Publication Plan April 2024

Ended on the 31 May 2024

3. What does the Local Plan need to consider?

National context

National requirements for plan-making

(2) 3.1 National policy requires that plans set out a vision and a framework for future development and seek to address the strategic priorities for the area. South Staffordshire is not within a Combined Authority area (or under the remit of an elected Mayor) and therefore strategic planning is the responsibility of the local planning authority. The strategic priorities for South Staffordshire will be set out in the Local Plan, which along with any potential Neighbourhood Plans, will form the Development Plan for the area.

3.2 The strategic policies for an area should include policies and site allocations to address key issues such as:

an overall strategy for growth
housing (including affordable housing)
commercial development
retail and leisure
infrastructure
community facilities
climate change
conservation and enhancement of the natural and built environment

3.3 Plans should be clear in identifying strategic policies. They should form a starting point for local non-strategic policies which can include more detailed development management policies. Strategic policies should include a clear spatial strategy for bringing forward enough land to address housing needs over the plan period and be underpinned by relevant and up to date evidence. It is now a legal requirement to have completed a review of the Local Plan within 5 years of its adoption to take account of changing circumstances affecting the area.

3.4 The NPPF sets out that Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered 'sound'. Plans are considered sound if they are: positively prepared, justified, effective, and consistent with national policy.

Neighbourhood Planning

3.5 South Staffordshire currently only has one adopted Neighbourhood Plan, the Kinver Neighbourhood Plan, which was made in September 2023. In addition, a number of other local groups have begun to advance plans for their area. The latest progress of these documents is available in the council's Local Development Scheme. Codsall, Bilbrook and Penkridge parishes have been designated Neighbourhood Plan areas and are currently undertaking scoping in advance of preparing Neighbourhood Plans. The role of Neighbourhood Plans is to promote a shared vision and identify local policies for the neighbourhood area, rather than strategic policies. Crucially, neighbourhood plans must be in general conformity with the area's strategic policies and cannot provide for less development than is set out in the Local Plan. Where a Neighbourhood Plan has been produced, then the local policies in it would take precedence over the local policies in the Local Plan if the Neighbourhood Plan has been adopted more recently.

Cross boundary Issues and the Duty to Cooperate

(23) 3.6 Local Planning Authorities have a legal duty to cooperate with neighbouring authorities and other prescribed bodies on strategic matters that cross administrative boundaries. Strategic matters can include housing, employment, infrastructure, and the Green Belt. The council has been working collaboratively with neighbouring authorities on cross boundary issues for a number of years. A clear example of this is how unmet employment needs from the Black Country helped support new employment allocations at i54 and ROF Featherstone in the adopted SAD (2018). Unmet housing need across the GBBCHMA, our own unmet needs for Gypsy and Traveller pitches and unmet employment land needs from the Black Country authorities are key cross boundary issue to be considered with neighbouring authorities through plan preparation.

(8) 3.7 The NPPF presumption in favour of sustainable development makes it explicit that authorities should plan for their own objectively assessed needs for housing and other development, as well as any needs that cannot be met in neighbouring areas unless NPPF policies provide a strong reason for restricting development or the adverse impacts of doing so would significantly and demonstrably outweigh the benefits. Agreements through Statements of Common Ground are now a necessity and will document the cross-boundary matters that need to be addressed and what progress has been made in dealing with them.

Evidence base

(3) 3.8 The new Local Plan must be based on a wide variety of up to date and robust evidence, providing technical information specific to South Staffordshire. Appendix A sets out the range of studies and topic papers that have been prepared and these are available on the council's website. After each policy in this document there is a bullet point list of the key evidence that has helped shape that policy.

3.9 A number of the evidence studies are iterative which means that an updated version will sit alongside each stage of the Local Plan. These are discussed in further detail below.

Sustainability Appraisal (SA)

(9) 3.10 The Local Plan must contribute to achieving sustainable development, aiming to achieve a better quality of life for all, both now and for future generations. A Sustainability Appraisal (SA) is a statutory requirement, which ensures that the environmental, social and economic effects of a plan and reasonable alternatives to the plan are being considered. A separate SA was prepared to appraise proposals at each stage of Local Plan preparation and was subject to consultation. The SA assesses the sustainability of the strategic approach, proposed allocations and reasonable alternatives, and the content of the policies contained in the plan. The SA findings have been used to help refine policy choices and site options through to the final proposals set out in the Local Plan.

