Publication Plan November 2022

Object

Representation ID: 5122

Received: 22/12/2022

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The Objector considers the proposed Local Plan to be both unsound and not complying with the provision of the Duty to Cooperate by not allocating the land, to the east of the A449 at Lawnswood for housing (please see site map at Appendix 1). Regarding the tests of soundness (National Planning Policy Framework 2021, paragraph 35 refers) the Objector does not consider the plan is either “positively prepared”, “justified”, “effective” nor “considered with National Policy” for the two
fundamental reasons:
1. The plan does not meet the District’s objectively assessed need for housing.
2. The plan does not set out nor provide enough housing to meet the substantive and significant unmet needs of the Black Country conurbation (in a planning context where Birmingham City has an even greater unmet housing need, approximately 79,000) which is also a failing in respect of the statutory Duty to Cooperate.

The Objection Site’s Vision Document (please see Appendix 2) demonstrates that within this very broad area there are sites which can deliver sustainable development.

It is important to point out that the Objection Site (Call for Sites reference 343) was discounted/ruled out of the Strategic Housing and Employment Land Availability
Assessment because it lies adjacent to a “Tier 5 Settlement” i.e. Lawnswood. The Objector considers that completely ignores the Objection Site’s potential to meet the significant unmet housing needs of the Black Country conurbation which abuts CFS 343.
A main attribute of the Objection Site is that it is well contained in the landscape and can deliver a new, more robust western boundary for a revised Green Belt area.
Regarding more detailed planning matters, these are dealt with in more detail in the Vision Document. Suffice to say here that regarding ecology, flood risk and drainage, landscape and visual impact, services and utilities, there are no planning constraint “showstoppers” and the Masterplan (Page 41 refers of the Vision Document) can be readily delivered (see Appendix 2 for Vision Document).

Object

Representation ID: 5198

Received: 22/12/2022

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We contend that any decision to allocate overspill land
beyond the Green Belt i.e., the 20% of South Staffordshire which is not within Green Belt, would not be in a sustainable location and would lead to unsustainable patterns of transport and commuting and would not effectively meet the housing needs of the Black Country conurbation.
However, an objective assessment of Green Belt purposes, demonstrates that there is no significant impact caused by the release of the site in terms of Green Belt objectives and it is evident that Green Belt land has to be released to meet development needs for both South Staffordshire and the Black Country conurbation.
The Objector considers that the failure of the Council to allocate the site for housing development is not in accordance with the principles of the Duty to Cooperate process and also renders the plan unsound.

Object

Representation ID: 5199

Received: 22/12/2022

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Should the site not be allocated for development within this Plan, the Objector would wish the site to be identified as a safeguarded site for future development to be released through a future Local Plan review. It is noted that the Council has made no provision to provide safeguarded land in the Regulation 19 Plan despite the expectation set out in paragraph 140 of the Framework.

It is abundantly clear that South Staffordshire, being on the edge of the Black Country conurbation, will have to accept a significant amount of overspill development, for
both housing and employment, both in this plan period and beyond. In this context the Council has made no attempt to identify land for development which should accommodate development needs beyond the plan period.
It is considered that the Council’s failure to identify safeguarded land to meet development needs beyond the plan period is contrary to the clear advice set out in
the Framework.
It is noteworthy that paragraph 143e also states that local authorities should demonstrate that Green Belt boundaries will not need to be altered at the end of the
plan period. Quite clearly the Council is unable to demonstrate this matter.

Object

Representation ID: 5200

Received: 22/12/2022

Respondent: Folkes Holdings

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The suggested housing requirement included in the Plan, of 9,089 dwellings, is fundamentally flawed.
In summary, there are three matters that the Plan fails to address in establishing the South Staffordshire element of the housing requirement:
1. The housing requirement proposed in the consultation draft Plan is below the Standard Method figure derived from the Council’s own SSHMA.
2. The SSHMA fails to correctly factor in affordable housing need. The draft plans seeks to rely upon affordable housing delivery from the 4,000 dwellings proposed to meet the growth requirements of the conurbation to support the South Staffordshire
affordable housing need. This is inappropriate given that these 4,000 dwellings are proposed to meet the growth requirements of the conurbation have their own
affordable housing needs.
2.No consideration has been given to uplifting the minimum Standard Method housing figure to take into account economic growth aspirations and the fact that the age profile of South Staffordshire is increasing resulting in a decrease in residents of a working age.

In relation to cross boundary need, even if the full
extent of the current shortfall is distributed evenly amongst the 9 authorities which are capable of accommodating growth, each authority should be providing approximately 7,370 dwellings. South
Staffordshire, given its functional relationship to the Black Country, should be accommodating a significantly greater amount of development than this in order to support the growth requirements of the conurbation.
The housing requirement in the Plan is not sound. It should be increased significantly. The South Staffordshire element of the housing requirement should be based upon the Standard Method and increased to address affordable housing and economic growth requirement. The 4,000 dwellings proposed to meet the growth requirements of the conurbation is woefully inadequate.
The housing requirement in the Plan is not sound. It should be increased significantly.
The South Staffordshire element of the housing requirement should be based upon the Standard Method and increased to address affordable housing and economic growth requirement. The 4,000 dwellings proposed to meet the growth requirements of the
conurbation is woefully inadequate.