Local Plan Review Consultation Response Form

Part A: Your Details (Please Print)

Please ensure that we have an up to date email address wherever possible, or postal address, at which we can contact you.

Your Details Agent’s Details (if applicable) Title Mr Mrs

First Name Rob Rachel

Last Name Boydon Best

E-mail Address [email protected] [email protected]

Job Title Operations Director Principal Planner (if applicable) Organisation Tardis Environmental UK Ltd Stansgate Planning Consultants Ltd. (if applicable) Address C/o Agent (ADM/RJB/8694) 9 The Courtyard Timothys Bridge Road Stratford-upon-Avon

Post Code CV37 9NP Telephone 01789 414097 Number

The South Staffordshire Local Plan review Spatial Housing Strategy & Infrastructure Delivery document is being consulted on for a period of 8 weeks from Thursday 17 October until 5pm Thursday 12 December 2019. For advice on how to respond to the consultation form please email [email protected] or call 01902 696000.

Please note:

• Comments must be received by 5pm on Thursday 12 December 2019. Late comments will not be duly made under the Regulations. • Please fill in a separate Part B for each paragraph/table/topic you are commenting on • Please explain your response where necessary

Representations cannot be kept confidential and will be available for public scrutiny, including your name and/or organisation (if applicable). However your contact details will not be published. Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: C/o Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 3 Paragraph Table Question (if applicable) 1 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that the evidence base used to inform the Spatial Housing Options is robust and proportionate? If not, what else should we consider?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

We object to two elements of the evidence base that are not considered to be robust. These are:

• The availability of sites – this relies solely on the SHELAA 2018 which is now 12 months old. It should be a ‘live’ assessment that takes account of any sites submitted anytime for assessment rather than fixed at a point in time, where no sites submitted after SHELAA 2018 are considered;

• The Rural Services and Facilities Audit 2019 - the downgraded categorisation of Essington from Tier 2 to Tier 3 does not reflect the evidence of access to services and facilities using the assessment criteria in the Audit. The Audit ignores those facilities available beyond the development boundary which when accounted for, shows Essington scores more highly than shown. Furthermore, it is vital the Audit recognises the contribution of the conurbation to the relative sustainability of settlements.

That does not appear to be any transport evidence. This could usefully provide information on the most accessible locations to guide development and focus the distribution strategy. There is guidance in the PPG.

THE AVAILABILITY OF SITES

Whilst it is right that sites must be deliverable and the purpose of the SHELAA is to inform site allocations with sites assessed to be deliverable, it must be a ‘live’ assessment that is not fixed at a point in time. It is already 12 months old and new sites will have been submitted to the Issues and Options Consultation that should be assessed and added. The District Council acknowledge the SHELAA is updated annually and sites can be submitted anytime. It should therefore be updated to take account of any additional sites presented or changes on sites assessed. It should be a starting point for site allocations to which sites can be added or amended as new factors become known. Other parts the evidence base have been updated following the Issues and Options Consultation that take account of comments made, but the SHELAA has not. My client submitted land to the SHELAA at Brownshore Lane, Essington in September 2018, regrettably too late to be included in the SHELAA published October 2018. Further details of the site, the constraints and the opportunities, were submitted in response to the Issues and Options Consultation November 2018 so the site is in front of the Council but is not included in the SHELAA 2018. Other parts the evidence base have been updated following the Issues and Options Consultation that take account of comments made, such as the Rural Services and facilities Audit, so why not the SHELAA too?

The SHELAA is to be the main source of sites for allocation and the sites assessed are found from several sources, not just sites promoted by a landowner but also sites identified by the planning officers. In the case of Brownshore Lane, land all around it is assessed but not the site promoted by my client which is notable in its absence when surrounded by submitted sites. It could have been assessed in any event for completeness.

The evidence base is not robust if it ignores opportunities coming forward post 2018 that were not known about at the time the SHELAA 2018 was prepared. The SHELAA should be regularly updated to pick up all opportunities. The Council are potentially missing opportunities and may allocate a less suitable site just because of the timing of submission.

THE RURAL SERVICES AND FACILITIES AUDIT 2019

This audit assesses the rural settlements by their relative level of access to services and facilities, to provide a settlement hierarchy of Tier 1-5 settlements (with Tier 5 settlements being the least sustainable in these terms). It has been updated since the 2018 version as a result of comments on the Issues and Options consultation.

The Audit is not robust for the following reasons:

1. The conclusions for Essington do not reflect the evidence;

2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation;

3. The groupings of settlements within tiers is arbitrary;

1. The conclusions for Essington do not reflect the evidence

Section 3 of the Audit provides the methodology for assessing the relative sustainability of settlements and lists five ‘Key Indicators’ which are:

A. Access to food stores

B. Diversity of accessible community facilities/services

C . Access to employment locations

D . Access to education facilities

E. Public transport access to higher order services outside of the village

The audit says how the key indicators will be measured and each indicator is assessed with its own colour banding. The colour banding for each indicator is shown on a summary sheet although it is a little confusing as each indicator has its own colour banding, rather than there being a standard banding for all indicators.

B. Diversity of accessible community facilities/services

Scored black, red, amber, green - Essington is ‘amber’ when it should be ‘green’ according to how the indicators are measured.

Paragraphs 3.7 to 3.13 of the Audit say how these key indicators will be measured and the justification. Paragraph 3.9 states “For the purposes of this measure, the presence of facilities within walking distance but past the built-up boundary of a village will also be considered, where these can be accessed via safe and legible routes with well-lit footways. Facilities and services up to 1 mile (i.e. 1610m) walk away from the development boundary of a settlement along such routes will be recorded for this purpose.” Essington is an unusual case due to its close proximity to the edge of the conurbation and the 1 mile (1610m) walk distance opens up huge opportunities not available at most other settlements further from the urban edge. The district boundary does not stop access. Enclosed plan 8694-602 Facilities Plan shows 4 isochrones at the 1 mile (1610m) walk distance centred on the Development Boundary of the settlement at 4 places:

• High Hill

• Brownshore Lane

• Upper Sneyd Road/Bursnips Road junction

• Syend Lane/Red Lane junction

The walking route from these points is on surfaced pavement with street lighting.

• High Hill, Upper Syend Lane and Kitchen Lane - there is pavement on one side and street lighting is at frequent intervals.

• Brownshore Lane - there is pavement on one side and one light at the bend in the road.

• Syend Lane – there is pavement on both sides and street lighting at frequent intervals.

