Publication Plan April 2024

5. Development Strategy

Green Belt

(8) 5.1 The distinctive character of South Staffordshire is directly influenced by the fact that approximately 80% of the district is Green Belt. This contributes to the district's rural character and helps distinguish the district from neighbouring urban areas such as the Black Country. Protecting the Green Belt from unplanned development as far as possible is therefore a key objective (Strategic Objective 1) of the Local Plan.

(2) 5.2 National Policy confirms that there is no requirement for Green Belt boundaries to be reviewed or changed when Local Plans are being prepared and that it is within authorities' gift to choose to review Green Belt boundaries through the Local Plan where they feel that exceptional circumstances for doing so exist and these can be fully evidenced and justified. The Local Plan review does confirm limited Green Belt boundary amendments and therefore a policy detailing where the council's development strategy requires such Green Belt amendments is necessary, as well as ensuring a strong policy framework for resisting planning applications that would result in inappropriate development in the Green Belt.

(7) 5.3 Wherever possible, the council has looked to allocate suitable brownfield sites first and foremost, to reduce pressure on the district's Green Belt, however these are very limited due to the largely rural nature of the district. Most large-scale site options on brownfield land are either in isolated rural locations or form part of the district's employment land supply and need to be retained to ensure the district can meet its employment land needs. Previous Local Plans also identified large brownfield sites in the Green Belt (known as major developed sites in the Green Belt) but all of these have now been developed. There is an area of brownfield land adjacent to the south-western edge of Wombourne, which is mainly occupied by the car storage company Copart. This site has been assessed as an option for housing, however it is not proposed for allocation due to uncertainty over the relocation of the existing business. Elsewhere, brownfield opportunities in sustainable locations tend to be small scale (e.g. garage sites, small infill plots, changes of use under permitted development) and if unconstrained have historically come forward through the Development Management process and outside of the Local Plan, as the principle of such schemes is generally considered acceptable. The council has included a windfall allowance for these smaller site opportunities within the housing trajectory to ensure this is accounted for in future supply.

5.4 In order to deliver the vision for the district over the plan period it is essential that there is a strong policy position for protecting the Green Belt and this is set out in Policy DS1 below.

Green Belt compensatory improvements

5.5 The NPPF requires local plans releasing Green Belt to set out ways in which the impact of altering Green Belt boundaries can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. It is therefore important that this Local Plan provides a mechanism to secure such improvements for any sites released from the Green Belt.

5.6 The district has a large rural area enclosing its numerous villages, the majority of which is covered by Green Belt. There are therefore a significant number of options available to sites in improving the environmental quality and accessibility of remaining Green Belt, many of which are set out in the district's Open Space Strategy and Nature Recovery Network mapping. Policy DS2 intends to offer a mechanism for delivering these improvements, offering a stepped approach to ensure that any compensatory improvements offer the greatest benefit to communities in closest proximity to land released from the Green Belt where possible.

Open Countryside

(1) 5.7 Equally important to maintaining the special character of South Staffordshire is having a policy framework for protecting the Open Countryside located to the northwest of the district beyond the Green Belt. Whilst not having the same level of national protection as Green Belt designation, the land designated in the Local Plan as Open Countryside is still much valued countryside particularly for its landscape and ecological qualities. It is therefore important as part of the district's wider development strategy, that a clear policy approach on what type of development is explicitly permitted in the Open Countryside is set out in this Local Plan. Equally, it will need to set out what policy factors proposals will need to be consistent with for development in the Open Countryside to be acceptable in principle.

Housing

The district's housing needs

(1) 5.8 The government requires that Local Plans cover a 15 year period post adoption of the plan and will cover the period 2023-2041. The district's future housing need is then calculated using the government's standard method. This currently requires the district to deliver a minimum annual average of 227 dwellings per annum starting from the 2023/24 monitoring year until the end of the plan period (2041). This equates to 4086 new homes over the plan period.

