Proposal: Outline planning permission for 40 dwellings

Objection to planning application 20/00621/OUT

Application number: 20/00621/OUT

Proposal: Outline planning permission for 40 dwellings

Site Address: Land South of White Hill, Kinver (site reference 274)

OBJECTION

By Fiona Holloway BSc FCA CTA, for and on behalf of the Kinver Green Belt

Action Group

October 2020

Objection report – 20/00621/OUT

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Table of Contents

1. INTRODUCTION AND DESCRIPTION OF THE SITE ......................................................... 3

2. OBJECTION ................................................................................................................ 4

3. GROUNDS FOR REMOVAL OF LAND FROM GREEN BELT AND 2018 SITE ALLOCATION ..... 5

4. SAFEGUARDED LAND .................................................................................................... 7

5. FLOOD RISK and DRAINAGE .......................................................................................... 8

6. TRANSPORT ASSESSMENT ............................................................................................. 9

7. ECOLOGY AND HABITAT LOSS ..................................................................................... 12

8. FACILITIES AND INFRASTRUCTURE ............................................................................... 15

9. HOUSING MIX ............................................................................................................. 17

10. PLANNING POLICY EQ4 .............................................................................................. 18

11. CONCLUSIONS ........................................................................................................... 19

Appendix 1 - Flooding .................................................................................................... 20

Appendix 2 - Traffic congestion (all photos taken October 2020) ..................................... 21

Appendix 3 – New development in Kinver since 2018 ...................................................... 24


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1. INTRODUCTION AND DESCRIPTION OF THE SITE

1.1 The application site consists of 1.47 hectares of agricultural fields. 1.2 There are hedgerows and trees along the site boundaries and the internal field boundary. It is understood that a number of trees within the application site are subject to a Tree Preservation Order. 1.3 The topography of the site is undulating, and the southern boundary of the site is defined by hedgerows. 1.4 The site frontage is currently undeveloped and affords unrestricted views to Kinver Edge and the historic Rock houses which are in the ownership of the National Trust. The National Trust has commented that they are “not convinced that the removal of the site from the Green Belt has been justified”. In 1981 there was a Public Enquiry and the Inspector's Report concluded that it had "a role in containing the spread of Kinver toward the woodland on the lower slopes of Kinver Edge". This is " especially noticeable when seen in the panorama of Kinver from the crest or the slopes of the Edge. 1.5 The site is overlooked to the south by Kinver Edge, a prominent area of higher ground over which there are numerous public footpaths which are popular with walkers, and lies 350m from the proposed site124 ha of Kinver Edge is a designated site of special scientific interest (SSSI for its biological (heathland and broadleaved woodland) and geological (Triassic sandstone exposures) interest. 1.6 Immediately to the south of the site is a further area of land which has been safeguarded land for longer term development needs. The Staffordshire Way (a public right of way) runs across two fields (the safeguarded land referred to) which adjoin the site and these fields are a valuable amenity used by walkers and local residents on a daily basis. It's a well-used footpath, the route of which was deliberately chosen to showcase the last clear views of the Kinver Edge. 1.7 The site is described as being in an “accessible, sustainable location” in the Avison Young Planning Statement (para 2.8) and the village has an “extensive range of services and facilities”. This is not borne out by reality, evidenced by the very limited availability of public transport (Transport assessment) and infrastructure (Facilities and infrastructure)


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2. OBJECTION

a. This document sets out the grounds for the objection to the proposed planning application by the Kinver Green Belt Action Group.

b. There are no exceptional circumstances to justify the removal of the site from Green Belt and alternative brownfield sites are available in South Staffordshire (page 5).

c. Kinver has already met its allocation for new houses under the 2018 site allocation document (SAD) (page 6).

d. We have grave concerns that the application to build on the two fields is a subterfuge to gain permission by default for the "safeguarded" land (page 7).

e. The flood risk assessment supplied in support of the application is inadequate. We are concerned that should this development proceed it will give rise to serious surface water flooding in the adjacent streets and at Potters Cross. The risk of surface water flooding is being exacerbated by climate change (page 8).

f. No evidence is provided that the proposed soakaways will be adequate for surface water drainage or that the additional runoff will not give rise to additional surface water flooding in the centre of the village. (page 8)

g. The assumptions made in the transport assessment are both unrealistic and inadequate. Available public transport is not guaranteed and is unsuitable for commuting (page 9)

h. The additional trip generation assumptions are implausible. The suggestion that 40 houses will give rise to only 24 trips in the morning and evening are untenable. (page 9)

i. The additional traffic generated will exacerbate the existing congestion at the Potters Cross junction and will lead to an increasing the incidence of road traffic accidents (page 10).