Within these isochrones are a diversity of community facilities/services too numerous to show all on plan and due to the nature of the urban area there are a greater variety than available to most settlements. In the wording of the Audit ‘the greater the variety of the community facilities on offer, the more sustainable the location will be’. Plan 8694-602 Facilities Plan shows a great variety and the key lists the type and number. As an example of a few, not all as they are too numerous to list, the following key facilities are accessible:

• Coppice Farm Way/Essington Road – supermarket and 4 shop units in a substantial purpose built local centre with parking and recycling centre

• Coppice Farm – Sina Health Centre and Lloyds Pharmacy

• Coppice Performing Arts Secondary School and sixth form

• Ashmore Park - shopping centre with sub post office and specialist shops

• Ashmoor Park - Corpus Christi Church, Social Centre and Primary School

• Ashmoor Park - Griffiths Drive supermarket

• Ashmoor Park - The Ashmore PH

• New Invention The Square Lichfield Road supermarket

• Sandlands Road shopping centre with at least 12 shop units, Library and adjacent public house

Therefore, Essington has a vast range and quantity of facilities accessible within 1 mile of the development boundary on routes of sufficient quality to encourage walking and it should score ‘green’. In the 2018 Audit it was shown as ‘green’ and nothing has changed. Furthermore, there is no explanation of why the colour has changed in the 2019 Audit.

C. Access to employment locations

Scored red, amber, yellow, light green, dark green – Essington is ‘light green’

The Hanson assessment has two shortcomings in its method and in addition, the interpretation of the results in the RSFA summary sheet appears at odds with the Hanson mapping in Appendix 3.

The shortcomings of the Hanson assessment are:

Firstly, it only assesses public transport within the district boundary – in the case of Essington there are bus stops within reasonable distance of the settlement but within the administrative boundary of Wolverhampton that do not appear to have been taken account of. These provide wider access than those within the administrative boundary of South Staffordshire. It is entirely reasonable to take account of bus services that are accessible from the settlement and not necessarily within the development boundary but in walking distance. Essington is not an island and is heavily influenced by its close proximity to the urban area.

Secondly, Hanson is entirely public transport based and overlooks the opportunity that the closer a settlement is to employment opportunities, the shorter the distances to travel. The NPPF paragraph 103 says “…Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes …” It seeks to ensure developments that generate significant movements are located where the need to travel will be minimised. Therefore, where settlements are located within a short distance this at least minimizes the length of the journey whatever the mode of transport, as compared to locations at further distance where journeys will be longer. Essington is located on the edge of the major urban area and journeys to employment will be reduced by virtue of distance travelled whatever the mode.

Having regard to the interpretation of the results in the summary sheet, RSFA Appendix 3 Hanson map does not appear to correlate with the scoring in the summary sheet as there is very little green on the map yet a lot of settlements scored as green. Hanson has only four colours and the summary sheet has five with an additional green. This is arbitrary and confusing and is not robust evidence.

Essington should be scored as the highest accessibility of ‘dark green’ on the basis of locational proximity to the major urban area providing access to additional bus routes and reducing the distance to travel to employment whatever the mode.

D. Access to education facilities

Scored red, amber, green for access to three types of education – primary/first, secondary/high, sixth form/college - Essington is ‘green’ for primary as there is a school in the settlement; and ‘red’ for the other two when it should be ’amber’ according to how the indicators are measured.

This key indicator is also assessed by facilities available within 1 mile (1610m) walk distance from the Development Boundary of the settlement. Within 1m is:

• Coppice Performing Arts School – 11-18 years mixed secondary school and sixth form with academy status located at Ashmore Park

There are numerous other secondary schools, sixth forms and specialist colleges in the vicinity although beyond the 1 mile criteria.

Essington should be scored:

• ‘green’ primary;

• ‘amber’ as there is a secondary school within the 1 mile criteria;

• ‘amber’ as there is a sixth form within the 1 mile criteria;

Overall therefore, Essington scores more highly than the audit shows and four of the key indicators should be higher ranked as shown in the comparison table: B. Diversity of C. Access D. Access to D. Access accessible to education to education community employment facilities facilities facilities/services locations Secondary/High 6th form/college

Council Green Red Red Red assessment 2018 Council Amber Red Red Red assessment 2019 Stansgate Green Amber Green Green assessment 2019

The Audit explains at paragraph 4.11 that Essington has been regraded from Tier 2 to 3 on the basis the overall level of facilities more closely relates to those settlements in Tier 3, notably Featherstone. This is at odds with previous assessment in 2018 that found:

“There is a wider range of community facilities available to Essington residents compared to other previous Local Service Villages (e.g. Coven). There is also a greater level of employment access for residents of the village when compared to other previous Local Service Villages (e.g. Swindon and Wheaton Aston). Furthermore, this village has similar or better levels of access to employment than other Tier 2 villages and has a range of community facilities comparable some Tier 2 villages (e.g. Perton). As such, Essington has been classified as a Tier 2 settlement.”

The 2019 Audit states in particular, that other settlements perform better under key criteria including walking access to secondary/high schools and supermarket provision, whilst in many cases having a substantially wider range of Community facilities on offer within their settlement. If Essington is assessed in accordance with the methodology of the Audit, it has walking access to a secondary school at Ashmore Park and access to a diverse range of facilities within the one mile (1610 metres) walking distance which includes access to the edge of the conurbation. Relative to other settlements in Tier 3 it has superior public transport access. With correct assessment it is comparable to Perton and Huntington in Tier 2.

Essington should be identified Tier 2. 2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation; The audit appears to be prepared in a vacuum as it does not account for facilities accessible beyond the South Staffordshire District Council boundary. This means it is fundamentally flawed as the settlements close to the edge of the conurbation that potentially have access to additional facilities are not properly assessed and yet such access may make them relatively more sustainable than other settlements due to proximity. The whole premise of the local plan review is to make provision to meet cross boundary needs and it focuses on locating development close to the urban edge. Any development taking place in this manner will need to be in a sustainable location and yet the evidence base focuses only on facilities accessible within the district boundary. Whilst the audit is considering relative sustainability of settlements, not urban extensions, it is significant to the whole strategy of the plan to know the most accessible settlements. 3. The grouping of settlements within tiers is arbitrary;

The information recorded in the audit leads to the settlements being grouped into the five tiers. As there is no numerical scoring it is somewhat arbitrary how groups have been defined and those with similar colours are grouped together. This makes it a somewhat subjective assessment as to where the boundaries of groups should be drawn. A numerical scoring might be more objective.

