December 2019 | DO/BC | P18-1747
SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW
SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION
WOLVERHAMPTON AIRPORT, HALFPENNY GREEN
ON BEHALF OF LILACTAME LIMITED
TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004
©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited
Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
CONTENTS:
Page No:
1. INTRODUCTION 1 2. CONTEXT 3 3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS 6 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION 7 5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS 10 6. INFRASTRUCTURE DELIVERY PLAN 2019 14 7. GREEN BELT STUDY 2019 20 8. LANDSCAPE STUDY 2019 28 9. SUSTAINABILITY APPRAISAL 2019 31 10. RURAL SERVICES AND FACILITIES AUDIT 2019 33 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 35 12. WOLVERHAMPTON AIRPORT, HALFPENNY GREEN 36 13. CONCLUSION 43
APPENDIX 1: SITE LOCATION PLAN
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Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
1. INTRODUCTION
1.1 This representation is made by Pegasus Group on behalf of Lilactame Ltd to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to Wolverhampton Halfpenny Green Airport, which Lilactame Ltd owns and is promoting for a mixed-use development designed to facilitate and support the continued operations at the airport.
1.2 These representations respond to the following documents, including addressing the questions set out within the Local Plan Review Consultation Document:
• Spatial Housing Strategy, October 2019
• Infrastructure Delivery Plan, 2019
• Habitats Regulations Assessment Review, 2018
• Green Belt Study, 2019
• Landscape Study 2019
• Rural Services and Facilities Audit 2019
1.3 The representations are framed in the context of the requirements of the Local Plan to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework (NPPF), paragraph 35. For a Plan to be sound it must be:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with
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rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
1.4 The representations also give consideration to the legal and procedural requirements associated with the plan-making process.
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2. CONTEXT
Adopted Local Plan
2.1 The South Staffordshire Local Plan comprises the Core Strategy (adopted December 2012) and the recently adopted Site Allocations Document (adopted September 2018).
2.2 Policy SAD1 of the Site Allocations Document requires South Staffordshire Council to carry out an early review of the Local Plan, which must be submitted to the Secretary of State for Examination by the end of 2021. The Review must be comprehensive and consider the need for additional growth and plan appropriately for it. This Plan will review, as a minimum, the following matters:
• South Staffordshire’s own objectively assessed housing need and the potential for housing supply within the District (including existing safeguarded land identified through the Site Allocations Document) to meet this need;
• The potential role of housing supply options within the District to meet unmet cross boundary needs from the wider Greater Birmingham Housing Market Area (GBHMA), including from the Black Country;
• Employment land requirements for South Staffordshire, as identified through a comprehensive Economic Development Needs Assessment (EDNA);
• South Staffordshire’s potential role in meeting wider unmet employment needs through the Duty to Co-operate;
• The appropriateness of the existing settlement hierarchy and the strategic distribution of growth in light of new housing and employment needs;
• The need for further additional safeguarded housing and employment land for longer term development needs, and the role of safeguarded land in meeting housing shortfalls across the GBHMA, including South Staffordshire’s own needs;
• Gypsy, Traveller and Travelling Showpeople provision; and
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• A comprehensive Green Belt Review undertaken jointly with the Black Country authorities, to inform any further Green Belt release to accommodate new development within the District.
Local Plan Review
2.3 The Local Plan Review is necessary in order to respond to the increasing need for development, both within South Staffordshire, and within neighbouring authorities which form the Greater Birmingham Housing Market Area (GBHMA). South Staffordshire District Council has determined that the Local Plan Review will cover the period to 2037.
2.4 South Staffordshire District Council commenced an Issues and Options (Regulation 18) consultation between Monday 8 October and Friday 30 November 2018. Representations were made by Pegasus Group on behalf of Lilactame to this consultation in respect of Wolverhampton Halfpenny Green Airport.
2.5 The Spatial Housing Strategy and Infrastructure Consultation represents a second ‘Regulation 18’ consultation, prior to the publication of a ‘Preferred Options’ (‘Regulation 19’) Local Plan, anticipated to occur in Summer 2020.
Wolverhampton Halfpenny Green Airport
2.6 The adopted Core Strategy makes numerous provisions for supporting development at Wolverhampton Halfpenny Green Airport. The Vision for Locality Area Five states:
“Wolverhampton (Halfpenny Green) Airport will be continuing to provide facilities for business aviation, recreational (private) flying, and flying training consistent with its role as a general aviation airport. The replacement of derelict and obsolete buildings with high quality well designed aviation related development and associated landscaping will have significantly improved the appearance of the site.”
2.7 Core Policy 12 of the adopted Core Strategy specifically relates to Wolverhampton Halfpenny Green Airport, along with Policy EV12 (Wolverhampton Airport – Approach to New Development) and Policy EV14 (Wolverhampton Airport – Existing and Future Uses).
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2.8 Core Policy 12 sets out an over-arching view in respect of the Airport, whilst Policies EV13 and EV14 provide further detail in respect of development management.
2.9 Policy EV13 states that the Council will support proposals for aviation uses including the replacement of existing outdated and unsustainable buildings and high-quality infill development where the proposals are consistent with national policy and other local planning policies and will not have a detrimental impact on the environment and nearby residents.
2.10 Policy EV14 states that the continued occupation of buildings on the site by existing established non-aviation uses that support the viability and sustainability of the Airport will be accepted where it is consistent with national planning policy.
2.11 Furthermore, Wolverhampton Halfpenny Green Airport is afforded its own Local Plan Policies Map inset through the Site Allocations Document (Inset Plan 43). This plan details the spatial application of Core Policy 12 and Policies EV13 and 14.
Figure 2.1: Site Allocations Proposals Map Inset Plan 43, Wolverhampton Halfpenny Green Airport
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3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS
Question 1: Do you agree that the evidence base used to inform Spatial Housing Options is robust and proportionate? If not, what else should we consider?
3.1 The consultation document identifies a range of evidence relied upon by the Council to inform the preparation of the seven Spatial Housing Options.
3.2 Lilactame Ltd is pleased to see the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Strategic Growth Study forms part of the Council’s evidence base, along with the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA 2018 provides the most up-to- date evidence on housing land availability in the district and, as such, is a key to identifying the reasonable alternative growth strategies to be considered through the plan-making process.
3.3 Lilactame Ltd is also pleased that the Council has had regard to evidence that will inform an updated Infrastructure Delivery Plan, including input from key stakeholders outside the District where necessary.
3.4 Whilst the Spatial Housing Strategy will represent a significant element of an overall spatial development strategy, the distribution of housing should be considered in the round having, regard to other uses that are required within the District to 2037. The distribution of other requirements, including employment and social and community infrastructure, are intrinsically linked to the delivery of homes as part of a comprehensive, sustainable strategy.
