Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1265

Received: 06/12/2024

Respondent: Stratford District Council

Para 3.30-3.35 of the Local Plan notes that Dudley Council has been working collaboratively with neighbouring authorities on cross-boundary issues for a number of years and will continue to do so. Para 3.33 refers specifically to Statements of Common Ground (SoCG), stating that draft SoCGs have been produced to support the current Local Plan stage on key Duty to Cooperate issues. These are to be formalised prior to Submission of the Plan. SDC look forward to working with DMBC on a SoCG in due course, whether this be a bilateral statement between the two authorities or through a joint GBBCHMA SoCG.
It is noted that a separate Duty to Co-operate Statement (dated October 2024) has been prepared to support the Publication stage version of the plan. Appendix 4 records Dudley MBC’s correspondence with Stratford DC at Dudley’s Regulation 18 stage1

Comment

Representation ID: 1266

Received: 06/12/2024

Respondent: Stratford District Council

Dudley’s Local Housing Need stands at 11,169 homes using the current Standard Method. The Local Plan’s proposal to deliver at least 10,470 new homes (94% of their Local Housing Need) leaves a shortfall of 699 homes. In line with national policy, there is a requirement for any housing or employment unmet need to be provided for across the relevant Housing Market Area, Functional Economic Market Area (FEMA) or other areas with which Dudley has a strong physical or functional relationship. A number of local authorities have made offers of housing and employment land contributions to assist in addressing the wider GBBCHMA shortfall or specifically the shortfall of the Black Country Authorities (who were previously working together on a joint Black Country Plan), however it is acknowledged that these contributions need to be formally confirmed as part of the Local Plan process and examination of each authority’s Local Plan. The Duty to Cooperate Statement at para 4.11 also states that the four Black Country Authorities have been working on an approach to determine how the contributions from outside the HMA could be apportioned between those authorities with a shortfall of housing supply., with the suggested approach being to use migration data and the functional relationship between the exporting area and the authority where the shortfall exists.

Comment

Representation ID: 1267

Received: 06/12/2024

Respondent: Stratford District Council

Regarding employment land, policy DLP18 ‘Economic growth and job creation’ states that Dudley Council will seek to deliver at least 72 hectares of new employment land between 2020 to 2041 through the allocation of new sites, the redevelopment/intensification of existing sites and through the Duty to Cooperate process – by the development of employment sites outside of the borough which have an evidenced functional link to Dudley Borough. Figure 9.2 illustrates the extent of the Black Country FEMA (Functional Economic Market Area) and extends to show the surrounding authorities with strong or moderate transactions with the Black Country. Neither Stratford nor Warwick Districts fall into these categories. It is therefore understood that Stratford District and Warwick District are not candidate authorities to assist with meeting Dudley’s shortfall in employment land due to the lack of an evidenced functional link.

Comment

Representation ID: 1268

Received: 06/12/2024

Respondent: Stratford District Council

Policy DLP49 concerns Dudley’s Green Belt. The policy states that a strong Green Belt will be maintained. Para 13.4 clarifies that the Plan is not proposing to review any of the Borough’s Green Belt boundaries or allocate any development sites within the Green Belt in accordance with the preferred spatial strategy

Comment

Representation ID: 1269

Received: 06/12/2024

Respondent: Stratford District Council

The South Warwickshire Local Plan is at an early stage of preparation and as such it is not yet known whether the needs of South Warwickshire can be met within the two districts, particularly in light of the potential significant increase in Local Housing Need arising from the proposed changes to the Standard Method, as proposed in the draft NPPF (July 2024). Therefore, at this stage, Stratford cannot make a commitment to assisting Dudley with meeting any of its unmet need. Whilst we are committed to continuing to work with our partner authorities across the GBBCHMA on an update to the 2018 Growth Study and an evidenced method to apportion any unmet need across the authorities, it would be premature to put forward any contributions that have not been derived from this joint work. However, we would take the opportunity to highlight as we have in our previous responses to you, that in the event that there may be a request/need for South Warwickshire to
accommodate any unmet housing need, then this would need to be considered in light of any necessary supporting infrastructure requirements and how this would be funded. SDC has a particular concern regarding how any infrastructure costs that cannot be directly attributed to a specific development will be met, noting previous infrastructure deficiencies from development in the district. In relation to a site which is meeting unmet need from another authority, there should be an arrangement between the exporting and receiving authorities to address any funding shortfall.

