Publication Plan November 2022

Object

Representation ID: 5513

Received: 22/12/2022

Respondent: Save the Lower Penn Green Belt (Action Group)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Not legally compliant, not sound, fails to comply with DtC.
Poor consultation processes contrary to NPPF requirements. Online meetings not available to people without PC and not long enough in length. Appointment based meeting inadequate, limited time slots and too restrictive for people who worked. No open public meetings. Sessions were poorly advertised.
Opus portal confusing, difficult to navigate and restrictive.
Poor quality evidence base, council decided on a high housing number which they have tried to retrospectively fit biased data.
Web based documents difficult to locate.
Spatial distribution is based on insufficiently robust and out of date technical evidence base.
No consideration given to the impact of economic recession.
Too much weight given by the District Council on report produced by Lichfields.
No detailed consideration to study produced by consultants on behalf of the action group.
10,000+ vacant homes in West Midlands conurbation.
Consideration needs to be given to changes in commuting patterns etc. following covid.
Current housing proposal is too high, is based on out-of-date housing needs forecasts. This is not sustainable and will negatively impact on amenity, landscapes and wildlife habitats.
Housing supply is being driven by a desire to increase council tax receipts with costs of infrastructure provision being borne by the adjoining conurbation.
Failed DtC, no evidence of an SPD, infrastructure delivery strategy or master plan.
2021 census results indicate lower number of households in Wolverhampton than 2014 ONS forecast.
Reg19 Plan has failed to take account of changes in Central Government planning policy including removal of need for mandatory housing targets.
Sustainability Appraisal
SA Objective 1: Lack of analysis of GHG emissions, no attempt to quantify and understand impact of CO2 emissions of site proposals.
SA Objective 2: Site 582 rated as high risk of surface water flooding. Adaptation to impacts of future climate change will be problematic and the site should be excluded from development.
SA Objective 3: Site 582 has a LNR along one of its boundaries. Assessment gives pre-mitigation impact as uncertain. This is contrary to stated methodology which indicates assessment should be minor negative.