Object

Representation ID: 1772

Received: 13/12/2021

Respondent: St Philips

South Staffordshire’s LHN should be applied over the whole of the plan period, including retrospectively. The SHMA should also be updated to reflect the most recent LHN figure as it currently uses an outdated 254 dwelling figure. The SHMA should also be reviewed to consider whether a further uplift to meet affordable needs is required. 53% of South Staffordshire’s own LHN figure is affordable need, leaving 6 dwellings per annum towards the affordable needs of in-migrating households.

Agree that a review of the EDNA is necessary given the growth in the industrial and logistics sector and the evidence of shortfalls vs this demand in the region. Projected population growth would only meet a small proportion of the WMI jobs. Reliance on WMI to meet the Black Country employment need would lead to a very high proportion of in-commuting. Sufficient homes should be planned for to align with anticipated job growth, or risk reinforcing unsustainable commuting patterns. This should be considered through updates to the SHMA/EDNA.

Lichfields has undertaken work to examine the extent of the functional relationships across the GBBCHMA (December 2021), including breaking down the GBBCHMA into two sub-HMAs. This identifies that South Staffordshire should accommodate 25% of Black Country unmet needs and 7% of Birmingham unmet needs, equating to circa 8,650 dwellings to the GBBCHMA. This level of growth should be tested through SA.

To ensure plan flexibility, 10% headroom should be built into supply against the housing target. Wombourne is identified as being capable of accommodating further growth due to its facilities and good access to public transport, so growth on Wombourne edge would be the most appropriate strategy for accommodating further growth.