Object

Representation ID: 5200

Received: 22/12/2022

Respondent: Folkes Holdings

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.
In summary, there are three matters that the Plan fails to address in establishing the South Staffordshire element of the housing requirement:
1. The housing requirement proposed in the consultation draft Plan is below the Standard Method figure derived from the Council’s own SSHMA.
2. 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 have their own
affordable housing needs.
2.No consideration has been given to uplifting the minimum Standard Method housing figure to take into account economic growth aspirations and the fact that the age profile of South Staffordshire is increasing resulting in a decrease in residents of a working age.

In relation to cross boundary need, even if the full
extent of the current shortfall is distributed evenly amongst the 9 authorities which are capable of accommodating growth, each authority should be providing approximately 7,370 dwellings. South
Staffordshire, given its functional relationship to the Black Country, should be accommodating a significantly greater amount of development than this in order to support the growth requirements of the conurbation.
The housing requirement in the Plan is not sound. It should be increased significantly. The South Staffordshire element of the housing requirement should be based upon the Standard Method and increased to address affordable housing and economic growth requirement. The 4,000 dwellings proposed to meet the growth requirements of the conurbation is woefully inadequate.
The housing requirement in the Plan is not sound. It should be increased significantly.
The South Staffordshire element of the housing requirement should be based upon the Standard Method and increased to address affordable housing and economic growth requirement. The 4,000 dwellings proposed to meet the growth requirements of the
conurbation is woefully inadequate.