In the case of Essington, as demonstrated above four of the key indicators should be higher ranked than currently shown. The colour coding leading to the groupings would put it on a par with other settlements in Tier 2, not Tier 3 and it should be restored to Tier 2.

For the Audit to be robust a numerical scoring would provide some objectivity.

For Essington, using the colour groupings, it should be higher ranked in Tier 2, not Tier 3.

Enclosure 8694-602 Facilities Plan

All comments should be made in writing preferably using this form and should be made no later than 5pm Thursday 12 December 2019

You can view the documents online at www.sstaffs.gov.uk/localplanreview

Contact:

Email the form to: [email protected]

Or send by post to: Strategic Planning Team, South Staffordshire Council, Council Offices, Wolverhampton Road, Codsall, South Staffordshire, WV8 1PX.

Data Protection

Your details will be added to our Local Plans Consultation database so that we can contact you as the review progresses. South Staffordshire Council will process your personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulations (GDPR). Our Privacy Notice can be viewed at https://www.sstaffs.gov.uk/planning/strategic- planning--data-protection.cfm N Facilities Primary School Nursery High school/Secondary school

Library

GP Medical

Dental Practice Optician

Pharmacy

Community Centre

Public house Village/club hall Leisure centre/Swimming pool

Resturants Takeaway Specialist shops Supermarket Newsagent Post office

Church Site Boundary Development Boundary Isochrne at (1610m) from x

Project: Land at Brownshore Lane Essington WV11 2AF

Client: Mr Rob Boydon ______Drawing No: Rev: 8694-602 Drawing Title: Facilities Plan ______Scale: @ 1:16000 A3 Date: 12/2019

9 The Courtyard, Timothy's Bridge Road Stratford-upon-Avon, CV37 9NP

Tel. 01789 414 097 www.stansgate.co.uk [email protected]

© S t a n s g a t e P l a n n i n g . A l l r i g h t s r e s e r v e d ; No parts of this drawing may be reused or copied. Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: C/o Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 4 Paragraph Table Question (if applicable) 3 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that all safeguarded land identified in the SAD should be released as a priority and it should be delivered at an average density of 35 dwellings per hectare?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

Safeguarded land identified in the SAD 2018 should be considered for reallocation if permission has not already been granted, before new Green Belt release. It should be reassessed based on the strategy of the plan and the site selection methodology and if suitable, should be reallocated. It should not be considered for priority release just because it is safeguarded land, it has to meet the strategy.

Having regard to density, it should be appropriate to the location rather than requiring a blanket density throughout the district. The density has to be in character with the surroundings and given smaller sites in edge of settlement locations in rural areas, 35 dwellings per hectare may be too high for some and may have an adverse impact on character such that 30 dwellings per hectare or less may be appropriate. By contrast in other locations, 40 dwellings per hectare maybe appropriate and overall the district may well average 35 dwellings per hectare.

The GL Hearn strategic growth study that the district council refer to as justification, says that the focus of the study is not to set housing density policies but to consider to what degree an increase in densities could contribute to meeting the housing supply shortfall. Site specific considerations including the site location, context and surrounding built form will be important considerations in determining appropriate densities of individual schemes (paragraph 6.15). In addition to the local context, the Councils’ evidence base on the need for different types/ sizes of homes is a consideration (paragraph 6.56).

GL Hearn conclude that applying a minimum 35 dwellings per hectare density would make a substantive contribution to addressing the unmet housing need but acknowledge that the Study is not evidence for setting policy and is the basis for more consideration (paragraph 6.58). What other consideration has the Council given to support a minimum density policy?

Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: C/o Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 5 Paragraph Table Question (if applicable) 5 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that the seven spatial housing options set out above are appropriate options to consider? Are there any alternative options we have not considered?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

A range of different approaches as set out, have suitable elements within them that can be combined into a suitable option. Housing options B, E and F should be incorporated into the preferred option G. In addition, it should be recognised that the distribution strategy should be applied to identify safeguarded land to be removed from Green Belt to meet long term needs.

Housing option A - this option is unsustainable. It relies on maximising use of land in locations furthest away from the conurbation and therefore less accessibility to jobs and higher order facilities. It is particularly unsuitable in contributing towards the unmet needs in the GBHMA due to the distance between land available and the conurbation. The strategic growth study ruled out an option for a new settlement in the countryside around Dunston beyond the Green Belt as not in the right location to meet the need. Furthermore, the reliance on large sites is unlikely to deliver the required housing in the plan period.

Housing option B - this option is highly relevant but on its own is unsustainable. It has been demonstrated to meet the housing requirement will require Green Belt release and it is right that areas of lesser Green Belt harm should be considered before areas of greater harm. To be sustainable housing should be focused in higher tier settlements and urban extensions, whilst Green Belt is a significant consideration it has to be balanced against other matters.

Housing option C - this option is less sustainable than others. Continuing with the existing core strategy strategic approach to distribution might meet the district needs but is unlikely to meet needs of the GBHMA in appropriate locations.

Housing option D - this option would accord with a wider strategic approach it may not necessarily be the best for meeting the district need. It also has heavy reliance on large sites that they not deliver the required housing in the plan period.

Housing option E - this option is especially relevant, and it should be incorporated into a final option with suitable elements from the other options. Notably Essington is in a ward which has an affordability ratio which is worse than both the West Midlands and district averages. Therefore, new housing will help the affordability position allowing local residents to stay in the area. Housing option F - this option is highly sustainable. Giving first consideration to Green Belt land which is previously developed and/or well served by public transport is not an option in itself, rather it is a necessary consideration to be applied to all options to fulfil guidance in the NPPF (paragraph 138). It is a necessary part of any option that involves Green Belt release. Furthermore, it should be acknowledged that the NPPF refers to land which has been previously developed and is well served by public transport as opposed to land that has just been previously developed.

Housing option G - this option is highly sustainable and could be enhanced by incorporating options B, E and F. Infrastructure led development is a sustainable approach as it seeks to direct development to locations where existing infrastructure is available. In respect of a new settlement, as this is to deliver beyond the plan period it is something of a distraction to the plan and a suitable strategy should not be focused around it. An area of search identified now will suit the local plan review distribution strategy and may not necessarily be the right strategy for the period beyond the plan. However, given the long lead in time to deliver a new settlement it is acknowledged early planning is necessary. In addition, the strategy should recognise the need to identify safeguarded land to be removed from Green Belt to meet long-term needs.

