Publication Plan November 2022

Object

Representation ID: 5070

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council’s existing ‘Open Space Audit Assessment Report’ (adopted October 2019) (Open Space Needs Assessment) (the Green Space Audit) forms insufficiently robust background technical evidence and fails to robustly respond to requirements of paragraphs 31 and 98 of the Revised NPPF (2021).
Put quite simply, the Council’s existing Green Space Audit (adopted 2019) does not give sufficiently clear and meaningful steer and direction, and does not provide robust recommendations to help inform Local Plan-preparation work going forward. In respect of the identification future open space needs required for the local area. These are critically important issues which should inform open space policy direction within the emerging Local Plan Review, and help inform the approach taken towards spatial planning across the district.
These future public open space supply issues (e.g. what are the future needs for open space provision required by a significantly expanded new residential population (aswell as existing residents living within long established residential communities) over the lifespan of the new Local Plan, extending up until the year 2039) are critically important, in order to help promote the future delivery of more sustainable residential communities. Which are well-served and have good access to a range of conveniently located different types of public open space provision. This is important to help support community well-being, community cohesion and integration, help support more physically active healthy lifestyles, as well as support biodiversity.
Highlights health benefits linked with open space. These were made even more apparent during the pandemic.
The Council is allowing insufficiently robust Green Space background technical evidence to be taken forward to inform Local Plan-preparation work.
By taking forward an insufficiently robust evidence base as referred to above, the Council is failing in its duty to protect the health of its existing and future new local residents by ensuring that there is a sufficient supply of important public open space areas, close to heavily populated residential areas and within easy reach of the various major new housing site allocations being proposed within the emerging Local Plan Review.

Object

Representation ID: 5071

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Substantial failings taken in the approach to public consultation and engagement with key stakeholders. Withholding vitally important and key pieces of information (e.g. representation previously received 12 months ago by the LPA to the Autumn 2021 Preferred Options Stage Report public consultation) from the public domain, placing members of the public, community pressure groups, local businesses, rural landowners, Duty to Co-operate partners, and other key stakeholders at a considerable disadvantage when trying to respond to this latest November 2022 Publication Stage Report consultation.
Planning Policy webpage insufficiently clear. Impossible to locate Publication Stage Report (Regulation 19) (November 2022) public consultation document on the Council’s webpage.
It is near on impossible to locate the South Staffordshire District Council’s Publication Stage Report (November 2022) public consultation document on the Council’s Planning Policy webpage. In order to achieve effective public consultation, the document should be clearly viewable on the Council’s Planning Policy webpage. This is not the case.
The above issues will place local communities, the local South Staffordshire business community and other key stakeholders at a considerable disadvantage when trying to respond to the Plan.

Comment

Representation ID: 5072

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Consultation Portal (Opus Consult) Local Plan consultation

Have concerns in relation to the use of the Consultation Portal (Opus Consult) which is being used by the Council to support Local Plan preparation. The Local Plans Consultation Portal (Opus Consult) is unclear and highly confusing for members of the public, community pressure groups, local businesses and other key stakeholders. The Consultation Portal is not fit-for-purpose.
This creates a highly restrictive approach and forms a barrier to effective community engagement. These types of public consultation portals, which are both highly ineffective and unnecessarily complex, are not effective ways for Local Planning Authorities (LPA’s) to consult local communities for Local Plan Reviews.

Object

Representation ID: 5073

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Local communities, Duty-to-co-operate contacts and other key stakeholders have been fully obstructed by the LPA from viewing the earlier Representations made by respondents to the Autumn 2021 Preferred Options Stage Report earlier public consultation stage, which closed 12 months ago on the 13th December 2021.
The Council has failed to place the Representations received to the earlier Autumn 2021 public consultation stage for the Preferred Options Stage Report (November 2021) Local Plan consultation which closed on the 13th December 2021 within the public domain. This is not a proper, fair and reasonable way for a Local Planning Authority to conduct a Local Plan Review, and is in direct conflict with the approach expected by paragraph 16 (indent c) of the Revised NPPF (2021).
This highly obstructive approach taken towards Local Plan preparation (by fully withholding key pieces of information from the public domain over an extended 12 month period – e.g. fully withholding all of the Preferred Options Report (November 2021) Representations from the public domain during the last 12 months) has placed Duty-to-co-operate partners and the other key stakeholders referred to above at a considerable disadvantage when trying to respond to this latest Autumn 2022 Regulation 19 public consultation stage.
This underlines the ongoing failure and continued incompetence of the Council in relation to its approach taken towards Local Plan-preparation and its failure to sufficiently involve key stakeholder in the Local Plan making process.
As a planning consultancy and key stakeholder, we strongly object to the way that we have been obstructed and totally excluded from the Local Plan making process by the Council, by not being able to view the earlier Representations made to the earlier Preferred Options Stage Report (November 2021) public consultation

