Publication Plan April 2024

Support

Representation ID: 5975

Received: 31/05/2024

Respondent: Wolverhampton City Council

Planning Practice Guidance encourages strategic Plan-making authorities to identify needs on a Functional Economic Market Area (FEMA) basis. Wolverhampton is located within the Black Country FEMA and a shortfall of 152ha of employment land is identified across the Black Country. Taking all potential supply into account, the WLP Issues and Preferred Options Report confirms a Wolverhampton employment land shortfall of 53ha.

The Council supports the SSLP contribution of 112.2ha towards unmet Black Country employment land needs. This contribution will make significant headway towards addressing the unmet employment land needs of the Black Country Functional Economic Market Area of 152ha, of which Wolverhampton is part. As with the housing contribution summarised above, this will need to be confirmed in an updated Statement of Common Ground.

Comment

Representation ID: 5976

Received: 31/05/2024

Respondent: Wolverhampton City Council

In terms of unmet need for gypsy and traveller pitches, CWC acknowledges the scale of unmet need for gypsy and traveller pitches arising in South Staffordshire, as set out in para 6.39 of the Plan. Work on the Wolverhampton Local Plan confirms that there are no opportunities within the City to deliver additional pitches to respond to this need.

Support

Representation ID: 5977

Received: 31/05/2024

Respondent: Wolverhampton City Council

Engagement with the Plan process has taken place on an individual basis, and through the Association of Black Country Authorities (ABCA), in the context of the Council’s involvement in the Black Country Plan (BCP). Following the dissolution of the BCP each Black Country authority agreed to prepare individual Local Plans. The Wolverhampton LDS was brought into effect in February 2024, confirming the commitment of the Council to continue to prepare an up to date Local Plan in a robust and timely manner.

It remains the case that there is a significant level of unmet housing an employment land need arising in Wolverhampton which the South Staffordshire Local Plan should seek to respond to in a positive manner.

CWC welcome the opportunity to comment on the Plan and confirm our active and positive engagement in the various stages of preparation of the Local Plan. We also welcome the cooperative engagement with South Staffordshire Council throughout. The strategic approach set out in the Plan towards meeting unmet housing and employment needs arising in Wolverhampton is supported, and we consider that the Duty to Cooperate has been met.

Support

Representation ID: 5978

Received: 31/05/2024

Respondent: Wolverhampton City Council

The SSLP is supported by an updated Infrastructure Delivery Plan (IDP) addressing a range of infrastructure issues including transport, schools, health facilities, community services, open space and retail. This has been developed through consultation with infrastructure providers and neighbouring authorities, including the City Council. Strategic infrastructure opportunities are identified, including a First School to serve Codsall / Bilbrook and A41 junction improvements at Perton to alleviate congestion. If these opportunities are delivered as planned, and the City Council is appropriately involved in all cross-boundary transport planning, it is considered that the three allocations listed above are themselves unlikely to have a negative impact on Wolverhampton infrastructure.

Comment

Representation ID: 5979

Received: 31/05/2024

Respondent: Wolverhampton City Council

It is essential that development links effectively to the strategic transport network and avoids excessive pressure on sensitive transport links, that effective sustainable transport solutions are provided to connect essential trips to the local network, and that developments seek to minimise trip generation though all available mechanisms.

Object

Representation ID: 5980

Received: 31/05/2024

Respondent: Wolverhampton City Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Disappointing that the SSLP does not safeguard land for a rail-based park and ride north of the M54, which would have contributed towards the delivery of sustainable transport in Wolverhampton. It is appreciated that it will be challenging to bring this project forward during the Plan period without cross-subsidy from housing development. We request that the benefits of this proposal are recognised and that the Local Plan continues to promote a rail based park and ride north of M54 and other supporting infrastructure which increases access to the rail network.

Comment

Representation ID: 5981

Received: 31/05/2024

Respondent: Wolverhampton City Council

Concerned that in terms of transportation infrastructure specifically, further work is require to understand the combined impact of the South SSLP development proposals and potential WLP developments on the wider transport network. Happy to discuss the scope of this work with you including the relationship with transportation assessments being undertaken in support of the Wolverhampton Local Plan.

Support

Representation ID: 5982

Received: 31/05/2024

Respondent: Wolverhampton City Council

In terms of cross-boundary infrastructure, the deletion of the development sites currently located within the green belt on the edge of Wolverhampton has removed the majority of the infrastructure concerns identified in our response to the previous Regulation 19 consultation.

Comment

Representation ID: 5983

Received: 31/05/2024

Respondent: Wolverhampton City Council

Wolverhampton has a very strong functional relationship with South Staffordshire, expressed through migration patterns and travel to work data. Therefore, the SSLP contribution towards meeting wider unmet housing need continues to be welcomed in principle. However, in order to provide certainty for the progression of the WLP and to inform our ongoing Duty to Cooperate engagement with other neighbouring Local Plans, it is critical that a Wolverhampton element of the 640 homes contribution is confirmed as soon as possible. We need to express this issue as a soundness matter at Regulation 19 stage, but are confident that it is capable of being rectified by the time of submission of the Plan, through appropriate text in the Plan itself and/or a Statement of Common Ground – ideally both.

In terms of the approach to calculate this apportionment, we recommend that migration patterns between South Staffordshire and those neighbouring authorities which can demonstrate unmet housing need would provide the starting point, with further refinement based on the scale and location of development proposed in the Plan and the proximity of these sites to Wolverhampton (details in full representation).

We note the reference in the Local Plan to the existing (2018) Growth Study being out of date, and welcome the commitment to updating this evidence and considering the implications of any update through future plan-making. This City Council is also committed to progressing this work.

Support

Representation ID: 5984

Received: 31/05/2024

Respondent: Wolverhampton City Council

The SSLP proposes a housing requirement of 4,726 homes over the period 2023-2041, which includes a 640 homes contribution towards unmet needs of the GBBCHMA. This is significantly reduced from that set out in the previous Regulation 19 Plan which identified areas of green belt release to provide land for housing development on the edge of Wolverhampton as the primary source of this contribution. We note the inclusion of land north of Penkridge on non-green belt land as a housing allocation in this version of the Local Plan, this being consistent with the recommendations of the 2018 HMA Growth Study. This change in approach, moving away from a strategy based on significant green belt release to meet needs arising in neighbouring areas, is made in the context of the current NPPF which post-dates the publication of the previous Regulation 19 Plan. We consider that the revised approach is in principle in accordance with the updated NPPF and therefore sound.