All comments should be made in writing preferably using this form and should be made no later than 5pm Thursday 12 December 2019

You can view the documents online at www.sstaffs.gov.uk/localplanreview

Contact:

Email the form to: [email protected]

Or send by post to: Strategic Planning Team, South Staffordshire Council, Council Offices, Wolverhampton Road, Codsall, South Staffordshire, WV8 1PX.

Data Protection

Your details will be added to our Local Plans Consultation database so that we can contact you as the review progresses. South Staffordshire Council will process your personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulations (GDPR). Our Privacy Notice can be viewed at https://www.sstaffs.gov.uk/planning/strategic- planning--data-protection.cfm Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 5 Paragraph Table Question (if applicable) 6 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that spatial housing option G Is a robust approach to meet needs in the district and to make a contribution towards the unmet needs in the GBHMA?

2.WRITTEN JUSTIFICATION FOR REPRESENTATION

No, housing option G needs some refinement to include options B, E, F and a redistribution of the percentages to increase that in the sustainable settlements.

Housing option G - this option is highly sustainable in principle, when combined with the site selection methodology to avoid areas of greater Green Belt harm. It could be enhanced by incorporating options B, E and F to ensure areas of lesser Green Belt harm are selected; affordable housing is delivered in the locations that need it most; and to ensure compliance with the NPPF in respect of sustainable Green Belt locations first.

Infrastructure led development as in option G is a sustainable approach as it seeks to direct development to locations where existing infrastructure is available and where development can provide new infastructure to meet an identified need. It recognises the sustainability of the metropolitan area and that development located close to it is sustainable and in a location close to where the need arises.

Notwithstanding this, option G places great reliance on large allocations that could have a long lead in delivery time. Therefore, to ensure delivery a combination of smaller sites easy and fast to deliver; and larger sites with longer lead in times, is needed. The percentage distribution should therefore be amended in favour of more to the sustainable settlements.

In respect of a new settlement, as this is to deliver beyond the plan period it is something of a distraction to the plan and a suitable strategy should not be focused around it. An area of search identified now will suit the local plan review distribution strategy and may not necessarily be the right strategy for the period beyond the plan. However, given the long lead in time to deliver a new settlement it is acknowledged early planning is necessary.

In addition, the strategy should recognise the need to identify safeguarded land to be removed from Green Belt to meet long-term needs. The settlement hierarchy establishes which are the more sustainable settlements using a comparative assessment based on how settlements perform against key indicators. The amount of housing distributed to Tier 1 to 4 settlements stated as 60% could be increased, particularly to higher tier settlements and should reflect not only their Tier but a number of other factors including:

• The settlement location in terms of its ability to meet local need and the cross-boundary needs arising from other parts of the HMA. Those settlements close to the metropolitan area offer the most potential to meet the cross boundary need close to where it arises. They are also well placed to provide for the local South Staffordshire need and such settlements should be the main focus for substantial development; Essington falls in this group;

• Prioritising those areas where Green Belt release results in lesser Green Belt harm; this also applies to Essington.

• Addressing local affordability issues in settlements with the greatest need; this also applies to Essington.

• Giving first consideration to previously developed Green Belt land and/or well served by public transport. This also applies to Essington which is well served by public transport.

In respect of settlement location, Essington is a Tier 3 settlement on the edge of the metropolitan area well placed to provide significant growth to meet both local needs and cross boundary needs.

It should be recategorised as Tier 2 as supported in Rural Services and Facilities Audit 2018. The 2019 Audit makes a change to how it scores on one of the key indicators and then downgrades it to Tier 3. Our representations to Question one in respect of the robustness of the evidence base demonstrate that the methodology of the Audit has not been followed and the results do not reflect the true circumstances. When it is reassessed, the key indicators score more highly, and the settlement is clearly a better fit with Tier 2. For ease of reference those representations to Question one are enclosed.

With regard to prioritising those areas where Green Belt release results in lesser harm, the Green Belt Study 2019 prepared by the district Council as part of the evidence base, shows the areas south and east of Essington as being areas of lesser Green Belt harm (‘moderate-high’) where most of the area north of the Black Country is of ‘high’ and ‘very high’ harm. This leads to the conclusion substantial development on the edge of Essington would accord with a refined option G releasing Green Belt land that results in lesser Green Belt harm. A sustainable urban extension north of the Black Country will be in areas of ‘high’ and ‘very high’ Green Belt harm such that the redistribution of the percentages to increase development in the sustainable settlements is essential.

Whilst the Plan is not yet site specific, there is land available at Essington capable of delivering around 200 houses. Land north of Brownshore Lane, Essington is promoted although is not yet assessed in the SHELAA 2018 as site submission was too late. A vision for development prepared by Stansgate Planning is enclosed with this representation titled “Residential Development Opportunity – Land at Brownshore Lane, Essington November 2018.” It was prepared prior to the District Council’s most recent evidence base that now includes Green Belt Study 2019 and Landscape Study 2019 which find in respect of the site:

• Green Belt Study 2019 – sub parcel S20H - Promotion Site 662 - ‘moderate – high’ harm;

• Landscape Study 2019 - Area SL62s1 - Site 662 - ‘low-moderate’ sensitivity.

The evidence base clearly demonstrates that Essington is a suitable location for further development.

In respect of addressing local affordability ratios, the Options for Growth and Rationale confirm a number of settlements sit within wards which have an affordability ratio which is worse than both the West Midlands and district averages, meaning that new housing may help to avoid local residents already living within the village from being priced out of the area. Option G should be modified to acknowledge that certain settlements should be considered before others for growth in order to address the affordability ratio. Essington is one such settlement which has an affordability ratio which is worse than both the West Midlands and district averages and as such should be considered before others for growth.

Finally, giving first priority to land which has been previously developed and/or well served by public transport, is part of the guidance provided in the NPPF (paragraph 138) and this is work that should take place in any event to justify site allocations. It is implicit however that previously developed sites are to be sustainable - “and well served by public transport “- and not prioritised just because they are previously developed, as not all previously developed sites will be in accessible locations meeting the second part of the criteria.

Overall option G should be refined as set out above and Essington should feature as a settlement for growth over and above that already committed.

Enclosure - Q1 response

-Residential Development Opportunity – Land at Brownshore Lane, Essington November 2018.

All comments should be made in writing preferably using this form and should be made no later than 5pm Thursday 12 December 2019

You can view the documents online at www.sstaffs.gov.uk/localplanreview

Contact:

Email the form to: [email protected]

Or send by post to: Strategic Planning Team, South Staffordshire Council, Council Offices, Wolverhampton Road, Codsall, South Staffordshire, WV8 1PX.

