Publication Plan November 2022

Object

Representation ID: 4955

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Regarding Strategic Objective 2 - RPS notes the plan period is now 2018-2039, or 21 years; it was 2018-2028 or 20 years in the Regulation 18 Preferred Options document consulted on previously. By extending the plan period forward by one year, the local housing need for South Staffordshire has increased by one year’s growth (at least 241 dwellings).

However, the contribution towards the unmet needs of the Black Country has not increased in the same way. By doing so, this would increase the contribution from 4,000 to 4,200 (on a pro rata basis as a 1/20 of 4000). This would go some way towards helping to further reduce the shortfall in housing in the Black Country and would represent an effective planning response on this matter. RPS sees no reason why the proportionate contribution to the unmet need should not be extended forward by one year in line with the local housing need increase.

Object

Representation ID: 4956

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Unclear if employment growth has been taken into account in determining the the appropriate minimum level of housing need to be provided for in the SSLP. Specifically the West Midlands Interchange proposal, which means that in total there is still 141.9ha which is not anticipated to meet either local employment need nor address the unmet employment needs from the Black Country. The substantial over-allocation of employment land in the SSLP, including that resulting from the WMI project, will need an additional labour supply to fill the new jobs provided. The Council’s employment evidence suggest that the additional jobs, including those provided at WMI, will be met by the existing South Staffordshire labour force through either reduced unemployment or reduced out-commuting (see Economic Development Needs Assessment 2020-2040, June 2022, paragraph 0.56). However, it remains unclear whether the potential impact on the demand for housing within the District, as a result of the jobs growth required to support the over-supply of employment, has been taken into account in determining the minimum local housing need figure now proposed in the SSLP. RPS recommends that the Council revisits its assessment of local housing need in order to properly assess the impact of planned future employment growth in the District and consider the implications on housing demand of the significant level of over-supply of employment land identified in the SSLP.

The contribution to unmet needs of neighboring authorities should be increased to at least 4200 dwellings to take account of the extra year of the plan.

The Council is still relying on the 2018 Strategic Growth Study to justify the 4000 home contribution, although the shortfall now extends 3 years beyond the end date of that study to 2039. Other relevant information (including data migration and commuting flows between the District and the Black Country) has been ignored in favour of the focus solely on the SGS as the basis for the scale of the redistribution. Both migration and communting flow data shows a very strong functional relationship between South Staffordshire and the Black Country. Therefore, RPS contend that other data sources should be taken into account and which indicate that the contribution should be higher than 4,000.

Object

Representation ID: 4957

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RPS agrees that exceptional circumstances exist to justify the release of green belt land for housing. This is because, as stated at paragraph 5.3 of the SSLP, opportunities to locate development on brownfield sites is ‘very limited’ due to the largely rural nature of the District. However, RPS considers that the Council can, and should, go much further than its current proposals for altering the Green Belt. RPS contend that Land east
of Brookhouse Lane (site 170) is an appropriate site to be released for this purpose.

The assessment of site 170 as moderate harm in the Green Belt Study is incorrect as this assessment relates to the sub parcel rather than specifically site 170. Furthermore, the GBS does not take into account the emerging proposals for the Site set out in the illustrative masterplan in the Vision Document, which shows that a significant proportion of the Site will remain open and undeveloped as part of development.

The assessment does not reflect on all available and relevant information submitted in support of Site 170. On this basis, the assessment of contribution and harm applied by the Council to Site 170 is not robust and so is not soundly-based.

A site-specific Green Belt assessment has been undertaken on behalf of Persimmon Homes by Pleydell Smithyman Ltd (PSL) against the five purposes of Green Belt demonstrates that the site has a low harm rating. On this basis, Land east of Brookhouse Lane should be released from the Green Belt and allocated for housing in the SSLP.

As an alternative, RPS contend that it would be logical to identify site 170 for safeguarding in this local plan. The evidence presented in this submission shows that Site 170 would cause the least harm to the wider Green Belt than any other Green Belt site option considered at Featherstone.

Object

Representation ID: 4958

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

The HMA SOCG does not confirm that any local authority member of the GBBCHMA as being signatories to the SOCG in its current form. Given that all local plans moving forward (either recently adopted or under review) will be planning beyond 2031, the lack of an agreed position on how the unmet need will be accommodated within the HMA and the scale of the shortfall post-2031 is a significant failing in the process of cooperation across the HMA to date.

Paragraph 7.2 of the Duty to Co-operate Topic Paper points to the need for an ‘urgent review’ of the current evidence base, including the SGS. However, there is no timetable for when this evidence base will commence or be completed. This represents a clear and obvious delay in the process of addressing the unmet needs of the HMA with no clarity on when this is likely to be concluded. This demonstrates that meaningful progress it not being made on addressing this strategic matter, and which is further undermined given the lack of signatories to the draft SOCG.

