25th November 2019 Local Plans Team South Staffordshire Council Council Offices Codsall South Staffordshire WV8 1PX Dear Sirs, Local Plan Spatial Housing Strategy and Infrastructure Delivery PlanIT Planning and Development (“PlanIT”) are instructed to submit representations to the South Staffordshire Local Plan Spatial Housing Strategy and Infrastructure Delivery consultation document (“SHSID”). Whilst we support the stated ambitions of the emerging Plan, in seeking to provide a sufficient amount of housing, employment land and infrastructure to meet not only the residents of South Staffordshire but also to assist in meeting the unmet housing requirements of the conurbation, these aspirations do not, in our view, appear to be reflected in the consultation document. Our comments on the consultation document are set out below. This letter responds to the various questions included in the SHSID consultation document as appropriate. We also provide comments on specific matters raised within the text of the SHSID where questions are not raised, but we have objections. 2. The Local Plan Review – Progress to Date (Paragraphs 2.1 – 2.2) Paragraph 2.2 of the consultation document advises that the Council is of the view that it should plan for its own housing needs, and a contribution of up to 4,000 dwellings towards the unmet needs of a wider Housing Market Area (“HMA”). However, if there is evidence that the extent of housing shortfall across the HA is significantly reduced prior to the Local Plan Review submission, the Council will reduce its contribution to the unmet needs of other authorities proportionately. We have a number of concerns with this approach. We set out our comments on the proportion of the unmet housing requirement of the conurbation that South Staffordshire should provide for in our response to paragraphs 2.3 to 2.6 below. In summary, it is our view that South Staffordshire will need to provide significantly more than the 4,000 dwellings suggested to help meet the unmet housing needs of the conurbation. There is still significant work to be done on the extent and distribution of the unmet housing requirements of the conurbation. However, as drafted paragraph 2.2 suggests that South Staffordshire’s contribution can only be decreased. Paragraph 2.2 should be amended to confirm that as the Plan progresses, and additional evidence arises on the extent and distribution of the housing shortfall from the conurbation, the emerging Local Plan will seek to 1 accommodate an appropriate proportion of this requirement. This could be greater than the 4,000 units currently suggested and it should not automatically be assumed that this figure will be reduced. The suggestion that the housing requirement can only be decreased is inflexible and entirely inappropriate. The Preferred Housing Target for the Local Plan Review (Paragraphs 2.3 – 2.6) We support the use of the Standard Method in establishing the South Staffordshire’s proportion of the emerging Local Plan’s housing requirement. It should, however, be noted that the Standard Method is under review. As a consequence the housing requirement in the emerging Plan may need to change in accordance with revisions to national planning policy. This aspect of the Plan, therefore, needs to be kept under review. It is our view that the Plan should make a significantly greater contribution to the unmet housing requirements of the conurbation than that currently identified. The current evidence on the extent of the housing shortfall from the conurbation can be found in a variety of sources, including the adopted Birmingham Development Plan and the emerging Black Country Core Spatial Strategy. The Birmingham Development Plan was adopted in January 2017. Policy PG1 – Overall Levels of Growth, advises that Birmingham’s objectively assessed housing need figure for the period 2011-2031 is 89,000 dwellings (4,450 dpa). It is not, however, possible for this level of development to be accommodated in the City’s administrative area. Policy PG1, therefore, plans for the provision of 51,100 dwellings within the Plan area and advises that the City Council will work with other authorities within the Housing Market Area through the Duty to Cooperate to deliver the residual 37,900 dwellings. Since the adoption of the Birmingham Development Plan, Birmingham City Council has produced a new Strategic Housing Land Availability Assessment 2018. This document suggests that the capacity for sites within the urban area of Birmingham has increased, and there is now a total supply of 61,403 dwellings during the course of the Plan period. This is made up of 14,047 completions between 2011/12 and 2017/18. The remaining 47,356 dwellings are from sites that are allocated by the Birmingham Development Plan, have planning permission, or are identified as potentially being suitable development opportunities by the SHLAA. The SHLAA advises at paragraph 2.2 that: “The inclusion of a site in the SHLAA does not