Object

Representation ID: 1485

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA. HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire. No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population.
Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall.
Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country. Insufficient capacity in other GBHMA authorities to absorb shortfall and South Staffordshire should be taking a greater proportion given its functional relationship with the Black Country. The plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation.