Preferred Options November 2021

Object

Representation ID: 1077

Received: 08/02/2022

Respondent: CPRE Staffordshire

- The housing target is far in excess of standard method required by government due to the contribution to the Black Country– CPRE questions the scale of the overspill from the Black Country and ask this to be reviewed. Upcoming planning reforms mean it is uncertain if the Duty to Cooperate will be retained.
- Windfalls are artificially low and should be increased to 100 DPA (1,500 over plan period) to reflect historic averages.
- The 4,000 contribution to the Black Country/HMA shouldn’t be reflected in the five year supply as it risks the Council being unable to demonstrate a five year supply in future.
- South Staffordshire should agree with the Black Country that no greenfield development will be allowed before brownfield sites in the Black Country are built out
- Request that explicit allocations should be made for the Black Country vs those made to meet South Staffordshire’s needs
- The over allocation for plan flexibility should be removed, it is not defensible to use it in case of development not coming forward on allocated sites
- Stafford has not requested its unmet needs be met and has previously objected to growth South of Stafford
- Suggest that housing targets are incorrectly calculated and could be reduced