Object

Representation ID: 4150

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to level of housing proposed and justification for this in paragraphs 5.8-5.24. Technically and due to emerging government policy it is no longer clear that the Black Country and Birmingham have unmet needs. It is unlikely the Duty to Cooperate will remain. Exceptional circumstances do not exist for Green Belt release under Policy DS1, which also requires amendments to Policies SA1, SA2, SA3, SA5 and SA7.

Commissioned evidence suggests that South Staffordshire's housing need is less than 5089 dwellings, whilst the plan is proposing 11,490 dwellings, 6,066 of which are already allocated or delivered. There is no need to release Green Belt. There may be no unmet needs from Birmingham/Black Country due to Census and supply data and plans are at early stages. South Staffordshire should withdraw Green Belt releases to meet those unmet needs and Michael Gove statements imply Duty to Cooperate would not exist. Higher density figure of 40dph should be assumed.

Housing target is grossly excessive and there is likely to be more urban capacity in the Black Country, no exceptional circumstances exist and Green Belt exists to deliver urban regeneration. Black Country duty to cooperate correspondence has been overtaken by collapse of Black Country Plan.

Plan is not in accordance with law and should be withdrawn. Revised plan should only allocate land to provide 4097 dwellings for the District, taking account of windfalls. If it is necessary to allocate Green Belt to meet Black Country needs this should be through local plan review. Deallocation should be based on Green Belt policy, sustainability, landscape, biodiversity and other relevant policies.