Strategic objectives - to deliver the vision

Object

Representation ID: 4173

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

see attachment

Object

Representation ID: 4361

Received: 22/12/2022

Respondent: St Modwen

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 2 is supported however all the FEMAs EDNAs have underestimated employment requirements. The methodology used should be reviewed, as per Savills recommendations in its Industrial and Logistics Need Assessment. Object to the evidence base supporting Strategic Objective 2.

Strategic Objective 6 is supported however suppressed demand as a result of under forecasting will mean that the Local Plan does not fulfill the requirements of Strategic Objective 6. Industrial and logistics development have a critical infrastructure role. Sites located directly adjacent to major motorway junctions such as Land at Dunston are critical to facilitating this growth in accordance with the requirements of Paragraph 83 of the NPPF. However, as matters stand, the Plan significantly underestimates the true extent of demand in the sector, and fails to deliver sufficient allocations to achieve Objective 6.

Support

Representation ID: 4898

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the vision and strategic objectives set out. Strategic Objective 2 in particular references the need to meet the housing and employment needs of the District whilst making a proportionate contribution towards the unmet needs of the GBBCHMA.
The objectives for high quality housing to meet a wide range of needs and provide beautiful and sustainable places where people want to live are welcomed. The LPR notes the lack of brownfield development sites available within the District, and the requirement for a careful release of suitable Green Belt land to meet housing need.
The strategic objectives of the LPR are sound.

Support

Representation ID: 4907

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the vision and strategic objectives set out. Strategic Objective 2 in particular references the need to meet the housing and employment needs of the District whilst making a proportionate contribution towards the unmet needs of the GBBCHMA.

The objectives for high quality housing to meet a wide range of needs and provide beautiful and sustainable places where people want to live are welcomed. The LPR
notes the lack of brownfield development sites available within the District, and the requirement for a careful release of suitable Green Belt land to meet housing need.

The strategic objectives of the LPR are sound.

Object

Representation ID: 4955

Received: 13/12/2022

Respondent: Persimmon Homes West Midlands

Agent: RPS Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Regarding Strategic Objective 2 - RPS notes the plan period is now 2018-2039, or 21 years; it was 2018-2028 or 20 years in the Regulation 18 Preferred Options document consulted on previously. By extending the plan period forward by one year, the local housing need for South Staffordshire has increased by one year’s growth (at least 241 dwellings).

However, the contribution towards the unmet needs of the Black Country has not increased in the same way. By doing so, this would increase the contribution from 4,000 to 4,200 (on a pro rata basis as a 1/20 of 4000). This would go some way towards helping to further reduce the shortfall in housing in the Black Country and would represent an effective planning response on this matter. RPS sees no reason why the proportionate contribution to the unmet need should not be extended forward by one year in line with the local housing need increase.

Object

Representation ID: 5037

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 11
the Green Infrastructure evidence being used by the Council is far too vague, unclear, meaningless, insufficiently robust, and fails to respond effectively to paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform Local Plan preparation and highly contentious spatial planning policy considerations, which will deliver thousands of new homes immediately alongside highly sensitive landscape-scale wildlife corridors. Such as the South Staffordshire Railway Walk in Lower Penn, which contains critically important bat roosts within areas of sensitive deciduous broadleaved woodland. The Council is taking forward an unsound policy (based on highly questionable, vague, meaningless and insufficiently robust evidence) which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) 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.
The Local Plan is not being informed by sufficiently robust green infrastructure evidence. In particular, robustly-based wildlife corridor green infrastructure assessments as required by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The emerging Local Plan Review assumptions are therefore based on flawed, insufficiently robust and missing evidence.

Object

Representation ID: 5038

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 1

Given South Staffordshire District Council’s previous under-performance on delivering natural green space environmental improvements across the district we have no confidence that the Council has the technical skills, ability, interest or desire to deliver environmental improvements. The Council is therefore taking forward an undeliverable policy approach which it has no intention of ever delivering, therefore conflicting with guidance in 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.

