Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1255

Received: 06/12/2024

Respondent: South Staffordshire Council

The draft plan identifies a supply of 10,470 dwellings against a calculated requirement of 11,169 homes leaving a marginal unmet need of 699 dwellings. SSC will continue to work closely with Dudley Metropolitan Borough Council (DMBC) alongside the other relevant partners consider unmet needs across the housing market area through the relevant working groups and duty to cooperate arrangements.
SSC has recently completed a consultation on an updated Publication Plan (Regulation 19). It should be noted that SSCs preferred strategy in its April 2024 Regulation 19 consultation is to meet the housing needs of our communities by focusing growth primarily on the district’s most sustainable Tier 1 settlements, including some Green Belt release at these settlements on sites assessed as suitable through our site assessment process. This does result in a potential 640 home surplus based on our current standard method requirement that could be attributed to unmet needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA).
We would support a commitment to continued attempts at increasing the supply of dwellings identified within the borough. Specifically, attention should focus on examining the scope for increased densities particularly in the larger urban centres, reallocation of sites from other uses were this doesn’t conflict with other plan objectives, housing area renewal proposals and exploring the potential release of Green Belt sites including those sites identified in the now abandoned draft Black
Country Plan. Such contributions will reduce the overspill requirement arising within Dudley and potentially make a contribution towards addressing housing market shortfalls in the wider Greater Birmingham and Black Country Housing Market Area.

Comment

Representation ID: 1256

Received: 06/12/2024

Respondent: South Staffordshire Council

SSC published an updated Gypsy and Traveller Accommodation Assessment in 2024 which has identified a need within the district for 162 pitches during the plan period.
SSC wrote to DMBC (and other GBBCHMA and neighbouring authorities) in August 2022, October 2023 and subsequently in March 2024, where we set out that we had only identified a supply of 37 pitches this is set against a revised 5-year requirement of 92 pitches, and therefore confirming we had a significant unmet need for pitches.
SSC are seeking to ensure that neighbouring and GBBCHMA authorities undertake the same steps that SSC 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 SSCs unmet needs for pitches. We therefore requested 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 city 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 the Gypsy and Traveller Accommodation Assessment (GTAA) 2022 identified a need for an additional 46 pitches in Dudley Metropolitan Borough for families meeting the planning definition. The plan has identified an additional capacity of 13 pitches and there is therefore a shortfall of 33 pitches to be identified which the Borough Council indicate will be delivered within the existing urban area through the planning application process. SSC would welcome an indication that all options identified above have been explored and in particular we would wish to reiterate that DMBC explore the potential for a public site in the Green Belt, a request which we have previously made in a letter dated in December 2023.

Comment

Representation ID: 1257

Received: 06/12/2024

Respondent: South Staffordshire Council

DMBC has identified a shortfall of 50 hectares in the supply of employment land to meet the needs of the Borough during the plan period. SSC has identified a potential surplus of 45.2 Ha. of employment land, which includes a new proposed allocation at Junction 13 of the M6. This land has been identified as being available to contribute towards addressing the employment land shortfall within South Staffordshire Functional Economic Market Area (FEMA) which includes DMBC. As stated in our signed Statement of Common Ground (SOCG) with DMBC, the role this surplus land will play in helping to address employment land shortfalls will be the subject of two separate SOCG covering the entire South Staffordshire FEMA and also the Black Country FEMA.
SSC will also allocate the consented strategic rail freight interchange (WMI). Though situated in South Staffordshire the WMI serves a wider market area (including Dudley). Through our 2022 EDNA & 2024 update SSDC identified a requirement of 18.8 ha of the WMI land to meet our labour demand requirements up to 2041. SSDC has acknowledged that there is surplus employment land at WMI that is currently ‘unclaimed’ 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 (18.8ha) 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 14ha of the site towards the B8 employment land needs of Dudley, and it is noted that this figure has been identified as a commitment in the Plan towards the employment land supply.

Comment

Representation ID: 1258

Received: 06/12/2024

Respondent: South Staffordshire Council

The proposed changes to the NPPF have recently been the subject of consultation and it is the Government’s intention to publish a finalised NPPF by the end of the year. Based on the transitional arrangement contained in the consultation NPPF it is our understanding that the Plan would need to be submitted on or before the publication of the revised NPPF (+ one month) if it is to be assessed against the current December 2023 NPPF. Should the Plan be submitted after NPPF publication date (+ one month) it would appear that the Plan would be considered in relation to the revised framework, as it doesn’t appear that any of point a-c in paragraph 226 of the draft NPPF would apply to DMBC. This would require DMBC to re-examine the current plan strategy particularly in light of the proposed introduction of a distinction between Green Belt and Grey Belt land, and the role which Green Belt can play in increasing the supply of land for residential development and Gypsy and Traveller provision. Therefore, whilst the plan is currently considered sound against the December 2023 NPPF, should the transitional arrangements in paragraph 226 of the consultation NPPF remain in the final version, and should DMBC be unable to meet any of points a-c in this paragraph, then the Publication Plan would not be sound and would need to be revisited.