Preferred Options November 2021

Ended on the 13 December 2021

6. Development Management Policies

6.1 In addition to delivering growth to meet new development needs, a key part of the Local Plan Review is reviewing the policy requirements set for all development in South Staffordshire, to ensure that future growth is sustainable and responds to the District's needs.

6.2 As part of this process, the Council considered a wide variety of alternative policy options as part of the 2018 Local Plan Review - Issues and Options consultation. This set out the Council's different options for addressing different policy areas that the Local Plan Review would need to address and sought views from local communities, developers and key stakeholders on these.

6.3 Where relevant to the proposed policy approach, the nearest corresponding policy option considered in the 2018 Local Plan Review - Issues and Options consultation has been highlighted. The Council assessed these policy options and reasonable alternatives through the Sustainability Appraisal of the Issues and Options consultation. However, in the vast majority of cases there was very little or no predicted difference in the Sustainability Appraisal between the relevant options, so in most cases the preferred policy approaches have been led by the recommendations of the emerging Local Plan Review evidence base documents and joint working with key statutory stakeholders.

6.4 The preferred policy approaches the Council intends to take forward are set out below. At this stage, these preferred approaches do not reflect the final policy wording that will be included in the Local Plan Review that will be submitted to the Secretary of State. Instead they are intended to highlight key requirements, aims and measures that the final submitted policies will deliver, focusing on the most important parts of the future policies to seek views on these.

6.5 The preferred policy approaches, or directions of travel, are set out in the tables below. Policies have been grouped under key themes, with a short explanation of key evidence that informed the Council's preferred approach to these policies given in summary under each of these.

Homes and Communities

Delivering the right homes
Policy Reference	Proposed Direction of Travel	Corresponding 2018 Issues and Options policy options
HC1 - Housing Mix	All development to provide a mixture of property sizes, types and tenures Proposals for major residential development^[11]: Market housing – 75% of properties to have 3 bedrooms or less, with specific breakdown to be determined with reference to latest Housing Market Assessment Affordable housing – Specific breakdown to be determined with reference to latest Housing Market Assessment and other affordable housing needs evidence Refusal of proposals that fail to make an efficient use of land by providing a disproportionate amount of large, 4+ bedroom homes	A combination of Housing Mix Policy Options A & B
HC2 - Housing Density	Aim to achieve a minimum net density of 35 dwellings per net developable hectare in developments within or adjoining Tier 1 settlements, in infill locations within the development boundaries of other settlements in the district or in urban extensions to neighbouring towns and cities	n/a (asked as a separate question - Question 17 - in the 2018 Issues and Options consultation)
HC3 - Affordable Housing	Proposals for major residential development: 30% of all dwellings to be affordable housing, broken down using the following ratio 50% social rent, 25% shared ownership and 25% first homes^[12] Affordable homes to be fully integrated, via suitable pepperpotting in clusters across the development and design which is materially indistinguishable from market housing Grant funding not supported for affordable housing required by the policy Offsite and financial contributions only acceptable in exceptional circumstances Proposals that comply with up to date policies in the plan assumed to be viable Adopt an Affordable Housing SPD to further clarify the Council's expectations for the delivery of affordable housing	Affordable Housing Percentage Requirement Policy Option A Affordable Housing Tenure Split Policy Option D Affordable Housing Boosting Supply Policy Option H
HC4 - Homes for Older People	Proposals for major residential development: Requirement to make a clear contribution to meeting the needs of the district's ageing population, through the provision of either: general needs properties for older people e.g. bungalows, other ground floor accommodation with appropriate age restrictions on occupation; or specialist housing e.g. sheltered, extra care homes 30% of all market and affordable homes to meet Building Regulations Standard Part M4(2) – Accessible and adaptable dwellings	Blended approach of Homes for Older People and Specialist Housing Policy Options A & D
HC5 - Specialist Housing Schemes	Strong support for proposals for specialist housing of all tenures, in the form of age-restricted accommodation, retirement homes, sheltered and/or extra-care housing, nursing/residential homes or other forms of supported living, subject to sustainability and design criteria Resistance to loss of specialist accommodation unless needed to increase quantity or quality of existing provision	Homes for Older People and Specialist Housing Policy Options A
HC6 - Rural Exception Sites	Support for sites that lie adjacent to a village falling within Tiers 1-4 of the settlement hierarchy Affordable housing need in the parish to be demonstrated through a robust, independent housing need survey which considers all tenures of affordable housing in NPPF definition, carried out within the last 3 years, in partnership with the Parish Council and a Rural Housing Enabler Proposals to be of a suitable size, scale, design and character in relation to the existing village Occupancy to be secured in perpetuity for local people in affordable housing need Small amount of market housing permitted in proposals outside the Green Belt where essential to viability of scheme	Rural Exception Sites Policy Option A
HC7 - Self & Custom Build Housing	Support for self-build and custom housebuilding proposals where they accord with other development plan policy requirements Sites for major residential development to have regard to any need identified on the self-build and custom housebuilding register, with provision to be agreed on a site-by-site basis	Self-build and Custom House Building Policy Option A
HC8 - Gypsy, Traveller and Travelling Showpeople	Criteria based policy that all proposals for Gypsy and Traveller pitches/plots must conform to covering: Access to essential services (waste, water, power etc); safe access for towing caravans; development well designed and landscaped; no net loss of biodiversity; protecting neighbouring amenity; avoiding areas of high flood risk and requiring the number and size of pitches to be of an appropriate scale and not dominate the nearest settlement. Policy to confirm that applications for pitches from individuals that don't meet the planning definition will be considered in line with this criteria based policy and other relevant policies (e.g Policy DS1:Green Belt; DS2: Open Countryside) on a case by case basis.	Gypsies, Travellers & Travelling Showpeople Policy Option A

6.6 Amongst other issues, South Staffordshire has an increasingly ageing population, high levels of under-occupation of the existing housing stock and a generally unaffordable housing stock, with average house prices costing over eight times the average lower quartile income. As the District will experience significant housing growth through the Local Plan Review and it is important that the district puts in place policies to ensure any growth responds to such issues, creating mixed and sustainable communities for all residents.

