Publication Plan April 2024

Object

Representation ID: 5866

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Goldfinch Town Planning Services maintains its view that the complex economic landscape described above has not been effectively shaped into the policy drafting being taken forward within South Staffordshire District Council’s Publication Stage Report (April 2024). In particular, in relation to employment land policy and centres/ retail policies. As an interested outside observer we remain unconvinced that South Staffordshire District Council’s Publication Stage Report (April 2024) will provide effective and deliverable planning policy solutions and interventions to prevent further levels of decline within many of the district’s centres. As a key local stakeholder, we consider that the policy approaches on centres and retail lack sufficient ambition and do not provide effective planning policy interventions to help support struggling retailers in many of the district’s centres.

Object

Representation ID: 5868

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Paragraph 7.7 (page 77) of the Publication Stage Report (April 2024) - Affordable Housing 29% proposed planning policy threshold: The 29% affordable housing planning policy threshold being proposed within the emerging Publication Stage Report (2024) is highly onerous, totally unreasonable, no longer justified, and no longer sustainable, and will have a highly damaging financial impact on the future viability and deliverability of new housing development schemes coming forward across the South Staffordshire District. within the emerging Local Plan Review, proposed affordable housing planning policy thresholds should therefore be significantly reduced downwards to 5% to reflect guidance reinforced within paragraphs 16 (indent
b: plans should be aspirational but also deliverable), 31 (policies should be based upon the most up-to-date and robust evidence), 35 (indents b: Local Plans should be based on proportionate evidence – indent c: contain deliverable policies) and 86 (indent d: policies should remain flexible to enable a rapid response to changes in economic circumstances) of the Revised NPPF (December 2023).

Object

Representation ID: 5869

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Indent c - Nature Recovery Network Mapping: We continue to object to the proposed use of the Nature Recovery Network Mapping. This ecological network mapping is too vague, provides weak technical evidence, is insufficiently robust, meaningless and unclear, and will therefore fail to effectively inform Local Plan preparation with a suitably robust policy approach. It will also fail to respond effectively to wildlife corridor/ ecological network focused guidance as set out in paragraphs 102, 157 - 158, 180, 185 of the Revised NPPF (December 2023). This issue has already been covered in further detail within our earlier Representations.

Object

Representation ID: 5870

Received: 29/05/2024

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

This is a poorly written policy and will therefore provide an ineffective Development Management policy to protect sensitive open space areas. Similar to issues facing the Black Country Council Planning Policy Teams of Wolverhampton, Dudley, Sandwell and Walsall, South Staffordshire District Council does not appear to have any specialist in-house green space planning policy expertise. This will play into the hands of private sector housing developers and private sector planning consultants who will be able to exploit this situation at the DM planning application stage, and during Local Plan Review various Reg 18 preparation stages. As well as the Reg 19 Local Plan. preparation stage. Goldfinch Town Planning Services continues to be very
disappointed and concerned given that the above LPA’s no longer seem to value specialist green space planning policy expertise. This is letting down local communities and failing to promote climate change resilience within their areas, and making sensitive natural green space areas and outdoor recreational areas more vulnerable to future development pressures. It also means that specialist technical evidence base documents such as paragraph 102 NPPF (December 2023) compliant Green Space Audits (Open Space Needs Assessments) can no longer be prepared in-house.