Object

Representation ID: 5039

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 2
South Staffordshire District Council has failed to take into account the recent Autumn 2022 collapse of the emerging Black Country Plan (BCP) (Review) (2022) and the subsequent massive void and uncertainty now created in terms of the level of estimated unmet housing needs present across the (GBBCHMA). We have concerns about this incompetent approach being taken to Local Plan-preparation within the South Staffordshire District. South Staffordshire District Council needs to finally accept that the GBBCHMA data is now no longer reliable, is heavily out-of-date, no longer sufficiently robust, and no longer provides credible or fit-for-purpose evidence to inform future Local Plan-preparation work across the district going forward. The Council’s Plan making approach is therefore not based on ‘proportionate evidence’ in direct conflict within test of ‘Soundness’ as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021). The Plan making approach is also failing to use the most robust and up-to-date evidence, in direct conflict with paragraph 31 of the Revised NPPF (2021). As well as taking forward undeliverable unmet housing needs forecasts information, in direct conflict with paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021).
Object to the continued poor quality of the evidence base being used by the Council to support Local Plan preparation. We also continue to object to the “incapable” management and leadership approach being taken towards Local Plan preparation work by South Staffordshire District Council. It is important that these failings now come to an end.