SOUTH LOCAL PLAN REVIEW 2018-2037

SPATIAL HOUSING STRATEGY & INFRASTRUCTURE DELIVERY

Gladman Representations

December 2019

South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

1 INTRODUCTION

1.1 Context

1.1.1 Gladman Developments Limited (Gladman) specialises in the promotion of strategic land for residential development with associated community infrastructure. This submission provides Gladman’s representations to the Local Plan Review Spatial Housing Strategy and Infrastructure Delivery Consultation.

1.1.2 The South Staffordshire Local Plan Review is being prepared in the context of a major shift in national planning policy. Since the adoption of the South Staffordshire Core Strategy in 2012, the Government has published the National Planning Policy Framework (NPPF) (also in 2012) which was revised in 2018 and most recently in February 2019. The Local Plan Review and its examination will, therefore, be subject to the policies of the NPPF 2019.

1.1.3 For the avoidance of doubt, Paragraph 35 of NPPF 2019 sets out the four tests that must be met for Local Plans to be concluded as sound:

 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;  Justified – An appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;  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  Consistent with National Policy – The plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

1.1.4 Gladman also notes the significant emphasis directed within NPPF (2019) to securing the sustainable and full delivery of housing requirements. Amongst other new policy requirements, NPPF introduces a new housing delivery test to monitor and measure housing delivery over the plan period, with specific measures outlined for those authorities unable to demonstrate sufficient levels of delivery. The NPPF also redefines what is considered deliverable in five-year supply terms, and the level of evidence required to demonstrate this.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

1.1.5 The Review currently being undertaken by South Staffordshire Council (the Council), provides the opportunity to ensure that the development plan is consistent with the most up-to-date national policy. The Review provides scope for development requirements and the spatial strategy to be updated in alignment with the most recent evidence. It also provides a vehicle in which the much-discussed unmet needs of Birmingham and the Black Country can be met.

1.1.6 The Spatial Housing Strategy consultation represents an early stage in the review process and asks for comments regarding a number of options for broad locations for housing growth.

1.1.7 Gladman welcomes the Council’s action to review the Local Plan, and the opportunity provided to submit comments at this early stage in the plan preparation process.

1.1.8 The comments provided within this representation have been structured to follow that set out within the consultation:

 Question 1 Evidence Base;

 Question 2 Housing Land Supply;

 Question 3 Safeguarded Land;

 Question 5 Spatial Housing Options;

 Question 6 Spatial Housing Option G;

 Question 7 New Settlement; and

 Question 10 Green Belt Release

1.1.9 In Section 4, Gladman submits a site at Cannock Road, for inclusion as a strategic housing allocation within the Local Plan Review.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

2 SUSTAINABILITY APPRAISAL

2.1.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies that are set out in local plans must be the subject of a Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against all reasonable alternatives.

2.1.2 The Council should ensure that the results of the SA process conducted through the Review clearly justify any policy choices that are ultimately made, including the proposed site allocations (or any decision not to allocate sites) when considered against ‘all reasonable alternatives’. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Council’s decision making, and scoring should be robust, justified and transparent.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

3 GLADMAN’S RESPONSE TO CONSULTATION QUESTIONS

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?

3.1.1 Yes, Gladman generally agrees that the evidence base is appropriate, however Paragraph 2.3 of the Consultation document refers to the Standardised Methodology for assessing housing need as set out in NPPF 2019 as the basis for the housing requirement in the Local Plan review. Whilst the role of the Standardised Methodology in defining housing needs in plan making is acknowledged, Gladman advises caution in the use of implied figures at face value for establishing the housing requirement. This is because the Standardised Methodology :

 Provides only the base requirement for local planning authorities and provides for the minimum level of housing needs. It does not therefore take into account local conditions and variations which may not be captured under national projections:  Does not take into account economic ambitions and projections; and  In any event the standard methodology is under review by the Government to ensure that the methodology supports the aspiration of a housing market that delivers 300,000 homes annually.

3.1.2 For these reasons, the Standardised Methodology must be considered to represent only a tentative starting point, with the actual level of objectively assessed need for the District somewhat higher. The revised Housing Needs Assessment (HNA) section of the Planning Practice Guidance (PPG) is very clear in this respect, paragraph ID2a-002 stating that “The standard method set out below identifies a minimum annual housing need figure. It does not produce a housing requirement.”

3.1.3 The planning policy context for the District over the past twenty years has been one of severe constraint in terms of housing development; it should not be assumed that this reflects the appetite for the delivery of new housing in the District by the housebuilding industry.

3.1.4 Gladman also notes that the Consultation document proposes that the Local Plan Review should accommodate up to 4,000 dwellings as a contribution towards meeting the unment needs of the Greater Birmingham Housing Market Area. The contribution that South Staffordshire District will be required to accommodate is, however, yet to be agreed and it may well be a higher figure.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

3.1.5 The District covers a significant geographical area that wraps around the western and north western boundaries of the Black Country. The District not only has a strong geographical and functional relationship with the Black Country and Birmingham but also is relatively free of significant physical and environmental constraints. As a result, the District has more potential to accommodate housing growth than many other authorities in the HMA.

