Publication Plan November 2022

Comment

Representation ID: 4900

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Comment

Representation ID: 4906

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Support

Representation ID: 4907

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the vision and strategic objectives set out. Strategic Objective 2 in particular references the need to meet the housing and employment needs of the District whilst making a proportionate contribution towards the unmet needs of the GBBCHMA.

The objectives for high quality housing to meet a wide range of needs and provide beautiful and sustainable places where people want to live are welcomed. The LPR
notes the lack of brownfield development sites available within the District, and the requirement for a careful release of suitable Green Belt land to meet housing need.

The strategic objectives of the LPR are sound.

Comment

Representation ID: 4908

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Whilst we have no in principle concern with draft policy DS1, the LPR should be drafted as though it is being read once the plan is adopted. The fifth paragraph may therefore need amendment to reflect that the Green Belt boundaries have already been altered, rather than ‘will be’.

We would recommend the following modification at draft policy DS1 paragraph 5 to reflect this:
“The Green Belt boundary has been altered through this Plan to accommodate development allocations set out in Policies SA1, SA2, SA3, SA5 and SA7”…

Comment

Representation ID: 4909

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

NPPF paragraph 142 states that the removal of land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. Planning practice guidance clarifies that this could include new or enhanced green infrastructure, woodland planting, landscape and visual enhancements, improvements to biodiversity and habitats, new or enhanced walking and cycling routes, and improved access to new or existing recreational and playing field provision.

Policy DS2 reflects this approach and provides sufficient flexibility to agree a contribution if no specific scheme can be identified.

Comment

Representation ID: 4915

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Given the significant remaining shortfall arising in the GBBCHMA and South Staffordshire’s clear functional relationship with the wider HMA (demonstrated by its
travel to work patterns, and transport links with Birmingham and the Black Country), Bellway are therefore supportive of the plan’s proposed contribution to the GBBCHMA’s unmet need. The scale of the contribution and the Council’s approach is justified by the Greater Birmingham and Black Country Strategic Growth Study (February 2018).

Nearly all of South Staffordshire’s villages are surrounded by Green Belt, therefore it is inevitable that the District will need to release Green Belt to meet its needs and those
of the wider GBBCHMA. As such exceptional circumstances have been clearly demonstrated to alter Green Belt boundaries through the draft plan, in accordance with NPPF paragraph 140.

The ongoing work with neighbouring authorities to agree the contribution to the shortfall is well evidenced, as such the Council has satisfied the duty to cooperate.

The approach to making a contribution to the wider GBBCHMA unmet needs is therefore positively prepared, based on effective joint working, and is consistent with
national policy.

Comment

Representation ID: 4916

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Wombourne is identified as a ‘Tier 2 Settlement’ within the policy. The village benefits from a host of local services and access to public transport, with close proximity to Dudley and Wolverhampton. Whilst we understand to some degree the rationale
underpinning the LPR’s settlement hierarchy, its rigid approach does not allow for making judgements on settlements such as Wombourne which has a significant
employment offer within Wombourne which is walkable and cyclable and not reliant on public transport. At 43.6ha Wombourne has the third highest provision of
employment land in South Staffordshire after Penkridge and Codsall / Bilbrook. This is significantly more employment land than other proposed Tier 1 settlements such as Cheslyn Hay / Great Wyrley (30.3ha).

Beyond this Wombourne also benefits from a frequent bus service (every 20 minutes) to Wolverhampton St Georges, just a 20-minute bus journey, therefore rail access is also nearby. Combined with its large retail, Wombourne’s employment provision and public transport accessibility clearly justifies it being a Tier 1 settlement.

Growth in Wombourne will be delivered through a combination of new allocations and the release of safeguarded land, such as that at Orton Lane, including the release of Green Belt land, particularly in the north eastern part of the village. The Plan recognises that this area benefits from good proximity to a variety of services and facilities, including regular public transport, as well as “relatively low Green Belt harm compared to other areas in the district”. It is therefore capable of accommodating
more than the level of growth identified for it, including Bellway’s land west of Strathmore Crescent, which is discussed further below.

