Preferred Options November 2021

Object

Representation ID: 3973

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Contrary to paragraph 31 of the NPPF (2021) which confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…”, the evidence base is in some cases outdated, especially in the light of trends accelerated by COVID and Brexit. This is likely to have a significant impact for example on the Economic Development
Needs Assessment (EDNA). The Strategic Housing Market Assessment (SHMA) suggests the current policy approach would encourage significant, and potentially unsustainable, out migration from the Black Country thereby undermining South Staffordshire’s Climate Change Strategy 2020 (strategic planning responsibilities) pertaining to reducing car use. The current policy of encouraging out-migration into South Staffordshire is not supported.

In terms of Site 582, as set out in this document, there are a number of concerns with the Sustainability Appraisal, both the limitations of the evidence about flooding, ecology and heritage but also the potential over-statement of the case in relation to education provision.
Appendix A is also limited in the documents it includes. There are concerns about the weight being placed on housing numbers, both in terms of Supply and Need. As set out in this document, there are concerns that the over-spill from the Black Country is over-stated in the
Joint Statement of 2020, and therefore the need for South Staffordshire to accommodate it. Equally there are concerns about the level of supply in South Staffordshire, in particular the significant understatement of windfall assumptions, which would suggest South Staffordshire
can provide 850 homes for the Black Country without any new allocations.

Object

Representation ID: 3974

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

There are a number of potential infrastructure issues associated with Site 582 which are implicit in our concerns, particularly about flooding and the lack of available educational provision, as well as access to public transport. It is noted that SSDC score Site 582 as high with regards to the provision of schools however the schools are full and you’ve indicated that children of
secondary school age will be schooled in Wombourne, which is a considerable distance away.

We believe that the assessment for Site 582 with regards to its infrastructure provision for schooling is significantly overstated. It is also noticeable that some of those needs would require significant infrastructure provision within Wolverhampton.

Object

Representation ID: 3975

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Strategic Objective 1 is supported however compensatory Green Belt provision is not something that fully ameliorates loss of Green Belt. Our evidence suggests that ‘exceptional circumstances’ do not exist for removal of many new housing sites from the Green Belt.

Strategic Objective 2 is not supported. The additional 4,000 houses for the Black Country should be removed. A policy to review that position subsequent to the adoption of the Black Country Plan based on up-dated evidence should be included if that is deemed to be necessary. The use of Urban Extensions should be reviewed as the Local plan attempts to justify this because of the acceptance of over-spill from the conurbation, which we are challenging.

Strategic Objectives 3-5 on housing can be supported but they should relate to needs arising in South Staffordshire. The evidence that significant housing needs to be included from the Black Country is not supported.

Strategic Objective 12 is wholly inadequate. The Objective should be much higher up in the Plan. The Plan should also aim to support a reduction in Climate Change emissions not only through mitigation at development sites but in the overall approach to development location.
Accepting significant amounts of housing from the Black Country undermines that goal.

Support

Representation ID: 3976

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

The general approach of Policy DS1 is supported. However the removal of sites from the Green Belt in line with SA1-SA7 is not supported. As stated in this document we do not consider ‘exceptional circumstances’ have been proven for these sites, based on clear evidence, not just numerical assumptions of Black Country over-spill. The sites (and, in particular, Site 582) should remain in the Green Belt.

Object

Representation ID: 3977

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Paragraph 31 of the NPPF (2021) expects Plans to be informed and “…underpinned by relevant and up-to-date evidence…” Paragraph 35 (indent b) of the NPPF confirms that Plans should be: “…Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence…”

Initial work on Local Plan preparation for the Council’s emerging Site Allocations Document (SAD) was undertaken under a significant and entirely different set of economic circumstances. Essentially, a significant and substantial amount of Plan Preparation work has already been undertaken on the emerging SAD before the year 2020 coronavirus (covid-19) pandemic. Which is likely to cause one of the worst United Kingdom (UK) economic recessions in living memory. The huge modelling assumptions being used to underpin, form and force through the Local Plan are flawed and no longer forms a credible, reliable or sound evidence.

We maintain our view that the potentially massive implications of the forthcoming severe UK economic recession on future housing delivery across the District going forward (and how the recession will affect new housing delivery within the District going forward over the lifespan of the new Local Plan once it has been adopted) has been given an insufficient level of planning policy weight, or seemingly no planning policy weight at all (See Appendix 11 Issue 2).

The addition of 4,000 homes to meet the needs of the Black Country is not supported because the evidence is not clear, the housing numbers used are out of date and the Black Country Plan is still in development. This would result in the removal of the named sites adjacent to the Urban Area and in particular Site 582. Given that SSDC planners themselves (see Appendix 10) view the Duty to Co-operate as ‘a fundamentally flawed instrument’, a review of whether any of the needs of the Black Country should be accommodated in South Staffordshire might be
considered in a review of the plan.

Support

Representation ID: 3978

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

The approach to the various Tiers is supported, including specifically in relation to Tier 5 and Lower Penn. This would suggest excluding all sites currently being promoted within the Parish Boundary including Site 582.

Object

Representation ID: 3979

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

The need for a new settlement is far from proven and given that we do not consider the current inclusion of 4,000 homes for the Black Country is justified it is hard to conclude that an additional settlement is likely to be required or would be consistent with long term Climate
Change goals.

