Object

Representation ID: 5063

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Having considered the evidence, we have concerns that The Council is taking forward an unsound Policy (Policy NB8) given that many of the Conservation Area Character Appraisals (CACA) background technical evidence base documents which support the designation of Conservation Areas are now heavily out-of-date. For example: Chillington Estate, Weston-under-Lizard, Enville Village, Shropshire Union Canal, Wombourne and Lower Penn.
The HESA reports provide evidence that is too vague and unclear, and which forms insufficiently robust guidance and should not therefore be being used solely to inform critically important spatial planning policy considerations for the future spatial distribution of major new housing development, within areas of historically sensitive countryside. The position is very clear, there is an incomplete and insufficiently robust up-to-date historic environment evidence base.
Nearly all of the Conservation Areas are being underpinned by an evidence base which is at least 12 years old, and therefore heavily out-of-date evidence. And as stated, alarmingly some of the district’s Conservation Area’s have not been surveyed for the last 51 years. We have concerns about this level of incompetence.
By taking forward insufficiently robust and unsound policies which are based on heavily out-of-date and highly questionable evidence, the Plan is clearly unsound and fails the proportionate evidence tests of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021). The approach taken towards Local Plan preparation is also in direct conflict with paragraphs 31 and 192 of the Revised NPPF (2021).