Publication Plan November 2022

Object

Representation ID: 5032

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The level of estimated housing need being proposed within the Publication Stage Report (Regulation 19) (November 2022) within the emerging Local Plan Review across the South Staffordshire District is far too excessive and is based on heavily out-of-date, highly questionable and insufficiently robust evidence.
We believe it would be harmful to the character, quality of life, economy and environmental quality of wider South Staffordshire District not to reduce the housing figure to a number significantly below 10,000 new homes by the year 2039.
Concerned that insufficient attention has been given to the cumulative impacts of these huge levels of new residential development being proposed within the South Staffordshire District.
Given the recent Autumn 2022 collapse of the Black Country Plan (BCP) (Review). Secondly, South Staffordshire District Council’s Publication Stage Report (November 2022) has failed to take into account the December 2022 substantial shift in central government (London) latest housing policy in relation to United Kingdom (UK) housing targets as part of a central government (London) recent political announcement made on the 6th December 2022.
The Local Planning Authority is therefore taking forward an insufficiently robust and unsound Local Plan Review forward, in direct conflict with the tests of 'Soundness' for Local Plan-preparation as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021).
Concerns about the deliverability of the housing figures and employment land deliverability being proposed within the emerging Local Plan Review at a time when the local area is being adversely affected by one of the worst economic recessions of a scale and severity not experienced across the local area and the wider United Kingdom (UK) for the last 300 years. This 300-year-economic-recession-event has not been shaped into Local Plan-preparation

Object

Representation ID: 5034

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Financial volatility in the residential mortgage market since late September 2022 due to high interest rates, combined with the year 2022 cost-of-living-crisis, severe UK economic recession, and Russia’s Spring 2022 invasion of Ukraine. The Council are taking forward undeliverable housing site allocations into the emerging Local Plan Review which may not all be deliverable in a severe economic recession.

As a result, the Council’s planning policy stance on these issues is no longer fit-for-purpose, no longer defendable or sufficiently robust, and is in direct conflict with guidance reinforced within paragraphs 16 (indent b), 31, 35 (indents b and c), and 82 (indent d) of the Revised NPPF (2021).
The emerging Local Plan Review Publication Stage Report (Regulation 19) (November 2022) is currently failing the ‘proportionate evidence’ test as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021).
It is quite clear that the Plan is not deliverable over the Plan-period. On this basis, the emerging Local Plan Review Publication Stage Report (November 2022) is therefore failing Revised NPPF (2021) paragraph 16 (indent b) and the ‘deliverability’ test as reinforced within paragraph 35 (indent c) of the Revised NPPF (2021).
By relying on heavily out-of-date background supporting technical evidence and by refusing to remain sufficiently flexible and respond to rapidly changing adverse economic circumstances, the emerging Local Plan Review is being prepared in a way that is in direct conflict with paragraphs 31 and 82 (indent d) of the Revised NPPF (2021).
The Council is taking forward an unsound, undeliverable, and insufficiently robust Local Plan Review to the forthcoming Examination in Public (EIP) stage.

Object

Representation ID: 5035

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Sustainability Appraisal (SA) being used to support South Staffordshire District Council’s Publication Stage Report (Regulation 19) (November 2022) emerging Local Plan Review has failed to consider all reasonable alternatives to the spatial strategy – There is a lack of certainty about the delivery of employment uses at a time when the South Staffordshire District, the wider West Midlands Region, and wider UK is facing a 300-year-economic-recession-event as a result of the global coronavirus pandemic (COVID-19), and as a result of Russia’s Spring 2022 ongoing invasion of Ukraine. There is also a lack of certainty concerning the delivery of major levels of new housing development across the district during the severe economic recession described above and during a period of severe volatility in the residential mortgages market.
Contend that the Sustainability Appraisal (SA) process is clearly unsound and is not legally compliant, and therefore fails various tests of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indents b – it is not based on proportionate evidence), (indent c – failing the deliverability test), and (indent d – it is failing to promote the most sustainable patterns of development) of the Revised NPPF (2021). The approach taken within the SA is also in direct conflict with paragraphs 31 (it is not based on sufficiently robust and up-to-date evidence) and 82 (indent d – the SA is failing to shape into its preparation the huge and rapid shift in adverse economic circumstances now affecting the district) of the Revised NPPF (2021).

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).

Object

Representation ID: 5037

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 11
the Green Infrastructure evidence being used by the Council is far too vague, unclear, meaningless, insufficiently robust, and fails to respond effectively to paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform Local Plan preparation and highly contentious spatial planning policy considerations, which will deliver thousands of new homes immediately alongside highly sensitive landscape-scale wildlife corridors. Such as the South Staffordshire Railway Walk in Lower Penn, which contains critically important bat roosts within areas of sensitive deciduous broadleaved woodland. The Council is taking forward an unsound policy (based on highly questionable, vague, meaningless and insufficiently robust evidence) which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021). Object to the continued poor quality of the evidence base being used by the Council to support Local Plan preparation.
The Local Plan is not being informed by sufficiently robust green infrastructure evidence. In particular, robustly-based wildlife corridor green infrastructure assessments as required by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The emerging Local Plan Review assumptions are therefore based on flawed, insufficiently robust and missing evidence.