Paragraph 7.4 of the DTC Topic Paper suggests that additional Strategic Growth Locations may be needed to meet any ‘residual unmet need’ This ignores the fact that other locations may be suitable to address any emerging shortfall, notably sites located on the edge of settlements in close proximity to where the unmet need arises from.Therefore, in order to reduce the delays, and to reflect the stage the SSLP has now reached, a more timely, pragmatic, and effective approach would be to focus the search for additional sites to address the unmet need on those settlements in the South Staffordshire that are well-located in relation to where the unmet need arises from, and which are locations where development would be consistent with the spatial development strategy. This includes Featherstone, which is well-located close to Wolverhampton. The Land east of Brookhouse Lane, Featherstone represents an obvious option.

Given that no substantive progress or agreements have been made, RPS does not consider that the Duty has been met at this time.

Object

Representation ID: 4959

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RPS contends that the Council has, through its evidence base, sought to underscore the potential for Featherstone to support higher levels of growth as a basis for limiting any further development opportunities in the SSLP.

The level of growth is most influenced by the Rural Services and Facilities Audit that has used Hansen scores to assess access to employment. The analysis has identified two ‘employment sites’ in close proximity to Featherstone, when four should have been identified (Hilton Main, Hilton Cross, HMP Featherstone, ROF Featherstone). When taking into account the provision of existing employment at Hilton Cross Business Park, and the emerging provision at ROF Featherstone, this would, in RPS opinion, lead to a different score for Featherstone in terms of access to employment. RPS suggest that a score of ‘Good’, and not ‘medium’, is more appropriate in this regard.

Featherstone is also accessible to the West Midlands conurbation via public transport so is ideally placed to accommodate additional housing to help balance the provision of employment currently provided. This 'balanced approach' to homes and jobs can assist in reducing the level of out-commuting, which the Council has identified as a key challenge for the District.

The strategy which seeks to limit growth at Featherstone does reflect the available evidence and so is not soundly-based (not justified). The Land east of Brookhouse Lane, being promoted by Persimmon Homes, represents an ideal opportunity to help deliver this.

The importance being placed on the SGS as the basis for allocating SA2: Land at Cross Green to address the needs of the Black Country raises concerns regarding the soundness of this approach. Specifically, the SGS does not take into account the relative affordability of housing in this area and its ability to meet the needs of black country residents. The data shows that house prices within the area where the Land at Cross Green site is allocated are nearly 60% higher than the average house price across the Black Country. This further supports the case for housing needs from the Black Country to be directed to Featherstone, where a broader mix of households already exists and where a mix of market and affordable housing can be easily integrated into the settlement. this brings into question the soundness of the approach in respect to the strategic location at Cross Green and specially whether households from the Black Country will be able to access housing. his problem is most likely going to be exacerbated due to the significant infrastructure needed to support a 'new village' at Cross Green.

A more appropriate response would be to allocate additional land at Featherstone, Land east of Brookhouse where affordability is more consistent with that of the Black Country.

Object

Representation ID: 4973

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Having reviewed the Housing Site Selection Topic Paper (HSSTP) with respect to the sites assessed at Featherstone, including site 170, RPS disputes the conclusions of the Council’s site assessment for site 170.

Firstly, it is clear, on the Council’s own evidence, that site 170 performs well in terms of Green Belt harm (‘moderate’) and Landscape sensitivity (low-moderate’).

Secondly, RPS contends the highways concerns raised by the County Highways Authority (CHA) has been over-stated and result in an unduly negative assessment for the Site. An initial transport strategy prepared by PJA, on behalf of Persimmon Homes, outlines how these concerns can be mitigated in order to facilitate suitable development on the Site. RPS therefore disputes the CHA view further assessments are required at this stage to justify allocating the site on highway capacity grounds. The reasons for excluding the site on highways grounds are therefore not justified.

The assessment for site 170 in the HESA (specifically the amber score for indirect impacts on designated heritage assets) is arbitrary in nature and does not represent a robust assessment. The vision document demonstrates that built development would be significantly set back from the edge of the site that would increase the stand off to more that double the Council's estimate.

The 'Known constraints' relating to site 170 are not justifiable. RPS does not agree with overall conclusions drawn by the Council in relation to site 170 which has resulted in its exclusion from the SSLP. Whilst some constraints may impact on the Site, none of them preclude residential development on the Site, nor do they prevent the Site from being allocated in the local plan for residential use. RPS does not consider the reasons for excluding the site to be soundly-based.

Object

Representation ID: 4976

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RPS does not consider the findings against a number of SA objectives to be soundly-based.

Under SA Objective 4, RPS would question the relevance of including consideration of Green Belt under this objective, given the fact that Green Belt is a strategic designation based on five purposes, none of which relate to landscape factors. RPS does not consider the Council’s conclusion that development on this site would cause ‘moderate harm’ to the Green Belt purposes soundly-based. In relation to landscape sensitivity, a previous Planning Inspector for application 06/00638/OUT would not have a material effect on the landscape character of the area.

