Publication Plan April 2024

Object

Representation ID: 5851

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The historic environment policies are not sufficiently robust as they are supported by a heavily out-of-date and insufficiently robust set of Management Plans/ Conservation Area Character Appraisals. One of the CACA documents is 51 years old since it was last surveyed.

Object

Representation ID: 5852

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The majority of new housing development and commercial development proposals which have come forward within the district over the last 10 years have all failed to include effective on-site biodiversity enhancement features. Such as micro-habitat scale wildlife features like bat bricks, swift nest box bricks and house sparrow terraced nest box bricks incorporated into external facing brickwork of new buildings, sustainable urban drainage (SDS) wetland habitat creation measures, creation of new wildlife corridors, etc.

Object

Representation ID: 5853

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The impacts of this proposed scale of growth on existing sensitive small rural village settlements which lack the range of services, facilities and highway infrastructure necessary to accommodate this proposed scale of growth in new pitch numbers is very concerning. The residential amenity impacts on the existing settled population will be considerable. This scale of growth in new, totally excessive high pitch numbers being proposed would appear to be more appropriate and suitable within a large urban area rather than a small, heavily rural district like South Staffordshire. This scale of growth in new pitch numbers does not appear to be sustainable in a heavily rural area,

Object

Representation ID: 5854

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Continue to have concerns in relation to the use of the Consultation Portal (Opus Consult) Local Plan consultation system. The Council has also deliberately obstructed local community groups, members of the public, rural landowners, local businesses, private sector town planning consultants, housing developers, environmental groups and other key stakeholders from the Local Plan-making process by deliberately keeping previous Representations made to earlier rounds of public consultation out of the public domain. The level of unreasonable obstruction referred to above, continuing to withhold critically important Representations previously made to earlier stages of the Local Plan from public view, strongly conflicts with guidance reinforced within the Local Government Ethical Standards.

Object

Representation ID: 5855

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Main concerns relate to the considerable adverse environmental impacts of this major transport infrastructure scheme, the considerable rural landscape impacts, wildlife habitat destruction, considerable adverse climate change impacts, given the huge levels of Heavy Goods Vehicles (HGV) traffic congestion which will be generated by the scheme. Congestion on local road networks as a result of HGV articulated lorries parking on nearby highway networks during the evenings will also cause considerable environmental problems, etc. The proposals will cause environmental vandalism on an industrial-scale in extensive areas of open countryside near Junction 12 of the M6.

Object

Representation ID: 5856

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The WMI proposals combined with the delivery of 4,086 new homes across the district over the Plan period will further increase and intensity localised air pollution problems within a part of the district, which is already suffering from very poor air quality problems. Due to the close proximity of the M6 motorway network, which is one of the busiest and most heavily congested sections of highway networks from Junctions 10 of the M6 (Walsall) to Junction 12 of the M6 (South Staffordshire) within the whole of Europe. And which creates significant levels of Nitrogen Dioxide (NO2) and Fine Particulate Matter (PM2.5) air pollution, which are both harmful to human health.
Given the severe adverse air quality health impacts on nearby heavily populated residential areas, the proposals discussed above will strongly conflict with guidance reinforced within paragraph 174 (indent e) of the Revised NPPF (2023), which confirms that: “…Planning policies and decisions should contribute to and enhance the natural and local environment by (indent e) preventing new and existing development from contributing to, being put at
unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality…”

Object

Representation ID: 5857

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Goldfinch Town Planning Services has concerns in relation to the “in-combination” effects of air pollution from the West Midlands Freight Interchange (WMI) and the resultant traffic congestion of HGV lorry movements to and from the WMI site. Combined with proposals to deliver of 4,086 new homes within the South Staffordshire District, and the subsequent severe traffic congestion implications on already heavily congested highway networks, which cannot cope with this scale of new traffic growth. These ‘in-combination’ effects have been completely overlooked and have not been sufficiently taken into account by the Council’s Planning Policy Team. The Local Plan Review is therefore based on insufficiently robust evidence, and is failing the ‘Sustainability’ test of Soundness as specified within paragraph 35 (indent d) of the Revised NPPF (December 2023).

Object

Representation ID: 5862

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

South Staffordshire District Council has a Legal duty under Article 2 of the Human Rights Act to ensure that the health of its local residents is protected when the Council is making decisions on formal planning applications, and when the Council is preparing its emerging Local Plan Reviews (Development Plan Reviews). The Council’s failed and ineffective approach taken towards protecting local air quality when preparing Local Plan Reviews and when making decisions on formal planning applications coming forward near to Junction 12 of the M6 motorway network, is breaching the human rights of those local residents living within nearby heavily populated residential communities. As well as destruction caused to sensitive wildlife habitats.

Object

Representation ID: 5863

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The WMI proposals combined with the delivery of over 4,000 new homes strongly conflict with Article 2 the Human Rights Act which reinforces that "...Everyone's right to life shall be protected by law..." The human rights of those local residents living within nearby established residential estates (located to the east of the WMI) is being substantially harmed and damaged, in clear and direct material breach of Article 2 of the Human Rights Act, which protects a person’s right to life. These proposals are therefore breaching the Human Rights of local residents due to the considerable health impacts associated with poor air quality. There has been a substantial failure to take on board the Human Rights Act legislation throughout the entire Local Plan Review process. The Council is taking forward a failed, not-fit-for-purpose and insufficiently robust Local Plan Review forward to the later Examination in Public (EIP) stage.

Object

Representation ID: 5865

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The emerging set of Development Management (DM) policies contained within Publication Stage Report (2024) appear to be of a poor quality (poorly written, lengthy and unclear) and are therefore unlikely to assist colleagues in the Council’s Development Management (DM) Team