Mrs K Harris CONTACT Alex Yendole Strategic Planning Team Manager DIRECT DIAL 01785 619 536 South Council FAX 01785 619 473 Council Offices EMAIL [email protected] OUR REF AY/766 Nr YOUR REF WV8 1PX DATE 12 December 2019

By post and e-mail

Dear Mrs Harris

SOUTH STAFFORSHIRE SPATIAL HOUSING STRATEGY & INFRASTRUCTURE DELIVERY

Thank you for the opportunity to respond to the South Staffordshire Local Plan Spatial Housing Strategy and Infrastructure Delivery consultation.

We note that South Staffordshire District’s housing need calculated, in accordance with the standard approach set out in Government planning guidance, to be 4,845 dwellings between 2018 and 2037. We also note that South Staffordshire Council proposes to plan an additional 4,000 homes as a contribution to meeting unmet housing need in the Greater Housing Market Area.

We see that seven spatial options for the distribution of those 8,845 homes have been appraised, and option G – Infrastructure-led development with an area of search for a new settlement beyond the plan period – is identified as the preferred option.

Appendix 4 (Indicative growth tables) to the Spatial Housing Strategy paper suggests that option G could include around 186 houses south of in the A34 corridor.

Stafford Borough Council has serious concerns about any urban extension to Stafford which does not provide appropriate infrastructure in Stafford to mitigate the impact. Whilst we note that option G shows an area of search in the north of your District adjacent to the Stafford boundary, the reality is that there is only one location where a development would form an urban extension to Stafford. If South Staffordshire Council decide to allocate land at this location for housing development the appropriate policy should recognize that, as the site is remote from any settlement or services in South Staffordshire, the occupiers of the development will look to Stafford to provide their services. Accordingly this will impact on roads, schools and leisure provision in Stafford, which should be appropriately mitigated. We therefore reserve the Council’s position on the proposal, pending further details being provided to demonstrate the following:

 that highways and education impacts in Stafford Borough can be acceptably mitigated,

 that contributions to meeting Stafford’s affordable housing need and providing for leisure facilities in Stafford would be secured,

 that impacts on the landscape, including the setting of the Chase Area of Outstanding Natural Beauty (AONB), would be acceptable,

 that appropriate mitigation for impacts on the Cannock Chase Special Area of Conservation (SAC) would be secured. To this end, Stafford Borough Council will continue to work alongside South Staffordshire Council through the Cannock Chase SAC Partnership.

We note that some of the rejected options included a larger urban extension south of Stafford and we strongly agree with the decision of South Staffordshire Council to reject this. As is mentioned in the consultation document, this option was not favoured in the Greater Birmingham Housing Market Area (GBHMA) Strategic Growth Study.

The preferred option involves an area of search on the A449 corridor for a new settlement beyond the plan period, after 2037. One of the options in the GBHMA Strategic Growth Study was a new settlement around Dunston, although this was not one of the recommended areas of search for strategic development. Any development in this location would have significant impacts on Stafford Borough. We would therefore be grateful if you could ensure that we are kept updated on the consideration of new settlement options and would welcome the opportunity to comment further, and consider infrastructure implications.

The Strategic Growth Study identified north of as a recommended area of search for a strategic urban extension. In our view this warrants further investigation, as an alternative to a new settlement or to new homes south of Stafford.

Finally, we note that the next consultation stage will consider options for accommodating requirements for employment land, and for gypsy, travelers and travelling show people’s accommodation. South Staffordshire Council is reviewing its needs and supply evidence regarding gypsies, travellers and travelling show-people. We would reiterate that, as previously advised, Stafford Borough Council is not in a position to provide for any unmet gypsy, traveller and travelling show-people needs within Stafford Borough.

I would be grateful if you could acknowledge safe receipt of this letter. In due course we will prepare and agree a statement of common ground in relation to strategic planning matters with cross border implications.

Yours sincerely,

Alex Yendole Planning Policy Manager