SOUTH COUNCIL – LOCAL PLAN REVIEW – 2018 - 2037 SPATIAL HOUSING STRATEGY & INFRASTRUCTURE DELIVERY – OCTOBER 2019

LAND WEST OF GUNSTONE LANE –

Mr & Mrs A LEWIS: Mr & Mrs J LEASON & Mr & Mrs A CHARTERS ______1. I refer to the above consultation and confirm that I act for the owners as above of the land identified on the attached plan .

2. The land concerned has not been put forward for consideration to-date and so not evaluated in the SHELAA. It does adjoin other land parcels (site refs. 222 and 513) which have been considered by the SHELAA as “potentially suitable”. An identical categorisation is appropriate for my clients’ land.

3. My clients wish their land to be considered for future housing development either independently or, in association with the above land parcels, as part of a comprehensive scheme.

4. It is noted that the Green Belt Assessment, at page 524, concludes that “.. Smaller areas adjacent to the edge of Codsall (west of Gunstone Lane) and Bilbrook (the sewage works and adjacent land to the west and south) are more contained by urban edges (and in the latter case by Moat Brook), such that their release would not weaken boundaries or the integrity of the wider Green Belt.” The assessment of harm from the land’s release is that it would be “moderate” and part of the above land parcels is specifically so designated on the “Overview Map”. That part (as is part of Site ref. 222) is also noted to be within the “buffer zone” of the Conservation Area which, in itself, does not preclude future built development

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5. It is also noted that the Landscape Sensitivity Assessment rates this area as “Moderate – High” -“The landscape has a moderate-high overall sensitivity to residential development due to its historic field pattern, visual prominence and its importance as a rural setting to the Conservation Area. This is counterbalanced by the lack of valued natural features and the low perceptual qualities.” The Assessment Area includes a significant area of open land to the west of the Conservation Area. It is considered that te inclusion of this area of land distorts this overall assessment. The development of my clients’ land parcels will have very limited landscape impact in itself.

6. From the published documentation, it is clear that within all the options put forward which can actually meet the housing requirement as stated, a significant area or areas of land will need to be removed from the green belt (either as allocations or future areas of safeguarded land) in Codsall/Bilbrook. This is both to meet for some of the housing need and also, as stated, to enable infrastructure needs, including the proposed new first school; the “by pass” for Bilbrook centre and a further station car park at Codsall made available etc.. to be met.

7. Whilst the generality of concentrating new development where it can assist in meeting infrastructure and related needs, is supported, this should be just one consideration in the strategy and site selection process. It is necessary and in accordance with national Policies to have regard to these and other material considerations. The Final Strategy should also, however, have regard to available infrastructure capacity within localities which does not appear to have been evaluated.

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8. Considering the Council’s preferred Option G in this context, it is noted the employment/warehousing led proposal west of ROF Featherstone is to provide some 23% of the new housing allocation (some 1200 dwellings), whilst allocations adjoining the Black Country are to provide some 39% of these new allocations.

9. These “unique infrastructure opportunities” west of ROF Featherstone closely align to an area of ‘very high’ harm Green Belt , as identified in the GBS . It is also noted that the SHELAA describes the location as “not disassociated from the urban area” . This description is challenged. The proposal will create new housing in a totally isolated location, devoid of any community and related facilities and unrelated to any urban area and related facilities and with no certainty of creating sustainable transport modes.

10. From documentation considered to-date, the feasibility and viability of the overall proposal at ROF Featherstone appears to be still under evaluation. Moreover, a decision on the proposed Interchange (Strategic Rail Freight Interchange) (SRFI) is anticipated during the early part of 2020. This proposes some 743,200m2 of new rail-served and rail-linked warehousing and other associated development on land west of Junction 12 of the M6 in and will create some “..8,550 direct jobs boosting opportunities”. If the SRFI proposal is approved, there would be no need for ROF Featherstone warehousing led scheme and no need, therefore, for the enabling housing development. There is clearly no certainty that the housing proposal in this location is deliverable.

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11. A Strategy that relies upon this proposal can, therefore, only be described as “high risk”. Moreover, from the SHELAA, much of the potential land available to provide for some 60% of new housing allocations, as above, appears to be under the control of a small number of national house builders, thereby placing heavy reliance on their ability to meet the requirements. This adds to the “risk” that the strategy will not produce the necessary number of dwellings and in the timescale required.

