Publication Plan November 2022

Comment

Representation ID: 4691

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Welcome the commitment for GBBCHMA authorities to update the 2018 housing shortfall position.

Housing Site Selection Topic Paper 2022
Failing to consider areas identified as having major negative impacts against the landscape criteria may result in an unsustainable pattern of development and would be contrary to ABCAs proposed use of Green Belt/landscape evidence base as identified in the Duty to Cooperate. The reference to the ABCA evidence base is odd, and the council has failed to provide a cogent justification for this; ABCA should not be involved with SSDC site selection.

Object

Representation ID: 4692

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The council is implementing 3 of the 4 Strategic Growth Study recommendations, the fourth - not being proposed - is a housing allocation north of Codsall/Bilbrook. This is contradictory to the council's own position in paragraph 5.15 of the GBBCHMA Development Needs Group Draft Statement of Common Ground August 2022.

The council has been misleading in it's references to 'north of Codsall/Bilbrook', as what is really being referred to is the extension to the previous allocation at 'land east of Bilbrook'. The council have in reality not accepted the Strategic Growth Study recommendations, and should provide an explanation as to why it has deviated from this approach.

The council should implement the Strategic Growth Study recommendations and locate growth to the north of Codsall/Bilbrook where Green Belt is less sensitive and would not have a 'significant impact'. This would be more consistent with NPPF Green Belt policy. The Growth Study also identifies this area as having potential for accommodating strategic growth.

The council should also: deliver a wider range of smaller sites which are more likely to deliver the range of homes needed to meet varying house type requirements. Help more smaller SME builders enter the market and not cater to volume housebuilders. Spread development to a wider range of locations which are likely to be more consistent with Green Belt policy and less likely to create coalescence with the Black Country. Review the council's housing provision in Codsall/Bilbrook as a stronger focus for development as a Tier 1 settlement and main administrative area of the district.

In terms of Green Belt boundary review, the Publication Plan fails to meet development needs and cater for the local economy and is therefore unsound.

The 'infrastructure led' plan appears to be an approach whereby sites are allocated where infrastructure can be more easily sought from developers by virtue of their size. This is not sound planning practice because: it introduces a new financially led criterion which conflicts with the objectives of achieving sustainable development where money steers the choice of sites. The selection methodology is being influenced by whether a developer is willing to offer a school (or not), which could be misinterpreted as a bidding process. It steers allocations towards large sites which favours volume housebuilders. And more critical planning issues are being traded off against an offer of infrastructure provision which is contrary to planning policy. E.g. Site 224 (Station Road, Codsall) has been selected due to the provision of a rail station car park despite high Green Belt harm.

Too much reliance has been placed on strategic sites which; are slow to come forward, focus more on volume builders providing similar product types, monopolises land release, create a danger of housing land supply shortages later in the plan period. The choice of alternative locations for allocations, or the distribution of the same level of housing across more locations, has not been sufficiently or thoroughly explored.

Object

Representation ID: 4695

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is illogical to determine the number of houses in a strategic location to meet the ambitions of the LEA to build a new first school. Further, it is the view of Bilbrook PC that the current school is adequate to serve requirements without the addition to the urban extension. The willingness of the developer to provide a first school should be irrelevant and unjustified; this would need to be done anyway for a scheme of its size.

Paragraph 8.39 of the Strategic Growth Study identifies the strategic separation between Wolverhampton and Codsall/Bilbrook as 'notable'. This allocation will remove this gap, and be compounded by local employment development.

The 2018 Green Belt review does not point to the allocation of SA1 (land east of Bilbrook). Further, the 2014 LUC Method Statement identified that Parcels 1 and 3 to the east of Bilbrook made a considerable contribution to the purposes of Green Belt: they had a 'strong' impact upon purpose a, and a 'moderate' impact upon purpose b. This harm is acknowledged in the Housing Site Selection Topic Paper, whilst the illustration in paragraph 5.41 does not indicate the true impact upon the Green Belt.

The site conflicts with the recommendations and findings of the Strategic Growth Study 2018 (where development to the east of Codsall/Bilbrook was warned against), and the Green Belt Study identified as having a 'strong' purpose.

Object

Representation ID: 4697

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Site 222 (land at Sandy Lane) - Omission Site.
Hallam Land Management were not contacted about the desire by the council to provide a new first school on site. Due to the site size and proximity to existing schools, there is no justification to deliver one. Nevertheless, the site could be delivered with the provision of a first school with c.115 dwellings.

The site was identified as part of a suitable strategic site within the Strategic Growth Study, and has less impact upon the Green Belt than SA1 with a 'moderate' impact upon Green Belt purposes a, and b. Unlike site SA1, there is no risk of coalescence with the Black Country or other settlement.

The findings of the LUC Green Belt Study have not been properly reflected in the sites chosen. Site 224 (land adjacent to Station Road, Codsall) is arguably contrary to NPPF Green Belt criteria.

The site has access to Codsall's local services and facilities including a first school, the council offices, shops, and railway station. It is also served by a bus route.

The site is now bounded on three sides by development. The adjacent Watery Lane development overcomes concerns around sensitivity. The Housing Site Selection Topic Paper is misleading in this regard.

The land parcels used in both the Landscape Sensitivity Study 2015 and Green Belt Review 2019 are too large so Sandy Lane is absorbed into a large land parcel which includes the conservation area and thus distorts the true character.

Object

Representation ID: 4722

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Accommodating Site SA1 (land east of Bilbrook) is contrary to NPPF Green Belt policy criteria pertaining to the coalescence of settlements, and does not meet the NPPF exceptional circumstances tests.

Site 222 (land at Sandy Lane, Codsall) could meet the NPPF exceptional circumstances test as it scores better in the LUC Green Belt Study for; size, character, and location, and would not cause coalescence.

Comment

Representation ID: 4725

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Provisionally support and welcome the contribution of 4,000 dwellings to meet the GBBCHMA shortfall. The shortfall is a constantly evolving figure, and there are ongoing uncertainties as to the Government's objectives in housing targets and the locations of growth. It is not considered unreasonable to believe that the shortfall will only increase.

Content with Codsall/Bilbrook being designated as a Tier 1 settlement, although believe Codsall's contribution to housing numbers is relatively modest as the administrative centre of the district.

Object

Representation ID: 4733

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is only a 5% flexibility allowance allowed for between 9,089 requirement and 9,588 capacity of available sites - 10% is expected. The extra flexibility has been accounted for through a windfall allowance.

Object

Representation ID: 4734

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is not appropriate for each site to display variety and choice in housing types and tenures, and for there to be a specific requirement of 70% of properties to be 3bed or less. It is not the case that smaller household units and an ageing population want smaller homes. There is a growing trend for the elderly to want spare rooms for visitors, and working age population to want home office space. This requirement should be removed.

Small sites should not be required to provide a mixture of property sizes.

Object

Representation ID: 4735

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirement for a minimum of 35dph will create high density designs which are contrary to people's expectations, demands, and needs. Sites will have too much public open space (and associated maintenance/management costs) but lack adequate private garden space. New houses mostly suffer from this to achieve arbitrary density standards.

The policy should be reviewed to ensure the council are not in danger of creating poorer future housing conditions. The solution is to release more land when and where it is needed.

Object

Representation ID: 4736

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Whilst the 30% requirement for affordable housing is accepted, this need not be a fixed figure. Sites will need to be considered against wider viability criteria and judged on its own merits/circumstances.

The Viability Study 2022 identifies that some sites may struggle to meet the affordable housing requirement. This may become more pronounced during a recession.

The guidance concerning the share and spread of affordable products is welcomed; but should not be a requirement as some sites may not be able to accommodate 50% Social Rented housing. Shared Ownership may become less attractive as interest rates rise, so developers should be given the opportunity to vary the offer to respond to local demand, viability factors, and grant funding circumstances at the time. The council should not hamstring itself by binding requirements to the SHMA.