Comment

Representation ID: 1270

Received: 06/12/2024

Respondent: Stratford District Council

The specific wording of proposed policy DLP1, point 3 states that full housing and employment land requirements will be met through identified sites and “through reliance on neighbouring and other local authorities who have a functional link with Dudley via the Duty to Cooperate”. It then goes on to state that “Those development needs that cannot be accommodated within the Dudley administrative area will be exported to sustainable locations in neighbouring local authority areas” As discussed above, neither Stratford or Warwick districts share a boundary with Dudley Borough and therefore are not neighbouring authorities. Whilst acknowledging that Dudley MBC and Stratford DC are both members of the GBBC Housing Market Area, it is noted that there is no specific reference to a functional link or historic migration pattern between Dudley and South Warwickshire in the Publication Local Plan or its accompanying evidence base.

Comment

Representation ID: 1271

Received: 06/12/2024

Respondent: Stratford District Council

Given that the proposed plan period for the Dudley Local Plan extends to 2041, which is beyond the 2031 horizon of the 2018 Growth Study, the planned update to the sub-regional work is required to provide an updated picture covering the entire plan period. There is no mechanism within the Publication Version of the Dudley Local Plan as drafted to respond to the planned work of the GBBCHMA regarding quantifying and apportioning the shortfall in homes across the Housing Market Area through the proposed Growth Study refresh. It is therefore currently unclear how this strategic work could influence the Dudley Local Plan and be effective in assisting with meeting the identified housing shortfall.

Comment

Representation ID: 1272

Received: 06/12/2024

Respondent: Stratford District Council

Regarding Dudley’s Green Belt, we would reiterate the comments we made at the Regulation 18 stage of the Local Plan. Given that the identified housing shortfall (and employment shortfall) could have been accommodated within Dudley’s 1,770ha2 of Green Belt through fairly moderate release of land, it is disappointing to see that this option has not been explored further in the Publication Local Plan. There is very limited commentary within the Local Plan itself explaining the rationale behind this decision. It is noted that the supporting evidence base document ‘Spatial Strategy Development’ (October 2024) touches on this matter, stating at para 4.16 that “Dudley’s housing and employment shortfalls are not considered significant”, and that therefore it is “considered that exceptional circumstances [to justify a review of Green Belt boundaries] have not been triggered”. The West Midlands Green Belt is extensive and all members of the GBBCHMA have land designated as Green Belt within their authority areas. Therefore, by protecting Dudley’s Green Belt, but suggesting that Dudley’s unmet needs are exported to surrounding authorities, Green Belt in other local authority areas could become under pressure for release. As the July 2024 draft NPPF proposed extensive changes to national policy regarding Green Belt and the triggers for a review of boundaries, the anticipated revised version of the NPPF may require that Dudley’s proposed approach is revisited

Comment

Representation ID: 1273

Received: 06/12/2024

Respondent: Stratford District Council

We welcome the Council’s commitment at para 5.13 of the Local Plan to continuing to work constructively with neighbouring authorities to help provide as much certainty as possible about how and where the borough’s full housing and employment land needs will be delivered. However, it is unclear how this continued work will inform the Local Plan as it progresses to Submission stage and subsequent examination. We note that a Statement of Common Ground is planned with members of the GBBCHMA regarding the apportionment of any contributions between the GBBCHMA authorities and agreement to refresh the 2018 HMA Strategic Growth Study. Stratford DC look forward to assisting with this in the coming months. We also note that the expected forthcoming publication of a revised NPPF will result in further consideration on this topic.
We would also reiterate that there are infrastructure pressures in both South Warwickshire districts and neither have sufficient infrastructure or the funds to cater for significant additional population, particularly in respect of health, education, and transport infrastructure. It would be necessary for any exported housing to be accompanied by sufficient, funded resources to provide for these.
Stratford on Avon District Council (with Warwick District Council) reiterate their ongoing commitment to working with Dudley Council on strategic matters that cross administrative boundaries under the requirements of the Duty to Cooperate.