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South Staffordshire Local Plan Review Spatial Housing Strategy And December 2019 | DO/BC | P18-1747 SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION WOLVERHAMPTON AIRPORT, HALFPENNY GREEN ON BEHALF OF LILACTAME LIMITED TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004 ©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 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery CONTENTS: Page No: 1. INTRODUCTION 1 2. CONTEXT 3 3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS 6 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION 7 5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS 10 6. INFRASTRUCTURE DELIVERY PLAN 2019 14 7. GREEN BELT STUDY 2019 20 8. LANDSCAPE STUDY 2019 28 9. SUSTAINABILITY APPRAISAL 2019 31 10. RURAL SERVICES AND FACILITIES AUDIT 2019 33 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 35 12. WOLVERHAMPTON AIRPORT, HALFPENNY GREEN 36 13. CONCLUSION 43 APPENDIX 1: SITE LOCATION PLAN December 2019 | DO/BC | P18-1747 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 1. INTRODUCTION 1.1 This representation is made by Pegasus Group on behalf of Lilactame Ltd to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to Wolverhampton Halfpenny Green Airport, which Lilactame Ltd owns and is promoting for a mixed-use development designed to facilitate and support the continued operations at the airport. 1.2 These representations respond to the following documents, including addressing the questions set out within the Local Plan Review Consultation Document: • Spatial Housing Strategy, October 2019 • Infrastructure Delivery Plan, 2019 • Habitats Regulations Assessment Review, 2018 • Green Belt Study, 2019 • Landscape Study 2019 • Rural Services and Facilities Audit 2019 1.3 The representations are framed in the context of the requirements of the Local Plan to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework (NPPF), paragraph 35. For a Plan to be sound it must be: a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with December 2019 | DO/BC | P18-1741 Page | 1 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework. 1.4 The representations also give consideration to the legal and procedural requirements associated with the plan-making process. December 2019 | DO/BC | P18-1741 Page | 2 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 2. CONTEXT Adopted Local Plan 2.1 The South Staffordshire Local Plan comprises the Core Strategy (adopted December 2012) and the recently adopted Site Allocations Document (adopted September 2018). 2.2 Policy SAD1 of the Site Allocations Document requires South Staffordshire Council to carry out an early review of the Local Plan, which must be submitted to the Secretary of State for Examination by the end of 2021. The Review must be comprehensive and consider the need for additional growth and plan appropriately for it. This Plan will review, as a minimum, the following matters: • South Staffordshire’s own objectively assessed housing need and the potential for housing supply within the District (including existing safeguarded land identified through the Site Allocations Document) to meet this need; • The potential role of housing supply options within the District to meet unmet cross boundary needs from the wider Greater Birmingham Housing Market Area (GBHMA), including from the Black Country; • Employment land requirements for South Staffordshire, as identified through a comprehensive Economic Development Needs Assessment (EDNA); • South Staffordshire’s potential role in meeting wider unmet employment needs through the Duty to Co-operate; • The appropriateness of the existing settlement hierarchy and the strategic distribution of growth in light of new housing and employment needs; • The need for further additional safeguarded housing and employment land for longer term development needs, and the role of safeguarded land in meeting housing shortfalls across the GBHMA, including South Staffordshire’s own needs; • Gypsy, Traveller and Travelling Showpeople provision; and December 2019 | DO/BC | P18-1741 Page | 3 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery • A comprehensive Green Belt Review undertaken jointly with the Black Country authorities, to inform any further Green Belt release to accommodate new development within the District. Local Plan Review 2.3 The Local Plan Review is necessary in order to respond to the increasing need for development, both within South Staffordshire, and within neighbouring authorities which form the Greater Birmingham Housing Market Area (GBHMA). South Staffordshire District Council has determined that the Local Plan Review will cover the period to 2037. 2.4 South Staffordshire District Council commenced an Issues and Options (Regulation 18) consultation between Monday 8 October and Friday 30 November 2018. Representations were made by Pegasus Group on behalf of Lilactame to this consultation in respect of Wolverhampton Halfpenny Green Airport. 2.5 The Spatial Housing Strategy and Infrastructure Consultation represents a second ‘Regulation 18’ consultation, prior to the publication of a ‘Preferred Options’ (‘Regulation 19’) Local Plan, anticipated to occur in Summer 2020. Wolverhampton Halfpenny Green Airport 2.6 The adopted Core Strategy makes numerous provisions for supporting development at Wolverhampton Halfpenny Green Airport. The Vision for Locality Area Five states: “Wolverhampton (Halfpenny Green) Airport will be continuing to provide facilities for business aviation, recreational (private) flying, and flying training consistent with its role as a general aviation airport. The replacement of derelict and obsolete buildings with high quality well designed aviation related development and associated landscaping will have significantly improved the appearance of the site.” 2.7 Core Policy 12 of the adopted Core Strategy specifically relates to Wolverhampton Halfpenny Green Airport, along with Policy EV12 (Wolverhampton Airport – Approach to New Development) and Policy EV14 (Wolverhampton Airport – Existing and Future Uses). December 2019 | DO/BC | P18-1741 Page | 4 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 2.8 Core Policy 12 sets out an over-arching view in respect of the Airport, whilst Policies EV13 and EV14 provide further detail in respect of development management. 2.9 Policy EV13 states that the Council will support proposals for aviation uses including the replacement of existing outdated and unsustainable buildings and high-quality infill development where the proposals are consistent with national policy and other local planning policies and will not have a detrimental impact on the environment and nearby residents. 2.10 Policy EV14 states that the continued occupation of buildings on the site by existing established non-aviation uses that support the viability and sustainability of the Airport will be accepted where it is consistent with national planning policy. 2.11 Furthermore, Wolverhampton Halfpenny Green Airport is afforded its own Local Plan Policies Map inset through the Site Allocations Document (Inset Plan 43). This plan details the spatial application of Core Policy 12 and Policies EV13 and 14. Figure 2.1: Site Allocations Proposals Map Inset Plan 43, Wolverhampton Halfpenny Green Airport December 2019 | DO/BC | P18-1741 Page | 5 Lilactame Ltd Wolverhampton Airport, Halfpenny Green, Bobbington, Staffordshire South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS Question 1: Do you agree that the evidence base used to inform Spatial Housing Options is robust and proportionate? If not, what else should we consider? 3.1 The consultation document identifies a range of evidence relied upon by the Council to inform the preparation of the seven Spatial Housing Options. 3.2 Lilactame Ltd is pleased to see the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Strategic
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