Report Contents ( Photo)

Lichfield District Council Local Plan Allocations Examination Reponse to Matter 5

August 2018

GVA HOW Planning Client: Grasscroft Homes & Property Ltd Response to Matter 5

Contents

1. Introduction ...... 1 2. Response to Matter 5 ...... 2 3. Summary ...... 8 Appendices

Appendix I Sefton Inspectors Report Extract Appendix II Sefton Local Plan Extract (Paragraph 1.19) Appendix III Sefton Local Plan Extract (Paragraph 4.42-4.44) Appendix IV South Staffordshire SAD Policy SAD1 Extract Appendix V Site Location Plan Appendix VI SHLAA 2018 Extract

Prepared By: Rachel Jones Status: 1 Draft Date: August 2018

For and on behalf of HOW Planning LLP

Date: August 2018 Client: Grasscroft Homes & Property Ltd Response to Matter 5

1. Introduction

1.1 On behalf of Grasscroft Homes & Property Ltd (“Grasscroft”), we thank you for the opportunity to submit representations to the Inspector on the Lichfield Local Plan Allocations Document.

1.2 These representations have been prepared by GVA HOW Planning (“HOW”) on behalf of Grasscroft and are submitted in relation to a site at Hay End Lane, Fradley (“the site”). They should be read in conjunction with Grasscroft’s previous representations to the Local Plan Review - Scope, Issues and Options (June 2018), the draft Local Plan Allocations Focused Change Document (February 2018), Publication Document (May 2017) and Call for Sites exercise (May 2017).

1.3 These representations respond to Matter 5 of the Inspectors Matters, Issues and Questions (MIQ’s):

How should the Plan deal with the housing shortfall, such as Birmingham and Tamworth?

1.4 On behalf of Grasscroft we have also prepared Hearing Statements in response to Matter 3 and Matter 11. This Hearing Statement should be read alongside these other Hearing Statements.

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2. Response to Matter 5

2.1 Matter 5 of the Inspector’s MIQ Discussion Note asks how the Plan deals with the housing shortfall in neighbouring authorities, such as Birmingham and Tamworth. Specifically, Matter 5 asks LDC the following questions:

5.1 In view of the urgency of making housing provision to meet the needs of Greater Birmingham, what are the arguments for delaying a positive response until the Local Plan Review? Does the GBHMA suggest a timeframe and quantum for contributions from Councils such as Lichfield? Is the estimated date for adopting such a review still December 2020? Should not this Plan be aiming to contribute towards these wider needs before December 2020, a date which may slip? [An MOU or SCG between the GBHMA and/or Birmingham CC and Lichfield DC would be helpful.]

5.2 Should the Plan deal with Tamworth’s housing shortfall during the same review process, or is the need sufficiently urgent for it to be addressed in this Plan? What role would the development at Arkall Farm play in this, and if planning permission is not forthcoming, what should be included in the Plan to address the shortfall? [An MOU or SCG between the Tamworth BC and Lichfield DC would be helpful.]

5.3 If the review of the Plan is more than an aspiration, should there be a specific policy committing the review process to start by a specific date?

2.2 This paper comments generally on how the Plan deals with housing shortfall in neighbouring authorities and specifically responds to Matter 5.3.

Greater Birmingham Housing Market Area (GBHMA) Need

2.3 The GBHMA Strategic Growth Study was published in February 2018 and is an evidence base document that has been jointly commissioned by the 14 Authorities from across the GBHMA and prepared by GL Hearn. The 14 Authorities includes Birmingham, the Black Country, Bromsgrove, Redditch, Solihull, North Warwickshire, Tamworth, Cannock Chase, South Staffordshire and parts of Stratford-on-Avon. The GBHMA Strategic Growth Study reflects the requirement in the Localism Act 2011 and the revised NPPF (paragraph 24) for Local Authorities to work together through the ‘Duty to Cooperate’ across the relevant Housing Market Area (“HMA”) to identify and then meet housing need where it is sustainable to do so. The study is intended to identify more specific options and broad locations for addressing the housing supply shortfall in Birmingham.

2.4 The key findings of the study can be summarised as follows:

• Provision of between 205,000 – 246,000 homes is needed across the GBHMA to 2031; and provision of between 256,000 – 310,000 homes to 2036 (from a 2011 baseline) to meet the GBHMA’s housing needs;

• There is a developable land supply of approximately 180,000 dwellings across the HMA to 2031, and 198,000 dwellings to 2036 based on sites and supply currently identified;

• Based on current supply assumptions, and taking into account proposed allocations in emerging plans, there is an outstanding minimum shortfall of 28,150 dwellings to 2031 and 60,900 dwellings to 2036 across the GBHMA;

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• Increases in development densities could potentially contribute 13,000 homes to addressing the housing needs shortfall. Taking this into account, the residual minimum shortfall would be 15,150 dwellings to 2031 and 47,855 dwellings to 2036;

• Clearly, additional land for residential development needs to be identified to meet development needs to 2031.This is likely to include a need for such sites both within and beyond the Green Belt; and

• To address the housing needs shortfall, it is important that housing requirement figures within Local Plans are amended and make provision for addressing unmet housing needs.