6.7 To achieve this, policy approaches are proposed to ensure a mix of property sizes and tenures are delivered in new development, including affordable housing. These include clear requirements to ensure that any development reflects the latest needs set out in the Strategic Housing Market Assessment 2021. These requirements also include a particular emphasis on avoiding a disproportionate amount of large dwellings on new schemes, to avoid the risk of development exacerbating existing under-occupation of market housing in the District. This is supported by a minimum density requirements policy, which reflects the findings of regional evidence on unmet housing needs, the Council's own evidence base on appropriate densities delivered within the district and the more sustainable locations identified in the Council's Spatial Strategy.

6.8 Policy approaches are set out to allow the district to meet its housing needs for the elderly population, both as part of wider housing sites and as part of targeted specialist housing schemes. These include requirements to encourage the provision of properties both designed and managed to accommodate the district's elderly population, ensuring that allocated general housing sites contribute towards specialist housing supply and responding to the support for such an approach in the South Staffordshire Housing and Homelessness Strategy. To ensure that elderly residents who remain within the general housing stock are also catered for, a proportion of all new dwellings will also be designed to be compliant with optional technical requirements for accessible and adaptable homes. For specialist housing schemes, such as extra care or nursing homes, a policy approach supporting the delivery of such schemes is proposed, including an additional requirement that existing specialist housing will be retained for its current use. Taken together, these approaches will allow elderly residents to be better catered for in the general housing stock for longer, whilst also encouraging the provision of a range of specialist options for residents with a variety of care needs.

6.9 A clear requirement and tenure split is also set for affordable housing. This reflects the evidence in the latest Strategic Housing Market Assessment 2021, the Council's Local Plan Review Viability Study 2021 and the emerging first homes requirements set out national policy. This policy approach also sets clear design requirements to ensure that such dwellings are well-integrated into the wider scheme, are genuinely 'tenure-blind' in design and are not consigned to the least attractive areas of a housing site. The Local Plan Review will also continue to offer support for affordable housing brought forward in rural exception sites, offering clear guidance about the process by which these should be identified and the locations in the district where these could be sustainably accommodated.

6.10 A policy approach is also set out above to respond to more recent national requirements for local authorities to respond to any identified need for people wishing to commission or build their own homes. Given the limited level of unmet demand identified on the Council's Self and Custom Build Register to date, a flexible policy approach has been adopted. This firstly encourages the provision of windfall self and custom build schemes, where these would be consistent with other development plan policies, ensuring that suitable schemes will receive clear support from the Council. In addition, to ensure the plan can respond flexibly if the need for such plots increases in the future, a requirement is introduced for general housing schemes to have regard to the findings of the register on a site-by-site basis.

6.11 In response to the district's needs forGypsy, Traveller and Travelling Showpeople pitches or plots, a criteria based policy is proposed. This is intended to reflect the national policy requirements for such policies to be fair and to facilitate the traditional and nomadic life of travellers while respecting the interests of the settled community. To achieve this, this policy approach will ensure that new sites/pitches are located in the right areas, are well designed, function effectively, and meet the needs of our Gypsy, Traveller and Travelling Showpeople communities', whilst also protecting the amenity of neighbouring residential areas, the Green Belt and landscape of the district.

Key evidence

Strategic Housing Market Assessment 2021
Housing and Homelessness Strategy 2018
Housing Density Topic Paper 2021
Specialist Housing: Local Need and Site Allocations Topic Paper 2021
Greater Birmingham Housing Market Area Strategic Growth Study 2018
Local Plan Review Viability Study 2021
Self and Custom Build Register
Gypsy and Traveller Accommodation Assessment 2021
Pitch Deliverability Study 2021

Design and space standards
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
HC9 - Design requirements	The policy will introduce a new set of requirements to ensure high quality design and creation beautiful places, which will require all new development to: Take account of any relevant requirements in the latest South Staffordshire Design Guide SPD, Shop Front Design Guide SPD or any design code or Conservation Area Management Plans relevant to the site Reflect the positive features that make up the character of the local area, enhancing and complementing the site's surroundings Require all developments to incorporate tree lined streets Positively respond to existing landform, layout, building orientation, massing and landscaping Use land efficiently whilst respecting existing landscape and settlement character Provide a clear and permeable hierarchy of streets, routes and spaces which incorporate a variety of green infrastructure through the development Give safe and convenient ease of movement to all users Provide access to local services and facilities Provide a range of house types and tenures Deliver tenure-blind housing for market and affordable properties, including the surrounding landscaping and public realm Integrates with any adjacent future planned development in the local area Clearly define public and private spaces Ensure that streets and other public spaces are well overlooked, whilst seeking to deliver wider Secure by Design principles, where practicable and consistent with other design objectives Accommodates car parking, cycle and bin storage using imaginative solutions that do not detract from the streetscene Deliver a high quality and well-maintained public realm that supports active recreation and travel To promote high quality design, the policy will also: Require Design and Access Statements on all planning applications, which should be proportionate to the scale and complexity of the development Include a policy hook for local design codes to be prepared for specific areas of the District following adoption of the Local Plan Identify specific strategic site SPDs and design codes to deliver the strategic development locations at Land East of Bilbrook, Land at Cross Green, Land North of Linthouse Lane and Land North of Penkridge Require other adjacent or closely related sites with similar delivery timescales to prepare a framework plan to show how a comprehensive and integrated layout could be achieved alongside other sites in the area	Blended approach of Design and Residential Amenity Policy Options A, B & C
HC10 - Protecting residential amenity	The policy will retain the existing approach set out in Policy EQ9 of the adopted Core Strategy.	n/a
HC11 - Space about dwellings and internal space standards	The Policy will retain the existing external space about dwellings standards set out in Appendix 6 of the adopted Core Strategy As a replacement to the existing internal space standards set out in the adopted Core Strategy, all properties will now be required to meet the government's Nationally Described Space Standard	Space About Dwellings Policy Option A Internal Space Policy Option C
HC12 - Parking Standards	Parking standards to be carried forward from the adopted Core Strategy In addition to the existing standards, electric vehicle charging standards will be introduced to achieve the following on new development: - Houses: One 7kW (or better) charge point per dwelling - Residential Flats/ C2 institutional accommodation: 20% of available spaces to be fitted with 7kw (or better) charge point and 20% of available spaces to be provided with power supply to allow for additional fast charge socket in future - Commercial Development: 20% of available spaces to be fitted with 7kw (or better) charge point and 20% of available spaces to be provided with power supply to allow for additional fast charge socket in future We feel that this approach strikes the correct balance between meeting the parking needs of residents, avoiding unnecessary on street parking, ensuring good design and reducing the impacts of climate change.	Blended approach of Residential Parking Policy Options E & F

