Publication Plan April 2024

Object

Representation ID: 6593

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The housing allocations at Policy SA3 do not allocate any housing to urban edge sites, which would take advantage of existing services and transport infrastructure of neighbouring Black Country settlements. We do not agree with allocations over reliant on the tiered settlements of South Staffordshire as this completely ignores the fact that the authority is inter-dependent with the Black Country for employment, retail and educational opportunities and that meeting the needs of the Black Country will require the release of some Green Belt land within South Staffordshire: something that was acknowledged in the later iteration of the emerging Black Country Plan.

With regard to the Land at Blackhalve Lane, we consider a more comprehensive scheme would ensure a more holistic approach is taken to creating a robust, enduring and permanent Green Belt boundary. An allocation here would also serve as a logical opportunity to deliver some of Wolverhampton’s unmet need in a highly sustainable location. The site can deliver a strong mix of housing in accordance with the density and type prescribed within the proposed policies, whilst delivering green infrastructure and other public benefits.

we urge that the council gives further consideration to our
client’s site at Blackhalve Lane, and it should be included as a housing allocation within the Submission Plan.

Comment

Representation ID: 7100

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Despite acknowledging a higher-than-average aging population and decline in families and working age residents, SSDC does not seek to directly address this issue by prioritizing the delivery of family homes and ensuring the housing needs of the working age population are met across the Plan period. Contributing a larger proportion of homes to the HMA would assist in addressing this issue, improving affordability of homes.

Comment

Representation ID: 7101

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

The Plan’s vision and objectives should be amended to reflect the need to meet both the present and future housing requirements, including those pressures arising through the Duty to Cooperate with neighbouring authorities, in particular the GBBCHMA.

Comment

Representation ID: 7102

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Strategic Objective 1 lacks clarity and does not define the exceptional circumstances for release of Green Belt land as part of its strategy. It should be made clear that the need to identify land for growth and development over the Plan period, and beyond, means that there are exceptional circumstances arising which have required a full & detailed Green Belt boundary review.

Comment

Representation ID: 7103

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Strategic Objective 2 could be strengthened in meeting the needs of both existing and new residents of the District and GBBCHMA. In determining what is considered to be a proportionate contribution to the HMA’s unmet housing needs, SSDC must ensure specific consideration has been given to the district’s ability to make a substantially larger contribution, and greater recognition should be given to Tier 2 and 3 settlements.

Object

Representation ID: 7104

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

St Philips do not accept the Council’s proposition that Green Belt ‘contributes towards rural character’. Green Belt is a development restraint policy set out at Chapter 13 of the NPPF and therefore the Council should amend the text in DS1 and its supporting text to represent national policy.

Comment

Representation ID: 7105

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

The Council are of the view that the Growth Study, on which the 4,000 contribution to the HMA was based, is out of date. Details on the HMA and shortfalls for other LA’s can be found in paragraphs 4.4 – 4.7 of the full representation. The Green Belt Exceptional Circumstances Topic Paper 2024 continues to acknowledge the exceptional circumstances for the release of Green Belt land, however, in terms of delivering housing for the District and HMA, this continues to focus on non-Green Belt options. Only 0.16% of the district’s Green Belt is proposed for release despite the significant unmet need for the HMA. There are clear opportunities for sustainable housing development across the district through Green Belt release whilst ensuring a significant quantum of high value Green Belt land is protected.

Comment

Representation ID: 7106

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

SSDC clearly recognise the scale of the housing shortfall. Since consultation on the 2022 Publication Plan, the housing shortfall across the HMA has grown further. SSDC’s reduced contribution of 640 homes is not reflective of the significant housing shortfall. The direct relationship between SSDC, Dudley and Wolverhampton provides further support for the release of Green Belt land. St Philips consider the 2024 Publication Plan should establish Green Belt boundaries which will not require amendment in the next Local Plan cycle through the introduction of safeguarded land. This would give the Council greater flexibility to accommodate development requirements and to assist in meeting a growing unmet need.

Object

Representation ID: 7107

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

DS1 is unsound and does not meet with the provisions of the NPPF. It has been demonstrated that there are clear exceptional circumstances for the release of Green Belt land. The delivery of 640 homes is not considered proportionate. There are additional Green Belt sites suitable and available for housing which are sustainably located.

Object

Representation ID: 7108

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The hierarchical approach to the Green Belt compensation policy as drafted is not supported. Neither the NPPF or PPG refer to a hierarchy or preferred methods of compensation. The policy should be amended to delete the hierarchy and instead state that Green Belt compensation is required in conjunction with development of sites removed from the Green Belt as set out in the NPPF.