12 December 2019 Kelly Harris Strategic Planning Team Manager Strategic Planning Team Jessica Graham South Staffordshire Council E: [email protected] Council Offices DL: +44 (0) 121 634 8494 Wolverhampton Road Codsall 55 Colmore Row WV8 1PX Birmingham B3 2AA T: +44 (0) 121 200 4500 F: +44 (0) 121 633 3666 savills.com Dear Kelly Response to Local Plan Review Spatial Housing Strategy & Infrastructure Delivery Consultation Barratt West Midlands – Land at Dunsley Road, Kinver We are writing to you in response to the South Staffordshire Local Plan Review Spatial Housing Strategy & Infrastructure Delivery (‘SHSID’) document consultation on behalf of Barratt West Midlands who are promoting two sites at Dunsley Road, Kinver for residential development. This submission includes answers to the following questions set out in the consultation document: Question 1 Question 3 Question 5 Question 6 Question 7 Question 8 Question 9 Question 10 In support of these representations and the promotion of sites, we have attached a Vision Statement with this submission which sets out a Site Location Plan, summary of technical information, a Illustrative Masterplan and key benefits that the allocation of the sites for residential development could bring to the local community and wider district. The responses below should be read in conjunction with the Vision Statement. 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? We have made the following comments in regards to the evidence base documents listed in Section 3 of the ‘Spatial Housing Strategy & Infrastructure Delivery’ (‘SPSID’) consultation document and our client’s land interests to the north and south of Dunsley Road, Kinver. In addition to the documents listed in Section 3, we also consider that the Landscape Sensitivity Assessment (July 2019) and an updated Strategic Housing Market Assessment should also inform the Spatial Housing Options. Environmental Constraints We acknowledge that the Council has considered high level constraints which may constrain the level of growth in broad locations. During the next stage of the Local Plan process where the Council will allocate potential development sites, we request that the Council utilise any additional technical evidence that has been submitted to them by landowners / promoters / developers. This will ensure that the Council allocate sites which they can demonstrate are suitable and deliverable to the Inspector at Examination. In our representations to the Issues and Options consultation, we submitted a Highways and Access Statement, Heritage Appraisal and a Preliminary Landscape / Green Belt Advice Note which had been undertaken for our client’s land interests to the north and south of Dunsley Road. Since that consultation, our client has also obtained drainage, ecology and arboricultural advice. The recommendations that have been received from the Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.. Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD landscape, heritage, highways, drainage, ecology and tree specialists demonstrates that both parcels of land are suitable options for residential development and any development on the parcels could be designed to ensure that there would be a limited impact on the surrounding landscape and heritage assets. This information has been summarised within the submitted Vision Statement t and has been utilised to produce an illustrative masterplan for the two sites (page 22 of the Vision Statement). Rural Services and Facilities Audit In our previous representations to the Issues and Options consultation of the Local Plan Review, we objected to the proposed revised Rural Settlement Hierarchy and the categorisation of the village of Kinver as a proposed Tier 2 Settlement. In the adopted Core Strategy and Site Allocations Document, the settlements of Kinver, Perton, Wombourne and Brewood are identified as ‘Main Service Villages’. The Issues and Options document and this SPSID consultation document propose to re-categorise these settlements as Tier 2 Settlements. We still consider that no change should be made to the current adopted settlement hierarchy and that the sustainable settlements of Kinver, Wombourne, Brewood and Perton should continue to be identified as Main Service Village settlements. The village of Kinver provides a range of shops, services and facilities required in order to support significant residential growth which includes a wide variety of shops and services (at least 43 non-convenience shops), two primary schools, a high school and sixth form, a day nursery, two GP surgeries, 5 public houses, a library, a post office and various communities centres. From a review of Appendix 4 ‘Services and Facilities Audit by Settlement’ of the Rural Services and Facilities Audit (‘RSFA’), Kinver provides a greater range of services than some of the Tier 1 settlements. It is considered that the only key difference between the proposed Tier 1 settlements and the village of Kinver is that the Tier 1 settlements have access to a Train Station and a supermarket. A Train Station is not the only means of public transport and bus transport is also a sustainable transport option which is provided in Kinver. Additionally, the village of Kinver does not have a large supermarket but it does have smaller convenience stores and provides a much greater range of non-convenience stores than some of the proposed Tier 1 villages such as Great Wyrley, Cheslyn Hay and Bilbrook. Supermarket providers are attracted to areas that will generate significant footfall. By directing the majority of growth to the proposed Tier 1 villages, the Council will be reducing the potential of settlements in Tier 2, such as Kinver, to generate the footfall required for certain services and facilities, such as a supermarket. Furthermore, the opportunity to provide additional facilities such as a small supermarket, will only be enhanced in locations such as Kinver, where additional residential development is supported, thereby adding to its sustainability. Additionally, Appendix 5 ‘Settlement Hierarchy Scoring’ of the RSFA sets out that Kinver has ‘very low’ access to employment. The settlement of Kinver is located within a 30 minute bus journey from the employment provided within Stourbridge and from Stourbridge there are rail links to Kidderminster (10 minutes from Stourbridge), Worcester City Centre (30 minutes from Stourbridge) and Birmingham City Centre (33 minutes from Stourbridge). All of these major employment centres can therefore be accessed by public transport within 60 mins of travelling from Kinver. We therefore do not understand how Kinver has been assessed as having “very low access to employment” and consider that it should be reassessed to correctly acknowledge the existing public transport links that provide sustainable connections to a wide range of employment locations. In summary, we still do not consider that the Council has sufficiently justified why there is a need for the adopted settlement hierarchy to be amended. It is considered that the modified Main Service Village settlements, which currently includes the settlement of Kinver, should remain as Main Service Villages as they are sustainable settlements which are capable of supporting significant residential growth. The approach being taken has the risk of constraining the growth of some Main Service Villages by not supporting growth, thereby constraining their potential to deliver more services. 2 The Availability of Sites We support the Council’s proposal to consider the sites that are included in their SHELAA. However, we consider that the SHELAA should be updated to include information that has been submitted to the Council since 2018. In February 2019, our client submitted revised site boundaries for their sites to the Council in order to reduce the site area being promoted on the northern site from 19.46 hectares (48.09 acres) to approx. 13 hectares (32 acres) (SHELAA Site 549) and the southern site from 8.52ha (21.05 acres) to approx. 3.5 hectares (9acres) (SHELAA Site 550). This amendment was undertaken following additional technical work and it is considered that the scale of the revised sites is a more appropriate extension to the settlement of Kinver. We request that the amended site boundaries are included within the SHELAA 2019 that the Council should produce and use to inform their site selection process. Infrastructure Delivery Plan We support the use of the Infrastructure Delivery Plan (IDP) 2019 to inform the broad locations of growth. The IDP sets out potential projects within Kinver. These include new signage along the canal network in Kinver and potential junction improvements. The Appendix B of the IDP sets out infrastructure concerns. Within Kinver these include local road capacity concerns at Potters Cross Junction, parking concerns within the village centre and GP capacity concerns within the village. We consider that none of the infrastructure concerns are so significant that the village would not be able to accommodate further housing growth. The infrastructure projects and concerns could be addressed through S106 contributions from additional housing growth in the village. Additionally, as part of our client’s promotion of their sites, they