Object

Representation ID: 4211

Received: 21/12/2022

Respondent: Lower Penn Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No requirement in law to accept overspill from neighbouring authorities. Dudley can meet its own needs and Wolverhampton had help to identify another 5,000 dwellings. No account has been taken of city centre supply and Black Country urban capacity is uncertain. Plan figures are outdated for reasons set out in consultant report. Majority of Black Country shortfall is from Sandwell, which is not adjacent to South Staffordshire. No account has been taken of WMCA funding to regenerate brownfield land or 5,000 dwellings at the NEC west of Birmingham. There is also an project for new housing on a Bushbury school site. These should be used to reduce duty to cooperate figures. Consultant report suggests capacity in Birmingham/Black Country vastly underestimates windfalls and vacant properties. 35% uplift shouldn’t merely be added on top of additional housing requirements. 13% buffer has also been added by South Staffordshire.

South Staffordshire should be holding urban authorities to account on regeneration before committing to releasing Green Belt land. WMCA have received £503 million from government and Wolverhampton alone has received £340 million for city centre regeneration. This warrants a re-evaluation of housing need in the GBBCHMA. The National Brownfield Institute offers greater cost-effective opportunities for redeveloping brownfield land.
The Black Country Plan has been abandoned and until these plans are more advanced committing to such a large contribution to their unmet need is disingenuous. The Secretary of State made it clear that the government intends to remove mandatory housing targets and drop requirements for the 20% buffer. He also indicated that a 2 year transition period for Councils to reassess land to be released, allowing for unsuitable sites to be removed from the plan.