Question 3

Object

Representation ID: 3758

Received: 13/12/2022

Respondent: Mr D E Marsh

An extra 4000 houses need for the Black Country has not been clearly justified.
Need has been overestimated and supply underestimated.
Overspill into South Staffordshire is unproven.
35% uplift in Wolverhampton to justify the shortfall seems contrary to Government Policy.
Out of date statistics were used to calculate housing need.
Already growth in South staffs is from out-migration suggesting a number driven approach would be against good planning (based on e Government’s 16 December 2020 Statement) as it would direct housing:
- away from where services are.
- away from where profound structural change is lily to occur.
- towards location undermining climate change objectives.

Object

Representation ID: 3760

Received: 11/12/2021

Respondent: Lynda and Robert Jeavons

Black country shortfall has been miss calculated and overstated.
4000 shortfall homes is to many.
There is an intention for the Duty to Co-operate to be embolised.
Green belt should not be scarified for shortfall housing.
There are 11,193 disused empty houses in the Black country and Staffordshire theses should be utilised before the green belt.
West Mids Mayor stated there is enough brownfield sites for housing shortage.

Object

Representation ID: 3768

Received: 23/11/2021

Respondent: Carol Hyatt

Housing target based on out of date data and should be re-calculated.

Object

Representation ID: 3822

Received: 13/12/2021

Respondent: Mr John Huband

What is the evidence used from neighbouring authorities that the duty to co-operate figure?

Object

Representation ID: 3875

Received: 14/12/2021

Respondent: Save the Seven Cornfields Campaign Group

Several local plans in the area are running out of phase for example South Staffs and the Black Country these plans should be made in parallel.
Overspill from Black Country and Birmingham has been exaggerated- and has been calculated using out of date figures.
Realising green belt for overspill housing is relinquishing one of South Staffordshire’s unique selling points.
Objects to the duty to co-operate - the council tax from Severn Cornfield site will go to South Staffordshire but amenities and services of adjacent authorities will be used.

Support

Representation ID: 3894

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

Reference to South Staffordshire seeking to strive to protect and enhance its distinctive rural character, communities and landscape; and to create beautiful thriving new places where people can live, work and play is supported.
Strategic Objective 6 - Developing an Economic Strategy, is supported. The Plan should seek to retain existing employment and foster sustainable economic growth, encouraging inward investment and job creation.

Object

Representation ID: 3895

Received: 10/12/2021

Respondent: Messrs - Jenks & Letts

Agent: PlanIt

Vision is inappropriate and should be amended - the economic objective of sustainable development requires a sufficient quantum of the right type of land to be available to support economic growth. The social objective requires local authorities to ensure that a sufficient number and range of homes are provided to meet the needs of current and future generations. Propose additional text to confirm that South Staffordshire will deliver sufficient land, of the right type, to meet the economic and housing growth requirements of South Staffordshire and which will support the growth of the conurbation.
Strategic Objective 1, and the Plan as a whole, fail to have any regard to the requirement of the NPPF para 140. Safeguarded land should be identified for longer term development.
Strategic Objectives 3, 4 and 5 do not contain reference to providing a sufficient quantum of housing to support the growing number of households in the district to provide enough homes to accommodate South Staffordshire’s working population, or to supporting the growth requirements of the conurbation. Additional Strategic Objective should be added to reflect this.

Object

Representation ID: 3975

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Strategic Objective 1 is supported however compensatory Green Belt provision is not something that fully ameliorates loss of Green Belt. Our evidence suggests that ‘exceptional circumstances’ do not exist for removal of many new housing sites from the Green Belt.

Strategic Objective 2 is not supported. The additional 4,000 houses for the Black Country should be removed. A policy to review that position subsequent to the adoption of the Black Country Plan based on up-dated evidence should be included if that is deemed to be necessary. The use of Urban Extensions should be reviewed as the Local plan attempts to justify this because of the acceptance of over-spill from the conurbation, which we are challenging.

Strategic Objectives 3-5 on housing can be supported but they should relate to needs arising in South Staffordshire. The evidence that significant housing needs to be included from the Black Country is not supported.

Strategic Objective 12 is wholly inadequate. The Objective should be much higher up in the Plan. The Plan should also aim to support a reduction in Climate Change emissions not only through mitigation at development sites but in the overall approach to development location.
Accepting significant amounts of housing from the Black Country undermines that goal.