Object

Representation ID: 5026

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

South Staffs is not affected by National park designations, AONB designations, the Water Directive and phosphate nutrient issues, circa 80% of its administrative area lies within the West Midlands Green Belt – however, it is recognised that in order to accommodate a proportion of the GBBCHMA unmet need (even sensibly located close to the Black Country boundaries), South Staffs has no choice but to allocate sites (both for its own needs and those of the GBBCHMA) within the Green Belt.
In this context, whilst it is commendable that the Council is still proposing to accommodate some 4,000 houses of unmet need, and that, as the Council, says at paragraph 5.6 of the Topic Paper and paragraph 5.16 of the Local Plan, there has been broad support from the other authorities for this, it does not negate the fact that the 4,000 is based on earlier study assumptions, with no consensus on the overall shortfall of provision within the GBBCHMA. Vistry is supportive of the principle and sentiment, but not necessarily the level of provision. This is because there is no certainty that the quantum of housing for which the Council is planning is actually sufficient.
Furthermore, it is important to highlight that the level of collaboration with other GBBCHMA authorities to date, still falls short of the requirements of the DTC as set out in both the NPPF and PPG. The reality is that very little has actually changed since the publication of the Regulation 18 Plan in 2021. Paragraph 27 of the NPPF requires the SOCG to be agreed, to be produced and publicly made available. This is still outstanding and therefore, Vistry consider that the Plan is unsound on the basis that it is not ‘positively prepared.