Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 534

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Land located south of Racecourse Lane, Norton, Stourbridge should be removed from the Green Belt boundary within the Local Plan Review, and should be allocated as a major new sustainable urban extension to deliver housing for the various reasons highlighted below. This is a key issue and the main focus of Goldfinch Town Planning Services Local Plan Representation (December 2023).

Robust, defendable and up-to-date photographic evidence contained in this Local Plan Representation (December 2023) demonstrates that the Green Belt farmland located south of Racecourse Lane, Norton, Stourbridge is of a very low quality from a Green Belt landscape perspective, climate change mitigation perspective (e.g. given its intensively farmed character and severe shortage of existing tree cover) and biodiversity perspective, and has no significant or special historic environment landscape value. It forms an area of sterile intensively farmed countryside, where many features have since been removed from the farmland rural landscape over the last 50 years, due to intensive farming practices. Including miles of previous extensive hedgerow networks crossing pasture farmland, mature veteran and ancient trees from hedgerow networks, removal of woodland copses, wetlands, etc. This area has no special landscape merit. It should therefore be fully removed from the Green Belt boundary and developed for a new major housing-led sustainable urban extension south of Stourbridge. This site meets a range of sustainability criteria for major new housing development, given its immediate proximity to already long-established major residential communities within the Norton area (on its northern boundary), its excellent access to good quality public transport connections, and its close proximity to a main town centre location - Stourbridge Town Centre. Importantly, releasing this area from the Green Belt boundary within the Local Plan Review and developing this area for major new housing development would help to relieve significant urban cramming pressures and poor-quality environmental conditions currently affecting the environmental quality of the heavily constrained and congested Dudley Borough inner urban area. As well as help to significantly improve the resilience of the inner urban area to cope with future climate change pressures as discussed further below.

Given that the Green Belt farmland located south of Racecourse Lane, Norton, Stourbridge has no special rural landscape merit or historic environment landscape value, it does not therefore meet and robustly satisfy the Green Belt purpose as set out in paragraph 143 (indent d) of the Revised NPPF (2023). Continuing to defend this site on Green Belt landscape planning policy grounds is not a robust or defendable planning policy position to take within the emerging Local Plan Review going forwards.

Need: There is a NEED for this development proposal (to deliver a major new build housing-led urban extension on land located south of Racecourse Lane, Norton, Stourbridge) given the severe and chronic housing shortage currently affecting the Dudley Metropolitan Borough. For a number of years the borough has suffered from long-standing housing shortfalls and significant delivery problems associated with bringing forward major urban brownfield land within the inner urban area for major new housing development, due to significant site constraints, flood risk pressures, contaminated land, mine shafts, and vehicular access problems. The land located at Old Wharf Road on the northern edge of Stourbridge Town Centre and Daniels Land located opposite the Copthorne Hotel in Brierley Hill Strategic Centre are both good examples of the site constraints affecting existing major housing site allocations (identified in previous Local Plan Reviews) within the inner urban area, which have been allocated for housing for a number of years and already have planning consent for a number of years. But have both consistently failed to come forward.

Land located south of Racecourse Lane, Norton, Stourbridge should be fully removed from the Green Belt boundary within the Local Plan Review and should be allocated as a major new sustainable urban extension to deliver thousands of new homes to help relieve pressures and protect the environmental quality of the Dudley Borough’s inner urban area. Developing this site for major new housing development would help to boost the supply of new housing in a sustainable and deliverable site location consistent with guidance reinforced in paragraph 60 of the Revised NPPF (2023).

In total, 10,876 new homes are being proposed across the borough within the emerging Local Plan Review during its shelf-life up until the year 2041. Based on 3 cars per household, this will generate an additional 32,628 thousand additional cars on the borough’s inner urban area already heavily constrained, heavily congested and pressured road networks. We would therefore urge the LPA to re-consider releasing some Green Belt land via a major housing-led sustainable urban extension south of Racecourse Lane, Norton, Stourbridge to help relieve significant highway congestion pressures affecting the Dudley Metropolitan Borough inner urban area. This planning policy approach would help to improve the climate change resilience of the Dudley Borough inner urban area to future climate change pressures as discussed further below.

Goldfinch Town Planning Services considers that it is possible to provide compensatory measures to help provide new wildlife habitat features/ habitat enhancements to help deliver net gains for biodiversity, within high quality new build residential schemes- consistent with guidance in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2023).

