Representations to the South Staffordshire Site Allocations Publication Plan
On behalf of Severn Trent Water Limited
Land at the Bratch Bratch Lane Wombourne Staffordshire
February 2017
Prepared by
GL Hearn Limited Vantage Point Hardman Street Spinningfields Manchester M3 3HF
T +44 (0)161 829 7800 glhearn.com
Representations to the South Staffordshire Site Allocations Publication Plan, February 2017 Severn Trent Water Limited, Land at the Bratch, Bratch Lane,Wombourne, Staffordshire
Contents
Section Page
1 INTRODUCTION 4
2 THE SITE AND ITS SURROUNDINGS 6
3 THE PLANNING FRAMEWORK 9
4 DETAILED REPRESENTATIONS 13
5 SUMMARY CONCLUSION 16
Appendices
APPENDIX A: SITE LOCATION PLAN 17
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Quality Standards Control
The signatories below verify that this document has been prepared in accordance with our quality control requirements. These procedures do not affect the content and views expressed by the originator.
This document must only be treated as a draft unless it is has been signed by the Originators and approved by a Business or Associate Director.
DATE ORIGINATORS APPROVED February 2017 Chris Sinton Emma Jones
This document has been prepared for the stated objective and should not be used for any other purpose without the prior written authority of GL Hearn; we accept no responsibility or liability for the consequences of this document being used for a purpose other than for which it was commissioned.
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1 INTRODUCTION
1.1 These representations have been prepared by GL Hearn on behalf of Severn Trent Water Limited (‘STW’) in response to South Staffordshire District Council (SSDC) consultation on the Site Allocations Document (SAD) Publication Plan dated January 2017. These representations relate specifically to STW’s landholding at The Bratch, Wombourne (‘the site’) as shown edged red on the attached Site Location Plan at Appendix A .
Severn Trent Water
1.2 STW is a regulated utility company with statutory responsibilities for the provision of water and sewerage services across the English Midlands and Central Wales. As a result of changing processes in relation to clean water provision and wastewater treatment, significant areas of land are no longer required by the business for operational purposes and as such are surplus to requirements. STW is currently undertaking a programme of rationalising its land holdings and is seeking to dispose of redundant operational assets for alternative uses through a process of Irrevocable Sign Off (ISO). Proceeds from the asset disposal are reinvested back into the core business to improve services for its customers.
National Housing Crisis
1.3 The UK is facing an unprecedented housing crisis as a result of successive Governments failing to build the homes people need 1. This failure has not only prevented people from accessing the housing market it has also damaged economic growth as it has reduced the mobility of the labour market and undermined the ability of areas to attract inward investment.
1.4 With a growing population and chronic undersupply of housing it is clear that issues of overcrowding, affordability and reduced social mobility are becoming more prevalent, particularly in rural areas where housing delivery has to be carefully balanced against the protection of the countryside. 2
Purpose of the Representations
1.5 The purpose of this representation is to demonstrate that the site is deliverable in that it is available now, is in a suitable location for development now, and is achievable with a realistic prospect that housing will be delivered on the site within five years. It also establishes that sensitive residential re- development of the site would accord with the principles of sustainable development set out in the National Planning Policy Framework (NPPF).
1 Lyons Housing Review: Mobilising across the nation to build the homes our children need (October 2014) 2 Towards a one nation economy: A 10-point plan for boosting productivity in rural areas, DEFRA, page 19 (August 2015)
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1.6 This representation seeks the allocation of the site for a residential led mixed use development under policy SAD2 ‘The Preferred Options Housing Allocations’ of the SAD and supports the removal of policy SAD9 ‘The Bratch, Wombourne Policy Area’.
