Object

Representation ID: 1620

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

The contribution provided to the GBBCHMA housing shortfall may need to rise as ABCA representation to Shropshire Regulation 19 consultation indicates. Additional release of land in South Staffordshire is required to meet Black Country needs.
Level of growth in Tier 4 and 5 settlements is considered to be inappropriate as it fails to recognise their sustainability, helping to protect and enhance their village centres. Failing to plan for Tier4 and Tier 5 settlements will result in the need for housing arising form their local communities being unmet.
Paragraph 4.16 of the consultation document indicates that housing allocations are not required in Tier 4 or Tier 5 settlements to meet the national requirement for 10% of housing growth to be delivered on sites no larger than 1ha. This is contrary to NPPF Paragraph 69 where the 10% requirement is a minimum figure and the allocation of such sites to meet this is necessary for the plan to be found sound.