assessed on a consistent basis. Joint working with Shropshire and Black Country to consider the merits of a new settlement in the
M54 corridor at J3 which has the potential to meet existing and future needs arising from all three
Local Plan review areas.

Object

Representation ID: 1614

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

2021 SHELAA is not identified within Appendix A of the PO although it is an important evidence base document.
Significant errors in scoring the settlements in Appendix 4 of the Rural Services and Facilities Audit; Weston-under-Lizard is identified as having no public transport access to employment and many other facilities, however the settlement is served by a regular bus service with travel times significantly less than 60 minutes to surrounding local/regional centres including Cannock, Shifnal and Telford. Blymhill is identified as having a village hall but fails to recongnise the various uses of the hall.
Categorisation of settlements should be based upon their access to services and facilities.
No consideration has been given to the ability of settlements to accommodate growth when allocating them a tier within the hierarchy. More residential development would help sustain and enhance existing community facilities.

Support

Representation ID: 1615

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

The vision and objectives seek to enable development that will meet the area’s needs whilst also protecting and enhancing the area’s most important assets.
The Plan’s objectives to provide housing to meet the needs of different groups in the community, including the elderly (strategic objective 4) and to protect and enhance sustainable village centres (strategic objective 8) are supported.

Object

Representation ID: 1616

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

Do not agree that the draft polcies in chapters 4, 5 and 6 will deliver the vision and strategic objectives. See representations made to questions 4, 5, 6, 7, 8, 11 and 12.

Object

Representation ID: 1617

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

Policy DS2 is in conflict with national policy by affording the same level of GB protection to the Open Countryside. Policy DS2 should be amended to align with national policy and recongnise opportunities for sustainable development in non-GB locations which is important due to the extent of the district covered by GB, limited supply of brownfield sites, and the national requirement for 10% of housing growth to be delivered on sites less than 1ha.

Object

Representation ID: 1620

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

The contribution provided to the GBBCHMA housing shortfall may need to rise as ABCA representation to Shropshire Regulation 19 consultation indicates. Additional release of land in South Staffordshire is required to meet Black Country needs.
Level of growth in Tier 4 and 5 settlements is considered to be inappropriate as it fails to recognise their sustainability, helping to protect and enhance their village centres. Failing to plan for Tier4 and Tier 5 settlements will result in the need for housing arising form their local communities being unmet.
Paragraph 4.16 of the consultation document indicates that housing allocations are not required in Tier 4 or Tier 5 settlements to meet the national requirement for 10% of housing growth to be delivered on sites no larger than 1ha. This is contrary to NPPF Paragraph 69 where the 10% requirement is a minimum figure and the allocation of such sites to meet this is necessary for the plan to be found sound.

Object

Representation ID: 1621

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

The plan places a significant reliance on the delivery of four strategic sites (SA1-SA4), such reliance brings into question the deliverability of the plan should any of these fail to deliver at the rate envisaged.
The delivery of infrastructure to serve these sites is fundamental to their delivery and yet the issue(s) are identified for further consideration as part of preparing an SPD. Without these detailed assessments, their is considerable uncertainty as to the deliverability of the strategic sites.
The Housing Topic Paper notes that site SA1-SA3 all have 'major negative effects predicted against the landscape criteria due to GB harm'.
2019 GB study notes that all strategic sites will have either a 'high' or 'very high' level of harm to GB. Release of these sites will therefore result in the weakening of GB.
Less reliance should be placed upon housing delivery from large scale strategic sites with greater level of growth and allocations directed towards lower tier settlements on sites which do not give rise to 'high' or 'very high' levels of GB harm.

Object

Representation ID: 1622

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

2019 GB study indicates that a number of sites proposed for allocation would result in a 'moderate-high', 'high' or 'very high' level of harm to GB (including sites; 224, 523, 536a, 591, and 582). Release of such sites will result in weakening of GB.
Growth proposed on allocations that result in significant levels of GB harm (moderate-high or above) should be directed to sites with a lesser degree of harm.