Structure of the Representations
1.7 These representations have been structured to respond to matters of specific relevance to the promotion of the site, as follows:
• The Site and its Surroundings; • The Planning Framework; • Detailed Representations to Policy SAD2; and • Summary and Conclusions
Collaborative Working
1.8 STW are keen to work collaboratively with SSDC to deliver a ‘sound’ SAD which meets the identified housing needs in the District whilst protecting the open countryside from unnecessary development. We would welcome a meeting with Council officers to discuss potential development opportunities at the site and would seek to allay any concerns regarding site access or any other technical matters.
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2 THE SITE AND ITS SURROUNDINGS
2.1 This section provides a contextual background to the site and its surroundings; sets out relevant planning and promotional history, and demonstrates its sustainability in terms of its proximity to amenities, services and facilities in Wombourne.
The Site
2.2 The site, which extends to approximately 9 hectares, is situated within the settlement boundary of Wombourne, a main village as defined in the South Staffordshire Core Strategy, in the administrative boundary of SSDC. It comprises a non-operational grade II* listed pumping station and a nitrate treatment plant which remains operations and does not form part of the proposals. The remainder of the site is no longer required by STW for operational purposes and is available for development immediately.
2.3 Existing vehicular access to the site is gained from Bratch Lane to the north. A public right of way (PROW) runs along western boundary of the site adjacent to the Staffordshire and Worcestershire Canal and continues across the southern boundary.
2.4 The western parcel of the site adjacent to the canal and including the existing buildings is located within flood zone 2 (medium probability) with the remainder of the site situated in flood zone 1 (low probability). There are no statutory or non-statutory nature conservation designations present on site. The north-west corner of the site is located within the Canal Conservation Area. Whilst it is acknowledged that there are a number of constraints present on site, it is considered that none are insurmountable and would preclude development at the site.
Site Surroundings
2.5 The site is located in a predominantly residential area and is bound by Bratch Lane and beyond that by residential properties to the north; the Staffordshire and Worcestershire canal (River Stour) to the west; South Staffordshire Railway walk to the east, and residential development to the south.
2.6 The South Staffordshire Railway Walk Local Nature Reserve (LNR) is located immediately to the east of the site. In terms of heritage assets there are two grade II listed buildings associated with the canal located to the south of the site.
A Sustainable Location
2.7 The site is located in a sustainable location within the Wombourne settlement boundary. It is situated in close proximity to a range of amenities, services and facilities including:
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• Wombourne Leisure Centre; • Ounsdale High School; • Westfield Community Primary School; • St Benedict Biscop C of E Primary School; • Wombourne Library; • Medical Practices; and • Wombourne village centre containing shops, pubs and restaurant.
2.8 The village is served by public transport with a number of bus services operating between Wolverhampton and Dudley.
Planning History
2.9 The planning history of relevance to this representation is set out in table 1 below:
Table 1 - Schedule of relevant planning history
Application Ref. Description Date Status Erection of nitrate treatment building, 06/00920/FUL 16/02/2007 Approved gate posts and gates Erection of nitrate building, gate and 06/01172/LBC 16/02/2007 Approved gateposts Installation of wheelchair lift to improve 07/00185/LBC 27/07/2007 Approved access for the disabled
Promotional History
2.10 STW has previously submitted representations to the SAD ‘Issues and Options’ consultation in May 2014 promoting land at The Bratch, Wombourne (site ref. 280) for residential / mixed use development incorporating ‘meaningful’ open space. However, the proposals at the site were not taken forward as part of the SAD ‘Preferred Option’. The reason for this, as detailed in the Site Assessment and Discounted Sites Paper published by the Council in December 2015, was as follows:
“Site representative has not provided details of suitable access. Proposed that the Bratch Policy Area is retained, with the option of the landowner working with the Council to bring forward through the Development Management process, ensuring that any development is undertaken sensitively, having regard to the proximity of the Grade II* listed building.”
2.11 STW also submitted representation to the Preferred Options consultation in February 2016 which sought the allocation of the site for residential development and removal of policy SAD9 ‘The Bratch, Wombourne Policy Area’. It was considered unnecessary as site specific assessments of heritage, ecology, access and landscape impacts would be provided at the detailed design stage.