Data Protection

Part A: Your Details (Please Print)

Please ensure that we have an up to date email address wherever possible, or postal address, at which we can contact you.

Your Details Agent’s Details (if applicable) Title Mr Mrs

First Name Rob Rachel

Last Name Boydon Best

E-mail Address [email protected] [email protected]

Post Code CV37 9NP Telephone 01789 414097 Number

Please note:

Name: Tardis Environmental UK Ltd

Organisation: C/o Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 3 Paragraph Table Question (if applicable) 1 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that the evidence base used to inform the Spatial Housing Options is robust and proportionate? If not, what else should we consider?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

We object to two elements of the evidence base that are not considered to be robust. These are:

THE AVAILABILITY OF SITES

THE RURAL SERVICES AND FACILITIES AUDIT 2019

The Audit is not robust for the following reasons:

1. The conclusions for Essington do not reflect the evidence;

2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation;

3. The groupings of settlements within tiers is arbitrary;

1. The conclusions for Essington do not reflect the evidence

Section 3 of the Audit provides the methodology for assessing the relative sustainability of settlements and lists five ‘Key Indicators’ which are:

A. Access to food stores

B. Diversity of accessible community facilities/services

C . Access to employment locations

D . Access to education facilities

E. Public transport access to higher order services outside of the village

B. Diversity of accessible community facilities/services

Scored black, red, amber, green - Essington is ‘amber’ when it should be ‘green’ according to how the indicators are measured.

• High Hill

• Brownshore Lane

• Upper Sneyd Road/Bursnips Road junction

• Syend Lane/Red Lane junction

The walking route from these points is on surfaced pavement with street lighting.

• High Hill, Upper Syend Lane and Kitchen Lane - there is pavement on one side and street lighting is at frequent intervals.

• Brownshore Lane - there is pavement on one side and one light at the bend in the road.

• Syend Lane – there is pavement on both sides and street lighting at frequent intervals.

• Coppice Farm Way/Essington Road – supermarket and 4 shop units in a substantial purpose built local centre with parking and recycling centre

• Coppice Farm – Sina Health Centre and Lloyds Pharmacy

• Coppice Performing Arts Secondary School and sixth form

• Ashmore Park - shopping centre with sub post office and specialist shops

• Ashmoor Park - Corpus Christi Church, Social Centre and Primary School

• Ashmoor Park - Griffiths Drive supermarket

• Ashmoor Park - The Ashmore PH

• New Invention The Square Lichfield Road supermarket

• Sandlands Road shopping centre with at least 12 shop units, Library and adjacent public house

C. Access to employment locations

Scored red, amber, yellow, light green, dark green – Essington is ‘light green’

The Hanson assessment has two shortcomings in its method and in addition, the interpretation of the results in the RSFA summary sheet appears at odds with the Hanson mapping in Appendix 3.

The shortcomings of the Hanson assessment are:

D. Access to education facilities

This key indicator is also assessed by facilities available within 1 mile (1610m) walk distance from the Development Boundary of the settlement. Within 1m is:

• Coppice Performing Arts School – 11-18 years mixed secondary school and sixth form with academy status located at Ashmore Park

There are numerous other secondary schools, sixth forms and specialist colleges in the vicinity although beyond the 1 mile criteria.

Essington should be scored:

• ‘green’ primary;

• ‘amber’ as there is a secondary school within the 1 mile criteria;

• ‘amber’ as there is a sixth form within the 1 mile criteria;

Council Green Red Red Red assessment 2018 Council Amber Red Red Red assessment 2019 Stansgate Green Amber Green Green assessment 2019

For the Audit to be robust a numerical scoring would provide some objectivity.

For Essington, using the colour groupings, it should be higher ranked in Tier 2, not Tier 3.

Enclosure 8694-602 Facilities Plan

All comments should be made in writing preferably using this form and should be made no later than 5pm Thursday 12 December 2019

You can view the documents online at www.sstaffs.gov.uk/localplanreview

Contact:

Email the form to: [email protected]

Or send by post to: Strategic Planning Team, South Staffordshire Council, Council Offices, Wolverhampton Road, Codsall, South Staffordshire, WV8 1PX.

Data Protection

Library

GP Medical

Dental Practice Optician

Pharmacy

Community Centre

Public house Village/club hall Leisure centre/Swimming pool

Resturants Takeaway Specialist shops Supermarket Newsagent Post office

Church Site Boundary Development Boundary Isochrne at (1610m) from x

Project: Land at Brownshore Lane Essington WV11 2AF

Client: Mr Rob Boydon ______Drawing No: Rev: 8694-602 Drawing Title: Facilities Plan ______Scale: @ 1:16000 A3 Date: 12/2019

9 The Courtyard, Timothy's Bridge Road Stratford-upon-Avon, CV37 9NP

Tel. 01789 414 097 www.stansgate.co.uk [email protected]

Land at Brownshore Lane Essington WV11 2AF

Residential Development Opportunity

Prepared by Stansgate Planning

November 2018

Introduction

Stansgate Planning are instructed by Tardis Environmental to promote land Figure 1 – Site Location Plan at Brownshore Lane, Essington for residential development in the South Staffordshire Local Plan. The site of 8 ha is shown in Figure 1 – Site Location Plan.

Tardis Environmental are a local company with their Headquarters a few miles from Essington on West Coppice Road, Brownhills. They were established as a small family company 26 years ago and have grown over that time to have nine depots and 130 employees, some from the local area. Their business began with the hire of portable toilets to construction sites where such items are commonly called a Tardis, which is where the name was adopted from. The business has since diversified to specialise in a host of environmental services.

This document sets out details in respect of their land at Brownshore Lane and looks at the Planning context; the settlement facilities; a site assessment of constraints and opportunities; and finally a Development concept.

Stansgate Planning ADM/RJB/K/8694 1

The Site

The site is located on the eastern settlement edge of Essington, north east Photo 1 -The site from Brownshore Lane of Wolverhampton. It comprises a large field of 8 ha, roughly triangular in shape, which is entirely contained by mature vegetation structure which affords a strong degree of containment to the site. The existing settlement edge of Essington is located to the west, with the rear and side curtilages of existing residential development located off Larchmere Drive and Rosewood Gardens forming the site boundary at this point. Bursnips Road (A462) and Brownshore Lane form the eastern and south western site boundaries respectively, with a reclamation yard and its associated sporadic built structures located immediately south.

