Preferred Options November 2021

Object

Representation ID: 1083

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Underlying consistency with the wording and layout of the overall Preferred Options Report (November 2021) which created confusion and clarity. Unusual approach to the public consultation system which lead to unclear community engagement, The existing adopted Local Plan comprised of the Core Strategy (adopted in 2012) an the Site Allocations Document (adopted in 2018) which seeks to deliver the spatial planning framework for the future distribution of new development across the South Staffordshire District within the Local Plan Review 2021. Therefore, concerns arise that South Staffordshire Council's Core Strategy and Site Allocations which are being used for the new Local Plan Review are based on out of date data. Any initial work on the plan preparation for the Council's emerging Local Plan Review was undertaken pre-Covid19 Pandemic which implicates the Local Plan Review viability and deliverability. The future recession can impact on the community within South Staffordshire which will implicate the planning policies therefore the foundation for the draft of the preferred options are based on out- of - date data.

Object

Representation ID: 1284

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

There are inconsistencies with the wording of the Preferred Options Report and questions which lead to confusion of the document. The public consultation approach is expressed by Goldfinch Town Planning Services, to be confusing and not effective in achieving clear engagements from members of the public and key stakeholders. Overall the document does not conform with NPPF/PPG. Goldfinch TPS express the adopted Local Plan and part of the spatial planning policy origins have been taken from South Staffordshire's Core Strategy (2012) and Site Allocations Document (2018) therefore, the data is expressed to be out of date. Initial work for plan preparation for the Local Plan Review was taken before the economic circumstances before
Covid-19. Goldfinch TPS views following the Covid-19 pandemic causes implications on future housing delivery and employment land delivery across the District and the lifespan of the Local Plan therefore, evidence base is
considered no longer fit to inform future plan preparation work on the emerging Local Plan Review which overall does not conform to with NPPF/PPG.

Goldfinch Town Planning Service comments there is missing evidence on Urban Capacity Study supporting any background technical evidence base for future proposed spatial distribution of new housing sites across the District. Expressed the need for potential new housing sites to be considered within more sustainable site locations to enhance or maintain the vitality of rural communities.

Object

Representation ID: 1285

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

IDP expressed as not comprehensive enough and informed by out of date date, to consider the proposed planning policy approach. There are questions raised towards reasonable prospects of the deliverability of some projects within the IDP.

Goldfinch TPS expresses the evidence base being informed by out of date data therefore questions the delivery and proposed policy approach being taken. Overall does not conform with NPPF and recommends to publish a 'deliverability test' for testing soundness of IDP.

Object

Representation ID: 1286

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policies covering the Green Belt (Policy DS1) and Open Countryside (Policy DS2) are developed through out of date data and insufficient technical evidence.

Object

Representation ID: 1287

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policies covering the Green Belt (Policy DS1) and Open Countryside (Policy DS2) are developed through out of date data and insufficient technical evidence.

Goldfinch TPS view the Policy DS1 is too prescriptive and needs to maximise development potential of sustainably-located infill sites and make effective use of urban brownfield land sites. Policy DS1 is considered restrictive and lacks flexibility with the policy depending on individual site circumstances, assessing sites on their own planning merits. Goldfinch concerns into the lack of Urban Capacity Study for the Black Country.

Goldfinch express considerable concerns that Policy DS2
promoting unsustainable patterns of development will deliver ‘landscape-scale’ ecological habitat damage to the local area.

The proposed policy wording and paragraphs does not conform with NPPF/PPG.

Object

Representation ID: 1288

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policy DS4 - Longer Term Growth Aspiration for a New Settlement are developed through out of date data and insufficient technical evidence.

Object

Representation ID: 1289

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policy DS3 - The Spatial Strategy to 2038 are developed through out of date data and insufficient technical evidence.

Object

Representation ID: 1290

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning polices SA1 - SA4 are developed through out of date data and insufficient technical evidence.

Object

Representation ID: 1291

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policy SA5 are developed through out of date data and insufficient technical evidence.

Object

Representation ID: 1292

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch Town Planning Services (West Midlands) express concerns about the ‘level and scale of growth’ of amount of new pitches being proposed across what is essentially a sensitive, heavily rural small District. Concerns to whether the small rural village settlements have the scale required infrastructure facilities and services in place to serve and support the sites and the level of growth impacts to the landscape within the District. Goldfinch express concerns that sites do not have the level of required infrastructure, services and
facilities in place such as a wide range of shopping facilities, cultural facilities, a range of employment infrastructure, sufficient healthcare facilities and adult and children’s welfare facilities. Good levels of high quality public transport facilities to help promote sustainable travel choices.

Goldfinch question to the high levels of growth being suitable over the long term and question the deliverability of the high amounts of pitches being proposed.