j. The ecology report evidences the fact there will a loss of valuable habitat in the form of mature trees and hedgerows (pages 12-13).

k. The proposed development will cause irreparable damage to the biodiversity of the site and will result in catastrophic habitat loss. The application should be refused on this basis (pages 12-13).

l. The village does not have the facilities or the infrastructure to support the level of proposed development. There is no guarantee that additional facilities will be provided by a Section 106 Agreement or the Infrastructure Levy (pages 15-16).

m. The proposed provision of Affordable Housing for the site does not (Policy H2) provide any real access to affordable housing for local residents (page 17).

n. The application itself creates harm within the definition of EQ4 (page 18).


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3. GROUNDS FOR REMOVAL OF LAND FROM GREEN BELT AND 2018

SITE ALLOCATION

3.1 It is our understanding that this land has been removed from green belt and is now safe guarded in order to meet the original 2018 Site Allocation requirement which was greater than it is now. 3.2 The Kinver allocation was reduced to a residual requirement of 48 in 2018 when Kinver was also down-graded to a Tier 2 village. At this point it was proposed that the White Hill and Hyde Lane sites would each comprise a minimum of 30 dwellings, i.e. 60 dwellings in total. This means that together the sites would have covered the 48 minimum, with a surplus of 12 dwellings. 3.3 However, the Hyde lane site that is currently under construction comprises 47 dwellings. Consequently, the Hyde Lane site plus a number of smaller sites that are under development mean that Kinver has already exceeded the number of dwellings set out in the 2018 Site Allocation document. At least 60 new residences have been granted planning permission and /or have been granted planning permission since the 20178 SAD (see Appendix 3), most notable amongst these developments is 9 new properties Cedar Vale Dark Lane, 20 Apartments at the Burgesses on the High Street and an increase of 6 dwellings at Stourton Court. We see no logical reason why such a significant number of properties should be ignored by SSDC on the basis that they comprise “windfall development”. These properties should be taken into consideration when determining whether Kinver has met its allocation under the 2018 SAD. 3.4 As Kinver has already met its 60 house allocation under the 2018 SAD the removal of the White Hill site from green belt (and the proposed development) cannot be justified as being for “exceptional circumstances”. 3.5 The National Planning Policy Framework states that:

“Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations”. 3.6 Alternative site are available. Birmingham and the Black Country should be made responsible for the housing allocated to them by central government. Brown field sites are available at Halfpenny Green and Dunston and others will become available as businesses close as a consequence of CV19. 3.7 The government requires that the district of South Staffordshire must build between 4,000 and 4,500 new dwellings by 2037. The additional quota transferred


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from Birmingham and the Black Country (‘duty to cooperate’) is not a statutory requirement but an economic convenience. An estimate of the housing proposed for Kinver indicates that this village is being victimised, possibly because of the extra profit to be made by building in a desirable location 3.8 Furthermore, the government Planning White Paper concerning the future of the planning system removes the “duty to cooperate” such that the development of the White Hill site cannot be justified on these grounds. 3.9 Consequently, it is our view that there are no “exceptional circumstances” which justify the removal of this land from the green belt and as a result this development should not proceed. 3.10 Planning policy – NPPF (2019) 3.11 Paragraph 139 states that plans should make it clear that “safeguarded land is not allocated for development at the present time” and that planning permission for the permanent development of safeguarded land should only be granted “following an update to a plan which proposes the development”. 3.12 The outline plans include a section of safeguarded land to the south of the site. This is in direct contravention of paragraph 139. 3.13 The Development Plan for South Staffordshire comprises the Core Strategy, adopted in December 2012 and the Site Allocations Development Plan Document, adopted in September 2018. The site is allocated for housing in the adopted SADPD under Policy SAD2. It identifies a minimum capacity of 30 dwellings on the site. The Avison Young Planning Statement states that; “This application seeks outline permission for up to 40 dwellings which is higher than the figure identified in the SAD but which would contribute further towards the very significant housing needs of South Staffordshire and the wider HMA.” 3.14 As set out above Kinver has already met its housing allocation under the SAD. Further, there are other brown field sites available in South Staffordshire and the duty to cooperate is likely be abolished following the adoption of the Planning White Paper. There are therefore no “exceptional circumstances” which justify the development of this area of green belt.


