Object

Representation ID: 5035

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Sustainability Appraisal (SA) being used to support South Staffordshire District Council’s Publication Stage Report (Regulation 19) (November 2022) emerging Local Plan Review has failed to consider all reasonable alternatives to the spatial strategy – There is a lack of certainty about the delivery of employment uses at a time when the South Staffordshire District, the wider West Midlands Region, and wider UK is facing a 300-year-economic-recession-event as a result of the global coronavirus pandemic (COVID-19), and as a result of Russia’s Spring 2022 ongoing invasion of Ukraine. There is also a lack of certainty concerning the delivery of major levels of new housing development across the district during the severe economic recession described above and during a period of severe volatility in the residential mortgages market.
Contend that the Sustainability Appraisal (SA) process is clearly unsound and is not legally compliant, and therefore fails various tests of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indents b – it is not based on proportionate evidence), (indent c – failing the deliverability test), and (indent d – it is failing to promote the most sustainable patterns of development) of the Revised NPPF (2021). The approach taken within the SA is also in direct conflict with paragraphs 31 (it is not based on sufficiently robust and up-to-date evidence) and 82 (indent d – the SA is failing to shape into its preparation the huge and rapid shift in adverse economic circumstances now affecting the district) of the Revised NPPF (2021).