Habitats Regulation Assessment (HRA)

(1) 3.11 The Habitats Directive establishes an ecological network of protected European Sites (Natura 2000 Network) and requires consideration of whether or not an Appropriate Assessment needs to be undertaken during the preparation of a Local Plan. The purpose is to assess what effects, if any, the plan might have on protected European sites. A Habitats Regulations Assessment (HRA) will be undertaken as required by Regulation 61 of the Conservation of Habitats and Species Regulations 2010 (as amended) in order to see whether the plan could have the potential to result in likely significant effects upon protected European sites and sites of international importance for nature conservation.

3.12 Mottey Meadows Special Area of Conservation (SAC) near Wheaton Aston is located entirely within South Staffordshire. There are also three SACs in close proximity to the district boundary; Cannock Chase SAC, Cannock Extension Canal SAC and Fens Pools SAC, which must be considered when preparing any plans or proposals, to ensure they have no adverse impact on these sites.

3.13 Further information on the HRA process and the mitigation required for Cannock Chase SAC, can be found in the HRA documentation and on our website.

Infrastructure Delivery Plan (IDP)

(3) 3.14 A refreshed Infrastructure Delivery Plan (IDP) has been prepared to support the new Local Plan to ensure the required infrastructure and investment needed to deliver the plan effectively is identified. The IDP includes the specific infrastructure projects needed to deliver planned growth as well as details of indicative costs, delivery mechanisms and the phasing on infrastructure where known. This is particularly important for the large strategic site allocations, which by their nature involve more complex infrastructure requirements and have been informed by extensive ongoing engagement with relevant infrastructure providers.

Issues and Challenges for South Staffordshire

(7) 3.15 Community engagement throughout plan preparation confirmed a number of issues and challenges in South Staffordshire that should be addressed by the new Local Plan and are set out in Tables 3-5. These issues and challenges are informed by the SWOT analysis in Table 2 below:

(6) Table 2: SWOT analysis

Strengths

Weaknesses

Natural assets including natural green spaces, parks and gardens and designated wildlife sites.
Built assets including attractive characterful villages, listed buildings, conservation areas and tourist attractions.
Very well served (particularly in the north) by national railway and highway transport corridors, with good access to nearby major conurbations.
Low levels of unemployment.
High life expectancy for residents.

Demographic imbalance with higher than average proportion of residents aged 65+, and a projected decline in families and working age residents, with resultant threat to some service provision.
Reliance on neighbouring areas for higher order services and a dependency on their economic health for access to employment.
Poor public transport connectivity in parts of the district.

Opportunities

Threats

Continued development of the strategic employment sites including at i54 South Staffordshire, ROF Featherstone and West Midlands Interchange leading to greater inward investment and prosperity.
Plan positively to meet future housing needs in a way that improves infrastructure, services and facilities for existing and new households.
Build on the tourism offer of the built and natural environment.
Enhance the natural environment through sympathetic new development and by measures such as biodiversity net gain and Green Belt compensatory measures.
Role in meeting cross boundary unmet needs and opportunities to masterplan strategic site allocations creating sustainable new communities.

Increasing pressure for development on land within the Green Belt to meet our own housing needs and the needs of adjoining areas, which if not properly managed, could threaten the quality and character of the district.
Lack of available brownfield land in the district.
A concentration of large scale developments, such as the West Midland Interchange (WMI) strategic rail freight interchange, poses a threat to the district in terms of the cumulative impact on the surrounding infrastructure.

Homes and Communities - Issues and Challenges

(1) Table 3: Homes & Communities – issues and challenges

Issue / Challenge

Explanation

Level of growth needed to meet South Staffordshire's housing needs and unmet housing needs of the wider housing market area.

South Staffordshire is within Greater Birmingham and Black Country Housing Market Area (GBBCHMA), which is made up of fourteen diverse local authorities, including Birmingham and the four Black Country authorities.
South Staffordshire's local housing need (LHN) is currently 227 dwellings per annum.
Through the Duty to Cooperate, South Staffordshire should consider its role in providing additional homes to meet needs of the GBBCHMA through a Statement of Common Ground, having regard to national policy.
Pressure on South Staffordshire to release land for housing in the Open Countryside and outside the Green Belt will be particularly acute.

Levels of growth needed to meet South Staffordshire's Gypsy and Traveller needs.

Need to provide additional Gypsy and Traveller pitches to meet as far as possible the need identified in the Gypsy and Traveller Accommodation Assessment (GTAA) 2024
Gypsy and Traveller sites within the district are often in rural locations, with a large proportion concentrated in north of district close to the strategic transport network.
Existing sites are privately owned and located in Green Belt. Strong preference for permanent residential pitches over new public sites from the traveller community.
Principle issues for meeting pitch needs include delivering new pitches in the right location for the right people, having regard to existing sites and family need, and recognising the constraints that impact the district.

Delivering a variety of homes, to meet the needs of all groups of the community and better balance the local housing market.

Currently, there is a mismatch between existing stock and future housing needs.
Providing smaller residential units for young families and older people wishing to downsize will free up family sized accommodation elsewhere in community.
The Housing Market Assessment 2022 and partial update (2024) considers the type of housing and mix of tenures needed and will guide policies to support an appropriate mix of market and affordable housing.

Meeting the housing needs of the ageing population and providing specialist housing.

District has an increasingly ageing population, considerably higher than the national average.
Major challenge in meeting needs of older people includes development of new and improved services, and the provision of the right mix of specialist housing, including bungalows.
The Local Plan will need to support the provision of specialist housing requirements of other groups, such as those with disabilities.

Delivering affordable housing to meet local needs.

House prices in the district have increased, with villages attracting those who are prepared to travel to work in nearby major urban areas. The ratio of house prices to incomes is high in regional terms.
Challenge of maintaining adequate and suitable supply of affordable housing for those on low incomes and first-time buyers.
A significant proportion of affordable housing is delivered through development contributions via Section 106 agreements.

Delivering decent homes of a high-quality design that reflect and maintain the local distinctiveness, character and quality of the countryside and villages.

Key challenge of providing a variety of well-designed homes through working with a variety of small and large housebuilders, meeting need for Self and Custom Build Housing, working with Registered Providers (RPs) and adopting a flexible approach to conversions and reallocation of undelivered sites.
Cost effective design measures can be undertaken to create well designed, energy efficient homes with appropriate levels of internal and external space which leads to wider health and wellbeing benefits for residents.
Use of masterplans and design codes to provide a framework for creating beautiful sustainable developments.

Ensuring access to a good range of health services as well as sport, leisure and recreational facilities, making a positive contribution to health and wellbeing of residents.

Issues including obesity affecting some areas of the district, and only just over half of South Staffordshire adults meet recommended levels of physical activity.
One in four adults are physically inactive in the district, similar to the national average.
Planning has an important role in facilitating healthy lifestyles changes, such as encouraging exercise.
Sport, leisure, and recreational facilities should be accessible to residents and be of a suitable quality to be attractive to users.
Active travel, such as cycling and walking, should be facilitated through scheme design and off-site financial contributions.
Key challenge is ensuring sufficient access to GP/health centres to accommodate residents from new developments.

Meeting the needs of children and young people, including the provision of good education and play spaces.

Issue of ensuring new developments incorporate play provision that parents and children in existing communities can access.
Education attainment in South Staffordshire for GCSEs is similar to England average however there are inequalities in attainment levels within the district.
Key challenge of ensuring there is adequate school provision to accommodate increased pupil numbers due to new development.

Reduction of crime and anti-social behaviour and fear of crime.

Planning for new development should include measures that limit crime and deter anti-social behaviour therefore promotion of natural surveillance and feeling of security for residents important.

Economic Prosperity - Issues and Challenges

(4) Table 4: Economic Prosperity – issues and challenges

Issue / Challenge

Explanation

Levels and types of growth needed to meet South Staffordshire's employment land needs and ensuring that local people have good access to a range of employment opportunities.

South Staffordshire is an attractive location for commercial development with a diverse range of small, medium, and large businesses and firms.
Key challenge of providing a mixed portfolio of employment in terms of quality, size and use classes.
Retaining existing businesses, diversifying the economy, creating more skilled jobs and increasing the retention of young, educated residents will strengthen the local economy and see local people have access to a range of employment opportunities.
Economic Development Needs Assessment (EDNA) 2024 identifies a pipeline of sites to meet our own needs and a potential contribution in meeting unmet needs of neighbouring authorities.
Regional need for more strategic employment identified through the West Midlands Strategic Employment Sites Study (2021).