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2.12 STW welcomes the opportunity to work collaboratively with the Council to deliver a sensitively designed, high quality residential development at the site which could contribute to meeting the Core Strategy housing requirement for Wombourne.
2.13 However, although the site is now proposed as ‘white land’ within the settlement of Wombourne, an allocation under policy SAD2 as the proposals would give greater certainty to the prospect of development as there is a requirement for significant local investment.
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3 THE PLANNING FRAMEWORK
3.1 This section sets out the national and local planning framework of specific relevance to the site.
National Planning Policy Context
National Planning Policy Framework
3.2 At the heart of the National Planning Policy Framework (NPPF) is a presumption in favour of sustainable development. For plan-making this means :
• Local Planning Authorities (LPAs) should seek opportunities to meet development needs of their area; and
• Local Plans should meet objectively assessed needs, with sufficiently flexibility to adapt to rapid change, unless:
• any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
• specific policies in this Framework indicate that development should be restricted. 3
3.3 Paragraph 7 of the NPPF identifies that there are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles including:
• Economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;
• Social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and
• Environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy. 4
3 National Planning Policy Framework, CLG, page 4, paragraph 14 (March 2012) 4 National Planning Policy Framework, CLG, page 2, paragraph 7 (March 2012)
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3.4 The proposed allocation of the site for residential led mixed use development would perform a positive economic, social and environmental role in accordance with the three pillars of sustainable development. This is explored in greater detail at paragraph 4.9 of this representation.
Delivering a wide choice of high quality homes
3.5 A key objective of the NPPF is to boost significantly the supply of housing 5. In order to achieve this LPAs should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land. To be considered deliverable sites should be “ available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable .” 6
3.6 In order to deliver a wide choice of homes, LPAs should plan for a mix of housing based on current and future demographic/ market trends, identifying the size, type, tenure and range of housing that is required in the local area, reflecting local need. 7
3.7 The most up-to-date assessment of local need is set out in the South Staffordshire SHMA 2012. This identifies that Wombourne is a desirable location to live within the District and that there is an acute need for a range of housing including family and elderly accommodation.
Local Planning Policy Context
3.8 The current Development Plan for South Staffordshire consists of the:
• Core Strategy (adopted December 2012); and • ‘Saved’ policies of the South Staffordshire Local Pan (adopted 1996)
South Staffordshire Core Strategy
3.9 The Core Strategy is the first part of the new Local Plan for South Staffordshire. Once adopted, the SAD will complete the Local Plan. It contains broad policies for steering and shaping development as well as defining areas where development should be directed to.
Core Policy 1: The Spatial Strategy for South Staffordshire
3.10 Core Policy 1 identifies Wombourne as a Main Service Village which are the preferred focus for housing growth, employment development and service provision in the District. The spatial strategy
5 National Planning Policy Framework, CLG, page 12, paragraph 47 (March 2012) 6 National Planning Policy Framework, CLG, page 12, footnote 11 (March 2012) 7 National Planning Policy Framework, CLG, page 13, paragraph 50 (March 2012)
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seeks to direct growth to the most accessible and sustainable locations in accordance with the settlement hierarchy. Paragraph 6.6 of the justification text highlights that Main Service Villages are the most sustainable locations in terms of the level of essential community facilities and services available, access to public transport and supporting infrastructure. By locating growth to the main service villages the Council seeks to create better balanced settlements, reduce the need to travel and utilise and consolidate existing physical, social and community and green infrastructure.
3.11 In addition to establishing the settlement hierarchy Core Policy 1 also provides guidance in respect of the Green Belt and Open Countryside. It states that “the general extent of the Green Belt and the area defined as Open Countryside will be protected and maintained for the Plan period but some land will need to be released from the Green Belt and Open Countryside in some locations at the Main and Local Service Villages to deliver the proposed development strategy and enable the sustainable growth of these villages. A partial review of Green Belt boundaries and a review of Major Developed Sites in the Green Belt will be carried out through the Site Allocations DPD.”