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4. SAFEGUARDED LAND

4.1 We have grave concerns that the application to build on the two fields is a

subterfuge to gain permission by default for the "safeguarded" fields behind these

fields. The outline application extends into the safeguarded land to the south and is

in direct contravention of planning policy.

4.2 Appendix IV in the Avison Young submission openly illustrates their intention for

"What happens next?" The plans clearly show two access roads into the

"safeguarded" fields and for 104 extra houses. This is an indication that a far larger

development is intended that the outline application for 40 houses.

What this means is that arguments/evidence provided in support of the 40 houses,

including transport, flood risk, access, infrastructure etc., become inappropriate for

the much larger proposed development.

4.3 If the application for 40 houses were to be approved it is likely to be almost

impossible to refuse an application for the southern safeguarded land and this will

represent a considerable encroachment upon the wooded slopes of Kinver Edge.

This development would bring it directly adjacent to the woods at Redcliff Covert on

the boundary of National Trust land. The National Trust have previously expressed

concerns about the impacts of housing development - "The National Trust remains

opposed to the landscape, visual and ecological implications of the development of

site 274. Building development would be unnecessary and unjustified." (See letter to

Local Plans Team).

4.4 The proposal (paragraph 7.1) also asserts that there would be no policy or other

harm. This is highly contentious and unsubstantiated. In addition, it is claimed the

development will ‘frame the view’. This is not further explained. From what

perspective, and how is this achieved? The view of the ancient Rock Houses does

not need to be “framed” by a housing development.

4.5 A ‘well designed scheme’ will celebrate natural features. Exactly how this is

achieved by building a series of conventional housing units is also not explained.

4.6 Finally, the connection to ‘a wider network of open spaces in the safeguarded

areas and beyond’ is entirely specious, and does not make any ecological or other

sense. How and where does it connect to other open land? Habitat loss is habitat

loss.


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5. FLOOD RISK and DRAINAGE 5.1 The Flood Risk Assessment provided in support of the application has been commented on by the Staffordshire County Council Flood Risk Management Team as follows:

“Thank you for consulting us on this outline application. Our response is detailed below. Staffordshire County Council Flood Risk Management position. We have reviewed the submitted information and there is insufficient detail to fully demonstrate that an acceptable outline drainage strategy is proposed for this outline application. We would therefore recommend that permission is not granted until this has been resolved. The outstanding issues are as follows: 1. Infiltration testing. The infiltration testing results presented in Appendix-B of the FRA and Drainage Strategy report (CTMR Consulting, RevB, Mar20) have not been carried out in accordance with BRE365. The methodology in BRE365 states that each trial pit should be tested a minimum of three times, whereas the results presented in Appendix-B indicate that only a single test was carried out for each trial pit. Since infiltration is proposed as the sole means of surface water disposal it is especially important the confidence in the design infiltration values are high. We would therefore ask that further testing is carried out to meet this requirement.” 5.2 We are concerned that should this development proceed it will give rise to serious surface water flooding in the adjacent streets and at Potters Cross. The risk of surface water flooding is being exacerbated by climate change. Extreme weather events, including flooding are projected to increase throughout the 21st century to a level up to three times the historical average. Even moderate amounts of rainfall can cause serious damage especially where urban runoff is being increased by housebuilding combined with inadequate sustainable urban drainage systems (SUDS) including the loss of open land which acts as a natural soakaway.

5.3 No evidence is provided that the proposed soakaways will be adequate for surface water drainage or that the additional runoff will not give rise to additional surface water flooding in the centre of the village. There is no evidence that there is a strategy to take account of climate change resilience in the plans. 5.4 The centre of the village has been subject to extensive flooding over the past few years and these issues will get worse as the frequency of extreme climate events increases. Photographic evidence of recent flooding events can be found in Appendix 1. 5.5 Avison Young state that (paragraph 7.80 of the Planning statement ) in terms of foul drainage there is an existing 225mm public foul water sewer in White Hill at the front of the site. Severn Trent Water Ltd has apparently confirmed that a connection can be made to this sewer However no evidence has been provided that the existing sewers have the capacity to cope with the additional houses. This is a fundamental omission. There is no reference to the capacity of the sewers to cope with the additional 104 dwelling proposed for the safeguarded land.


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6. TRANSPORT ASSESSMENT 6.1 The Transport Assessment conducted by Hub Transport Planning Limited is inadequate. 6.2 For example, the assumptions with regard to accessibility by bus are out of date as the current bus service is only guaranteed until the end of September 2020 and Diamond Buses have notified their intention to withdraw the service with effect from that date. Another operator has now taken on the service however it is unclear whether this service has any degree of longevity. 6.3 Furthermore the last return bus from Stourbridge is currently 17:45 which renders the service impractical for commuting to and from Stourbridge Junction railway station, and also for most employees that work in Stourbridge itself. Although cycling to Stourbridge Junction is suggested as an option for “proficient cyclists” the 10km distance and the nature of the route renders this highly impractical and dangerous.