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.

Object

Representation ID: 5040

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 4
By promoting heavily urbanising major residential development across sensitive greenfield sites within areas of open countryside, we maintain our view that the Publication Stage Report (November 2022) is promoting inappropriate, damaging and unsustainable patterns of development within the district, in direct conflict with sustainability development focused guidance reinforced in paragraphs 7, 8, 10, 11 (indent a), 16 (indent a), 35 (indent d), 38, 119, and 120 (indents d and e) of the Revised NPPF (2021).
The proposed housing sites within the Publication Stage Report (November 2022) are proposing a net site density level of 35 dwellings per hectare (dph) across sensitive greenfield sites. This is fairly high-density residential development for these sensitive greenfield sites within the Green Belt countryside, and will therefore result in future new housing development site layouts coming forward which would be heavily urbanised and therefore fail to deliver any meaningful on-site biodiversity/ nature conservation enhancement features and climate change mitigation benefits.
The ongoing failure and continued refusal to promote the most sustainable patterns of new housing development across the district, means that the emerging Local Plan Review is therefore vulnerable to potential future Legal challenge at the later Examination in Public (EIP) stage - against the ‘Sustainability tests of soundness’ for Local Plan preparation, as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).

Object

Representation ID: 5041

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 5
We have concerns that the Council considers that it will be creating healthy communities. To be perfectly clear, the new residential communities being proposed through major housing-led urban extensions within the open countryside will be heavily isolated from existing services and public open space provision, and given their isolated position, will be heavily car dependent. We have Council’s that the Council’s Sustainability Appraisal (SA) process has failed to recognise these critically important sustainability issues. This underlines the ongoing failure and continued incompetence being taken towards Local Plan. Both the Sustainability Appraisal (SA) and this policy is unsound.

Object

Representation ID: 5042

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 11 (BNG)
Not one of the new build private sector residential developments delivered within the district over the last 10 years has incorporated a single bat brick or swift nest box brick within external facing brickwork. If the Council cannot even deliver one single bat brick within private sector new build residential schemes over the last 10 years, we have no confidence that the Council has any interest in delivering meaningful BNG within the district going forward. This incompetent planning policy approach cannot be allowed to continue within the district.
By incorporating sufficient new habitat creation measures within new housing development proposals. We are disappointed that the Council’s Planning Policy and Development Management Teams continue to promote poor quality forms of new housing developments across the district, which fail to effectively respond to BNG focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021).
By incorporating sufficient new habitat creation measures within new housing development proposals. We are disappointed that the Council continues to promote poor quality forms of new housing developments across the district, which fail to effectively respond to BNG focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021).

Object

Representation ID: 5043

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 12
By promoting heavily urbanising major residential development across sensitive greenfield sites within areas of open countryside, we maintain our view that the Publication Stage Report (November 2022) is promoting inappropriate, damaging and unsustainable patterns of development within the district, in direct conflict with sustainability development focused guidance reinforced in paragraphs 7, 8, 10, 11 (indent a), 16 (indent a), 35 (indent d), 38, 119, and 120 (indents d and e) of the Revised NPPF (2021).
The proposed housing sites within the Publication Stage Report (November 2022) are proposing a net site density level of 35 dwellings per hectare (dph) across sensitive greenfield sites. This is fairly high-density residential development for these sensitive greenfield sites within the Green Belt countryside, and will therefore result in future new housing development site layouts coming forward which would be heavily urbanised and therefore fail to deliver any meaningful on-site biodiversity/ nature conservation enhancement features and climate change mitigation benefits.
The approach being taken within the emerging Local Plan will worsen the effects of the Urban Heat Island Effect and cause increased levels of surface water run-off (creating flood risk pressures), given that greenfield sites (green space vegetated surfaces) within the open countryside will be replaced by heavily urbanising brick, concrete, tile and macadam surfacing. We have concerns that the Council appears to have no understanding of the urban heat island effect or surface water run-off issues.
The position is perfectly clear, the emerging Local Plan Review will promote highly damaging and unsustainable patterns of new housing and employment land development across the district, contrary to the ‘Sustainability’ test of ‘Soundness’ as reinforced in paragraph 35 (indent d) of the Revised NPPF (2021). The Council is taking forward an unsound Local Plan Review.

