Publication Plan April 2024

Object

Representation ID: 6196

Received: 30/05/2024

Respondent: Bloor Homes

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

In order to achieve a sustainable pattern of development for Wombourne, Site 283,Land North of Bridgnorth Road should be allocated in the Plan. Green Belt postion paper prepared for Bloor Homes confirms that the site afford less of a contribution to the Green Belt that the wider land parcel in the Council Green Belt Study. The site is well enclosed and unlikley to have a harm effect on the visual opness of the Green Belt. The release of the Site from the Green Belt would afford an opportunity for a consistent boundary treatment for Wombourne, and better integrate the southern edge of the village into the landscape. The site could deliver Green Belt compenastory benefits as well as ecological benefits.

The Plan should be amended to identify safeguarded land to meet longer term development needs in sustainable locations.

Object

Representation ID: 6197

Received: 30/05/2024

Respondent: Bloor Homes

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan is not sound as it inconsistent with national policy and not justified based on the supporting evidence. The settlement hierarchy should be revised to differentiate Wombourne from other Tier 2 settlements. Wombourne should play a greater role in housing provision in order to meet its own local housing needs, and there are clear exceptional circumstances to further amend Green Belt boundaries.

In the Rural Services and Facilities Audit (2021) which informed the settlement hierarchy, the weighting for access to employment is too high with too much weight on rail provision. Whilst there is no railway in Wombourne, there are regular and frequent bus services to neighbouring towns. The RSFA also doesn't recognise the availability of employment opportunities in Wombourne itself or that more people are choosing to work from home.

In determining the settlement hierarchy, consideration has not been given to the relative size of the settlement and in turn the housing needs that it is likely to generate on its own. The Plan is therefore unsound as it is not positively prepared. Wombourne residents have strong commuting links with the HMA hasn't been reflected.

In respect of Wombourne, it is located within the Southern Sub Area as prescribed by the Council’s SHMA, within which a need of 1,291 dwellings is identified over the Plan period. By way of comparison, an analysis of the planned housing supply as identified in the Plan totals only 410 dwellings within the Southern Sub Area. At present, there therefore exists an unmet need within the Southern sub area of approximately 881 dwellings over the Plan period. There is also an area of a high affordability ratio with demand very high, as reflected in the Council's 2021 viability study. This is evidence of the attractiveness of this area as a location for further housing to meet existing and future housing need.

Part of the rationale for the Council’s Spatial Strategy approach relies on the most recent revisions to the NPPF. Yet, in essence the approach taken in the NPPF remains unchanged, i.e. that there is no requirement to alter Green Belt boundaries but if it is proposed it must be fully justified. We consider that the substantial unmet needs arising from the GBBCHMA represent exceptional circumstances for Green Belt boundary amendments.

Object

Representation ID: 6198

Received: 30/05/2024

Respondent: Bloor Homes

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

For Site 283, the key determinant in the Sustainability Appraisal and Site Assessment is the potential for major negative impacts in relation to landscape criteria due to Green Belt harm.It is not appropriate for the Green Belt Study to have been used as a criteria for the Sustainability Appraisal rather than the Landscape Sensitivity assessment only, which would conclude differently in relation to the assessment of Sites.The SA should be amended to be consistent with the Housing Site Selection Topic Paper and vice versa.

Object

Representation ID: 6202

Received: 30/05/2024

Respondent: Bloor Homes

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

An objection to draft Policy SA3 is made due the omission of Land north of Bridgnorth Road which should be allocated for residential development, Wombourne as an allocation for housing. is evident that Site 283 performs better than other proposed allocations around Wombourne, contrary to the Site Selection Proformas’conclusion.In summary, Site 283 is suitable, available and deliverable and is in an area of low landscape sensitivity and affords a lesser contribution to the Green Belt than the wider parcel S27. There is an opportunity to provide substantial landscape enhancements through green corridors, buffering and the reinforcement of existing hedgerows. The site is well connected to services and facilities and will integrate well with an existing sustainable settlement.

Support

Representation ID: 6636

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

It is agreed that Green Belt release is necessary to deliver a sustainable spatial strategy. Bloor Homes agrees that exceptional circumstances exist for this release.

Comment

Representation ID: 6637

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Land East of Bilbrook -
Bloor Homes recognises that the Local Plan should set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements. The proposal for land east of Bilbrook identifies adjacent land to provide these improvements.

Support

Representation ID: 6638

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes generally supports the policy approach set out in Policy DS4.

Support

Representation ID: 6639

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Land East of Bilbrook and Additional Land East of Bilbrook -
Unmet need from neighbouring authorities – details of unmet need in paragraphs 3.13 – 3.19 in full representation. Bloor Homes supports the Council in providing a contribution to assist in meeting these unmet needs, however, raises concerns that this is not evidence based. The capacity-led approach will need to be explored and tested through the EiP.

Support

Representation ID: 6640

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The Straits, Coven and Royal's Farm -
Unmet need from neighbouring authorities – details of unmet need in paragraphs 2.11 – 2.18 in full representation. Bloor Homes supports the Council in providing a contribution to assist in meeting these unmet needs, however, raises concerns that this is not evidence based. The capacity-led approach will need to be explored and tested through the EiP.

Comment

Representation ID: 6641

Received: 31/05/2024

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Economic uplift – further consideration should be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth. Further evidence is necessary to consider the balance between jobs and the working age population that would be necessary to satisfy the jobs demand.