Goldfinch Town Planning Services maintains its view that this is particularly possible and relevant when progressing new build housing development schemes coming forward on low-quality green space sites. Such as underutilised, low-quality former horse grazing paddock land, and for site locations coming forward within areas of severely ecologically damaged open countryside. Which have suffered from considerable and constant ecological habitat damage, as a direct result of years of uncontrolled mechanized industrial-scale intensive farming practices. Which has resulted in the widescale removal of features from the rural landscape which would have previously provided important and highly beneficial wildlife habitats. For example, such as farmland wildlife ponds and other wetland habitat features, extensive hedgerow networks previously crossing large-expanses of farmland, removal of veteran and ancient trees within hedgerow networks due to widespread hedgerow destruction. Loss of wild flower hedgerow field margins, small woodland copses, wildflower meadows, etc.

Up-to-date photographic evidence in this Local Plan Representation provides robust and defendable evidence to demonstrate that extensive areas of Green Belt farmland located south of Racecourse Lane, Norton, Stourbridge has particularly suffered from significant environmental damage as a result of 50 years of successive intensive farming practices, which have all resulted in the removal of miles of hedgerow networks, removal of woodland copses and blanket tree removal across vast areas of southern Green Belt countryside, wetland habitat features, mature veteran and ancient trees, wildflower meadows, etc. This has all created a vast, open, sterile, prairie style “severely ecologically damaged and heavily eroded rural landscape,” which now has no significant biodiversity interest.

There is therefore an significant opportunity to replace some of the threatened wildlife habitat features that have already been lost from this area of countryside, within a future new-build residential site layout coming forward as part of a future major housing-led sustainable urban extension, to help deliver net gains for biodiversity, consistent with the planning policy approach strongly encouraged in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b), and paragraph 180 (indent d) of the Revised NPPF (2023).

Guidance in paragraph 180 (indent d) of the Revised NPPF (2023) is perfectly clear in its view that development proposals whose primary objective is to conserve or enhance biodiversity should be strongly supported by Local Planning Authorities.

This biodiversity enhancement approach discussed above is also strongly supported and encouraged by guidance from the Birmingham and Black Country Local Biodiversity Action Plan (BAP), which, alongside the Birmingham and Black Country Wildlife Trust, are both highly supportive of new build housing development proposals which include measures which actively seek to support the recovery of vulnerable and highly fragile populations of Priority Wildlife Species, and the recovery of priority wildlife habitat features across the wider Birmingham and Black Country sub-region.

There is therefore a sufficiently robust, clear and compelling planning policy case to release the area of Green Belt farmland located south of Racecourse Lane, Norton, Stourbridge for a major new housing-led sustainable urban extension, in order to help deliver substantial new nature conservation habitat creation/green infrastructure benefits and climate change mitigation features (via significant new tree planting and wetland habitat creation features), within an area of currently severely ecologically damaged intensive farmland.

Object

Representation ID: 535

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Goldfinch Town Planning Services has significant planning policy concerns that the LPA is accommodating and taking forward completely undeliverable and unrealistic housing site allocations within the emerging Local Plan Review (2023/ 2024) which directly conflict with deliverability focused guidance set out in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2023). Paragraph 16 (indent b) of the Revised NPPF (2023) is perfectly clear in its view that: “…Plans should (indent b) be prepared positively, in a way that is aspirational but deliverable…” The tests of Soundness for Local Plan preparation as set out in paragraph 35 (indent c) of the Revised NPPF (2023) are clear that: “…Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: (indent c) Effective – deliverable over the plan period…”

Goldfinch Town Planning Services has major concerns in relation to the proposed spatial planning policy approach of focusing the proposed 10,876 new homes within the urban area within the Dudley Metropolitan Borough, and considers that in order to create sustainable communities and protect sensitive urban green space areas, reduce urban air pollution, and protect sensitive wildlife corridors within the inner urban area from built development encroachment pressures, and protect existing employment land sites from changes of use to new housing, there will need to be some Green Belt release within the Local Plan Review to form a sustainable major urban extension within the Green Belt immediately alongside established residential communities.