6.12 South Staffordshire is characterised by a rural landscape containing a diverse collection of villages of differing built character, with no one dominant town or city within the District. As the District is expected to accommodate significant growth during the plan period, it is imperative that there are strong design policies and mechanisms in place to ensure that new development enhances the existing character of the District and provides a good quality of life to existing and future residents. It has therefore been necessary to update the design requirements policy in the Local Plan Review, to ensure focuses on the design issues most likely to face the Council in delivering development through the Local Plan Review.

6.13 The Council already has a number of design guides which it uses to ensure that new development responds appropriately to the diverse built character across the District. These currently include the District Design Guide, the Shopfront Design Guide and the Conservation Area Management Plans. However, with the change in the scale of development across the District and the increasing emphasis on design in national policy, it is clear that other tools will be required through the Local Plan Review to ensure beautiful and high quality design across the District. To ensure large scale developments have a comprehensive layout that is phased appropriately to deliver the necessary on-site retail, education facilities and green infrastructure, Supplementary Planning Documents are proposed for the four largest sites in the Local Plan Review. These will include site specific masterplans and design codes, recognising the requirements of the government's emerging National Model Design Code. In addition, the future design policy will highlight which other areas of the District will have their own design codes, once greater clarity regarding the use of design codes in rural areas is offered by the government. This mixture of approaches recognises the additional benefits that design codes and masterplanning can provide compared to standard design policy requirements^[13], whilst ensuring the use of such tools can be prioritised to the areas and types of site where they will be of most benefit.

6.14 It is also important that key design standards from the Council's existing Core Strategy are reconsidered to ensure they respond effectively to emerging issues. Given their importance in securing adequate separation distance and private amenity space between dwellings, the Council is proposing to retain the existing policies concerning residential amenity and the Space About Dwellings standards set out in Appendix 6 of the Core Strategy. However, because of changes in national policy, it will be necessary to replace the existing internal floorspace standards with the government's Nationally Described Space Standard, in line with the latest government guidance.

6.15 Due to the findings of the District's climate change evidence base and the government's intention to transition to electric vehicles, it will be necessary to update the existing parking standards to ensure on-plot charging facilities are provided with each new dwelling and on other non-residential developments. This is especially important as the District's climate change evidence base identifies road transport as South Staffordshire's biggest generator of carbon emissions by some distance, albeit this is in part due to the motorways that run through the District. The majority of the District's residents also drive to work, often in neighbouring towns and cities outside of the District. Whilst the location of development in proximity to bus and rail services may help to lessen this impact to some extent it is still vital that electric vehicle infrastructure is provided to improve air quality and to allow residents can access jobs in a sustainable manner.

Key evidence

National Design Guide - Ministry for Housing, Communities and Local Government
National Model Design Code: Consultation Proposals – Ministry for Housing, Communities and Local Government
District Design Guide 2018, including the Shop Front Design Guide
Conservation Area Management Plans
Historic Environment Site Assessment
Climate Change Adaptation & Mitigation – Final Report October 2020
Climate Change Adaptation & Mitigation – Baseline Report October 2020
Appendix 5 of the 2012 Core Strategy
Air Quality Annual Status Report 2019
Technical Housing Standards – Nationally Described Space Standard – Department for Communities and Local Government March 2015
Appendix 6 of the 2012 Core Strategy

