Object

Representation ID: 4159

Received: 20/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Objections relate to para 5.61, SA1, SA2, SA3, SA5 and SA7. Object to the level of employment provision, particularly the 36.6ha allocated to the Black Country. Black Country urban capacity report gave shortfall of 553ha, but updated Economic Development Needs Assessment implied figures varying from 364-502ha (past completions) to 418-806ha (GVA). Little need under employment based scenario for additional land.

Even if 210ha shortfall is accepted, dispute that only 30-35% of the proposed 270ha WMI site should address Black Country needs. Emerging plans to replace Black Country Plan are at early stage and it is unclear whether South Staffordshire will be under an obligation to meet employment needs from these given structural economic changes.

Any correspondence on duty to cooperate has been overtaken by collapse of Black Country Plan. South Staffordshire's employment needs should be based on its own requirement. 'Exceptional circumstances' for Green Belt release for employment should be reviewed.