Publication Plan November 2022

Comment

Representation ID: 4160

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Plan for adoption in winter 2023/24 may be unrealistic. If the Plan period does need to be extended to account for any slippage in its adoption date, the Council could explore the potential for increasing the capacity of the proposed allocation. We certainly believe that our client’s Land at Keepers Lane/Wergs Hall Road, has potential for increased completions over the 317 minimum figure which has been quoted at policy SA5.

Comment

Representation ID: 4161

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

There is a mismatch between the potential size of the employment pool from those who reside in the district and the new job opportunities which will be created. The Issues and Challenges for South Staffordshire’ section of the Plan should be re-drafted to reflect the fact that the housing and employment requirements are an opportunity for the local economy. Delivering sustainable development should be at the heart of the Plan and it should look to facilitate the delivery of this development at suitable locations.

Object

Representation ID: 4162

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS2 is ambiguous and simply suggests that S.106 agreements will be used to secure “compensatory improvements” to the environmental quality. What constitutes a “compensatory improvement” is not clear, and provides no certainty to developers.

Policy DS2 should be deleted. The “key requirement” of the proformas for each of the allocations should be used to clearly set out any Green Belt compensatory measures that may be required as part of the development of any former Green Belt sites. Policy DS2 is unclear and potentially undeliverable and could result in housing
delivery being stalled.

Support

Representation ID: 4163

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

We support the Spatial Housing Strategy identified in Table 8 and its 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 within the Plan area. Codsall and Bilbrook have a high level of services and facilities in this area compared to other villages in the district, including access to two railway stations and have good functional relationship with the conurbation. These locations are therefore well placed to accommodate additional growth.

Comment

Representation ID: 4164

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

We support the recognition that housing in Locality 4 should be focused in and around Codsall/Bilbrook. However, Additional development should be directed towards Codsall. Codsall is one of the largest and most sustainable settlements within the Plan area and readily capable of accommodating additional growth. The Council should encourage densities to ensure that the best use is made of those sites which are proposed as allocations.

Object

Representation ID: 4165

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to the requirement for 70% of homes to be 3 bed or less. The demand for property types could change over time. As such, policy HC1 should not be prescriptive and restrict the number of larger properties at this stage as there may be demand for larger properties later in the plan period. In addition, South Staffordshire has a large plan area. The demand for different property types is likely to change across the plan area.

We object to the suggestion that S.106 agreements will be used to secure the mix of outline planning applications as this can be done by condition if necessary.

Object

Representation ID: 4166

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 should be reworded to advise that the density requirement of 35dph is a“target” rather than a requirement. Density should be a product of good design and a policy should not prescribe density; a better approach is to consider density at the planning application stage.

As drafted, the policy suggests it would be accepted for the scheme to deliver at 35dph if it had an adverse, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate. In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework. NDSS requirements would also restrict density requirements.

Object

Representation ID: 4169

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

On site provision of custom and self build not necessary as the very small level of need can be addressed on small 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 larger, individual plots.

The better approach to meet the scale of the identified need for Self-Build homes is to provide support for such applications from windfall opportunities. The policy should be revised. The first paragraph in the policy
should be retained and the remaining sections should be deleted.

Object

Representation ID: 4170

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Internal Space Standards Topic Paper does not justify the requirement for use of space standards in Policy HC12 but identifies a series of matters relevant throughout the country. There is no evidence to suggest that the existing stock of housing is deficient against NDSS. Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDSS and the policies should seek to deliver this amount. The Council needs to recognise that if they require all properties to be NDSS compliant, it will have a direct impact on densities and affordability of new homes.

Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain, it should make it clear that some flexibility to the policy may be applied depending on the individual merits of the development proposal. This flexibility is applied to the part of the policy on external space standards and the same principle should also apply to internal space standards.

Object

Representation ID: 4181

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence that the cost implications of the net zero policy, and its impact on viability, have been assessed. We consider that this policy is unnecessary and that the proper framework for delivering carbon reduction is through the Building Regulations legislative framework. There is no justification for the Council to accelerate the requirement for net zero through a planning policy.

It is noted that policy NB6 requires a 10% improvement to the Part L 2021 Target for Fabric Energy Efficiency. However, that benchmark standard is already out of date and is replaced by the introduction of the 2022 changes to the Part L Building Regulations; those changes achieve the 10 % improvement which is referenced in policy NB6. This policy should be removed from the Plan.