Promoting successful and sustainable communities
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
HC13 - Health and Wellbeing	All development should be designed to maximise the positive impact on promoting health and wellbeing and supporting healthy communities Large developments (150+ dwellings) are also required to demonstrate through Design and Access Statements how specific measures have been designed into the development to have a positive impact on the health and wellbeing of residents. Include policy hook for a health and wellbeing SPD that will provide further detailed guidance on how the Council expects health and wellbeing benefits to be delivered through specific design interventions.	Blended approach of Health and Wellbeing Policy Options A & B
HC14 - Health Infrastructure	Existing healthcare infrastructure to be protected. Proposals for major residential developments must be assessed against the capacity of existing healthcare facilities through engagement with the revenant Clinical Commissioning Group (CCG), Where it is determined that the development results in an unacceptable impact on these facilities then a proportionate financial contribution will be sought agreed through engagement with the CCG. In the first instance, any infrastructure contributions will be sought for existing facilities.	n/a – informed by joint working with key infrastructure providers
HC15 - Education	Existing education infrastructure to be protected New education infrastructure to be required from new development in line with the latest Staffordshire Education Infrastructure Contributions Policy	n/a – informed by joint working with key infrastructure providers
HC16 - South Staffordshire College	Retain existing policy set out in the adopted Core Strategy (Policy EV4), with the exception of removing reference to Masterplan.	n/a (asked as a separate question - Question 49 - in the 2018 Issues and Options consultation)
HC17 - Open Space	Existing open spaces will be protected Require 0.006 hectares of multi-functional, centrally located open space per dwelling, with the threshold for on-site provision being required where new development would generate a need for 0.2ha of open space or more (i.e sites of 33 dwellings or above would require on site open space provision) On-site open space should include equipped play provision as a default Require sites of between 10 and 33 dwellings will be required to provide an offsite financial contribution equivalent to the amount of open space that would otherwise be required on-site Clarify that small incidental green infrastructure without a clear recreational purpose (e.g. landscape buffers, highways verges) should not be used to meet the quantitative on-site open space standard Further guidance on the procedure for determining provision required from new development will be set out in an Open Space, Sport and Recreation SPD	Leisure Facilities Policy Option B Question 77 in the 2018 Issues and Options consultation Children's Play and Youth Development Policy Option A
HC18 - Sports Facilities and Playing Pitches	Existing sports facilities and playing pitches will be protected Major developments will determine required provision through use of the latest Playing Pitch Calculator and Sports Facilities Calculator provided by Sport England, informed by the recommendations of both the Indoor Sports Facilities Strategy 2020 and the Playing Pitch Strategy 2020 Further guidance on the procedure for determining provision required from new development will be set out in an Open Space, Sport and Recreation SPD	Leisure Facilities Policy Option B
HC19 - Wider green infrastructure design principles	Introduce a policy to ensure opportunities to introduce green infrastructure provided to meet open space, biodiversity, active travel, climate mitigation/adaptation and sustainable drainage are integrated together within a scheme in a genuinely multi-functional manner, where this can be achieved in a manner consistent with other local design policies. Further strategic guidance on green infrastructure provision to be set out in a Green Infrastructure SPD	n/a

6.16 It is important that the Local Plan Review provides the social and green infrastructure to provide existing and future residents with the facilities they need. As part of this process, the Council continues to work closely with stakeholders from NHS England and local Clinical Commissioning Groups to ensure that there is capacity in local primary health care infrastructure for future development, securing contributions from development towards necessary improvements where required. It also works closely with the Education Authority (Staffordshire County Council) to ensure new school infrastructure is provided by developments and will continue to use the Staffordshire Education Infrastructure Contributions Policy to ensure this is provided in future. As part of the District's education offer development associated with the use of South Staffordshire College (Rodbaston) as an education and training establishment will continue to be supported.

6.17 To support the Local Plan, a number of evidence base documents have been prepared to identify the scale of open space, sports and recreation facilities needed to support future housing growth in the District. The preferred policy approaches and standards set out above have been informed by the recommendations of these studies to ensure that, where there is a local need identified in the relevant strategy, development can make a contribution to providing the relevant facilities and open spaces. They also include the relevant protections to ensure existing facilities are protected from development, in line with national policy. Recognising the need to ensure that green infrastructure is designed in a truly co-ordinated and multi-functional way, a green infrastructure policy has also been introduced to make it clear that such elements should be integrated together within scheme design, rather than being designed in isolation from one another.

Key evidence:

Staffordshire Education Infrastructure Contributions Policy
Open Space Audit Assessment Report October 2019
Open Space Study Standards Paper January 2020
Playing Pitch Strategy Assessment Report January 2020
Playing Pitch Strategy & Action Plan September 2020
Indoor Sports Facilities Needs Assessment Final Report January 2020
Indoor Sports Facilities Strategy February 2020
Infrastructure Delivery Plan 2021

Economic Vibrancy

Building a strong local economy
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
EC1 - Sustainable economic growth	Policy will ensure that there is a sufficient supply of employment land to meet the needs of the economy, to encourage inward investment and to support identified and potential growth sectors such as advanced manufacturing including Auto-Aero and Agri-Tech. Growth to be focussed at the currently identified employment areas and the recently approved West Midlands Interchange. Continue to support the delivery of strategic employment sites at West Midlands Interchange, Four Ashes, I54, Hilton Cross and ROF Featherstone. Support opportunities for employment development within the Tier 1 and Tier 2 villages identified within the settlement hierarchy subject to other policy requirements including ensuring proposals do not have an unacceptable impact on local amenity. Promote the diversification of the economy in rural areas where compatible with other plan policies Support measures to provide necessary infrastructure Preference given to the use of previously developed land except where this would result in significant biodiversity loss. Promote the provision of active travel measures and the creation/enhancement of multifunctional green spaces and the enhancement of the Green Infrastructure Network.	Employment Sites Policy Option A
EC2 - Retention of employment sites	Policy would seek to protect existing designated employment areas set out in Table 9 at paragraph 5.12 and to be reflected on the policies maps. Loss will not be permitted unless: Site has been marketed for employment uses without success for a minimum of twelve months. Redevelopment would result in significant economic benefits Alternative uses must not prejudice continued operation and viability of existing/allocated employment areas. Strong presumption in favour of retaining strategic employment sites for employment uses.	Employment Sites Policy Option A
EC3 - Inclusive Growth	Policy to require applicants to submit an Employment and Skills Plan (ESP) for developments of 100 or more residential units or 5000sqm of commercial floorspace. Delivery of the ESP secured through a Section 106 agreement or via a planning condition where it is considered appropriate to do so.	Inclusive Growth Policy Option C
EC4 - Rural employment and tourism	Retain existing policy approach of supporting rural diversification with a preference for development within existing development boundaries. Development outside existing villages to be primarily restricted to opportunities relating to reusing existing buildings. Rural Development SPD to give greater guidance of nature of business case requirements.	Rural Employment and Tourism Policy Option A
EC5 - Agricultural workers dwellings and equine related development	Agricultural: Retain broad principles of existing policy approach set out in the adopted Core Strategy (Policy EV8). Include reference to a Rural Developments SPD which will provide detailed guidance on barn conversion, equine development and polytunnels. Rural workers dwellings policy approach to be retained however reference the requirement for an essential need to be demonstrated. Equine Retain broad principles of existing policy approach set out in the adopted Core Strategy (Policy EV7). Include reference to Rural Development SPD to offer further guidance on implementation of the policy.	n/a

