Preferred Options November 2021

Object

Representation ID: 1492

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

No. It is recognised that the Council have gone through a process of commissioning and considering
evidence, however D Morgan PLC are of the view that whilst the correct documents have been
compiled, their content and use is deficient and in conflict with the NPPF and local policies as to how
they are applied. Promoting sites references: 116 + 131.
Sustainability Appraisal
The Sustainability Appraisal relies on the Rural Services and Facilities Audit 2021. It crucially does not take into account a key rail corridor for commuting into the GBHMA.
Critical of the SA's assessment of sites 116 & 131. Request a number of actions to remedy the SAs assessment of the sites (p27).
Strategic Housing and Employment Land Availability Appraisal (SHELAA)
Request a number of actions to remedy the SHELAA assessment of the sites (p27).

Object

Representation ID: 1493

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

Q1 cont...
Green Belt Study
The Green Belt Study has not been updated since the previous round of consultation which means that
references to national policy throughout are outdated. sites submitted to the Council since 2019 for consideration as part of the Call for Sites/SHELAA process, have not been identified and considered. Remain concerned that the Council’s strategy will lead to the ‘leapfrogging’ of the Green Belt.
Housing Site Selection Topic Paper
Sets out why sites 116 and 131 should be allocated.

Object

Representation ID: 1494

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

a) No.
b) Yes.
The Chase Line is a major asset to the District in terms of accessibility to surrounding settlements, towns and cities, including the GBHMA however the emerging Local Plan does not emphasise its presence. The baseline position is significantly outdated and results in an unsound and flawed assessment.

Object

Representation ID: 1497

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

a) No
b) No. Whilst the Council have identified the correct policies (see pages 1-20) we do not consider the Council’s implementation of them will result in the vision being achieved, owing to conflict with the proposed strategic objectives.
D Morgan PLC does not agree with the vision and strategic objectives as currently worded. We consider
that the vision and strategic objectives could give rise to isolated communities, highly reliant on the private car for travel and creating a conflict with the settlement hierarchy (Policy DS3).
Proposed revised wording to SO2.

Object

Representation ID: 1504

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

No. D Morgan PLC supports locating growth in the most sustainable locations, and although Policy DS3 appears to agree with this approach, the strategy has not been implemented in the manner stated; many proposed allocations are in locations that are not sustainable. Suggests wording changes to DS3. We request that the Council implements its strategy as it sets out in Strategic Objective 2 and Policy DS3, with growth being located in the most sustainable Tier 1 settlements. Failure to direct growth to these most sustainable locations will inevitably result in unsustainable development and isolated communities, something which Strategic Objective 2 and Policy DS3 and national policy seeks to avoid.

Object

Representation ID: 1506

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

No. D Morgan PLC considers that the Council’s attempt to identify a new settlement is contrary to national policy which seeks to ensure that the planning system contributes towards sustainable development.
The Council’s plan period runs from 1 April 2018 to 31 March 2038; there is therefore no requirement
for the Council to consider planning beyond this date. The commitment to longer-term growth aspirations for a new settlement pre-empts any future changes to national policy, demographic projections, and any findings arising from future evidence base studies.

Object

Representation ID: 1508

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

a) No
D Morgan PLC do not support strategic housing allocations Policy SA2-SA4 and do not believe the Council’s evidence is adequate in justifying their inclusion for the reasons set out in this submission which evidences that these proposed allocations are in conflict with Local Plan and national policy. There is no justification which explains why our
client’s sites rank poorly than site refs 486c and 646 a&b. As an alternative to the unsustainable sites proposed for allocation, we propose the inclusion of our client’s sites (refs: 116 and 131) at Cheslyn Hay/Great Wyrley which utilise Landywood Station on the Chase Line.

Object

Representation ID: 1509

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

b) No
We consider that strategic allocations SA2, SA3 and SA4 to be unsound so therefore a masterplanning exercise is premature and unnecessary at these sites, and would be in conflict with NPPF. If the Council proceeds with its current approach, without ensuring adequate evidence and justification have been prepared, it is likely to encounter difficulties at examination, reflecting a similar
situation to that experienced by the City of York Council.