2.5 It is noted that the identified minimum shortfall of 28,150 dwellings to 2031 within the study is considerably lower than the figure within the Birmingham Development Plan (“BDP”), adopted in January 2017, which quantified the shortfall as 37,900 dwellings to 2031.

2.6 In any event, it is important that LDC addresses how much of the GBHMA housing need will be met within Lichfield. The Local Plan Allocations document does not do this.

2.7 A number of the other Local Authorities within the GBHMA have considered the possibility of assisting in meeting Birmingham’s housing shortfall and have suggested an indicative figure of how many dwellings they may be able to accommodate. These include:

• Solihull - The draft Local Plan Review document published in November 2016 indicates that Solihull should test the potential to accommodate a further 2000 dwellings from the shortfall in addition to accommodating the Borough’s own needs;

• North Warwickshire – The draft submission document of the new Local Plan (November 2017) states that a figure of 10% of the shortfall should be tested which would mean a potential additional number of dwellings of 3,790 for GBHMA; and

• Cannock Chase - The consultation on the Local Plan (Part 2) Issues & Options Development Plan Document ran between the 29th January until 27th March 2017. This document put forward the possibility of accommodating 1,000 additional dwellings.

2.8 The Local Plan Allocations Focused Changes document does not accommodate any of the GBHMA needs. It is not understood from the Focused Changes document why LDC, who acknowledge there is a need, are not willing to accommodate this need now. Failing to deal with the GBHMA need now, could lead to economic and social problems in the Borough.

2.9 Paragraph 60 of the revised NPPF requires any needs that cannot be met within neighbouring areas to be taken into account in the housing requirements contained with planning policies:

“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”

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2.10 LDC should plan for a level of housing growth to support the economic aspirations of the Local Authorities, align with their growth objectives, and accommodate the unmet need from the GBHMA. There are substantial negative economic and social implications of not providing sufficient housing to meet identified needs and demand. It is therefore crucial that enough housing land is allocated in the Allocations document for residential development to meet the needs of the GBHMA.

Addressing GBHMA Need

2.11 Whilst LDC do not commit to how many dwellings it may be able to accommodate, it does commit to a review to address the GBHMA issues at paragraph 1.10 of the Focused Changes document:

“In order to facilitate much needed development the District Council has proactively prepared this Allocations document. The Council is aware, and is committed to reviewing its Plan in full to address the Greater Birmingham Housing Market Area issues, specifically the shortfall in addressing the housing needs within this area. The Council continues to work proactively with partners to identify the appropriate amount of growth to be accommodated within the boundaries of Lichfield District. In addition, as part of this review the Council will continue work with other Neighbouring Authorities through the Duty to Cooperate, as well as undertake a comprehensive review of its evidence base.”

2.12 LDC’s commitment to review is addressed again under ‘A Commitment to Review’ at paragraphs 4.7 and 4.8 of the same document.

2.13 It is noted that the Focused Changes document only goes as far as to commit to a review of the Local Plan and does not give any indication of how many houses will need to be accommodated, or provide a date of when a review is required by.

2.14 Whilst it is our view that the Local Plan Allocations document should address the GBHMA housing need now, should the Inspector not require this, then the Local Plan Review mechanism at least needs to be clear as to when a review will take place. It should also identify the appropriate amount of growth to be accommodated within the boundaries of LDC, including an indicative number of dwellings. Not doing so puts LDC at risk of not being able to deliver the required dwellings and meet its growth objectives and vision as set out in the Local Plan Strategy.

2.15 This approach has been undertaken elsewhere, for example, in Sefton Metropolitan Borough Council and in South Staffordshire (ie: a GBHMA Authority).