12. Codsall/Bilbrook, as one of the identified Tier 1 settlements and recognised in the GBHMA Strategic Growth Study as a growth location close to employment opportunities and with good public transport links to the conurbation, could provide for an additional scale of new housing beyond the indicative figure set out currently for Codsall/Bilbrook in Option G. This would be a more balanced approach and one more consistent with national green belt and related Policies – NPPF paras. 60; 78; 91; 92: 96: 138; 139 and 141, in particular refer.

13. It is noted that the Sustainability Appraisal [SA](Para. 10.14.2) whilst concluding Option G is identified as the best performing option, states that “ It is difficult to differentiate between the sustainability performance of Spatial Options D, E, F and G, as the proposed development under all of these options would be likely to result in the same or similar sustainability impacts….” . The justification for choosing Option G is that it “..would be likely to result in the greatest positive impacts in terms of sustainability in particular in regard to education and access to employment”. This assertion is neither fully explained nor justified.

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14. In the above context, objection is made to the approach in paras.1.5 & 1.6 of Appendix 6 which state that the Council “..will only consider the allocation of sites which are either suitable (i.e. S1, S2 and S3), or could be made suitable through the removal of a policy or physical constraint (i.e. NCD1 and NCD2)” and “..1.6 To further narrow down which sites will be selected for allocation, sites will only be assessed for allocation where they are in an potential location for growth under the infrastructure-led strategy (Spatial Option G) (my emphasis) proposed by the Council in section 5 of the Spatial Housing Strategy and Infrastructure Delivery document….”

15. This is in direct contrast with the stated intention in the published Spatial Housing Strategy & Infrastructure Delivery Consultation document at paras. 2.7-2.9 and 5.3., that:

“.. We are seeking views on these options to allow for more detailed consideration of potential sites and infrastructure requirements which will meet the preferred Spatial Housing Strategy. This will be reflected in the Preferred Options Plan consultation (Summer 2020).”

and

“Feedback from this consultation on all of the spatial housing options will be used to consider whether the Council’s preferred approach (Spatial Option G) should be amended to place greater weight to delivering other elements of the alternative options, or whether a different strategy should be pursued altogether”.

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16. It must be correct that the basis of any consultation exercise must be to obtain both information and views on the preferred approach and the options available. In this case, the Council’s preferred option is a significant departure from historic development patterns in the District. Moreover, the Council acknowledges (paras. 2.17 – 2.18 of Infrastructure Delivery Plan [IDP] 2019 refers) that various studies are still underway on aspects of the strategy, the results of which may influence the final strategy and site selections.

17. The land parcels individually also “fit” the NPPF requirement (para. 68) to accommodate at least 10% of their housing requirement on sites which are no larger than I hectare. Such sites are assessed in the above as making an important contribution to meeting housing requirements and are “..often built-out relatively quickly..”.

18. In summary:

i) My clients’ land is now put forward for consideration in the context of the Local Plan Review process. It’s potential to meet some of the housing needs, either independently or in conjunction with adjoining land needs to be fully evaluated

ii) Development of the land parcels would overall have a moderate impact upon green belt and landscape considerations and accord with many other aspects of national planning policy and guidance, including para. 68.

iii) Objection is also made to the site selection methodology (Appendix 6) which limits further consideration to those sites that fit the Council’s currently preferred

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strategy, without regard to the responses to this consultation and other material considerations

iv) The Council’s currently Preferred Option G is very high “risk” in view of its heavy reliance on both the implementation of ROF Featherstone etc. “enabled” by development which would result in “high harm” to the Green Belt and fails to accord in this and other respects with many aspects of national planning policy and guidance.

v) The “risk” is exacerbated by the apparent reliance also on a small number of national house builders, who appear to have secured interests in the land areas concerned, to ensure that housing requirements over the plan period are met.

vi) The final Strategy should give more consideration to the potential of Tier 1 villages in meeting housing and infrastructure needs (particularly Codsall/Bilbrook, which is recognised in the GBHMA Strategic Growth Study as a potential growth location).

19. In relation to the specific questions set out, the above results in the following responses:

Q1 - no, the evidence base awaits the completion of further studies and the results of this consultation, the conclusions and findings of which may influence the final strategy and site selections.

Q2 - yes

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Q3 - yes but density should be considered on a site by site basis having regard to context and consistent with the emphasis in the NPPF on design considerations

Q4 - no, provided that elements of the seven options are not considered to be mutually exclusive

Q5 - yes, provided that elements of the seven options are not considered to be mutually exclusive. An alternative strategy delivering elements of other options (Option D in this case) as above should be pursued.

Q6 - no, as explained above

Q7 - no

Q8 - green belt release is inevitable

Q9 - yes

Q10 - yes

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