6.4 The reports completed by the council have abundant data to suggest that the majority of our residents have to commute to work, as they concede that job opportunities in South Staffs are limited and are particularly poor in Kinver. Census data also backs this up. It is therefore fair to say the vast majority of new residents will commute to and from work and will therefore use private transport for most journeys. 6.5 The additional trip generation assumptions in the Transport Assessment are clearly implausible. It is suggested that a development of 40 properties will give rise to only 23 additional trips in the morning and 24 trips in the evening. Given that there is very limited employment available in Kinver and the fact that most households will have two vehicles, with both occupants commuting to and from work, then the development will give rise to significantly higher traffic flows and consequent congestion at the Potters Cross junction at the foot of White Hill. This junction is already a pinch point due to adjacent schools and residential car parking and is a known traffic “hot spot” in the area.

6.6 The 2020 Transport Assessment states that 3 accidents have occurred within the last five years, 2 of which were in 2018. The previous 2017 report stated that there was one accident in the previous 5 years. If you compare the two periods together it demonstrates there is in fact a 300% increase from pre 2017 to post 2017.The rising trend in the number of accidents over time should be a red flag. 6.7 A well-used tool in the health and safety industry is the health and safety triangle proposed by Herbert William Heinrich and extended upon by Frank E. Bird. This model suggests that trends in increasing near misses and also minor incidents is a significant indicator for the occurrence of a more significant event. Without remedial action, near misses and incidents will lead to fatalities. Traffic volumes and congestion will rise as the Hyde Lane, and other sites are completed, which means that near misses, incidents and traffic collisions will also increase and the severity of the consequences of these accidents will also worsen. It is also significant that injury accidents predominantly involve pedestrians being struck by cars.


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6.8 The Potters Cross junction is already giving rise to significant safety concerns and the traffic at the foot of White Hill is already effectively single file only due to the number of residents’ cars which are parked on the south side of White Hill and customers using the Potter’s Cross post office. This issue gave rise to the highest number of concerns raised at the Avison Young consultation meeting on 29th January 2020. It is difficult to see how the increase in traffic at this junction can be accommodated without eventually resulting in fatalities. With the recent closure of the Post Office in the High Street, the Post Office/newsagents/shop at the bottom of White Hill has become much busier. It has no off-road parking for customers and post office vans. The houses opposite also have no off-road parking so this area is congested. Cars park on the pavement forcing pedestrians and mobility scooter users into the road. Traffic from 2 schools, 2 playgroups, a beautician, a veterinary surgery, a take-away, a post office and a church all park around Potters Cross. Had a proper traffic survey been carried out, White Hill would never have been considered suitable for additional housing. 6.9 The letter from Mark Parkinson, Economic Development & Planning Policy Manager (SSDC) dated 27 February 2017 states that: “Most of these [additional traffic] movements could be expected to impact on this [Potters Cross] junction during these periods, as residents attempt to access the A458 Bridgnorth Road and A449 Wolverhampton Road. This is an unconventional junction formed by the intersection of two priority junctions White Hill/Meddins Lane and Meddins Lane/Enville Road. The location of Brindley Heath Junior School, Kinver High School and 6th Form accessed off Enville Road and Foley Infants School nearby accessed off Fairfield Drive can be expected to attract additional vehicle journeys; however, in the morning the majority would logically be linked to work journeys. At school times the environment around the junction looks disorganised due to informal school parking.” 6.10 The infrastructure of the roads adjoining White Hill is such that an increase in volume of traffic will radically affect congestion and safety in the area. The road itself is 5.1 metres wide at the point of the intended new development and Staffordshire's own technical standards guidelines state that the carriage way width should be 6 metres with two footpaths of 1.8 metres and curb radii of 10 metres. The current footpaths and radii do not accommodate these criteria. The width of the footpath at Potters Cross Farm in only 1.0m, the width of the footpath outside the post office is between 0.8 and 1.0m for a length of 20 metres and the footpaths in the vicinity of Jenks Avenue are only 1.4 metres wide. There should also be access from both directions as a 'loop road or connected street' - White Hill cannot provide this. 6.11 Hub Transport Planning (paragraph 7.67) has designed the proposed access which will be in the form of a new priority junction on to White Hill. It is unclear what this means in practice. It is further stated that the proposed access junction takes the form of a 5.5 metre access road, with 6.0 metre radii and 2.0 metre footways linking into the existing infrastructure on White Hill As the existing footways are significantly narrower than 2.0m (see above) and the road is already narrow, it is difficult to see how this can be achieved within the constraints of the existing infrastructure.


