Publication Plan April 2024

Comment

Representation ID: 7083

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

If the Local Plan is adopted in 2026 this would leave the minimum 15-year period to 2041. There cannot be any delays during examination, however there is a real risk of delay (Government amendments to national policy, planning reform etc). To safeguard against these delays and ensure adoption stays on track for 2026, we consider that additional housing allocations should be identified now.

Object

Representation ID: 7084

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The standard method has been used for calculating local housing needs and is the minimum starting point for delivery. This is not justified, considering the reasonable alternatives, and based on proportionate evidence. We consider there are exceptional circumstances which justify an alternative approach to assessing housing needs. The district already has very significant gross commuting flows, and we consider the local housing need figure will exacerbate these flows.

Comment

Representation ID: 7085

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

The updates to the NPPF do not nullify the previous position that a 4000-home contribution was required for soundness. The Council are still justifiably relying on this as an exceptional circumstance for Green Belt release (albeit to the Tier 1 settlements). A reduction in the contribution largely defers the issue of addressing unmet needs to other authorities in the GBBCHMA who are not as advanced in plan-making. A higher contribution would be a positive approach, justified, and more effective in addressing the cross-boundary issue of unmet need.

Comment

Representation ID: 7086

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

The policy should have a clear requirement within it to ensure the Council undertake regular annual monitoring of housing delivery and set out what actions will be taken if housing delivery is slow to progress or drops below five-year supply, which in our view should trigger a full review of the Local Plan. The development needs beyond the Plan period are not accounted for the in the Publication Plan. For soundness, we consider that the Council need to identify longer-term development needs and identify areas of safeguarded land.

Support

Representation ID: 7087

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Miller Homes fully support the allocation ‘Land off Holly Lane’ (ref 536a) and can confirm that it is suitable and deliverable. The Illustrative Masterplan (figure 2.2) shows how this part of the landholding can achieve the requirement of the allocation including new homes, specialist units for older people, drop-off parking for Landywood Primary School, open space, landscaping and access. The site allows for around 72 standard residential dwellings based on 35dph, and specialist housing element comprises 40 units. Miller Homes appointed highways consultant, Sweco, to progress detailed proposals for the access arrangements off Holly Lane and the drop-off parking area. Two minor amendments proposed to the site proforma for Holly Lane as detailed in paragraphs 3.12-3.14 of the representation.

Object

Representation ID: 7088

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Miller Homes are promoting 23ha of land for developed, located to the south of Holly Lane, Great Wyrley. Great Wyrley is a highly sustainable Tier 1 settlement which is a suitable location for growth. The entire landholding is available, suitable, and deliverable and would form a logical and sensitive extension to the Tier 1 settlement. If during examination it becomes clear that the Council need to increase their housing requirement, we ask that consideration be given to the following options –
• Extending the boundary of Site 536a by taking in land to the west that is within the landholding; or,
• Extending the boundary of Site 536a by taking in land to the west and south that is within the landholding.
Figure 2.3 shows the masterplan should the land to the west of 536a be included in the allocation, and this would provide an additional 22 standard residential dwellings. Figure 2.4 shows the masterplan should the land to the west and south be included in the allocation. This site could provide a larger specialist facility for older people and has the potential to deliver recreation uses with its own access and parking. Details on the Green Belt harm if this section of the site is allocated can be found in paragraphs 2.16 – 2.4 of the full representation.

Object

Representation ID: 7089

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that the lack of flexibility in this policy is justified. The most suitable and appropriate manner to assess housing mix is by determination of the market at the time of submission of a planning application, rather than at adoption of the Local Plan.

Object

Representation ID: 7090

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that the lack of flexibility in this policy is justified. Different proportions of social rent and shared ownership should be allowed to come forward, based on the latest evidence of need at the time of making a planning application. The shared ownership definition should be broadened to encapsulate all other affordable routes to home ownership.

Object

Representation ID: 7091

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that this policy is justified. Part M4(2) is an optional standard. It is for the Council to demonstrate the need for Part M4(2) with PPG providing details on what factors can be considered. It is justified to allow for a level of flexibility within the policy and to do otherwise could have a knock-on impact on housing delivery.

Object

Representation ID: 7092

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that this policy is justified. The need for custom and self-build plots is relatively low. The blanket approach of this policy is likely to frustrate the delivery of regular housing particularly for volume housebuilders. This part of the policy should be removed and the Council consider alternative approaches.