Publication Plan November 2022
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Publication Plan November 2022
Policy DS4: Development Needs
Representation ID: 4318
Received: 21/12/2022
Respondent: Wolverhampton City Council
CWC considers that the SSLP has been prepared in a manner which is legally compliant and meets the Duty to Cooperate. The Draft BCP identified a shortfall of some 28,000 homes to 2039 across the four Council areas. For Wolverhampton, the housing shortfall is substantial at some 7,900 homes. The BCP identifies a shortfall of some 210ha of employment land to 2039, this being the sum of shortfalls across the four Council areas. The EDNA confirms that the Wolverhampton element of this shortfall is between 40ha to 80ha. We do not anticipate that this work will reveal any significant sources of additional land to meet housing or employment needs. Wolverhampton has significant unmet housing need, taking into account capacity in the urban area and limited, sustainable green belt release.
In order to provide certainty for the progression of the WLP and to inform our ongoing Duty to Cooperate engagement with other neighbouring Local Plans, it is critical that a Wolverhampton element of the 4,000 homes contribution is confirmed as soon as possible. We recommend that migration patterns between South Staffordshire and those neighbouring authorities which can demonstrate unmet housing need would provide a reasonable and robust evidential basis. migration patterns over the period 2002-2019 between South Staffordshire and the Black Country / Birmingham shows that Wolverhampton accounts for 37% of net inflows, Walsall 25%, Birmingham 3%, Sandwell 11% and Dudley 24%. However it is not currently clear if either the Dudley Local Plan or the Walsall Local Plan will generate a residual housing shortfall. It would be appropriate for the 4,000 homes to be divided between Wolverhampton, Sandwell and Birmingham in proportion to their share of historic net migration inflows, with Wolverhampton allocated some 72.5%, or 2,900 homes.
We request that affordable housing provided on these sites should be available to City residents, specifically that 50% of the affordable rent housing secured on the sites is allocated (both at first let and subsequent re-lets) through nomination rights for Wolverhampton residents.
CWC accepts that the contribution of 4,000 homes by the SSLP to the HMA is a reasonable one and should not be increased. The Council supports the SSLP contribution of 100.2ha towards unmet Black Country employment land needs. CWC commit to explore the potential for gypsy and traveller sites in Wolverhampton to help address that unmet need through the WLP process.
Comment
Publication Plan November 2022
Policy DS5 – The Spatial Strategy to 2039
Representation ID: 4319
Received: 21/12/2022
Respondent: Wolverhampton City Council
Proposed allocations adjoining Wolverhampton raise cross-boundary infrastructure issues. Each development, including site 582, needs to be carefully masterplanned with sufficiently detailed evidence and joint working.
Impacts on the transport network must be assessed including corridors into the urban area. CWC welcome the continued promotion of Brinsford Park and Ride. High quality cycling and pedestrian infrastructure should be included for local journeys and first/last mile links. Effective links should be provided to strategic transport network. Co-ordinated transport modelling and indicative mitigation work indicates impacts on Wolverhampton can be mitigated - this work should be completed prior to plan submission. Confirmation should be given that CWC will be consulted on work associated with development sites.
Linthouse Lane, Cross Green and Langley Road would generate additional new patients requiring cross-boundary solutions. Off-site health contributions will be secured for Wolverhampton GP improvements - this principle must be set out in the IDP. The indicative concept plan for the Linthouse Lane site locates a large area of green space, including the Community Park, to the north of the site. This is a significant weakness in the masterplan. A greater quantity of green space and associated facilities should be provided in the southern part of the site.