3.5 In light of the above, the evidence identified to inform the Spatial Housing Options appears to omit other relevant technical reports identified at the Issues and Options stage which, it is assumed, will be utilised by officers in formulating the Preferred Options document in Summer 2020.
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4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION
Question 2: Do you agree that taking account of housing land supply from the start of the new plan period (1 April 2018) is the correct approach?
4.1 It is noted that all Spatial Housing Options take account of existing ‘potential’ sources of supply i.e. permissions, completions and current allocations. This approach, in principle, is supported. However, it is considered necessary to scrutinise the supply position for robustness.
4.2 Through the Local Plan Review it is considered essential to review all sources of housing supply, including existing commitments. Whilst it is recognised that the Site Allocations Document was only adopted in September 2018, further information or evidence may have arisen since adoption that raises questions of suitability or delivery of sites allocated.
4.3 All potential sources of supply will require scrutiny through the Local Plan Examination in Public and it is recommended that a site-specific housing trajectory is prepared to support the Preferred Options consultation in the Summer of next year. This should provide delivery assumptions in respect of any proposed preferred option allocation i.e. build out rates and lead in times.
Question 3: Do you agree that all Safeguarded Land identified in the SAD should be released as a priority and should be delivered at an average density of 35 dwellings per hectare?
4.4 It is noted that all Spatial Housing Options assume existing ‘safeguarded land allocations’ will be released for development. This approach, in principle, is supported. However, it is considered necessary to apply a level of further scrutiny to this potential source of future supply for robustness.
4.5 As set out above in respect of current commitments, further information or evidence may have arisen since adoption of the Site Allocations Document that raises questions of suitability or delivery of individual safeguarded land allocations.
4.6 In respect of the safeguarded land allocations an assumption of 35dph has been utilised to determine the likely yield from this source of supply. This relates back
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to the recommendations of the Greater Birmingham Housing Market Area Study and is considered to represent a reasonable average assumption. However, this average density assumption should only be applied to a net developable area and not the total safeguarded area of 86.8ha established through Policy SAD3. This appears to be the case albeit the calculations utilised in arriving at the Council’s stated yield of 1,651 additional dwellings is not set out.
4.7 The safeguarded land allocations identified in Policy SAD3 are not strategic in size and there are no reasons why their delivery should be delayed. These sites are likely to provide a helpful boost to delivery in the early years of the plan period which would help to support longer-term delivery of strategic sites that may experience longer lead in times to delivery.
Question 4: Are there any other options we should consider?
4.8 The consultation document identifies that new settlements have been considered as part of the growth options, in line with the findings of the GBHMA Strategic Growth Study. The Study identified two areas of search for a new settlement of 10,000 dwellings or more within South Staffordshire, which were either around Dunston or between Wolverhampton and Penkridge. The justification presented for this approach is that national policy requirements state that new settlements should consider opportunities presented by existing or planned infrastructure and ensure that their location will allow sufficient access to employment and services in larger towns to which there is good access. South Staffordshire Council is, therefore, only considering new settlement options within the A449 corridor, given that it is an existing and future strategic road and rail corridor.
4.9 Whilst Lilactame Ltd does not dispute the findings of the Strategic Growth Study or the sustainability credentials of the A449 corridor, it remains that the findings of the Growth Study do not prevent South Staffordshire District Council considering alternative options for growth at other locations within the District of a reduced scale. Indeed, the Growth Study was strategic in nature, considering only new settlement options capable of accommodating 10,000+ new dwellings.
4.10 This approach overlooks other options within South Staffordshire, especially brownfield options like Wolverhampton Halfpenny Green Airport, which is capable of accommodating residential development as part of a mixed-use proposal. This
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proposal could include additional/improved employment floorspace, retail/service floorspace to serve a local need, and associated areas of green infrastructure.
4.11 The preferred options also consider previously developed sites in the Green Belt. Wolverhampton Halfpenny Green Airport represents one of the largest brownfield sites in the District. It represents a valuable resource which ought to be considered by the Council within Preferred Spatial Option G. There are opportunities to significantly improve the highways and public transport connectivity of the site which could be delivered in conjunction with a mixed-use development.
4.12 The growth option presented by Wolverhampton Halfpenny Green Airport is considered further in Chapter 12 of this representation.
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5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS
Question 5: Do you agree that the 7 Spatial Housing Options are appropriate options to consider? Are there any alternative options we have not considered?
5.1 Lilactame Ltd supports the identification of the alternative spatial housing options that have been identified by the Council. It is considered that these represent appropriate high-level options to inform a preferred spatial strategy for housing growth. Although, whilst the Spatial Housing Strategy Options have been presented as separate and distinct options, alternative strategies could be achieved through a hybrid of the options identified.
5.2 However, as set out previously, it is considered that the growth options presented do not sufficiently explore the opportunity presented by brownfield opportunities within the Green Belt, such as Wolverhampton Halfpenny Green Airport. Preferred Spatial Option G provides some recognition of the opportunities presented by brownfield sites in the Green Belt at Wombourne, but no other alternatives are identified or explored.
5.3 National Planning Policy and guidance is clear that development on brownfield sites is preferable to greenfield sites. Indeed, Paragraph 117 of the NPPF requires strategic policies of local plans to ‘…set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land’.
5.4 Paragraph 118 goes on to require planning polices and decisions to:
• encourage multiple benefits from both urban and rural land, including through mixed use schemes and taking opportunities to achieve net environmental gains
• promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained, and available sites could be used more effectively
5.5 Lilactame Ltd accordingly submits that further work should be undertaken to fully assess growth opportunities presented by brownfield sites within the Green Belt, in accordance with national policy, within the context of Spatial Option G.
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Question 6: Do you agree that Spatial Housing Option G is a robust approach to meet needs in the district and to make a contribution towards unmet needs within the GBHMA?
5.6 Lilactame Ltd has no further comments to make in respect of Spatial Housing Option G, beyond the response made in respect of Question 5.
Question 7: Do you agree that we should continue to explore options for a new settlement?
5.7 Lilactame Ltd supports the Council’s approach to continue exploring Option G for the provision of a new settlement for delivering growth. This is aligned to the recommendations of the Greater Birmingham Strategic Housing Market Area Strategic Growth Study.
5.8 However, as set out previously, the growth options presented do not sufficiently explore the opportunity presented by brownfield opportunities within the Greenbelt, such as Wolverhampton Halfpenny Green Airport. Preferred Spatial Option G provides some recognition of the opportunities presented by brownfield sites in the Greenbelt at Wombourne, but no other alternatives are identified or explored.
5.9 Indeed, Spatial Housing Option G only seeks to identify an ‘area of opportunity for a new settlement beyond the plan period’ recognising that, to date, no proposal has been put forward to demonstrate self-containment and deliverability. Therefore, it is clear that this potential source of supply should not be relied upon to meet the proposed housing requirement of 8,845 dwellings between 2019 and 2037 and that alternative growth options, such as the redevelopment of brownfield sites in the Greenbelt, should be explored.