2.16 An immediate review of Sefton’s Local Plan was required by the Inspector following the publication of the Inspectors report into the Sefton Local Plan in March 2017. The requirement for an immediate Local Plan review is required to deal with any unmet needs arising from the Liverpool City Region Strategic Housing and Employment Land Market Assessment. The approach required by the Inspector at Sefton in terms of the Local Plan review has clear similarities to the situation in Lichfield. Sefton Council adopted its Local Plan on 20 April 2017 and the Inspectors Report at paragraph 20 states the following in relation to an immediate review of the Plan (with HOW emphasis in bold):

“During the examination hearings many representors argued that an ‘early’ review process is not sufficiently urgent or precise to deal with any unmet needs arising from the SHELMA study. In response,

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the Council agreed to commit to an ‘immediate’ review or partial review following publication of the SHELMA study and to submit the review within two years of adoption of this Plan. This strengthened commitment is necessary for the Plan to be found sound; MM6 incorporates it as a new part 5 to policy MN1 and MM2 and MM8 make similar changes to the text.”1

2.17 An extract of paragraph 20 of the Inspectors Report is provided at Appendix 1.

2.18 The Inspector in South Staffordshire similarly required the Council to include a robust review mechanism within the Local Plan.

2.19 Chapter One of the Sefton Local Plan states the following at paragraph 1.19 (with HOW emphasis in bold):

“In 2013, the Local Enterprise Partnership commissioned a study of the land implications arising from the expanded Port of Liverpool (under construction at the date of publication). This study found that in the short term (the first 5 years) there were sufficient high quality sites to accommodate the needs of the expanded port. However in the medium-to-long-term (i.e. 5-20 years), the study found a deficit of around 400 to 500 ha of high quality sites across the wider Liverpool City Region (LCR) relative to anticipated demand. Given respective Local Plan timescales, with some either adopted or at an advanced stage, it has not been possible for local authorities to act in tandem to identify sites to meet this need in the short term. A need for an immediate review of the Local Plan to address the needs generated by the expanded Port of Liverpool is considered at paragraph 4.42. A commitment to undertaking the necessary sub- regional studies is currently being sought form the other Liverpool City Region local authorities, as required by the Duty to Cooperate document.”2

2.20 An extract of paragraph 1.19 of the Sefton Local Plan is provided at Appendix 2.

2.21 Paragraph 4.42 of the Sefton Local Plan confirms that Sefton Council propose to review their Plan if required to take account of the results of the Liverpool City Region study focusing on addressing the land needs arising from port expansion, and paragraph 4.44 commits to an immediate review of the Plan if the publication of the sub-regional Strategic Housing and Employment Land Market Assessment (SHELMA) identified a need for more housing or employment including land for logistics associated with the Port of Liverpool. An extract of the relevant paragraphs of the Sefton Local Plan is provided at Appendix 3.

2.22 Policy SAD1 (Local Plan Review) of the South Staffordshire Site Allocations Document (SAD) (June 2018) states:

“South Staffordshire Council shall carry out an early review of the Local Plan that will be submitted to the Secretary of State for Examination by the end of 2021. This will be a comprehensive review of the Local Plan for South Staffordshire that will consider the need for additional growth and plan appropriately for this. This plan will review, as a minimum, the following matters, which are based upon known strategic issues affecting the District at this point in time;

1 Sefton Local Plan – Inspector’s Report, March 2017, paragraph 20, page 7 2 Sefton Local Plan (April 2017), paragraph 1.19, page 2

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• 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.

• 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.”3

2.23 An extract of Policy SAD1 of the South Staffordshire SAD is provided at Appendix 4.

2.24 Taking the above into account, Grasscroft agrees with the Inspectors suggestion at 5.3 that there should be a specific policy committing the review process to start by a specific date.

2.25 In summary, it is important that LDC includes a clear mechanism for a full or partial review of its Local Plan within the Local Plan Allocations document for it to be found sound. The Local Plan review mechanism should also include specific timescales for a review following. Appropriate wording is suggested below as follows:

"In order to facilitate much needed development the District Council has proactively prepared this Allocations document. The Council is aware, and is committed to reviewing its Plan in full within 1 year of adoption to address the Greater Birmingham Housing Market Area issues, specifically the shortfall in addressing the housing needs within this area. The Council continues to work proactively with partners to identify the appropriate amount of growth to be accommodated within the boundaries of Lichfield District. In addition, as part of this review the Council will continue to work with other Neighbouring Authorities through the Duty to Cooperate, as well as undertake a comprehensive review of its evidence base."

Additional Sites

2.26 In order to achieve the commitment to meeting GBHMA needs, it is likely that LDC will be required to accommodate a significant level of housing growth, therefore additional housing allocations will be required. The site at Hay End Lane represents a sustainable location which would contribute towards meeting the wider requirement to deliver an additional 28,150 homes in the GBHMA.

2.27 As set out in the previous representations made by Grasscroft to the Local Plan Review - Scope, Issues and Options (June 2018), the draft Local Plan Allocations Focused Change Document (February 2018), Publication Document (May 2017) and Call for Sites exercise (May 2017), the site at Hay End Lane, Fradley should be allocated for housing to compensate for the under delivery of strategic sites and allocated sites and to contribute towards meeting the needs in the Greater Birmingham Housing Market Area (GBHMA). A site location plan is provided at Appendix 5.

