Policy CSA2 – Fallings Park Strategic Allocation

Support

Representation ID: 22041

Received: 08/10/2021

Respondent: Sandhills Estates Ltd

Agent: Planning & Urban Design Solutions

I write on behalf of Sandhills Estates Ltd, the owner of land at Grassy Lane, Wolverhampton - site ref WOH264 - to support of proposed Strategic Allocation CSA.2 Fallings Park.

Key points to note are
* that given the evidence of the scale of housing need in the Black Country and the available capacity of the area to accommodate new housing development, it is clear that exceptional circumstances exist to release land from the Green Belt and that the requirements of para 140 of
the National Planning Policy Framework in this regard are met
* that the land scores Low-Moderate in the Black Country Green Belt Study and so is amongst the areas most suitable for release from the Green Belt
* no physical constraints on development exist and the land could be brought forward for immediate development
* the site could be developed independently of in conjunction with other land within the proposed
Strategic Allocation.

Further detail in these respects was provided in the response to the Black Country Call for Sites (ID ref 47) including illustrative layouts of development of the Grassy Lane site and of the wider area.

As stated in that response, the owner (copied in here) is keen to work with Wolverhampton City Council and other interests in the area to detail and bring forward development. Such a joint approach is consistent with the requirements of paras D.49 and D.51 of the Draft Black Country Plan and would allow the considerations set out in paras D.52-64 to be taken forward positively &
collaboratively.
In this last respect, I look forward to rejoining with the City Council in due course.

Object

Representation ID: 22553

Received: 04/10/2021

Respondent: Mr Michael O'Kelly

Number of people: 2

Building either side of Wood Hayes Road. Greenbelt farmland.
bullet points.
1. This is greenbelt and should not be built on!
2. I purchased my property based on its location with a countryside view.
3. The price I paid would have been reflected in point 2 above.
4. If built on my property will loose value.
5. Traffic volume will increase for both construction and when completed for new properties.
6. The road is not suitable for such a project in its construction development nor access for properties.
7. The land was always meant to be left for the people of Wednesfield hence the farm use

Comment

Representation ID: 23199

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

Object

Representation ID: 23380

Received: 11/10/2021

Respondent: Councillor Adam Collinge

In relation to wider strategic proposals, I note that the Council has promoted greenfield and green belt Council owned land into the plan and draw attention to Wood Hayes open space (WOH271/CSA2)) /playing fields and land at Grapes Pool/Moseley Road (WOH273). These areas I believe will be highly valued by local residents. I note that Paragraph 99 of the National Planning policy Framework (NPPF) protects open spaces and playing fields and this may have been a legitimate stance to take in terms of strategy in relation to all open space. Para 99 reads: "Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use".

Whilst there may be the intention of wider open space enhancements or provision, the clear purpose of the strategic releases is housing development; therefore Part c) does not appear relevant and it is difficult to understand at this stage the wider open space provisions that could be made. At this stage, I cannot see from the evidence a clear assessment as to why the playing fields/open space have been declared surplus to requirements by the Council, with reference to relevant open space standards adopted by the Council. In this case, I believe it would likely be useful to assess the land in the context of wider population growth to 2039 (over the plan period), the pressure this would place on open space standards and also accounting for any cumulative effects from adjacent proposals by other authorities. Additionally, Part b) of Para 99 requires replacement provision of better quantity and quality. Irrespective of any enhancements elsewhere, the total amount of accessible open space will likely reduce as a result of allocation and any future development and this would be adverse in relation to quantity open space standards and how this relates to future population growth. I believe existing opens spaces and playing fields can be protected under Paragraph 99 and should not be released for development without clear transparent evidence they are surplus to requirements.

Object

Representation ID: 23402

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

WOH 262/263/264/271 Wolverhampton Wednesbury
The land is largely agricultural. It is unclear that there is a clearly defensibly Green Belt boundary, apart from the South Staffordshire District boundary. There is, therefore, a risk of further green belt loss as far as Blackhalve Lane. Linthouse Road is, however, well-served by public transport.
Green Belt assessment in Land Use Consultants’ 2019 Green Belt Study – Low

Object

Representation ID: 43844

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

1. INTRODUCTION
1.1. This is a representation to the Regulation 18 Draft Black Country Plan which is subject to consultation until 11 October 2021. It is made on behalf of St Philips in respect of land they are promoting for residential development at Blackhalve Lane, Wolverhampton.
1.2. A Vision Document for the site has already been submitted and is included again with this submission. The site largely falls within South Staffordshire with the area to the south falling within the Wolverhampton City boundary.
1.3. The Vision Document explains the background work that has been undertaken and how the site constraints and characteristics have influenced a framework masterplan, which St Philips would like both Wolverhampton City and South Staffordshire Councils to consider. Similar representations will be made to the South Staffordshire Preferred Options plan, where consultation is due to begin in the coming weeks.
1.4. The following document covers a number of policies and paragraphs in the plan which are considered to be relevant to St Philips and/or the site they are promoting. St Philips reserve the right make further representations in due course. It should be noted that not commenting on an aspect of the emerging plan does not mean they agree with that content.
1.5. The remainder of this representation document is as follows:
· Representation
· Conclusion

