25th November 2019

Local Plans Team South Council Council Offices Codsall WV8 1PX

Dear Sirs,

Local Plan Spatial Housing Strategy and Infrastructure Delivery

PlanIT Planning and Development (“PlanIT”) are instructed to submit representations to the South Staffordshire Local Plan Spatial Housing Strategy and Infrastructure Delivery consultation document (“SHSID”). Whilst we support the stated ambitions of the emerging Plan, in seeking to provide a sufficient amount of housing, employment land and infrastructure to meet not only the residents of South Staffordshire but also to assist in meeting the unmet housing requirements of the conurbation, these aspirations do not, in our view, appear to be reflected in the consultation document. Our comments on the consultation document are set out below. This letter responds to the various questions included in the SHSID consultation document as appropriate. We also provide comments on specific matters raised within the text of the SHSID where questions are not raised, but we have objections.

2. The Local Plan Review – Progress to Date (Paragraphs 2.1 – 2.2)

Paragraph 2.2 of the consultation document advises that the Council is of the view that it should plan for its own housing needs, and a contribution of up to 4,000 dwellings towards the unmet needs of a wider Housing Market Area (“HMA”). However, if there is evidence that the extent of housing shortfall across the HA is significantly reduced prior to the Local Plan Review submission, the Council will reduce its contribution to the unmet needs of other authorities proportionately.

We have a number of concerns with this approach. We set out our comments on the proportion of the unmet housing requirement of the conurbation that South Staffordshire should provide for in our response to paragraphs 2.3 to 2.6 below. In summary, it is our view that South Staffordshire will need to provide significantly more than the 4,000 dwellings suggested to help meet the unmet housing needs of the conurbation. There is still significant work to be done on the extent and distribution of the unmet housing requirements of the conurbation. However, as drafted paragraph 2.2 suggests that South Staffordshire’s contribution can only be decreased. Paragraph 2.2 should be amended to confirm that as the Plan progresses, and additional evidence arises on the extent and distribution of the housing shortfall from the conurbation, the emerging Local Plan will seek to 1 accommodate an appropriate proportion of this requirement. This could be greater than the 4,000 units currently suggested and it should not automatically be assumed that this figure will be reduced. The suggestion that the housing requirement can only be decreased is inflexible and entirely inappropriate.

The Preferred Housing Target for the Local Plan Review (Paragraphs 2.3 – 2.6)

We support the use of the Standard Method in establishing the South Staffordshire’s proportion of the emerging Local Plan’s housing requirement. It should, however, be noted that the Standard Method is under review. As a consequence the housing requirement in the emerging Plan may need to change in accordance with revisions to national planning policy. This aspect of the Plan, therefore, needs to be kept under review.

It is our view that the Plan should make a significantly greater contribution to the unmet housing requirements of the conurbation than that currently identified.

The current evidence on the extent of the housing shortfall from the conurbation can be found in a variety of sources, including the adopted Development Plan and the emerging Black Country Core Spatial Strategy. The Birmingham Development Plan was adopted in January 2017. Policy PG1 – Overall Levels of Growth, advises that Birmingham’s objectively assessed housing need figure for the period 2011-2031 is 89,000 dwellings (4,450 dpa). It is not, however, possible for this level of development to be accommodated in the City’s administrative area. Policy PG1, therefore, plans for the provision of 51,100 dwellings within the Plan area and advises that the City Council will work with other authorities within the Housing Market Area through the Duty to Cooperate to deliver the residual 37,900 dwellings.

Since the adoption of the Birmingham Development Plan, has produced a new Strategic Housing Land Availability Assessment 2018. This document suggests that the capacity for sites within the urban area of Birmingham has increased, and there is now a total supply of 61,403 dwellings during the course of the Plan period. This is made up of 14,047 completions between 2011/12 and 2017/18. The remaining 47,356 dwellings are from sites that are allocated by the Birmingham Development Plan, have planning permission, or are identified as potentially being suitable development opportunities by the SHLAA.