3 South Staffordshire Site Allocations Document (SAD) (June 2018), Policy SAD1: Local Plan Review, page 22

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2.28 The site at Hay End Lane, is identified in the Strategic Housing Land Availability Assessment 2018 as site 1119 and is shaded in green which denotes it is a deliverable site. Table B.144 of the same document provides further information on the site including stating that it is suitable, available and achievable. On suitability the table states:

“Outside village boundary but is adjacent to a sustainable settlement as identified within the adopted Local Plan Strategy. Outside settlement. Does not wholly comply with current development plan policies in the Local Plan. However, site falls within broad area for search for assessment of sites which could contribute to sustainable mixed communities…”4

2.29 An extract from the SHLAA is provided at Appendix 6.

2.30 It is clear the Council consider the site to be a sustainable and suitable housing site which Grasscroft strongly supports.

2.31 Grasscroft’s representations to the Local Plan Allocations – Focused Change Document in February 2018 (pages 8 to 11) fully demonstrates the sustainability and deliverability of the site to support its allocation for future residential development in the Local Plan Allocations Document. The site is located within a highly sustainable location, benefits from strong transport links and is close to a variety of local services and facilities. Furthermore, the nature and location of the site is such that it is considered capable of delivering a high-quality residential development of a modest scale within the plan period, contributing to meeting housing need not just within LDC, but also the wider Greater Birmingham HMA. Housing development would be well related to and in keeping with the character of Fradley village and the adjacent residential development that is currently coming forward.

4 Strategic Housing Land Availability Assessment 2018, Table B.144, page 129

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3. Summary

3.1 In summary, the Local Plan Allocations document is not sound as it does not meet the requirements of paragraph 35 of the NPPF in the following ways:

• Positively prepared – The Local Plan Allocations Focused Changes document does not accommodate any of the 28,150 units required in the Greater Birmingham HMA and therefore fails to adequately take account of its own evidence base which demonstrably highlights the need for a portion of this housing to be delivered in Lichfield Borough.

• Justified – The Local Plan Allocations Focused Changes document is not justified as it does not allocate additional sites in line with LDC’s and Greater Birmingham’s housing needs. Therefore, it is not the most appropriate strategy based on proportionate evidence.

• Effective - The Local Plan Allocations Focused Changes document is not effective because it ignores the requirement to accommodate any of the 28,150 units required in the Greater Birmingham HMA and therefore fails to undertake effective joint working on cross-boundary strategic priorities.

• Consistent with National Policy - The Local Plan Allocations Focused Changes document does not deliver enough housing for Lichfield. It also does not accommodate any of the 28,150 units required in the GBHMA. Overall, the Local Plan Allocations document fails to identify enough sites to accommodate LDC’s need as well as GBHMA’s need and as such the Plan jeopardises the delivery of the Council’s development growth. The Plan is therefore not consistent with the NPPF,

3.2 To conclude, this Hearing Statement establishes that LDC should accommodate GBHMA’s housing needs now. Furthermore, Grasscroft’s response to Matter 3 casts doubt as to whether the strategic housing needs over the Plan Period will be delivered as evidence suggests the outline planning permissions and Strategic Development sites in Fradley are likely to under deliver. In addition, there is evidence which doubts the deliverability of sites relied upon in the Five-Year Housing Land Supply Paper. Finally, and as set out in Matter 11, there are serious doubts on the deliverability of allocated sites.

3.3 Whilst it is Grasscroft’s primary position that additional sites should be allocated for housing now to accommodate GBHMA housing needs, such as the site at Hay End Lane, Fradley, if the Inspector does not agree, then the Allocations document should at least identify how much of the GBHMA house needs will be accommodated as well as provide firm timescales for a review of the Local Plan in the same way that the Inspector required at Sefton.

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Appendix I Sefton Inspectors Report Extract

Sefton Local Plan - Inspector’s Report, March 2017

Assessment of Soundness Early Review of Plan

17. When submitting the Plan for examination, the Council indicated that an early review will be necessary for two reasons. Firstly, the imminent major expansion of the Port of Liverpool is expected to generate significant additional demand for employment land across Merseyside which is to be reviewed at sub-regional level. Secondly, the housing requirement in the Submission Plan was based on household projections from 2011, the most up-to-date available at the time it was prepared. In February 2015 new (2012-based) household projections were released which indicate significantly higher growth than previously. Furthermore, employment–led projections suggest an even higher level of household growth which could have implications at sub-regional level. The early review is intended to take account of the findings of the SHELMA study which will address housing and employment growth across the LCR.

