Publication Plan April 2024
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Publication Plan April 2024
Policy SA3: Housing Allocations
Representation ID: 6712
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy SA3 [corrected from SA5] of the Publication Plan proposes a number of site allocations that, as detailed in the Green Belt Study (2019) (table 7.2), would result in ‘moderatehigh’, ‘high’ or ‘very high’ levels of harm to the Green Belt.
Such sites include sites 224 Codsall, 523 Cheslyn Hay and 536a Great Wyrley. The release of these sites will therefore result in a weakening of the Green Belt, for
example by leaving a narrow gap between towns, increasing its containment by urban areas or by isolating an area of Green Belt that makes a stronger contribution (as detailed in paragraph 6.23 of the Green Belt Study).
Given the above, it is considered that growth proposed on allocations that would result in significant levels of harm (moderate-high and above) to the Green Belt, should be directed to sites where a lesser degree of harm would arise and where the level of growth would ensure that the Plan plans positively for the provision of housing sites of less than one hectare, meets housing needs of lower tier (tier 4) settlements, maintains and enhances the vitality of rural communities and their local services.
The Plan is therefore considered to be unsound as it not justified (is an appropriate strategy, taking into account the reasonable alternatives).
In order to ensure that the Plan is justified (is an appropriate strategy, taking into account the reasonable alternatives) a greater level of growth, and allocations,
should be directed away from allocations that would result in significant levels of harm (moderate-high and above) to sites in lower tier (tier 4) settlements in need of growth where allocations would maintain and enhance the vitality of these communities and not give rise to the ‘high’ or ‘very high’ levels of harm to the Green Belt.
Object
Publication Plan April 2024
Policy SA3: Housing Allocations
Representation ID: 6717
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Omission site 671
Policies Map 28 for Seisdon limits opportunities for housing growth as it does not identify any housing site allocations and draws the development boundary tightly around the existing built form of the settlement.
This treatment of Seisdon in the Publication Plan fails to: recognise the sustainability of the settlement, protect and enhance the settlement’s sustainable village centre and its
services and facilities, meet housing needs during the Plan period, including the needs of the settlement and the NPPF requirement to provide 10% of housing growth on sites of less than 1 hectare, ensure that the Plan makes an appropriate contribution towards the unmet
needs of the Greater Birmingham Housing Market Area, reduce reliance on the delivery of housing on two strategic sites & ensure that development is directed to sites that have less harm on the Green Belt. The Green Belt Study identifies that sites 671 and 358 give rise to the least amount of harm on the purposes of the Green Belt in this location. In addition, it is contended that there are a
number of inaccuracies or omissions with the sustainability assessment of site 671 in Seisdon including on: Climate Change and Adaptation, Cultural
Heritage & Green Belt.
It is considered that the site represents the most sustainable location for new housing development in Seisdon and should therefore be allocated in whole, or part, to help ensure that development needs are met, an
appropriate strategy is provided that takes into account the needs of this Tier 4 settlement, reduced reliance is placed on sites that suffer from significant questions over deliverability and consistency with national policy on housing site requirements and Green Belt.
Policies Map 28 should be amended to include the allocation of housing site 671 in Seisdon.This proposed modification will contribute to the soundness of the Plan
by helping to ensure: that development needs are met (it is positively prepared), an appropriate strategy that takes into account the needs of Tier 4 settlements (it is justified), that the Plan relies on sites that do not suffer from significant questions over deliverability (it is effective); and consistency with national policy on housing site requirements and Green Belt.
Object
Publication Plan April 2024
Policy SA1 – Strategic development location: Land East of Bilbrook
Representation ID: 6719
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There is significant reliance on the delivery of housing on two strategic sites where considerable uncertainty remains over the potential rates of housing delivery. In addition, one of these sites will result in ‘high’ and ‘very high’ levels of harm to the Green Belt that could potentially be avoided by allocating land in other areas, such as land in Tier 4 settlements.
As a consequence, the Plan is considered to be unsound as it is not justified (is an appropriate strategy, taking into account the reasonable alternatives) nor effective (deliverable over the Plan period).