The SHLAA advises at paragraph 2.2 that:

“The inclusion of a site in the SHLAA does not mean that it will be developed for housing, it does not mean that housing is the only suitable use for a site, and does not necessarily mean, where it is not already the case, that planning permission would be granted for housing. Circumstances may change over time.”

The SHLAA is not an allocations document. It has not been the subject of examination or independent testing in the same way that the capacity figures in Birmingham Development Plan Policy PG1 have been. In addition, there is no suggestion by the City Council that we are aware of that policy PG1 is an out of date policy of that the residual housing shortfall figure identified by Policy PG1 should not be planned for by other authorities within the Plan area. However, even based upon the SHLAA capacity figures, the outstanding housing requirement drops to 27,597 dwellings. This is still a significant amount.

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In addition, if the SHLAA is to be treated as new and relevant updated evidence regarding the capacity of Birmingham to accommodate development and the extent of the shortfall, other relevant material considerations that have arisen since the adoption of the Birmingham Development Plan should also be taken into account. This includes the application of the Standard Method to identify Birmingham’s housing requirement. The adopted Birmingham Development Plan includes a requirement of 4,550 dwellings per annum. However, this figure is below that which arises from the application of the Standard Method calculation for the City. The Standard Method housing requirement figure for Birmingham is 4,975 dpa. If the SHLAA capacity figures are to be treated as new and up-to-date evidence so should the Standard Method housing requirement.

In addition, the extent of the identified shortfall for Birmingham also needs to be considered in the context of the Plan periods for the adopted Birmingham Development Plan and the emerging South Staffordshire Plan. The Birmingham Development Plan has an end date of 2031. As such the extent of the housing requirement, and the extent of the housing shortfall, is only established for a period up to 2031. The emerging South Staffordshire Plan is being prepared to have an end date of 2037. Consequently, no provision will be made within the emerging South Staffordshire Plan for any shortfall that could arise from Birmingham in the period beyond 2031. However, all current evidence suggests that it is highly unlikely that Birmingham will be unable to identify any significant new capacity within its administrative area through any future Local Plan Review. In all likelihood Birmingham City Council will need to ask neighbouring authorities, including South Staffordshire, to make contributions in their replacement plans to meet the growth of Birmingham beyond 2031. If South Staffordshire fails to make an appropriate contribution towards the unmet housing requirements from the conurbation emerging evidence through the Birmingham Local Plan Review process could result in the emerging South Staffordshire Plan either being found to be unsound as it progresses through examination or, potentially, there being an immediate requirement for a review in order to assist in meeting the growth requirements of other authority areas.

The Black Country authorities are also in a position where they are relying upon other authorities within the HMA to deliver a significant amount of housing to help meet their growth requirements. The Black Country authorities are currently in the process of preparing a replacement for the Black Country Core Strategy. Issues and Options consultation was taken on the emerging Core Strategy between July and September 2017. The consultation document advises that 78,000 dwellings will be required between 2014 and 2036 in order to meet the growth requirements of the Black Country (3,545 dpa). However, the Issues and Options consultation document was published before the revisions to the PPG that require the application of the 2014 household projections in the Standard Method calculation. This level of growth referred to in the Issues and Options consultation document is lower than that required through the application of the Standard Method which the emerging Plan will now be required to comply with. The Standard Method results in a housing requirement for the Black Country of 3,761 dpa.

The Issues and Options consultation Black Country Core Strategy advised that it is estimated that sites within the Black Country urban area, including developments already being built, sites with planning permission and for increased densities on existing sites could deliver 56,000 dwellings. This leaves a shortfall of 22,000 dwellings that will need to be provided outside of the urban area. This is, however, an under-estimate based upon the updated Standard Method figure referred to above.

It is appreciated that land may be released from Green Belt within the emerging Black Country Core Strategy plan area to meet part of the identified shortfall. However, Green Belt development opportunities are highly limited. The emerging Black Country Core Strategy currently under- estimates housing needs due to the changes to the Standard Method, it is highly unlikely that all identified SHLAA sites will be found to be deliverable or be capable of allocation, and the density 3

assumptions within the emerging Black Country Core Strategy are extremely ambitious. It is, therefore, our view that the 22,000 dwelling shortfall figure represents a robust starting point for understand the combined housing shortfall of the conurbation.