2. REPRESENTATION
2.1. St Philips would like to begin by expressing their support for the allocation of the land (inside the Wolverhampton CC boundary) at Blackhalve Lane, particularly as it relates well to the existing established settlement edge, with the opportunity to provide a more definitive boundary to the Green Belt beyond.
2.2. The following table summarises the policies that we have commented on in this representation: Table 1 – Policies/Paragraphs subject to comment:
Policy/Para Title Page
HOU1 Delivering Sustainable Housing Growth 89 (Table 3 and Table 4)
HOU2 Housing Density, Type and Accessibility 96
HOU3 Delivering Affordable, Wheelchair Accessible and
Self Build / Custom Build Housing 101
CC2 Energy Infrastructure 267
CC7 Renewable and Low Carbon Energy and BREEAM
Standards 290
HOU1 – Delivering Sustainable Housing Growth and WOH271 FPNGA - Land east of Wood Hayes Road, Wolverhampton and CSA2 Fallings Park Strategic Allocation.

2.3. The land east of Wood Hayes Road is proposed to be allocated for about 40 dwellings at a density of around 25 dwellings per ha. We consider this could be increased on the basis that there are opportunities within the wider side for compensatory access to open spaces, should the wider site be included as an allocation in the emerging South Staffordshire Local Plan. Moreover, a development density of around 30 dwellings per ha would be more aligned to the established densities within the immediate vicinity of the site.

2.4. The site would fall into the ‘Fallings Park’ strategic housing allocation for this edge of the city, which is proposed as an allocation under Policy CSA2 for around 300 dwellings, plus open space and other facilities.
2.5. It is noted that the council expect the partners within the allocation to enter into dialogue over the delivery of the allocation as a strategic whole and this is something St Philips welcome and would like to take part in, particularly where it relates to ensuring there is adequate apportionment over school place impacts, highways impacts, provision of green infrastructure (including recreational open space) and biodiversity net gain.

4. CONCLUSION
4.1. Overall St Philips welcome the inclusion of their site east of Wood Hayes Road as part of the Fallings Park strategic allocation and its removal from the Green Belt. We agree with the reasoned justification and evidence that underpins the approach the city council have taken so far. St Philips will make further representations to the emerging South Staffs Local Plan when the consultation begins as they believe there is an opportunity for further land to be included in this allocation within their administrative boundary.

4.2. They fully intend to cooperate with the other landowners/promoters of the parcels within the allocation and agree that a holistic approach is clearly preferable. Whilst St Philips have prepared a Vision document for the site, this is subject to further conversations with the other partners within the allocation.

4.3. We have made comments on more generic planning policies where we consider it is justified, and we urge the BC councils to consider the points we have made.

Object

Representation ID: 43850

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

1.0 INTRODUCTION
1.1 This Representation has been prepared by Pegasus Group on behalf of Taylor Wimpey UK Ltd (hereafter referred to as 'Taylor Wimpey') to respond to the Draft Black Country Plan 2039 (Regulation 18) Consultation (hereafter referred to as 'the Plan') and accompanying published evidence.
1.2 This representation relates to Land North of Grassy Lane (Site Ref: WOH263), which is allocated for approximately 80 dwellings within the Plan as part of the wider Fallings Park Strategic Allocation (Policy CSA2) (see Site Location Plan at Appendix 1 to this Representation).
1.3 Land North of Grassy Lane forms part of a wider land holding known as Land at Linthouse Lane, which Taylor Wimpey is promoting for a residential-led development through both the Black Country Core Strategy Review and the South Staffordshire Local Plan Review (see Promotional Document at Appendix 2).
1.4 This representation is prepared in the context of national planning policy which requires local plans to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework ('NPPF') at paragraph 35. For a development plan to be considered sound it must be:
· Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreement with other authorities, so that unmet need from neighbouring areas is accommodated where it is practicable to do so and is consistent with achieving sustainable development;
· Justified – an appropriate strategy taking into account the reasonable alternatives, and based on proportionate evidence;
· Effective – deliverable over the plan period and based on effective joint working on cross boundary strategic matters that have been dealt with rather than deferred, as evidenced by the Statement of Common Ground; and
· Consistent with National Policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
1.3 This representation also considers the legal and procedural requirements
associated with the plan making process.

