Object

Representation ID: 5104

Received: 23/12/2022

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The suggested housing requirement included in the Plan of 9,089 dwellings, is fundamentally flawed.

Now that the Plan period has been extended to 21 years this would increase the need for South Staffordshire on a pro rata basis to 5,322 dwellings based on the Standard Method (SM) calculation. The plan target at Table 7 is therefore not based on the SM.

The 4000 figure is based on the 2018 SGS which is out of date and not based on the SM. Shortfalls have increased significantly since the SGS including the circa 78000 shortfall identified in the Birmingham Issues and Options consultation. The 4,000 dwellings proposed to meet the growth requirements of the conurbation is woefully inadequate and needs to be increased significantly.

Completions to date from the start of the plan period are used as a proxy for housing need for the period 2018 to 2022. There have been 992 completions during this period. There is no evidence to suggest that the 992 completions were sufficient to meet the housing requirements of the district during this period. Housing schemes have been restricted to windfall schemes within settlement boundaries due to the restrictive Green Belt policies that are in place. Consequently, using a constrained figure as a proxy is flawed.

Furthermore, we have identified in our other submissions that the plan period should be extended by at least 2 years to ensure that the plan covers 15 years from the date of adoption. This would add a further 507 dwellings to the housing target, and means the plan is current planning for 740 dwellings less than it should be.

The South Staffordshire Standard Method housing requirement is 254dpa according to the SSHMA. As a consequence, an affordable housing requirement of 128dpa is approximately 50% of South Staffordshire’s minimum Standard Method housing requirement. By contrast, the figure in Paragraph 8.7 of the SSHMA is skewed, as the total housing requirement proposed by the Plan is used (9,068 dwellings), which includes the 4,000 dwellings the plan proposes to deliver to meet the growth requirements of the conurbation. The 4,000 dwellings proposed to meet the growth requirements of the conurbation cannot be considered as a source of affordable housing supply to support the affordable housing delivery needs of South Staffordshire. Any affordable housing provided as part of the delivery of these 4,000 units will be to support the affordable housing needs arising from the conurbation, not South Staffordshire.

Table 2 references the demographic imbalance. • No consideration has been given to uplifting the minimum Standard Method housing figure to support the economic growth aspirations or the fact that changes in age profile of South Staffordshire means there is a decrease in residents of a working age.