Comment

Representation ID: 22481

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

DUTYT TO COOPERATE
South Staffordshire District Council has sought to work closely alongside the Black Country
authorities in addressing its strategic cross boundary issues, primarily its unmet housing needs and
emerging potential employment land shortfall. We welcome the progress on the Black Country
Plan to date and support the Black Country in its efforts to meet its own development needs as
fully as possible whilst progressing Duty to Co-operate discussions with surrounding authorities to
address any remaining shortfalls. The comments below outline where the District Council consider
clarifications or alterations are required to the evidence which sits behind the proposed Draft Black
Country Plan policies, in order to fully address national policy requirements and respond to
regional evidence on unmet needs.

We note the findings of the Black Country Plan Duty to Co-operate Statement July 2021. However,
we are not entirely clear from the published statement what the intended next steps are to
distribute the Black Country’s housing and employment shortfalls. Specifically, there is no clear
reference to the evidential basis that will be used to determine surrounding authorities’
contributions to the GBHMA/Black County unmet housing needs or employment needs (if arising).
Given the Black Country’s role in currently generating the majority of unmet housing needs within
the GBHMA, it is important that the Black Country clarifies where additional contributions to its
unmet needs are required based on the existing GHBMA evidence base. It is equally important that
the Black Country does not solely accept existing housing contribution offers proposed by other
local authorities before deferring any remaining shortfalls to subsequent early reviews of Local

Plans to address any remaining shortfalls. Such an approach would fail to engage with the existing
HMA evidence base (i.e. the 2018 GBHMA Strategic Growth Study) and could risk undermining the
progress of plans in the surrounding area.

Given the number of years the HMA has had to respond to its findings, it is important the Black
Country ensures the findings of the 2018 GBHMA Strategic Growth Study are reflected in Duty to
Co-operate discussions on unmet housing needs with surrounding authorities. In the first instance,
we consider that the existing strategic growth locations recommended in each local authority area
around the GBHMA should be fully explored and delivered as far as possible, given the cross-
authority evidence base that sits behind them. We would only consider it appropriate to not bring
forward these recommendations if a local authority could show these are truly not deliverable or
that there are more sustainable options within its area that could accommodate a similar level of
growth. We would welcome clarity on whether the Black Country intends to pursue such an
approach to provide a framework for further Duty to Co-operate discussions prior to submission of
the Black Country Plan.


Notwithstanding the comments made above, it is acknowledged that there is a significant
possibility that the locations identified in the GBHMA Strategic Growth Study 2018 may not be
capable of fully addressing regional housing shortfalls, particularly in light of the emerging review
of the Birmingham Development Plan. To address this issue, we would support the Black Country
and Birmingham Authorities in seeking to review and update the 2018 Strategic Growth Study and
would welcome involvement in such a study. Any such review should:

• Build upon, rather than replace, the existing growth locations proposed in the 2018
Strategic Growth Study
• Offer an independent audit of urban capacity across the GBHMA, identifying areas where
further work could identify further non-Green Belt housing supply
• Be based upon close engagement with the West Midlands Combined Authority and any
other relevant Integrated Transport Authorities to ensure future growth locations are truly
aligned to existing or proposed sustainable transport improvements

To deliver the findings of any reviewed HMA-wide evidence base we would also support any
efforts to establish governance arrangements for the co-operation process on unmet housing
needs. The lack of such a formal structure has created significant uncertainty in current local plan
reviews and could be crucial to the effective delivery of any future updated growth study
recommendations.

Throughout the consultation period on the South Staffordshire Local Plan which is due to
commence on the 1st November, we will continually assess any housing shortfalls within the
context of duty to cooperate and our proposed approach to date. Further conversations regarding
our proposed contribution may be required depending on the outcome of ongoing duty to
cooperate conversations and the ongoing progression of Local Plans in our and neighbouring HMA
areas.