Object

Representation ID: 5069

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Ongoing concerns about the continued poor quality of the background technical evidence base being used by South Staffordshire District Council to support Local Plan preparation and justify spatial planning policy decisions relating to the spatial distribution of new housing development. For example, the emerging Local Plan Review is not even supported by a robust and up-to-date Green Infrastructure Study (GI Study), and therefore the approach taken towards Local Plan making by the Local Planning Authority (LPA) is in direct conflict with paragraphs 174 (indents a and d), 175 and 179 of the Revised NPPF (2021).
The South Staffordshire District Nature Recovery Network (NRN) Mapping (2020) is a highly aspirational document which provides very weak, not fit-for-purpose and insufficiently robust background technical evidence from which to make planning policy assumptions, and from which to inform critically important land use spatial planning policy considerations, to inform the future spatial distribution of new housing development across the district. Particularly those housing sites coming forward alongside landscape-scale wildlife corridors, such as the South Staffordshire Railway Walk dismantled railway line within the Lower Penn area of the district.
Alarmed that the Council is relying on this weak evidence base to inform Local Plan preparation and critically important spatial planning policy considerations. In accordance with paragraph’s 174 (indent d) and 179 of the Revised NPPF (2021) the Council should have used a sufficiently robust and up-to-date Green Infrastructure Study (GI Study) to inform the Publication Stage Report (November 2022) (Regulation 19) Local Plan document.