Publication Plan April 2024

Comment

Representation ID: 7093

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Criteria a) – these documents are material considerations and should be listed as key documents beneath the policy rather than in the policy itself. Criteria c) – an element of flexibility needs to be drafted into the wording to reflect national policy. Criteria i) – should be removed to avoid unnecessary duplication elsewhere.

Object

Representation ID: 7094

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

HC12
We do not consider that this policy is justified. NDSS is an optional standard. It is for the Council to provide justification for requiring the internal space policy, with PPG providing details on what factors should 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: 7095

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 consistent with national policy. We consider that the policy needs rewording so it requires a contribution only when it is demonstrably necessary, so it is consistent with national policy.

Comment

Representation ID: 7096

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

This policy should be reworded so that it is clear which developments are exempt from the requirements. The post-development habitat value only needs to be demonstrated through the biodiversity metric after approval, the policy should be reworded so it is clear what information needs to be submitted and when.

Comment

Representation ID: 7097

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Turley have provided comments on this policy in Appendix 3. It is considered that any feasible and viable policy should be restricted to regulated energy only. Any emissions reduction targets should be in line with the latest national standards. We broadly support the addition of a mechanism to offset residual carbon emissions provided that the scope and cost of such a policy has been tested.
For soundness, amendments are proposed to the wording of the policy so that:
• Reference to unregulated energy is removed;
• Energy efficiency and renewable energy targets are removed;
• Timeframes are incorporated for the spending of offsetting obligations;
• Post occupancy evaluation is for a sample size of 10% of homes.

Comment

Representation ID: 7098

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Turley have provided comments on this policy in Appendix 3. We fully support the Council’s objective to address embodied carbon and waste but we are concerned about setting any fixed targets.
For soundness, amendments are proposed to the wording of the policy so that:
• Embodied carbon is reduced only where feasible and viable to do so;
• Fixed targets for limiting embodied carbon are removed.

Object

Representation ID: 7099

Received: 31/05/2024

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree that the principal mechanism for monitoring should be the AMR. However, we urge these to be updated in a timely and consistent format each year to allow for effective monitoring and the ability to notice trends in certain areas. There must be a commitment within the Local Plan to undertake this monitoring in light of the fact that it is no longer a legal requirement to do so. There is a notable omission of any trigger points within the monitoring framework that would prompt the requirement for a Local Plan review. As such, we consider the monitoring framework will be ineffective.

Comment

Representation ID: 7271

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

Table 1 advises that it is expected the Plan will be adopted in February 2026. In our experience the plan making process is often delayed and there is a real danger that the emerging plan will not have a minimum 15-year plan period. There is a strong possibility of a change in Government which is likely to result in further changes to the plan system and the reversal of the December 2023 NPPF amendments. The plan period should be kept under review and if the plan period does need to be extended, the Council could explore the potential for increasing the capacity of proposed housing allocations. Land at Keepers Lane / Wergs Hall Road has potential for increased completions.

Comment

Representation ID: 7272

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

Table 2 confirms there is a demographic in-balance which will lead to a decrease in the size of the employment pool from residents in South Staffordshire. There is an identified mismatch between the potential size of the employment pool and the new job opportunities which will be created.
Table 3 advises there is a mismatch between existing housing stock and future housing need. There is a requirement to provide smaller residential properties for younger families and older people wishing to downsize and free up family sized accommodation. The housing pressures and need to support economic growth should be recognised as an opportunity for the local economy.

Object

Representation ID: 7273

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DS2 puts in place a series of potentially undeliverable requirements for Green Belt compensation. It is ambiguous and suggests that s106 agreements will be used to secure ‘compensatory improvements’ to the environmental quality. It is unclear what is meant by ‘compensatory improvement’ and this provides no certainty to developers. It is unclear how the local authority can be sure that the applicants have control over any adjoining land required to deliver the improvements. A simpler approach would be to use the ‘key requirements’ of the various allocation proformas to identify the specific Green Belt compensatory measures for each relevant allocation, any measures would need to be subject to agreement between the Council and the landowners.