Publication Plan November 2022

Object

Representation ID: 5301

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 effective or consistent with national policy as currently drafted and should be amended as suggested.

Miller do raise issues with the following criteria:

Criteria a – this criteria and wider policy largely relies on detail within latest South Staffordshire Design Guide SPD and relevant national and local design guides etc.; however these documents cannot be given full weight as they have not been subject to examination and are not part of the Local Plan. As such any detail from these documents which is intended to guide the determination of applications for planning permission should be set clearly within this Local Plan policy, to ensure that it is effective in line with the NPPF test.

Criteria c – tree lined streets – this should be refined to reflect footnote 50 of the NPPF which states streets should be tree-lined: ‘unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate’, and to note that such an approach is subject to highway authority agreement.

Criteria l – simply duplicates policy HC1 and is therefore unnecessary and could be removed.

Support

Representation ID: 5302

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy.This policy requires all developments to account for the amenity of nearby residents in respect of to privacy, security, noise and disturbance, pollution (including light pollution), odours and daylight.

Object

Representation ID: 5303

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is neither justified nor consistent with national policy, and should be amended as suggested unless further evidence is provided.

it is our view that this policy should be more flexible on both internal and external standards to account for specific circumstances on sites that might support smaller units; and to acknowledge that well-designed dwellings below NDSS can still provide good, functional homes.

At this stage, the Council have not prepared the evidence base necessary to support the introduction of these standards. Indeed, the Council’s Viability Study 2022 only tests five average house type sizes, rather than testing the 16 NDSS compliant house typologies. There is no evidence to demonstrate that testing only a limited number of average sized dwellings would meet all the technical requirements of the NDSS.

For external space standards, We object to this prescriptive approach, which does not allow for flexibility in design on a site-by-site basis, where creative design solutions may be required to address other issues such as privacy, lighting etc, which fall short in achieving such prescriptive standards.the current approach to maintain prescriptive, top-down standards is not appropriate and at a minimum should include amendments to the wording noting ‘where possible’ and ‘where feasible’ should be added into the policy.

Object

Representation ID: 5305

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 consistent with national policy as currently drafted and should be amended as suggested.

If the policy is to be retained, it should accurately reflect the national Building Regulations standard which states that the total number of charging points must be equal to the number of parking spaces if there are fewer parking spaces than dwellings, or equal to the number of dwellings where there are more parking spaces.

The Council will also need to keep monitoring viability implications here, as the 2022 Viability Study recognises that the cost of providing charging points has increased significantly since 2021,

Object

Representation ID: 5306

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 unless further evidence provided.

This policy refers to proposed developments causing ‘unacceptable impact’ on existing healthcare facilities but fails to define what level of impact is deemed unacceptable or how that is to be measured. The policy should acknowledge that not all residents of a development will be new to a catchment area of the relevant NHS Trust and that many will indeed be registered with local health care providers, thereby not creating any additional impacts.

Careful analysis is required in respect of the capacity of existing infrastructure to accommodate new patients, before reaching a conclusion as to what any CIL compliant financial contribution might be, and the requirement for CIL compliance of any request should be specified within the policy for clarity.

The policy is not justified as currently drafted and should be amended as suggested above unless further evidence provided.

Object

Representation ID: 5308

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 consistent with national policy as currently drafted and should be amended as suggested

The policy makes a blanket assumption that new education infrastructure will be required from all new development. However, any such provision to be delivered via S106 legal agreement, must have regard to the tests within CIL Regulation 122 and the policy should make this explicit. Furthermore, the policy should also recognise that new infrastructure will only be required from new development where it can be demonstrated that existing capacity to accommodate growth does not currently exist.

Object

Representation ID: 5309

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 should be amended as suggested.

The policy should acknowledge that the type of open space provision, including formal play equipment, should be considered on a site by site basis and take account of on-site circumstances and existing provision in the wider area (for example, play equipment may not work within the wider open space strategy on an individual site and may not be required if there is an existing play area nearby).

Support

Representation ID: 5310

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is considered sound subject to our comments.

Miller have no specific comments on Policy HC18, other than to reiterate our comments in section 4, that the wider Holly Lane site has the potential to provide recreation facilities, including onsite sports/playing pitch provision which would be fully accessible to future residents and the wider community.

Object

Representation ID: 5311

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 consistent with national policy as currently drafted and should be amended as suggested.

Miller are committed to the delivery high-quality green infrastructure within their schemes. The only point we wish to reiterate from the comments on Policy HC10 above is that the reference to a requirement for all developments to incorporate tree lined street should be refined to reflect the NPPF.

Support

Representation ID: 5312

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is considered sound subject to our comments.

We stress the importance that the Infrastructure Delivery Plan is up to date at the time of examination to ensure that the viability implications of the proposed strategic infrastructure have been fully accounted for in the plan, given current rates of inflation, particularly in respect of construction costs.