Object

Representation ID: 1118

Received: 11/02/2022

Respondent: Lower Penn Parish Council

The addition of 4,000 homes from the Black Country is not supported because the evidence is not clear and the Black Country Plan is still in development. Housing supply has improved across the conurbation but South Staffordshire’s contribution has not reduced to reflect this. Black Country unmet needs can be considered through a plan review. The approach to settlement Tiers is supported, which would suggest removing all sites within the Lower Penn parish boundary. Housing for Locality 5 more than doubles need figures in the 2018 Locality Profile. A moratorium on Green Belt urban fringe should be imposed until all sites in the GBHMA have been delivered. Black Country housing supply is being underestimated, including through exclusion of large site windfalls and the arbitrary 35% uplift.

A comprehensive assessment of vacant dwellings in South Staffordshire should be undertaken. The windfall allowance should be increased to provide 1500 dwellings over the plan period and the 1153 dwellings over-allocation should be removed. SSDC have declared a climate emergency but govt. statements acknowledge Green Belt housing leads to a greater reliance on public transport and turns a carbon sink into a carbon source. There is no analysis of the climate change impact of the plan or strategy to reduce these impacts.