Brownshore Lane is approximately 5.5m wide with street lighting and is subject to a 30mph speed limit way. Traffic calming control measures with road humps are noted along its length and a footway is located along the west side of Brownshore Lane adjacent to the site. Bursnips Road (A462) is approximately 6.5m wide and is subject to a 30mph speed limit. A footway is located on the eastern side.

There is a network of public rights of way running to the north, east and south of the site, none of which connect to each other. Those to the north and east provide access to wider areas of open space and countryside, whilst that to the south provides access from Brownshore Lane to the built- up area of the conurbation at the junction of Upper Sneyd Road/Bursnips Road/Essington Road. These are shown on Figure 4 Development Concept.

Stansgate Planning ADM/RJB/K/8694 2

Planning Context no further Green Belt release was considered in the SAD. No new sites were assessed. The development plan comprises: Site Allocations (SAD) 2018 applies the policies of the Core Strategy at a • South Staffordshire Core Strategy 2012 local level. The SAD acknowledges an early review of the Core Strategy is • South Staffordshire Site Allocations DPD (SAD) September 2018 needed to allow a full Green Belt review. This will take place with Black Country authorities to inform further Green Belt release to accommodate The Core Strategy shows the site to adjoin the inset boundary of Essington. new development to meet additional housing needs and cross boundary It lies within the Green Belt. Core Policy 1 says growth will be located at development. the most sustainable locations in accordance with the settlement Local Plan Issues and Options October 2018 is the first stage of a review. hierarchy. The principal aim of the Strategy is to meet local needs whilst The settlement hierarchy is re-assessed and Essington is recognised as one recognising the constraints that impact upon the District, and support the of the more sustainable locations identified as a Tier 2 settlement. The retention of existing facilities and services in villages in a sustainable way Issues and Options seeks views on a strategy for distribution of growth and and where possible improve them. The hierarchy consists of four levels of an option for rural housing growth focused on the district’s larger and settlement with Essington falling within the second level as a Local Service better connected villages (Tiers 1 and 2) would allow for a sustainable Village. Main Service Villages will take 90% of the growth and Local Service pattern of development including growth at Essington. Villages will take 10%. In addition to the district’s growth directed to Local Service Villages, Core Policy 1 would allow limited development where it meets local needs, whilst recognizing the constraints that impact upon the district.

This Spatial Strategy has identified broad locations to accommodate housing growth up to 2028. The Settlement Hierarchy has provided a clear direction for the subsequent Site Allocations DPD.

Policy GB:2 Land safeguarded to meet longer term needs – shows 3 areas of land at Essington safeguarded from the 1996 South Staffordshire Local Plan, all of which are now developed or have planning permission. Additional safeguarded land for 2028 to 2038 is identified in the SAD at Main and Local Service Villages but as Essington already had available land

Stansgate Planning ADM/RJB/K/8694 3

The Settlement – Local Facilities The proximity of the site to these key facilities is shown on Figure 2 Facilities Plan. Most facilities are within the 1km walking distance from the Essington is well placed geographically to accommodate growth to meet site with all routes utilising the existing footway network. It is considered local and cross boundary needs as it is located close to the edge of the that the majority of key facilities and amenities the residents will require conurbation with close functional and physical links to Wolverhampton are accessible from the site. and Walsall. Figure 2 – Facilities Plan The settlement has a modest range of facilities that currently include:

• convenience store and 4 other Shops • an industrial estate • primary school • a community centre • Hall • GP surgery • church • 2 pubs • clubs • takeaway • restaurant • sports grounds • pharmacy

There are employment opportunities in running these facilities along with those at the industrial estate, a motor salvage yard and there is good access to the adjoining conurbation that offers higher order services and a greater variety of jobs.

Stansgate Planning ADM/RJB/K/8694 4

Site Assessment The impact of the proposed development on the highway network will be assessed in due course as part of a detailed Transport Assessment. Analysis The total site is 8 ha. The site assessment results in Figure 4 Development of distribution of traffic from the site, using Census 2011 data’ Location of Concept Plan that aims to retain an open space around the southern and usual residence and place of work by method of travel to work’ shows that eastern edges of the site. A development area of 5ha to accommodate 200 most people from the area travel to work south of the side towards dwellings is identified. Wolverhampton. Therefore, it is expected that approximately 80% of the Access and movement – The principal site access to serve 200 dwellings residents will turn left out of the access towards the junction of High Hill will be taken from Brownshore Lane. The lane is 5.5m wide and has a speed and Brownshore Lane. A proportion of these will head straight towards limit of 30mph. A 5.5m wide access will be required to serve the proposed Kitchen Lane. The remaining 20% will be travelling north towards development which accords to a Major Residential Access Road in the Featherstone and Cannock. Junctions to be assessed are: Staffordshire County Council residential design guide. • Brownshore Lane/High Hill/Upper Sneyd Road/Kitchen Lane The access road will have 2 x 2m wide footways and the existing footway crossroads network on Brownshore Lane will be improved to cater for the proposed • Upper Sneyd Road/Bursnips Road/Sneyd Lane traffic light junction development. • Bognor Road/B4156 mini roundabout • B4156/Bursnips Road mini roundabout Visibility splays of 2.4 x 43m (based on Table 7.1 of Manual for Streets) can be provided which is commensurate to the subject speed limit of the road. It is considered a T-junction will be sufficient to serve the proposed development. However, should the Highway Authority require a right turn lane to be provided then this can also be facilitated on Brownshore Lane

The provision of an emergency access could be delivered from multiple locations. This could also provide pedestrian and cycle connectivity from the site and it is envisaged the access will be a minimum of 3.5m wide. This provision can be provided from Brownshore Lane either side of the proposed access or from the A462 Bursnips Road (via the existing gated access to the north of the site is likely to avoid impacts on the existing vegetation).

