Publication Plan November 2022

Object

Representation ID: 4149

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to level of housing proposed and justification for this in paragraphs 5.8-5.24. Technically and due to emerging government policy it is no longer clear that the Black Country and Birmingham have unmet needs. It is unlikely the Duty to Cooperate will remain. Exceptional circumstances do not exist for Green Belt release under Policy DS1, which also requires amendments to Policies SA1, SA2, SA3, SA5 and SA7.

Commissioned evidence suggests that South Staffordshire's housing need is less than 5089 dwellings, whilst the plan is proposing 11,490 dwellings, 6,066 of which are already allocated or delivered. There is no need to release Green Belt. There may be no unmet needs from Birmingham/Black Country due to Census and supply data and plans are at early stages. South Staffordshire should withdraw Green Belt releases to meet those unmet needs and Michael Gove statements imply Duty to Cooperate would not exist. Higher density figure of 40dph should be assumed.

Housing target is grossly excessive and there is likely to be more urban capacity in the Black Country, no exceptional circumstances exist and Green Belt exists to deliver urban regeneration. Black Country duty to cooperate correspondence has been overtaken by collapse of Black Country Plan.

Plan is not in accordance with law and should be withdrawn. Revised plan should only allocate land to provide 4097 dwellings for the District, taking account of windfalls. If it is necessary to allocate Green Belt to meet Black Country needs this should be through local plan review. Deallocation should be based on Green Belt policy, sustainability, landscape, biodiversity and other relevant policies.

Object

Representation ID: 4150

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to level of housing proposed and justification for this in paragraphs 5.8-5.24. Technically and due to emerging government policy it is no longer clear that the Black Country and Birmingham have unmet needs. It is unlikely the Duty to Cooperate will remain. Exceptional circumstances do not exist for Green Belt release under Policy DS1, which also requires amendments to Policies SA1, SA2, SA3, SA5 and SA7.

Commissioned evidence suggests that South Staffordshire's housing need is less than 5089 dwellings, whilst the plan is proposing 11,490 dwellings, 6,066 of which are already allocated or delivered. There is no need to release Green Belt. There may be no unmet needs from Birmingham/Black Country due to Census and supply data and plans are at early stages. South Staffordshire should withdraw Green Belt releases to meet those unmet needs and Michael Gove statements imply Duty to Cooperate would not exist. Higher density figure of 40dph should be assumed.

Housing target is grossly excessive and there is likely to be more urban capacity in the Black Country, no exceptional circumstances exist and Green Belt exists to deliver urban regeneration. Black Country duty to cooperate correspondence has been overtaken by collapse of Black Country Plan.

Plan is not in accordance with law and should be withdrawn. Revised plan should only allocate land to provide 4097 dwellings for the District, taking account of windfalls. If it is necessary to allocate Green Belt to meet Black Country needs this should be through local plan review. Deallocation should be based on Green Belt policy, sustainability, landscape, biodiversity and other relevant policies.

Object

Representation ID: 4151

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4152

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 and DS5

Object

Representation ID: 4153

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4154

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4155

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4156

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 & DS5

Object

Representation ID: 4157

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 and DS5

Object

Representation ID: 4159

Received: 20/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Objections relate to para 5.61, SA1, SA2, SA3, SA5 and SA7. Object to the level of employment provision, particularly the 36.6ha allocated to the Black Country. Black Country urban capacity report gave shortfall of 553ha, but updated Economic Development Needs Assessment implied figures varying from 364-502ha (past completions) to 418-806ha (GVA). Little need under employment based scenario for additional land.

Even if 210ha shortfall is accepted, dispute that only 30-35% of the proposed 270ha WMI site should address Black Country needs. Emerging plans to replace Black Country Plan are at early stage and it is unclear whether South Staffordshire will be under an obligation to meet employment needs from these given structural economic changes.

Any correspondence on duty to cooperate has been overtaken by collapse of Black Country Plan. South Staffordshire's employment needs should be based on its own requirement. 'Exceptional circumstances' for Green Belt release for employment should be reviewed.