18. In its Housing Technical Paper2 the Council stated that to meet the economic- led housing requirement would require a re-write of the plan, setting back the process by a number of years. It cited a Written Ministerial Statement (WMS) of 21 July 2015 which stresses the Government’s commitment to timely local plan production and indicates that an early review of a plan may be appropriate to ensure that it is not unnecessarily delayed by seeking to resolve matters which are not critical to its soundness or legal competence as a whole.

19. Because this matter could potentially have threatened the entire examination process, it was discussed at the Pre-Hearing Meeting (PHM) in September 2015. Many representors supported the early review process and no one present argued against it. Consequently, and mindful of the WMS and the Government’s strong advocacy of adopted local plans as a means of addressing housing needs, I indicated at the PHM that the examination would proceed on the following basis. If I were to find that housing delivery did not meet the substantially increased objectively assessed housing need based on 2012 household projections, the fact that the increase in housing need arose very late in plan preparation, coupled with the commitment to an early review, would be sufficient for the Plan not to be found unsound. There has been no objection to this course of action since the PHM.

20. During the examination hearings many representors argued that an ‘early’ review process is not sufficiently urgent or precise to deal with any unmet needs arising from the SHELMA study. In response, the Council agreed to commit to an ‘immediate’ review or partial review following publication of the SHELMA study and to submit the review within two years of adoption of this Plan. This strengthened commitment is necessary for the Plan to be found sound; MM6 incorporates it as a new part 5 to policy MN1 and MM2 and MM8 make similar changes to the text.

21. Shortly before this report was completed the Government published the Housing White Paper entitled “Fixing our broken housing market”.3 The White Paper is a consultation document on a number of proposed policy changes to

2 Document TP.1, July 2015. 3 Published by Department for Communities and Local Government on 7 February 2017 – Cm 9352.

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the NPPF as well as to the regulatory framework for plan making. Whilst the proposals in the White Paper may have implications for matters discussed during the examination, they do not yet form part of Government policy and they might change following the consultation. Because the end of the examination was imminent, and in light of the Government’s objective that plans should not be unnecessarily delayed, I decided (after consulting Sefton Council) that it was not necessary to seek comments on the implications of the White Paper for this Plan. Instead, it will be for the Council to respond to the forthcoming changes to the NPPF, and any regulatory changes, when undertaking the review of the Plan.

Main Issues

22. Taking account of all the representations, written evidence and the discussions that took place at the examination hearings I have identified six main issues upon which the soundness of the Plan depends. Under these headings my report deals with the main matters of soundness rather than responding to every point raised by representors.

1 – VISION AND OBJECTIVES

Issue 1: Whether the Plan’s vision and objectives provide a sound framework for the sustainable development of Sefton borough.

23. Sefton is a flat, low-lying coastal borough extending from Bootle in the south to the Victorian resort of Southport in the north. It is an area of considerable variety and contrasts, from areas of closely-spaced 19th century terraced housing around the Liverpool docks to leafy, low density 20th century suburbs, from long-established industrial and port-related activity to modern business and retail parks, and from internationally important nature conservation sites along the coast to high quality agricultural land in the centre and east of the borough. Almost half the population lives in settlements that abut and make up the northern extent of the Liverpool urban area (Aintree/Bootle/Netherton/ Litherland/Crosby/Waterloo/Blundellsands), a third lives in Southport (including Birkdale and Ainsdale), while the remainder lives mainly in the free- standing dormitory towns of Maghull and Formby.

24. Rather than defining a simple, all-encompassing vision for Sefton, the Plan outlines the various ways in which the needs of Sefton’s communities will have been met by 2030. These include increasing the range and affordability of housing, and making the most of the borough’s assets – its coastal location, attractive environment and position within the LCR – to attract jobs and investment. The Plan seeks a more flexible approach to town and local centres to enable them to withstand changes in retailing, and improved infrastructure which provides better access to facilities, employment and services. At the same time the Plan aims to protect important nature sites, heritage assets and green infrastructure, and to promote the borough’s tourism potential. All these objectives are consistent with the NPPF.

25. There are major constraints to development in Sefton. All of the borough outside the existing urban areas is part of the Merseyside Green Belt and most of the coastline comprises internationally important sites for nature conservation. Much of the flat, low-lying land behind the coast is of high

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Appendix II Sefton Local Plan Extract (Paragraph 1.19)

SEFTON LOCAL PLAN CHAPTER ONE - INTRODUCTION AND DUTY TO CO-OPERATE

advantage was countered by potential loss of some of its population to Sefton. All adjoining authorities supported Option 2 which was based on Sefton meeting its needs.

