Publication Plan April 2024

Object

Representation ID: 6963

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Density policy has been weakened compared to the 2022 Plan. The 2024 Plan omits reference to rural exception sites and the aim to exceed densities refers only to 'central areas'. Whilst policy specifically expects sites to seek to make efficient use of land this is no longer identified as a reason for refusal. The council should revert to the 2022 policy. We consider that a minimum density of 40-45 dph may be appropriate in some locations and this should be defined in policy.

Object

Representation ID: 6964

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Duty to Cooperate
The housing study (see attached) identifies a surplus supply of 2,292 compared to requirements. This surplus could be used to reduce the level of housing identified on greenfield sites or reassess the scale of housing available to meet the needs arising in the Black Country.

Object

Representation ID: 6965

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPRE commissioned housing need study (see attached) identified a need of 4,086 and a supply of 6,378, indicating an over-supply of 2,292 dwellings. The unmet need housing figure in the conurbation is also the subject of considerable uncertainty. South Staffordshire should therefore review its housing figures and reassess the requirement for strategic sites and green belt allocations. We question if there are 'exceptional circumstances' for the release of Green Belt land.

Object

Representation ID: 6966

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPRE object to policy SA1. CPRE housing study (see attached) identifies an oversupply of 2292 dwellings above requirements. The local plan should review allocations to consider if they are justified given constraints such as landscape, biodiversity and green belt.

Object

Representation ID: 6967

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPRE object to policy SA2. CPRE housing study (see attached) identifies an oversupply of 2292 dwellings above requirements. The local plan should review allocations to consider if they are justified given constraints such as landscape, biodiversity and green belt.

Object

Representation ID: 6968

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPRE object to policy SA3. CPRE housing study (see attached) identifies an oversupply of 2292 dwelling above requirements. The local plan should review allocations to consider if they are justified given constraints such as landscape, biodiversity and green belt.

Object

Representation ID: 6969

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPRE favours rooftop renewables (see attached report) with the use of productive farmland as a last resort. The plan should be amended page 144 first para to insert after 'previously developed land' the phrase 'including on rooftops, above car parks and other developed land'.

Object

Representation ID: 6970

Received: 23/05/2024

Respondent: CPRE West Midlands Regional Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to the amendment of Green Belt boundaries to accommodate development allocations set out in Policies SA1, SA2 and SA3. Independent CPRE report (see attached) on housing numbers suggests a surplus of 2292 homes in the plan. We do not consider that 'exceptional circumstances' have been met to justify the release of Green Belt land.