Here Yet again an inspector questions undeliverable and untested memorandums.
… the 8,700 dwellings referred to in the Plan includes 1,000 dwellings
to meet the needs of Tamworth and Cannock Chase Councils and when this
figure is taken out, the Plan only provides 7,700 dwellings to meet the needs
of Lichfield District (385 dpa) over the plan period – a figure that is below
the range set out in the Housing Needs Study.
30. At the hearings the Council accepted that that the 410-450 dpa range in the
Housing Needs Study did not include the 1,000 dwellings for Tamworth and
16 CD5.5. Lichfield, Tamworth and Cannock Chase Housing Requirement Update.
17 CD5.5a. Addendum.5
Cannock Chase so it was indeed proposing a lower housing figure for
Lichfield District than its own evidence indicated was needed. However, it
considered that the important figure to look at was the 903 dpa for South
Eastern Staffordshire as a whole (ie including Cannock Chase and Tamworth)
and that this figure would be achieved.
31. I do not accept this approach. While the Council has quite correctly cooperated with its neighbours in preparing its evidence base, while it has
signed memoranda of understanding with them relating to the delivery of
housing and while Cannock Chase and Tamworth have each submitted local
plans (the latter having been withdrawn) – the fact remains that the Council
is not preparing a joint plan with its neighbours.
32. To rely on the figure of 903 dpa would be to rely on those other councils
being able to deliver their share of overall housing provision. This is
something that has not been tested and on which I have very limited
evidence to formulate a view, even if it were appropriate for me to do so.
33. Given that there is no significant evidence to dispute the soundness of the
figure of 1,000 dwellings to meet the needs of Cannock Chase and
Tamworth, I consider that the figure which needs to be scrutinised is the
7,700 dwellings (385 dpa) proposed in the Plan to meet the needs of
Lichfield District. This figure is below the Council’s own objective assessment
of housing need (410-450 dpa) set out in its housing needs assessment and
the Council put forward no substantial reasons at the hearings as to why this
should be.