Stansgate Planning ADM/RJB/K/8694 5

There is a network of public rights of way in the area that provide access to Public Transport Accessibility − The nearest bus services to the site are the wider countryside and to the conurbation. Development on the site 71 and 868 which run during schooldays and connect the site to Cannock provides the opportunity to connect these routes together and provide a and Wolverhampton, which according to Census data are two of the major new route through the site offering enhanced access to the countryside for work destinations. The bus routes are shown on Figure 3 – Bus Route Map. new and existing residents. These are shown in Figure 4 – Development Concept Plan later on in the document. Figure 3 – Bus Route Map

Photo 2 – Public Right of Way from Brownshore Lane

Stansgate Planning ADM/RJB/K/8694 6

Flood Risk and Drainage - The site is Flood Zone 1 and is therefore at low Landscape - South Staffordshire District Council has undertaken a risk of flooding from rivers. The Environment Agency’s website also Landscape Sensitivity Study Update 2017. The study assesses a number of indicates no risk of flooding from surface water run-off. parcels around the settlement edge of Essington, with the site being identified as parcel ES2, which is assessed as being of High landscape

sensitivity. Parcel ES2 is described as being a ‘Large featureless area of land Green Belt – Essington was not covered in the South Staffordshire Council located on the south-eastern edge of the main body of the settlement. Partial Green Belt Review which was undertaken by LUC in November Bordered on its eastern edge by Bursnips Road. The parcel is generally well- 2016. Our assessment finds that the site is influenced by its close proximity screened from surrounding roads by hedgerows.’ to the village edge of Essington reducing the sensitivity of the site and its contribution to the purposes of the Green Belt. Aspect Landscape Consultants has provided a more localised landscape character assessment. They find that whilst the site itself has been The site has strong and defensible site boundaries which contain the site identified as being of high landscape sensitivity, it is located directly from wider countryside and limit inter-visibility from the site to the wider adjacent to the existing settlement edge with which it shares a degree of countryside. It has strong boundary features which aid its ability to inter-visibility and is entirely contained by existing development and road successfully accommodate residential development without harm to the corridors. Whilst the elevated topography within the site itself does purposes of the Green Belt. contribute to its sensitivity, the mature vegetation structure along the site boundaries largely restricts views towards the site to the immediate The proposed development would need to be removed from the Green landscape setting, with only filtered long distance views available from Belt although the proposed green infrastructure around the development within the site during winter months. can remain in the Green Belt. In terms of the susceptibility of the landscape resource to accommodate

change of the type proposed, they consider that the presence of the Heritage –The County Council’s ‘Historic Character Assessment: South existing settlement edge immediately to the west reduces the Staffordshire January 2011’ does not identify any designated or non- susceptibility of the site to change resulting from residential development. designated heritage or archaeological interest in the vicinity. The site itself The established vegetation structure along the site boundaries and is identified as ‘Post 1880’s Small Replanned Enclosure’ which is the same localised landscape create a robust external edge to the site and form a status as other land to the north east of Essington that now has planning defensible boundary between the settlement fringe and the wider rural permission for residential development. setting. It is therefore considered that the landscape character of the site has capacity to accommodate sensitively designed residential development. Stansgate Planning ADM/RJB/K/8694 7

In terms of value, the landscape in which the site is immediately set is not Trees – trees are restricted to the site boundaries and beyond so can be subject to any landscape designation and is not publicly accessible. It is retained where possible in a development scheme. Vegetation on the however noted that the Green Belt extends to cover the site and wider Brownshore Lane frontage will need to be partly removed to achieve landscape setting. There are no known historic or literary associations with visibility as currently there is vegetation within the highway verge. Any lost the site. The site is influenced by the presence of existing development to can be replanted behind the new visibility splay. the south and west, alongside the localised road corridors, which detract

from the tranquillity of the localised landscape. The site does not include any landscape features of note and it is considered that the site and its Photo 3 – Site from Brownshore Lane looking towards Bursnips Road immediate countryside setting represent an ordinary landscape.

When both value and susceptibility of the landscape resource are considered together, Aspect find that the site would typically be of medium landscape sensitivity.

Aspect therefore consider that the site and receiving environment have the capacity to accommodate sensitively designed development that will respond to the localised context and will not result in significant harm to the landscape character, visual environment or ‘openness’ of the Green Belt and is supportable from a landscape and visual perspective.

They recommend a robust landscape strategy with a defensible green edge to the south and eastern site boundaries, preventing encroachment into the wider rural setting and unrestricted sprawl.

Physical and Environmental Constraints – The District Councils Assessment in 2009 finds the agricultural land quality to be grade 3 and that Essington is free from constraints.

Stansgate Planning ADM/RJB/K/8694 8

The Development Concept Figure 4 – Development Concept

The Development Concept is informed by the site assessment and includes the following principles:

• Provision of 5 ha of residential development land which can accommodate 200 houses; • Provision of 3 ha of Green Infrastructure to offset the loss of Green Belt land; • a defensible green edge to the south and eastern site boundaries that will remain in Green Belt; • site access from Brownshore Lane; • a new footpath network through Green Infrastructure to link with existing public rights of way to provide new and enhanced access to wider open space and open countryside. • A central area free of development to respect the local topography.

Stansgate Planning ADM/RJB/K/8694 9

Conclusion

Overall, Essington is a sustainable settlement with a good level of facilities that place it in Tier 2 of the settlement hierarchy. In addition, its geographical location and functional links to the conurbation means it is well placed to take cross boundary growth to meet the needs of Birmingham and the Black Country.

The site itself lies adjacent to existing development and is well contained by existing vegetation. It does not include any landscape features and would typically be of medium landscape sensitivity. The site and receiving environment have the capacity to accommodate sensitively designed development.

The site can provide 200 houses on 5ha and 3ha of Green Infrastructure offering the opportunity for compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.

Prepared by Stansgate Planning 9 The Courtyard, Timothy’s Bridge Road Stratford-upon-Avon CV37 9NP Tel. 01789 414 097 [email protected] www.stansgate.co.uk

Stansgate Planning ADM/RJB/K/8694 10

Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 5 Paragraph Table Question (if applicable) 8 Other document eg SA, HRA

2. Please set out your comments below

Have we identified the key criteria for the identification of sites (as set out in appendix 6)? Are there any other factors we should consider?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

There may be other factors to consider depending on which housing option is selected or how option G might be modified as a result of this consultation. It is disappointing that the Site Selection Methodology for Preferred Options (Appendix 6) takes its starting point as only considering sites that a) were submitted to SHELAA 2018; and b) are in a potential location for growth under the infrastructure led strategy option G. This rather prejudges the outcome of the Spatial Housing Strategy and Infrastructure Delivery consultation that we are responding to the comments we have made on both of those issues.

Notwithstanding this, the following should be added to the methodology:

• Section 4 Green Belt Harm, should explicitly state sites that would result in lesser Green Belt harm should be considered for allocation; 'Lesser harm’ is the way it is expressed in the NPPF rather than avoiding allocating housing sites that would result in very high Green Belt harm.

• Whether a site can provide a new Green Belt boundary clearly defined using physical features that are readily recognisable and likely to be permanent (NPPF paragraph 139f);

• Give first consideration to land which has been previously developed and/or is well served by public transport.

Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter 5 Paragraph Table Question (if applicable) 10 Other document eg SA, HRA

2. Please set out your comments below

Do you agree that when selecting sites to deliver the preferred spatial housing strategy, the council should seek to avoid allocating housing sites that would result in ‘very high’ Green Belt harm where possible?

2. WRITTEN JUSTIFICATION FOR REPRESENTATION

The Site Selection Methodology for Preferred Options (Appendix 6) should explicitly state in Section 4 Green Belt Harm, sites that would result in lesser Green Belt harm should be considered for allocation as this is the way it is expressed in the NPPF. That is different to avoiding areas of very high harm which implies that areas assessed as high harm are acceptable when in fact there may be areas of lesser harm available. For example, North of the Black Country there is land around Essington assessed as moderate– high harm, compared to other areas close by assessed as high harm which need not be used when areas of laser harm (moderate-high) harm are available.

Part B: Please complete a new Part B for each representation you wish to make.

Name: Tardis Environmental UK Ltd

Organisation: Stansgate Planning

1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to?

Chapter Paragraph Table Question (if applicable) Other document eg SA, HRA Document Rural Services and Facilities Audit 2019

2. Please set out your comments below

THE RURAL SERVICES AND FACILITIES AUDIT 2019

The Audit is not robust for the following reasons:

1. The conclusions for Essington do not reflect the evidence;

2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation;

3. The groupings of settlements within tiers is arbitrary;

1. The conclusions for Essington do not reflect the evidence

Section 3 of the Audit provides the methodology for assessing the relative sustainability of settlements and lists five ‘Key Indicators’ which are:

A. Access to food stores

B. Diversity of accessible community facilities/services

C. Access to employment locations

D. Access to education facilities

E. Public transport access to higher order services outside of the village

Scored black, red, amber, green - Essington is ‘amber’ when it should be ‘green’ according to how the indicators are measured.

Essington is an unusual case due to its close proximity to the edge of the conurbation and the 1 mile (1610m) walk distance opens up huge opportunities not available at most other settlements further from the urban edge. The district boundary does not stop access. Enclosed plan 8694-602 Facilities Plan shows 4 isochrones at the 1 mile (1610m) walk distance centred on the Development Boundary of the settlement at 4 places:

• High Hill

• Brownshore Lane

• Upper Sneyd Road/Bursnips Road junction

• Syend Lane/Red Lane junction

The walking route from these points is on surfaced pavement with street lighting.

• High Hill, Upper Syend Lane and Kitchen Lane - there is pavement on one side and street lighting is at frequent intervals.

• Brownshore Lane - there is pavement on one side and one light at the bend in the road.

• Syend Lane – there is pavement on both sides and street lighting at frequent intervals.

• Coppice Farm Way/Essington Road – supermarket and 4 shop units in a substantial purpose built local centre with parking and recycling centre

• Coppice Farm – Sina Health Centre and Lloyds Pharmacy

• Coppice Performing Arts Secondary School and sixth form

• Ashmore Park - shopping centre with sub post office and specialist shops

• Ashmoor Park - Corpus Christi Church, Social Centre and Primary School

• Ashmoor Park - Griffiths Drive supermarket

• Ashmoor Park - The Ashmore PH

• New Invention The Square Lichfield Road supermarket

• Sandlands Road shopping centre with at least 12 shop units, Library and adjacent public house

Scored red, amber, yellow, light green, dark green – Essington is ‘light green’

The Hanson assessment has two shortcomings in its method and in addition, the interpretation of the results in the RSFA summary sheet appears at odds with the Hanson mapping in Appendix 3.

The shortcomings of the Hanson assessment are:

These provide wider access than those within the administrative boundary of South Staffordshire. It is entirely reasonable to take account of bus services that are accessible from the settlement and not necessarily within the development boundary but in walking distance. Essington is not an island and is heavily influenced by its close proximity to the urban area.

D. Access to education facilities

This key indicator is also assessed by facilities available within 1 mile (1610m) walk distance from the Development Boundary of the settlement. Within 1m is:

• Coppice Performing Arts School – 11-18 years mixed secondary school and sixth form with academy status located at Ashmore Park

There are numerous other secondary schools, sixth forms and specialist colleges in the vicinity although beyond the 1 mile criteria.

Essington should be scored:

• ‘green’ primary;

• ‘amber’ as there is a secondary school within the 1 mile criteria;

• ‘amber’ as there is a sixth form within the 1 mile criteria;

Council Green Red Red Red assessment 2018 Council Amber Red Red Red assessment 2019 Stansgate Green Amber Green Green assessment 2019

Essington should be identified Tier 2.

2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation; The audit appears to be prepared in a vacuum as it does not account for facilities accessible beyond the South Staffordshire District Council boundary. This means it is fundamentally flawed as the settlements close to the edge of the conurbation that potentially have access to additional facilities are not properly assessed and yet such access may make them relatively more sustainable than other settlements due to proximity. The whole premise of the local plan review is to make provision to meet cross boundary needs and it focuses on locating development close to the urban edge. Any development taking place in this manner will need to be in a sustainable location and yet the evidence base focuses only on facilities accessible within the district boundary. Whilst the audit is considering relative sustainability of settlements, not urban extensions, it is significant to the whole strategy of the plan to know the most accessible settlements.

3 . The grouping of settlements within tiers is arbitrary;

For the Audit to be robust a numerical scoring would provide some objectivity.

For Essington, using the colour groupings, it should be higher ranked in Tier 2, not Tier 3.

Enclosure 8694-602 Facilities Plan

All comments should be made in writing preferably using this form and should be made no later than 5pm Thursday 12 December 2019

You can view the documents online at www.sstaffs.gov.uk/localplanreview

Contact:

Email the form to: [email protected]

Or send by post to: Strategic Planning Team, South Staffordshire Council, Council Offices, Wolverhampton Road, Codsall, South Staffordshire, WV8 1PX.

Data Protection

Library

GP Medical

Dental Practice Optician

Pharmacy

Community Centre

Public house Village/club hall Leisure centre/Swimming pool

Resturants Takeaway Specialist shops Supermarket Newsagent Post office

Church Site Boundary Development Boundary Isochrne at (1610m) from x

Project: Land at Brownshore Lane Essington WV11 2AF

Client: Mr Rob Boydon ______Drawing No: Rev: 8694-602 Drawing Title: Facilities Plan ______Scale: @ 1:16000 A3 Date: 12/2019

9 The Courtyard, Timothy's Bridge Road Stratford-upon-Avon, CV37 9NP

Tel. 01789 414 097 www.stansgate.co.uk [email protected]