Supporting the economies of adjoining areas and pressure to release land to meet a proportion of their unmet employment needs.

Significant proportion of South Staffordshire's population travels to work outside the district. The Black Country and other adjoining authorities' economies are an important source of employment for residents and an important factor in the prosperity of the district.
Over recent years South Staffordshire has aspired to provide more local jobs, reduce levels of out commuting and provide employment for our residents and those of neighbouring areas, such as through i54 South Staffordshire.
South Staffordshire EDNA (2022) identifies South Staffordshire as being in the same FEMA (Functional Economic Market Area) as Cannock Chase, Dudley, Stafford, Walsall and Wolverhampton. The Black Country FEMA has a significant unmet need for employment land for the period to 2041
As South Staffordshire is in the same FEMA as three of the Black Country authorities the Local Plan needs to consider South Staffordshire's role in meeting any cross-boundary needs.

Supporting the aims and ambitions of the Staffordshire and Stoke-on-Trent Local Enterprise Partnership (SSLEP).

Including expansion in large and small businesses in a number of priority sectors.
Incorporates development of advanced manufacturing industries in aerospace and automobile sectors and capitalising on supply chain opportunities from global businesses such as Jaguar Land Rover.

Managing the impact of West Midlands Interchange (WMI).

Ensuring a policy framework is in place to manage the local environmental impacts and pressure on local infrastructure as effectively as possible.

Supporting our existing employment sites, including strategic sites at i54 South Staffordshire, ROF Featherstone, Hilton Cross, Four Ashes and West Midlands Interchange.

Safeguarding delivery of strategic employment sites which provide important job opportunities for residents of South Staffordshire and neighbouring areas.
Inward investment opportunities should be fully harnessed at the strategic sites, including opportunities for further expansion of the sites where appropriate and feasible.

Supporting higher education attainment, the development of skills and access to training and employment opportunities

District is relatively prosperous - the number of those employed within the top 3 professional and managerial sectors exceeds national average and the number of adults with no qualifications below national average.
There are pockets of deprivation within district with higher levels of unemployment.
Supporting development of skills, access to education and local training opportunities are key issues for the Local Plan to ensure residents can benefit from economic growth.

Provide opportunities for sustainable rural economic growth whilst protecting the environment, including supporting farm diversification and tourism.

Need to diversify the rural economy whilst enabling farmers to continue to manage the rural landscape.
Farm complexes can offer scope for alternative local employment uses for residents that support the rural economy and reduce the need for travel.
Conversions of agricultural buildings to employment uses, such as tourism, are preferred to conversions to residential uses, which may be less sustainable.
Need to proactively support and encourage improvement of tourist facilities and attractions to promote South Staffordshire as a place to visit and as a base to access a wide range of tourist attractions within the West Midlands and beyond.

Ensuring local people have access to retail and a good range of essential community facilities and services, supporting the continued role of village and neighbourhood centres as a focus for delivery of these.

The larger villages in South Staffordshire contain a range of community facilities including retail centres, libraries, sport and recreation and serve smaller outlying villages and hamlets.
Local residents also rely on services provided within towns and cities outside of district to meet higher order needs.
Loss of facilities and services in smaller villages is an ongoing trend.
Protecting village shops and community facilities and providing accessible services to meet needs of all sectors of the community are key priorities.

Ensuring impact on the road network is fully considered during plan-making.

Important when considering growth options that impact on road network is fully considered and proposals limit impact on network and mitigation measures are secured where appropriate.
Understanding the effect of the M54/M6 link road.

Ensuring provision of suitable public transport services with appropriate facilities (such as adequate parking) at transport hubs.

Proximity to strategic road and rail links, particularly in north, connects the district to the West Midlands and beyond, attracting commuters and creating pressure on housing and employment.
West Coast Main Line railway runs through the northern part of the district between Wolverhampton and Stafford, stopping at Penkridge.
Rail services provided on Shrewsbury to Wolverhampton line, with stations at Codsall and Bilbrook.
Walsall to Rugeley line with station at Landywood (Great Wyrley).
Challenge for car and bicycle parking at all stations, with commuters parking on surrounding residential roads.
Parking an issue in some village centres for residents accessing shops and other services.
High level of car ownership and improving access to public and community transport for those without a car remains an issue.
Challenges around increasing cycle and footpath provision for leisure or commuting, including connecting to established routes.
Effective rural public transport services are key for ensuring people have sustainable access to facilities and employment opportunities inside and outside the district.

