Object

Representation ID: 4956

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Unclear if employment growth has been taken into account in determining the the appropriate minimum level of housing need to be provided for in the SSLP. Specifically the West Midlands Interchange proposal, which means that in total there is still 141.9ha which is not anticipated to meet either local employment need nor address the unmet employment needs from the Black Country. The substantial over-allocation of employment land in the SSLP, including that resulting from the WMI project, will need an additional labour supply to fill the new jobs provided. The Council’s employment evidence suggest that the additional jobs, including those provided at WMI, will be met by the existing South Staffordshire labour force through either reduced unemployment or reduced out-commuting (see Economic Development Needs Assessment 2020-2040, June 2022, paragraph 0.56). However, it remains unclear whether the potential impact on the demand for housing within the District, as a result of the jobs growth required to support the over-supply of employment, has been taken into account in determining the minimum local housing need figure now proposed in the SSLP. RPS recommends that the Council revisits its assessment of local housing need in order to properly assess the impact of planned future employment growth in the District and consider the implications on housing demand of the significant level of over-supply of employment land identified in the SSLP.

The contribution to unmet needs of neighboring authorities should be increased to at least 4200 dwellings to take account of the extra year of the plan.

The Council is still relying on the 2018 Strategic Growth Study to justify the 4000 home contribution, although the shortfall now extends 3 years beyond the end date of that study to 2039. Other relevant information (including data migration and commuting flows between the District and the Black Country) has been ignored in favour of the focus solely on the SGS as the basis for the scale of the redistribution. Both migration and communting flow data shows a very strong functional relationship between South Staffordshire and the Black Country. Therefore, RPS contend that other data sources should be taken into account and which indicate that the contribution should be higher than 4,000.