6.18 South Staffordshire currently contains four existing freestanding strategic employment sites at i54, ROF Featherstone, Hilton Cross and Four Ashes, which accommodate a large proportion of the District's employment land supply and have good access to the strategic road network. The employment offer on the larger freestanding sites is balanced by a number of smaller industrial estates located both within some of the District's existing settlements and in the wider functional economic market area (e.g. the urban area of the Black Country). Within the wider rural area, employment, tourism and recreation opportunities are driven by appropriate rural diversification and small-scale start-up businesses.

6.19 Recognising the range of employment opportunities across the District, multiple policy approaches are proposed to allow for sustainable employment growth within the District. Firstly, a sustainable economic growth policy is set out, indicating how the Council will encourage growth, key growth sectors, the types of locations that new employment growth will be permitted within and how this will be done in an environmentally sensitive manner. As part of this policy the newly consented strategic rail freight interchange known as West Midlands Interchange is recognised as a new freestanding strategic employment site, recognising the scale and strategic location of the site, alongside the substantial additional employment land it contributes to the Council's supply. A corresponding policy approach to protect existing sources of employment is also proposed unless specific tests are met, recognising the importance of safeguarding these sites to meet the employment needs of residents both within and outside of the District.

6.20 To ensure that growth benefits the local communities located in close proximity to it, a policy approach is proposed to secure an Employment and Skills Plan on large scale housing and employment schemes. This will allow such proposals to support upskilling in the local area, providing a strong and skilled workforce that benefits both local businesses and residents, whilst also helping to encourage more sustainable commuting patterns by encouraging local residents to work more locally within the District.

6.21 In the District's wider rural area, the existing policy approaches to tourism, rural diversification and agriculture will be largely retained, recognising the need for such approaches to sensitively managing the growth of such uses alongside the rural area's sensitive landscapes and habitats, alongside the extensive Green Belt coverage in many such areas. However, to provide greater clarity and guidance to applicants, a Rural Developments SPD will be prepared, to offer greater guidance on the appropriate siting, scale and design of such proposals. Continuing to prioritise delivering tourism and rural diversification in existing development boundaries and through the re-use of existing buildings reflects the greater level of protection such an approach may offer the District's landscapes and habitats^[14].

Key evidence

Economic Development Needs Assessment Part 1 August 2018
Economic Development Needs Assessment Part 2: Economic Land Availability Assessment 2021
Stoke-on-Trent & Staffordshire Strategic Economic Plan April 2018
Stoke-on-Trent and Staffordshire Local Enterprise Partnership Growth Deal 1-3
Destination Staffordshire Tourism Review, Strategy and Action Plan
A Tourism Strategy for South Staffordshire

Community services, facilities and infrastructure
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
EC6 - Retail	Policy will: Identify three tier hierarchy (Large Village Centres, Village Centres and Neighbourhood Centres) as recommended in the Retail Centres Study 2021 (para.7.31). On site retail in strategic growth areas may be justified where this does not conflict with existing retail provision. Introduce Impact Test threshold of 500 sqm for new retail provision (consider a 300sq.m. threshold for comparison floorspace). Support residential development within village centres only where this doesn't result in the loss of essential services or facilities (including retail services) and where it would not create a concentration of non-centre uses or result in a change to the retail character of the surrounding area.	Village Centres and Retail Policy Option A
EC7 - Protecting community services and facilities	Policy will retain the existing approach set out in the adopted Core Strategy (Policy EV9). Support the provision of new services and facilities. Seek to protect against the loss of existing services particularly where this is the sole or last remaining facility.	Protecting Community Services and Facilities Policy Option A
EC8 - Wolverhampton Halfpenny Green Airport	Policy will maintain the existing approach set out in the adopted Core Strategy (Policy EV13). Supporting development proposals related to general aviation and the existing businesses but only within the developed area of the site as defined by the current policies map.	Wolverhampton Halfpenny Green Airport Policy Option A
EC9 - Infrastructure	Policy will commit the council to working with infrastructure providers, agencies, organisations and funding bodies to enable, support and co-ordinate the delivery of infrastructure to support the delivery of the growth identified within the Local Plan and offer policy support for other infrastructure requirements set out in the Council's Infrastructure Delivery Plan.	Infrastructure Policy Option A
EC10 - Developer contributions	Policy will retain commitment to using s106 payments to fund all types of infrastructure. Specific infrastructure requirements will be identified in relevant policy areas and site proformas.	Infrastructure Policy Option A
EC11 -Sustainable transport	The policy will: Promote joint working between the District, County Council and neighbouring highways authorities on sustainable transport measures, including active travel Support strengthening bus/rail services and connections to these services in response to increased demand from new development Commit the District/County Council to preparing Local Walking & Cycling Infrastructure Plan to identify strategic opportunities for walking and cycling improvements within the District Ensure development is designed to promote high quality walking and cycling, both within sites and to links to nearby services and facilities Require new cycle infrastructure to be compliant with Local Transport Note 1/20, or subsequent updates Support the widespread delivery of electric vehicle charging points through new development, through the revision of existing car parking standards Provide support for the delivery of a rail-based park and ride within the Land at Cross Green strategic development location identified in Appendix B of this document	Public Transport and Highway Network Policy Option A

6.22 The District's services and facilities are spread across the various rural communities spread throughout South Staffordshire, with no central town or city to form the focus for provision or investment. To ensure the proper protection and recognition of retail within the District, a retail centres hierarchy and retail impact assessment threshold have been established using a thorough study of the District's existing centres. To maintain the vitality and sustainability of the District's communities protections have also been retained for the District's existing facilities and services, alongside delivery mechanisms to fund and deliver new facilities through developer contributions and joint work with infrastructure providers. Recognising its role in contributing to the District's employment offer, a policy seeking to retain and enhance the existing extent of Wolverhampton Halfpenny Green Airport has also been retained.

