Publication Plan April 2024

Object

Representation ID: 7333

Received: 31/05/2024

Respondent: Save the Seven Cornfields Campaign Group

Legally compliant? No

Sound? No

Duty to co-operate? No

The Save the Seven Cornfields Campaign Group (SSCCG) and Penn Resident’s Association (PRA) have many concerns that the South Staffs Council’s Publication Plan (Regulation 19) (April 2024) public consultation report is an unsound plan. It is insufficiently robust. It fails the various tests of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (a to d) of the Revised NPPF (December 2023). SSCCG & PRA object to the continued poor quality and lack of universal objectivity of the evidence and forecasting base. The lack of presentation of assumption and testing of assumptions is another concern. Furthermore, given the overall evidence and success of a ‘brownfield first’ strategy in the West Midlands Combined Authority and the Black Country areas, we are compelled to raise the issue about the lack of monitoring and review of brownfield developments in the West Midlands Combined Authority and Black Country and the form and scope of data and information presentation of the Plan being used by the Local Planning Authority to support Local Plan preparation. During the Local Plan preparation period from beginning to present time, the Brownfield site reclamation for housing has been significantly different. This in itself reduces the extent of the Duty to Co-operate. In addition the build high storey option in Wolverhampton City Centre has gained significance on the basis of the application of this strategy in Manchester and Birmingham. This type of development best suits first time buyers who normally can ill afford the luxury of a car to commute to employment or public transport hubs. Green Belt development is very rarely suitable for first time buyers. The model for consultation is flawed and a more participative model with an emphasis on a bottom-up approach would have captured more of the desires, perspective and problems of residents and other key stakeholders. There are grave concerns that SSDC is far too strident in pushing and proposing large and unnecessary levels of unsustainable and environmentally damaging new sites for housing development, employment land plus gypsy and traveller pitches development across the South Staffordshire District. The plan is, therefore, not promoting the most environmentally sustainable and inclusive perspective. It conflicts with the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation as stated within paragraph 35 (d) of the Revised NPPF (December 2023). In summary the South Staffordshire Local Plan: Has not been Positively Prepared. The Housing forecast aggregate numbers are questionable. These are presented as Objective, unquestionably valid and foundational. In fact, these are highly subjective and, therefore, the release of the Green Belt is Not Justified as reasonable and logically proved. The SSLP is inconsistent with National Policy.