2019 October: Local Plan Major Modifications Page 1
Following the October 2018 Planning Inspection of the Local Plan, the Planning Inspector has invited comments on so called Major Modifications with a 31st October 2019 deadline for responses. The Letter reads:
The Staffordshire Moorlands Local Plan was submitted to the Secretary of State for Examination in June 2018 and Examination hearing sessions took place in October 2018.
The Inspector is inviting comments on the main modifications and associated documents to the Staffordshire Moorlands Local Plan Submission Version 2018. Main modifications are those necessary to make the plan sound/and or legally compliant. The Inspector will only consider comments relating to the main modifications. This is not an opportunity to repeat or raise further representations on the plan.
Cheadle Unite have raised 3 issues regarding the Major Modifications :
1) Objecting to the excessive Level of housing planned - based on the latest 2016 and 2018 ONS Figures
2) Objecting to the assessment of build against excesive targets
3) Highlighting the lack of co-operation with neighbouring authorities
The Full submission is as follows:
Cheadle Unite comments (29th October 2019) on the
Main Modifications (MM) to the Staffordshire Moorlands Local Plan Submission version 2018 are as follows:
We believe the Local Plan should reflect the aspirations of the local community and their way of life, be collaborative with neighbouring authorities in delivering a sustainable strategy on employment, transport and infrastructure, and be environmentally sound whilst sympathetic to National Policy and the need for housing, striking an appropriate balance.
We feel the local plan over-rides local aspirations as evident from many thousands of consultation responses and is competitive with neighbouring authorities rather than collaborative, the growth trajectory is not sustainable or environmentally sound. The plan should sit within a 50+ year strategy that looks to protect our environment and recognises that the economic based term ‘sustainable growth’ is by definition a contradiction in a world of finite resource and hence should be a plan that looks beyond economic costing models which have repeatedly proven to be unreliable with dire impacts on society.
1) The proposed housing level increase of 6000 dwellings for the Staffordshire Moorlands in the original Local plan was already significantly higher than the DCLG household projections of 2015 (and 2012 ONS Sub National Population Projection based figures) , which detailed a net housing requirement of only 2573 dwellings across the Moorlands.
MM8 retains a very high figure of 6080 dwellings to 2033.
The 2016 ONS SNPP figures [1] Released late 2018 with new Local Authorities figures published April 2019 have been available for 6 months during the Major Modifications review.
The tables below published April 2019, show the ONS data with the percentages calculated at the right of the table to years 2031, 2036 and 2041.
The above figures shows a further drop in the “Population projection” growth for Staffordshire Moorlands, now only 1.58% growth to 2036 and “Household Projection” of 6.4% growth to 2036 which goes beyond the Local Plan period to 2033.
If we add these figures onto the graphs already presented by Cheadle Unite to SMDC and the planning inspection we have the following 2016 SNPP figures for the Staffordshire Moorlands:
The new 2016 Figures in black show just how far the sub national population projections have dropped since 2010 in blue. The graph shows a natural tendency to levelling off, a process that should be celebrated in lowering our carbon footprint and working towards a sustainable future for our children.
The 2016 ONS figures now show a population increase of only 1491 to the Year 2031 and 1534 to 2036.
Based on the UK National average of 2.4 occupants per household, this would suggest a natural demand of under 650 homes to 2036 across the Staffordshire Moorlands
The 2016 SNPP projections by definition “Provide statistics on the potential future size and age structure of the population in England at regional, county and local authority .. levels. They are used as a common framework for informing local Level policy and planning as they are produced in a consistent way.”
Building over 6000 houses for a net ONS increase in the population of 1,534 across the Moorlands does not reflect the aspirations of the local community as detailed by numerous consultations including at least 5,500 responses.
SMDC have presented the Planning Inspector with an ‘Oxford Economics’ model that significantly inflates the perceived level of housing need. The claim that such high levels of net migration (7,697) to increase the working population by just 85 to 2031 is seriously flawed. It is not a sustainable model (what for 2033 to 2048 another 10,000?). The net migration makeup cannot be defined and is likely to contain a significant older none-working population, especially with properties that are unlikely to be affordable to the local community. This is likely to exacerbate the demand on infrastructure, roads and services not least in the promotion of a commuter / service town as presented in the local plan and is not a sustainable model in line with UK commitments to health (including Nitrogen Oxides NOx levels) and the environment.
Instead of planning for an average population growth of 1.58% and household growth of 6.4% to 2034 in line with the 2016 ONS figures (produced nationally in a consistent way) , the local plan as presented targets a much higher local population growth of over 20% based on an obscure model best described by Secretary of State for Housing Sajid Javid in 2017as an ‘assessments commissioned by individual authorities according to their own requirements, carried out by expensive consultants using their own methodologies. The result is an opaque mish-mash of different figures that are consistent only in their complexity.’
Comments Page 2
