Issue and Options 2023

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South Warwickshire Local Plan – Issues and Options consultation This letter contains the officer response on behalf of the City of Wolverhampton Council to the Issues and Options Consultation on the South Warwickshire Local PLan. The principles which underpin the response were approved by the Council’s Cabinet at its meeting on 22nd February. In summary, the Council welcomes the progress made with the new Local Plan, and the positive approach which it takes to the Duty to Cooperate in responding to the unmet strategic housing needs arising across the West Midlands and the Black Country authorities specifically. In the context of this broad support, we have a number of points which we wish to raise on specific issues. Our detailed response is set out below. Background A Representation was submitted to the previous stage (Scoping Report) of the Plan preparation process in 2021 on behalf of the City Council through the Association of Black Country Authorities (ABCA). This representation expressed strong support for those Growth Options which provide the opportunity to meet the housing and employment land needs arising in the Greater Birmingham and Black Country HMA (GBBCHMA). As you may be aware, in September 2022 the Leader of Dudley Council announced that he wished to withdraw the Council from involvement in the Black Country Plan (BCP). The four Black Country Councils subsequently agreed to prepare individual local plans and the associated Local Development Schemes (LDSs) are in the process of being brought into effect. As a consequence of this approach, the Councils also agreed to progress Duty to Cooperate work on an individual basis rather than jointly through ABCA. The Wolverhampton Local Plan The Wolverhampton LDS was adopted by Cabinet on 22nd February 2023, confirming the commitment of the Council to continue to prepare an up to date Local Plan in a robust and timely manner. This February 2023 LDS supersedes the LDS approved in October 2022, reflecting the need for the Council to consider the implications of the final version of proposed changes to the National Planning Policy Framework published for consultation in December 2022. The LDS programmes an Issues and Preferred Options consultation on the Wolverhampton Local Plan in July 2023, followed by a Regulation 19 consultation in February 2024. The Local Plan will build on the work progressed on the BCP and subsequent evidence. Our current position on housing and employment land need and supply is as set out in the Draft BCP, published for consultation in 2021. In the case of housing, the Draft BCP identified a shortfall of some 28,000 homes to 2039 across the four Council areas. For Wolverhampton, the housing shortfall was substantial at some 7,700 homes to 2039. On the basis of the consultation version of the NPPF referred to above, the Leader of the Council has committed to excluding any sites which are currently located within the green belt as development allocations within the new Local Plan. This, will further increase the 2039 City housing shortfall to some 8,700 homes. The new Local Plan will also have a Plan period extending to 2041, which could further increase this shortfall. Turning to employment land, the National Planning Practice Guidance encourages strategic Plan-making authorities to identify needs on a Functional Economic Area (FEMA) basis. In the case of Wolverhampton, the City is located within the Black Country FEMA as identified in the Black Country Economic Development Needs Assessment (EDNA) published in 2017. Across the FEMA as a whole, the BCP identifies a shortfall of some 210ha of employment land to 2039, this being the sum of shortfalls across the four Council areas. The EDNA confirms that the Wolverhampton element of this shortfall is between 40ha to 80ha. An updated EDNA was in the course of preparation to support the BCP Regulation 19 draft, and the four Council’s agreed to complete this update to support individual Local Plan preparation. The update was published in January 2023 as supporting evidence to the Sandwell Local Plan Regulation 18 consultation (https://www.sandwell.gov.uk/info/200317/planning_policy/4990/sandwell_local_plan ). The update recommends that collectively, the employment land ‘need’ should be reduced to some 512ha, and that the corresponding shortfall is some 22.4ha after taking into account current proposed contributions from neighbouring Local Plan areas. The Report recommends that the closing of this gap should be addressed through ongoing Duty to Cooperate activity with a focus on those areas having a strong or moderate functional economic relationship with the Black Country (as defined in the 2017 EDNA), and other areas where there is evidence of a functional relationship. In the case of South Warwickshire, it is not considered that such a relationship exists. While the Council will be updating land supply as part of the preparation of the Local Plan, we do not anticipate that the work will reveal any significant sources of additional land to meet housing needs. For these reasons, we are strongly of the view that the Wolverhampton housing shortfall identified in the Draft BCP remains and could potentially rise further. The ABCA representation to the Local Plan scoping consultation identified a limited functional relationship between the Black Country and South Warwickshire housing markets, but the housing land capacity constraints in the Black Country post 2031 will create a ripple effect across the conurbation and the wider HMA. On this basis, the Council remains of the view that not only is there compelling evidence of a housing shortfall arising in Wolverhampton and the wider Black Country, but also that South Warwickshire has a role to play towards addressing this shortfall through the current Local Plan. The recently published Interim findings of the Shropshire Local Plan (https://www.shropshire.gov.uk/media/25337/id28-inspectors-interim-findings-letter-15-feb-2023.pdf ) support this approach (paras 14-15), confirming the Black Country housing land shortfall including in the light of the Council’s progressing individual Local Plans. This supports our view that the shortfall cannot be ignored. The Issues and Options consultation The Issues and Options consultation document acknowledges the relationship with the GBBCHMA and Coventry Warwickshire HMA (CWHMA) and notes that, subject to soundness, the Stratford SAD will contribute 380 dwellings up to 2031 to the former. It also notes the scale of the GBBCHMA shortfall originating from Birmingham and the Black Country authorities post 2031, and that South Warwickshire may be part of the solution and that a CWHMA shortfall may be more modest. In demonstrating support, the S(E)A has considered an initial contribution of 5-10,000 dwellings to alleviate the wider GBBCHMA shortfall. This is a significant contribution and is welcomed in principle. In noting that the constraints within the GBBCHMA are due to the West Midland Green Belt, the document correctly infers that open countryside areas beyond the Green Belt are the first port of call. However, the document recognises that there are potential Green Belt locations north of Stratford, which would meet need closer to where it arises. We recommend that all of these options set out in the document are tested through the next stages of the Plan preparation process. We also recommend that the Councils continue to engage with the work of the GBBCHMA officer group and the programme of work contained within the Statement of Common Ground as circulated by South Staffordshire Council in 2022. Clearly, as is the case with the Interim findings of the Shropshire Local Plan Examination, it is not and should not be the case that South Warwickshire is expected to meet the entirety of the GBBCHMA shortfall. A regional approach is required but the potential contribution from the South Warwickshire Local Plan has the potential to make headway into addressing the gap. We trust that these comments are helpful and will be considered by the Council as part of the preparation of the next stage of the Local Plan.