Unmet housing needs from the wider housing market area

(7) 5.9 In addition to the district's own housing needs, there is emerging evidence of unmet needs from the wider GBBCHMA, within which South Staffordshire is located. The two most significant sources of potential unmet needs are currently Birmingham City and the four Black Country authorities. The adopted Birmingham Development Plan^[1] and urban capacity evidence from the Black Country^[2] authorities suggests that a significant unmet need is arising across the GBBCHMA, driven by limited housing land in these urban areas.

5.10 Recognising the existing and emerging shortfalls, the fourteen GBBCHMA local authorities^[3] jointly prepared the GBBCHMA Strategic Growth Study in 2018. This drew together existing evidence on housing supply and need across the entire housing market area, estimating that at that time the unmet needs of the GBBCHMA sat at around 28,000 dwellings up to 2031, rising to nearly 61,000 dwellings by 2036. Subsequently consultation by the Black Country authorities in 2021 and Birmingham City Council in 2022 indicated a potential shortfall of 28,239 and 78,415 homes respectively, indicating that the shortfall is likely increasing.

5.11 In light of unmet needs, the 2018 Strategic Growth Study recommended a series of strategic growth locations across the housing market area, including a number of locations in South Staffordshire. Using this evidence, it was proposed to test an additional contribution of 4,000 dwellings to the unmet housing needs of the GBBCHMA in the council's Local Plan review, based on the scale of growth implied in the district by the strategic locations identified in the GBBCHMA Strategic Growth Study. Alternative levels of growth were tested through the Sustainability Appraisal process.

Spatial strategy for housing

(7) 5.12 The district's proposed 4000 contribution to wider unmet housing needs was included in the superseded November 2022 Publication Plan (Regulation 19) consultation following testing through plan preparation. However, following proposed changes to the NPPF published in December 2022, progress on the previous iteration of the plan was paused. In December 2023 the updated NPPF was published and confirmed that there is no requirement for Green Belt boundaries to be reviewed or changed when Local Plans are being prepared and that it is within authorities' gift to choose to review Green Belt boundaries through the Local Plan where they feel that exceptional circumstances for doing so exist and these can be fully evidenced and justified. Furthermore, the delay to preparation of the Local Plan means that the Strategic Growth Study (2018) on which the previous 4,000 home contribution was based is no longer up to date. Proposals for updated evidence considering the housing market area shortfalls and potential growth locations are currently in discussion across the West Midlands Development Needs Group and South Staffordshire is committed to participating in updating the evidence base and considering its findings through future plan-making.

5.13 Given the change in circumstances, the council tested further spatial strategy options considering the ways in which housing growth could be distributed across the district, as detailed in the council's Spatial Housing Strategy Topic Paper 2024. Unlike the majority of previous options tested that sought to deliver a 4000 home contribution derived from the 2018 Strategic Growth Study, the new options tested (Options H and I) considered different levels of growth based upon capacity led approaches that further limited Green Belt release compared to other options tested, and with a greater focus on the district's most sustainable locations.

(3) 5.14 Having considered all of these different approaches previously tested in earlier iterations of the Local Plan, and their relative merits in the round, the council's preferred approach is Spatial Option I - a capacity-led approach focusing growth to sustainable non-Green Belt sites and limited Green Belt development in Tier 1 settlements well served by public transport.

5.15 The main focus of the growth under this preferred strategy is on non-Green Belt land at suitable existing safeguarded land sites, sustainable Open Countryside sites, and limited brownfield sites available within settlement boundaries of sustainable settlements. The release of land within the wider Open Countryside has regard to "the consequences for sustainable development of channelling development … towards locations beyond the outer Green Belt boundary", in accordance with the NPPF. New allocations in the Open Countryside are therefore focused into suitable and potentially deliverable land adjacent to Tier 1 settlements and neighbouring towns.