In order to ensure that the Plan is justified (is an appropriate strategy, taking into account the reasonable alternatives) and effective (deliverable over the Plan
period), less reliance should be placed on the delivery of housing on large scale strategic sites (SA1 and SA2) with a greater level of growth, and allocations, directed to lower tier (tier 4) settlements in need of growth where allocations would maintain and enhance the vitality of these communities but not give rise to uncertainties over delivery and ‘high’/‘very high’ levels of harm to the Green Belt.
Object
Publication Plan April 2024
Policy SA2 – Strategic development location: Land North of Penkridge
Representation ID: 6720
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There is significant reliance on the delivery of housing on two strategic sites where considerable uncertainty remains over the potential rates of housing delivery.
In order to ensure that the Plan is justified (is an appropriate strategy, taking into account the reasonable alternatives) and effective (deliverable over the Plan
period), less reliance should be placed on the delivery of housing on large scale strategic sites (SA1 and SA2) with a greater level of growth, and allocations, directed to lower tier (tier 4) settlements in need of growth where allocations would maintain and enhance the vitality of these communities but not give rise to uncertainties over delivery
Object
Publication Plan April 2024
Policy DS1 – Green Belt
Representation ID: 6722
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Green Belt should also be altered through the Plan to accommodate development allocations on sites in Tier 4 settlements, to recognise the sustainability of those
settlements, to protect and enhance their sustainable village centres and to meet housing needs during the Plan period, including the needs of the settlement and
the requirement to provide 10% of housing growth on sites of less than 1 hectare.
The Plan is therefore considered to be unsound as it fails to meet the development needs of Tier 4 settlements and is inconsistent with the national policy requirement (detailed in paragraph 70 of the National Planning Policy Framework) to promote the development of a good mix of sites, including identifying land to accommodate at least 10% of the housing requirement on sites no larger than one hectare.
See above
Object
Publication Plan April 2024
Policy DS4: Development Needs
Representation ID: 6725
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There is a significant reduction in housing provision compared to that detailed in policy DS4 of the November 2022 Publication plan. This decrease in housing provision in the area is a direct consequence of a change
in strategy in the 2024 Plan to 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, the reasoning provided for the change in strategy, and therefore for the significant reduction in housing provision, is considered inappropriate and
unsound. The Plan’s strategy also appears inconsistent, as housing provision has been significantly reduced whilst the overall provision of employment land has been bolstered from 99ha. in the 2022 Plan to 107.45ha. in the 2024 Plan.
It is recognised that there have been changes to the NPPF since publication of the 2022 Plan. Nonetheless, these changes are not considered sufficient to move away from the 2022 Plan’s housing strategy (including Green Belt). The contribution provided in the South Staffordshire Local Plan towards the unmet needs of the Greater Birmingham Housing Market Area should be increased.
Policy DS4 should be amended to increase the housing contribution made by the South Staffordshire Local Plan towards the unmet needs of the Greater Birmingham Housing Market Area.
As identified in the representor’s objection to policy DS5, any increase in housing land supply should be focused in Tier 4 settlements to recognise the sustainability
of those settlements, protect and enhance their sustainable village centres and meet housing needs during the Plan period, including the needs of the settlement and the requirement to provide 10% of housing growth on sites of less than 1 hectare.
The proposed modification to policy DS4 will therefore contribute to the soundness of the Plan by ensuring that housing development requirements are met and that
the Plan is, as a consequence, consistent with the national policy.
Object
Publication Plan April 2024
Policy DS5 – The Spatial Strategy to 2041
Representation ID: 6727
Received: 30/05/2024
Respondent: John Davies Farms ltd.
Agent: Berrys
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Plan is considered to be unsound as it fails to meet the
development needs of Tier 4 settlements, make an appropriate contribution to the unmet housing needs of the Greater Birmingham Housing Market Area and meet
small site housing requirements identified in the NPPF.
Policy DS5 should be modified to reintroduce small site allocations in Tier 4 settlements.
Significantly, the modification will also ensure that an appropriate level of growth is provided in Tier 4 settlements to meet the Plan’s objectives.
The proposed modification to policy DS5 will therefore contribute to the soundness of the Plan by ensuring that it positively plans housing development to meet identified needs and requirements and, as a consequence, is positively prepared, justified, effective and consistent with national policy.
