Object
Publication Plan November 2022
Representation ID: 4629
Received: 22/12/2022
Respondent: CWC Group - Clowes Developments
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Object to Policy DS4 as written, because it is not justified, effective or positively prepared. South Staffordshire’s local housing need has been calculated by using the figure derived using the standard methodology for calculating housing need. The PPG is clear that this sets the minimum housing need and does not produce a housing requirement figure (PPG Reference ID: 2a-002-20190220). The Council should therefore produce evidence as to why this figure does not require any additional uplift or buffering, due to economic growth for example.
It is unclear what the rationale is for the 4,000 HMA contribution figure is, having stayed the same since the issues and options version of the Local Plan review on 2018. We consider that in order to demonstrate on-going and effective joint working with the HMA authorities, that a single SoCG with all authorities should be produced to set out the agreed distribution of the shortfall across the HMA that takes into account latest evidence which points to a significantly increased shortfall. This is required in order to make the plan sound and to meet the legal duty to cooperate.