Preferred Options November 2021

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.

Support

Representation ID: 1296

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

We welcome the fact that Cheslyn Hay/ Great Wyrley is now proposed for some additional growth and allocations (including site 536a south of Holly Lane), reflecting its status as one of the highest performing settlements in sustainability terms

Object

Representation ID: 1297

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

Cheslyn Hay/ Great Wyrley is still underrepresented compared to the other Tier 1 Villages and this is not supported by the evidence base. Miller consider a further allocation (Option 2) is justified as if the wider land parcel (Option 3), which as a minimum should identified as safeguarded land. New Safeguarded land in line with NPPF 2021 is justified with 15 years worth - 3645 dwellings based on standard method or over 10000 homes if a higher proportion of unmet need is accounted for.

Support

Representation ID: 1298

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

Site 536a is sustainable and deliverable for at least 100 dwellings. Holy Lane site 536a/b/c has good rail links and is well placed to meet unmet needs of B'ham the Black Country. Offers opportunity to deliver elderly accommodation, where need is evidenced, and school drop off parking. Wider site 536c has options to deliver a new 3G pitch

Object

Representation ID: 1300

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

HC1 - housing mix better determined on site by site basis considering market demand - policy approach is too prescriptive as drafted. HC3 - viability study supports only 20% affordable housing requirement from specialist housing provision, so the Council should consider a differentiated policy. HC4 - regarding requirement for 30% of homes to meet M4(2) building regs, the evidence base has not yet been provided to demonstrate a clear and demonstrable need for the introduction of such optional technical standards. HC11 - do not support standards for space about dwellings - does not allow for pragmatism and creative design solutions. Consider an inflexible approach to NDSS will impact on affordability and affect customer choice; currently no evidence has been prepared to support requiring NDSS. HC12 - requirement for electric charging should be removed as now required through building regs; viability study makes insufficient allowance for the cost of charging points. NB3 - if SANGs are required for Cannock Chase SAC mitigation then these need to be properly considered through the viability study. NB6 - The Council does not need to set local energy efficiency standards to achieve the shared net zero goal, because of the higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and proposals for the 2025 Future Homes Standard. A case to introduce the optional water efficiency standards has yet to be provided and South Staffordshire is an area of only moderate water stress.

Support

Representation ID: 1301

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

HC2 - proposed approach supported. HC5 - Miller will work alongside the Council and specialist providers to deliver this specialist elderly accommodation on the allocation site at Holy Lane, should the need be confirmed through the evolving evidence base. HC7 - Support the flexible approach to self build provision. HC9 - reference to tree lined streets should reflect footnote 50 of the NPPF.