Local Plan Review Consultation Response Form Part A: Your Details (Please Print) Please ensure that we have an up to date email address wherever possible, or postal address, at which we can contact you. Your Details Agent’s Details (if applicable) Title Mr Mrs First Name Rob Rachel Last Name Boydon Best E-mail Address [email protected] [email protected] Job Title Operations Director Principal Planner (if applicable) Organisation Tardis Environmental UK Ltd Stansgate Planning Consultants Ltd. (if applicable) Address C/o Agent (ADM/RJB/8694) 9 The Courtyard Timothys Bridge Road Stratford-upon-Avon Post Code CV37 9NP Telephone 01789 414097 Number The South Staffordshire Local Plan review Spatial Housing Strategy & Infrastructure Delivery document is being consulted on for a period of 8 weeks from Thursday 17 October until 5pm Thursday 12 December 2019. For advice on how to respond to the consultation form please email [email protected] or call 01902 696000. Please note: • Comments must be received by 5pm on Thursday 12 December 2019. Late comments will not be duly made under the Regulations. • Please fill in a separate Part B for each paragraph/table/topic you are commenting on • Please explain your response where necessary Representations cannot be kept confidential and will be available for public scrutiny, including your name and/or organisation (if applicable). However your contact details will not be published. Part B: Please complete a new Part B for each representation you wish to make. Name: Tardis Environmental UK Ltd Organisation: C/o Stansgate Planning 1. Which part of the Local Plan review Spatial Housing Strategy and Infrastructure Delivery consultation does this representation relate to? Chapter 3 Paragraph Table Question (if applicable) 1 Other document eg SA, HRA 2. Please set out your comments below Do you agree that the evidence base used to inform the Spatial Housing Options is robust and proportionate? If not, what else should we consider? 2. WRITTEN JUSTIFICATION FOR REPRESENTATION We object to two elements of the evidence base that are not considered to be robust. These are: • The availability of sites – this relies solely on the SHELAA 2018 which is now 12 months old. It should be a ‘live’ assessment that takes account of any sites submitted anytime for assessment rather than fixed at a point in time, where no sites submitted after SHELAA 2018 are considered; • The Rural Services and Facilities Audit 2019 - the downgraded categorisation of Essington from Tier 2 to Tier 3 does not reflect the evidence of access to services and facilities using the assessment criteria in the Audit. The Audit ignores those facilities available beyond the development boundary which when accounted for, shows Essington scores more highly than shown. Furthermore, it is vital the Audit recognises the contribution of the conurbation to the relative sustainability of settlements. That does not appear to be any transport evidence. This could usefully provide information on the most accessible locations to guide development and focus the distribution strategy. There is guidance in the PPG. THE AVAILABILITY OF SITES Whilst it is right that sites must be deliverable and the purpose of the SHELAA is to inform site allocations with sites assessed to be deliverable, it must be a ‘live’ assessment that is not fixed at a point in time. It is already 12 months old and new sites will have been submitted to the Issues and Options Consultation that should be assessed and added. The District Council acknowledge the SHELAA is updated annually and sites can be submitted anytime. It should therefore be updated to take account of any additional sites presented or changes on sites assessed. It should be a starting point for site allocations to which sites can be added or amended as new factors become known. Other parts the evidence base have been updated following the Issues and Options Consultation that take account of comments made, but the SHELAA has not. My client submitted land to the SHELAA at Brownshore Lane, Essington in September 2018, regrettably too late to be included in the SHELAA published October 2018. Further details of the site, the constraints and the opportunities, were submitted in response to the Issues and Options Consultation November 2018 so the site is in front of the Council but is not included in the SHELAA 2018. Other parts the evidence base have been updated following the Issues and Options Consultation that take account of comments made, such as the Rural Services and facilities Audit, so why not the SHELAA too? The SHELAA is to be the main source of sites for allocation and the sites assessed are found from several sources, not just sites promoted by a landowner but also sites identified by the planning officers. In the case of Brownshore Lane, land all around it is assessed but not the site promoted by