Publication Plan April 2024

Comment

Representation ID: 6054

Received: 24/05/2024

Respondent: Staffordshire County Council

Policy NB4 states ‘Proposals must consider the County Council Landscape Character Assessment’. This should be shown as Planning for Landscape Change or any subsequent revised version.

It continues, ‘and Historic Landscape Characterisation in assessing their impacts upon landscape character’. The HLC is available as separate data.

It ‘should also (where applicable) have regard to the findings of the latest Landscape Sensitivity Study prepared by the council.’ It is not clearly stated if this study is by Staffordshire County Council (SCC) or South Staffordshire District Council?

Key evidence shown is ‘Planning for Landscape Change – SCC’. This remains the official guidance available but is not shown in the Local Plan review evidence base.

It is understood that South Staffordshire District Council have their own Landscape Assessment which may be more recent than the SCC Landscape Character Assessment.

Comment

Representation ID: 6055

Received: 24/05/2024

Respondent: Staffordshire County Council

In comments made by SCC at the previous R19 consultation, it was suggested including the Local Transport Plan (LTP) as a key document in Appendix A (Key evidence and Topic Papers). The LTP will help inform decision making on transport matters for planning applications and will be used for future Plan/Policy reviews. This is still missing from Appendix A and therefore should be included.

Comment

Representation ID: 6056

Received: 24/05/2024

Respondent: Staffordshire County Council

Please can the risk of flooding from artificial sources be included in the paragraph. For example, reservoir overtopping or breach and canal breaches can be a significant source of flood risk that should be considered.

Object

Representation ID: 6057

Received: 24/05/2024

Respondent: Staffordshire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The employment site E30 (M6, Junction 13, Dunston) wasn’t included previously in the Publication Plan 2022 or Preferred Options. Further, consideration will need to be given to the A449 junctions through Penkridge and Stafford depending on the level of trips using these routes.

To date, Staffordshire County Council has not seen any evidence through the Local Plan process to suggest that this site can be delivered in transport terms. It is noted that paragraph 6.46 states the site ‘…will be subject to further detailed scrutiny through the Development Management process.’ The Development Management team at Staffordshire CC has requested further assessment work be undertaken as part of the live planning application to demonstrate deliverability of the development, and to the best of our knowledge are awaiting the outcome.

Further, it is important that there is a strong Travel Plan in place to ensure opportunities for sustainable travel are provided and encouraged.

Comment

Representation ID: 6058

Received: 24/05/2024

Respondent: Staffordshire County Council

In respect to Site 119a, Land adjoining Saredon Road (pg. 176, Appendix C), we have accepted this allocation in previous consultations, the allocation takes into account site layout and the adjoining mineral working.

We accept and wish for the key requirement to remain which states, “Site layout and design to be based on an environmental assessment that takes into account permitted mineral operations and avoids additional restrictions being imposed on those operations.”

We support this requirement noting that the quarry has a permission to win and work clay and import waste until 21 February 2042 (refer to condition 2 of permission SS.EA/11)

Comment

Representation ID: 6059

Received: 24/05/2024

Respondent: Staffordshire County Council

In respect to Site Allocation 523 (p.g 178, appendix C) Land East of Wolverhampton Road which is adjacent to Campions Wood Quarry. We think it is necessary to include and keep key requirement “Site layout and design to be based on an environmental assessment that takes into account permitted mineral operations and avoids additional restrictions being imposed on those operations.”

For information, the County Council is dealing with an application of a revised restoration scheme to achieve long term stability of slopes involving the importation of inert materials at Campions Wood Quarry (ref: SCC/24/0014/FULL-MAJ) which would achieve an earlier restoration of the quarry than currently planned (i.e. restoration to commence by at least 21 February 2042 – Condition 6 of permission SS.09/08/611 M).