Question 8: What other information (if any) should we consider before concluding that Green Belt release is justified?
5.10 The Issues and Options document highlighted the issue of ‘protecting the Green Belt’ recognising that around 80% of the South Staffordshire is designated Green Belt. In addition, it highlighted the issue of ‘protecting sensitive areas of Open Countryside beyond the Green Belt,’ recognising that much of the character of the countryside beyond the Green Belt is of high landscape quality.
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5.11 In light of the emerging housing requirement, capacity within the existing urban areas and the issues and challenges associated with the natural and built environment identified by the Council, development will have implications for Green Belt or the open countryside beyond. Lilactame Ltd considers the Council’s evidence is clear and conclusive in requiring Green Belt release to deliver a sustainable and sound spatial development strategy to 2037. This evidence supports a strong case for demonstrating the necessary exceptional circumstances for such release.
5.12 Of the seven Spatial Housing Strategy options identified, only one (Option A) would negate the need to remove land from the Green Belt. The Council concludes that this option is ‘unsustainable and potentially undeliverable’ as set out in paragraph 5.11 of the consultation document. Lilactame Ltd supports the Council’s conclusion in respect of this option.
Question 9: 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?
5.13 Lilactame Ltd disagrees with the site selection methodology that will inform the identification of preferred options.
5.14 Paragraph 1.5 of the Site Selection Methodolgoy states that the Local Plan Review will ‘…avoid the allocation of sites which are fundamentally less suitable for housing, such as isolated sites which are poorly related to existing settlements’.
5.15 Paragraph 1.6 goes on to state:
“To further narrow down which sites will be selected for allocation, sites will only be assessed for allocation where they are in an [sic] potential location for growth under the infrastructure-led strategy (Spatial Option G) proposed by the Council in section 5 of the Spatial Housing Strategy and Infrastructure Delivery document. This means that the Council will not assess any potential site options in or adjacent to Tier 5 settlements or in isolated locations in the district’s rural area.”
5.16 Whilst the overall logic of this approach is understood, it nevertheless fails to take into account unique site-specific opportunities presented by large stand-alone brownfield sites, such as Wolverhampton Halfpenny Green Airport.
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5.17 The overall size and brownfield nature of Wolverhampton Halfpenny Green Airport allows for the provision of supporting infrastructure and services which would not be available on other, smaller sites. Furthermore, the residential development at Wolverhampton Halfpenny Green Airport is intended to serve a wider purpose; cross-subsidising development to support the upgrading of existing services and facilities present on site, thus supporting existing employment opportunities and the local economy.
5.18 The rigid interpretation of the Site Selection Methodology does not allow for such circumstances to be considered and should be amended accordingly.
Question 10: 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 wherever possible?
5.19 Lilactame Ltd agrees 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 wherever possible. Having regard to the Council’s Green Belt evidence, development at Wolverhampton Halfpenny Green Airport would accord with approach (see Chapter 7 of this representation).
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6. INFRASTRUCTURE DELIVERY PLAN 2019
6.1 South Staffordshire District Council has produced an Infrastructure Delivery Plan (2019) to identify infrastructure projects required to support growth through preparation of the Local Plan Review. This forms part of the evidence base for the Local Plan Review.
6.2 At this stage, the role of the IDP is to identify the district’s baseline infrastructure requirements as well as known requirements that have emerged through engagement with infrastructure providers to date.
6.3 The IDP broadly reflects the infrastructure requirements associated with the preferred Spatial Growth Option G and therefore does not consider the infrastructure requirements of alternative options.
6.4 It is submitted that the IDP should consider infrastructure requirements and opportunities across the District as a whole, which should then inform the preferred spatial option for growth, rather than the preferred spatial option for growth determining the identified infrastructure requirements identified in the IDP.
Question 1: Do you agree that the delivery of the above infrastructure opportunities should be explored further? If not, please explain why
6.5 Lilactame Ltd agrees that that the infrastructure projects identified in the IDP should be explored further. Nevertheless, as set out above, the IDP only considers infrastructure requirements associated with the preferred Spatial Growth Option G. It is considered that District-wide infrastructure opportunities should be considered and should be used to inform the preferred spatial options for growth.
Question 2: Having regard to the level of growth proposed for each village and broad location (see map), are there any other infrastructure projects that you like to see delivered?
6.6 At this time, Lilactame Ltd has not identified any other infrastructure projects required in respect of the broad locations for growth. However, this position may change once specific sites come forward at future stages of the Local Plan Review process.
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General Comments
6.7 In additional to the questions set out within the IDP, Lilactame Ltd would make the following general comments in relation to the IDP.
Delivery Mechanisms
6.8 Paragraph 3.1 of the IDP states:
“New development will need to be supported by new infrastructure where there is an evidenced need, and this will need to be at the cost of the developer. Development will not be proposed through the Local Plan unless it has been robustly demonstrated that the development will provide or facilitate the necessary infrastructure.”
6.9 Whilst Lilactame Ltd recognises the importance of development contributions towards the funding of infrastructure, public sector funding can, and should, also play a key role in the delivery of infrastructure, particularly strategic infrastructure. Public sector funding sources include Local Enterprise Partnership (LEP), central Government, grant funding or National Lottery funding. These funding streams should not be ignored.
Strategies
6.10 A number of strategies and studies are currently being drafted which will identify existing infrastructure provision and deficiencies, with a view to guiding future requirements. It is strongly recommended that these documents are expedited in order to understand relative infrastructure requirements across the District and how these may influence the proposed spatial strategy. The documents currently being prepared include:
• Playing Pitch and Sports Facilities Audit and Strategy
• Open Space Audit and Strategy
• Strategic Flood Risk Assessment and Water Cycle Study
• Brinsford Strategic Park and Ride Feasibility Assessment
• Viability Study
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6.11 Whilst all of the above documents are important in informing the Local Plan, of paramount importance is the Viability Study, which will evidence the viability of development proposals, including the costs associated with the infrastructure identified to support the delivery of development sites. Abnormal costs associated with a development site may reduce the scope to deliver identified infrastructure requirements. The Viability Study will therefore determine if identified infrastructure is feasible in financial terms and whether the proposals and polices in the Plan are deliverable. It is therefore a key piece of evidence which will underpin and inform all elements of the Local Plan and should be completed before, and used to inform, a draft version of the Plan.
Community Infrastructure Levy (CIL)
6.12 The IDP identifies that the Council does not have a Community Infrastructure Level (CIL) charging schedule. However, the decision on whether to implement CIL will be taken ‘as the Local Plan progresses’, following identification of preferred sites, the outcome of the stage 2 viability assessment, and once a cost- benefit analysis of introducing a CIL has been undertaken.