(2) 5.16 Spatial Option I does not avoid Green Belt release, despite national policy allowing for such an approach and indicating any Green Belt release is solely the choice of the council. However, Spatial Option I does propose to limit Green Belt allocations to suitable sites in areas of the district best served by public transport, which the NPPF specifies are to be given first consideration for Green Belt release. Local evidence shows the district's Tier 1 settlements are the areas best served by public transport in the district, particularly where these transport links offer sustainable commuting patterns into the neighbouring Black Country and Birmingham conurbation. Given this, at the strategic level, it is concluded that exceptional circumstances exist to release Green Belt for housing at the Tier 1 settlements well served by public transport. This is expanded on further in the council's Green Belt Exceptional Circumstances Topic Paper 2024.

5.17 In summary Spatial Option I represents a sound and sustainable strategy for accommodating the required amount of housing in the district by 2041 that best balances the district's growth opportunities with national policy and the district's constraints. The strategy recognises the pressing need to deliver additional housing, whilst balancing this against the constraint that Green Belt land and sustainability factors places on the plan's ability to deliver housing growth.

Site Assessment

5.18 Previous spatial strategy options tested through plan preparation sought to find sites to meet a 'top down' housing requirement (i.e. own needs + 4000 homes). However, under the preferred strategy (Option I) based on a capacity led approach of limiting Green Belt to the most sustainable settlements, the housing target is derived through the determination of the most sustainable housing sites through the council's Housing Site Assessment Topic Paper 2024.

5.19 These site assessments reflect the preferred spatial strategy of proposing sustainable non-Green Belt development (i.e. sustainable Open Countryside sites, safeguarded land and brownfield sites) and limited Green Belt release at suitable sites at the Tier 1 settlement, where these sites are free from significant constraints and are in walking distance of these settlements train stations. However, these site assessments also include assessment of reasonable alternative Green Belt site options in other areas of the district (i.e. Tier 2-4 settlements and areas of search for urban extensions). This ensures that the site-specific merits of reasonable alternatives to the council's preferred strategy have been fully considered before final decisions are made on proposed allocations.

5.20 Following the site assessment process, the council has concluded that the exceptional circumstances for Green Belt boundary changes exist at the site-specific level for the Green Belt allocations at the Tier 1 settlements, based on the strategic approach taken and their individual merits, as they are assessed as the most suitable options. Exceptional circumstances do not exist for other reasonable alternative Green Belt site options assessed through the site assessment topic paper.

The housing target

(5) 5.21 The outcome of this site assessment process confirmed that there were suitable sites available to deliver the spatial strategy (spatial option I). The capacity of these sites is sufficient to meet our own need plus a proportionate 640 dwelling contribution towards unmet needs of the GBBCHMA. The specific elements of the housing target are set out below:

(2) Table 7: Housing Target

5.22 The council's final preferred strategy seeks to deliver a balance of housing sites across the district, balancing the need for housing growth early in the plan period and for 10% of housing growth to be delivered on sites of less than 1 hectare, with the need for larger sites to deliver growth later in the plan period. The distribution of housing by settlement/area is set out below.

(10) Table 8: How housing growth will be distributed across the district

(1) 5.23 In total, this distribution of growth exceeds the minimum amount of land release required to meet the district's 4726 dwellings housing target. This will help the plan to meet the national policy requirement to respond to changing circumstances in the plan period and demonstrate plan flexibility. The housing numbers for each village/broad location are influenced by the capacity of sites considered suitable for allocation, as determined through the housing site assessment topic paper.

5.24 The sections that follow set out the strategy for delivering our housing growth in different areas of the district. The diagrams and descriptions that follow summarise only the locations that will be the focus for housing allocations. They do not include existing planning permissions within the district, which make up the remainder of the housing growth for the plan period up to 2041, as set out in Table 8.

Housing growth in Locality 1

5.25 The diagram below summarises where new housing growth will be delivered in Locality 1 (the north of the district).

Penkridge

5.26 Housing growth in this part of the district will be driven by a large-scale extension in the Open Countryside to the north of Penkridge. This larger scale development will deliver significant housing growth alongside a mix of other uses, including a new first school, local retail and a country park. This recognises the recommendations for a large-scale extension north of Penkridge in the GBBCHMA Strategic Growth Study, the non-Green Belt land available in this area of the village and the greater level of services and facilities in Penkridge compared to other villages in the district, including access to a railway station. The council has also proposed an additional amount of limited Green Belt release to the south of the village, recognising Penkridge's status as a Tier 1 settlement and the sustainability of this location compared to other areas of the district.