The emerging Sustainability Appraisal (SA) supporting background technical evidence base accompanying the emerging Local Plan Review and policies contained within the emerging Local Plan Review are both currently failing to address the critical climate change emergency now affecting the Dudley Metropolitan Borough inner urban area, by continuing to support a spatial planning policy approach that is forcing through 10,876 new homes solely into the inner urban area.

In the Dudley Metropolitan Borough, the main contributor to poor air quality is from the emissions produced by transport. The two most harmful are Nitrogen Dioxide (NO2) and Fine Particulate Matter (PM2.5). There is a particular problem of very poor air quality within the Dudley Borough inner urban area, given that existing road networks within this area are already heavily congested. The traffic highway congestion implications of focusing proposed 10,876 new homes within the urban area will be considerable. Given that existing road infrastructure networks within urban areas within the Dudley Metropolitan Borough are already heavily constrained and heavily congested with vehicular traffic. They have no capacity to accommodate this significant scale of new traffic growth.

Promoting 10,876 new homes solely within the urban area is not promoting the most sustainable patterns of new housing development and is therefore conflicting with the ‘Sustainability’ test as set out in paragraph 35 (indent d) of the Revised NPPF (2023).

We have concerns that insufficiently robust green infrastructure evidence is being used to support local plan preparation.

The urban cramming of 10,876 new homes solely into the inner urban area will result in the loss of extensive areas of sensitive urban green space areas which provide a critically important outdoor recreational resource, serving heavily populated residential areas within the inner urban area. Ensuring the ongoing planning policy protection of these sensitive publicly accessible urban green space areas is critically important in order to help tackle the worsening adult and childhood obesity epidemic which is now affecting the Dudley Metropolitan Borough and wider Black Country sub-region. It is important that these existing urban green space areas are protected, in order to help promote more sustainable patterns of development and to help support more physically active healthy lifestyles to address the local obesity epidemic, consistent with health focused guidance reinforced within paragraphs 8 (indent b), 92 (indents b and c), 93 (indent b), 97, 130 (indent f) and 185 of the Revised National Planning Policy Framework (NPPF) (September 2023). Securing the ongoing planning policy protection of these critically important urban green space areas provides exceptional circumstances to help support Green Belt release within the emerging Local Plan Review. The scale of new housing development being proposed within the inner urban area is just not sustainable or deliverable.

In recent years, the Black Country Council’s have now all lost specialist urban green space planning policy expertise, so these issues are considered important. Urban green space planning is a specialist and highly complex planning policy topic area, and many LPA’s across the UK do not place enough importance on this specific town planning skillset. Which is an alarming situation because many urban LPA’s are now in a position where they are having to now consider the release of urban green space areas for new housing development as the supply of previously-developed land sites (urban brownfield land) starts to run out within many LPA areas, and there is a chronic shortage of sites for new housing. Given that there is no longer specialist urban green space planning policy expertise in place to ensure that the right types of urban green space areas are protected and suitable urban green space sites released for new housing development, we have concerns that the loss of urban green space areas to a significant urban cramming spatial planning policy approach will not be properly managed and co-ordinated by the LPA. We have ongoing concerns that focusing major new levels of new housing development into the inner urban area is not feasible, not deliverable and will result in the extensive loss of sensitive urban green space sites. Which will mean that both the environmental quality and local communities health will suffer as a result within the inner urban area. The position is perfectly clear, there are now sufficiently robust exceptional circumstances in place for the LPA to now consider Green Belt release within this emerging Local Plan Review, in order to protect the environmental quality of the inner urban area.

Focusing 10,876 new homes within the inner urban area will cause environmental vandalism on an “industrial-scale” across large parts of the urban area, and will cause considerable levels of environmental damage to sensitive wildlife corridors, in direct conflict with guidance reinforced within paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2023). The proposals would also conflict with existing adopted Black Country Core Strategy (BCCS) (adopted February 2011) nature conservation focused policies CSP3 (Environmental Infrastructure) and ENV1 (Nature Conservation), given significantly adverse and severe wildlife corridor impacts. This is important given that important wildlife corridors link to critically important ecologically sensitive sites within the borough, such as the Fens Pool SAC, LNR and SSSI. There is an extensive green infrastructure ‘landscape-scale’ wildlife corridor network within the Dudley Metropolitan Borough which requires urgent and ongoing Planning Policy protection. The position is perfectly clear, there are now sufficiently robust exceptional circumstances in place for the LPA to now justify and consider Green Belt release within this emerging Local Plan Review, in order to protect key natural green space resources within the Dudley Metropolitan Borough inner urban area.