6.13 Lilactame Ltd supports the acknowledgement that ‘new settlements or urban extensions need to be CIL exempt due to their significant upfront infrastructure costs’; a CIL requirement could otherwise make such developments unviable. However, this consideration should be extended to brownfield sites, which are also subject to significant upfront infrastructure costs, associated with site clearance and land remediation.
6.14 Lilactame Ltd nevertheless recommends caution regarding CIL, following changes to the CIL Regulations which came into force on 1st September 2019. These changes included the removal of the pooling restrictions and Regulation 123 Lists, and the introduction of new reporting requirements through Infrastructure Funding Statements (IFS). CIL authorities must produce their first IFS by 31st December 2020.
6.15 Although the new IFS will include information on how much money authorities have collected in developer contributions and how it has been spent, it is unclear how authorities will ensure effective monitoring, regulation and control of the relationship between CIL and Section 106 obligations.
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6.16 With the removal of statutory Regulation 123 lists and the restriction on ‘double- dipping’ previously contained in Regulation 123, the only means of addressing the potential risk of ‘double-dipping’ between CIL payments and section 106 obligations will be through the limitations on the use of Section 106 obligations set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.
6.17 Regulation 122 assumes that the infrastructure to be secured through CIL will be identifiable and fixed for the whole development programme and that when entering into a section 106 agreement there is this certainty that the identified developer contributions will not be replicated in CIL payments.
6.18 However, with the removal of Regulation 123 lists, authorities will no longer be restricted in the application of anticipated CIL payments for any specific purpose. Authorities will be able to allocate CIL funds as they see fit and to re-direct such funds should the need arise.
6.19 As such, there is the potential for an authority to secure a S106 contribution to a certain infrastructure project, then subsequently divert CIL funds to ‘top up’ this funding in the future, effectively resulting in ‘double dipping’.
6.20 The absence of Regulation 123 lists accordingly places a significant emphasis on the importance of producing detailed IFS, which are then regularly kept up to date, to ensure that ‘double dipping’ does not occur.
Highways
6.21 Paragraph 5.20 of the IDP states:
“SCC confirmed that they are unable to determine the cumulative effect that the proposed level of growth (circa 9000 dwellings) for the plan period will have on the local highway network without knowing site specific locations. Once preferred sites are identified these will be provided to SCC who will then be able to consider traffic flows at specific junctions and identify where further assessment may be required.”
6.22 Whilst it is accepted that detailed highways modelling cannot be undertaken without considering traffic flows at specific junctions, it nevertheless remains a
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concern that this modelling will only take place once preferred sites are identified. It is plausible that sites may be identified in a ‘preferred options’ version of the Local Plan, which are subsequently demonstrated to be undeliverable in highways terms, or the cost of highways mitigation is so significant so as to render a site unviable.
6.23 Ideally, detailed highways modelling would be undertaken after the identification of preferred sites, but prior to the publication of the ‘preferred options’ version of the Local Plan, so that this modelling forms part of the evidence base at this stage.
6.24 Transport work undertaken on behalf of Lilactame was part of their on-going due diligence in respect of the site has demonstrated that the highway network in the vicinity of the site has capacity to accommodate development without any adverse impact.
6.25 Highways and access matters are considered further in Chapter 12 of this representation.
Baseline Infrastructure Projects
6.26 Appendix 1 of the IDP identifies upwards of 80 specific infrastructure projects which are anticipated to be delivered during the plan period. A number of these are identified as being funded either entirely by private developers, or as a combination of public and private sector funding. However, in the vast majority of cases, the estimated cost of these projects is identified as being ‘unknown’.
6.27 If a planning application was to come forward on a development site which SSDC considered eligible to contribute towards an identified infrastructure project, SSDC would not be able to request a Section 106 contribution towards the project, as the total cost of that project, and therefore the necessary proportional contribution, would be unknown. Therefore, there would be no way of assessing whether the request for a S106 contribution met the tests set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.
6.28 It is therefore of paramount importance that SSDC works with relevant parties to assess and cost specific infrastructure projects as soon as possible, particularly as
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these costings may have implications for the viability of certain sites and, by extension, the viability of the Local Plan.
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7. GREEN BELT STUDY 2019
7.1 South Staffordshire District Council has commissioned a Green Belt Assessment, alongside the City of Wolverhampton, Dudley, Sandwell and Walsall, (together comprising the Black Country authorities). The Study forms an important piece of evidence for the partial review of the Black Country Core Strategy (the Black Country Plan) and the strategic site allocations and individual development plans of the Black Country Authorities, as well as South Staffordshire District.
7.2 The Green Belt Study has two stages; the first is to assess ‘strategic variations’ between the contribution of land to the five purposes of the Green Belt, whilst the second includes a more focused assessment of the potential ‘harm’ of removing land from the Green Belt. Alongside the Green Belt Study, a Stage 3 assessment involved undertaking a landscape sensitivity assessment in order to assess the sensitivity of land within the South Staffordshire to housing and employment development. Whilst there is a relationship between landscape sensitivity and Green Belt contribution/harm, in that physical elements which play a role in determining landscape character, there are fundamental differences in the purposes of the two assessments. As such, the findings of the Stage 3 landscape sensitivity assessment for South Staffordshire and the Black Country are presented in a separate document (Landscape Study 2019) and is considered later is this representation.
Green Belt Purposes
7.3 The National Planning Policy Framework (NPPF) states that the Green Belt should serve the five following purposes:
• To check the unrestricted sprawl of large built-up area;
• To prevent neighbouring towns merging into one another;
• To assist in safeguarding the countryside from encroachment;
• To preserve the setting and special character of historic towns; and
• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
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Wolverhampton Airport; Contributions to Green Belt Purposes
7.4 The Green Belt Study assesses Wolverhampton Halfpenny Green Airport in two parts: the buildings and the runways.
Wolverhampton Airport Buildings
7.5 Wolverhampton Airport buildings are identified as falling within Green Belt Sub- Parcel Ref S76A, which is identified as making the following contribution to the five purposes of the Green Belt:
GB Purpose Assessment Rating P1: Checking the Land is sufficiently separated or distant from the West Weak / No unrestricted sprawl of Midlands conurbation for there to be no significant contribution large built-up areas potential for urban sprawl from the large built up area. P2: Preventing the Land plays no significant role due to the distance Weak / No merging of neighbouring between the West Midlands conurbation and contribution towns Bridgnorth, its nearest neighbouring towns. P3: Safeguarding the Land retains some degree of openness but is countryside from Moderate compromised by urbanising development within it. encroachment P4: Preserve the setting Land does not contribute to the setting or special Weak / No and special character of character of a historic town contribution historic towns P5: Assist urban regeneration, by All parcels are considered to make an equal encouraging recycling of Strong contribution to this purpose. derelict and other urban land
Table 7.1: Land Parcel S76A (Wolverhampton Airport Buildings) Contribution Towards Green Belt Purposes
7.6 The Study goes on to identify that, should Green Belt Sub-Parcel ref: S76A be released for development, the resulting harm would be ‘moderate’, stating:
“The sub-parcel makes a moderate contribution to preventing encroachment on the countryside. The existing development is of a moderate density, and there is little distinction from the surrounding open grassland and runways. The introduction of a new inset area would constitute a limiting weakening of the wider Green Belt, but the location within countryside that is some distance from any sizeable inset settlement means that there would be negligible harm to settlement separation and no increase in containment of other Green Belt land.”
