Publication Plan November 2022

Object

Representation ID: 4350

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

In Section 6 the housing allocations identified for cross-boundary growth are Land at Cross Green, Land north of Linthouse Lane and Land at Langley Road. The plan's figures suggest these could deliver 2790 dwellings in the plan period and 776 more beyond. There is no justification for this deferral approach.

These sites either abut the edge of Wolverhampton or are in close proximity to it. There is not evidence to show the Duty to Cooperate has been met through joint working with Wolverhampton. We question whether the Council has carried out its Duty to Co-operate with the relevant bodies. We have not seen the evidence for this in the published documents.

East of Bilbrook and Land North of Penkridge would provide at least 1977 houses in total and are easily accessible to Wolverhampton by train. Assume that the balance of the 4,000 would be met by these sites with the remaining 757 considered to serve the needs of South Staffordshire. This issue is not addressed in the plan.

Object

Representation ID: 4351

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concerned that South Staffordshire is unnecessarily and inappropriately proposing development in the Green Belt and greenfield sites well in excess of the need of its own residents and migration.

South Staffordshire is apparently providing 11190 homes within the plan, which is 3,093 dwellings in excess of both South Staffordshire's own needs and its 4,000 dwelling provision for the GBBCHMA. This would be 75% over South Staffordshire's calculation of its own housing need. The plan seriously underestimates windfalls and does not justify relying on only 1,200 dwellings from Linthouse Lane in the plan period against a minimum of 1976 dwellings on the site.

Object

Representation ID: 4352

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concerned that South Staffordshire is unnecessarily and inappropriately proposing development in the Green Belt and greenfield sites well in excess of the need of its own residents and migration.

South Staffordshire is apparently providing 11190 homes within the plan, which is 3,093 dwellings in excess of both South Staffordshire's own needs and its 4,000 dwelling provision for the GBBCHMA. This would be 75% over South Staffordshire's calculation of its own housing need. The plan seriously underestimates windfalls and does not justify relying on only 1,200 dwellings from Linthouse Lane in the plan period against a minimum of 1976 dwellings on the site.

Object

Representation ID: 4353

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocated sites have a far lower density than the minimum density given in Policy HC2 (20 - 25 dwellings per hectare rather than 35 dwellings per hectare).

Object

Representation ID: 4354

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Table 8 includes an allowance of 600 windfall dwellings but doesn't explain how this has been derived. The Council's Five Year Supply document (2020-2021) indicates that there has consistently been a windfall supply in excess of 100 dwellings per annum. No explanation is given for the assumption of only 30 dpa when there have been over 100 windfalls in every year both before and during the current Local Plan period. Tables later in the document relate to 2021 and 2022 and show that windfalls are still a significant contributor to housing provision. Appendicies containing large and small sites later in the document show that the majority of current five year supply is from windfalls. On the basis of both 'Historic' and 'Current' data the windfall allowance is unjustifiably low, creating unnecessary Green Belt/greenfield loss.

Object

Representation ID: 4355

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Object

Representation ID: 4356

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Object

Representation ID: 4357

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Object

Representation ID: 4358

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Object

Representation ID: 4359

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.