Publication Plan November 2022

Object

Representation ID: 4360

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The West Midlands Interchange was identified and given a Development Consent Order on the basis of the road/rail link. If removed from the Green Belt there is a distinct possibility that the road-rail interchange would not be built but the development would proceed anyway. As the consent is already in place there is no good reason to allocate the site - this could be considered again in local plan reviews once the site is constructed.

Object

Representation ID: 4364

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council is seeking an excessive area of land for new housing development in this location. Gross site areas are at unduly low densities and no detail is given of net developable areas, maximum numbers of dwellings or land requirements for other uses. No detail is given of infrastructure needs such as highways, drainage/sewerage, playing fields and associated facilities. No information is provided on funding, phasing or thresholds for provision of facilities and services.

Land East of Bilbrook only requires 24.2ha of land at the Council's minimum density of 35dph.

Object

Representation ID: 4365

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council is seeking an excessive area of land for new housing development in this location. Gross site areas are at unduly low densities and no detail is given of net developable areas, maximum numbers of dwellings or land requirements for other uses. No detail is given of infrastructure needs such as highways, drainage/sewerage, playing fields and associated facilities. No information is provided on funding, phasing or thresholds for provision of facilities and services.

No neighbourhood centre is shown on concept plan and no land requirements are given. At 35 dph only 34.3ha of land is required, leaving 20ha for other uses. Includes a primary school despite a three tier system being in operation here. Unclear where secondary school children will be accommodated. Have Education Authorities in Wolverhampton and Staffordshire agreed education provision and funding? No explanation given around areas for development or sports pitches. New rail station and neighbourhood centre are not located centrally. Only Site 646b has a frontage to the A449. Site access to 646a is unsatisfactory, what have the highways authority said? No evidence from Network Rail of agreement to new station on this aprt of the West Coast Main Line, no feasbility or viability assessments or information such as funding. Unclear how station will be supported by development. No indication of public transport services (bus). How has the Duty to Coopearte been met in relation to the new road crossing the railway?

Object

Representation ID: 4366

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council is seeking an excessive area of land for new housing development in this location. Gross site areas are at unduly low densities and no detail is given of net developable areas, maximum numbers of dwellings or land requirements for other uses. No detail is given of infrastructure needs such as highways, drainage/sewerage, playing fields and associated facilities. No information is provided on funding, phasing or thresholds for provision of facilities and services.

At 35dph only 56ha of land is required. The proposal includes a school but is in a three-tier area. Where are secondary age children to be educated? Have the education authorities in Wolverhampton and Staffordshire agreed education provision and funding with South Staffordshire Council?

Object

Representation ID: 4367

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council is seeking an excessive area of land for new housing development in this location. Gross site areas are at unduly low densities and no detail is given of net developable areas, maximum numbers of dwellings or land requirements for other uses. No detail is given of infrastructure needs such as highways, drainage/sewerage, playing fields and associated facilities. No information is provided on funding, phasing or thresholds for provision of facilities and services.

At 35dph the area required for housing development would be 32.3ha.

Object

Representation ID: 4370

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Stafford Borough Council is over-providing against its own needs, with housing growth in the adopted Stafford Local Plan being 70% driven by in-migration, including from South Staffordshire District, an approach which was supported by Duty to Cooperate meetings at the time. It was agreed with South Staffordshire at the time that Stafford would not extend southward. Stafford is also exceeding its own housing targets, averaging over 600dpa against a requirement of 500dpa.

There is no reasoning for allocating the site as it was refused permission previously and does not serve the needs of South Staffordshire or the Black Country. South Staffordshire is already over-allocating above its own needs and this and other greenfield sites are not needed.

Object

Representation ID: 4371

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Surprised that the Duty to Cooperate has been fulfilled as Stafford previously objected to the site. Wish to see correspondence evidencing that the duty has been satisfied. No acknowledgement has been given in South Staffordshire's local plan to the previous Stafford Borough Plan statements indicating that Stafford is planning for in-migration from South Staffordshire.

We question whether South Staffordshire Council has cooperated with Stafford Borough Council and Staffordshire County Council, particularly on education, and other relevant bodies (particularly medical). The Duty to Cooperate topic paper doe not cover the issues raised in this representation.

Object

Representation ID: 4372

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We have failed to find evidence to show the reasoning for the choice of the 'magic number' of 4000 additional homes and that the calculation of the scale and distribution of the 'overspill' from the Greater Birmingham area has been agreed with all of South Staffordshire's neighbouring Councils in Statements of Common Ground (or in some other form) and with the authorities in the Greater Birmingham Housing Market Area.

We have not found evidence that the Duty to Co-operate with all neighbouring authorities has been met in respect of the whole plan, particularly Staffordshire County Council in relation to education and highways and Wolverhampton City Council also in relation to education and highways.