Under SA Objective 5, the effects are over stated when taking into account the potential for mitigation. Air and noise effects from the M54 were considered in the earlier planning application where both the Planning Inspector and the Secretary of State concluded that this would not represent a barrier to development. The assessment has also not taken account of the decision made the Government in April 2022 to allow the construction of a new M54/M6/M6 Toll/ A460 link road that will reduce traffic flows. For water, RPS highlights that the illustrative masterplan shows that any bult development would set back from existing watercourses in the vicinity and within the site and, notably, a sustainable urban drainage system will be designed and installed as part of development on the site.

Under SA Objective 6,RPS disputes the score given for the site. Firstly, the site has been used for cultivation more many years and so, for the vast majority of the site, it is disputed whether the soils are, in fact, of ‘ecologically valuable’ given its current use. No evidence is presented by the Council which shows the site to be of Grade 3a value, and thus classed as ‘BMV’ land. In light of the above, RPS contends that the site should not be scored ‘minor negative’ under this objective without sufficient evidence to support the Council’s claim.

Under SA Objective 10, RPS disputes the assertion that the site would have a minor negative impact with respect to access to bus stops. 800 meter threshold is used in Manual for Streets and there are a number of bus services within this distance. Furthermore, the use of a 400m threshold differs from those used by the Council as part of its rural services audit. Specifically, the Rural Services and Facilities Audit (RSFA), which applies a proximity ‘range’ of between 800 to 2,000m (see paragraph 3.17 of that report). RPS contends the SA methodology for this objective is not fit for purpose as a reasonable measure of significant effects. Consequently, when applying the national standards and those used elsewhere in the Council’s evidence base, as a measure of access to local services, site 170 would clearly score ‘minor positive’. RPS also disputes the Council’s suggestion that site 170 is located beyond 2km of a convenience store, and thus would score ‘minor negative’.RPS contends that site 170 would, in overall terms, have a ‘minor positive’ impact on access to transport and accessibility.

Under SA Objective 11 RPS disputes the basis for the criteria identified in the SA methodology for distance to education. The 1.5km threshold applied under this objective equates to a distance of less than one mile (0.9 miles). However, both national and local guidance applies a wider distance threshold (3 miles) in measuring appropriate distances between home and school locations. RPS considers the distance thresholds applied under this SA objective to be arbitrary in nature and are not based on any local assessment of what would constitute an appropriate distance. Consequently, the score for Site 170 under this objective should be adjusted to ‘minor positive’.

Under SA Objective 12, it is wrong to suggest the site has unreasonable access to local employment opportunities when the RSFA using the same Hansen scores identified site 170 as having ‘medium access to employment’. RPS contends that the SA has wrongly applied the findings of the RSFA in light of Featherstone’s accessibility to local employment. Accordingly, the Council should identify the correct effect consistent with the SA methodology. The correct score in RPS’ view, as defined in the methodology, is ‘minor positive’.

It is unclear how the SA has informed the site selection process given that the reasons for why sites have been rejected have been inserted into the SA from elsewhere in the evidence base. This approach is therefore contrary to the approach required in national policy.

The SA should therefore be updated in response to the issues raised and Site 170 (Land east of Brookhouse Lane) allocated.

Object

Representation ID: 5368

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Further to the Preferred Options consultation the Vison has been amended to reflect the Council’s declared climate emergency, with greater emphasis placed on providing homes which accord with the NPPF 8c guidance that in order to achieve sustainable development, proposals should mitigate and adapt to climate change. It also seeks to 'protect and enhance' the District as it currently exists, rather than thinking forward and considering how the growth proposed within the Plan can better the District as a whole.
Although the Vision is broadly supported it should be amended to reflect the need to meet both the present and future housing requirements, including those pressures arising through the Duty to Cooperate with neighbouring authorities, with specific reference to meeting the unmet housing needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA). The delivery to meet the housing requirements of the GBBCHMA is discussed further in this representation, however Persimmon Homes considerers that it should be included in the Vision to clearly demonstrate commitment to the statutory Duty to Cooperate.

Object

Representation ID: 5369

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Vision seeks to create ‘beautiful and thriving’ new places, however as stipulated in earlier representations to the Preferred Options Consultation, there also needs to be a greater emphasis placed on a Vision which is locally relevant. Whilst the Vision is succinct, as currently written it is not considered to be relevant locally and contains no spatially specific elements, and this should be reflected through further amendments to the Vision Statement.

Object

Representation ID: 5370

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In relation to Strategic Objective 2, reference is made to meeting the housing and employment needs of the District. It is considered this could be strengthened to refer to meeting the needs of both existing and new residents of the District. The overarching thrust that new housing should be focussed on sustainable locations in the District, including the key villages, is supported.