Object

Representation ID: 5060

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

A rigidly fixed template for the future spatial distribution of new housing and new and existing employment land development across the district has already been decided by the LPA and is being forced-through and used as the place shaping agenda going forward, from the now heavily out-of-date existing adopted Core Strategy (adopted 2012). The adopted Core Strategy (2012) (which is now 10 years old since it was originally adopted) now forms a heavily and long out-of-date Plan, based on a huge mountain of insufficiently robust, highly questionable pre-COVID-19 economic data, long out-of-date, unsound background supporting technical evidence base, and unsound spatial planning policy modelling assumptions for the future spatial distribution across the district of new employment land.
This is not a sound and robust way to undertake a Local Plan Review and does not conform with the planning policy approach expected by paragraph 31 of the Revised NPPF (2021).
contend that the Employment land policy approach being taken forward within both the Publication Stage Report (November 2022) and the accompanying not fit-for-purpose Sustainability Appraisal (SA) background evidence supporting Local Plan preparation, are clearly both unsound and are not legally compliant.
both the Publication Stage Report and accompanying SA are both failing to shape into their Plan-preparation approach the huge and unprecedented rapid shift in adverse economic circumstances now affecting the South Staffordshire District) of the Revised NPPF (2021). We have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation by the Council.