6.23 The Council's climate change evidence base shows that transport continues to be a significant source of the District's carbon emissions and it is vital for the plan to provide mechanisms to address this issue. The District is heavily reliant on neighbouring towns and cities for employment and higher order services, so it is necessary to provide a range of sustainable transport measures that seek to reduce the District's carbon emissions whilst recognising this interrelationship. Recognising these relationships, the sustainable transport policy supports the shift towards electric vehicles, alongside the longer-term delivery of a rail-based parkway within the District, recognising the role both of these measures could play in reducing carbon emissions associated with accessing employment and facilities outside of the District.

6.24 The sustainable transport policy seeks to deliver new walking and cycle provision in line with the government's design standards, whilst recognising the need to align planned improvements with walking and cycling improvements planned in neighbouring towns and cities. There are ambitious plans to expand the walking, cycling, rail and metro network in the Black Country so it is important that any future improvements in South Staffordshire plan to align with these wherever possible. The Council will work with Staffordshire County Council and Black Country partners to ensure that the local walking and cycling evidence base is updated to reflect the needs of the District and the planned improvements adjacent to its borders.

Key evidence

Rural Services and Facilities Audit 2019
Retail Centres Study April 2021
Infrastructure Delivery Plan 2021
Climate Change Adaptation & Mitigation – Final Report October 2020
Climate Change Adaptation & Mitigation – Baseline Report October 2020
Staffordshire Local Transport Plan 2011
Staffordshire County Council Local Cycling and Walking Infrastructure Plan 2020 – 2030
Cycling and Walking Network – Transport for West Midlands 2019
Starley Network – West Midlands Network
Movement for Growth – 2026 Delivery Plan for Transport – Transport for West Midlands
2040 Plan for Metro and Rail in the West Midlands – West Midlands Mayor
Cycle infrastructure Design: Local Transport Note 1/20 – Department for Transport 2020

The Natural and Built Environment

Protecting and enhancing the natural environment
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
NB1 - Protecting, enhancing and expanding natural assets	Policy will promote the protection, enhancement and restoration of the natural environment. Proposals which could have an adverse impact on Internationally and Nationally designated habitats and protected and priority species (including habitats considered to be irreplaceable – ancient woodland, ancient/veteran trees, historic parkland) will be determined in accordance with the provisions of the relevant statutory and national policy. Support will be given to any proposals to enhance designated sites. Locally designated habitats, including local wildlife sites, will be protected and enhanced. Opportunities to improve connectivity and to facilitate the creation of wildlife corridors will be supported. Protect and enhance areas of high habitat distinctiveness and support the creation of strategic linkages and stepping stones, using the most up-to-date Nature Recovery Network mapping prepared by the Staffordshire Wildlife Trust. Require developments to enhance the natural as well as the built environment, including through a requirement for tree lined streets,	Natural Environment Policy Option B
NB2 - Biodiversity	Policy will employ use of the mitigation hierarchy (Avoid, Mitigate, Compensate) when considering the potential impacts of development on biodiversity. Details of proposed mitigation/compensation will need to be agreed prior to gaining approval. Where relevant applicants will be required to undertake an Ecological Survey/Ecological Impact Assessment. All new development will contribute a measurable net biodiversity gain: A threshold of 10% will be set for major developments. Applicants will be expected to submit a Biodiversity Baseline Assessment of the current site. Calculation to be based on Defra's biodiversity metric. Net-gain is to be delivered on-site wherever possible. If this cannot be achieved and where the ecological benefits are greater through enhanced off-site provision then a financial contribution will be sought and directed to off-site projects informed by the most up-to-date Nature Recovery Network mapping prepared by the Staffordshire Wildlife Trust.	Natural Environment Policy Option B
NB3 - Cannock Chase SAC	The Principal legislative framework surrounding SAC's remains unaltered. The principle of requiring mitigation to address the likely adverse effects of residential development remains valid. The policy will however require updating to take account of emerging changes being promoted by the SAC partnership i.e. The range of development captured by the scheme may be extended to encompass other forms of accommodation including tourism facilities, HMO's, Assisted Living, Sheltered housing etc. Reference to suitability of Sites of Alternative Natural Green Space (SANGs) as a possible mitigation measure is still to be resolved, the recent SAC Planning Evidence Base update suggested that this be the subject of a separate scoping study. Update the separate Guidance to Mitigation note or produce a dedicated SPD. This will need to be cross referenced by the Local Plan Policy and will contain details of the necessary mitigation including the charging regime and its extent both geographically and in terms of accommodation types (different types may attract differential charging). Include a policy hook to address potential issue with air quality on Cannock Chase SAC and other SAC sites and the potential need for mitigation to address this issue.	Question 75 in the 2018 Issues and Options consultation
NB4 - Landscape Character	Policy will maintain the current approach used in Core Strategy Policy EQ4 seeking to protect and enhance landscapes including a commitment to undertake landscape sensitivity and capacity assessment to seek to focus growth in areas of lesser sensitivity. A potential amendment would be the strengthening of the protection for on-site trees and hedgerows.	Landscape Character Policy Option A

6.25 South Staffordshire is host to a wide variety of assets that contribute to the District's natural environment, ranging from designated Special Areas of Conservation to the hedgerows and trees that contribute to the biodiversity and rural character of the District. The policy approaches proposed by the Council seek to offer protection to all of these natural assets, in a manner proportionate to their importance. Recognising more recent changes to national policy, the policies now offer greater protection to irreplaceable natural assets and recognise the role of highly distinctive habitats and strategic linkages identified in the District's Nature Recovery Network Mapping, putting in place proportionate protections for these areas.