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6.12 When speed recording equipment was placed on White Hill to try and record data with reference to the building project, it was placed past the proposed position of the entrance to the site and would have recorded an artificially low percentage of traffic which actually uses White Hill, due to the position so far up the road. 6.13 The Transport Assessment concludes that the development “will have a minimal impact on the operation of the local highway network and will not have an unacceptable impact on highway safety.” This statement is implausible in view of the existing congestion at the Potters Cross junction. 6.14 Should this development (and the development of the safeguarded land) proceed then the additional traffic flows will give rise to a need for the remodelling of the Potters Cross junction – probably by way of a traffic island, along with the requirement for a pedestrian crossing on White Hill. 6.15 Photographic evidence of the current levels of congestion at Potters Cross before the construction of any additional housing can be found at Appendix 2. 6.16 As a result of the deficiencies in the traffic survey and the significant concern regarding the existing traffic congestion at Potters Cross the Kinver Parish Council has voted to undertake an independent traffic survey in the area of Potters Cross to show traffic flows and the impact of any future developments. 6.17 Planning Policy 6.18 Core Policy 11 (transport) outlines that new developments must be served by an attractive choice of sustainable modes of transport. It identifies a series of measures to encourage sustainable transport in new developments. 6.19 There is no choice of sustainable modes of transport in Kinver. There is a bus service which is under threat of withdrawal and no other public transport possibility. The development will increase commuting and thereby increase pollution and congestion. Core Policy 11 has not been met.


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7. ECOLOGY AND HABITAT LOSS 7.1 The loss of habitat resulting from the proposed development will give rise to species loss and a potentially disastrous reduction in local biodiversity. 7.2 The Ecology Report (which has not been published on the South Staffs web site) contains the following comments: 7.3 The on-site hedgerows containing frequent mature trees and the woodland edge habitats along the Study Area’s southern and western boundaries offer good foraging resources and commuting routes for local bat populations. The woodland edge habitats have the potential to be of particular value to bats, likely supporting high densities of suitable prey and offering a direct link between any potential roost sites within the built environment to the east and north of the Site and extensive area of woodland of high foraging value to the south. (Para 4.21) 7.4 Paragraph 5.24 refers to the fact that ten of the mature trees on this site have the potential to support roosting bats and 5.25 refers to the fact that such trees are likely to be subject to negative impacts from artificial lighting. Consequently these potential roosts are likely to be lost as a result of street lighting and additional artificial light from the proposed housing. Paragraph 5.26 also refers to the fact that potential roosts can be lost via the severance of connecting habitat. Overall, the development will give rise to the loss of bat habitats.

7.5 A number of protected and notable bird records were provided for the local area. With the exception of the historic record of nightjar recorded within Kinver Edge SSSI, located approximately 350m south of the Survey Area. A summary of these records is provided within Table 4. Eight species of birds documented on this table are on the Red List of endangered species (Para 4.26), these include the common cuckoo, the European nightjar and the skylark. Further, paragraph 5.30 of the report states that proposals including the removal of approximately 20m of hedgerow will result in the reduction of nesting and foraging habitat available to birds locally, possibly including species of conservation. We are also aware that newts have been detected on the site. 7.6 With the exception of hedgerow H1, all of the hedgerows within the Site are native species-dominated and are a Habitat of Principal Importance on S41 of the NERC Act 2006, similarly hedgerows (H3, H4, H6 and H7) situated within the area of Additional Land are also included under the same classification. Ancient/diverse hedgerows, which would include hedgerow H5 identified as species-rich, are also included as Priority Habitat on the SBAP. This hedgerow, in addition to hedgerow H2 all fronting White Hill were found to be ‘Important’ hedgerows under the Hedgerow Regulations Act 1997 and of moderately high to high conservation value (Grade 2) under HEGS. (Para 5.11). 7.7 The site supports a resource of mature trees and such concentrations are particularly valuable as a habitat and landscape feature. Two of the mature oaks (T2 and T4) exhibited large girths and may meet the definition of veteran trees, with T2 located on the north Site boundary and T4 located off-Site within the Additional Land respectively.