3.1.6 The Local Plan Review identifies the potential for additional employment land being allocated to meet some of the employment needs of the Black Country and consequently the housing requirement needs to be increased to take into account higher employment growth. Furthermore, there is a prospect of a Strategic Rail Freight Interchange being developed in the district at Four Ashes, which is estimated to produce 8,550 direct new jobs and additional housing would be required to provide balanced growth should that development go ahead. Overall, if the District has aspirations to maintain and grow a strong economy, additional housing should be planned for in addition to that required under the standard methodology.

Question 2: Do you agree that taking account of housing land supply from the start of the new plan period (1st April 2018) is the correct approach?

3.1.7 Gladman agrees that it is correct to take account of the housing land supply from the start of the Plan Period, however from our experience, it would be appropriate to apply a 10% lapse rate to the supply deemed likely to emanate from existing commitments and allocations.

Question 3: Do you agree that all Safeguarded Land identified in the SAD should be released as a priority and should be delivered at an average density of 35 dwellings per hectare?

3.1.8 Gladman agrees that the safeguarded land identified in the Site Allocations Document should be brought forward in the Local Plan Review provided it can be demonstrated that the sites concerned are still available and deliverable within the lifetime of the Local Plan Review. Whilst the introduction of minimum housing densities may be considered appropriate for the urban authorities in Birmingham and the Black Country, it is not considered a suitable strategy for South Staffordshire due to the rural character of the District and its villages. It would not be appropriate for blanket density of 35 dwellings per hectare to be applied to Green Belt safeguarded sites; a suitable density for each site will depend upon a number of site specific factors including its location, the character and nature of any surrounding development and its accessibility to sustainable transport connections.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

Question 5: Do you agree that the 7 Spatial Options set out above are appropriate options to consider? Are there any alternative options we have not considered?

3.1.9 Yes, Gladman agrees that the 7 spatial options are appropriate, however it considers that the Local Plan when published in draft may well need to incorporate an amalgam of two or more options in order to provide a deliverable and coherent strategy for housing development.

Question 6: Do you agree that Spatial Option G is a robust approach to meet needs in the District and to make a contribution towards unmet needs in the GBHMA?

3.1.10 Gladman believes that Spatial Option G is a robust approach to meeting housing needs in the District and the GBHMA.

Question 7: Do you agree that we should continue to explore options for a new settlement?

3.1.11 Yes, Gladman considers that a new settlement may be an appropriate component of the overall strategy for South Staffordshire subject to any proposal being deliverable, at least in part during the Plan period.

Question 10: Do you agree that, when selecting sites to deliver the preferred spatial housing strategy, the Council should seek to avoid allocating housing sites that would result in very high Green Belt harm wherever possible?

3.1.12 Generally, Gladman considers that any Green Belt releases should avoid areas which make a significant contribution to the purposes of Green Belt designation, however, in practice, endeavouring to achieve a sustainable pattern of new development may mean that it is not always possible to find sufficient suitable sites for housing development in areas which are of lesser value in terms of Green Belt purposes. The Council will therefore need to bear in mind that the Green Belt assessments in the South Staffordshire Green Belt Study (Stage 1 and 2 - LUC July 2019) suggest it will prove difficult for them to achieve the majority of the options proposed without development being located in areas which are shown as high/very high Green Belt harm.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

4 SITE SUBMISSION: LAND WEST OF CANNOCK ROAD, STAFFORD

4.1.1 Gladman is promoting land for residential development at Cannock Road, Weeping Cross in the Parish of Acton Trussell and . The site is outlined in red in Figure 1. It corresponds to the broad strategic housing location on the southern edge of Stafford shown on the Option G plan within the Consultation document. Gladman confirms that this site is available for development and is emminently deliverable in the Plan Period.

4.1.2 South Staffordshire is heavily constrained with around 80% of the Local Planning Authority lying within the Green Belt. However, the area of search for an urban extension for Stafford including our site at Land at Cannock Road is not designated as Green Belt.

4.1.3 The National Planning Policy Framework (February 2019) paragraph 137 is clear that ‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development’. The area of search for an urban extension of Stafford assists in demonstrating that all reasonable alternative options have been considered prior to any potential Green Belt release.

Figure 1 Land at Cannock Road, Weeping Cross, Stafford (in the Parish of Acton Trussell and Bednall)

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

4.1.4 The site extends to some 7.97 hectares on the southern edge of Stafford. It enjoys good links with the adjoining Wildwood Estate within Stafford and is close to existing shops, services and employment opportunities.

4.1.5 The site comprises agricultural land the eastern side of which is bound by Acton Hill Road and Cannock Road. To the north, a route with public access forms the boundary and divides the site from the settlement edge of Stafford, to the south and west there is a combination of woodland and open countryside.

