Publication Plan April 2024

Object

Representation ID: 6677

Received: 31/05/2024

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that the Council has met the Duty to Cooperate and do not consider that the Publication Plan is sound. It is noted in the Council’s Duty to Cooperate paper a list of Council’s that South Staffordshire intends to engage with. However, a number of authorities in the HMA are excluded – Sandwell, Birmingham, Solihull, Lichfield and Stratford-upon-Avon. To meet the DtC it is imperative that these authorities are engaged to ensure a coordinated response to meeting the shortfall. Details on the HMA authorities & their housing capacity can be found in the full representation.

Previously South Staffordshire was a signatory to a Statement of Common Ground in 2022, however, South Staffordshire have reduced their contribution to the unmet need following the publication of the updated NPPF. There have been other notable changes since the signing of the SoCG including a significant increase in unmet need.

Whilst we acknowledge the challenging position the Council finds itself in with the sensitivity to releasing Green Belt, the provision of just 640 dwellings towards meeting the identified shortfall is woefully inadequate and the level of contribution is not supported by any evidence. The shortfall represents 110,000 families/households who will go without adequate accommodation if meaningful steps are not taken to address the shortfall.

Comment

Representation ID: 6678

Received: 31/05/2024

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Strategic Objective 2 seeks to meet housing and employment needs of the District whilst making a proportionate contribution towards the unmet needs of Greater Birmingham. What is meant by a ‘proportionate’ contribution in the context of picture across the HMA is not clear, but 640 dwellings does not begin to scratch the surface.

Object

Representation ID: 6679

Received: 31/05/2024

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Folkes does not consider that the housing requirement of 4,726 homes has been formulated on a sound basis. Folkes do not consider that the 640 dwelling contribution will adequately address the unmet need that has been identified and that the approach will not be effective as it would not result in effective joint work on cross boundary strategic matters. In light of the fact that the Council had previously confirmed a 4,000 contribution to meeting the unmet needs of the HMA, the reduction to 640 confirms that the plan is not positively prepared and unsound. We recommend that South Staffordshire enter into further negotiations with adjoining authorities.

Object

Representation ID: 6680

Received: 31/05/2024

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Folkes do not consider that the Development Strategy is sound or that it complies with the NPPF.

Folkes agree fully with the Council that exceptional circumstances exist to support the release of Green Belt land. Where Folkes differs from the Council is that they consider the evidence supports the release of significantly more land to meet the unmet housing need across the HMA. We would welcome the opportunity to discuss this matter with the Council and to review any evidence based documents that support the conclusion on how much land should be released.

When it comes to Green Belt boundaries, they should endure beyond the plan period. It is evident that the Council has made no attempt to safeguard land for future development needs arising from South Staffordshire or the wider HMA. This is a significant shortcoming and means the requirements of the NPPF have not been met.

Object

Representation ID: 6681

Received: 31/05/2024

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Folkes are promoting land at Lawnswood for a proposed residential development to accommodate approximately 475 dwellings to meet the needs of South Staffordshire or the unmet need arising in the wider HMA.
It is considered that sustainable sites on the edge of the conurbation, including Folkes’ site at Lawnswood should be included in SA3 for it to be effective and sound. Details on this site can be found in the full representation, including a Vision Document which was previously submitted.