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7.8 Veteran trees are particularly important for biodiversity. The NPPF (February 2019) states that “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”. (Para 5.12). 7.9 Numerous reports (WWF, IPCC etc) have conclusively demonstrated the global unsustainable loss of biodiversity, primarily due to habitat destruction. The least we can do is properly impose the few rules and regulations at our disposal to safeguard and improve what remaining undeveloped land currently exists. 7.10 The ecological report fails to recognise the true ecological value of the site. The fact that there are many TPO'd trees, five with moderate potential for roosting bats and one with exceptionally high potential, is sufficient to illustrate that a residential development on this site will have a serious negative impact on the fauna currently using it. It is unlikely that sensitive species will remain in trees surrounded by housing and roads. As with the hedgerows, the ecological value of urban trees is greatly altered from their value in a rural setting. The report fails to address wildlife/biodiversity valuation techniques, such as ecosystem services. 7.11 Potential development of the safeguarded site shows houses and infrastructure along the boundary of the woodland. There needs to be a 15 metre buffer zone around the woodland to protect it from the worst elements of development. Developers may suggest no dig zones for the developments within the buffer zone, but this does not prevent the negative overspill effects of gardens, houses, and roads being located within the buffer zone. 7.12 The Avison Young Planning report refers to “habitat enhancements and opportunities for tree and hedgerow planting” (para 3.1). These habitats, trees and hedgerows are already in existence and should not be destroyed. In addition, new planting projects never replicates the complexity of established ecosystems. 7.13 The proposed development will cause irreparable damage to the biodiversity of the site and will result in catastrophic habitat loss. The application should be refused on this basis.

7.14 Planning policy 7.15 Core Policy 2 relates to ‘Protecting and Enhancing the Natural and Historic Environment’. It confirms that the Council will support developments that enhance or conserve the natural and historic environment by not inflicting detrimental impacts on the significance of the assets. 7.16 The outline planning application is not compliant with Core Policy 2. 7.17 Policy EQ4 establishes that the Council will seek to maintain and enhance the intrinsic rural character and local distinctiveness of the South Staffordshire landscape. It seeks to protect trees, hedgerows and woodland from removal unless it


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can be demonstrated that removal is necessary and appropriate. This has not been demonstrated. 7.18 Compensation for biodiversity loss must be the "last resort", according the NPPF. This application doesn't even offer compensation, let alone show that no alternative sites exist that will not be environmentally harmful. 7.19 There is no mention in the ecological appraisal of the European Protected Species hazel dormouse. Their presence has been confirmed at a site less than 10 km to the south west in a well-connected woodland. Failure to provide an EPS survey would be considered reckless and be a criminal act if any such species is harmed.


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8. FACILITIES AND INFRASTRUCTURE 8.1 The village does not have the facilities or the infrastructure to support the level of proposed development. 8.2 The primary schools in Kinver are not equipped to deal with an increase in pupil intake in their current state and the fabric of the junior building (a 'temporary prefabricated building' erected in the 1970s) in particular is inadequate. It is also questionable whether the current secondary school provision would be adequate. 8.3 Lack of services: Whilst we are classed as a 'main service provider' village, we no longer have many of the main services that would ordinarily be included within this category. Since this designation Kinver has lost its only petrol station, main Post Office, a supermarket, its last bank, a butchers, a greengrocers, a florist which housed tourist information, a bridal shop, and a shop selling blinds. The police station has closed, the fire station was threatened with closure, and the library was saved only due the fact that it is now staffed by volunteers and it now has extremely limited opening hours. Despite a steady increase in population and new housing, the High Street has shrunk. 8.4 There are also intractable problems with parking/traffic and access in the village centre. 60%- 70% of our free parking has been lost in the last few years, 20% of the remainder is used by residents and retail workers. The single doctor's surgery, is already overwhelmed with waiting lists in excess of two weeks and is threatened with potential closure, with patients forced to travel to a sister practice. There is no leisure centre or swimming pool. 8.5 The government are insisting on the country being equipped with better and faster internet services. Parts of the village suffers from extremely poor internet speeds and it is likely that with further residents will give rise to a deterioration in internet speeds. 8.6 The Avison Young Planning Statement states that; “Trebor has confirmed that, as a matter of principle, that the scheme could contribute to improvements to local schools and health facilities by way of a Section 106 agreement where requested by the local education authority and CCG and where there is evidence of need. Trebor has confirmed that it would welcome early dialogue with the District Council as part of the outline planning application regarding the scope of planning obligations.” 8.7 The Avison Young Planning Statement asserts that increased local spend which would support the vitality and viability of local services and facilities in the village. There is no evidence that this will be the case and that the development will not lead to additional pressure on the existing services which are already under strain. Furthermore, there will be no “additions to the local employment pool” which “assist with economic growth”. There are no local employment opportunities within the village which might require an “employment pool” to support economic growth as reflected by the fact that the vast majority of residents already commute to work in other areas.