4.1.6 The site is well related to Stafford and is contained by physical features. The development of the site would naturally round off the settlement with particularly strong and clear defensible boundaries and represents a logical extension of the Weeping Cross neighbourhood of Stafford. It would not result in built form extending any further than the existing settlement edge on the opposite side of Cannock Road.

4.1.7 The site has been subject to recent planning applications (Ref: 18/01031/OUT) and as such is supported by detailed site-specific evidence. The application illustrates the availability, and in Gladman’s view, the deliverability of the site for housing.

4.1.8 The detailed technical information examined and illustrated the developability of the Site in response to environmental, infrastructure, and built environment constraints. This demonstrated that the site has the capacity to deliver 155 dwellings and 55 extra-care dwellings.

4.1.9 A Framework Plan for the development of the site is attached as Appendix 1 to this submission.

4.1.10 The site is a suitable and sustainable site for development for the following reaosns:

 The site is well contained within the landscape and important trees and other landscape features would be retained;  The local highway network has capacity to accommodate the additional traffic that would be generated by the development of the site;  The site is not designated as part of the West Midlands Green Belt;  The site has a low ecological value; the loss of habitat would not be significant and mitigation and net biodiversity gains can be readily achieved;  The site falls within the EA Flood Risk Zone 1 (i.e land assessed as having less than 1 in 1,000 annual probability of flooding); and  There are no designated heritage assets within or immediately adjacent to the site and the development of the site would not affect the setting of any listed building.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

4.1.11 The site is within easy walking and cycling distance of a wide range of facilities and services including: Primary School. Secondary School, Sports Ground, Pub/Restaurant, Post Office, Pharmacy, Local Shop, Butcher, Hairdresser, Community Centre/Village Hall, Allotments and a Doctors Surgery.

4.1.12 Cannock Road is served by regular bus services to Stafford Town Centre and Cannock. Stafford, in particular, offers a range of higher level services including Hospital, Further and Higher Education facilities, a range of emploment opportunities and a mainline railway station providing frequent services to Wolverhampton, Birmingham, Stoke on Trent, Manchester and London.

4.1.13 In summary, the site at Cannock Road represents a logical urban extension to the south of Stafford that is suitable, available and deliverable within the plan period.

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South Staffordshire Council Spatial Housing Strategy & Infrastructure Delivery Consultation Gladman

5 CONCLUSION

5.1.1 This representation has been prepared by Gladman in response to the current consultation on the South Staffordshire Local Plan Review (2018-2037) Spatial Housing Strategy & Infrastructure Delivery. Gladman hope that the above comments are constructive and prove helpful for the Council to consider in preparing the Local Plan Review. As a company we are committed to working alongside South Staffordshire Council through the plan making process.

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APPENDIX ONE – Indicative Development Framework for Land off Cannock Road, Stafford CANNOCK ROAD This drawing is the property of FPCR Environment and Design Ltd and is issued on the condition it is not reproduced, retained or disclosed to any unauthorised person, either wholly or in part without written consent of FPCR Environment and Design Ltd.

Site Boundary (7.97Ha)

Proposed Development Area (4.54Ha) @ 35 dph up to 155 dwellings

WILDWOOD DRIVE Apartments with Care (C2) (0.55Ha) up to 55 units

Proposed Boundary Planting

Proposed Tree Planting

Proposed Hedgerow

Proposed Location for Foul Water Pumping Station - at least 15m from wet well to nearest habitable building Proposed Location for Play Area - with 20m offset

Proposed Trim Trail Items

CANNOCK ROAD OLD CROFT ROAD HAZELSTRINE Proposed Location for Attenuation Basin

Proposed Access Location

Indicative Road Layout

Proposed Footpath

Proposed Uncontrolled Pedestrian ACTON HILL ROAD Crossing

Proposed Bus Lay-by and Shelter

Existing Trees and Hedgerows

Root Protection Area of Trees in close Green Infrastructure (GI) Schedule proximity to Development GI TYPE LOCAL REQUIREMENTS PROPOSED (South Staffordshire Local Plan Site HA Allocations Document (SAD) Sept Other Route with Public Access 2018. Policy SAD7 Open Space Requirements) Formal Play Provision 0.04ha minimum 0.04ha Existing Settlement Public Open Space 2.06ha N Community Green Space @ 0.01ha per dwelling 2.10ha Storm Water Drainage Pipe with Scale: 1:2500 @ A3 ACTON HILL FARM (0.25ha minimum) 10m Easement Green Infrastructure 0.78ha

0 50 100m Overall Total 2.88ha J:\7600\7640\LANDS\Plans\7640-L-06 Development Framework REV A.indd

masterplanning 1:2500@A3 environmental assessment Gladman Developments landscape design FPCR Environment and Design Ltd urban design Lockington Hall ecology Lockington 19.12.2018 JPF/ KMN Derby DE74 2RH Cannock Road INDICATIVE DEVELOPMENT FRAMEWORK architecture arboriculture t: 01509 672772 f: 01509 674565 rev fpcr Stafford 7640-L-06 A e: [email protected] w: www.fpcr.co.uk