Publication Plan April 2024

Comment

Representation ID: 7044

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

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. SSDC has the ability to make a significant contribution to unmet needs as it has a contiguous border with the West Midlands conurbation. The eastern edge of SSDC adjoins the local authority areas of Dudley and Wolverhampton with key infrastructure links running through. This provides further support for the release of Green Belt land and Clowes consider that land at Himley should be removed via the exceptional circumstances test and a new boundary redrawn. Clowes has considered the implications of the release from the Green Belt in paragraphs 5.16 – 5.20 of the full residential representation, with further arguments towards the release of the site in paragraphs 5.21 – 5.26.

Object

Representation ID: 7045

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

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. In addition, there are Green Belt sites suitable and available for housing that are sustainably located and will contribute to meeting this need.

Object

Representation ID: 7046

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? No

It is inevitable that any land identified for employment land overspill have to take place on greenfield sites within the Green Belt where they are in a sustainable location. There are locational benefits of the land at Wall Heath in terms of its size, containment, and ability to meet employment floorspace needs for local businesses. If an alternative location in close proximity to Pensnett Trading Estate and Heathmill Road Trading Estate is not found, jobs will be lost when business relocate. Clowes has considered the implications of the release from the Green Belt in paragraphs 5.8 – 5.11 of the full employment representation, with further arguments towards the release of the site in paragraphs 5.12 – 5.15.

Comment

Representation ID: 7047

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Clowes supports the inclusion of a policy setting out the need for Green Belt compensation in relation to sites being removed from the Green Belt. However, despite representations in the 2022 Publication Plan, the policy still leaves elements of ambiguity, and its practical application is unclear. The proposed rewording of the policy is in paragraphs 5.29 – 5.30 of the representation.

Object

Representation ID: 7048

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

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. It appears that all the potential methods require some method of actually delivering the compensation. In practical terms this is likely to be via a S106 agreement associated with a planning permission to develop the allocation. Whilst it is accepted that having the Green Belt compensation close to the allocation could be advantageous, it is the overall value of that improvement which is of greatest significance. There is also potential for the lowest ranked element of the hierarchy to result in the same, or greater, benefit than compensation associated with the highest rank.
The policy is considered unsound as it is neither justified nor consistent with national policy. 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.

Comment

Representation ID: 7049

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Details of housing figures, contribution to the HMA and NPPF/PPG extracts can be found in paragraphs 5.36 – 5.46 of the residential representation. The Plan provides a buffer of 10%, this has been reduced from 13% in the 2022 Publication Plan. In view of the 2024 Publication Plan reducing housing supply rather than reducing the buffer, it ought to be increasing it as there will be less supply overall and a proportionally greater impact if sites do not come forward. Clowes objects to DS4 as it is not justified based on proportionate evidence nor positively prepared in line with national policy. The minimum housing requirement figure across the Plan period should be substantially greater than that currently proposed.

Comment

Representation ID: 7050

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

DS4 sets out that delivery of new development will be monitored. If the LP is not to allocate additional land to contribute to meeting the overwhelming shortfall, it is imperative that further work in accordance with DtC, along with an early review of the LP, is undertaken. The extent of the unmet housing need clearly requires cooperation of adjoining authorities such as South Staffordshire to contribute a substantial, albeit appropriate, quantum of housing land.

Object

Representation ID: 7051

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? No

The employment figure set out in DS4 is not sound and the amount of land which needs to be found for development needs to be increased significantly. The policy should be amended by removal of references to contributions from WMI (which would otherwise be regarded as windfalls if they do meet the requirements for local businesses), this would mean the amount of land to meet local needs should be increased by 18.8 hectares. Land to the north of Wall Heath should be allocated for 80 hectares of mixed employment, which will give a total of 192.05 hectares to be allocated. Clowes considers that DS4 with regards to employment provision should align with the NPPF.

Comment

Representation ID: 7052

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

SSDC’s preferred spatial strategy, Option I, focuses growth to sustainable non-Green Belt locations alongside limited Green Belt allocations in Tier 1 settlements. The Plan relies upon the delivery of over a third of the district’s housing on the large strategic allocations. Larger sites will typically have longer lead in times, which is reflected in the Indicative Housing Trajectory with completions falling significantly short of local housing need in the period through to 2028. Contributing a larger proportion of homes to the unmet needs would assist in improving the affordability of homes.

Comment

Representation ID: 7053

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The role the district plays in the wider GBBCHMA and FEMA must be emphasised further within the wording of DS5. Spatial Strategy Option I currently fails to reflect the district’s relationship with the adjoining areas of Dudley and Wolverhampton. It should place greater emphasis on housing growth along the eastern edge of the district. It is acknowledged in the evidence base that Tier 2 and 3 settlements can also accommodate housing growth, whilst this may require the release of Green Belt land, carefully considered layouts can enhance setting through appropriate compensatory measures. It is important that over reliance on brownfield sites does not result in an overprovision of development unable to meet a range of needs.