Object

Representation ID: 3980

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

As set out in this document we do not believe Site 582 should be released. This is because:
Housing Numbers

1. The justification for the housing numbers proposed in South Staffordshire relies on 4,000 from overspill from the Black Country that is untested. Without them no new allocations are needed.
2. The Government’s arbitrary 35% uplift of housing in Wolverhampton is being added to general housing need when it should be targeted at brownfield regeneration.
3. The level of housing supply both in the Black Country (and wider conurbation) and in South Staffordshire is being under-estimated. In the case of the Black Country this could amount to over 5,000 homes and in South Staffordshire another 1,000 homes from windfall sites.
4. Accelerated changes to retail and office provision, particularly in centres following COVID may increase housing land available in the Black Country.
5. Even if the level of housing is required from the Black Country South Staffordshire is overproviding by 1153 homes, so does not need this housing allocation.
Sustainability
6. The location of the site suggests it would, along with other allocations in South Staffordshire, encourage people to move out of the Black Country and then commute back in.

7. The site is located in the Green Belt without a clear boundary beyond it. The impact could be significant on the purposes of the Green Belt, in particular encroachment into the countryside, urban sprawl and impact on regeneration.
8. The site is poorly located for public transport access and is likely to be heavily car dependent, increasing climate change emissions.
9. The site would impact on the landscape and amenity of people round the site.
10. There are potential flooding and water issues that need further investigation.
11. The site is used by a variety of wildlife and includes important habitats which link into a wildlife corridor along the South Staffordshire Railway Walk Local Nature Reserve and the Smestow Nature Reserve.
12. It is not clear that the site is adequately served by local services, and although there is a nearby Primary School, it is unclear how educational services would be improved to cater for the site.
13. There are English heritage assets in terms of a World War II battery which have yet to be properly examined.

Support

Representation ID: 3981

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

We have not considered in detail the Homes and Communities Policies which determine how development is considered.

Although we agree with policy H13 we note that H13 Health and Wellbeing isn’t being complied with when taking into consideration the wellbeing of the residents adjacent to the proposed development at Site 582. There will be increased noise, air pollution and light pollution in the vicinity of where they live.

HC14 and HC15 specifically consider the impact on health and education. HC15 refers to the Staffordshire Education Infrastructure Contributions Policy and this policy notes that when ensuring the sufficient supply of school places (as discussed in paragraph 94 of the NPPF), Staffordshire County Council has duties to “secure diversity in the provision of schools and to
increase opportunities for parental choice” (Education and Inspections Act 2006 Part 1 Section 2(3A)).

To understand the impact of a development on education infrastructure in publicly funded schools, an analysis would need to be undertaken using:
• pupil number on roll
• school capacity
• pupil projections during Local Plan period or otherwise
• committed developments and housing allocations in an emerging Local Plan as advised by LPAs on an annual basis
• any other relevant factors

Although we support policy H15 the education infrastructure analysis has not been carried out
pertaining to site 582. During the consultation process we were informed by South Staffs planner Ed Fox that a desk top study only had been carried out looking purely at the vicinity to local schools and not their ability to provide places.

The standard pupil product ratio (PPR) for calculating the number of mainstream pupils attributable from new housing development is 0.03 children per school year group per dwelling. Our group’s analysis of the local schools to site 582 is that there are insufficient places within the local schools adjacent to Site 582 to accommodate this number of additional children. Even
if the local primary school Bhylls Acre can be extended to increase the pupil capacity there is no room for the additional teacher/staff parking that would be required.

We have not considered in detail all of the EC Policies which address community services, facilities and infrastructure.

EC4 -Rural employment. We support this policy in that it retains the existing policy approach of supporting rural diversification with a preference for development within existing development boundaries. Development outside existing villages to be primarily restricted to opportunities
relating to reusing existing buildings. We do however note that a significant proportion of Site 582 is arable land that this is currently farmed and the development of Site 582 will be contrary to policy EC4.

Policy EC11 seeks to: ‘Ensure development is designed to promote high quality walking and cycling, both within sites and to links to nearby services and facilities’ however your policy is without any clear guidance as to how this will happen.

With regards to the NB Policies which address protecting and enhancing the natural environment we note that in NB1 there is an intention to protect, enhance and expanding natural assets however removing Site 582 from the green belt and developing it would be completely
against the proposed Direction of Travel as stated in NB1.
The NB policies which deal with climate change should be linked to policies on the location of development and the corresponding location of amenities and employment. The SSDC approach to climate change is considered too weak when accounting for the long-term impacts
on climate change of such unsustainable development patterns.

Policy NB9 states that ‘’ Proposals for enabling development will be considered and assessed to
determine if the benefits of securing the future conservation of the heritage asset outweigh the
departure from adopted plan policies.’’ This comment appears to place the adopted plan policy higher than the need to protect heritage assets and puts the reliance on the heritage asset to have a higher benefit that the adopted plan in order to save the heritage asset. This appears to undermine the rest of policy NB9 which is the safeguarding of heritage assets and their setting.
This is of particular relevance to the heritage asset on Site 582 which is the Word War II Gun Battery Site.

Support

Representation ID: 3982

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Yes, but the obvious omission is a strategic policy to limit the impact of development on Climate Change, including its location and its impact on development in more sustainable locations.