Object

Representation ID: 6062

Received: 24/05/2024

Respondent: Staffordshire County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan has not been positively prepared in taking into account the unmet housing need from the Greater Birmingham and Black Country Housing Market area in the longer term. The Plan sets out in paragraph 5.12 that recent evidence suggested the shortfall across the HMA will be in the order of 106,654 dwellings. Previous iterations of the SSDC Local Plan have tested a contribution of 4,000 units towards the shortfall based on a 2018 study for the HMA. The Plan further goes on to state that the 2018 study is now out of date and new evidence is to be prepared, with SSDC being committed to participating and considering finding through future Plan making. It is in this context we find the Plan unsound by lacking vision and forward thinking to provide insight into future long term growth options.

Earlier iterations of the Local Plan included policy provision for a New Settlement and set out an area of search aligned with the A449 between Featherstone and Dunston. To that end the County Council also made SSDC aware through call for sites and direct engagement that the County own substantial tracts of land as part of the County Farm estate that could be made available for housing growth.

Since 2021 the County Council has commissioned extensive technical work and Masterplanning, including transport, viability and environmental studies that underpin the David Lock Associates and AECOM Growth Scenario Report, which was submitted through the Plan making process. This body of work explores what a western urban extension could look like and deliver and can be viewed at www.penkridge2050.co.uk

Re-insert the section and policy for Longer Term Growth Aspirations for a New Settlement that was included within the 2022 Publication Plan, but amended such that it also allows for the consideration of expanded settlements in the area of search.

Comment

Representation ID: 6064

Received: 24/05/2024

Respondent: Staffordshire County Council

The council’s preferred approach to housing is Spatial Option I - a capacity-led approach focusing growth to sustainable non-Green Belt sites and limited Green Belt development in Tier 1 settlements well served by public transport. However, at paragraph 5.16 the Plan states ‘Spatial Option I does not avoid Green Belt release…Spatial Option I does propose to limit Green Belt allocations to suitable sites in areas of the district best served by public transport… Local evidence shows the district’s Tier 1 settlements are the areas best served by public transport in the district, particularly where these transport links offer sustainable commuting patterns into the neighbouring Black Country and Birmingham conurbation…This is expanded on further in the council’s Green Belt Exceptional Circumstances Topic Paper 2024.’

Whilst this approach only provides for a relatively small contribution to the GBHMA unmet need it does show alignment with the West of Penkridge proposal at a strategic level. Penkridge is a Tier 1 settlement; it includes a railway station and regular bus services; and ‘the council has also proposed an additional amount of limited Green Belt release to the south of the village, recognising Penkridge’s status as a Tier 1 settlement and the sustainability of this location compared to other areas of the district.’ The West of Penkridge proposal is adjacent to the Village, potentially offers improvements to the railway station, and could therefore be seen to align with the SSDC strategic approach and offer opportunity to consider the longer term housing growth of the District and wider HMA unmet need.

Object

Representation ID: 6065

Received: 24/05/2024

Respondent: Staffordshire County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

SCC have been in dialogue with the Parish Council for an extended period of time in relation to their Neighbourhood Plan and the scenarios presented by public land holdings to the west of the village. There is an increased sense of frustration that the ‘West of Penkridge’ proposal has not been properly communicated/articulated and considered by the LPA so the community can understand the options and benefits. We are also concerned over long term impacts of further piecemeal development to the north of Penkridge in a non-sustainable linear fashion without any infrastructure improvements (as opposed to just mitigation) – i.e. not using planning as a tool to improve the community through strategic planning. For example the proposals for the West of Penkridge include provision for re-routing of the A449 through the new development on a road designed to accommodate high vehicle flows and HGVs given the A449 is the signed diversion route for M6 closures. The proposal to re-route the A449 will allow the historic centre of the village to be returned to a local street and provide more of a Place function, with active travel options and alternate uses to land previously dedicated to motor vehicles.

The pause in Plan making following the 2022 Regulation 19 consultation afforded opportunity for West of Penkridge to be considered in the 2024 Spatial Housing Strategy Paper, which added new options and refreshed those previously considered. However, this was not undertaken.

Comment

Representation ID: 6074

Received: 24/05/2024

Respondent: Staffordshire County Council

Flood Zone 2 and 3 in the extreme Southern limit

Surface water - very intermittent minor ponding on site and minor flow path in south of site

Flooding hotspots - large cluster of internal property flooding hotspots to the south of the railway. Instances of highways flooding dotted through the village.