1.19 In 2013, the Local Enterprise Partnership commissioned a study of the land implications arising from the expanded Port of Liverpool (under construction at the date of publication). This study found that in the short term (the first 5 years) there were sufficient high quality sites to accommodate the needs of the expanded port. However in the medium-to-long-term (i.e. 5- 20 years), the study found a deficit of around 400 to 500 ha of land for high quality sites across the wider Liverpool City Region (LCR) relative to anticipated demand. Given respective Local Plan timescales, with some either adopted or at an advanced stage, it has not been possible for local authorities to act in tandem to identify sites to meet this need in the short term. A need for an immediate review of the Local Plan to address the needs generated by the expanded Port of Liverpool is considered at paragraphs 4.42 and 4.43. A commitment to undertaking the necessary sub-regional studies is currently being sought from the other Liverpool City Region local authorities, as required by the Duty to Cooperate document.

1.20 The Mersey Ports Master Plan identifies a number of ‘areas of change’ within or adjacent to the Port estate where land will be required to accommodate the expansion of the Port. One area at Regent Road/Derby Road which straddles the Sefton-Liverpool boundary is currently occupied by a significant number of small and medium sized businesses. If the land were acquired by the Port to facilitate expansion, then any businesses that were displaced would create additional demand for employment land elsewhere. In a report appended to the 2012 Employment Land & Premises Study, a total requirement of 13.16ha arising from this source was identified. Following discussions with Liverpool City Council, an 80-20 split of this requirement was formally agreed, leading to an apportionment of 2.63ha to Sefton’s employment land requirement, with the balance of 10.53 ha to Liverpool.

1.21 In addition, Sefton adopted the Joint Waste Local Plan in 2013 which was jointly prepared with the other Liverpool City Region (LCR) authorities. It has also worked on a number of joint studies, including:

 The Merseyside and West Lancashire Traveller Accommodation Assessment 2014

 Green Belt Study 2013 - prepared to a common methodology with Knowsley and West Lancashire

 A joint Housing and Economic Development Evidence Base Overview Study 2011 (the ‘Overview’ Study) which included the LCR authorities plus Cheshire West and Chester authorities, and the former 4NW

 Annual Strategic Housing Land Availability Assessments (SHLAAs) - prepared to a common methodology with Knowsley and West Lancashire

 Employment Land and Premises Study (2010) jointly commissioned between Sefton, West Lancashire and Knowsley

1.22 Sefton also attends bi-monthly meetings with other LCR authorities to discuss sub-regional issues, and is a formal member of the LCR Combined Authority which was formally established on 1 April 2014. The Council has also worked closely with the Local Enterprise Partnership and other relevant bodies including the Environment Agency, Historic England, the Homes and Communities Agency, Merseytravel and others in preparing its Local Plan.

Appendix III Sefton Local Plan Extract (Paragraph 4.42-4.44)

SEFTON LOCAL PLAN CHAPTER FOUR - DEVELOPING A STRATEGY FOR SEFTON

4.35 In response to local concern about the value of local agricultural land, a separate study has assessed the quality of the agricultural land where development was likely to be proposed. Around 30% of Sefton’s agricultural land is classified as grade 1, grade 2 and grade 3a (‘best and most versatile’ agricultural land), together forming less than 1% of England’s best and most versatile agricultural land.

4.36 Where significant development of agricultural land is demonstrated to be necessary, the NPPF requires that “local planning authorities should seek to use areas of poorer quality land in preference to land of a higher quality” (paragraph 112). In Sefton, the majority of the sites suitable for development are on high quality agricultural land. However, there is not enough land of a poorer agricultural quality to meet objectively assessed housing and employment needs. Even where such land is available, these sites are often subject to other constraints. In Sefton’s case therefore, ‘best and most versatile’ agricultural land will need to be allocated for development consistent with national planning policy.

How much development are we providing for in total?

Land for homes 4.37 The housing requirement over the Plan period is calculated at 11,520. It is good practice to add in a ‘buffer’ of at least 5% in case a few sites do not come forward as anticipated or the densities are lower than proposed. The total identified supply is 11,435. Local authorities are also expected to look beyond the Plan period and to identify what is known as ‘safeguarded land’ in order to meet longer-term needs beyond the current Plan period.

4.38 Safeguarded land is taken out of the Green Belt upon adoption of the Local Plan, but is protected from development. It can only be allocated for development through a future review of the Local Plan. Safeguarded Land has been identified to accommodate around 1,000 dwellings. In addition, some of the sites identified in the Plan will not be completed until beyond 2030, and will therefore contribute an additional 500 dwellings to the supply after the end of the Plan period.

Land for employment 4.39 The employment land requirement over the Plan period is for 81.59 hectares, as recommended by the Employment Land and Premises Study Refresh.

4.40 The majority of this requirement can be met from sites in the existing urban area, but at least 28 hectares will need to be accommodated elsewhere. For this reason, the Plan proposes to identify two Strategic Employment Locations on land previously in Green Belt.

