SOUTH STAFFORDSHIRE COUNCIL – LOCAL PLAN REVIEW – 2018 - 2037 SPATIAL HOUSING STRATEGY & INFRASTRUCTURE DELIVERY – OCTOBER 2019 LAND AT LANDYWOOD – GREAT WYRLEY KGL (HOLDINGS ) LTD: Mr C WALLACE & Mrs SNAPE 1. I refer to the above consultation and confirm that I act for the owners, as above, of the land identified on the attached plan . 2. Firstly, the approach in the Review which states that areas of safeguarded land will become housing land allocations, is welcomed and endorsed . In the context of my client’s land which is already allocated and safeguarded, this will enable a comprehensive scheme for these areas to come forward, consistent with the need to ensure public safety within the areas concerned. 3. However, my clients wish their land, as above, to be considered for future housing development either independently or, in association with the above land parcels, as part of an overall comprehensive scheme thereby providing the potential to incorporate employment and other uses, as appropriate, in a highly sustainable location. 4. The land parcels concerned which are owned by KGL (Holdings) Ltd., have previously been considered in the 2018 SHELAA (site refs. 136 and 137) and categorised as “potentially suitable”. 1 5. It is noted that the Green Belt Study 2019 (GBS) assesses the impact upon the green belt of development on the land east of Upper Landywood Lane now being promoted as “moderate” , with the following explanation: “The sub-parcel (S21A) makes a strong contribution to preventing sprawl of the large built-up area of Cannock/Great Wyrley and to preventing encroachment on the countryside, and a moderate contribution to maintaining the separation between the neighbouring towns of Great Wyrley and Bloxwich. The sub-parcel is contained on three sides by the settlement edge of Great Wyrley/Cheslyn Hay, but retains strong spatial openness within. Due to the extent of its containment, the release of this subparcel would lead to a simpler and more consistent Green Belt boundary, which would now lie along Upper Landywood lane to the south, without significantly weakening the integrity of adjacent Green Belt land to the south. (my emphasis) 6. Moreover, the GBS assesses the impact upon the green belt of development in land parcel 137, west of Upper Landywood Lane, as “moderate-high” with the following explanation: The sub-parcel S20B “..has strong spatial openness but is somewhat contained by surrounding urbanising uses, and the nature-designated area around the former Wyrley and Essington canal (Forest of Mercia Way) contains the land and limits its relationship with the wider countryside. As such, releasing this land would not significantly weaken the integrity of surrounding Green Belt land, given the role of the clear boundary provided to the south. It should be recognised that releasing this land would lead to the almost complete containment of neighbouring sub- parcel S21A, leaving little justification for the latter remaining within the Green Belt, however this would not increase the overall degree of harm.” (my emphasis) 2 7. Noting that the assessment above for sub-parcel 21A does not have regard to the public open space proposal within the adopted SAD (this proposal must reduce any potential green belt harm), these assessments are generally agreed and, in particular, simpler and enduring green belt boundaries would clearly result from the allocation of these two parcels for development “..without significantly weakening the integrity of adjacent green belt areas to the south.” Moreover, the degree of green belt harm is in stark contrast to some proposals which form the basis of the Council’s preferred Option G – please see below. 8. It is further noted that the Landscape Study 2019 (LS ) assesses the two parcels as having “low-moderate” overall sensitivity to residential development. “The larger scale, generally flat topography, together with lack of time depth in much of the area indicates lower sensitivity. However, this is counterbalanced by the importance of the area in providing a rural gap between Great Wyrley and Cheslyn Hay. The strength of the landscape pattern and rural perceptual qualities increase to the south of the area around Upper Landywood”. 9. Again, whilst generally supporting this assessment, it does not have regard to the public open space proposal within the adopted SAD which substantially maintains the “gap”. Moreover, the sub parcel evaluated includes a large area of land beyond my clients to the east and south east where, inter alia,, “rural perceptual qualities increase” , which may have distorted the overall assessment. 10. Despite the above assessments of the land, the Council’s currently preferred Option G rules out any further new housing in Cheslyn Hay/Great Wyrley beyond that provided for in the currently allocated and safeguarded sites. 