Object

Representation ID: 5000

Received: 15/12/2022

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

St Philips notes that the Council has not reflected on the critical concerns raised by St Philips in the previous PO and SHSID consultation responses. Firstly, as St Philips
previously stated in their PO representations, the Council should not utilise completions already delivered in the District prior to the current base year in generating the District’s housing need for the plan period. As St Philips has previously advised, to ensure a sound approach, which aligns with the guidance in the PPG3, St Philips consider that the Council’s LHN should be applied to the whole emerging plan period (2018-2039).
Secondly, as set out in detail within St Philips’ PO and SHSID representations, both the NPPF and PPG are clear that the LHN figure generated by the standard method is a minimum starting point and the PPG is clear that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs.
An affordable housing need uplift would be required to account for the affordable housing needs of in-migrating households from the Black Country or Birmingham, resulting from the proposed 4,000 dwelling unmet housing needs contribution.
Whether there would be a sufficient supply of housing to meet the indigenous employment needs identified within the Council’s new ‘Economic Development Needs Assessment.
Moreover, the Council’s proposed unmet need provision is contrary to the clear caveats set out in the SGS, that it is for Local Planning Authorities to test potential growth through the local plan process (Para 1.41 and 1.42). The quantum of growth identified within the SGS is therefore not a maximum or minimum, and it is for the Council to establish through its own Local Plan process the quantum of growth the District is capable of accommodating above its own LHN.
To this end, St Philips PO response suggested that there was a cogent need – if not a requirement – for the Council to prepare a robust and evidence-led approach which draws on analysis that considers the functional housing market relationship between the various local authority areas. As the Council will be aware, Lichfields, on behalf of St Philips, undertook this analysis. Lichfields’ functional housing market relationship analysis indicates that the Council should be seeking to make provision for c.25% of the total unmet needs of the Black Country HMA up to 2039 and c.7% of the total unmet needs of the Birmingham HMA up to 2031. When combined this would equate to c.8,650 dwellings above the District’s own housing needs, which should be seen as a starting position and tested through the Sustainability Assessment [SA] process.
However, St Philips disagrees with the conclusions of the Reg 19 SA. On the face of it, the Reg 19 SA is fundamentally unclear as to how the Residential Growth Options have been scored. Indeed, there appears to be little evidence to justify the scores given, as the Reg 19 SA notes that the assessment is only at a high-level, is limited, and results in “uncertain impacts being identified for various SA Objectives” (Para N32), other than the Housing SA objective, due to “the uncertainty over the distribution of development” (Para E.2.1.).
Disagree and state there are flaws in the SA conclusions on the growth scenario conclusions.
contribution.
It is evident that there are opportunities to allocate additional ‘suitable, available and achievable’ land and sites in sustainable locations across the District. Indeed, St Philips site at Wolverhampton Road, Wedges Mills (Site ref: 529) is one of these opportunities.
Disagree with the buffer - quoting other authorities which have had higher.