Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 599

Received: 21/12/2023

Respondent: Shropshire Council

. Development Needs
2.1. We consider that your draft Spatial Strategy and draft Policy DLP1 clearly identify
your preferred strategy and your proposed scales of growth supported by Table
5.1 and your justification in paragraphs 5.4 to 5.13. Your statement in draft
Policy DLP1(1) that you seek ‘to deliver sustainable economic and housing growth
to meet strategic planning targets’ is significant and would appear to prioritise the delivery of an ‘economic’ spatial strategy with an appropriate balance of housing
growth. We also acknowledge the clear statement of both your housing and
employment land positions set out in paragraph 5.12 and acknowledge that this
will assist to improve the effectiveness of their DtC process.
2.2. We recognise your housing need comprises 11,954 dwellings and that 10,876
dwellings may be provided within your Borough, leaving an unmet housing need of
1,078 dwellings. Your employment land need comprises 72 hectares (rising to
98ha to replace your employment land losses), but only 25 hectares may be
provided within your Borough. This leaves a more significant unmet employment
land need of 47 hectares, or 73 hectares after replacing employment land losses.
2.3. Your unmet development needs are a cross boundary strategic matter for the
Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and the
Black Country FEMA. It is noted this strategic issue has been discussed
extensively with LPAs in the GBBCHMA and with other closely related authorities
like Shropshire Council. As part of our Local Plan process our Council agreed with
ABCA to contribute 1,500 dwellings and 30 hectares of employment land towards
the unmet needs in the Black Country. This agreement did not determine how
these contributions would be apportioned between the four Black Country
Authorities, and it is assumed this process will be undertaken through DtC
conversations between the Black Country Authorities through ABCA. It should be
noted the Shropshire Local Plan remains at Examination.
2.4. It is expected that through the process of plan preparation in the West Midlands
region, and in particular by Authorities in the GBBCHMA, that further contributions
to unmet needs in your Borough and to the other Black Country LPAs will be
considered.
3. Unmet Development Needs
3.1. We have considered the implications of your land availability on your capacity to
meet your development needs and the contributions from LPA in the GBBCHMA,
the BCFEMA and from closely related authorities who have engaged in your DtC
process.
3.2. We recognise that you cannot currently show how your unmet development needs
will be met in full and that further measures may be necessary to meet these
unmet needs. We acknowledge your draft Local Plan articulates your
Development Strategy and how you will manage your Green Belt in Strategic Priorities 2 and 3 and in draft Policies DLP1, DLP3, DLP15, DLP37, DLP49 and
DLP50.
3.3. It is recognised that a decision to review Green Belt boundaries is for individual
LPAs to make. However, based upon the evidence of unmet need it is suggested
there is potential for your Authority to review Green Belt boundaries in order to
fully explore all development opportunity in your Borough, and thus reducing the
level of identified unmet need.
3.4. It is recognised the provisions of the new NPPF (published on 19th December) will
need to be considered in this context. In your evidence base you identify that the:
a. Black Country Green Belt Study (BCGBS) (September 2019) identifies in
paragraph 2.32 a significant conclusion in the Black Country Urban Capacity
Study (BCUCS) (May 2018) that your urban capacity evidence provides the
exceptional circumstances to trigger a Green Belt Review in the Black Country
to meet housing and employment land needs:
b. BCGBS sets out the method and findings of your Green Belt Review but it is
not sufficiently explicit about your findings on exceptional circumstances to
trigger the release of Green Belt land for development or for safeguarding for
future growth in your Borough;
c. Dudley Local Plan – Options to the Preferred Strategy states in paragraph 3.7
that: “Whilst further clarity is required on the current status of Local Plans
for Lichfield, South Staffordshire, Cannock Chase, Telford & Wrekin and
Bromsgrove as the work on Local Plans further progress, the potential
contributions that could be apportioned towards Dudley’s unmet need will
make some significant headway in addressing the borough’s unmet housing
needs. It is for this reason that it is considered that ‘exceptional
circumstances’ have not [been] triggered to justify the need to consider a
review of the borough’s Green Belt.” This statement refers only to your
unmet housing need and a similar statement has not been made about your
more significant unmet employment land need.
d. In relation to your unmet development needs, it is not currently possible for
you to show how you can achieve your intention in draft Policy DLP1 to
‘export’ these unmet needs to other LPAs;
3.5. We consider that your approach may already be largely compliant with national
policy on Green Belts but some further steps may help to justify the soundness of
your draft Local Plan and to help show whether your preferred strategy is
appropriate for your Borough. We acknowledge that you:a. have evaluated the urban capacity of your Borough as part of more extensive
assessments across the Black Country area. You have clearly identified your
unmet development needs to support ABCA to engage effectively in the DtC
process. These measures are consistent with paragraph 141 of the NPPF but
you should recognise that your intention to ‘export’ unmet need might:
i. result in pressure to release Green Belt land in other locations, which in
the view of this Council would be a far less sustainable option for meeting
unmet needs; and
ii. be balanced by a release of Green Belt land within the Black Country area.
b. are considering the sustainability of directing development into your urban
area, into the wider Black Country area, into neighbouring urban authorities and
have looked for further opportunities within and beyond the Metropolitan Green
Belt to meet your unmet needs as required by NPPF, paragraph 142.
3.6. This advice seeks to help your Authority show how your draft Local Plan provides
an appropriate strategy for your Borough. We believe this will help to evidence
your compliance with the tests of soundness for plan making in national policy.