Publication Plan November 2022

Object

Representation ID: 5031

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Concerns over the soundness of the proposed housing allocation for the following reasons:
-current requirement (241 dpa) is lower than recent delivery rates, PPG states that higher delivery rates can be considered when determining need.
-current requirement does not promote uplift to support economic growth.
-4,000 contribution needs to be revised to take into account Black Country shortfall, Birmingham plan review and urban capacity evidence.

Object

Representation ID: 5033

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Concerned that the approach will not provide an effective supply of deliverable sites throughout the different stages of the plan period. Object to the exclusion of proportionate scale allocations near to small settlement. The proposed distribution is unbalanced and skewed towards large strategic sites and existing allocations/safeguarded sites. To promote health of all settlements the portfolio should be more balanced.

Amend the spatial strategy to increase the provision of smaller sites which will be able to be delivered early in the plan period distributed throughout settlements in each of the Tiers 1-5.This will help to maintaining a healthy five year supply of sites throughout the plan period. the current strategy is over-reliant on a limited number of larger sites.

Object

Representation ID: 5050

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Identify safeguarded land and Increase the flexibility allowance for the housing land requirement to 20% to ensure the local plan delivers at least the minimum housing requirement within the plan period. The additional sites should be identified which are capable of delivery early in the plan period.

Object

Representation ID: 5055

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Sustainability Appraisal

Green Belt criteria has not been applied consistently across the site assessments in the SA. SA methodology fails to distinguish between potential level of Green Belt impacts, particularly around settlements with sites of moderate-high impacts expected to perform comparatively better than sites of high or very high impact.

Education criteria has not been applied consistently across the site assessments in the SA. Education criteria assessment unclear. The only criteria for a major or minor impact is whether the housing is a ‘new’ development. SA for site 515 refers to minor negative impact so it is not clear how a subsequent ‘major’ impact (pre mitigation) has been derived.

Overall, neither the Greenbelt or education criteria appear to have been applied consistently.

Object

Representation ID: 5056

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Sustainability Appraisal

Suggest that Option F should be given more thorough consideration as a viable alternative option which would increase the level of housing supply to address the concerns identified in separate representation 5031 on the inadequacy of the present approach.

Object

Representation ID: 5062

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Green Belt Assessment

Anomalies identified, particularly at Codsall, which need to be addressed. SHEELA site 515 is located in parcel S46Bs2 which is assessed as being moderate-high. The site 515 should be categorised as ‘moderate harm rating’ the same as the adjacent land parcel to the east (Parcel S50A). Conversations with officers has suggested that this anomaly would be corrected.

Object

Representation ID: 5066

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Concern that 30% requirement is over optimistic given the reliance on strategic sites. A more balanced portfolio of sites is required including proportionate scale sites associated with the small settlements.

Object

Representation ID: 5067

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Include the following sites to improve the diversity of deliverable sites which will ensure that the delivery of housing with remain consistent through the plan period and that delivery will promote the health of settlements throughout the district:

SITE – Tonge Road, Bishop’s Wood
Disagree with Publication Plan spatial strategy and the decision to omit allocations adjacent to Tier 4 settlements. This approach will not support a proportionate and balanced level of growth across the District or ensure effective delivery across different phases of the plan period. The site at Tong Road is not known to be unduly constrained by topography, ecology, flood risk or heritage and provides an opportunity to deliver Tier 4 growth as identified in the Spatial Housing Strategy and Infrastructure Delivery Plan (2019) consultation.

SITE – Hockerhill Farm, Brewood
This site is readily available and would form an appropriate alternative or additional site allocation to the existing site allocation Site 079. The site would be is adjacent to the Tier 2 settlement of Brewood and would be in keeping with the linear pattern of development along Kiddemore Road.

SITE – Dirty Lane 1, Brewood
Site is located adjacent to the Tier 2 settlement of Brewood, in a sustainable location providing ready access to a range of facilities. Site compares favourably in term of Green Belt impacts, LUC study concludes that release of this parcel would not weaken the Green Belt boundary or the integrity of Green Belt designation. The site is considered to be a suitable candidate as an allocation for residential development and could contribute to the 10% supply on sites less than 1 hectare. Further site investigation required in relation to access.