4.41 In addition, Government population projections indicate a decline in Sefton’s working age population to 2030. The new housing provided through the Local Plan will help to retain families and younger people and minimise the reduction in the Borough’s labour force.

Immediate review of the Plan

4.42 It is acknowledged that the expansion of the Port of Liverpool is likely to generate significant additional demand for distribution and other port-related uses across Merseyside. This is likely to be such a significant issue that it will need to be reviewed comprehensively at a sub- regional level. The Liverpool City Region authorities have agreed in principle to carry out a study focusing on addressing the land needs arising from port expansion. It is proposed to

29 SEFTON LOCAL PLAN CHAPTER FOUR - DEVELOPING A STRATEGY FOR SEFTON

review the Plan if required to take account of the results of this study in a co-ordinated sub- regional manner.

4.43 This review will also reflect the conclusions of the Port of Liverpool Options Identification and Assessment commissioned by Highways England in relation to proposals for major road improvements. Public engagement as part of this work took place early in 2017. The options assessment work is expected to be completed in summer 2017.

4.44 The Council is committed to an immediate review of the Plan if the publication of the sub- regional Strategic Housing and Employment Land Market Assessment (SHELMA) identifies a need for more housing or employment, including land for logistics associated with the Port of Liverpool (see part 5 of policy MN1 ‘Housing and Employment Land Requirements’). To this end, and as part of the Duty to Co-operate, it is collaborating with the other Liverpool City Region authorities to carry out this study. 4.45 Any review of the Plan also provides the opportunity for the Council, working where appropriate in collaboration with the other Liverpool City Region authorities, to generate a new evidence base regarding wind energy. This would assist the Council to determine wind energy applications in the light of the NPPF, National Planning Practice Guidance and the Ministerial Written Statement of 18 June 2015.

Capacity of the existing built-up area

4.46 Around 6,300 homes can be accommodated in the urban area when proposed housing allocations on former green space land are taken into account. In addition, a further seven employment sites are located within the urban area.

Proposed pattern of development

4.47 A key objective of the Plan is ‘to meet the diverse needs for homes, jobs, services and facilities, as close to where they arise as possible’. 4.48 In considering the approach to locating future development, it is helpful to reflect on historic patterns of development. Detailed records of new house building are available over the past 30 years.

Figure 4.2 No. of homes completed in the last 30 years (1984-2014) by area (Sefton, 2014)

1984 – 2014 % of total Southport 5,089 32.5 Formby 1,064 6.8 Sefton East Parishes* 1,839 11.7 Crosby & Hightown 2,107 13.4 Bootle & Netherton 5,581 35.6 Sefton 15,680 100 *Sefton East Parishes comprises Molyneux, Park, and Sudell wards 4.49 The above table shows that Bootle, Netherton, and Southport have accommodated two-thirds of total housing development over the past 30 years. However, this pattern of development cannot continue over the plan period as the opportunities to build new homes in these areas are not available to the same degree as previously.

Appendix IV South Staffordshire SAD Policy SAD1 Extract

Site Allocations Document (SAD) June 2018

South Staffordshire’s Local Plan Review

Policy SAD1: Local Plan Review

South Staffordshire Council shall carry out an early review of the Local Plan that will be submitted to the Secretary of State for Examination by the end of 2021. This will be a comprehensive review of the Local Plan for South Staffordshire that will consider the need for additional growth and plan appropriately for this. This plan will review, as a minimum, the following matters, which are based upon known strategic issues affecting the District at this point in time;

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 New SADneeds policies 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. • 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.

6.18 Policy SAD1 as set out above responds to the known cross boundary evidence of unmet development needs, including unmet housing needs across the Greater Birmingham Housing Market Area (GBHMA) – which includes the Black Country and 9 other neighbouring authorities (including South Staffordshire).

6.19 The Council will continue to work positively towards a Memorandum of Understanding (MoU) or Statement of Common Ground (SoCG) with all local planning authorities across the GBHMA. However, it may be the case that the GBHMA authorities fail to agree a MoU or SoCG setting the apportionment of housing growth across the HMA in advance of the publication draft of the Local Plan Review, which is anticipated before the end of 2020. If this is the case, the Council will consider providing a proportionate contribution to unmet cross boundary

Appendix V Site Location Plan

Appendix VI SHLAA 2018 Extract

ID: 666 Settlement: Fradley Location: land off Common Lane Ward: Alrewas and Fradley

Suitability Notes: Outside village boundary but is adjacent to a Availability Notes: Achievability Notes: sustainable settlement as identified within the adopted Local plan No known constraints. Strategy. Multiple ownerships, but agent advises they are working Outside settlement. Does not wholly comply with current development together. plan policies in the Local Plan. However site falls within broad area for search for assessment of sites which could contribute to sustainable mixed communities. When is site likely to come forward?: 0 - 5 years

Loss of Grade 3 Agricultural Land may need justification. An SBI is within Proposed Yield: 24 Current Deliverability: 1km and the impact on it may need further investigation. Site is within Deliverable the Cannock Chase zone of influence therefore mitigation may be required.