6.26 Recognising the increasing importance of biodiversity net gain in national planning policy, the policy approaches also seek to introduce a new mechanism to secure biodiversity net gain within the District, using a clear metric, mitigation hierarchy and evidence base to identify potential off-site improvement options. The District's Nature Recovery Network Mapping offers guidance on how any habitat mitigation or compensation could be appropriately directed across the District, ensuring that any habitats provided are in the right location and of the right type to genuinely improve biodiversity. Taken together with the other protective policy approaches, this will help to ensure that new development proposals improve, rather than detract from, the District's natural environment.

6.27 In addition to more general policies seeking to manage the District's wider natural environment, the Council's specific policy approach to the Cannock Chase Special Area of Conservation (SAC) has been restated and amended to reflect the most up-to-date evidence regarding this important habitat. The updates made recognise the existing and emerging work that the Council participates in with Natural England and other Council's through the Cannock Chase SAC Partnership, ensuring that this SAC is not adversely affected by planned development.

6.28 The District's natural environment has value not only in terms of its biodiversity and habitats, but also in terms of its contribution to the rural character of the District. The existing landscape character policy in the Council's Core Strategy is to be retained, but also updated to include an increased emphasis on the Council's landscape sensitivity evidence base and the importance of tree and hedgerow retention within the District. This approach recognises the presence of valuable landscapes within the District as well as the intrinsic character and beauty of South Staffordshire's rural area, ensuring that new development responds positively to these assets.

Key evidence

Nature Recovery Network Mapping 2020
Cannock Chase Special Area of Conservation Evidence Base Review Stage 2
Landscape Sensitivity Study 2019
Planning for Landscape Change - Staffordshire County Council

Climate Change and sustainable development
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
NB5 - Renewable and low carbon energy generation	Indicate general in-principle support across the District for renewable or sustainable energy schemes, such as solar and wind generation, subject to conformity with other local plan policies (particularly those relating to the natural and historic environment, amenity and landscape character) Clarify that the Council may still consider biomass schemes where fully compliant with both the existing adopted Core Strategy Policy EQ6 criteria and additional criteria regarding sustainable biomass fuel sources and impacts on air quality Indicate general support for on-shore wind, removing the areas of search set out in the adopted Core Strategy Policy EQ6, instead adopting a District-wide criteria-based policy which also reflects national policy requirements on community engagement Confirm that renewable energy development in the Green Belt may be justified, where very special circumstances can be demonstrated for any elements which would be inappropriate Green Belt development	Adapting to a Changing Environment Policy Option D
NB6 - Energy and water efficiency, energy and heat hierarchies and renewable energy in new development	All major residential developments must: achieve a 31% carbon reduction improvement upon the requirements within Building Regulations Approved Document Part L 2013, or conform with any national targets which subsequently exceed this standard exceed the carbon emission targets set by current UK Building Regulations through fabric and energy efficiency measures alone, whilst achieving the additional 31% CO2 improvement target through further fabric and energy efficiency and/or the use of decentralised, low and zero carbon energy technologies submit an energy statement identifying the predicted energy consumption and associated CO2 emissions of the development and demonstrating how the energy hierarchy has been applied to make the fullest practicable reduction in regulated carbon emissions arising from the development deliver the optional water efficiency standards for new developments set out in the Planning Practice Guidance All major non-residential development must: achieve BREEAM 'Excellent or Outstanding' standard submit an energy statement demonstrating how the energy hierarchy has been applied to make the fullest practicable reduction in regulated carbon emissions arising from the development	Adapting to a Changing Environment Policy Option B Question 77 in the 2018 Issues and Options consultation
NB7 - Managing flood risk, sustainable drainage systems & water quality	The following will be key requirements of any future policy: All major developments should deliver sustainable drainage systems and provide a site specific flood risk assessment and surface water drainage strategy, which should include details of adoption, ongoing maintenance and management Site-specific flood risk assessments should be in accordance with any relevant national requirements and take account of the latest climate change allowances Sustainable drainage systems should reflect the design requirements and drainage hierarchy set out in the Staffordshire County Council Sustainable Drainage Systems (SuDS) Handbook - February 2017, or subsequent updates Development should not adversely affect the quality or quantity of water, either directly through pollution of surface or ground water or indirectly through the treatments of waste water	n/a (informed by joint working with key infrastructure providers)
NB8 - Hazardous and environmentally sensitive development	Retain current approach set out in the adopted Core Strategy (Policy EQ10).	n/a

6.29 The District has recently declared a climate emergency, recognising the importance of the Council's functions in contributing to a radical reduction in carbon emissions. To help the Council to identify opportunities to achieve this aim it has jointly prepared a climate change evidence base with other Staffordshire authorities. It is proposed to take forward a number of recommendations from this study.

6.30 To assist in climate change mitigation, the policy approaches include enhanced energy efficiency standards and encourage the use of energy hierarchies and on-site renewable energy provision, recognising the need to reduce carbon emissions in the District's built environment and the difficulties and additional costs of retrofitting the necessary technology at a later date. It also addresses the need to decarbonise energy generation within the District, introducing an in-principle support for most types of renewable energy generation within the District, where these can be sensitively accommodated. It also reflects the climate change evidence base's recommendations regarding onshore wind and biomass, proposing appropriate updates to the Council's existing policies to reflect more recent evidence and changes in national planning policy on such schemes.

