3.14

Object

Representation ID: 4172

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

see attachment

Comment

Representation ID: 4698

Received: 23/12/2022

Respondent: National Highways

Paragraph 5.22 of the IDP - the principle of the approach towards transport evidence has been agreed between National Highways and Staffordshire County Council but there remain technical details to discuss and agree. Highways England is committed to ongoing engagement with South Staffordshire Council and the local highways authority in order to finalise the technical details of this methodology.

Note that the document has been updated to reflect the April 2022 decision to grant the DCO for the M54-M6 link road. National Highways will enter into Section 278 arrangements with developers to deliver specific necessary improvement schemes on the SRN. This provides certainty of delivery.

Object

Representation ID: 5019

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

The Infrastructure Delivery Plan (IDP), as it was in 2021 at the time of the Regulation 18 Plan publication, is still prepared on the basis of the unresolved uncertainty regarding the overall unmet housing requirement need.
addition, whilst there has been dialogue as part of the DTC, it is clear that the Regulation 19 sites have been allocated without regard (or little regard) to highway modelling – paragraphs 5.22-23 of the IDP refers. This is not only risky in terms of potential need for significant and costly improvements, but is also contrary to the PPG (paragraph 059).
As noted above in the PPG, the DTC extends to other infrastructure providers. The DTC Paper lists all the bodies that the Council has consulted/collaborated with. One glaring omission is Network Rail/Rail Operators. This is particularly important in the context of the delivery of Cross Green (in whole or in part), one of the strategic allocations – further detail and commentary on this is provided in paragraphs 3.10-3.16 below.
In short, the lack of a SOCG, whether that be in the context of the GBBCHMA housing need or in terms of infrastructure provision with key providers/service delivery organisations/etc raises questions about the delivery of some of the allocations either in their entirety, or in part within the plan period. This goes to the heart of the soundness or otherwise of the plan.
Vistry considers that the Plan is unsound in this context as it is not ‘positively prepared’ and it is not ‘justified’ (i.e., based on proportionate evidence base).

Object

Representation ID: 5036

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Reference a number of projects within the IDP stating that they will now be undeliverable or more expensive given the current economic climate and build costs.

Have concerns that the IDP is taking forward totally unrealistic, highly questionable and undeliverable projects in direct conflict with paragraph 31 (e.g. the financial project costings are not based on accurate, credible, robust and up-to-date evidence) of the Revised NPPF, and the 'proportionate evidence test' and 'deliverability test' for Local Plan-preparation tests of 'Soundness', as reinforced within paragraphs 16 (indent b), 35 (indents b and c) of the Revised National Planning Policy Framework (NPPF) (2021).