Publication Plan April 2024

Object

Representation ID: 7232

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Vision – details on the vision in paragraphs 2.25 – 2.28 of the full representation (Wedges Mills). St Philips strongly contends that a higher housing requirement reflecting the critical need for a larger contribution to the unmet need will deliver the Council’s priorities. Details on loss of economic growth, environmental enhancements and social inclusion as a result of the reduction in housing allocations are detailed in paragraph 2.29 of the full representation. Significantly reducing the number of homes delivered is not the long-term solution to addressing issues such as social infrastructure, climate change and inclusive economic growth.

Comment

Representation ID: 7233

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Buffer – It is critical that the Local Plan’s housing trajectory has sufficient land supply across the plan period. St Philips fundamentally supports the principle of the Council’s approach of ensuring a sufficient headroom is built into the supply and applying the buffer to both its housing need and the contribution to the unmet need of the Black Country. However, St Philips has concerns regarding the reduction in buffer from 13% to 10%. The proposed 10% buffer is well below the range identified by other Councils and found sound at the examination. St Philips recommends that a minimum of circa 20% headroom should be incorporated into the Local Plan.

Object

Representation ID: 7234

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Local Plan Review policy – St Philips considers that the Council’s current position fails to provide any certainty of an outcome or clearly defined timescale. This would fail to deliver against identified housing and employment needs within the GBBCHMA leaving a vacuum in the period post 2031 and up to 2041. The failure to commit to a review of the plan would also be contrary to paragraph 33 of the NPPF. Consideration should be given to an early review of the Local Plan.

Object

Representation ID: 7235

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Details on the revised spatial strategy can be found in paragraphs 2.39 – 2.43 of the full representation. The St Philips site has not been allocated for development in either the 2022 or 2024 publication plan, nor has any growth been directed towards the edge of Cannock. Whilst the Council ahs set out in great detail, through a suite of topic papers, the rationale and justification for its proposed spatial strategy, St Philips has significant concerns. It is entirely reasonable and consistent with the NPPF for the Council to release further Green Belt land to assist in meeting the unmet need of the GBBCHMA. St Philips consider that the Council should allocate growth to the edge of Cannock to capitalise on the role that Cannock’s ‘higher order’ services have for the residents of settlements on the boundary.

Object

Representation ID: 7236

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

St Philips is concerns that the Council’s chosen approach does not support the vitality of lower-tier settlements which have the capacity to accommodate growth. Wombourne is one of the most sustainable locations within the District for housing growth but the total proportion of growth directed here has fallen from 8% to 5.7% between the two publication plans. By focusing new allocations exclusively at Tier 1 settlements, the Council is limiting the ability of Tier 2, 3 and 4 settlements to thrive. St Philips also notes that affordability ratios are higher in Wombourne that in the wider district. By not allocating any new sites here, the affordability pressures will be exacerbated. Details on the comparison of spatial strategy options can be found in paragraphs 2.13 – 2.17 of the full representation (Wombourne), and details regarding Wombourne can be found in paragraphs 2.19 – 2.22.

Object

Representation ID: 7237

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

It is clear that the Council will need to release further housing land, either to address the GBBCHMA’s or District’s needs. There are limited options for meeting these long-term needs outside of the Green Belt and very likely that the Council will against need to revisit releasing GB land in due course. Identification of additional safeguarded land will ensure GB boundaries will not need to be altered at the end of the plan period.

Object

Representation ID: 7238

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Wedges Mills, Wolverhampton Road
Details on the site can be found in paragraphs 2.49 – 2.51 of the full representation (Wedges Mills). It would be well-served by the existing transport infrastructure and wider mitigation benefits such as the provision of new open space. St Philips requests the Council to consider a modification to draft DS5 to allocate Land at Wolverhampton Road, Wedges Mills for residential development.

Object

Representation ID: 7239

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site 416a
St Philips is concerns that site 416a has been deallocated in the 2024 Publication Plan. St Philips considers that the Council has not sufficiently demonstrated why site 416a was considered a sustainable site for allocation within the 22 Publication Plan but is no longer considered to perform well enough to be allocated. Sites 416 and 416a performed identically within the SA, with the exception that site 416a was found to have higher levels of Green Belt harm and Landscape harm. However, this was basis that 416 had already been removed from the Green Belt, and by virtue of its safeguarded status has previously been assessed. The relevant site proforma in the 2022 Publication Plan set a key requirement that 416 and 416a should be planned and delivered as a single site. A vision document for the site is included at Appendix 1, Green Belt issues at the site (paragraphs 2.33 – 2.38), lack of comprehensive development (paragraphs 2.39 – 2.44) and further site details in paragraphs 2.45 – 2.48 of the full representation (Wombourne).