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8.8 There is no guarantee or evidence whatsoever that any additional facilities or infrastructure will be provided. The Planning White Paper dispenses with Section 106 as a financing mechanism and there is considerable concern that the proposed ‘Infrastructure ievy’ will be able to deliver similar compensatory activity. It is noted that the Community Infrastructure Levy is not to be imposed on the 40 house development. This is surprising. The local authority will therefore be required to pay for the necessary (and no doubt numerous) measures to facilitate what is espoused. 104 houses will put an even greater burden on public services and public finances. Why should the public, the taxpayer and the ratepayer be expected to subsidise the enrichment of a private developer? 8.9 Planning policy 8.10 Core Policy 1 of the Core Strategy establishes the Spatial Strategy for South Staffordshire. It states that growth will be located at the most accessible and sustainable locations in accordance with the Settlement Hierarchy, as follows: ‘Main Service Villages’, including Kinver - the main focus for housing growth, employment development and service provision. 8.11 The services available in Kinver are deteriorating rather than improving and there is no local employment growth. The outline proposals do not meet Core Policy 1 for these reasons. 8.12 The Avison Young Planning Statement refers to “job creation on site during the construction period”. This is clearly inaccurate – no jobs for local residents will be created by this development either during or after the initial construction phase.


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9. HOUSING MIX 9.1 The Illustrative Mix (Masterplan) shows that of the 40 units, 16 are termed ‘affordable’. This includes 8 for social rent and 8 for shared ownership. These are a mix of 2 and 3 bedroom maisonettes, apartments and semi-detached or detached buildings. It also claims to be compliant with the Council policy for affordable housing and tenure mix. 9.2 There is an assertion that these units will be ‘affordable’. However, for those on low incomes, who are most likely to need these houses, this is extremely unlikely, even with shared ownership. 9.3 This issue can be illustrated with reference to the Hyde lane development in the village. The minimum price of a 2 bedroom property is £285,000. This does not constitute ‘affordable’ in a meaningful way, and is prohibitive even for shared ownership. These assertions smack of being purely policy compliant but lacking in any real provision of accommodation which is affordable for local residents. Although some are nominally for social rent, it is not clear how will this be managed and enforced, and also fails to address the significant shortage of affordable rental properties in South Staffordshire. 9.4 Planning policy 9.5 The proposed provision of Affordable Housing for the site does not (Policy H2) provide any real access to affordable housing for local residents for the reasons set out above.


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10. PLANNING POLICY EQ4 10.1 Policy EQ4 establishes that the Council will seek to maintain and enhance the

intrinsic rural character and local distinctiveness of the South Staffordshire

landscape. It seeks to protect trees, hedgerows and woodland from removal unless it

can be demonstrated that removal is necessary and appropriate. It also encourages

the design and location of new development to take account of the characteristics

and sensitivity of the landscape and its surroundings and not have a detrimental

effect on the immediate environment and any important medium and long distance

views.

10.2 It is noted that the Avison Young Planning Statement states (at 5.16) that: “the visual change would result in very limited ‘harm’ and such ‘harm’ would be significantly less than substantial”.

10.3 This is a matter of opinion and puts a very optimistic (developers’) interpretation on EQ4. The objection is that the application itself creates ‘harm’ within the definition EQ4; it certainly creates ‘harm’ which would not be limited. And once building has commenced the consequent harm can never be undone.

10.4 Significantly more harm will be created if the scheme mentioned at the end of Appendix IV were to go ahead. The developers indicate on the site plan for the 40 houses, that the two roads going up to the boundary of the safeguarded land to the south will serve many additional houses, 104 in all. Hardly limited ‘harm’. 10.5 The Avison Young Planning Statement (at 7.51) concludes that there would be

some minor visual change in the wider views from the north-eastern tip of Kinver

Camp but the impact on the monument’s setting is otherwise very limited.

10.6 The reference to ‘Kinver Camp’ is misleading: Kinver Camp, an Iron Age hill fort, is just one small part of Kinver Edge, which is a very popular and significant National Trust beauty spot of considerable local and historic importance extending over 200 acres, and the proposed development encroaches on its northern wooded slopes. That natural environment would consequently be at risk. 10.7 On this basis we conclude that the proposals do not comply with the relevant local and national policy.