At this early stage of Local Plan preparation (Regulation 18), we have concerns that the emerging Local Plan Review and its accompanying emerging Sustainability Appraisal (SA) are both not currently effectively accommodating climate change pressures into the Plan making approach, in direct conflict with climate change focused guidance set out within paragraphs 153 and 154 of the Revised NPPF (2023). Given that considerable levels of urban cramming are being proposed by the LPA within the inner urban area which will result in the extensive loss of small, medium and large-scale urban woodlands across the borough’s inner urban area, which are all critical for helping the urban area to respond more effectively to the urban heat island effect (promoting urban cooling and reducing extremes in temperature), for reducing flood risk, for promoting carbon storage, and for improving poor urban air quality. All of these climate change pressures will become more severe in future years across the Black Country sub-region. The position is perfectly clear, there are now sufficiently robust exceptional circumstances in place for the LPA to now consider Green Belt release within this emerging Local Plan Review, in order to help protect the climate change future resilience of the Dudley Borough inner urban area, by maintaining a good supply of urban green space areas within the heavily urbanised inner urban area.

Local residents living within the Dudley Metropolitan Borough have a fundamental, clear and basic Legal Right “to be able to breathe clean and healthy air”. This basic Legal right is supported under Article 2 of the European Convention on Human Rights (The Human Rights Act) Legislation. The proposed spatial planning policy approach of focusing 10,876 new homes within the urban area could breach Article 2 of the Human Rights Act legislation, given that highly unsustainable patterns of new housing development are being encouraged by a proposed “urban cramming” planning policy approach. Which will only lead to greater levels of air pollution, which will have a detrimental effect on local residents and their health, contrary to guidance in paragraph 35 (indent d) of the Revised NPPF (2023).

Within the emerging Local Plan Review the council should focus on protecting existing employment land sites (including lower quality employment land sites which are currently struggling during the severe economic recession) in order to ensure that there is a sufficient ready supply of employment land available to meet the Dudley Borough’s current and future employment land needs. Essentially to ensure that local communities have a supply of local jobs within the inner urban area close to existing established residential communities. This plan-making approach will help to ensure the delivery of sustainable communities consistent with guidance in paragraph 35 (indent d) of the Revised NPPF (2023). The proposed spatial planning policy approach of focusing over 10,000 new homes into the inner urban area will result in the loss of employment land sites within the inner urban area, which could help meet future community needs. All types and condition of employment land sites should therefore be safeguarded within the inner urban area in the emerging Local Plan Review, and significant new housing development focused towards a housing-led sustainable urban extension in the borough’s low quality Green Belt countryside at land located south of Racecourse Lane, Norton, Stourbridge. The position is perfectly clear, there are now sufficiently robust exceptional circumstances and planning policy grounds now in place for the LPA to now consider Green Belt release within this emerging Local Plan Review, in order to help protect and maintain a sufficient and adequate supply of employment and provision within the inner urban area. To help ensure that there is a sufficient supply of locally-based employment land opportunities provision available to meet local community urgent needs, during a severe prolonged economic recession and cost-of-living crisis. This is particularly relevant given that the Black Country’s traditional manufacturing industry has suffered extensive decline during the last 60 years. There is a need to future proof existing employment sites within the urban area with new, more resilient employment uses to help meet the local communities needs. The economic vitality of the inner urban area needs to be protected as the local area emerges from the post COVID-19 economic recovery.

Safeguarding the protection of vulnerable historic environment assets. We are using the example of the recent demolition of the Crooked House (public house) as this provides an excellent example of the challenges that the Black Country sub-region is currently facing in respect of historic environment planning policy matters. Essentially how to successfully protect important historic environment assets, not all of which will necessarily be either Locally Listed or Statutory Listed (Grades I, II, etc) buildings. This planning policy matter requires urgent consideration by the LPA within the Local Plan Reviews (2023/ 2024) historic environment chapter, in order to help protect the historic environment. We have concerns that the forcing through and urban cramming of 10,876 proposed new homes into the Dudley Borough inner urban area will cause significant levels of harm to the borough’s highly sensitive historic environment assets, the areas historic character and its local distinctiveness. Green Belt release for major new housing development should be strongly promoted within the emerging Local Plan Review south of Racecourse Lane in order to help protect the inner urban areas important historic environment assets, the inner urban areas local distinctiveness and its historic landscapes.