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Figure 7.1: Green Belt Harm Rating for Land Parcel S76A (Wolverhampton Airport Buildings)
Wolverhampton Airport Runways
7.7 Similarly, Wolverhampton Airport runways are identified as falling within Green Belt Sub-Parcel Ref S64F, which is identified as making the following contribution to the five purposes of the Green Belt.
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GB Purpose Assessment Rating P1: Checking the Land is sufficiently separated or distant from a large Weak / No unrestricted sprawl of built-up area for there to be no significant potential for contribution large built-up areas urban sprawl from the large built up area. P2: Preventing the Land plays no significant role due to the distance Weak / No merging of neighbouring between the West Midlands conurbation and Albrighton contribution towns and Bridgnorth, its nearest neighbouring towns. Land contains the characteristics of open countryside P3: Safeguarding the (ie an absence of built or otherwise urbanising uses in countryside from Green Belt terms) and does not have a stronger Strong encroachment relationship with the urban area than with the wider countryside. P4: Preserve the setting Land does not contribute to the setting or special Weak / No and special character of character of a historic town. contribution historic towns P5: Assist urban regeneration, by All parcels are considered to make an equal encouraging recycling of Strong contribution to this purpose. derelict and other urban land
Table 7.2: Land Parcel S64F (Wolverhampton Airport Runways) Contribution Towards Green Belt Purposes
7.8 The Study goes on to identify that, should Green Belt Sub-Parcel ref: S64F be released for development, the resulting harm would be ‘moderate-high’, stating:
“The sub-parcel makes a strong contribution to preventing encroachment on the countryside. The adjacent buildings of Wolverhampton Halfpenny Green Airport (S76A) have an influence on character but do not decrease the openness of this subparcel. Introduction of a new inset development area would constitute some weakening of the wider Green Belt, but the location within countryside that is some distance from any sizeable inset settlement means that there would be negligible harm to settlement separation and no increase in containment of other Green Belt land.”
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Figure 7.2: Harm Ratings for Land Parcel S64F
Contribution to Green Belt Purposes
7.9 Whilst the conclusions of the above assessments are noted, it is considered that the Airport as a whole performs a reduced function in terms of the purposes of the Green Belt, particularly in light of the intended redevelopment options for the site, as set out below.
To Check the Unrestricted Sprawl of Large Built-Up Areas
7.10 Lilactame agrees with the findings of the Green Belt assessment in respect of the first purpose of the Green Belt, in that the site is sufficiently separated from any large built-up area so that any development would not result in urban sprawl.
7.11 The site therefore makes no contribution towards this purpose.
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To Prevent Neighbouring Towns from Merging into One Another
7.12 Again, the Study identifies the site plays no significant role in respect of the second purpose of the Green Belt, due to the significant distance between the West Midlands conurbation, Albrighton and Bridgnorth, the site’s nearest neighbouring towns.
7.13 The site therefore makes no contribution towards this purpose.
To Assist in Safeguarding the Countryside from Encroachment
7.14 The Green Belt Study identifies that the existing Airport Buildings impact upon the Green Belt, compromising its openness. Nevertheless, the Airport retains an overall degree of openness, particularly the runways, which are identified as making a ‘strong’ contribution to this purpose.
7.15 Lilactame Ltd disagree with the above assessment, in that encroachment constitutes more than just an absence of built development. The runways amount to a significant extent of tarmacked land which would otherwise be greenfield. They therefore constitute previously developed (brownfield) land. Furthermore, they are subject to daily recreational air traffic as part of the day-to-day operation of the Airport. This frequency of activity further compromises the openness of the site.
7.16 Lastly, the inter-visibility between the Airport and the area beyond is limited by the dense perimeter hedgerow, low lying topography of the surrounding area and scattered field trees. This, again, serves to limit openness of the Green Belt in this location.
7.17 It is, therefore, considered that the Airport runways makes a ‘moderate’ contribution to assisting in safeguarding the countryside from encroachment, rather than the ‘strong’ contribution identified within the Green Belt Study.
To Preserve the Setting and Special Character of Historic Towns
7.18 The site is not located adjacent to, or within the setting of, a historic town. Lilactame Ltd therefore agrees with the conclusions of the Green Belt Study, that the site makes a ‘weak/no’ contribution to this Green Belt purpose.
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To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and other Urban Land
7.19 The Green Belt parcels relating to both the buildings and the runways are identified as making a ‘strong’ contribution to this purpose in the Green Belt Study, as ‘all parcels are considered to make an equal contribution to this purpose.’
7.20 Lilactame Ltd strongly objects to this assessment, particularly in respect of the Airport buildings, which constitute previously developed land in their entirety, whilst the runways also represent significant swathes of previously developed land, surrounded by smaller areas of greenfield land.
7.21 Contrary to the findings of the Green Belt Study, the Green Belt designation in this location actually serves to prejudice the recycling of brownfield land, in that it limits the development and redevelopment opportunities at the Airport.
7.22 It is, therefore, submitted that the Green Belt parcel which contains the buildings (S76A) makes no contribution to this purpose, whilst the parcel which contains the runways (S64F) makes a moderate contribution to this purpose.
Summary of Green Belt Purposes
7.23 Overall, it is therefore considered that Wolverhampton Halfpenny Green Airport, makes a reduced contribution to the five purposes of the Green Belt than that identified within the Green Belt Study for parcels S76A and S64F. This contribution is summarised in the table below:
GB Purpose Rating Weak / No P1: Checking the unrestricted sprawl of large built-up areas contribution Weak / No P2: Preventing the merging of neighbouring towns contribution P3: Safeguarding the countryside from encroachment Moderate P4: Preserve the setting and special character of historic Weak / No towns contribution P5: Assist urban regeneration, by encouraging recycling of Moderate derelict and other urban land
Table 7.3: Wolverhampton Halfpenny Green Airport, Green Belt Assessment
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Green Belt Harm
7.24 Given the reduced impact upon the five purposes of the Green Belt, is contented that the overall Green Belt harm identified within the Study should be reduced from ‘high’ to ‘moderate’, for the runways, and from ‘moderate’ to ‘low-moderate’ for the buildings.
