Object

Representation ID: 3977

Received: 12/12/2021

Respondent: Save the Lower Penn Green Belt (Action Group)

Paragraph 31 of the NPPF (2021) expects Plans to be informed and “…underpinned by relevant and up-to-date evidence…” Paragraph 35 (indent b) of the NPPF confirms that Plans should be: “…Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence…”

Initial work on Local Plan preparation for the Council’s emerging Site Allocations Document (SAD) was undertaken under a significant and entirely different set of economic circumstances. Essentially, a significant and substantial amount of Plan Preparation work has already been undertaken on the emerging SAD before the year 2020 coronavirus (covid-19) pandemic. Which is likely to cause one of the worst United Kingdom (UK) economic recessions in living memory. The huge modelling assumptions being used to underpin, form and force through the Local Plan are flawed and no longer forms a credible, reliable or sound evidence.

We maintain our view that the potentially massive implications of the forthcoming severe UK economic recession on future housing delivery across the District going forward (and how the recession will affect new housing delivery within the District going forward over the lifespan of the new Local Plan once it has been adopted) has been given an insufficient level of planning policy weight, or seemingly no planning policy weight at all (See Appendix 11 Issue 2).

The addition of 4,000 homes to meet the needs of the Black Country is not supported because the evidence is not clear, the housing numbers used are out of date and the Black Country Plan is still in development. This would result in the removal of the named sites adjacent to the Urban Area and in particular Site 582. Given that SSDC planners themselves (see Appendix 10) view the Duty to Co-operate as ‘a fundamentally flawed instrument’, a review of whether any of the needs of the Black Country should be accommodated in South Staffordshire might be
considered in a review of the plan.