Publication Plan April 2024

Object

Representation ID: 6279

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to the application of Policy DS1 to include land which borders the edge of the conurbation of Wolverhampton and the Black Country and specifically the proposal to accommodate Policy SA1 ‘Land East of Bilbrook’, on these grounds since there is a clear danger of ‘coalescence’ with the urban area.On the other hand, we consider that the site at Sandy Lane, Codsall (area 222) is consistent with the area which was recommended for future growth within the 2018 Strategic Sites Study (north of Codsall/Bilbrook) could logically meet the exceptional circumstances

Support

Representation ID: 6280

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

We acknowledge the fact that where green belt incursions are made through the Local Plan review that there should be compensatory improvements (to meet national policy advice within the NPPF) albeit that these need to be feasible and capable of delivery within the green belt policy advise to enable the site to be released and therefore we would support this policy in principle

Object

Representation ID: 6281

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We recognise that a firm ‘Open Countryside’ policy is needed for sites which are outside the urban areas. However, we consider that the Sandy Lane, Codsall site should be allocated and therefore should not be subject to this policy and should be included in the list of allocated sites within Policy SA3.

Object

Representation ID: 6282

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The housing target in the plan is insufficient and equates to a reduction of 3,608 homes from the 2022 Publication Plan.the scale of housing needs is not reducing but is actually increasing. Whilst there is a clear logic to focusing the new housing allocations in the Tier 1 settlements, there is serious doubt therefore whether the current housing requirement of 4726 dwellings (2023 -2041) meets the District Council’s development needs – compared with the 9,089 dwellings prepared in the 2022 Local Plan. The 2024 Publication Local Plan therefore clearly fails the ‘positively prepared’ and ‘justified’ tests and it also fails the ‘duty to co-operate’ test in failing to make an adequate contribution to meeting the wider needs of the Black Country housing market of which South Staffs is a part.

We fully support the notion that larger settlements with better accessibility, facilities and services should accommodate the bulk of new housing and that the ‘exceptional circumstances’ for releasing sites from the green belt should be focused on Tier 1 settlements. If this is the policy decision, then more sites (such as the Sandy Lane, Codsall site) will need to be found in future – and indeed, possibly in this SSDC Local Plan, should the Inspector decide that insufficient sites have been provided overall.

The shift towards a capacity-led approach which simply sticks with the current ‘stock’ of housing allocations based on a reduced housing target demonstrates that the Local Plan has not been ‘positively prepared’ and is therefore unsound.

There would appear to be a clear dichotomy between the Council’s approach towards employment and its stance on housing. This is a ‘soundness’ issue, since it demonstrates the lack of cohesion in the 2024 Publication Plan brought about by the reduction of housing.

Object

Representation ID: 6283

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objection to the policy as unsound on grounds of lack of a ‘positively prepared’ Local Plan and conflict with national policy within NPPF.The Council has introduced a shift in its Spatial Strategy which does not arise out of a change in either housing or employment needs but simply an ‘opportunist’ decision arising out of a political choice.This demonstrates that the Local Plan is not ‘positively prepared’ nor ‘properly justified’.

We would argue that neither a pure ‘infrastructure-led’ approach still less a ‘capacity-led’ approach is entirely suitable in forming the basis for a ‘positively prepared’ planning strategy which genuinely caters for peoples’ and business’s needs in the District. Instead, a ‘demands-led and/or a ‘needs led’ approach is more appropriate.

Object

Representation ID: 6284

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Allocation of site is contrary to green belt policy which specifically guards against coalescence of settlements with main towns and cities – in this case the effective merging of Bilbrook with the edge of Wolverhampton.

It also conflict with the recommendations of the GL Hearn/Wood Strategic Growth Study 2018 which specifically recommended releasing land for between 500-2,500 dwellings to the north of Codsall/Bilbrook, as opposed to east of Codsall/Bilbrook as this site is.

it also conflicts with the findings of the Council’s own 2019 LUC Green belt study which found that the land to the east of Bilbrook has a ‘strong’ green belt purpose.

The case for expanding an existing urban extension on the grounds that it helps support a new First School, should be irrelevant in terms of green belt policy and unjustified in planning terms.

In conclusion, we are not convinced that the extension of the Policy SA1 (east of Bilbrook site) within the 2024 Publication Plan can be considered consistent with green belt policy and hence is unsound as being contrary to national policy within the NPPF and we consider it should be deleted in favour of other sites which have more consistency with green belt policy.

Object

Representation ID: 6285

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

General concerns about the soundness of the housing allocations policy and specific objections to the exclusion of the Sandy Lane, Codsall site.we feel that the Council should not put too much focus on large strategic sites which may be slow to come forward and be affected by infrastructure delivery issues. More sites should be allocated in Tier 1 settlements such as Codsall/Binbrook which are closer to services and facilities, more accessible and more consistent with green belt policy. However, sites need to be avoided which would create coalescence with Wolverhampton, as the ‘East of Bilbrook site will undoubtedly do. The plan includes limited flexibility of 10% overall including the windfall sites. Normally, plans would expect to provide much greater flexibility allowance. This demonstrates that the plan has not been positively prepared. We are also concerned that the Housing Site Selection paper gives far too much emphasis to infrastructure contributions which ought not to be a major factor in choosing sites in the first instance.

Site 222 should be allocated as it is is more consistent with green belt release policy insofar as there is no risk of coalescence with major towns and cities, has easy access to local services and facilities,3. The site is now effectively surrounded on three sides by development.

Assessment of lanscape sensitivity of the site is flawed as it is absorbed into a larger land parcel for assessment which includes the conservation area which distorted its true character.

Site is north of Codsall/Bilrbook so aligns with the Stratgeic Growth Study 2018 recommendation, unlike the allocation east of Bilbrook.9. The Council indicates that the willingness to provide a school within the scheme is an important consideration which favours the allocation of sites (such as ‘East of Bilbrook). However, our clients were not contacted about the desire by SSDC to provide a new First School on their site. We are not convinced that the selection procedure has been fair and impartial in this case which we feel renders the Publication Plan unsound.

Object

Representation ID: 6286

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Not necessarily appropriate for each site to display variety and choice and for there to be a specific requirement for 70% of properties to be 3 bedrooms or less. We suggest you remove the requirement for 70% of properties to have 3 bedrooms or less. Moreover, sites of less than 10 dwellings should not be required to provide a mixture of property sizes.

Object

Representation ID: 6287

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We are concerned that in a rural District such as South Staffordshire, the requirement for a minimum net density of 35 dwellings per hectare is completely unrealistic and will create high density designs. This policy should be reviewed with a simple ‘common-sense check’ to decide whether the Council are creating better living conditions or are in danger of creating poorer housing conditions for the future. If the Council wish to provide more housing, the solution may be to release more land where and when it is needed and ensure there is enough space to build the homes that are needed without creating cramped high-density housing which will be unpopular with the public.

Object

Representation ID: 6288

Received: 31/05/2024

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We broadly accept the requirement for 30% affordable housing as a general target, although this cannot be a fixed figure since sites will need to be considered against wider viability criteria. Each site needs to be judged on its own merits and individual circumstances.