The current combined housing shortfall of the conurbation should, therefore, be considered to be 55,800 dwellings. There has been highly limited progress with the authorities within the HMA in preparing Local Plans to assist in meeting the unmet growth requirements of the conurbation. This position is summarised below:

• – Lichfield District are currently undertaking consultation on the Preferred Options version of their Local Plan. This document suggests that Lichfield District will make provision for 4,500 dwellings to meet the growth requirements of the conurbation.

• North Borough – The Local Plan is currently proceeding through the examination process. The Plan makes reference to ‘testing’ the potential to deliver up to 3,790 dwellings to meet the needs of the Greater Birmingham and Black Country Housing Market Area. However, the Local Plan Inspector wrote to the Local Authority on 12/06/19 expressing a number of concerns with the Plan. Significantly, the Plan must represent a deliverable strategy based on proportionate evidence and a significant element of the development proposed relies upon the outcome of a Housing Infrastructure Funding bid of around £58m, which is currently being appraised by the Government. Until the outcome of the HIF bid is known there is uncertainty regarding whether the allocations in the Plan are deliverable.

• Solihull MBC – The Solihull draft Local Plan Supplementary Consultation document makes reference to Solihull ‘testing’ the provision of 2,000 dwellings to meet the growth requirements of the conurbation.

• Borough – the most recent Redditch Local Plan was adopted in January 2017. Due to a lack of urban capacity the Local Plan relies on the adopted Local Plan in meeting a significant proportion of its housing requirement. It is highly unlikely that any significant new urban capacity will be found in future versions of the Redditch Local Plan. As such Redditch Borough will not be playing any role in meeting the growth requirements of the conurbation.

• Tamworth – The most recent Tamworth Local Plan was adopted in February 2016. Due to a lack of urban capacity the Local Plan relies on the Lichfield District and North Warwickshire Local Plans in meeting a significant proportion of its housing requirement. It is highly unlikely that any significant new urban capacity will be found in future versions of the Local Plan. As such Tamworth Borough will not play any role in meeting the growth requirements of the conurbation.

• – Cannock Chase District are in the process of preparing a new Local Plan. Issues and Options consultation took place in May and June 2019. The Issues and Options draft document acknowledges that the District will need to consider how it addresses the unmet housing needs of the conurbation. There are, however, various constraints to development within Cannock District including the Cannock Chase AONB, the Cannock Chase SAC and Green Belt designation. This will limit Cannock Chase development capacity. Given its relationship to Birmingham and the

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Black Country, it is our view that any development directed towards Cannock Chase will predominantly meet the needs of the Black Country.

• Stratford-on-Avon – Birmingham Development Plan Policy PG1 supporting text advises that ‘part’ of the administrative area of Stratford-on-Avon falls within the HMA. Stratford-on-Avon District adopted its most recent Core Strategy in July 2016. Work on a replacement Plan is scheduled to start next year. The replacement Plan will need to assist in meeting the growth requirements of the conurbation. However, the contribution that could be made is not yet known.

• Bromsgrove District – Bromsgrove District are currently in the process of preparing a replacement Local Plan. The Bromsgrove District Plan Review Update Further Consultation document was produced in September 2019. Whilst the consultation document acknowledges that Bromsgrove District will have a role to play in helping to assist in meeting the growth requirements of the conurbation no figure is provided.

To summarise the position, Lichfield District, North Warwickshire and Solihull are preparing Plans that between them propose making a maximum contribution of 10,290 dwellings towards the housing shortfall. Redditch and Tamworth Districts are unable to make any contribution to the shortfall. As such the current evidence suggests that Bromsgrove District, Cannock Chase, Stratford-on-Avon and South Staffordshire will need to make significant contributions to addressing the remaining shortfall of 45,510 dwellings (55,800 dwellings minus 10,290 dwellings).