7.25 It is accordingly submitted that the area currently identified by existing Site Allocations Proposals Map Inset Plan 43 (Wolverhampton Halfpenny Green Airport) should be released from the Green Belt to facilitate development at the Airport. It should be noted that this area is slightly different to Green Belt Assessment Parcel S76A and fully encompasses all of the existing Airport buildings.
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8. LANDSCAPE STUDY 2019
8.1 South Staffordshire District Council has produced a Landscape Study (2019) which forms part of the Local Plan Review evidence base. Wolverhampton Halfpenny Green Airport falls within Landscape Parcel Reference: SL11. The area falls within the following Landscape Character Type: Sandstone Estatelands. The area is located southwest of Halfpenny Green and east of the village of Bobbington. The eastern boundary is Gospel Ash Road, the southern boundary Water Lane and the western boundary Crab Lane. The northern boundary marks the extent of Wolverhampton Halfpenny Green Airport, which occupies this whole area.
8.2 An extract of the Council’s Appraisal of Landscape Sensitivity is included below:
Characteristic / Lower Sensitivity to Moderate Sensitivity Higher Sensitivity Attribute Development to Development to Development The use of the area as Wolverhampton Scale Halfpenny Green Airport has eroded previous field boundaries. A very flat landscape Landform between 80m and 85 m AOD. An RAF training station was laid out on this site Landscape pattern in 1941, and this has . and time depth removed any previous time depth. There are no priority habitats within the area which is largley made up of amenity grass between the runways. 'Natural' Valued nature features character include the mature trees around the airport buildings and along Water Lane and Gospel Ash Road. An RAF training station was opened on this site in 1941, and three Second Wold War pillboxes are located within the airport and some of its associated Built character building are still in use. There are detatched properties along Gospel Ash Road including the historic farmstead Yew Tree Farm and a Methodist Chapel (unlisted). There is no public access Recreational to this site, although the character airport is used for
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recreational flights. An open tranquil area, which is slightly Perceptual impacted by the noise
aspects from flight and lights for occasional night-time flying. The area has no visual relationship with The area provides an Settlement Bobbington due to open backdrop to the
setting intervening vegetation hamlets at Halfpenny along the perimetre of Green and Gospel Ash. this flat site. A flat landscape which is visually enclosed except from roads immediately to the west and some Visual prominence inter-visibility with wooded hills at Highgate Common and Blackhill Plantation. Inter-visibility There is no inter-visibility with adjacent with adjacent sensitive designated landscapes or marked landscapes or viewpoints on the OS promoted view 1:25k. points Landscape The landscape is considered to have low-moderate Sensitivity overall sensitivity to residential development as all Low - Moderate Judgement the criteria score low or moderate.
8.3 The Study concludes that Landscape Parcel SL11 (which encompasses the site) is considered to have a ‘low-moderate’ overall sensitivity to residential development, as identified on Figure 8.1 overleaf.
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Figure 8.1: Landscape Sensitivity Rating Parcel SL11
8.4 The findings of the Landscape Study are supported by Lilactame Ltd. It is considered that development at the site provides opportunities to strengthen existing landscaping, as well as also providing opportunities for new areas of planting on land which was previously development.
8.5 The refurbishment and redevelopment of existing buildings and structures on site would also allow for their replacement with replacements which are more sensitive to the surrounding landscape, through careful consideration of layout and materials.
8.6 Matters relating to site-specific landscape sensitivity are considered further in Chapter 12 of this Representation.
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9. SUSTAINABILITY APPRAISAL 2019
9.1 Lepus Consulting has produced a Sustainability Appraisal of the South Staffordshire Local Plan Review: Spatial Housing Strategy and Infrastructure Delivery (‘the SA’), on behalf of the Council.
9.2 The SA assesses the sustainability effects of the seven growth options identified within the South Staffordshire Local Plan Review and does not assess the sustainability of individual sites or land parcels at this stage.
9.3 A summary of the findings of the SA is included below at Figure 9.1.
Figure 9.1: Summary of SA Appraisal Findings for Each Growth Option
9.4 Whilst it is acknowledged that the SA is ‘high level’ at this stage, it remains that the Council has commissioned a number of pieces of evidence to inform the Local Plan Review at this stage, including a Landscape Sensitivity Study (prepared by LUC, 2019).
9.5 This Study assesses the landscape sensitivity of 96 broad parcels of land and the subsequent degree of harm that would result if these parcels were to be developed. The Study concludes that these parcels demonstrate five degrees of varying sensitivity, from ‘low’ to ‘high’.
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9.6 Given the varying nature of these landscape parcels and their attributed sensitivity ratings, coupled with the varying typologies of the growth options presented in the Local Plan Review, it is illogical that all seven growth options should score the same (a ‘double negative’) in respect of Landscape and Townscape. Such a conclusion effectively renders the findings of the Landscape Study irrelevant in informing the preferred spatial strategy for growth.
9.7 It is therefore considered that more could be done to differentiate between the sustainability benefits of the seven growth options identified within the plan.
9.8 Nonetheless, Lilactame Ltd agrees with the overall conclusion of the SA at this stage, that Option G – ‘Infrastructure-led development with a garden village area of search beyond the plan period’ represents the most sustainable growth option available, subject to the further consideration of previously developed land options as part of this strategy.
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10. RURAL SERVICES AND FACILITIES AUDIT 2019
10.1 South Staffordshire District Council has prepared a Rural Services and Facilities Audit (2019) (‘the RSFA’) which presents evidence on the relative level of services and facilities present in settlements within South Staffordshire.
10.2 The RSFA identifies five key indicators to compare the relative sustainability of settlements within the District as follows:
• Access to food stores;
• Diversity of accessible community facilities/services;
• Access to employment locations;
• Access to education facilities; and
• Public transport access to higher order services outside of the village.
10.3 Wolverhampton Halfpenny Green Airport is not located within or adjacent to any named settlement within South Staffordshire District. The nearest named settlement is that of Bobbington, approximately 1.25km to the south-west.
10.4 Bobbington is identified as falling within ‘Tier 4 Settlements’ which are described as:
“Settlements in this tier have either no or very few facilities. Typically, these settlements will have either a small food store and public transport access outside of the village or contain a limited degree of educational facilities (e.g. a primary school). Access to employment via public transport is much poorer than in the higher tiers and there is also much poorer access to other facilities by public transport, with some villages having no public transport provision.”