6.31 The District's areas of flood risk, existing drainage infrastructure and water resources need to be managed effectively to adapt to the effects of climate change and to ensure new development is supported by appropriate infrastructure. Policy approaches have been drafted to address these issues, reflecting previous engagement with the Lead Local Flood Authority (Staffordshire County Council) and Severn Trent Water. This had led to key design requirements that should be used by new development, such as delivering on-site sustainable drainage systems designed and delivered in accordance with the Lead Local Flood Authority's SuDS handbook and ensuring new dwellings are designed to be water efficient to reduce the burden on the surrounding drainage infrastructure.

6.32 Recognising the ongoing importance of ensuring that potentially hazardous or polluting uses are kept separate from other sensitive uses, the Local Plan Review proposes to retain the existing policy approach to such developments, set out in the 2012 Core Strategy.

Key evidence

Southern Staffordshire Councils Level 1 Strategic Flood Risk Assessment - Final Report October 2019
Staffordshire County Council Sustainable Drainage Systems (SuDS) Handbook - February 2017
Staffordshire Climate Change Adaptation & Mitigation – Final Report October 2020
Staffordshire Climate Change Adaptation & Mitigation – Baseline Report October 2020
Southern Staffordshire Councils Water Cycle Study – Phase 1 Scoping Study February 2020

Enhancing the Historic Environment
Policy Reference	Proposed Direction of Travel	Relevant 2018 Issues and Options policy options
NB9 - Conservation, preservation and protection of historic assets	Policy to promote the conservation and enhancement of the historic environment through the positive management of development proposals and the safeguarding of heritage assets and their setting. Development affecting heritage assets and their setting to be determined in accordance the approach detailed in the NPPF. Applicants to be required to submit a proportionate assessment of the impact of proposed development on the significance of any identified heritage assets. New development to take account of existing historical character when considering siting, design and use of materials. Development to be sympathetic and consistent with the conservation and enhancement of heritage assets and their setting. New development to take the opportunity to better reveal the significance and increase understanding of heritage assets. Alternative uses for heritage assets, consistent with asset conservation, will be supported subject to consideration of the viability of the proposed new use. Works to heritage assets to be informed by historical, architectural and archaeological evidence proportionate to significance. Proposals for enabling development will be considered and assessed to determine if the benefits of securing the future conservation of the heritage asset outweigh the departure from adopted plan policies. Maintain a local list of non-designated heritage assets. Proposals to conserve and enhance local list assets will be supported. Proposals affecting Conservation Areas and their setting should take account of the appraisals and recommendations contained with the adopted Conservation Area Management Plan. Features to be considered include respecting focal buildings, important views and positive buildings and open spaces.	Historic Environment Policy Option A
NB10 - Canal network	Proposals for new canal-side development to: Be sympathetic and consistent with the conservation and enhancement of the canal network. Be located within or close to existing settlements in preference to isolated developments within the District's wider rural area. Support measures to integrate the canal network into the wider Green Infrastructure network through biodiversity net gain. Maintain support for restoration of the Hatherton Branch Canal extension.	n/a

6.33 South Staffordshire has a rich variety of historic assets spread throughout the District, of a variety of scales and importance. In the wider rural area these often include canal conservation areas which run for large distances through the District, as well as large designated and undesignated historic parks and gardens sat within a wider rural landscape. The villages within South Staffordshire also have a varied historic past, from the historic medieval market towns in Penkridge, Kinver and Brewood to the more recent settlements in the north-east of the District based upon the historic mining industry in that area. Numerous conservation areas are also spread throughout the District, often recognising the historic core of the District's rural villages, whilst a variety of listed buildings are scattered throughout both the District's villages and wider rural area.

6.34 To ensure appropriate mechanisms are in place to respond appropriately to this tapestry of heritage assets, the Local Plan Review will include a policy reflecting the approach set out the above. This builds on the District's existing historic environment policies, whilst increasing the emphasis on the use of the Conservation Area Management Plans prepared throughout the District to ensure that new development in such areas is sympathetic to the surrounding historic character. It also clarifies that development proposals affecting the setting of a heritage asset will be determined using the relevant policy test in national planning policy, to offer clarity to applicants and decision makes.

6.35 Reflecting the recreational and historic importance of the District's canal network, a policy approach has been set out above to sensitively manage development in such locations. This builds upon existing policies within the District's Local Plan, but places an increased emphasis on the role of the canal network in contributing to biodiversity net gain, whilst also encouraging new canal-side development towards existing settlements within the District to increase the sustainability of such proposals.

Key evidence

Conservation Area Management Plans
Historic Environment Site Assessment
Historic Environment Character Assessment
Staffordshire Historic Environment Record
Hatherton Canal Restoration Feasibility Report and Supplementary Feasibility Report

(270) Question 11:

Do you agree with the proposed policy approaches set out in Chapter 6? Yes/No

If no, then please provide details setting out what changes are needed, referencing the Policy Reference number (e.g HC1 - Housing Mix).

(79) Question 12:

It is proposed that the fully drafted policies in this document (Policies DS1-DS4 and SA1-SA7) are all strategic policies required by paragraph 21 of the NPPF. Do you agree these are strategic policies? Yes/No
Are there any other proposed policies in Chapter 6 that you consider should be identified as strategic policies? Yes/No

If yes, then please provide details including the Policy Reference (e.g HC1 – Housing Mix)

^[11] Major residential development is defined in the 2019 National Planning Policy Framework as "development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more".

^[12] Subject to viability testing through the Local Plan Review evidence base

^[13] Section 3.37 of the 2018 Local Plan Review Issues and Options Sustainability Appraisal

^[14] Section 3.47 of the 2018 Local Plan Review Issues and Options Sustainability Appraisal

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