5.27 The delivery of the existing non-Green Belt safeguarded land in the village will also be brought forward, to ensure that sustainable non-Green Belt sites in the district are delivered.

Southern Edge of Stafford (A34 corridor)

(2) 5.28 This location will not be a focus for larger-scale housing growth. This recognises the sensitive landscape and potential highways concerns that larger scale growth in this location could cause, as well as the lack of unmet housing needs in Stafford and the location's remoteness from areas where unmet needs are generated. Instead, a smaller scale extension to the adjacent town of Stafford will be delivered in this area, which will ensure the sustainable delivery of non-Green Belt housing land in the district.

Huntington

5.29 Housing growth in the village will be limited to existing planning permissions and the safeguarded land previously identified adjacent to the village. This approach recognises that Huntington is a Tier 2 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This also recognises the relative level of services and facilities in Huntington compared to some other settlements in the district and potential for impacts on the nearby Cannock Chase AONB.

Housing growth in Locality 2

5.30 The diagram below summarises where new housing growth will be delivered in Locality 2 (the north-west of the district).

Brewood

(5) 5.31 Housing growth in the village will be limited to existing planning permissions and the safeguarded land previously identified adjacent to the village. This approach recognises that Brewood is a Tier 2 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This also recognises the historic character of the village and relative level of services and facilities in Brewood compared to some other settlements in the district.

Coven

5.32 Housing growth in the village will be limited to existing planning permissions and the delivery of the safeguarded land adjacent to the village. This approach recognises that Coven is a Tier 3 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This also recognises the limited level of services and facilities in Coven compared to some other settlements in the district.

Wheaton Aston

5.33 Housing growth in the village will be delivered through limited land release to deliver an allocation of an existing allocated site to the south of the village. This approach recognises the village's relatively limited services and facilities, concerns raised by a statutory body and a lack of additional suitable non Green Belt options when considering sites through the site assessment process.

Housing growth in Locality 3

5.34 The diagram below summarises where new housing growth will be delivered in Locality 3 (the north-east of the district).

Cheslyn Hay/Great Wyrley

(1) 5.35 New housing growth in this area will be increased through the delivery of new allocations, which will be directed to less constrained site options around the two villages. These will be delivered alongside the existing allocated and safeguarded housing sites dispersed around the two villages.

5.36 The delivery of new housing allocations in Cheslyn Hay/Great Wyrley recognises the greater level of services and facilities to support local growth in these villages and the potential for additional allocations to be made to address the acute local need for specialist elderly housing in this location. Unlike other Tier 1 settlements (Penkridge & Codsall/Bilbrook), growth in Cheslyn Hay/ Great Wyrley is tempered by the site-specific constraints affecting numerous site options in this area.

Featherstone & Shareshill

5.37 Housing growth around the village will be limited to existing planning permissions, and the delivery of the safeguarded land adjacent to Featherstone. Green Belt release is not proposed in this area, recognising the villages Tier 3 status and that this would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements.

Housing growth in Locality 4

5.38 The diagram below summarises where new housing growth will be delivered in Locality 4 (the central area of the district).

Codsall/Bilbrook

(2) 5.39 Housing growth in this part of the district will be largely focused on Codsall/Bilbrook. Increased allocations around the village will deliver housing growth alongside a mix of other uses, including a new first school, local retail and strategic green infrastructure. This recognises the recommendations for proportionate dispersal around Codsall/Bilbrook in the GBBCHMA Strategic Growth Study and the greater level of services and facilities in this area compared to other villages in the district, including access to two railway stations. The level of growth to be delivered is also aligned to the level of growth advised by the Education Authority to deliver an appropriately sized First School in this location whilst avoiding creating capacity issues at the Middle and High School level. It also offers opportunities to deliver additional station car parking at Codsall.

