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South Staffordshire Local Plan Review Spatial Housing Strategy And December 2019 | NCO/BC | P18-1803 SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION LAND OFF STRAWMOOR LANE, CODSALL ON BEHALF OF RICHBOROUGH ESTATES 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 Richborough Estates Land off Strawmoor Lane, Codsall 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 5 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION 6 5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS 8 6. INFRASTRUCTURE DELIVERY PLAN 2019 12 7. GREEN BELT STUDY 2019 17 8. LANDSCAPE STUDY 2019 24 9. SUSTAINABILITY APPRAISAL 2019 27 10. RURAL SERVICES AND FACILITIES AUDIT 2019 29 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 30 12. LAND AT STRAWMOOR LANE, CODSALL 31 13. CONCLUSION 37 APPENDIX 1: SITE LOCATION PLAN APPENDIX 2: VISION DOCUMENT December 2019 | NCO/BC | P18-1803 Richborough Estates Land off Strawmoor Lane, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 1. INTRODUCTION 1.1 This representation is made by Pegasus Group on behalf of Richborough Estates to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Strawmoor Lane, Codsall, which Richborough Estates is promoting for residential development. 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 rather than deferred, as evidenced by the statement of common ground; and December 2019 | NCO/BC | P18-1803 Page | 1 Richborough Estates Land off Strawmoor Lane, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 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 | NCO/BC | P18-1803 Page | 2 Richborough Estates Land off Strawmoor Lane, Codsall 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 | NCO/BC | P18-1803 Page | 3 Richborough Estates Land off Strawmoor Lane, Codsall 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 on an Issues and Options (Regulation 18) consultation between Monday 8 October and Friday 30 November 2018. 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. December 2019 | NCO/BC | P18-1803 Page | 4 Richborough Estates Land off Strawmoor Lane, Codsall 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 Richborough Estates is pleased to see the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Strategic Growth Study forms part of the Council’s evidence base, along with the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA 2018 provides the most up-to- date evidence on housing land availability in the district and, as such, is a key to identifying the reasonable alternative growth strategies to be considered through the plan-making process. 3.3 Richborough Estates is also pleased that the Council has had regard to evidence that will inform an updated Infrastructure Delivery Plan, including input from key stakeholders outside the District where necessary. 3.4 Whilst the Spatial Housing Strategy will represent a significant element of an overall spatial development strategy, the distribution of housing should be considered in the round having regard to other uses that are required within the District to 2037. The distribution of other requirements, including employment and social and community infrastructure, are intrinsically linked to the delivery of homes as part of a comprehensive, sustainable strategy. 3.5 In light of the above, the evidence identified to inform the Spatial Housing Options appears to omit other relevant technical reports identified at the Issues and Options stage which, it is assumed, will be utilised by officers in formulating the Preferred Options document in Summer 2020. December 2019 | NCO/BC | P18-1803 Page | 5 Richborough Estates Land off Strawmoor Lane, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION Question 2: Do you agree that taking account of housing land supply from the start of the new plan period (1 April 2018) is the correct approach? 4.1 It is noted that all Spatial Housing Options take account of existing ‘potential’ sources of supply i.e. permissions, completions and current allocations. This approach, in principle, is supported. However, it is considered necessary to scrutinise the supply position for robustness. 4.2 Through the Local Plan Review it is considered essential to review all sources of housing supply, including existing commitments. Whilst it is recognised that the Site Allocations Document was only adopted in September 2018, further information or evidence may have arisen since adoption that raises questions of suitability or delivery of sites allocated. 4.3 All potential sources of supply should be scrutinised through the Local Plan Examination in Public, especially non-allocated windfall sites, and it is recommended that a site-specific
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