Preferred Options November 2021

Object

Representation ID: 1645

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

2021 SHELAA is not identified within Appendix A of the PO although it is an important evidence base document.
SA fails to give sufficient weight to Site 671's location to connectivity and services.
Site 671 represents the most sustainable location for new housing in Seisdon.

Object

Representation ID: 1781

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

Site 671 has been identified as having part of site subject to surface water flooding, however this is contended to be negligible and can be excluded from allocation or accommodated within site layout. Climate Change and Adaption impact within the Housing Site Selection Topic Paper should be revised to negligible.
Site 671 scores the same ('poorly') as Site 359 for Cultural Heritage within the Housing Site Selection Topic Paper but contend Site 671 should score negligible has it has far less concerns raised by comparison to Site 359 which has far greater impact. Cultural Heritage impact within the Housing Site Selection Topic Paper should be revised to negligible for Site 671.
Disagree with Site 671 scoring of moderate harm to GB as site is located within the settlement adjacent to recreational ground. Compensatory improvements can be made: new/enhanced; green infrastructure, biodiversity habitats, walking and cycling routes, access to recreational fields, and landscape and visual.
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.

Support

Representation ID: 1782

Received: 13/12/2021

Respondent: John Davies Farms ltd.

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: 1783

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

Policy DS4 - definition of "limited infilling" fails to recognise the interpretation of should be made having regard to local circumstances.
Policy DS4 - should be amended to omit reference to "small gaps (1 or 2 buildings)" and "exceed the height of existing buildings" as these limit the scale of development regardless of GB impact. These matters should be left to application stage.

Object

Representation ID: 1784

Received: 13/12/2021

Respondent: John Davies Farms ltd.

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 settlements is considered to be inappropriate as it fails to recognise their sustainability, helping to protect and enhance their village centres.
Diminishing supply of brownfield land within settlements requires allocations in all settlements to meet demand arising from local community to support and enhance local community services in Tier 4 settlements.
It is unclear whether requirement for 10% of housing will be on sites less than 1ha, NPPF Paragraph 69 notes 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. Allocations in Tier 4 settlements can achieve this.

Object

Representation ID: 1785

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

Premature to include a policy seeking to set out criteria for a settlement when the justification for it has not been established/explored.
Alternative options for accommodating housing and employment growth of future plan periods include direction growth to lower tier settlements.
Policy DS4 should be omitted from the plan to ensure it does not prejudice future consideration of alternative options.

Object

Representation ID: 1786

Received: 13/12/2021

Respondent: John Davies Farms ltd.

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 would maintain/enhance their local communities and do not give rise to 'high' or 'very high' levels of GB harm.

Object

Representation ID: 1787

Received: 13/12/2021

Respondent: John Davies Farms ltd.

Agent: Berrys

Policies SA1 - SA7 all provide a level of detail that is more appropriately dealt with through non-strategic policies.