Object

Publication Plan November 2022

Representation ID: 4958

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

Representation Summary:

The HMA SOCG does not confirm that any local authority member of the GBBCHMA as being signatories to the SOCG in its current form. Given that all local plans moving forward (either recently adopted or under review) will be planning beyond 2031, the lack of an agreed position on how the unmet need will be accommodated within the HMA and the scale of the shortfall post-2031 is a significant failing in the process of cooperation across the HMA to date.

Paragraph 7.2 of the Duty to Co-operate Topic Paper points to the need for an ‘urgent review’ of the current evidence base, including the SGS. However, there is no timetable for when this evidence base will commence or be completed. This represents a clear and obvious delay in the process of addressing the unmet needs of the HMA with no clarity on when this is likely to be concluded. This demonstrates that meaningful progress it not being made on addressing this strategic matter, and which is further undermined given the lack of signatories to the draft SOCG.

Paragraph 7.4 of the DTC Topic Paper suggests that additional Strategic Growth Locations may be needed to meet any ‘residual unmet need’ This ignores the fact that other locations may be suitable to address any emerging shortfall, notably sites located on the edge of settlements in close proximity to where the unmet need arises from.Therefore, in order to reduce the delays, and to reflect the stage the SSLP has now reached, a more timely, pragmatic, and effective approach would be to focus the search for additional sites to address the unmet need on those settlements in the South Staffordshire that are well-located in relation to where the unmet need arises from, and which are locations where development would be consistent with the spatial development strategy. This includes Featherstone, which is well-located close to Wolverhampton. The Land east of Brookhouse Lane, Featherstone represents an obvious option.

Given that no substantive progress or agreements have been made, RPS does not consider that the Duty has been met at this time.