3.12 STW interpretation of this policy is that a partial review of the Green Belt will be required where the housing requirement cannot be met on suitably located sites within the settlement boundary. As such this implies that there is a sequential preference for sites in the development boundary over sites located in the Green Belt.
Core Policy 6: Housing Delivery
3.13 The housing target for South Staffordshire over the Plan period of 2006 to 2028 is 3,850 new homes which equates to 175 dwellings per annum. As of 1st April 2010, 2,244 new homes have been completed or are committed and the balance of new housing development (1,606 homes rounded to 1,610) are to be distributed between the existing villages of South Staffordshire, in accordance with the principles of the settlement hierarchy defined in Core Policy 1. The minimum apportionment proposed for Wombourne is 256 net dwellings across the Plan period.
Other Core Strategy Policies of Relevance
3.14 Other Core Strategy policies which are of relevance to the site include:
• Policy EV3 ‘Canal and Canalside Development’ • Core Policy 14 ‘Open Space, Sport and Recreation’ • Policy HWB1 ‘Protection of Open Space, Sport and Recreation Facilities’ • EQ3 ‘Conservation, Preservation and Protection of Heritage Assets’
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‘Saved’ South Staffordshire Local Plan
3.15 The ‘Saved’ Local Plan was adopted in December 1996. Following the adoption of the Core Strategy only 3 policies remain ‘saved’ as part of the Development Plan. Of specific relevance to the site is the following ‘saved’ policy R8 ‘Bratch Policy Area – Land East of Canal’.
‘Saved’ Local Plan Policy R8 ‘Bratch Policy Area – Land East of Canal’
3.16 The site is allocated under policy R8 ‘Bratch Policy Area – Land east of Canal’ within the ‘saved’ Local Plan which states:
“Planning permission will be granted for the recreational use of the land to the east of the canal identified on inset Plan 51, provided the recreational uses would not generate significant traffic movements or require large scale building development.”
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4 DETAILED REPRESENTATIONS
4.1 This section presents detailed representations on the relevant SAD Publication Plan policy SAD2 ‘The Preferred Option Housing Allocations’ and the deleted Preferred Options Policy SAD9 ‘The Bratch, Wombourne Policy Area’.
SAD2: The Housing Allocations
4.2 As set out in section 7 ‘Housing Sites and Safeguarded Land for Longer Term Need’ the Council has identified a residual housing requirement of 177 dwellings in Wombourne across the remainder of the Plan period set against the target of 256 set out in Core Strategy Policy 6.
4.3 Policy SAD2 details the proposed allocations across the 5 localities in the District required to meet the residual housing need. Three sites are allocated in Wombourne for the delivery of housing as shown in table 2 below:
Table 2 – The Housing Allocations
Minimum Site Ref Proforma Page Village Site Location Dwelling No. No. Delivery Wombourne (a) 281a Land off Ounsdale Road (south) 19 120 Land North of Beggars Bush Wombourne (b) 302 80 122 Lane Wombourne (c) 283 Land North of Bridgnorth Road 80 124 Total
4.4 In order to identify the most suitable development sites for allocation the Council undertook a site assessment against the following criteria:
• Green Belt Sequential Test; • Green Belt Review Categorisation; • Countryside/ Landscape Quality; • Accessibility to amenities (including employment); • Surface Water Flooding; • Highways (accessibility to the site); • Impact on current land use; • Impact on Environmental Quality; and • Historic Environment/ Heritage Assets.
4.5 Following this assessment the Council has proposed the allocation of 3 no. sites within Wombourne, of which Land North of Beggars Bush Lane (ref. 302) and Land North of Bridgenorth Road (ref. 283 are both located adjacent to the settlement boundary within the Green Belt.
