Publication Plan November 2022

3. What does the Local Plan need to consider?

National context

National requirements for plan-making

(1)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.

(1)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)3.5 South Staffordshire does not currently have any adopted Neighbourhood Plans in its area; however, Kinver, Codsall, Bilbrook and Penkridge Parishes have been designated Neighbourhood Plan areas and are currently undertaking scoping with a view to 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

(8)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 is a key cross boundary issue to be addressed with neighbouring authorities (including South Staffordshire's role in meeting a proportion of the shortfall) through plan preparation.

(2)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. Agreement 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

(38)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)

(22)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)

(4)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

(6)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:

Table 2: SWOT analysis

Homes and Communities - Issues and Challenges

Table 3: Homes & Communities – issues and challenges

(1)Economic Prosperity - Issues and Challenges

Table 4: Economic Prosperity – issues and challenges

(4)The Natural and Built Environment - Issues and Challenges

Table 5: Natural and Built Environment – issues and challenges