Draft Black Country Plan

Comment

Representation ID: 45419

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Comment

Representation ID: 45420

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Comment

Representation ID: 45421

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Comment

Representation ID: 45422

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager