3.6

Object

Representation ID: 4343

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Cooperation between the local authorities which form the South Staffordshire Functional Economic Market Area (FEMA) is essential to ensuring an appropriate supply of land to address future needs. An agreed Duty to Cooperate Statement of Common Ground is required for the South Staffordshire FEMA. This should confirm the requirements of the FEMA local authorities and Sandwell, following the termination of the joint Black Country Plan preparation. Without a full understanding of the implications of this on the requirements of the FEMA authorities and wider West Midlands, the employment land requirements for SSDC cannot be confirmed.

Object

Representation ID: 4372

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We have failed to find evidence to show the reasoning for the choice of the 'magic number' of 4000 additional homes and that the calculation of the scale and distribution of the 'overspill' from the Greater Birmingham area has been agreed with all of South Staffordshire's neighbouring Councils in Statements of Common Ground (or in some other form) and with the authorities in the Greater Birmingham Housing Market Area.

We have not found evidence that the Duty to Co-operate with all neighbouring authorities has been met in respect of the whole plan, particularly Staffordshire County Council in relation to education and highways and Wolverhampton City Council also in relation to education and highways.

Object

Representation ID: 4488

Received: 22/12/2022

Respondent: Seddon Homes

Agent: WSP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

Within para 3.6 there is no mention as to how South Staffordshire has considered the potential for any cross-boundary sites with Stafford. There needs to be an acceptance in the emerging Local Plan that cross-boundary sites exist and these need to be identified and allocated appropriately to ensure consistency. It is important that the part of site 034 within South Staffordshire is also allocated for housing to enable the entire site to come forward. For the Duty to Cooperate to be met, there needs to be consideration and an acknowledgement of cross-boundary sites, such as Ashflats, Stafford.

Comment

Representation ID: 4732

Received: 23/12/2022

Respondent: National Highways

National Highways has engaged with Local Planning Authorities to develop and agree a Statement of Common ground to summarise the ongoing discussions and co-operation between South Staffordshire Councils and National Highways. It includes details of how the Councils have responded positively to comments and representations made by National Highways as part of the development plan review process.

Comment

Representation ID: 4896

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Comment

Representation ID: 4900

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

It is welcomed that the LPR acknowledges from the outset and at paragraph 3.6-3.7, the opportunities section of Table 2 SWOT analysis, and the strategic objectives, and a theme throughout the plan, that unmet housing needs from the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA) is a ‘key cross boundary issue’ to be addressed through the plan.

Object

Representation ID: 4958

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

The HMA SOCG does not confirm that any local authority member of the GBBCHMA as being signatories to the SOCG in its current form. Given that all local plans moving forward (either recently adopted or under review) will be planning beyond 2031, the lack of an agreed position on how the unmet need will be accommodated within the HMA and the scale of the shortfall post-2031 is a significant failing in the process of cooperation across the HMA to date.

Paragraph 7.2 of the Duty to Co-operate Topic Paper points to the need for an ‘urgent review’ of the current evidence base, including the SGS. However, there is no timetable for when this evidence base will commence or be completed. This represents a clear and obvious delay in the process of addressing the unmet needs of the HMA with no clarity on when this is likely to be concluded. This demonstrates that meaningful progress it not being made on addressing this strategic matter, and which is further undermined given the lack of signatories to the draft SOCG.

Paragraph 7.4 of the DTC Topic Paper suggests that additional Strategic Growth Locations may be needed to meet any ‘residual unmet need’ This ignores the fact that other locations may be suitable to address any emerging shortfall, notably sites located on the edge of settlements in close proximity to where the unmet need arises from.Therefore, in order to reduce the delays, and to reflect the stage the SSLP has now reached, a more timely, pragmatic, and effective approach would be to focus the search for additional sites to address the unmet need on those settlements in the South Staffordshire that are well-located in relation to where the unmet need arises from, and which are locations where development would be consistent with the spatial development strategy. This includes Featherstone, which is well-located close to Wolverhampton. The Land east of Brookhouse Lane, Featherstone represents an obvious option.

Given that no substantive progress or agreements have been made, RPS does not consider that the Duty has been met at this time.

Object

Representation ID: 5026

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

South Staffs is not affected by National park designations, AONB designations, the Water Directive and phosphate nutrient issues, circa 80% of its administrative area lies within the West Midlands Green Belt – however, it is recognised that in order to accommodate a proportion of the GBBCHMA unmet need (even sensibly located close to the Black Country boundaries), South Staffs has no choice but to allocate sites (both for its own needs and those of the GBBCHMA) within the Green Belt.
In this context, whilst it is commendable that the Council is still proposing to accommodate some 4,000 houses of unmet need, and that, as the Council, says at paragraph 5.6 of the Topic Paper and paragraph 5.16 of the Local Plan, there has been broad support from the other authorities for this, it does not negate the fact that the 4,000 is based on earlier study assumptions, with no consensus on the overall shortfall of provision within the GBBCHMA. Vistry is supportive of the principle and sentiment, but not necessarily the level of provision. This is because there is no certainty that the quantum of housing for which the Council is planning is actually sufficient.
Furthermore, it is important to highlight that the level of collaboration with other GBBCHMA authorities to date, still falls short of the requirements of the DTC as set out in both the NPPF and PPG. The reality is that very little has actually changed since the publication of the Regulation 18 Plan in 2021. Paragraph 27 of the NPPF requires the SOCG to be agreed, to be produced and publicly made available. This is still outstanding and therefore, Vistry consider that the Plan is unsound on the basis that it is not ‘positively prepared.