Perton

5.40 Housing growth in the village will be limited to existing planning permissions and the safeguarded land previously identified adjacent to the village, with no additional Green Belt release proposed. This approach recognises that Perton is a Tier 2 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. It is also recognised that highways concerns and proximity to education are also factors that limit suitable site options.

Pattingham

(1) 5.41 Housing growth in the village will be delivered through the delivery of the safeguarded land identified adjacent to the village, with no additional Green Belt release proposed. This approach recognises that Pattingham is a Tier 3 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This also recognises the limited level of services and facilities in Pattingham compared to some other settlements in the district.

Housing growth in Locality 5

5.42 The diagram below summarises where new housing growth will be delivered in Locality 5 (the south of the district).

Wombourne

(1) 5.43 Housing growth in the village will be delivered through the delivery of the safeguarded land identified adjacent to the village, with no additional Green Belt release proposed. This approach recognises that Wombourne is a Tier 2 settlement and therefore Green Belt release would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This recognises that unlike the Tier 1 settlements, Wombourne does not have rail access in walking distance that can offer greater sustainable access to employment and services.

Kinver

5.44 Housing growth in the village will be delivered through the delivery of the safeguarded land identified adjacent to the village, with no additional Green Belt release proposed. This approach recognises that Kinver is a Tier 2 settlement and therefore Green Belt release here would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements. This also recognises the historic character of the village and relative level of services and facilities in Kinver compared to some other settlements in the district.

Swindon

5.45 Housing growth in the village will be delivered through a small existing site allocation. The safeguarded land in the village is not proposed for allocation as following its re-examination through our housing site assessment topic paper, is not considered suitable to accommodate a well designed scheme layout. This approach also recognises that Swindon is a Tier 3 settlement and therefore Green Belt release here would not align with the spatial strategy which focuses Green Belt release only on the most sustainable Tier 1 settlements.

Gypsies and Travellers

(2) 5.46 It is also a requirement of the Local Plan to assess and plan to meet the housing needs of different groups of the community, including Gypsies, Travellers and Travelling Showpeople. The government's Planning Policy for Traveller Sites (PPTS) 2015 details how travellers' housing needs should be assessed for those covered by the definition in Annex 1 of the 2012 PPTS. The focus of Gypsy, Traveller and Travelling Showpeople policies in this plan is therefore to make provision for those traveller families that meet the definition, with the housing needs of those not falling within this definition met through general needs housing policies.

5.47 In line with national policy, the needs for families have been assessed through the Gypsy and Traveller Accommodation Assessment (GTAA) update 2024 and Pitch Deliverability Study (2021). This evidence demonstrates that need is being generated by existing families. Some of this is current need as a result of being on an unauthorised pitch and overcrowding. However, the vast majority of need is generated through household formation derived from the demographics of residents and teenagers on sites needing a pitch of their own within the next five years.

5.48 Due to this, the council's strategy for new Gypsy, Traveller and Travelling Showperson provision will be to continue to deliver privately owned sites/pitches to meet the needs of existing families. The evidence supports an approach therefore of looking to allocate existing temporary or unauthorised sites to permanent (subject to other planning considerations) and looking to intensify and extend existing sites to meet identified family need, rather than allocating wholly new sites that may have been suggested by landowners without any connection or agreement to meet local needs, and where deliverability is more uncertain. This approach will see the continued concentration of traveller pitches where sites have historically been consented on appeal in the north of the district predominantly along the A449 and A5 transport corridors. It is currently not possible to test an alternative distribution of traveller pitches that would disperse pitches more widely across the district due to a lack of deliverable alternative pitch options elsewhere in the district.

5.49 The GTAA update (2024) has identified a need for 142 pitches to 2042 from families that meet the definition of a Gypsy and Traveller. However, assuming that 84% of 'undetermined household' (where interviews were not secured) would need a pitch, then this requirement could rise to 162 pitches up to 2042. The GTAA update identified a 5-year need (2024-2028) of 92 pitches.

