Publication Plan November 2022

Object

Representation ID: 5043

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 12
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 approach being taken within the emerging Local Plan will worsen the effects of the Urban Heat Island Effect and cause increased levels of surface water run-off (creating flood risk pressures), given that greenfield sites (green space vegetated surfaces) within the open countryside will be replaced by heavily urbanising brick, concrete, tile and macadam surfacing. We have concerns that the Council appears to have no understanding of the urban heat island effect or surface water run-off issues.
The position is perfectly clear, the emerging Local Plan Review will promote highly damaging and unsustainable patterns of new housing and employment land development across the district, contrary to the ‘Sustainability’ test of ‘Soundness’ as reinforced in paragraph 35 (indent d) of the Revised NPPF (2021). The Council is taking forward an unsound Local Plan Review.

Object

Representation ID: 5044

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Green Infrastructure evidence being used by the Council, provides meaningless evidence, is insufficiently robust, and fails to respond effectively to requirements of green infrastructure guidance expected by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The position is perfectly clear, the Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform critically important housing-led spatial planning policy considerations across the district. The Council is taking forward an unsound policy 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.

Object

Representation ID: 5045

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The 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).

Object

Representation ID: 5046

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

We have concerns that the Council will fail to deliver this policy, given the low-quality approach taken to other new build residential developments across the district over the last 15 years. Remain unconvinced that this policy will be delivered effectively across the district. The Publication Stage Report (November 2022) is promoting inappropriate, damaging and unsustainable patterns of development within the district, contrary to sustainable development focused guidance reinforced within 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). As well as in direct conflict with green infrastructure (wildlife corridor focused) guidance reinforced within paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021).

Object

Representation ID: 5047

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The tables appearing on pages 32 to 33 contain misleading information. The total numbers of new housing adds up to 10,188 dwellings, not the 9,098 being stated. This misleading approach to Local Plan preparation conflicts with guidance in paragraph 16 (indent c) of the Revised NPPF (2021) which confirms that: “…Plans should (indent c) be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees…”
The above misleading housing figures information will place local communities at a considerable disadvantage when trying to respond to the Publication Stage (Regulation 19) (November 2022) public consultation stage, in direct conflict with paragraph 16 (indent c) of the Revised NPPF (2021).

Object

Representation ID: 5048

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 5
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) (the SA is not fit-for-purpose or sufficiently robust) process has failed to recognise these critically important sustainability issues. Both the Sustainability Appraisal (SA) and the policy itself within the Publication Stage Report is unsound.
The Council is also using an insufficiently robust Green Space Audit (Open Space Needs Assessment) to inform and support Local Plan preparation, that fails to meet the requirements of paragraph 98 of the Revised NPPF (2021).
Given that highly unsustainable new residential communities will be created, in isolated site locations, poorly served by publicly accessible green space resources, the Council’s Publication Stage Report (2022) will make the obesity epidemic far worse, will help increase cases of Types 1 and 2 Diabetes, coronary heart disease, lung disease due to increased levels of air pollution from thousands of additional cars placed onto the district’s already pressured road networks, etc. We have concerns that the Council’s proposed spatial planning policy approach will make health inequalities far worse across the district.

Object

Representation ID: 5049

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

RE: Gypsies and travellers and travelling showpeople, page 44 (paragraphs 5.51 to 5.53), and page 51 Policy DS5: The Spatial Strategy – Gypsy, Travellers, and Travelling Showpeople, and pages 80 to 82 (paragraphs 6.36 to 6.40), 101 to 103 (paragraphs 7.23 to 7.25).

Unsustainable levels of new pitch numbers are being proposed across the district which will promote inappropriate, damaging and unsustainable patterns of development within the local area, and cause significant residential amenity conflicts with the settled community, as well as damage sensitive rural landscapes and fragile wildlife corridors. These gypsy and traveller planning policy concerns are already covered within this wider December 2022 Representations Statement.

Object

Representation ID: 5051

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Relates to: Employment land, pages 44 to 47 (paragraphs 5.54 to 5.63).

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 the wider UK is facing one of the worst economic recessions of a scale and severity not experienced across the South Staffordshire District for the last 300 years. This huge adverse shift in economic circumstances will affect both the future NEED and DEMAND for new employment land across the district.
A rigidly fixed template for the future spatial distribution of new housing and new and existing employment land development across the district has already been decided by the LPA and is being forced-through and used as the place shaping agenda going forward, from the now heavily out-of-date existing adopted Core Strategy (adopted 2012).
Given the above issues, we contend that the Employment land policy approach being taken forward within both the Publication Stage Report (November 2022) and the accompanying not fit-for-purpose Sustainability Appraisal (SA) background evidence supporting Local Plan preparation, are clearly both unsound and are not legally compliant. The Plan-making approach 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).

Object

Representation ID: 5052

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The planning policy approach being taken towards new employment land needs has failed to remain sensitive and sufficiently flexible to the 300-year economic recession event now facing the district. The Council’s planning policy stance on these issues is therefore no longer based on a sufficiently robust platform of up-to-date economic evidence. The LPA has conveniently chosen to ignore the presence of a huge economic recession now facing the local area, in direct conflict with guidance reinforced in paragraphs 31, 35 (indent b), and 82 (indent d) of the Revised NPPF (2021).
Information relating to unmet needs of the Black Country is no longer sufficiently based on a platform of sufficiently robust and defendable evidence, given the recent Autumn 2022 collapse of the emerging Black Country Plan (BCP) (Review). We are concerned that the Council has failed to shape this important matter into Local Plan preparation within both policies within the Publication Stage Report (November 2022) and the insufficiently robust Sustainability Appraisal (SA) which is being used to inform Local Plan-preparation.

Object

Representation ID: 5053

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

This highly aspirational and vague policy is being brought forward in a highly uncertain economic climate, when the district is being adversely affected by a long-term 300-year-economic-recession-event as discussed further above. The approach within this highly questionable and insufficiently robust policy is therefore failing the ‘deliverability’ tests as reinforced within paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2021). The approach is also contrary to guidance reinforced in paragraph 82 (indent d) of the Revised NPPF (2021), given that the huge levels of new housing development being proposed in this highly aspirational policy have failed to take into account the rapid shift in adverse economic circumstances now facing the district.
This policy approach will also promote the delivery of very isolated new residential communities which will be car dependent, as well as cause significant built development encroachment pressures across sensitive areas of open countryside.
The South Staffordshire District is being over-loaded with an unreasonable and unsustainable amount of new housing development. This considerable over-development and imbalance will promote inappropriate, highly damaging and unsustainable patterns of development within district. Resulting in the loss of sensitive arable farmland, as well as damage sensitive rural landscapes and sensitive wildlife habitats.
The continued failure and ongoing refusal to promote the most sustainable patterns of development within the emerging Local Plan Review within the South Staffordshire District, means that the emerging Local Plan Review is currently failing the ‘sustainability’ test for Local Plan preparation tests of ‘Soundness’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).