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11. CONCLUSIONS 11.1 Paragraphs 7.88 to 7.93 of the Avison Young Planning Statement draw a number of conclusions with which we fundamentally disagree.

a. Paragraph 7.88 refers to the Council’s housing land supply. As set out above the allocation of 60 additional dwelling has already been met. Furthermore, no evidence is provided that the “affordable homes” will be affordable for local residents on lower than average incomes (see page 6).

b. Paragraph 7.90 states that “the proposals would provide a small area of public open space within the area of ‘safeguarded land’.” The whole of the site is already open space, the additional houses are not required and the extension of the site into the safeguarded land is in contravention of planning policy. The report concludes (somewhat surprisingly) that the proposed open space would result in no policy or other harm and there are benefits associated with the creation of the proposed area of open space. The destruction of existing ecosystems does not feature and cannot be justified (see pages 12-13).

c. We refute the assertion that the site would provide affordable dwellings as set out on page 17. Furthermore, there is no evidence that there is a significant unmet housing need in the village for “market housing” especially given the lack of local employment opportunities.

d. The range of local services in the villages has reduced significantly in recent years and cannot support the additional population that will be added by this development (pages 15-16).

e. No evidence is provided regarding how the “new green infrastructure” is to be created (paragraph 7.91) when in reality the existing ecosystems will be destroyed – it is not possible to simply manufacture “green infrastructure”, whatever that means.

f. The assertion that that there will be job creation during the construction phase is laughable. These will not be jobs for local people nor will they provide permanent employment. There is no local employment requirement which needs a “local employment pool”. Kinver is already a commuter village and local services and infrastructure are already under strain (pages 15-16). No guarantee is given that local services or infrastructure will be improved via “specific planning obligations”. Experience would suggest that developers will do all in their power to avoid such obligations.

g. The additional traffic generated by the propose development will further exacerbate and already dangerous and congested road layout leading to additional accidents (page 9)

h. All of the above objections relate to the outline application for 40 houses. What about the 104 houses which will inevitably follow?

i. On the basis of what we have set out in the above report we have concluded that the proposed development will not deliver sustainable development and nor does it comply with Development Plan Policy. The application will benefit Avison Young, Trebor Developments and the landowners. The development will provide no benefit to the existing residents of the village of Kinver, and on this basis planning permission should be refused.


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Appendix 1 - Flooding

Flooding of playing fields at the KSCA – December 2019

Flooding at Stag Meadow (site of the Kinver Country Fair) in June 2016

Flooding in car park to rear of Kinver High Street – July 2017


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Appendix 2 - Traffic congestion (all photos taken October 2020)

Single file traffic on White Hill, opposite Potters Cross post office

Rush hour congestion at Potters Cross junction at bottom of White Hill


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Single file traffic and illegally parked vehicles at the bottom of White Hill

Illegally parked vehicle on junction of White Hill and Enville Road during morning rush hour


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Illustration of narrow pavements at bottom of White Hill, forcing mobility scooter into road to mix with traffic (permission of scooter driver was obtained for the photo).


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Appendix 3 – New development in Kinver since 2018 White Hill 66 and 68 Hillsborough Rise Plans for 1 new bungalow Enville Road 1 detached house - next to 49A in Private drive at side of Church 1 detached divided into 2- 3 bed semis 177A, 177B + 1 new detached house (no number) Upper Simms Piece – 1 detached house Church View Gardens 5 new – Nos. 103/105/107/109/1011 James Street ‘Oak Trees’ in garden of Beech Trees White Harte Caravan Park Plans for 5 x 2 bed apartments Chenavere Mews 1 development back of Café No. 5 Off High Street Car Park No. 2 Otters Reach Plus 1 in under construction Plus 1 small wooden chalet style bungalow behind fencing (appears to be occupied) High Street – The Burgesses 20 apartments Mill House Outline plans for future development 35/40 apartments High Street 21A Stable conversion adjacent to Co-op Dark Lane No. 6 ‘Fair View’ Cedar Vale – 9 new properties The Saplings (off Willow Road) 3 new bungalows Dunsley – Lock Side – adjacent to No. 3 1 property under construction Orchard Grove 5A


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Comber Road, the Compa 1 New house Stourton Stourton Court (re-development from 4 – 10 ) – increase of 6 dwellings Rear of Stourton Court -The Coach House and The Mews Stourton Stables 1 bungalow

Documents

Proposal: Outline planning permission for 40 dwellings