Employment

The district's employment needs

(2) 5.50 It is the role of the Local Plan to consider the district's employment needs and plan for employment growth over the plan period, taking account of the evidence of need and the existing pipeline of employment land. A partial update of the Economic Development Needs Assessment (EDNA) was published in 2024 to inform the emerging Local Plan and was an update to a previous EDNA published in 2022.

5.51 The EDNA 2022 and 2024 update, in accordance with the PPG, analysed the socio-economic landscape of the district (including around employment, business development, demographics and labour markets) and concluded that the local economy in South Staffordshire was healthy and was still benefiting from investment particularly as a result of strategic site delivery in the district. The EDNA also analysed which authorities South Staffordshire had the strongest economic links with, and from this identified a Functional Economic Market Area (FEMA) comprising of South Staffordshire, Cannock, Dudley, Stafford, Walsall and Wolverhampton.

5.52 The study's main focus was to draw together the market intelligence, economic forecasts and other relevant data to conclude on the employment land needs of the district up until 2041. The study included detailed analysis of employment projections on a sector-by-sector basis utilising data from the three main forecasting houses. The study adjusted the Experian forecast to arrive at a 'LEP based Growth Scenario' and following a series of further adjustments (e.g. building in plan flexibility such as projected employment losses and an increased margin for frictional vacancy), arrived at an objectively assessed employment land need figure of 62.4ha up to 2041.

5.53 The study also undertook analysis on the impact of West Midlands Interchange (WMI) on the district, including on the demand for employment, as well as considering the proportion of WMI that could contribute towards the supply of employment land for South Staffordshire given the strategic nature of the site. This concluded that 18.8ha of WMI would contribute towards the district's supply of employment land to meet the projected demand.

(1) 5.54 The EDNA undertook further analysis by examining the supply/demand balance for the district, in order to inform the amount of employment land that would need to be allocated through the Local Plan. It considered the supply of employment land at the base date of April 2023 (circa 90ha, excluding WMI)) and explored how this would likely be split between strategic and non-strategic employment land supply. Following consideration of the supply/demand balance specifically for strategic sites, it was concluded what proportion of the surplus strategic employment land could be attributed to providing towards sub regional supply and what proportion could be considered providing towards South Staffordshire's supply, informed by the labour demand forecasts. It concluded that in terms of strategic employment land, 27.6ha of surplus land (excluding WMI) could reasonably be attributed to cross boundary unmet needs in the Black Country FEMA. This increases further to 45.2ha when factoring in an additional strategic allocation at M6 Junction 13, Dunston (17.6ha) that boosts the supply pipeline to ensure plan flexibility and that the pipeline of sites more closely reflect recent take up. Meanwhile, the supply-demand balancing exercise that could be attributed to South Staffordshire, taking on board both strategic and non-strategic employment land, concluded there is sufficient supply to meet the council's employment needs based on South Staffordshire's forecast labour demand, with supply/demand broadly in balance. Overall, the district can meet its own employment land needs, together with making a proportionate contribution to unmet needs in the Black Country.

Unmet employment needs from the wider functional economic area

(2) 5.55 National planning practice guidance requires authorities consider the 'most appropriate geography' to prepare policies for employment and require authorities to define their 'best fit' Functional Economic Market Area. Given this, it is over the South Staffordshire FEMA geography that it is considered the most appropriate basis for considering our role in meeting cross boundary employment needs.

5.56 Of the other authorities within the South Staffordshire FEMA, Cannock Chase District Council (CCDC) are also in the process of preparing their new Local Plan. In February 2024 they consulted on their Pre-Submission (Regulation 19) consultation which indicated that up to 74ha of employment land will be provided over the plan period up to 2040 to meet Cannock's employment needs. There is currently no indication that Cannock are unable to meet this need within their administrative boundary, with the exception being confirmation that they require 10ha from WMI. Stafford Brough consulted on their Preferred Options document in October 2022 which confirmed around 156ha of employment land supply over their emerging plan period. There is no indication to date that Stafford will not be able to meet its own development needs.