Given the close geographical relationship of South Staffordshire to the Black Country it is our view that South Staffordshire will need to play an important role in meeting a significant proportion of the unmet housing need figure. It is our view that current evidence indicates that South Staffordshire’s contribution should be 10,000 dwellings or more given the approach of the other authorities within the HMA. We see no evidence within the consultation document justifying the 4,000 dwelling figure within the context of the approach of the other authorities within the HMA.

It is also our view that the emerging Plan should include a buffer to allow for allocations not delivering as expected. It is not uncommon for Local Plan allocations to not deliver as expected. This could be for a variety of reasons including change in landowner’s aspirations, detailed technical work reducing the capacity of sites or change to the housing market. Therefore, it is commonplace for Plans to include a buffer so that there is, an over-allocation compared to the housing need to ensure delivery. For example, the Committee Report that accompanies the emerging Lichfield District Preferred Options Local Plan refers to a requirement for a 20-25% buffer to take account of non-delivery.

It is our view that the same approach will be adopted in South Staffordshire. Indeed, given that South Staffordshire is a predominantly Green Belt authority if, for any reason, the emerging Local Plan housing allocations do not come forward as expected, and a five year housing land supply shortfall arises, the opportunity for additional levels of windfall development coming forward to address the shortfall are constrained. A five year housing land supply shortfall alone is not sufficient to constitute ‘Very Special Circumstances’ to overcome the Green Belt designation. As a consequence development opportunities outside of the allocations in the emerging Plan will be limited and this could adversely affect housing delivery. A 20-25% buffer should, therefore, be added to the overall housing requirement to prevent this from occurring.

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The Purpose of this Consultation (paragraphs 2.7 – 2.9)

Whilst we support the preparation of a consultation document that seeks to indicate how development could be distributed across the Plan area, to assist local communities and infrastructure providers in understanding the implications of the distribution options, we are concerned that the level of development identified is unrealistic. As referred to above, it is our view that the emerging Plan substantially under-estimates the role it will need to play in assisting to meet the growth requirements of the conurbation. We are, therefore, concerned that the consultation document could be misleading.

Question 1 – Do you agree that the evidence based used to Inform spatial housing options is proportionate?

No. No reference is made to the progress of other Authorities Local Plans and the proportion of the unmet housing needs of the conurbation they may plan for. There is no reference to the fact that the housing shortfall identified by the Birmingham Development Plan is for the period up to 2031, whilst the emerging South Staffordshire Plan will have a Plan period that extends beyond this.

In addition, the Greater Birmingham Housing Market Area – Spatial Growth Study 2018, should not be considered a robust evidence-based document. When the Spatial Housing Options study was produced it was acknowledged that whilst it identified a potential housing shortfall figure it did so purely on a demographic basis. The housing requirement included within that document was not an objectively assessed housing needs figure. Indeed, the document suggests that if economic factors are included within the housing requirement figure it could be 50,000 dwellings more than that identified within the study. Furthermore, since it was produced the Standard Method has now come into place which means that the housing figure within that document is completely redundant. In addition the capacity figures provided by the Local Authorities to inform the study are entirely out of date. It is not a robust source of evidence.

Question 2 – Do you agree that taking account of housing land supply from the start of the new Plan period (1 April 2019) is the correct approach?

No. The housing being delivered up until the point of the adoption of a new Plan will be to meet the housing requirements of the adopted Local Plan. It is our view the emerging Plan’s housing requirement start date should be based upon the predicted date of the adoption of the Plan, i.e. 2022. This removes any potential criticism of there being an oversupply or an undersupply of housing that could be considered an ‘exceptional circumstance’ to depart from the application of the Standard Method. It also means the Plan does not need to be continually updated at the end of each monitoring year until the point of adoption to reflect changes in land supply. For example, if in any particular year there is a very limited delivery this will necessitate the Council potentially having to look to identify additional land for development. If in the following year there is significant over- delivery this matter could immediately correct itself and the allocations will need to be changed again.

