Publication Plan April 2024

Object

Representation ID: 7385

Received: 31/05/2024

Respondent: Peveril Securities ltd.

Agent: S Drury

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The previous Regulation 19 Plan sought to deliver 9,089 homes to meet the district’s own housing requirement of 5,089 homes and a further 4,000-home contribution towards unmet housing needs of the GBBCHMA. In the ‘Report of the Lead Planning Manager’ to a Special Council Meeting held on 2nd April 2024, the authority (at para. 3.5) refers to a change in the National Planning Policy Framework (NPPF) at Paragraph 145 in December 2023 (after the SSLP (2022) consultation), which removes the requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated. As a result, the new SSLP (2024) is now a “constraints-led” strategy, which is significantly different to the previous SSLP (2022) with less Green Belt sites proposed. Policy DS4 seeks to deliver 4,726 homes over the period 2023-2041 to meet the district’s own housing requirement of 4,086 homes and a further 640-home contribution towards unmet housing needs of the GBBCHMA. This is still a significant fall in the authority’s housing target. The SSLP (2024) - in particular Policy DS4 - does not meet the ‘tests’ of soundness. The SSLP (2024) has not been positively prepared as the housing delivery target in Policy DS4 is not informed by agreements with other authorities. The SSLP (2024) at para. 5.12 states that the 2018 HMA Strategic Growth Study on which the 4,000 home contribution to the HMA in the SSLP (2022) was based is now out-of-date. In the absence of an up-to-date evidence base to identify the HMA shortfalls and ensure that these are appropriately apportioned to the district under the Duty to Cooperate, the SSLP (2024) fails to meet the tests soundness in NPPF Paragraph 35 as it is not based on “proportionate evidence”. It is noted that the SSLP no longer includes extensions to the Wolverhampton urban area on Green Belt land at Linthouse Lane, Langley Road and Cross Green. The Wolverhampton Local Plan Issues and Preferred Options states it is likely to generate shortfalls of around 11,413 homes. The South Staffordshire Local Plan is providing significantly less than the 2,900 home contribution anticipated from the SSLP (2022). It follows that the authority has not met the Duty to Cooperate and that the current proposed overall provision of housing in the SSLP (2024) would not support the Government’s objective of significantly boosting the supply of homes as required under NPPF Paragraph 60.

Comment

Representation ID: 7386

Received: 31/05/2024

Respondent: Peveril Securities ltd.

Agent: S Drury

The concentration of such a large number of new jobs within the M54 corridor proposed by the plan should be matched by the scale and provision of housing in the locality to promote sustainable development. Land should be safeguarded for housing along the M54 corridor including their clients land.

Their client continues to support the strategy for employment in the SSLP (2024) which places an emphasis on delivering strategic employment sites given their ability to provide quality employment land due to their location and transport linkages. Whilst our client also welcomes the allocation of the WMI site, it is noted at Table 9 of the Local Plan Review that the Council's intention is to deliver 328 hectares of employment land in the period 2023 to 2041, of which 74% of that provision (297 hectares) is intended to come forward on a single site – the WMI site. Should there be issues regarding the delivery of this site, this could significantly impact on the supply of employment land over the plan period.

Object

Representation ID: 7387

Received: 31/05/2024

Respondent: Peveril Securities ltd.

Agent: S Drury

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Omission site – Featherstone
Their client remains of the view that the Local Plan Review should safeguard land to provide for more housing convenient to the M54 corridor in the southern part of the borough close to the strategic employment sites. This could potentially be via a targeted review of certain Green Belt boundaries on the condition that any safeguarded land identified would not be required to be developed unless a need for more housing can be demonstrated. This could include land on the edge of Featherstone where our client’s site is located (see enclosed drawing).

Object

Representation ID: 7388

Received: 31/05/2024

Respondent: Peveril Securities ltd.

Agent: S Drury

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is noted that paragraph 6.47 of the SSLP (2024) states the allocation of the WMI site will be "balanced by smaller scale employment opportunities". The Hilton Cross site has historically been identified as an important strategic employment site both in the adopted Core Strategy and the Site Allocations Document – mainly for B1 uses (now Class E(g)) – and continues to be identified as a strategic employment site in the SSLP (2024). Only a relatively small portion of the Hilton Cross site – some 5 hectares – is now available to be taken up. Consider that in order to recognise the benefits that the Hilton Cross site has to complement WMI, the Hilton Cross allocation should be extended to provide more land for well-located small scale employment opportunities close to the M54. Requests that land to the south of Hilton Cross should be specifically allocated for employment purposes.

Comment

Representation ID: 7389

Received: 31/05/2024

Respondent: Peveril Securities ltd.

Agent: S Drury

It is understood the allocation of Biological Alert Sites has been carried forward from the adopted South Staffordshire Core Strategy, however there is no evidence to demonstrate that the continuing allocation of these sites is based on up-to-date evidence. We therefore ask that the Council present the appropriate evidence base to justify the allocation of this Biological Alert Site. In particular, the Biological Alert Site shown on the policies map which covers a proportion of their clients site.