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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. Date: June 2018 Page: 1 Client: Grasscroft Homes & Property Ltd Response to Matter 5 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; Date: August 2018 Page: 2 Client: Grasscroft Homes & Property Ltd Response to Matter 5 • 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.” Date: August 2018 Page: 3 Client: Grasscroft Homes & Property Ltd Response to Matter 5 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,

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