In addition to Wombourne’s level in the settlement hierarchy, Bellway also have concerns regarding the spatial strategy’s reliance on land at Cross Green, which we comment on in response to draft policy SA2.

Comment

Representation ID: 4917

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

We have no objection in principle to the proposed allocation at Cross Green, however we have some concerns regarding the scale of delivery anticipated for the proposed plan period given infrastructure delivery.

Firstly, there are concerns regarding the access road to ROF Featherstone and the associate costs and the potential impacts on Cross Green’s viability and delivery
trajectory. The IDP now estimates the cost of delivering the access road at £14.4m-£19m, to be funded via Staffordshire County Council and developer contributions. Evidence should be provided as to how this will be funded. The only funding evidence to date is reference to £1.5m of Growth Deal funding being made available via the Stoke-on-Trent and Staffordshire Local Enterprise Partnership.

Secondly, mindful of the scale of infrastructure delivery at the site, no detailed evidence has been provided to support the site’s proposed quantum of housing growth
(1,200 new homes).

The Lichfields Start to finish report shows that the lead in times and delivery rate are ambitious.

In total, it is therefore assumed that Cross Green will only deliver around 1,000 new homes before the end of the plan period, 200 less than the policy assumes.

The Council should therefore consider preparing further evidence to justify the scale of growth proposed for Cross Green, or if this is not possible reduce the anticipated delivery before 2039 to 1,200 homes and identify other sustainable locations for this growth to be delivered elsewhere in the District (such as (such as Bellway’s site at Strathmore Crescent).

If the delivery rates cannot be evidenced than the following modification to draft policy SA2 at part a) will be necessary: “a) A minimum of 1,000 homes”

Comment

Representation ID: 4918

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Orton Lane (Housing Allocation 416)

We continue to support the principle of the release of the safeguarded land at Orton Lane for allocation for housing growth. The site remains suitable, available and
achievable, in accordance with Paragraph 68 of the NPPF. It was confirmed through the Housing Site Selection Topic Paper (2021) that the “site’s assessment process has revealed no unmitigable constraints to the delivery of the safeguarded land in Wombourne”. This was also confirmed through the examination of the SAD as recently as 2018.

Initial baseline technical work has demonstrated that the site can come forward for development in the short term, so can contribute to the Council being able to maintain
their five year housing land supply, and there are no constraints which would limit this. The enclosed framework plan (Appendix 2) demonstrates how the site can be delivered, responding to its constraints.

It is Bellway’s intention to commence pre-application discussions with the Council early in 2023 with a view to submitting an application before summer.

Bellway control the southern extent of the proposed allocation, St Phillips control the northern extent. Although there will be separate applications made by each party, we are committed to continuing to work together to ensure there is a coordinated approach to delivery.

Comment

Representation ID: 4923

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land off Billy Buns Lane and Gilbert Lane (Site Refs: 462 and 284) are proposed as allocations for a minimum of 223 dwellings. Bellway consider that their additional land
to the west of Strathmore Crescent (Site Ref: 708) is a more sustainable and suitable option for meeting Wombourne’s (and the wider District’s) housing needs.

Firstly, the Council’s own evidence (LUC Landscape Sensitivity Study (2019)) demonstrates that land west of Strathmore Crescent is less visually sensitive. EDP’s Landscape and Green Belt Review (2021) (Appendix 4) shows that the site has no landscape features of note and there are features present which limit the site’s sensitivity.

Secondly, the Council’s Green Belt Review (LUC Green Belt Study (2019) also shows that land west of Strathmore Crescent is located in a parcel which represents less Green Belt harm.
Land west of Strathmore Crescent’s lower Green Belt harm is influenced by fact it is visually and physically well contained being bound along its western edge by the
railway walk, residential development to the east and south.
In addition, there are clear synergies of delivering land west of Strathmore Crescent given its location adjacent to the proposed allocation and already safeguarded site at Orton Lane – it would support sustainable patterns of development as per NPPF paragraph 142.
Policy SA5 should therefore be modified to reduce the capacity of land off Billy Buns Lane and Gilbert Lane to reflect its constraints and land west of Strathmore Crescent should be added into the policy for a minimum capacity of around 40 homes.