Object

Representation ID: 4854

Received: 21/12/2022

Respondent: John Davies Farms ltd.

Agent: Berrys

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Association of Black Country Authorities
(ABCA) wrote to Shropshire Council on the 24 February 2021 (in responseto Shropshire Council’s Regulation 19 consultation), to highlight that there will continue to be a shortfall of land to meet the Black Country’s housing needs even in the light of Shropshire’s proposed contribution in its Regulation 19 Plan and the proposed contributions in other emerging neighbouring Local Plans, including South Staffordshire, Lichfield and
Cannock. ABCA anticipate that these contributions could accommodate in the region of up to 10,500-12,500 homes and, in the best-case scenario, would leave the Black Country with a significant shortfall.
Significantly, paragraph 5.15 of the Publication Plan highlights the significant housing shortfall likely to remain across the Greater Birmingham Housing Market Area (GBHMA) but states that its exact extent is not currently known. As a consequence, the Publication Plan proposes to retain a contribution of 4,000 dwellings to the GBHMA. This appears to be an arbitrary figure brought forward from the 2018 Issues and Options consultation, which was based on the findings of a 2018 Strategic Growth Study that did not extend up to 2039 (the end date of
the Publication Plan).
The Draft SoCG (provided in the
Duty to Cooperate Topic Paper) highlights, in section 6, a number of key issues, including that:
- there remains a shortfall of 6,302 homes between 2011 and 2031 based on April 2020 information; and
- there is evidence of a shortfall post-2031 that is unlikely to be met and which is likely to increase in the future.
Given the above, it is considered evident that, in order to meet housing needs in the period up to 2039, the contribution provided in the South Staffordshire Local Plan towards the unmet needs of the Greater
Birmingham Housing Market Area should be increased. This is additional justification for the release of land in South Staffordshire for housing development. As detailed in the representor’s objection to policy DS5, the
release of additional land for housing development should be focused on Tier 4 settlements to recognise the sustainability of those settlements, protect and enhance their sustainable village centres / services and
facilities and to meet housing needs including the requirement to provide 10% of housing growth on sites of less than 1 hectare.
The Plan is therefore considered to be unsound as it fails to meet housing development requirements.