Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 583

Received: 21/12/2023

Respondent: South Staffordshire Council

The strategy identifies a Growth Network comprising urban centres and corridors as the principal focus for future growth, maximising the effective reuse of land in accordance with national policy priorities. Though a housing shortfall has been identified the Draft Plan has not sought to consider amendments to existing Green Belt boundaries. This approach reflects the recent changes to the National Planning Policy Framework (NPPF) which now states that there is no requirement for Green Belt boundary alterations when plans are being updated or reviewed though authorities may choose to make such boundary amendments.

Comment

Representation ID: 584

Received: 21/12/2023

Respondent: South Staffordshire Council

Housing Provision
The standard method currently calculates a total future housing requirement figure of 11,954 dwellings across the plan period (2023-2041). Dudley currently anticipates being able to deliver 10,876 dwellings across the plan period, leaving a shortfall of 1,078 dwellings. It is the stated intention of DMBC to export this shortfall through Duty to Co-operate arrangements. Given that Dudley is situated within a Housing Market Area (HMA) geography primarily composed of net exporting metropolitan authorities and rural shire authorities comprising significant amounts of green belt it is unclear how readily this surplus requirement will be absorbed through duty to cooperate arrangements within the HMA. South Staffordshire considers that Dudley should seek to maximise delivery within its own administrative boundaries. As the plan making process proceeds forwards, continued efforts to increase capacity through site regeneration, housing renewal schemes, increased densification and the release of town centre sites should be ongoing with the aim of reducing the net requirement to be exported to other authorities.

Comment

Representation ID: 585

Received: 21/12/2023

Respondent: South Staffordshire Council

Gypsies, Travellers and Travelling Showpeople
South Staffordshire Council (SSDC) published an updated Gypsy and Traveller Accommodation Assessment in 2022 which identified a need for 121 pitches during the plan period to 2039. SSDC are now updating the GTAA to align with our revised plan period up to 2041. We have not yet received the findings of the updated GTAA but expect our needs for pitches may have increased.
South Staffordshire Council wrote to DMBC (and other GBBCHMA and neighbouring authorities) in August 2022, and subsequently in October 2023, where we set out that we had only identified a supply of 37 pitches to allocate against a 5-year requirement of 72 pitches. In the letters we set out the steps we had taken to explore supply options including exploring options in the Green Belt, options on publicly owned land, and options for new pitches as part of proposed housing allocations.
SSDC are seeking to ensure that neighbouring and GBBCHMA authorities undertake the same steps that SSDC have taken in exploring pitch options so we can have confidence that our Duty to Cooperate partners have taken a consistent approach when considering if they can assist with SSDCs unmet needs for pitches. We therefore request that through your plan preparation you explore, and evidence, the following options:
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Intensifying supply on existing sites
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Expanding all suitable existing sites
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Exploring all public land options in the Borough for new public sites
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Approaching sites proposed for general housing allocation to identify if the landowner would be willing to set aside part of the site for pitch needs
It is noted that Dudley have identified a likely shortfall in provision of suitable pitches following the ‘call for sites’ process, though it is not clear that all the options identified above have been explored to determine if additional capacity could be available. South Staffordshire Council would welcome an indication that all such options have been explored and we look forward to continuing to engage with DMBC on this issue.

Comment

Representation ID: 586

Received: 21/12/2023

Respondent: South Staffordshire Council

Employment Land Need
The latest evidence on employment needs covering the Black Country (Black Country EDNA 2023 update) has identified a need for 72ha of employment land in Dudley. This figure increases to 98 ha.

once replacement for operational employment land sites identified for reallocation to residential development is included.
South Staffordshire Council paused local plan production following completion of a Regulation 19 Publication Plan consultation in December 2022 in light of proposed Government changes to national planning policy. South Staffordshire Council has now recommenced work on plan production but is awaiting the final adoption of changes to national policy before proceeding to an updated Publication Plan (Regulation 19) consultation in Spring 2024. The Regulation 19 Plan was supported by a draft Statement of Common Ground (SoCG) across the South Staffordshire FEMA (consisting of South Staffordshire, Cannock, Dudley, Stafford, Walsall and Wolverhampton), plus Sandwell, as a result of its close economic relationship with the three other Black Country authorities that fall within the South Staffordshire FEMA. At this time, South Staffordshire through this SoCG indicated its position, as set out in our November 2022 Publication Plan, that we have a 36ha (excluding WMI) surplus of employment land that we can make available to unmet needs of the Black Country FEMA. Following the decision by national government to amend national planning policy with respect to Green Belt land releases South Staffordshire Council is currently reassessing the scale of future commitments with a view to producing a revised draft local plan in Spring 2024. To accompany the revised plan SSDC is undertaking an update to the evidence base which will include revisiting the EDNA prior to our next stage of public consultation and this will inform the council’s decisions with respect to future employment land commitments. This will inform an update to the SoCG across the FEMA and our position in relation to contributing to unmet employment needs.
West Midlands Interchange
A Strategic Rail Freight Interchange (West Midlands Interchange (WMI)) is situated within South Staffordshire though this serves a wider market area (including Dudley). Through our 2022 EDNA South Staffordshire Council identified a requirement of 18.8 ha. of the WMI land to meet our labour demand requirements up to 2040. This will be subject to further analysis as part of the update to the EDNA in 2024. South Staffordshire Council has acknowledged that there is surplus employment land at WMI that the council does not require and that could be utilised to meet the unmet needs of the wider market area. Whilst we have taken a more in-depth approach to calculating our share of WMI through our local evidence, we still consider that the 2021 Stantec report1, that considered potential apportionment across the sites market areas based upon population change within each LPA area, is a reasonable basis for determining wider authorities’ potential share of the site given its wider role and in the absence of sub-regional details of labour demand. The Stantec report apportions 67ha of the site towards the Black Country, with a further breakdown suggesting that 14ha of the site could be apportioned to Dudley.