Object

Representation ID: 5074

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Publication Stage Report (Regulation 19) public consultation stage is being undertaken on the run up to the Christmas holiday period and during the middle of a December 2022 UK wide postal strike

We are surprised that the Council’ has decided to undertake this critically important public consultation stage over the Christmas holiday period. The public consultation stage closes on the 23rd December 2022 just one day away from Christmas day. Running a critically important Local Plan consultation over the Christmas holiday period will have a damaging impact on key stakeholder engagement and will have a detrimental effect on public participation rates.
The public consultation stage is also taking place during the middle of a UK wide postal strike.

Object

Representation ID: 5075

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Whilst we recognise that the above ‘pitch needs’ figures/ requirements have been informed by evidence to emerge from the Council’s updated Gypsy and Traveller Accommodation Assessment (GTAA) technical evidence base document, the figure of 121 Gypsy and Traveller pitches required within the district over the new Local Plan period does appear a little high and overly excessive. Particularly, given the heavily rural character and appearance of this rural district.
The scale of growth being proposed by the LPA will have a significantly damaging impact on the areas special rural landscapes, its local distinctiveness, its special rural identity, by introducing significant adverse and damaging landscape impacts into the districts sensitive countryside as a result of excessive pitch numbers.
The Council is also promoting sites to isolated parts of the district which do not have the necessary range of services and infrastructure facilities in place to serve new gypsy and traveller site, particularly as they further expand over the coming years.
Unsustainable levels of pitch numbers are being proposed 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 wildlife habitats, and place unreasonable pressure loads on road infrastructure, existing healthcare and welfare facilities, and local schools.

Object

Representation ID: 5076

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Article 2 of The Human Rights Act Legislation – The Right to Life - Placing local communities at increased risk of exposure to harmful levels of air pollution (therefore contravening their Right to Life) by actively encouraging promoting unsustainable patterns of residential development, which will be highly dependent on private motor car journeys given their isolated locations.
In total, 10,000 new homes are being proposed across the district within the emerging Local Plan Review during its shelf-life from the years 2018 to 2039. Based on 3 cars per household, this would generate an additional 30,000 thousand cars on the districts already heavily constrained and pressured road networks. Which are already at capacity and unable to cope with this significant increase in vehicular traffic.
Types of air pollution typically associated with vehicular traffic (cars, vans and lorries) include Nitrogen Dioxide (NO2), Fine Particulate Matter (PM2.5), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs) or hydrocarbons (HCs) and nitrogen oxides (NOx). These pollutants are all harmful to human health and help cause lung disease.
By placing thousands of local residents within the South Staffordshire District at increased risk of developing lung disease due to exposure to significantly increased levels of harmful air pollution from the huge levels of vehicular traffic that will be generated from considerable levels of new housing development across the district. The Plan is contravening Article 2 of the Human Rights Act Legislation which protects a person’s right to life.
Public authorities should also consider your right to life when making decisions that might put you in danger or that affect your life expectancy.
the huge and excessive levels of new housing development being proposed within South Staffordshire District Council’s Publication Stage Report (Regulation 19) (November 2022) will breach the basic Human Rights of local residents living within the South Staffordshire District to be able to breathe clean and healthy air. As such, the emerging Local Plan Review is therefore in direct conflict with Article 2 of the European Convention on Human Rights (The Human Rights Act) Legislation.
Given the above concerns, the emerging Local Plan Review is also in direct conflict with air quality focused guidance as reinforced within paragraph 174 (indent e) of the Revised NPPF (2021), and is also failing the ‘Sustainability test’ for Local Plan preparation tests of Soundness as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021).