2.0 THE SITE
2.1 Taylor Wimpey is in control of land referred to as Land North of Grassy Lane (Site Ref: WOH263), which is allocated for approximately 80 dwellings within the Plan as part of the wider Fallings Park Strategic Allocation (Policy CSA2).
2.2 Land North of Grassy Lane forms part of a wider land holding known as Land at Linthouse Lane, which Taylor Wimpey is promoting for a residential-led development through both the Black Country Core Strategy Review and the South Staffordshire Local Plan Review (see Location Plan at Appendix 1).
2.3 A Promotional Document is included at Appendix 2 to this Representation which provides information relating to Green Belt, landscape and visual impact, ecology, transport, flood risk and drainage, and agricultural land quality. In addition, a development brief has been prepared which sets out how the proposal could deliver a strategic housing allocation in a fundamentally sustainable fashion and can readily integrate itself with the surrounding urban edge of Wolverhampton.

13.0 SUB-AREAS AND SITE ALLOCATIONS – WOLVERHAMPTON
13.1 Chapter 13 of the Plan concerns Sub-Areas and Site Allocations and is split into four parts concerning Dudley, Sandwell, Walsall and the City of Wolverhampton. This Representation concerns the City of Wolverhampton sub¬area and the Fallings Park Neighbourhood Growth Area.
13.2 Taylor Wimpey supports the recognition in the introductory paragraphs (D1-D5) that Wolverhampton plays a significant role in contributing towards the employment and the Black Country economy. However, it is submitted that the paragraphs should also recognise the role the City plays in terms of housing. In particular, it is paramount to recognise that the City is one of the 20 local authorities which are subject to a 35% 'uplift' under the Government's Standard Method for calculating housing need.
13.3 This should also be reflected within the vision presented at paragraph D6, which begins by confirming the aspiration for the City is to be "a place where people come from far and wide to work, shop, study and enjoy...". This opening statement should include being a place where people want to 'live'.
13.4 Policy CSA 2 concerns the Fallings Park Strategic Allocation and is preceded by a map on page 624 which illustrates how the strategic allocation is comprised of four individual allocations (refs: WOH263, WOH264, WOH262 and WOH271). Whilst this map is useful in clarifying the composition of the allocation, it is not understood why the lines which delineate the individual allocations overlap one another in places (WOH262 and WOH263), and fall slightly short of the full extent of the strategic allocation in others (north of WOH263). There is also a small area of the strategic allocation along the western edge of WOH271 which does not appear to be covered by any individual allocation. It is not understood whether these are drawing errors or whether clarity is required regarding the actual extent of the four individual allocations.
13.5 Paragraph D47 confirms that the individual allocations are collectively anticipated to deliver approximately 303 homes at an average density of 40dph (excluding WOH271). This includes 1 hectare of central public open space to be delivered on allocation WOH262. This is supported by Taylor Wimpey, although the Plan should be clear that the density referred to is a net, rather than gross, figure.
13.6 However, paragraph D51 goes on to confirm that "...a masterplan will be prepared to guide the comprehensive development of the Fallings Park Strategic Allocation". Paragraph D55 also states that details of major highways improvements along Cannock Road and Wood Hayes Road are likely to be required and will be detailed within the masterplan.
13.7 The principle of an allocation-wide masterplan is not disputed by Taylor Wimpey. However, the Plan is not clear as to the format or timescales of such a masterplan. The current wording implies that this will be in the form of a supplementary planning document to be produced following the adoption of the Plan. This would not be supported by Taylor Wimpey. Any masterplan should be produced now and should be integral to the Plan. Furthermore, any masterplan should consider how allocations in neighbouring South Staffordshire (specifically Policy SA3 – Strategic development allocation: Land North of Linthouse Lane) influence and interact with the allocation within the Black Country Plan. It is suggested that a significant amount of this masterplanning work has already been undertaken by Taylor Wimpey (see Promotional Document at Appendix 2 to this Representation).
13.8 Paragraph D56 stipulates that mitigation for the loss of Green Belt at the Strategic Allocation will be provided through improvements to the significant areas of recreational open space located in the nearby Bushbury Hill area, which are owned and managed by City of Wolverhampton Council. Paragraph 61 also confirms that these areas could also be utilised as part of securing 10% biodiversity net gain for the allocations. An off-site approach is supported by Taylor Wimpey and the suggested location is broadly considered to represent a logical approach to both Green Belt and biodiversity mitigation.
13.9 However, Paragraph D57 goes on to require all Green Belt loss mitigation works and any necessary transfer of land ownership to be completed before 'substantial completion' of development at the Strategic Allocation. This is not supported by Taylor Wimpey, as it may unnecessarily delay the delivery of much needed housing through the allocation, should unforeseen delays arise that are beyond the control of either the applicants or the Council.
13.10 Notwithstanding this, there is also no clarity as to what constitutes 'substantial completion' of the development. It is submitted that it is not necessary for the mitigation to be in place prior to the completion of the development, as long as any necessary contributions towards that mitigation have been secured.
13.11 Lastly, it is submitted that, given the interrelationship between the Black Country allocation and the neighbouring strategic allocation in South Staffordshire District (Land North of Linthouse Lane), the land within South Staffordshire also represents a significant opportunity for providing biodiversity net gains. As illustrated within the Promotional Document at Appendix 2 to this Representation, a significant portion of Land North of Linthouse Lane is to be delivered as a country park and therefore provides a significant opportunity for biodiversity net gain. As such, a collaborative approach is considered to be most appropriate regarding biodiversity in this location.