Object

Representation ID: 5045

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The 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).

Object

Representation ID: 5048

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 5
the new residential communities being proposed through major housing-led urban extensions within the open countryside will be heavily isolated from existing services and public open space provision, and given their isolated position, will be heavily car dependent. We have Council’s that the Council’s Sustainability Appraisal (SA) (the SA is not fit-for-purpose or sufficiently robust) process has failed to recognise these critically important sustainability issues. Both the Sustainability Appraisal (SA) and the policy itself within the Publication Stage Report is unsound.
The Council is also using an insufficiently robust Green Space Audit (Open Space Needs Assessment) to inform and support Local Plan preparation, that fails to meet the requirements of paragraph 98 of the Revised NPPF (2021).
Given that highly unsustainable new residential communities will be created, in isolated site locations, poorly served by publicly accessible green space resources, the Council’s Publication Stage Report (2022) will make the obesity epidemic far worse, will help increase cases of Types 1 and 2 Diabetes, coronary heart disease, lung disease due to increased levels of air pollution from thousands of additional cars placed onto the district’s already pressured road networks, etc. We have concerns that the Council’s proposed spatial planning policy approach will make health inequalities far worse across the district.

Comment

Representation ID: 5259

Received: 19/12/2022

Respondent: St Philips

Agent: Pegasus Group

The Plan’s objectives should be amended to reflect the need to meet both the present and future housing requirements, including those pressures arising through the Duty to Cooperate with neighbouring authorities. In this instance the well-known unmet housing needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) should be clearly considered.
The Local Plan lacks clarity at Strategic Objective 1 and does not define the exceptional circumstances for release of Green Belt land as part of its strategy. It should be made clear that the need to identify land for growth and development over the Plan period, and
beyond, means that there are exceptional circumstances arising which have required a full and detailed Green Belt boundary review, with a view to identifying land that it is proposed to be released from the Green Belt to meet the District’s growth requirements.
In relation to Strategic Objective 2, reference is made to meeting the housing and employment needs of the District. It is considered this could be strengthened to refer to meeting the needs of both existing and new residents of the District, but the overarching thrust that new housing should be focussed on sustainable locations in the District, including the key villages, is supported.

Object

Representation ID: 5273

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend objectives to reflect the need to meet both the present and future housing requirements including those arising from the DtC.

Object

Representation ID: 5274

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Strategic Objective 2 could be strengthened to refer to meeting the needs of both existing and new residents.

Support

Representation ID: 5275

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Overarching thrust that new housing should be focussed on sustainable locations in the District and the edge of the conurbation.

Object

Representation ID: 5368

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Further to the Preferred Options consultation the Vison has been amended to reflect the Council’s declared climate emergency, with greater emphasis placed on providing homes which accord with the NPPF 8c guidance that in order to achieve sustainable development, proposals should mitigate and adapt to climate change. It also seeks to 'protect and enhance' the District as it currently exists, rather than thinking forward and considering how the growth proposed within the Plan can better the District as a whole.
Although the Vision is broadly supported it should be amended to reflect the need to meet both the present and future housing requirements, including those pressures arising through the Duty to Cooperate with neighbouring authorities, with specific reference to meeting the unmet housing needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA). The delivery to meet the housing requirements of the GBBCHMA is discussed further in this representation, however Persimmon Homes considerers that it should be included in the Vision to clearly demonstrate commitment to the statutory Duty to Cooperate.

Object

Representation ID: 5370

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In relation to Strategic Objective 2, reference is made to meeting the housing and employment needs of the District. It is considered this could be strengthened to refer to meeting the needs of both existing and new residents of the District. The overarching thrust that new housing should be focussed on sustainable locations in the District, including the key villages, is supported.