Object

Representation ID: 5038

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 1

Given South Staffordshire District Council’s previous under-performance on delivering natural green space environmental improvements across the district we have no confidence that the Council has the technical skills, ability, interest or desire to deliver environmental improvements. The Council is therefore taking forward an undeliverable policy approach which it has no intention of ever delivering, therefore conflicting with guidance in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021).
Object to the continued poor quality of the evidence base being used by the Council to support Local Plan preparation.

Object

Representation ID: 5039

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 2
South Staffordshire District Council has failed to take into account the recent Autumn 2022 collapse of the emerging Black Country Plan (BCP) (Review) (2022) and the subsequent massive void and uncertainty now created in terms of the level of estimated unmet housing needs present across the (GBBCHMA). We have concerns about this incompetent approach being taken to Local Plan-preparation within the South Staffordshire District. South Staffordshire District Council needs to finally accept that the GBBCHMA data is now no longer reliable, is heavily out-of-date, no longer sufficiently robust, and no longer provides credible or fit-for-purpose evidence to inform future Local Plan-preparation work across the district going forward. The Council’s Plan making approach is therefore not based on ‘proportionate evidence’ in direct conflict within test of ‘Soundness’ as reinforced within paragraph 35 (indent b) of the Revised NPPF (2021). The Plan making approach is also failing to use the most robust and up-to-date evidence, in direct conflict with paragraph 31 of the Revised NPPF (2021). As well as taking forward undeliverable unmet housing needs forecasts information, in direct conflict with paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021).
Object to the continued poor quality of the evidence base being used by the Council to support Local Plan preparation. We also continue to object to the “incapable” management and leadership approach being taken towards Local Plan preparation work by South Staffordshire District Council. It is important that these failings now come to an end.

Object

Representation ID: 5040

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 4
By promoting heavily urbanising major residential development across sensitive greenfield sites within areas of open countryside, we maintain our view that the Publication Stage Report (November 2022) is promoting inappropriate, damaging and unsustainable patterns of development within the district, in direct conflict with sustainability development focused guidance reinforced in paragraphs 7, 8, 10, 11 (indent a), 16 (indent a), 35 (indent d), 38, 119, and 120 (indents d and e) of the Revised NPPF (2021).
The proposed housing sites within the Publication Stage Report (November 2022) are proposing a net site density level of 35 dwellings per hectare (dph) across sensitive greenfield sites. This is fairly high-density residential development for these sensitive greenfield sites within the Green Belt countryside, and will therefore result in future new housing development site layouts coming forward which would be heavily urbanised and therefore fail to deliver any meaningful on-site biodiversity/ nature conservation enhancement features and climate change mitigation benefits.
The ongoing failure and continued refusal to promote the most sustainable patterns of new housing development across the district, means that the emerging Local Plan Review is therefore vulnerable to potential future Legal challenge at the later Examination in Public (EIP) stage - against the ‘Sustainability tests of soundness’ for Local Plan preparation, as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).

Object

Representation ID: 5041

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 5
We have concerns that the Council considers that it will be creating healthy communities. To be perfectly clear, the new residential communities being proposed through major housing-led urban extensions within the open countryside will be heavily isolated from existing services and public open space provision, and given their isolated position, will be heavily car dependent. We have Council’s that the Council’s Sustainability Appraisal (SA) process has failed to recognise these critically important sustainability issues. This underlines the ongoing failure and continued incompetence being taken towards Local Plan. Both the Sustainability Appraisal (SA) and this policy is unsound.

Object

Representation ID: 5042

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 11 (BNG)
Not one of the new build private sector residential developments delivered within the district over the last 10 years has incorporated a single bat brick or swift nest box brick within external facing brickwork. If the Council cannot even deliver one single bat brick within private sector new build residential schemes over the last 10 years, we have no confidence that the Council has any interest in delivering meaningful BNG within the district going forward. This incompetent planning policy approach cannot be allowed to continue within the district.
By incorporating sufficient new habitat creation measures within new housing development proposals. We are disappointed that the Council’s Planning Policy and Development Management Teams continue to promote poor quality forms of new housing developments across the district, which fail to effectively respond to BNG focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021).
By incorporating sufficient new habitat creation measures within new housing development proposals. We are disappointed that the Council continues to promote poor quality forms of new housing developments across the district, which fail to effectively respond to BNG focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021).