Question 3 – Do you agree that all safeguarded land identified in the SAD should be released as a priority and should be delivered at an average density of 35 dwellings per hectare?

The release of safeguarded land should be prioritised over Green Belt land release. However, it is clear that additional Green Belt land allocations will be required in the emerging Plan.

We are concerned that it is suggested an average density of 35 dpa will be used. It is not clear what assumptions are made about gross to net ratio conversions for the purposes of the density calculation. In addition, in certain areas such as the rural fringes, 35 dwellings per hectare may result in unduly dense development that detracts from the surrounding area. In more urban areas it 6 may be possible to deliver a greater quantum of units entirely in keeping with the character of the neighbouring area.

Question 5 – Do you agree that the seven spatial housing options are appropriate to consider?

Yes. We agree that the spatial housing options are all robust. However, this must be considered in the context of our response that the housing requirement in the emerging Plan that is currently considered to be inadequate. In terms of a Preferred Option – Spatial Housing Strategy Option G, we support the recognition that Pattingham should be expected to accommodate additional development. It is a sustainable locations with a variety of services and facilities. It is in relatively close proximity to the conurbation. It is entirely appropriate for development to be directed towards this location.

Question 6 – Do you agree that spatial housing option 6 is a robust approach to meeting the needs of a District and to make a contribution towards the unmet needs of the GBHMA?

No. For reasons referred to in our response to paragraph 2.3 – 2.6 it is our view that the housing requirement within the Plan is inadequate. The emerging Plan should seek to make a greater contribution towards meeting the unmet housing requirements of the conurbation. In addition, a buffer should be added to the housing requirement to take account of under-delivery. That being the case, whilst we support the overall strategy identified by Option G, the level of housing should be increased proportionately in accordance with our suggestions to increase the overall housing requirement.

Question 7 – Do you agree that we should continue to explore options for new settlements?

Yes. We support the aspiration to identify a potential new settlement. However, it is highly unlikely that a new settlement allocation will deliver any housing until the latter part of the Plan period. New settlements have significant infrastructure requirements. There are often land assembly issues to resolve. There are complex planning issues to address once Local Plan allocations are put in place. That being the case, the lead-in time for the release of the first plots from the point of allocation will be a minimum of 5-6 years, and more likely close to 10 years. In view of this, if a new settlement is identified within the emerging Plan it should be done so on the basis that it will deliver within the next Plan period as oppose to the current Plan period. This is an approach that Lichfield District have adopted in their emerging Local Plan and an approach we consider to be sound.

Question 9 – Have we identified the three criteria for the identification of the sites? Are there any other factors we should consider?

We are generally supportive of the assessment criteria identified by Appendix 6 of the Plan. However, each potential allocation must be treated on its merits. Given the nature of the site selection process each site will have benefits and disadvantages and no two sites will be directly comparable. Therefore, whilst site selection criteria can be a useful guide in helping to assess sites, there also needs to be a degree of discretion. For example, it may be appropriate to allocate a site for development that has a greater degree of harm on the open countryside than an alternative location if that site has better access to services and facilities and is in a location that has a greater level of housing need. As a consequence a range of factors need to be considered when allocating sites for development and officers descension should be used. However, the rational for the selected sites should be clearly set out.

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Question 10 – Do you agree that when selecting sites to deliver the preferred spatial housing strategy, the Council should seek to avoid allocating housing sites that result in very high Green Belt harm wherever possible?

Under normal circumstances, yes. However, Green Belt harm needs to be weighed against other factors. That being the case, if a site is identified where its release would have a notable impact upon the Green Belt this does not automatically mean that it cannot be allocated for development. However, in order for it to be allocated for development significant evidence needs to be available about the wider benefits of the site such as access to services and facilities, its ability to deliver infrastructure such as affordable housing, public open space and any wider role it can perform such as potentially enabling development.

We trust you have found these representations useful. If you have any queries, please do not hesitate to contact the undersigned.

Yours sincerely,

John Williams

John Williams BA (Hons) MRTPI PlanIT Planning & Development Ltd http://www.planit-planningdevelopment.co.uk

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