SITE – Dirty Lane 2, Brewood
Site is located adjacent to the Tier 2 settlement of Brewood, in a sustainable location providing ready access to a range of facilities. Site compares favourably in term of Green Belt impacts, LUC study concludes that release of this parcel would not weaken the Green Belt boundary or the integrity of Green Belt designation. The site is considered to be a suitable candidate as an allocation for residential development and could contribute to the 10% supply on sites less than 1 hectare. Further site investigation required in relation to access.

SITE – Land South of Coven Road, Brewood
Non SHEELA site, in close proximity to the settlement of Brewood. The site is considered a potentially suitable allocation for residential development.

SITE – Land North of Whitehouse Lane, Codsall Wood
The site offers the opportunity for a proportionately sized allocation that respects the scale, character and distinctiveness of its surroundings. The site could help deliver rural housing in the early stages of the plan period.

SITE – Land North of Harriott Hayes Lane, Codsall Wood
The site offers the opportunity for a proportionately sized allocation that respects the scale, character and distinctiveness of its surroundings. The site could help deliver rural housing in the early stages of the plan period.

SITE – Land off Heath House Lane, Bungalow Site, Codsall
The site is located directly adjacent to the Tier 1 settlement of Codsall. The site has a lower ‘harm’ rating in relation to Green Belt than the majority of the land parcel within which it is situated and in comparison to other land parcels near to the settlement edge. The concern for the developer is that the 2019 and 2022 Greenbelt assessments differ in some interpretations when compared to the assessments conducted in 2014 and 2016. Notwithstanding these concerns the 2019 Greenbelt assessment would suggest that the representation site would comprise a natural extension to the settlement edge without comprising the purposes of Greenbelt. The site should be allocated for development to add flexibility to plan allocations and/or to provide future safeguarded land sites.

SITE – Land west of Heath House Lane, Codsall
The site is located adjacent to the Tier 1 settlement of Codsall. Land West of Heath House Lane, Codsall provides capacity for immediate housing development and a substantial and sustainable area of suitable land that can be safeguarded. Site should be read in conjunction with the Bungalow Site (see separate representation). Owing to larger size this site may be physically capable of accommodating first school requirements for Bilbrook/Codsall.

Object

Representation ID: 5068

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Include the following sites to improve the diversity of deliverable sites which will ensure that the delivery of housing with remain consistent through the plan period and that delivery will promote the health of settlements throughout the district:

SITE – Dirty Lane 2, Brewood
Site is located adjacent to the Tier 2 settlement of Brewood, in a sustainable location providing ready access to a range of facilities. Site compares favourably in term of Green Belt impacts, LUC study concludes that release of this parcel would not weaken the Green Belt boundary or the integrity of Green Belt designation. The site is considered to be a suitable candidate as an allocation for residential development and could contribute to the 10% supply on sites less than 1 hectare. Further site investigation required in relation to access.

SITE – Land South of Coven Road, Brewood
Non SHEELA site, in close proximity to the settlement of Brewood. The site is considered a potentially suitable allocation for residential development.

SITE – Land North of Whitehouse Lane, Codsall Wood
The site offers the opportunity for a proportionately sized allocation that respects the scale, character and distinctiveness of its surroundings. The site could help deliver rural housing in the early stages of the plan period.

SITE – Land North of Harriott Hayes Lane, Codsall Wood
The site offers the opportunity for a proportionately sized allocation that respects the scale, character and distinctiveness of its surroundings. The site could help deliver rural housing in the early stages of the plan period.

SITE – Land off Heath House Lane, Bungalow Site, Codsall
The site is located directly adjacent to the Tier 1 settlement of Codsall. The site has a lower ‘harm’ rating in relation to Green Belt than the majority of the land parcel within which it is situated and in comparison to other land parcels near to the settlement edge. The concern for the developer is that the 2019 and 2022 Greenbelt assessments differ in some interpretations when compared to the assessments conducted in 2014 and 2016. Notwithstanding these concerns the 2019 Greenbelt assessment would suggest that the representation site would comprise a natural extension to the settlement edge without comprising the purposes of Greenbelt. The site should be allocated for development to add flexibility to plan allocations and/or to provide future safeguarded land sites.

SITE – Land west of Heath House Lane, Codsall
The site is located adjacent to the Tier 1 settlement of Codsall. Land West of Heath House Lane, Codsall provides capacity for immediate housing development and a substantial and sustainable area of suitable land that can be safeguarded. Site should be read in conjunction with the Bungalow Site (see separate representation). Owing to larger size this site may be physically capable of accommodating first school requirements for Bilbrook/Codsall.