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Justification for the Allocation of The Bratch, Wombourne (ref. 280)
4.6 In order for the policy to be considered ‘sound’ the Council should allocate STW’s site at The Bratch (ref. 280) for circa 70 dwellings thereby contributing to delivering part of the Core Strategy housing allocation for Wombourne on land within the settlement boundary.
4.7 The proposed allocation of the site for residential development would perform a positive economic, social and environmental role in accordance with the three dimensions of sustainable development.
Economic Benefits
4.8 It is important to ensure that there is sufficient land available in the right places at the right time to support growth. The allocation of the site will provide housing for existing and future residents and thereby help to meet the Council’s aim of offering a full range of dwellings to meet all needs across the District.
4.9 In economic terms housing supply can play a key role in the flexibility of the local labour market which itself is an important component in local economic competitiveness. This is because a shortage of housing or a lack of affordability can act as a barrier to people accessing employment opportunities or result in long-distance commuting with adverse transport and environmental impacts.
4.10 Furthermore, the development of a residential led mixed use scheme at the site would generate direct and indirect employment in the area which would also contribute to supporting the local supply chain and services.
4.11 As part of the proposed residential led mixed use scheme at the site there may be potential to enhance the leisure and tourism offer associated with the Grade II* listed pumping station and canalside area subject to feasibility and viability considerations. This in turn could boost the local economy and further improve the vitality and viability of the village centre. STW would welcome discussions with the Council to develop potential future options for the management/ enhancement of the pumping station.
Social Benefits
4.12 The proposed development of the site would complement the existing residential area and diversify the choice and range of housing to meet local needs as identified in the Council’s SHMA. The site is sustainably located within the settlement boundary in close proximity to range of amenities, services and facilities.
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4.13 As part of residential led mixed use scheme there may also be potential to provide an area of meaningful publicly accessible open space around the canal for the benefit of residents and the community subject to viability considerations. As noted above, discussions are welcomed with the Council to develop potential options for the management/ enhancement of the pumping station which could become a significant community benefit.
Environmental Benefits
4.14 Any proposals at the site would be sensitively designed to enhance the existing wildlife corridor and maximise protection for the historic setting of the Grade II* listed pumping station and Conservation Area. At the detailed design stage any planning application submitted at the site would be accompanied by comprehensive technical assessments.
4.15 Whilst it is acknowledged that there are a number of constraints present on site, it is considered that none are insurmountable and would preclude development at the site.
4.16 In light of the above it is respectfully requested that the site is allocated for housing with an indicative capacity of 70 dwellings.
Deleted SAD 9: The Bratch, Wombourne Policy Area
4.17 STW support the removal of a restrictive policy on the site as it is considered that site specific assessments of heritage, ecology, access and landscape impacts would be provided at the detailed design stage. As such there is no requirement for a policy.
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5 SUMMARY CONCLUSION
5.1 These representations have been prepared by GL Hearn on behalf of Severn Trent Water Limited (‘STW’) in response to South Staffordshire District Council (SSDC) consultation on the SAD Publication Plan dated January 2017. These representations relate specifically to STW’s landholding at The Bratch, Wombourne (‘the site’) as shown edged red on the attached Site Location Plan at Appendix A .
5.2 The purpose of this representation is to support the deletion of the draft SAD9 ‘The Bratch, Wombourne Policy Area’ and propose the allocation of the site for housing as sensitive residential re-development of the site would accord with the principles of sustainable development set out in the National Planning Policy Framework (NPPF).
5.3 This representation seeks the allocation of the site for a residential led mixed use development under policy SAD2 ‘The Housing Allocations’. An allocation would provide greater certainty that, as a sustainably located site within the settlement of Wombourne, the site is suitable in principle for residential led development, subject addressing the detail of site specific issues of heritage, ecology, access and landscape impacts.
5.4 STW request that the site is allocated for housing with an indicative capacity of 70 dwellings. By allocating the site for housing it would perform a positive economic, social and environmental role in accordance with the three dimensions of sustainable development established in the NPPF.
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Appendices
APPENDIX A: Site Location Plan
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