my client which is notable in its absence when surrounded by submitted sites. It could have been assessed in any event for completeness. The evidence base is not robust if it ignores opportunities coming forward post 2018 that were not known about at the time the SHELAA 2018 was prepared. The SHELAA should be regularly updated to pick up all opportunities. The Council are potentially missing opportunities and may allocate a less suitable site just because of the timing of submission. THE RURAL SERVICES AND FACILITIES AUDIT 2019 This audit assesses the rural settlements by their relative level of access to services and facilities, to provide a settlement hierarchy of Tier 1-5 settlements (with Tier 5 settlements being the least sustainable in these terms). It has been updated since the 2018 version as a result of comments on the Issues and Options consultation. The Audit is not robust for the following reasons: 1. The conclusions for Essington do not reflect the evidence; 2. It is fundamentally flawed as it fails to recognise facilities available in the conurbation; 3. The groupings of settlements within tiers is arbitrary; 1. The conclusions for Essington do not reflect the evidence Section 3 of the Audit provides the methodology for assessing the relative sustainability of settlements and lists five ‘Key Indicators’ which are: A. Access to food stores B. Diversity of accessible community facilities/services C . Access to employment locations D . Access to education facilities E. Public transport access to higher order services outside of the village The audit says how the key indicators will be measured and each indicator is assessed with its own colour banding. The colour banding for each indicator is shown on a summary sheet although it is a little confusing as each indicator has its own colour banding, rather than there being a standard banding for all indicators. B. Diversity of accessible community facilities/services Scored black, red, amber, green - Essington is ‘amber’ when it should be ‘green’ according to how the indicators are measured. Paragraphs 3.7 to 3.13 of the Audit say how these key indicators will be measured and the justification. Paragraph 3.9 states “For the purposes of this measure, the presence of facilities within walking distance but past the built-up boundary of a village will also be considered, where these can be accessed via safe and legible routes with well-lit footways. Facilities and services up to 1 mile (i.e. 1610m) walk away from the development boundary of a settlement along such routes will be recorded for this purpose.” Essington is an unusual case due to its close proximity to the edge of the conurbation and the 1 mile (1610m) walk distance opens up huge opportunities not available at most other settlements further from the urban edge. The district boundary does not stop access. Enclosed plan 8694-602 Facilities Plan shows 4 isochrones at the 1 mile (1610m) walk distance centred on the Development Boundary of the settlement at 4 places: • High Hill • Brownshore Lane • Upper Sneyd Road/Bursnips Road junction • Syend Lane/Red Lane junction The walking route from these points is on surfaced pavement with street lighting. • High Hill, Upper Syend Lane and Kitchen Lane - there is pavement on one side and street lighting is at frequent intervals. • Brownshore Lane - there is pavement on one side and one light at the bend in the road. • Syend Lane – there is pavement on both sides and street lighting at frequent intervals. Within these isochrones are a diversity of community facilities/services too numerous to show all on plan and due to the nature of the urban area there are a greater variety than available to most settlements. In the wording of the Audit ‘the greater the variety of the community facilities on offer, the more sustainable the location will be’. Plan 8694-602 Facilities Plan shows a great variety and the key lists the type and number. As an example of a few, not all as they are too numerous to list, the following key facilities are accessible: • Coppice Farm Way/Essington Road – supermarket and 4 shop units in a substantial purpose built local centre with parking and recycling centre • Coppice Farm – Sina Health Centre and Lloyds Pharmacy • Coppice Performing Arts Secondary School and sixth form • Ashmore Park - shopping centre with sub post office and specialist shops • Ashmoor Park - Corpus Christi Church, Social Centre and Primary School • Ashmoor Park - Griffiths Drive supermarket • Ashmoor Park - The Ashmore PH • New Invention The Square Lichfield Road supermarket • Sandlands Road shopping centre with at least 12 shop units, Library and adjacent public house Therefore, Essington has a vast range and quantity of facilities accessible within 1 mile of the development boundary on routes of sufficient quality to encourage walking and it should score ‘green’.