Publication Plan November 2022

Comment

Representation ID: 4188

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

We fully support the identification of land at Keepers Lane and Wergs Hall Road as a residential development site within the Plan. We do, however, consider that the reference to a minimum capacity of 317 dwellings on the site allocation Pro forma, should be reviewed. The quoted capacity of the site should be revised to 340 to 400 dwellings.

Support

Representation ID: 5292

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is sound in respect of its inclusion of allocation 536a. Wider policy could be amended as suggested to include some or all of the wider Holly site if additional land is required to meet the plans’ needs.

The Holly lane site is required to deliver a disproportionate level of specialist housing. To be clear, we are not suggesting that there is not demand for elderly accommodation in this location or that it cannot be provided on this site (indeed we confirm below that it can), however we ask that the above comments and concerns are considered through the EIP process before the proposed mix for the Holly Lane site is finalised.

Consider that there is a compelling case to allocate both northern parcels. The north west parcel should not score a red in the HESA, but an amber, as confirmed by the Pegasus Heritage note. The north west site is almost identical in characteristics to the allocation site. Allocating both northern parcels provides further flexibility and opportunities to provide differentiation between the different uses.

Finally we would request that if the Council are required to identify additional sites through the EIP and main modifications process, that the full wider Holly Lane site be considered for allocation or at least as safeguarded land such that it could form a later phase to the development of the northern parcels (Options 1 and 2), as part of a future Local Plan review, and provide certainty and comfort to Miller to provide the necessary infrastructure and futureproofing into the current development (in terms of access routes etc).

Object

Representation ID: 5293

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not positively prepared, justified and consistent with national policy as currently drafted and should be amended as suggested.

Miller contend that whilst the proposed figure exceeds the minimum starting point of the standard method, and is therefore not technically unsound; there are a number of factors at play in South Staffordshire, and the wider Greater Birmingham Region that would justify an increase to this figure.there are economic growth strategies in the South Staffordshire area which justify the standard housing method being exceeded
in the District. In addition, South Staffordshire is likely to see significant benefits arising from the development of the West Midlands Interchange (WMI) and M54/M6 link road and these need to be taken into consideration in establishing the District's housing requirement.

there is a compelling case to increase the proportion that South Staffordshire takes of the unmet housing need above 4,000 dwellings. The apportionment of unmet need across the relevant LPAs should be based on a robust capacity study, as opposed to figures which do not appear to be justified or based on demonstrable evidence.

This significant rise in house prices and the corresponding affordability of housing in South Staffordshire provides a compelling case for the need for additional market housing to alleviate cost pressures, and this would also assist in delivering additional affordable housing.

Table 8 suggests a total supply of 9,588 dwellings. A windfall allowance of 600 dwellings has been added on top of this, which is an increase from the 450 dwellings presented at the Preferred Options stage. This brings the overall land supply figure within the Publication Plan to 10,188.Therefore, the total proposed supply exceeds the target by 1,099 dwellings or 10.7%. Miller reiterate concerns with this level of headroom (which has reduced from 12.9% in the Preferred Options) as it does not allow sufficient flexibility to provide a choice and range of sites and to allow for under delivery of allocated/ committed sites, particularly given the number of strategic sites and level green belt release proposed.The text of policy DS4 needs to be updated to reflect this as it still says that it provides “approximately 13% additional homes to ensure plan flexibility”. A 20% buffer is more appropriate.

Object

Representation ID: 5294

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy is not fully justified or consistent with national policy as currently drafted and should be amended as suggested.

it is our strong view that Cheslyn Hay/ Great Wyrley is still underrepresented compared to the other Tier 1 Villages, as it only receives approximately 1/3 of the growth of the other two tier 1 villages of Codsall/ Bilbrook and Penkridge and even less growth than Wombourne in Tier 2. This position is simply not justified in the evidence base, as the updated 2021 Rural Services and Facilities Audit reconfirms its status as a Tier 1 Village,

Safeguarded land can also be used to provide
flexibility to the current plan period supply. It is our view that if it is not allocated for development that the wider Holly Lane site should be considered for safeguarding to provide a later phase to the current allocation and wider
northern parcel site to the west of the railway line..

Object

Representation ID: 5295

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not justified or effective as currently drafted and should be amended as suggested.

This policy is inappropriate as currently drafted. Housing mix is best determined on a site by- site basis, taking account of site-specific characteristics and local demand in the area. The requirement for 70% of properties to be 3 bedroom or less is overly prescriptive in nature and does not allow for a flexible approach.

Object

Representation ID: 5296

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy is not fully justified as currently drafted and should be amended as suggested.

The policy sets a blanket housing density target across the majority of the district, which needs to be relaxed to allow greater flexibility to allow developers to take account of local evidence in relation to market aspirations, deliverability, viability and accessibility.

Object

Representation ID: 5297

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy is not fully justified as currently drafted and should be amended as suggested.

The HBF’s comments on this policy note how the Council’s Viability Study (2022) clearly highlights the challenges in delivering the 30% affordable housing requirement, and that without higher sales values many sites may not be viable.

The breakdown in terms of tenure broadly aligns with national policy, although should include flexibility to adapt to the latest evidence of need and any future changes to the tenure definitions and requirements of national policy (noting change from Starter Homes to First Homes in recent years). It may also be beneficial for the Shared Ownership definition to be broadened out into other forms of affordable home ownership in line with the NPPF to provide further flexibility.

Object

Representation ID: 5298

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not fully justified as currently drafted and requires further evidence, otherwise it should be amended as suggested.

With regard to the requirement for 100% of homes to meeting M4(2) building standards, Whilst we note the October 2021 Viability Assessment (prepared by Dixon Searle Partnership) has factored in 30% provision into site viability costings, we have not assessed the
methodology or conclusions in detail and no further calculations provided within the 2022 Viability Study. Furthermore, the evidence base has not yet been provided to demonstrate a clear and demonstrable need for 100% provision of these optional technical standards.

Support

Representation ID: 5299

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is considered sound subject to our comments.

As noted in section 3, Miller have been asked to accommodate an element of specialist elderly accommodation into the proposed allocation at Holly Lane, Landywood (Site 536a) and will work alongside the Council and specialist providers to deliver this within the allocation, in accordance with local need, with reference to our comments on the associated evidence base.

We do not question the soundness of this policy, subject to our comments above and within section 3, but reserve the right to interrogate the evidence base further at EiP stage.

Object

Representation ID: 5300

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not justified as currently drafted and should be amended as suggested above.

The second and third paragraphs suggest that major developments will be required to provide for self-builders, and may also be required to provide design codes to support delivery of these plots, and to market such plots for a 12 month period before they can be brought forward as standard homes.

We do not consider a blanket approach to all large sites with the associated restrictions noted above to be appropriate, as this is likely to have significant negative impacts on delivery and viability for both regular housing and self-builds; particularly for volume housebuilders who will be bringing the majority of large sites forward, as their approach is not always compatible with self-building. We would therefore ask that this requirement is removed.

Instead, the Council should look to allocate sites specifically for self and custom-build housing, in and negotiation with landowners; supported by a more flexible policy that supports self-build on a site by site basis where there is a demand and appetite for it, and in line with relevant design parameters and other policies.