The importance of improving poor urban air quality within heavily urbanised parts of the Dudley Metropolitan Borough, and along major highway networks to help promote more healthy communities is considered critically important. The considerable levels of urban cramming being proposed within the Local Plan Review by delivering 10,876 new homes within the urban area will make the poor air quality position far worse, which reinforces the urgent need for Green Belt release on land located south of Racecourse Lane, Norton, Stourbridge.

Sensitive urban green space (of value for outdoor recreation and nature conservation) vs Green Belt release – finding sufficient sites for new housing. Urban green space areas in many cases have significant more outdoor recreational and biodiversity value, and climate change mitigation benefits in comparison to restricted access intensive Green Belt farmland. A good example of this is the ecologically sterile intensive farmland located south of Racecourse Lane, Norton, Stourbridge. These aspects are supported by robust, defendable and up-to-date photographic evidence within this Local Plan Representation.

Object

Representation ID: 537

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Need to identify and investigate the reasons why specific housing sites such as Daniels Land within the Brierley Hill AAP and Old Wharf Road within the Stourbridge AAP have both failed to consistently come forward over the last 10 years, despite being both allocated for new housing development in previous Dudley Borough Local Plan Reviews. What barriers are in place preventing new housing land delivery for this specific site locations? Both these sites already have planning consent from consents extending back a number of years for major new residential development. Both sites have failed to consistently come forward during successive Local Plan Reviews. As stated further above, Goldfinch Town Planning Services has concerns that the LPA is accommodating and taking forward undeliverable housing site allocations within the emerging Local Plan Review (2023/ 2024) which directly conflict with deliverability focused guidance reinforced in paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (2023).

Object

Representation ID: 538

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

The LPA is taking forward a seemingly inflexible, heavily out-of-date, unsound and highly onerous affordable housing planning policy regime, an onerous Community Infrastructure Levy (CIL) and planning obligations policy regime into the emerging Local Plan Review (2023). These policies, such as affordable housing policy, are fixed and based on planning policy assumptions made a number of years ago now as part of the evidence base work previously undertaken for the now collapsed Black Country Plan (BCP) Review (Autumn 2021). This BCP Review evidence base work is based on insufficiently robust and heavily out-of-date pre-COVID-19 economic data which is no longer defendable. This planning policy approach is therefore in direct conflict with guidance reinforced within paragraphs 31 and 82 (indent d) of the Revised NPPF (2023). Future Policy formulation and policy shaping needs to remain significantly more responsive to the adverse economic landscape now facing housing developers operating across the Black Country sub-region for the various economic factors discussed above now facing the construction industry. The LPA cannot continue to keep placing unreasonable and financially onerous planning policy demands on rural landowners and housing developers within the borough during a 300-year-economic-recession-event.

Object

Representation ID: 539

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

The Council should prioritise attracting high quality economic regeneration growth and new inward investment opportunities to the Dudley Metropolitan Borough to help deliver good quality jobs growth for local residents. Making the local area a more resilient and attractive location in which to live, visit, work and invest should be a key local plan priority. Supporting the post COVID-19 fragile local economic recovery, and making the local area more resilient to the current and future economic recessions and global health pandemic events is very important. This is a key issue given that the Black Country sub-region has suffered long term economic decline in its manufacturing industry employment base. Therefore, the emerging Local Plan Review should be taking a sufficiently robust and more pro-active planning policy approach towards these issues with planning policy intervention solutions that actually work on-the-ground, in order to help improve the economic, social and environmental conditions of the local area, consistent with guidance reinforced within paragraph 38 of the Revised NPPF (2023).

Object

Representation ID: 540

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Responding effectively to the changing role of town centres and interventions needed to prevent further decline during a severe economic recession and cost-of-living-crisis is considered important.

Office floor space issues within town centres – changing working patterns driven by the COVID-19 pandemic, increased home working, etc. The emerging Local Plan Review needs to explore ways of encouraging more office workers to return back to the borough’s main town centre locations in order to help support the future vitality and viability of these town centres.

The importance of promoting mixed-use developments within town centres to help support their vitality and viability is considered important. Particularly schemes which focus retail uses on the ground floor with residential and office provision uses located on upper floors.