Improving access to suitable broadband and digital communication networks.

Access to digital networks and high-speed broadband remains inconsistent.
Home working is becoming an increasing feature in rural areas, which has been further accelerated as an effect of the Covid-19 pandemic.
The expansion of broadband internet and other technologies are important to support sustainable forms of employment and will help encourage the development of small and medium sized enterprises (SMEs) in the district.

The Natural and Built Environment - Issues and Challenges

Table 5: Natural and Built Environment – issues and challenges

Issue/Challenge

Explanation

Protecting the Green Belt and understanding which areas of South Staffordshire's Green Belt make the most contribution to the five national purposes of the Green Belt.

80% of South Staffordshire is designated Green Belt.
There is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated, although authorities may choose to review and alter Green Belt boundaries where exceptional circumstances are fully evidenced and justified.
The Black Country and South Staffordshire's Green Belt Study (2019) is a key piece of evidence when considering this issue, identifying the least to the most sensitive parcels of Green Belt.

Protecting sensitive areas of Open Countryside beyond the Green Belt.

Around 14% of district is Open Countryside.
Much of the character of countryside beyond the Green Belt is of high landscape quality, ecological, historical, archaeological, agricultural and recreational value.
Protecting the most sensitive areas of Open Countryside is a key issue.

Understanding South Staffordshire's landscape character and areas sensitive to change.

Landscape character and structure of South Staffordshire has changed significantly over time, including the removal of trees and hedgerows and increased agricultural activity.
Key issue for Local Plan is understanding landscape character and where possible, protecting the most sensitive areas.

Protecting, conserving and enhancing the district's rich natural environment and ecological assets

Varied landscape in the district and home to a rich biodiversity providing many types of habitats including Special Areas of Conservation (SACs), Special Protection Areas (SPAs), National Nature Reserve (NNR), Local Nature Reserves (LNRs), Sites of Biological Importance (SBIs) and Sites of Special Scientific Interest (SSSIs).
Western fringe of Cannock Chase Area of Outstanding Natural Beauty (AONB) lies within the district and there is a statutory obligation to protect and manage the area. Within the AONB lies an area of lowland heath, protected by SAC status.
Agricultural land within the district ranges from best quality grade 1 down to grade 3b. The best and most versatile agricultural land is classified as grades 1 and 2 & 3a.
Conserving and protecting valued finite resources is a key issue to consider when planning new development.
Hatherton Canal Restoration Project could contribute to tourism and flood risk alleviation.

Ensuring sufficient good quality public open spaces and green infrastructure is available for residents and visitors to the district.

Extensive areas of attractive open land within the district for public recreational uses.
These public open spaces provide informal leisure opportunities as well as enjoyment of the natural environment.
Key challenge of conserving and protecting open space for use by generations to come.

Protecting and conserving the district's historic asset.

Over 640 listed buildings and 19 Conservation Areas within the district with many other locally important buildings and structures.
The district's archaeological resource is rich and varied and includes scheduled ancient monuments.
Ensuring development is sensitive to these irreplaceable assets and their settings and appropriate mitigation is applied where harm is unavoidable is a key challenge.

Planning for the impact of climate change and protecting existing and new communities from flood risk through flood resilience measures.

South Staffordshire Council declared a climate emergency in 2019.
Major challenge of ensuring new development is sustainable, addressing the implications of climate change and the reduction of Co2 emissions, encouraging renewable energy and the promotion of energy efficiency.
Challenge of ensuring a sufficient amount of electric vehicle charging points are provided throughout the district, with increased demand and in preparation for the ban on the sale of petrol and diesel cars.
South Staffordshire is covered by two river catchments: Smestow Brook within the River Severn Catchment; and the River Penk within the Trent catchment. Many additional tributaries flow into the main rivers contributing to the flood risk within the district. Penkridge, Wombourne and Kinver, and a number of other settlements, are affected by fluvial flooding.
Surface water flooding an issue in certain hotspots. The Lead Local Flood Authority identifies Brewood as one of the top 10 'rural' areas and Perton one of the top 10 'urban' areas with properties at risk from surface water and small water courses in Staffordshire.
Key challenge in ensuring future growth does not exacerbate these issues and where possible can contribute to reduction in flood risk.

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