Publication Plan April 2024

Support

Representation ID: 7274

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

We support the Spatial Housing Strategy’s emphasis on directing the majority of development to the larger settlements. Our client’s land interests are in Codsall/Bilbrook which is one of the largest and most sustainable locations for development in the plan area. Codsall and Bilbrook have many services and facilities compared to other villages in the District, including access to two railway stations and a functional relationship with the conurbation.

Support

Representation ID: 7275

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

We support the recognition that housing in Locality 4 should be focused in and around Codsall and Bilbrook. The settlement benefits from a range of services and facilities including two railway stations. It is one of the most sustainable locations for development in the plan area. It is ideally located to accommodate additional development and the number of dwellings proposed should be maximised to take advantage of the sustainable location.

Comment

Representation ID: 7276

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

The plan has been prepared to have a 15-year time horizon. The demand for property types could change over time. As such, HC1 is overly prescriptive and will restrict the number of larger properties with no recognition that the demand for such properties could be very different over the plan period. South Staffordshire has a large plan area. The demand for different property types will be different across the plan area – e.g. housing sites allocated adjacent to the edge of the urban area to meet the growth requirements of Birmingham and the Black Country should meet their housing mix requirements, not South Staffordshire. We object to the suggestion that s106 agreements will be used to secure the mix of outline planning applications, this matter can be addressed by a condition. Conditions should only be applied where there is evidence that this approach is necessary and should be determined on a site-by-site basis.

Object

Representation ID: 7277

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

HC8 is problematic and we have concerns for the following reasons –
The latest Authority Monitoring Report states there are 32 individual entries on the SCB Register. There were an additional 2 entries over 12 months to 2023. Over that period the Council granted planning permission for 5 SCB plots which was sufficient to meet its regulatory requirement over a rolling 3-year period. The level of need can be easily addressed on suitable windfall sites.
There is unlikely to be a take-up of self-build plots on large housing estates. Those plots are unlikely to appeal to those on the self-build register whose requirements are for larger, individual plots. The better approach to meet the scale of the identified need is to provide support for such applications from windfall opportunities.

Comment

Representation ID: 7278

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

The starting point for the preparation of Local Plans is that they should not include policies requiring NDSS compliant housing. The NPPF makes it clear that policies should make use of the Government's optional technical standards for accessible and adaptable housing. The Internal Space Standards Topic Paper does not justify the requirement for use of space standards, it identifies a series of generic matters that are relevant throughout the country. There is no evidence to suggest that the existing stock of housing is deficient against NDSS, in the absence of such evidence there is no policy justification to impose the standards on all new development. If the Council insists all new properties must meet NDSS, entry level properties will be more expensive and those additional costs will be passed on to house buyers.

Comment

Representation ID: 7279

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

We support measures to reduce carbon emissions through both construction and operation and recognise the Council’s ambition in setting policies which go beyond national requirements. Any specific requirements which go beyond the current Local Plan and national guidance need to be supported by an appropriate evidence base. The unregulated energy consumption is the function of the residents’ use of the building and therefore the requirement on the developer to reduce emissions from residents’ unregulated energy use is not appropriate.
We agree with the Council’s policy requirement to achieve regulated carbon emissions reduction through energy efficiency features. Any emission reduction targets should be in line with latest national standards. Details from the Written Ministerial Statement are in the ‘Energy Efficiency’ paragraph in representation 9. We support the policy’s requirement on provision of renewable energy generation to help reduce carbon emissions, we are cautious over a requirement to achieve a 100% reduction in TER via onsite generation. We do not believe the renewable energy target in regards to building footprint is achievable.
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. We agree that offsetting payments should be linked to the Government's Green Book carbon pricing and should take account of grid decarbonisation. We have concerns that the policy refers to both regulated and unregulated emissions for the reasons outlined above, we suggest the policy is amended to offsetting remaining regulated emissions only. The policy needs to include reference to delivering the required carbon offset within a reasonable timeframe. Details on viability can be found in the relevant paragraph in representation 9. Proposed updates to the policy can be found in representation 9.

Comment

Representation ID: 7280

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

We fully support the Council’s objective to address embodied carbon and waste. Whilst we support the Council’s requirement for new developments to be supported by a Whole Life Cycle Assessment, we are concerned about setting any fixed targets. We recommend the policy is updated to reducing embodied carbon where feasible and viable and removing the fixed target to ensure the policy is effective. Proposed updates to the policy can be found in representation 9.

Comment

Representation ID: 7281

Received: 31/05/2024

Respondent: Miller Homes

Agent: PlanIt

Miller Homes control and are promoting land at Keepers Lane / Wergs Hall Road for 317 dwellings. Miller Homes wholly support the principle of the allocation but wish to submit important clarification on the wording of the allocation policy. Miller Homes have tested the capacity of the allocation through masterplanning and technical work and this has demonstrated that the site is capable of delivering a scale of development which far exceeds the 317 homes referenced in the policy. Although this figure is expressed as a ‘minimum’, it is well short of the numbers which could be built on this site – which is 340 – 400 dwellings. A supporting concept plan is provided to illustrate how development can deliver on many of the policy objectives and accommodate the higher number of dwellings. The policy should be revised to state the site can deliver a minimum of 340 dwellings.