5.57 The Black Country authorities of Dudley, Sandwell and Wolverhampton are also currently preparing their Local Plans and their employment evidence has identified a self-contained Black Country FEMA covering the four Black Country authorities, albeit with strong and moderate links to a number of neighbouring authorities, including strong links with South Staffordshire. The Black Country authorities latest Employment Land Needs Assessment (October 2023) identifies a shortfall of 153ha of employment land. That study recommends that the Black Country local authorities should continue to engage through the Duty to Cooperate with neighbouring authorities that have a strong or moderate functional economic relationship with the Black Country to consider this shortfall.

5.58 Site assessment of employment site options (existing sites with available land parcels and new site options) have been undertaken, which has re-confirmed that those sites assessed as part of the supply/demand exercise in the EDNA update (2024) and that did not have full or reserved matters planning permission at the base date of April 2023 are suitable for allocation. As such, the findings of the supply/demand exercise and the conclusion in the EDNA update (2024) that 27.6ha (excluding WMI and M6 Junction 13, Dunston) of strategic employment land is available for unmet cross boundary needs has been confirmed. In addition, WMI represents a significant supply of employment land within the district that will come forward within the plan period. As confirmed through the EDNA 2022 and 2024 update, South Staffordshire requires 18.8ha of WMI within our supply to meet our forecast labour demand, leaving a considerable proportion of the site available to meet cross boundary needs. The Black Country authorities commissioned a report considering the proportion of WMI that could be considered towards their needs based upon projected population change. This identified a minimum 67ha 'claim' from WMI for the Black Country authorities, which when taken alongside the 45.2ha^[5] surplus of strategic employment land means that 112.2ha of employment land in South Staffordshire is available for strategic cross boundary unmet needs from the Black Country (circa 153ha shortfall), subject to agreement through a Statement of Common Ground.

Strategic Employment Sites

5.59 The issue of strategic employment delivery across the wider West Midlands region has started to be explored most recently through the West Midlands Strategic Employment Sites Study (WMSESS) 2021. The WMSESS 2021 was commissioned by Staffordshire County Council, Black Country LEP, Greater Birmingham and Solihull LEP and Coventry and Warwickshire LEP with local planning authorities in the region not directly involved in the study. In this context, the study's primary focus was around engagement with the private sector to gauge market demand for new strategic employment sites, to examine recent take up, and to identify broad areas of market demand. It did not provide a full assessment of need (in terms of floorspace) that could be attributable at across the study area, however it did conclude that there was considerable demand for strategic employment site opportunities across the region and identified a number of broad locations around key junctions, including junctions on the M6 and M54 in South Staffordshire.

Development Needs & Spatial Strategy to 2041

5.60 The development needs set out in Policy DS4, and spatial strategy set out in Policy DS5, describe how the district will meet its housing, Gypsy and Travellers and employment needs up to 2041; whilst sensitively managing other uses such as retail, agriculture and tourism. These are key strategic policies that set the framework for delivering growth through the Local Plan and provide details of how windfall developments will be considered that are proposed outside the Local Plan allocations process.

5.61 The spatial strategy and distribution the growth outlined in Policy DS4 is based upon a capacity led approach that focuses the majority of growth on the district's most sustainable settlements, with Green Belt release limited to these Tier 1 settlements. Non-Green Belt options have been maximised in line with national policy requirements with the limited number of suitable and deliverable brownfield site options in the district proposed for allocation as well as the reassessment of existing safeguarded land sites to confirm their suitability for allocation. Suitable sites in sustainable locations in the Open Countryside to the north of district are allocated, specifically adjacent the sustainable settlements of Penkridge and neighbouring Stafford. The spatial strategy also facilitates the delivery of key infrastructure where opportunities are presented (e.g. a new First School at Bilbrook).

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