Object

Representation ID: 5112

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

there are three matters that the Plan fails to address in
establishing the South Staffordshire element of the housing requirement:
- The housing requirement proposed in the consultation draft Plan is below the Standard Method figure derived from the Council’s own SSHMA.
- The SSHMA fails to correctly factor in affordable housing need. The draft plans seeks to rely upon affordable housing delivery from the 4,000 dwellings proposed to meet the growth requirements of the conurbation to support the South Staffordshire affordable housing need. This is inappropriate given that these 4,000 dwellings are proposed to meet the growth requirements of the conurbation who have their own affordable housing needs.
- No consideration has been given to uplifting the minimum Standard Method housing figure to support the economic growth aspirations and the fact that changes in age profile of South Staffordshire means there is a decrease in residents of a working age.
If the housing shortfall figures identified in policy PG1 of the BDP and the emerging Black Country Plan Preferred Options document are added together, there is a total
housing shortfall of 66,139 dwellings. This should be considered as an absolute minimum, given that the emerging Birmingham City housing shortfall is significantly greater than this combined figure. The 4,000 dwellings proposed by South Staffordshire Local Plan to meet the growth requirements of the conurbation is
approximately 6% of the conservative shortfall figure. South Staffordshire, given its functional relationship
to the Black Country and for the reasons previously mentioned, should be accommodating a significantly greater amount of development than this to support
the growth requirements of the conurbation.