14.0 DELIVERY, MONITORING AND IMPLEMENTATION
14.1 This section of the Plan merely sets out the Black Country Authority's commitment to monitoring the implementation of the plan and to ensure it is delivered successfully, efficiently and working in partnership with stakeholders. It sets out that the purpose of the monitoring indicators identified in the PLAN is to assess the performance of the plan in delivering the spatial vision, identify the need to amend the policies and to demonstrate that the plan is deliverable. It also indicates that the Plan is prepared to be flexible over the plan period and adjust where changes arising. The one obvious omission in considering these factors is how the plan will relate to the shortfall in housing supply over the plan period which amounts to some 28,000 dwellings. Other plans including the currently adopted Birmingham Development Plan, had provisions within it to deal with occurrences where the shortfall was not being addressed. The Plan does not include this and therefore requires further consideration by the relevant authorities.

15.0 LAND NORTH OF GRASSY LANE, FALLINGS PARK (WOH263)
15.1 Taylor Wimpey is in control of land collectively known as Land North of Linthouse Lane, Wolverhampton, as shown on the Site Location Plan included at Appendix 1 to this Representation. This includes land located within both the City of Wolverhampton and South Staffordshire District.
15.2 The land which falls within the City of Wolverhampton is identified within the Plan as Land North of Grassy Lane, Fallings Park (site ref: WOH263). This site is identified as comprising 2.7 hectares of land and as being capable of accommodating 80 dwellings (at 40 dwellings per hectare, net), following its removal from the Green Belt. Taylor Wimpey supports this allocation.
15.3 Pegasus Group has prepared an Illustrative Development Framework Plan on behalf of Taylor Wimpey which shows how site WOH263 might come forward for development (see page 45 of the submitted Promotional Document). The Illustrative Plan also shows how site WOH263 might interact with neighbouring allocations WOH262, WOH264 and WOH271, although it should be made clear that Taylor Wimpey does not control these other allocation parcels.
15.4 The Framework Plan illustrates how the Fallings Park allocation will be accessed from Cannock Road (A460) to the west, with a network of secondary and tertiary streets connecting the four development parcels. The allocation includes a centralised area of open space within parcel WOH262, as required by the Black Country Plan.
15.5 The Framework Plan also illustrates how the Fallings Park Allocation has the potential to link into further land within South Staffordshire District to the north, controlled by Taylor Wimpey.
15.6 Pegasus Group and Taylor Wimpey will continue to refine proposals for the site going forward, in conjunction with the neighbouring landowners and promotors. less

Object

Representation ID: 43896

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

WOH263 Land North of Grassy Lane, Fallings Park, Wolverhampton

WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.

Object

Representation ID: 44759

Received: 05/10/2021

Respondent: Pamela & Trevor Brown

Number of people: 2

Pamela Brown

Re using green belt land wood hays Lane Wednesfield

I oppose building all these houses on country side land which is in short supply anyway in this area . It will damage all wildlife , trees and fauna . The green land is a pleasure to see and walk on and brings relaxation to people. We cannot cope with more cars and pollution and people in the area. It is bringing in the value of our property down , if we had wanted to live in a built up area we would have bought there but we choose country side to enjoy . Don’t do it !!

Object

Representation ID: 44760

Received: 05/10/2021

Respondent: Pamela & Trevor Brown

Number of people: 2

Re: Re using green belt land wood hays Lane Wednesfield

I oppose the building of more houses on the green belt land in the areas stated. Green belt land is at a premium in these areas and should be preserved and not destroyed. Is any thought given to the people who cherish their semi rural location who have probably lived there for many years and will find themselves being engulfed in a large development.
More and more houses will mean more and more cars, more and more cars will bring more and more pollution, more congestion on already very busy roads, more and more people living in areas already struggling to cope with inadequate doctors, dentists etc. Building these houses will move the green belt further and further out and eventually destroy it completely which in my and thousands of others opinions should NOT happen
Trevor Brown