Supporting the future vitality and viability of Brierley Hill High Street is considered very important. Photographic evidence within this Local Plan Representation shows the extensive town centre decline of this once vibrant town centre location.

Consistent and repeated failures of centres and retail studies and employment land previous background technical evidence base studies used to support earlier Dudley Borough Local Plan Reviews, the adopted Black Country Core Strategy (2011), and the now collapsed Black Country Core Strategy (BCCS) Review (Autumn 2021). Failure to deliver meaningful changes on the ground and deliver fit-for-purpose and effective planning policy approaches for earlier Local Plan Reviews. Previous centres studies prepared by private sector planning consultants are clearly not fit-for-purpose and do now warrant the significant financial expense of commissioning these documents from so called retail and employment land specialist private sector planning consultancies.

The Council now needs to use in-house expertise to complete such studies to avoid previous retail study failings, which consistently fail to deliver any meaningful and effective on-the-ground improvements within the borough’s main town centre locations centres.

Object

Representation ID: 541

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Goldfinch Town Planning Services would suggest that the emerging Local Plan Review could be significantly strengthened and improved from a nature conservation new habitat creation planning policy perspective, by emphasising the important role that new high quality housing development schemes can play in helping to promote and deliver new on-site nature conservation habitat features, integral for helping to support the delivery of Biodiversity Net Gain (BNG) across the Dudley Metropolitan Borough.

Object

Representation ID: 546

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

As part of the Local Plan Review making process, the LPA should undertake comparative research of other LPA areas across the UK to help identify best practice, in terms of identifying techniques used by other LPA planning policy teams to help support the future vitality and viability of existing centres, and strategies used to help attract high quality new inward investment opportunities within allocated employment land sites. In order to help support town centre regeneration and high-quality economic regeneration growth and good quality job creation opportunities. This is considered particularly important in order to help support the post COVID-19 highly fragile local economic recovery across the Dudley Metropolitan Borough and wider Black Country sub-region, which is experiencing significant decline within the Black Country’s various Town Centre locations and existing industrial estates.

Object

Representation ID: 547

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

The proposed new housing site allocations are not clearly presented within the Council’s emerging Local Plan Review ‘Draft Plan’ stage report (Regulation 18 (November 2023). They should be provided in an Appendix Section with each proposed housing site allocation accompanied by a O.S base plan, with the proposed housing allocation outlined in red ink. With street names clearly visible on the O.S. based plan. A recent photograph of each proposed housing allocation site would also be beneficial. The way that the information is currently displayed is vague and unclear, and does not assist local communities, landowners and other key stakeholders, in accordance with guidance set out in paragraph 16 (indent c) of the Revised NPPF (2023).

Object

Representation ID: 548

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

The consultation website for the Local Plan Review (November 2023) consultation is confusing and unclear. It is not easy to locate the November 2023 public consultation document (the actual Local Plan Report subject to consultation) on the Council’s consultation website. The Council needs to ensure that the main Local Plan report is easily and quickly accessible to the public and key stakeholders in order to ensure an effective public consultation approach, consistent with guidance reinforced within paragraph 16 (indent c) of the Revised NPPF (2023) which confirms that: “…Plan 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…”

We continue to have concerns and object in relation to the use of the Consultation Portal (Opus Consult) Local Plan consultation system which is being used by the Council’s Planning Policy Team to support Local Plan preparation. As a key local stakeholder, we maintain our view that the Local Plans Consultation Portal (Opus Consult) is unclear and highly confusing for members of the public, community pressure groups, elderly residents over 75 years of age, local businesses, landowners, 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, and have financially expensive ongoing maintenance costs, are not effective ways for Local Planning Authorities (LPA’s) to consult local communities for Local Plan Reviews, and are a considerable waste of local taxpayer’s money during a severe cost-of-living crisis. Given the very high financial service costs or running/ maintaining these consultation portals by the private sector companies who operate these systems. These consultation portals do not deliver effective consultation strategies and therefore fail to respond and directly conflict with guidance reinforced within paragraph 16 (indent c) of the Revised NPPF (2023) which confirms that: “…Plans should (indent b) be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees…” During a severe economic recession and at a time when a significant increasing number of Council’s across the UK are filling for effective bankruptcy, the LPA should be using much more cost effective public consultation approaches which deliver meaningful outcomes for local communities and key stakeholders.