Object

Representation ID: 3973

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Contrary to paragraph 31 of the NPPF (2021) which confirms that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…”, the evidence base is in some cases outdated, especially in the light of trends accelerated by COVID and Brexit. This is likely to have a significant impact for example on the Economic Development
Needs Assessment (EDNA). The Strategic Housing Market Assessment (SHMA) suggests the current policy approach would encourage significant, and potentially unsustainable, out migration from the Black Country thereby undermining South Staffordshire’s Climate Change Strategy 2020 (strategic planning responsibilities) pertaining to reducing car use. The current policy of encouraging out-migration into South Staffordshire is not supported.

In terms of Site 582, as set out in this document, there are a number of concerns with the Sustainability Appraisal, both the limitations of the evidence about flooding, ecology and heritage but also the potential over-statement of the case in relation to education provision.
Appendix A is also limited in the documents it includes. There are concerns about the weight being placed on housing numbers, both in terms of Supply and Need. As set out in this document, there are concerns that the over-spill from the Black Country is over-stated in the
Joint Statement of 2020, and therefore the need for South Staffordshire to accommodate it. Equally there are concerns about the level of supply in South Staffordshire, in particular the significant understatement of windfall assumptions, which would suggest South Staffordshire
can provide 850 homes for the Black Country without any new allocations.