Publication Plan April 2024

Object

Representation ID: 6691

Received: 30/05/2024

Respondent: FGD Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We object Policy DS4 and the level of housing growth being planned for and the Council’s proposed change in their housing growth strategy. We disagree with SSDC’s interpretation of the NPPF and their relance on it to justify the change in approach to growth.We acknowledge that the amended wording allows for authorities to choose whether to review Green Belt boundaries when preparing or updating their Local Plan but there is now no reference to reviews being based on meeting objectively assessed needs and Councils have always had to demonstrate that exceptional circumstances exist.There is nothing in the NPPF which restricts the amount of Green Belt land that can be released. SSDC are still choosing to release Green Belt land for housing so therefore consider that exceptional circumstances exist to release Green Belt. We therefore fundamentally disagree with SSDC’s interpretation of the policy and the use of the revised NPPF to justify the change in strategy to reduce Green Belt release.

The policy states there is a 10% buffer but this just comprises the proposed 640 dwelling contribution. This is
not considered to provide a sufficient buffer and is reliant on all of the proposed supply (Table 8 in the plan) to
be delivered which only amounts to 5,199 dwellings. This is far from aspirational (NPPF paragraph 16).

Despite the evidence demonstrating that the
GBHMA shortfall has significantly increased, SSDC have chosen to reduce their contribution by 3,360
dwellings. The plan is therefore not sound because a reduction in housing to support the neighbouring shortfall
has not been justified (NPPF paragraph 35).

SSDC’s 2022 plan and evidence base demonstrated that the district could accommodate 4,000 dwellings towards the GBBCHMA shortfall. We therefore know that SSDC does have capacity to practically deliver more than 640 dwellings towards the shortfall. The only thing to have changed since this consultation is a revised NPPF which we consider SSDC has interpreted incorrectly.

Object

Representation ID: 6692

Received: 30/05/2024

Respondent: FGD Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We do not consider that sufficient justification has
been provided for not pursuing Option G (or a hybrid of Option G and I) when it was previously assessed by
SSDC in 2022 as being the most suitable option (Sustainability Appraisal 2022). From our review, it appears that Option I has been ‘created’ by the Council in order to achieve their interpretation of the amended NPPF
2023 and support the reduction in housing to meet local and wider housing market area needs.

SSDC has produced evidence in order to support their unjustified desire to deliver less housing in the 2024
plan, rather than the evidence informing the strategy and approach to growth as they did for the 2022 plan. The
approach to the spatial strategy is not justified and is therefore unsound (NPPF paragraph 35b).

The Sustainability Appraisal and Spatial Option I fails to consider that there are settlements outside of the
SSDC, for example the edge of the Black Country, which are far more sustainable than the Tier 1 settlements
assessed. Site reference 577, is located immediately adjacent to the urban area of Dudley and is well related
to existing development and facilities, with good public transport connections. Site reference 577 is therefore
in a highly sustainable location,

In order to policies DS4 and DS5 to be sound, SSDC should be planning for additional housing growth to meet
a housing requirement above the minimum housing needs and accommodates more than 640 dwellings to
address the GBBCHMA shortfall. Site reference 577 is located immediately adjacent to the edge of the black
country and is considered a highly sustainable location. Therefore my client’s land should be considered for
release from the Green Belt and allocation in the plan.

Object

Representation ID: 6693

Received: 30/05/2024

Respondent: FGD Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Promoted site at Mile Flat, Kingswinford is
considered that the Site is suitable for residential and / or employment uses, is available for development and
could be delivered within the next 5 years if required.

In regards to education, the site is of a scale where
land for a primary school and / or community facilities could be provided to support residential development on
the site and elsewhere in the District / Kingswinford if required.

Although the Site is in an area of ‘high’ Green Belt harm, all of the land to the west of the Black Country has either been assessed as ‘high’ or ‘very high’ and the Site has ‘low-moderate’ landscape sensitivity. It is
considered that suitable Green Belt compensatory and landscape improvements could be provided on the Site
if it was allocated for residential and / or employment uses.

Regarding the impacts on the scheduled roman forts to the south identfied in the HESA, the HESA is a purely desk based exercise therefore we do not consider that development in the south of the site should be ruled out at this early stage. If the site were to be allocated, further technical work could be undertaken by the landowner to identify the significance of the heritage assets and any mitigation which could be implemented.

There are also existing bus stops on Swindon Road (immediately adjacent) and Enville Road (c. 50m from the Site) to the north of the Site. Both stops serve bus route 16 which offers a frequent service and connects the Site to Stourbridge, Wombourne, Kingswinford and Wolverhampton.