10.5 The overall settlement hierarchy scoring for Bobbington is presented overleaf.
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Access to convenience stores/ supermarkets Diversity of other accessible community facilities/ services Access to employment locations Access to primary/ first school within settlement Access to secondary/ high school within settlement Access to 6th form/college within settlement Public transport access to higher order services outside of the village
Figure 10.1: Settlement Hierarchy Scoring for Bobbington, RSFA (2019)
10.6 Whilst the identification of Bobbington as a Tier 4 Settlement is not disputed overall, it remains that Wolverhampton Halfpenny Green Airport is a large brownfield site, currently in employment and recreational use. Any development on the site represents an opportunity to provide additional services and facilities, as part of an overall masterplan for the site. This would serve to improve the sustainability credentials of not only the existing users of Airport, but also for the neighbouring settlement of Bobbington.
10.7 Wolverhampton Airport lies within walking distance of Bobbington, including Corbett Primary School. The site is also close to parts of the PRoW network, with public footpaths leading from Crab Lane and providing alternative links to Bobbington. These PRoW routes would help to promote leisure walking for potential future residents at the site and the presence of numerous PRoW in this area suggests that there is a reasonable level of existing leisure walking activity that is already taking place involving the use of the local roads.
10.8 It is considered that development on the site represents an opportunity to meet some of the local retail/service needs of the residents of Bobbington, which currently does not benefit from any local retail services.
10.9 A travel plan would accompany any planning application for the site, which would set sustainable travel targets for the development and identifies proposed measures to help achieve these. Proposals would include off‐site measures to improve the environment for pedestrians and cyclists in the local area, and there is potential to explore bringing community transport to serve the site in the future through local bus services.
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11. HABITATS REGULATION ASSESSMENT REVIEW 2018
11.1 South Staffordshire District Council has produced a Habitat Regulations Appraisal (HRA) Review to support the Issues and Options consultation document. The report aims to identify and collect information in relation to designated European Nature Conservation sites which could be affected by proposals promoted through the Local Plan Review process. The report also provides an initial overview of the potential effects on European sites of the policy and growth options contained within the Local Plan Review Document.
11.2 However, the HRA Review has not been updated to consider or reflect the spatial options for growth presented within this latest consultation. The Review should be updated as soon as possible to consider the potential impact and necessary mitigation of preferred Housing Option G.
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12. WOLVERHAMPTON AIRPORT, HALFPENNY GREEN
Site History and Context
12.1 Wolverhampton Halfpenny Green Airport is located approximately 11km southwest of Wolverhampton and 24km to the west of Birmingham City Centre, close to the villages of Bobbington and Halfpenny Green. The Airport is washed over by the Green Belt. A Site Location Plan is included at Appendix 1 to this Representation.
APPENDIX 1 – SITE LOCATION PLAN
12.2 The original airport was known as RAF Bobbington (later known as RAF Halfpenny Green) and was constructed between 1940-1941 by the Royal Airforce and used as an Air Observer Navigator School. The RAF operation ended in around 1956 with the site’s civil aviation use started up in the early 60s and has been used continuously through to the present day.
12.3 The current airport is home to a number of businesses. This includes the following:
• aircraft and helicopter flying school
• private and commercial aircraft operators
• aviation and non-aviation related businesses.
12.4 The site currently contains hard and grass runways. It contains a helicopter school, autogyro supplier and microlight school.
12.5 In terms of non-aviation related business this includes the following activities:
• Specialist historic car restorer
• Manufacturer of bespoke furniture
• Antique and vintage centre
• Website design and marketing company
• Professional photographer
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• Dust and fume extraction business
• Rotas sport sales and service business
• Motor cycle maintenance business.
12.6 There are approximately a total of 75 full or part-time jobs supported on site.
12.7 In addition to the above businesses the airport also provides accommodation for the Halfpenny Green Air Scouts. This Scout Group was established in 1964 and has been based at the airport. The Halfpenny Green Air Scouts follow the same purposes and values of any other Scout Group but has a particular aeronautical twist. Facilities on the airport include computer room, archery range, air rifle range and bouldering wall. There is also an outdoor area for games, campfires and camping.
12.8 Unfortunately, the airport has suffered from under investment in the past and currently operates unprofitably. One of the runways (Runway 28/10) which is essential for General Aviation aircraft and training, cannot be used at present as it requires repair works which will cost in the region of £300,000.
12.9 The current hangars predominantly date from the second world war and were designed for military aircraft from that period, rather than the current planes that use the airport. New hangars tend to be smaller and more efficient in terms of how planes access and are parked within them.
12.10 For the airport to be turned from a struggling business into a thriving one substantial capital investment is required to ensure the facilities are up to the standard of the 21st century and so it can become a self-sustaining business.
12.11 Lilactame purchased the airport in 2015. They proposed an investment strategy that will enhance the physical infrastructure on the site and therefore bolster the current airport and its associated businesses.
Planning Policy Context
Local Policy
12.12 The Airport site is identified in the adopted Core Strategy through Core Policy 12, Policy EV13 and Policy EV14. Core Policy 12 sets out an over-arching view in
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respect of the Airport, whilst Policies EV13 and EV14 provide further detail in respect of development management.
12.13 Policy EV13 states that the Council will support proposals for aviation uses including the replacement of existing outdated and unsustainable buildings and high-quality infill development where the proposals are consistent with national policy and other local planning policies and will not have a detrimental impact on the environment and nearby residents.
12.14 Policy EV14 states that the continued occupation of buildings on the site by existing established non-aviation uses that support the viability and sustainability of the Airport will be accepted where it is consistent with national planning policy.
12.15 Furthermore, Wolverhampton Halfpenny Green Airport is afforded its own Local Plan Policies Map inset through the Site Allocations Document (Inset Plan 43). This plan details the spatial application of Core Policy 12 and Policies EV13 and 14.
12.16 These policies are supported by Lilactame Ltd, including the provision of a dedicated proposals map inset, and should be carried forward into the Local Plan Review, to ensure the long-term longevity and viability of the Airport.
National Policy
12.17 The Airport is located within the Green Belt and is therefore subject to national Green Belt policy, as set out within the NPPF, which addresses the proposed re- use of buildings.
12.18 Paragraph 145 of the NPPF (July 2018 version) sets out exceptions which are deemed appropriate development in the Green Belt. Subsection G of Paragraph 145 includes limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would:
• not have a greater impact on the openness of the Green Belt than the existing development; or
• not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to
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meeting an identified affordable housing need within the area of the local planning authority.
Proposed Development
12.19 Lilactame is promoting the Airport as a location for a mixed-use development, including new residential, employment retail and ancillary services. This growth will serve to cross-subsidise development to generate the capital necessary to upgrade the existing facilities on site, in association with supporting the existing significant levels of employment and provide additional benefits to the local economy. It will add a new element of residential development to the site to maximise the utilisation of the total land area. The proposal will potentially involve additional vehicular traffic to the site, and this will need to be established and suitably mitigated. In terms of the visual impact beyond the confines of the existing site, this is likely to be limited due to the significant screening effects of existing trees and other vegetation and the limited other consequences relating to such matters as scale of buildings, noise, air quality and flood risk. All of the above is currently being pursued in the context of the site being in the Green Belt.
