Object

Representation ID: 1214

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

Unclear that the need for elderly accommodation of the scale proposed is justified by the evidence at this current time. Object to HESA methodology and conclusions relating to assessment of site 436b and its potential impact on Landywood Farmhouse- an amber score would be more appropriate.Concerns regarding the 2019 Green Belt assessment methodology as well as the site specific findings - the wider site does not make a meaningful contribution to the purposes of the Green Belt. Highways - dispute the conclusions of SCC highways - development of up to 250 homes could be secured from the 3 proposed accesses without impacting on the local network or Holly Lane Bridge. Question reliance on GBHMA Growth Study to support plan target and should be uplifted considering; Standard Method number is a minimum starting point and recent employment growth and new infrastructure justifies an uplift, as does previous SHMA and past recent past delivery. Wider unmet need show significant shortfall from the Black Country that only be met by 6 authorities, suggesting South Staffordshire contribution may need to increase by 3000-5000 homes. The apportionment of unmet need across the relevant LPAs should be based on a robust capacity study. Plan flexibility of 12.9% is insufficient, should be 20%,and the windfall allowance too optimistic.