mean that it will be developed for housing, it does not mean that housing is the only suitable use for a site, and does not necessarily mean, where it is not already the case, that planning permission would be granted for housing. Circumstances may change over time.” The SHLAA is not an allocations document. It has not been the subject of examination or independent testing in the same way that the capacity figures in Birmingham Development Plan Policy PG1 have been. In addition, there is no suggestion by the City Council that we are aware of that policy PG1 is an out of date policy of that the residual housing shortfall figure identified by Policy PG1 should not be planned for by other authorities within the Plan area. However, even based upon the SHLAA capacity figures, the outstanding housing requirement drops to 27,597 dwellings. This is still a significant amount. 2 In addition, if the SHLAA is to be treated as new and relevant updated evidence regarding the capacity of Birmingham to accommodate development and the extent of the shortfall, other relevant material considerations that have arisen since the adoption of the Birmingham Development Plan should also be taken into account. This includes the application of the Standard Method to identify Birmingham’s housing requirement. The adopted Birmingham Development Plan includes a requirement of 4,550 dwellings per annum. However, this figure is below that which arises from the application of the Standard Method calculation for the City. The Standard Method housing requirement figure for Birmingham is 4,975 dpa. If the SHLAA capacity figures are to be treated as new and up-to-date evidence so should the Standard Method housing requirement. In addition, the extent of the identified shortfall for Birmingham also needs to be considered in the context of the Plan periods for the adopted Birmingham Development Plan and the emerging South Staffordshire Plan. The Birmingham Development Plan has an end date of 2031. As such the extent of the housing requirement, and the extent of the housing shortfall, is only established for a period up to 2031. The emerging South Staffordshire Plan is being prepared to have an end date of 2037. Consequently, no provision will be made within the emerging South Staffordshire Plan for any shortfall that could arise from Birmingham in the period beyond 2031. However, all current evidence suggests that it is highly unlikely that Birmingham will be unable to identify any significant new capacity within its administrative area through any future Local Plan Review. In all likelihood Birmingham City Council will need to ask neighbouring authorities, including South Staffordshire, to make contributions in their replacement plans to meet the growth of Birmingham beyond 2031. If South Staffordshire fails to make an appropriate contribution towards the unmet housing requirements from the conurbation emerging evidence through the Birmingham Local Plan Review process could result in the emerging South Staffordshire Plan either being found to be unsound as it progresses through examination or, potentially, there being an immediate requirement for a review in order to assist in meeting the growth requirements of other authority areas. The Black Country authorities are also in a position where they are relying upon other authorities within the HMA to deliver a significant amount of housing to help meet their growth requirements. The Black Country authorities are currently in the process of preparing a replacement for the Black Country Core Strategy. Issues and Options consultation was taken on the emerging Core Strategy between July and September 2017. The consultation document advises that 78,000 dwellings will be required between 2014 and 2036 in order to meet the growth requirements of the Black Country (3,545 dpa). However, the Issues and Options consultation document was published before the revisions to the PPG that require the application of the 2014 household projections in the Standard Method calculation. This level of growth referred to in the Issues and Options consultation document is lower than that required through the application of the Standard Method which the emerging Plan will now be required to comply with. The Standard Method results in a housing requirement for the Black Country of 3,761 dpa. The Issues and Options consultation Black Country Core Strategy advised that it is estimated that sites within the Black Country urban area, including developments already being built, sites with planning permission and for increased densities on existing sites could deliver 56,000 dwellings. This leaves a shortfall of 22,000 dwellings that will need to be provided outside of the urban area. This is, however, an under-estimate based upon the updated Standard Method figure referred to above. It is appreciated that land may be released from Green Belt within the emerging Black Country Core Strategy plan area to meet part of the identified shortfall.