12.20 It is noted that third parties have suggested that the Airport could be identified as the location for a new settlement which could contribute towards meeting the significant uplift in housing required in South Staffordshire as a consequence of the shortfall in the GBHMA. Lilactame is willing to work with the Council and other stakeholders to bring forward the benefits that could be associated with the site.
Pre-Application Discussions
12.21 Lilactame has entered into pre-application discussions with South Staffordshire District Council regarding the Airport and will continue to work positively and collaborative with the Council to secure the Airport’s future.
Green Belt Harm
12.22 As set out in Chapter 7 of this representation, it is consideration that Wolverhampton Airport serves a reduced function against the purposes of the Green Belt than identified in the Green Belt Study.
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12.23 In particular, the Green Belt Study identifies the site’s Green Belt designation as making a ‘strong’ contribution to assisting urban regeneration, by encouraging recycling of derelict and other urban land.
12.24 Lilactame Ltd strongly objects to this assessment, in that the Green Belt designation in this location actually serves to prejudice the recycling of brownfield land, as it limits the development and redevelopment opportunities at the Airport, particularly in respect of the existing Airport buildings.
12.25 Much of the any built development proposed by Lilactame at the Airport would take place within the previously developed portion of the site. In particular, the commercial element predominantly consists of limited infilling and the redevelopment of previously developed land. As such, it would not have any greater impact on the openness of the Green Belt than the site in its current form.
12.26 It is accordingly submitted that the area currently identified by existing Site Allocations Proposals Map Inset Plan 43 (Wolverhampton Halfpenny Green Airport) should be released from the Green Belt to facilitate development at the Airport.
Landscape Sensitivity
12.27 Lilactame Ltd has instructed Ecus Environmental Consultants Ltd to prepare a Landscape and Visual Appraisal (LVA) in order to assess the impact of a development at site.
12.28 There would be some beneficial landscape effects due to the replacement of dilapidated buildings and runways and unmanaged vegetative areas, which include Japanese knotweed. The Site would also become more accessible to the public with links to surrounding footpaths, and improvements to the airport after completion.
12.29 Inter-visibility between the Site and the area beyond the airfield tends to be limited by the dense perimeter hedge, low lying topography, scattered field trees and blocks of woodland.
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12.30 However, it is acknowledged that development at the site beyond the area occupied by existing buildings would have some degree of impact upon the wider landscape. This would be assessed as part of any planning application.
Sustainability
12.31 The Council’s Sustainability Appraisal (2019) does not consider site-specific details at this stage. Nevertheless, the development of the site presents the opportunity to provide on-site services and facilities, thereby improving the sustainability of the existing site, as well as benefitting the nearby village of Bobbington.
Flood Risk and Drainage
12.32 Environment Agency mapping indicates that the site is located wholly in Flood Zone 1. The site is at low risk of flooding from all other sources. Mitigation measures would be proposed to reduce the risk of flooding during extreme events as part of any development. The flood risk to the development is considered to be low overall.
12.33 The feasibility of infiltration techniques at this site would be discussed with the LLFA. A number of attenuation features may be proposed, comprising a combination of open ponds / wetlands, underground attenuation tanks and swales. Investigations will be needed to see if other locations can be suitably used. Other source control SuDS features would be implemented wherever possible, such as water butts, permeable paving or rainwater harvesting.
12.34 STW have confirmed that a surface water connection into their sewer is not appropriate in this instance. As the foul drainage from the site already drains to the Airport’s privately-owned sewage treatment works, it is anticipated that the new development drainage will also take this route, subject to an assessment and upgrade in size if required.
Highways (Accessibility to the Site)
12.35 The site lies within walking distance of a number of facilities and amenities, including the Corbett Primary School in Bobbington. The site is also close to parts of the PRoW network, with public footpaths leading from Crab Lane and providing alternative links to Bobbington. These PRoW routes would help to promote leisure
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walking for potential future residents at the site and the presence of numerous PRoW in this area suggests that there is a reasonable level of existing leisure walking activity that is already taking place involving the use of the local roads.
12.36 To support and promote sustainable travel practices amongst residents and employees at the site, a Travel Plan would support any proposed development and set out a framework for travel targets and identify proposed measures to help achieve these. Any development would also include off‐site measures to improve the environment for pedestrians and cyclists in the local area, and there is potential to explore bring community transport to serve the site in the future through a local bus service.
Site-Specific Opportunities
12.37 As set out previously within this Representation, the development of the site will serve to cross-subsidise development to provide the capital necessary to upgrade the existing facilities on site and support the existing significant levels of employment and provide additional benefits to the local economy. It will also add a new element of residential development to the site to maximise the utilisation of the total land area.
Suitability
12.38 The information set out above demonstrates that Wolverhampton Halfpenny Green Airport is a suitable site for development.
Deliverability
12.39 Lilactame Ltd owns Wolverhampton Halfpenny Green Airport and there are no existing uses that would require relocation and no known contamination issues that would require remediation. Many of the impacts of development can be mitigated and, in many cases, a positive outcome can be achieved.
12.40 The site is deliverable and immediately available and could deliver homes and associated community benefits within the next 5 years.
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Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
13. CONCLUSION
13.1 This representation is made by Pegasus Group on behalf of Lilactame Ltd Limited to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to Wolverhampton Halfpenny Green Airport, which Lilactame Ltd is promoting for a mixed-use development designed to facilitate and support the continued operations at the airport.
13.2 It is noted that third parties have suggested that the Airport could be identified as the location for a new settlement which could contribute towards meeting the significant uplift in housing required in South Staffordshire as a consequence of the shortfall in the GBHMA. Lilactame is willing to work with the Council and other stakeholders to bring forward the benefits that could be associated with the site.
13.3 The information contained within this representation, read in conjunction with the appended illustrative masterplan, demonstrates that Wolverhampton Halfpenny Green Airport is a suitable and deliverable site for development, subject to its release from the Green Belt.
13.4 It is therefore submitted that the area currently identified by existing Site Allocations Proposals Map Inset Plan 43 (Wolverhampton Halfpenny Green Airport) should be released from the Green Belt and allocated for development through the Local Plan Review, to facilitate development at the Airport.
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APPENDIX 1 Key Site Location
e*SCAPE urbanists Project Title Halfpenny Green Airport
e*SCAPE Job No. 017-030
Client MCR Property Group
Drawing Number Revision 017-030-P001 REV -
0m 200m 400m 600m 800m 1000m Drawing Title Site Location Plan Scale 1:25,000 (@A3) Scale Date Ordnance Survey © Crown copyright 2018. All rights reserved. Licence number LIG1024 1:25,000 @ A3 January’18