Publication Plan November 2022

Object

Representation ID: 4209

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No evidence of SPD, infrastructure delivery strategy or masterplan in evidence base for Langley Road. Lack of an urban capacity study to show how SSDC has examined all other reasonable alternatives. Lack of evidence from Local Health Authorities, Social Services, LEA, Highways Authority, Emergency Services. No up to date Air Quality Study.

Object

Representation ID: 4211

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No requirement in law to accept overspill from neighbouring authorities. Dudley can meet its own needs and Wolverhampton had help to identify another 5,000 dwellings. No account has been taken of city centre supply and Black Country urban capacity is uncertain. Plan figures are outdated for reasons set out in consultant report. Majority of Black Country shortfall is from Sandwell, which is not adjacent to South Staffordshire. No account has been taken of WMCA funding to regenerate brownfield land or 5,000 dwellings at the NEC west of Birmingham. There is also an project for new housing on a Bushbury school site. These should be used to reduce duty to cooperate figures. Consultant report suggests capacity in Birmingham/Black Country vastly underestimates windfalls and vacant properties. 35% uplift shouldn’t merely be added on top of additional housing requirements. 13% buffer has also been added by South Staffordshire.

South Staffordshire should be holding urban authorities to account on regeneration before committing to releasing Green Belt land. WMCA have received £503 million from government and Wolverhampton alone has received £340 million for city centre regeneration. This warrants a re-evaluation of housing need in the GBBCHMA. The National Brownfield Institute offers greater cost-effective opportunities for redeveloping brownfield land.
The Black Country Plan has been abandoned and until these plans are more advanced committing to such a large contribution to their unmet need is disingenuous. The Secretary of State made it clear that the government intends to remove mandatory housing targets and drop requirements for the 20% buffer. He also indicated that a 2 year transition period for Councils to reassess land to be released, allowing for unsuitable sites to be removed from the plan.

Object

Representation ID: 4212

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Accommodating unmet needs is not an exceptional circumstance for Green Belt release. The Black Country and SSDC have not examined all reasonable alternatives to accommodate need. SSDC have not completed an urban capacity study and Black Country Authorities have not assessed their city centre capacity. CPRE brownfield report identified 99,600 dwellings that could be built in the West Midlands.

No public consultation was carried out on proposals to split Lower Penn into separate ‘settlements’. Describing parish as ‘land to the west of Wolverhampton/urban edge’ rather than Lower Penn is contrary to NPPF 35(b), does not recognise Lower Penn’s classification as a Tier 5 settlements and is inconsistent with the treatment of other Tier 4/5 settlements.

Object

Representation ID: 4213

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 1: the SA is wrong to record GHG emissions as uncertain, both in respect of the number of dwellings on the site and because of the lack of differentiation for undeveloped/greenfield sites. The SA fails to meet the SEA directive requiring integration of environmental considerations with a view to promoting sustainable development. Objective 2: SA fails to explain how post-mitigation scenario has changed from major negative to positive. Objective 3: Assessments of impact on LNR and habitats fail to have regard to evidence submitted by ecologists in 2021 consultation and Staffordshire Wildlife Trust. Objective 12: Appraisal notes that residents at the proposed site would have ‘unreasonable’ sustainable access to employment. This is contrary to local plan aim to locate development in more sustainable locations making the plan unsound. Inaccuracies are also present in the Appendix H site selection reasons and this section is at odds with the objectives of the Sustainability Appraisal

Object

Representation ID: 4214

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Public consultation on the plan has not been inclusive or accessible. Residents who are not computer literate have been excluded from the plan process. Barely any copies of the quarterly magazine with the 2021 consultation were received. Online sessions have been wholly unenlightening due to format. The 2021 consultation only achieved a 3.5% response rate. The references to external documents and technical terminology in the plan are not easily understood. Online consultation system was overly complex and Site 582 was rarely, if at all, referenced by Parish name.