3 11. This is on the alleged basis that (page 21 of Appendix 3) “.. there do not currently appear to be the same opportunities to address infrastructure needs through new development when compared to other Tier 1 villages” and “larger strategic site options with significant on site infrastructure offers exist on the northern edge of the Black Country and in the vicinity of ROF Featherstone which may be more sustainable alternatives given the locations which drive unmet housing needs in the wider housing market area”. 12. It is not at all clear from published documentation what infrastructure needs (or indeed what spare infrastructure capacity exists) have been identified for Cheslyn Hay/Great Wyrley or, indeed, why these cannot be addressed “through new development” . Representations made on recent planning applications suggest that there are issues regarding drainage; highway capacity; existing play provision and education etc., albeit not all assertions are borne out by statutory consultees’s responses. However, these and related mattes clearly need further consideration and evaluation. 13. Furthermore, the assertion that larger strategic developments may be “more sustainable alternatives” is highly questionable given the relative sustainability credentials of these locations and those of my clients’ land and the proximity of my clients’ land parcels to the conurbation edge and the ability to access these areas by public transport. 4 14. Cheslyn Hay/Great Wyrley is one of three localities which are now re-classified in the Rural Services and Facilities Audit 2019 (RSF) as Tier 1 settlements along with Penkridge and Codsall/Bilbrook. “These settlements typically have food stores, a wider range of services and facilities than other villages, a range of education establishments, access to a train station and good access to employment and wider facilities outside the village via public transport.” (page 11 of the RSF). Moreover, Cheslyn Hay/Great Wyrley contain “..the largest proportion of the District’s young population when compared to all other tier 1-4 settlements meaning additional housing may assist in providing new homes for these residents should they seek to remain in the area within which they grew up ..” (Appendix 3, page 12) 15. From the published documentation, it is clear that within all the options put forward which can actually meet the housing requirement as stated, a significant area or areas of land will need to be removed from the green belt (either as allocations or future areas of safeguarded land). 16. The NPPF is clear (para. 78) that, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. This approach supports a pattern of development which facilitates sustainable transport modes, including walking, cycling and use of public transport and minimising journey lengths to employment, shopping, leisure, education and other activities. Development also should maximise the opportunities to use existing and proposed transport infrastructure. 5 17. Furthermore, the NPPF (paras. 92; 102, 103 and 104) encourages that an integrated approach is used in considering the location of housing, employment uses and community facilities and requires plans and decisions to ensure developments that generate significant movements are located where the need to travel will be minimised and use of sustainable transport modes can be maximised. 18. It is agreed that, in the case of South Staffordshire, which has relatively few employment opportunities within its existing settlements when compared to the centres of adjacent towns/cities which border the district, the availability of public transport access to employment is particularly important. 19. Considering the Council’s preferred Option G in this context, it is noted the employment/warehousing led proposal west of ROF Featherstone is to provide some 23% of the new housing allocation, whilst allocations adjoining the Black Country are to provide some 39% of these new allocations. 20. These “unique infrastructure opportunities” west of ROF Featherstone closely align to an area of ‘very high’ harm Green Belt , as identified in the GBS. It is also noted that the SHELAA describes the location as “not disassociated from the urban area” . This description is challenged. The proposal will create new housing in a totally isolated location, devoid of any community and related facilities and unrelated to any urban area and related facilities and with no certainty of creating sustainable transport modes. 6 21. From documentation considered to-date, the feasibility and viability of the overall proposal at ROF Featherstone appears to be still under evaluation. Moreover, a decision on the proposed West Midlands Interchange (Strategic Rail Freight Interchange) (SRFI) is anticipated during the early part of 2020. This proposes some 743,200m2 of new rail-served and rail-linked warehousing and other associated development on land west of Junction 12 of the M6 in South Staffordshire and will create some “..8,550 direct jobs boosting opportunities”. If the SRFI proposal is approved, there would be no need for ROF Featherstone warehousing led scheme and no need, therefore, for the enabling housing development. 22. A Strategy that relies upon this proposal can, therefore, only be described as “high risk”.