FEBRUARY 2017 | NC | BIR.5025 PUBLICATION PLAN RESPONSE SOUTH STAFFORDSHIRE SITE ALLOCATIONS DOCUMENT LAND OFF PENDEFORD MILL LANE, BILBROOK ON BEHALF OF BLOOR HOMES TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004 Prepared by: Pegasus Group Pegasus Group 5 The Priory | Old London Road | Canwell | Sutton Coldfield | West Midlands | B75 5SH T 0121 308 9570 | F 0121 323 2215 | W www.pegasuspg.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool |London | Manchester ©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan CONTENTS: Page No: 1. INTRODUCTION 1 2. PLANNING POLICY CONTEXT 2 3. METHODOLOGY AND SITE SELECTION 10 4. BILBROOK 11 5. LAND AT PENDEFORD MILL LANE, BILBROOK 13 6. CONCLUSION 24 APPENDICES: APPENDIX 1: SITE PLAN APPENDIX 2: ILLUSTRATIVE MASTERPLAN - PHASE 1 APPENDIX 3: ILLUSTRATIVE MASTERPLAN - PHASE 2 APPENDIX 4: TECHNICAL NOTE ON FLOOD RISK APPENDIX 5: TECHNICAL NOTE ON ECOLOGY APPENDIX 6: TECHNICAL NOTE ON HIGHWAYS FEBRUARY 2017 | NC | BIR.5025 Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan 1. INTRODUCTION 1.1 These representations are made by Pegasus Group on behalf of Bloor Homes Limited to the South Staffordshire Site Allocations Document (SAD) ‘Publication’ Consultation. This representation relates to land off Pendeford Mill Lane, Bilbrook (Site Ref: 443) which is within the control of Bloor Homes (Appendix 1). 1.2 These representations respond to the emerging policies and allocations, having regard to the national and local policy context. The representations also provide comment in respect of the evidence base that underpins the emerging Site Allocations Document and the methodology and approach to site selection, making reference to representations submitted on behalf of Bloor Homes at earlier stages in the formulation of the Plan. 1.3 The representations are framed in the context of the requirements of the South Staffordshire SAD to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework (NPPF), paragraph 182. For a Plan to be sound it must be: Positively Prepared – the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; Effective – the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities; and Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework. 1.4 The representations also have regard to the Government’s recently published White Paper which places emphasis on planning for the right number of homes in the right places, in particular making enough land available and assessing housing requirements. FEBRUARY 2017 | NC | BIR.5025 Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan 2. PLANNING POLICY CONTEXT 2.1 It is recognised that the SAD is intended to deliver the spatial strategy set out in the Core Strategy, adopted by the Council in December 2012. The Core Strategy sets out a hierarchy of settlements and a spatial strategy of dispersing growth across the District, with the majority of development being focussed to the Main Service Villages (MSV), which includes Bilbrook within Locality Area 4 (Central Area). 2.2 Within these villages a choice of housing will be delivered to meet local needs, whilst recognising the constraints that impact upon the District, including affordable housing, with extra care and specialist housing being regarded as a priority. The Core Strategy recognises that development to meet the Districts housing need will be required outside the existing development boundaries of a number of settlements. Core Policy 1 of the Core Strategy confirms that Green Belt release will be required around some of the villages to deliver the housing numbers allocated within Core Policy 6. Housing Requirement 2.3 The Core Strategy identifies, through Core Policy 6 (Housing Delivery) a minimum requirement to deliver 3,850 net new homes within the District between 2006 and 2028. This equates to delivery of 175 new homes per annum. Core Policy 6 then provides greater detail as to how the housing requirement will be delivered across the Locality Areas. This includes the provision of a minimum of 515 dwellings within Locality Area 4 within which Bilbrook is located. Of this requirement for Locality Area 4, a minimum of 105 dwellings are to be allocated within or adjacent to Bilbrook. 2.4 It is recognised that net housing completion rates within the Plan period have often exceeded the annual minimum requirement established through the Core Strategy, however site opportunities outside of the Green Belt are becoming significantly diminished. 2.5 In addition to the reduction in deliverable supply, concern is raised that the housing requirement contained within the Core Strategy has not been informed by the consideration of the full objectively assessed housing need (FOAN) for the District. Instead, the Core Strategy requirement has been derived from the West Midlands Regional Spatial Strategy (WMRSS) Phase Two Revision Panel Report. FEBRUARY 2017 | NC | BIR.5025 Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan 2.6 The Government’s imperative to boost significantly the supply of housing is set out clearly in paragraph 47 of the National Planning Policy Framework (NPPF). This requires local planning authorities to ensure their local plans meet the full, objectively assessed needs for market and affordable housing in the housing market area, consistent with the policies set out in the Framework. 2.7 In relation to establishing a housing requirement, paragraphs 50, 158 and 159 of the NPPF set out a number of matters which should be taken into account. Local Planning Authorities should ensure that their assessment of, and strategies for housing, employment and other uses are integrated and they take full account of relevant market and economic signals. In order to assess full housing needs, there is a need to take account of evidence of current and future demographic trends, market trends and the needs of different groups in the community. Paragraph 159 explains that this means: Meeting household and population projections, taking account of migration and demographic change; Addressing the need for all types of housing including affordable housing and the need of different groups in the community; Catering for housing demand and the scale of housing to meet this demand. 2.8 On 6 March 2014 the Department for Communities and Local Government (CLG) launched the Planning Practice Guidance (PPG). This was accompanied by a Written Ministerial Statement which included a list of the previous planning practice guidance documents cancelled when the website was launched. 2.9 The PPG seeks to explain further elements set out in the NPPF. With respect to the objective assessment of housing need, it makes the following points amongst others: Household projections provide the starting point of overall housing need; They may require adjustment for example to reflect previously suppressed household formation rates; and It is relevant to take account of the likely change in job numbers. FEBRUARY 2017 | NC | BIR.5025 Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan 2.10 The recently published White Paper recognises that over 40% of local planning authorities do not have a plan that meets the projected growth in households in their area. South Staffordshire District Council falls into this category. 2.11 It is understood that the Council, in conjunction with the Black Country Authorities, has now undertaken a SHMA to consider the Full Objectively Assessed Need (FOAN) for the period 2016 to 2036, however this work remains unpublished and the FOAN remains unestablished. It is noted that the Council is instead seeking to rely on the minimum housing requirement of 175 dpa identified through the adopted Core Strategy. Whilst there is likely to be a significant level of criticism raised that this element of the evidence base is missing, it is clear that land needs to be taken out of the Green Belt as soon as possible to boost and enable a continuous supply of housing to meet needs in the short term. Therefore, the production of the SAD provides the most expeditious route to significantly boosting housing land supply in line with Government policy. 2.12 Whilst the production of this second tier Local Plan is supported as a mechanism by which to remove land from the Green Belt and boost housing land supply within the immediate future, progression of the SAD should not delay the publication of the Joint SHMA or be at the expense of an early review of the Local Plan.