Table B.143

ID: 700 Settlement: Fradley Location: Long Ln., 4 Ward: Alrewas and Fradley

Site Area (ha): 0.03 Source: Submission Proposal: Size of Proposed Residential Density Rate (dph): 30 Residential (ha): 0.03

Yield Note: Expired Planning Permission 13/01286/FUL

Currently Suitable? Yes Currently Available? Yes Currently Achievable?Yes

Suitability Notes: Within village boundary which is a sustainable Availability Notes: Achievability Notes: settlement as identified within the adopted Local plan Strategy. No known constraints. Site is not currently for sale or Complies with current development plan policies in the Local Plan. Site being marketed . is within the Cannock Chase zone of influence therefore mitigation may be required. When is site likely to come forward?: 0 - 5 years

Proposed Yield: 1 Current Deliverability: Deliverable

Table B.144

ID: 1119 Settlement: Location: land off Common Lane Ward: Alrewas and Fradley Fradley

Site Area (ha): Source: Proposal: Size of Proposed Residential (ha): Density Rate (dph): 40 1.6 Submission Residential 1.28

Yield Note: Indicative using 80% @ 40dph Rep submitted to Reg 19.

Currently Suitable? Yes Currently Available? Yes Currently Achievable?Yes

Suitability Notes: Outside village boundary but is adjacent to Availability Notes: Achievability Notes: No a sustainable settlement as identified within the adopted Local known constraints. plan Strategy. Multiple ownerships, but agent advises they are working together. Outside settlement. Does not wholly comply with current Site is being promoted by developer development plan policies in the Local Plan. However site falls through the emerging Local Plan within broad area for search for assessment of sites which could Allocations document. Additional contribute to sustainable mixed communities.

June 2018 129 Strategic Housing Land Availability Assessment 2018

ID: 1119 Settlement: Location: land off Common Lane Ward: Alrewas and Fradley Fradley

Loss of Grade 3 Agricultural Land may need justification. An information has been submitted by the SBI is within 1km and the impact on it may need further developers seeking to address all investigation. Site is within the Cannock Chase zone of influence issues. therefore mitigation may be required.

When is site likely to come forward?: 0 - 5 years

Proposed Yield: 54 Current Deliverability: Deliverable

Table B.145

ID: 138 Settlement: Fradley Location: Bridge Farm Ward: Alrewas and Fradley

Site Area (ha): 6.69 Source: Survey Proposal: Size of Proposed Residential Density Rate (dph): 40 Residential (ha): 6.69

Yield Note: See also site 412 and 438. 40dph @ 60%

Currently Suitable? Yes Currently Available? No Currently Achievable?Yes

Suitability Notes: Within village boundary in a settlement Availability Notes: Achievability Notes: considered to be a sustainable settlement as identified within the No known constraints. adopted Local plan Strategy. Owner has indicated that does not wish to develop at present Part outside settlement. Does not wholly comply with current and has put forward part of site development plan policies in the Local Plan. However site falls for an alternative use - sports within broad area for search for assessment of sites which could pitches for community use. contribute to sustainable mixed communities.

Loss of Grade 3 Agricultural Land may need justification. Site has When is site likely to come forward?: 6 - 10 years potential for protected species. Site is within the Cannock Chase zone of influence therefore mitigation may be required. Proposed Yield: 160 Current Deliverability: Developable

Table B.146

ID: 436 Settlement: Location: Hay End Lane Ward: Alrewas and Fradley Fradley

Site Area Source: Proposal: Size of Proposed Residential (ha): 10.19 Density Rate (dph): 40 (ha): 10.19 Submission Residential

Yield Note: 40dph@60%

Currently Suitable? No Currently Available? Yes Currently Achievable?Yes

Suitability Notes: Outside village boundary but Availability Notes: Achievability Notes: No is adjacent to a sustainable settlement as identified known constraints. within the adopted Local plan Strategy. Site is not currently for sale or being marketed but has been promoted by the owner/agent. Outside settlement. Does not wholly comply with current development plan policies in the Local Plan. However site falls within broad area for search for When is site likely to come forward?: 0 - 10 years assessment of sites which could contribute to sustainable mixed communities. Site is within 0-5 years 6-10 years 11-15 years mineral safeguarding area

130 June 2018

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