Publication Plan April 2024

Object

Representation ID: 6428

Received: 30/05/2024

Respondent: Payne Hicks Beach Trust Corporation Limited

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

The level of housing need across the GBBCHMA has not reduced in the time between the two versions of the Publication Plan. The current Publication Plan April 2024 will not therefore deliver anywhere near the level of new homes required to address the unmet need and this need for housing will remain unaddressed.

This does not represent a positive approach to plan making or effective joint working on this important strategic matter. South Staffordshire are seeking to bypass the allocation of sufficient sites to deliver their proportionate level of additional housing need arising within the GBBCHMA and do not therefore meet the legal compliance with the Duty to Co-operate.

The draft SoCG does not provide an agreed position in respect of housing supply within the South Staffordshire District or the level of unmet housing need arising from the GBBCHMA that should be addressed within the South Staffordshire District.

Whilst there has been engagement with surrounding local planning authorities in the preparation of the revised Publication Plan it is not evidenced that this has produced a positively prepared and effective plan that meets the requirements of the Duty to Co-operate and therefore the tests of soundness.

Object

Representation ID: 6429

Received: 30/05/2024

Respondent: Payne Hicks Beach Trust Corporation Limited

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

The Publication Plan fails to provide for sufficient housing delivery to meet the needs of South Staffordshire District alongside a proportionate level of housing to assist in addressing the unmet needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA). The Plan is not therefore sound.

There is no indication that the level of unmet housing need arising from Birmingham and the Black Country Authorities will have diminished or disappeared since the previous Strategic Growth Study of 2018.

The current Publication Plan approach is based on the changes to the NPPF that came forward in December 2023. The only change to national policy is confirmation that there is no requirement to review Green Belt boundaries, however, this was always the case, just not explicitly stated. Paragraph 140 of both the 2021 NPPF and the September 2023 NPPF stated that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. This test remains the same and there are not any more stringent tests to be applied now than there were in respect of the previous 2022 Publication Plan. Therefore there is no national policy change that would rationalise this change of approach over that of the previous Publication Plan.

Whilst growth avoiding use of Green Belt would be an appropriate strategy where this enables a sufficient level of housing to be delivered, the requirement for the Plan to be positively prepared and to be based on effective joint working with neighbouring authorities on strategic matters, renders this approach inappropriate and unsound in the case of South Staffordshire.

In order to assist in meeting the unmet housing needs of the HMA it is entirely appropriate, fully evidenced and justified that a review of Green Belt boundaries should be undertaken as part of the plan-making process. This should form part of this Local Plan and an assessment of Green Belt boundaries to enable the provision of an additional 3,360 new homes (over the numbers set out in the Publication Plan 2024) across the plan period must be undertaken in order for the Plan to be considered sound.

Object

Representation ID: 6430

Received: 30/05/2024

Respondent: Payne Hicks Beach Trust Corporation Limited

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan does not provide sufficient housing allocations or policies to adequately address the housing needs of the Housing Market Area. See separate representations made in respect of Policies DS4 and DS5 and the Duty to Co-operate.

The proposed housing allocations set out at Policy SA3 will deliver insufficient housing over the plan period and do not reflect a positively prepared plan to deliver sustainable development assisting in meeting the unmet needs of neighbouring authorities.

Policy SA3 should include a greater number of housing allocations to ensure the provision of housing across the District to meet the objectively assessed needs of the area plus an appropriate level of unmet needs from neighbouring authorities. Wombourne should be re-classified as a Tier 1 settlement (see separate representations made in respect of Policy DS5) and additional housing allocations proposed in this locality to reflect its sustainable location and access to services and facilities.

Object

Representation ID: 6431

Received: 30/05/2024

Respondent: Payne Hicks Beach Trust Corporation Limited

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

The overall housing target identified in Policy DS5 is not considered to adequately address the housing needs of the Housing Market Area (HMA). See separate representations in relation to Policy DS4 and housing needs.

The approach to locate growth at the most sustainable locations within the District is supported, however, the settlement hierarchy set out within Policy DS5 is considered to be flawed.

Clear evidence that Wombourne should be categorised as a Tier 1 settlement as it has a very similar, if not greater level of accessibility to services and facilities than Penkridge. The proposed categorisation as a Tier 2 settlement is unjustified and Wombourne should be reclassified as a Tier 1 settlement.

Appendix 4 of the RSFA sets out a table of facilities and services at each of the settlements appraised. Wombourne, when compared against Penkridge, is confirmed as having access to a wider range of retail opportunities, additional GP surgeries, additional pharmacies, more dental surgeries, more churches, more village hall facilities, more pubs and more day nurseries. Wombourne and Penkridge are shown as having similar levels of education provision, libraries, sports provision and travel times to larger centres. Whilst there is no railway station within Wombourne the frequency and ease of access to bus routes which link Wombourne to the adjacent higher order settlements of Wolverhampton, Dudley and Stourbridge, in particular, are not fully considered.

The ability for people to travel to employment opportunities by bus should be given equal, if not greater, weight than the availability of railway stations for access to employment opportunities in the categorisation of settlements within the hierarchy.