Comment

Representation ID: 22488

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Appendix 1 - Dudley Green Belt site options discounted but potentially capable of delivery [table] [see attachment]

[Taken table headings, presented here as headings:]
Ward/Site Reference/Site area

/Comments on site assessment [appears below these]:

Pedmore and Stourbridge East SA -0031 -DUD 19.8

Appears reliant on Green Belt/landscape factors in part for discounting. Heritage impacts cited as part of reason for unsuitability but no indication of 'substantial
harm'. Appears to have site frontage directly onto main road (Pedmore Lane); unclear why access is a constraint.

Kingswinford North and Wall Heath SA -0114 -DUD 27.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
Unclear why access could not be achieved through adjacent parcel (SA-0017-DUD)

Kingswinford North and Wall Heath SA -0033 -DUD 1.7

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
SLINC appears to be the only constraint preventing delivery of a site in otherwise less harmful Green Belt/landsacpe area.

Cradley and Wollescote SA -0034 -DUD 13.8 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only partially covers the site and the remainder could be feasibly considered

Cradley and Wollescote SA -0081 -DUD 64.2 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting archaeology is prohibitive.

Pedmore and Stourbridge East SA -0250 -DUD 20 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' to SAM indicating proximity is prohibitive.

Halesowen South SA-0088-DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' due to heritage effects; only a 'potential' to impact upon
setting.

Halesowen South SA-0087-DUD-B 30

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC/Ancient Woodland only cover small part of site and could be designed around.
Access concerns may be addressed through delivery alongside adjacent parcels (e.g SA-0242-DUD)

Halesowen South SA-0015-DUD 14.7

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why access onto Lapal Lane has been treated as a constraint as site appears to have
access onto other roads which could provide a satisfactory access

Halesowen South SA-0242-DUD 150

Appears reliant on Green Belt/landscape factors in part for discounting. Scale of potential development could deliver singificant scope for highways/access solution
and on-site facilities. SINC/SLINC/Ancient Woodland/Flood Zones only cover small part of site and could be designed around. Impacts around surface water aren't
clearly set out but at this scale it seems unlikely that they could not be designed around. No indication/evidence for why the potential harm on SAM setting is
considered to be substantial and therefore prohibitive. This appears to closely align to a recommendation made by the GBHMA Strategic Growth Study for a 1,500-
7,500 dwelling SUE South of Halesowen which doesn't appear to be given weight in site selection.

Hayley Green and Cradley South SA-0135-DUD 54 Unclear why SINC/SLINCs crossing site are considered prohibitive given significant site area - offers opportunity to design around these.
Halesowen South SA-0255-DUD 5.2 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0246-DUD 64 Appears reliant on Green Belt/landscape factors in part for discounting.

Sedgley SA -0125 -DUD 5.8

Appears reliant on Green Belt/landscape factors in part for discounting. Given the limited cover of pylons within the site, the significant site area and that the bat
corridor is only adjacent (not covering) the site, it is unclear why these constraints can't be overcome.

Pedmore and Stourbridge East SA -0018 -DUD - C 4.7

Text on page 106-107 indicates the site (Worcester Lane South) is suitable for development alongside adjacent parcels, acknowledging the potential to create a new
defensible boundary to the south; unclear why it hasn't been selected.

Pedmore and Stourbridge East SA -0251 -DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC only cover a small portion of the site and it is unclear why they cannot be
designed around.
Norton SA -0019 -DUD 1.37 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only affects limited area of site.

Gornal SA - 0139 -DUD 0.06

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why settlement pattern is considered a prohibitive constraint given the need to
increase densities within the Black Country.
Norton SA -0009 -DUD 1.19 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0091-DUD 2.73 Appears reliant on Green Belt/landscape factors in part for discounting.

Hayley Green and Cradley South SA-0244-DUD 1.5 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC/TPO coverage is only partial and majority of the site appears unaffected.

Norton SA -0018 -DUD - A 38

Appears reliant on Green Belt/landscape factors in part for discounting. Areas of lesser Green Belt harm with 20ha of non-SINC land; unclear why trees scattered
throughout site cannot be designed around/mitigated.


Norton SA -0018 -DUD - B 167

Appears reliant on Green Belt/landscape factors in part for discounting. Partial coverage of SINC/SLINC within the site but given the large site size (167ha) it is
unclear why impacts cannot be mitigated through scheme design. Intervisibility with SAM and archaeological factors given, unclear from information provided why
these would be prohibitive towards development or whether there would be substantial harm to heritage.

Gornal SA -0059 -DUD 10.6

Unclear from the information provided why the site is considered not deliverable within the plan period, despite the site proforma otherwise indicating that site
issues can be mitigated.

Cradley and Wollescote SA -0027 -DUD 6.87

Appears reliant on Green Belt/landscape factors in part for discounting. Given the site size it is unclear why the loss of a limited area of SLINC (hedgerow) loss could
not be mitigated within the wider site.

Gornal SA-0243-DUD 50.18

Appears reliant on Green Belt/landscape factors in part for discounting. Majority of the site (between Cotwall End Rd and Sandyfields Rd) appears to be a golf
course and it is unclear why this use precludes redevelopment.
Lye and Stourbridge North SA -0227 -DUD 2.13 Appears to be listed as a rejected site but is allocated elsewhere in the Draft Plan (but only for part of the site area - see DUH025)