Object

Representation ID: 14164

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

P4B
1. The draft submission Plan fails to identify if the green belt land referred to includes the land that SMBC seek to release from the Green Belt or whether this is additional green belt land that SMBC would support the release of to meet a Local Need for housing. This policy is unclear and needs clarification.
2. If the policy is proposing the release of additional green belt land, it is unsound and fails to consider the provisions of the NOP whereby the view is that Brownfield sites should be considered at first instance
3. P4B ii is contrary to principles of freedom of choice to limit those in need of accommodation to allocated housing sites before access to a local needs' provider can be accessed.
4. The "local connection to the parish" provisions cannot override the terms of Trusts established within Charity Schemes as governed by the Charity Commission to which Charities are open public scrutiny, to do so fetters Trustees discretion which is an integral part of Charity Law. An exclusion within this clause should be applied in respect of registered Almshouse Charities.
5. The provision of Community-Led Housing is supported by the Parish Council to meet the needs of the local populace within the allocated sites.
6. By implication, green belt site allocation would not be within easy access of the local amenities or transport which is prejudicial and discriminatory to the local parish community whose personal circumstances may require accommodation nearer to amenities but which would not be available due to them by virtue of their characteristics.
7. A community-led housing project for those who are in the older age bracket, as is typically the case for the Almshouse Model, could risk being considered under the rural exceptions policy despite being a registered affordable housing provider for the most vulnerable in society as the Local Plan is currently drafted
8. The allocation of Local needs via the Rural Exceptions Policy demonstrates a total lack of community engagement regarding the need to respect and listen to the needs of the community. Any development envisaged by the rural exceptions rule by the Local Plan appears to be the only mode that Local Housing needs can be met and such a project would likely be under the umbrella of a Community-Led Housing Scheme. Yet the benefits of Community-Led Housing, the Strategic Vision for Solihull 2020-2025 and Partnerships with Birmingham together with the White Paper, "Planning for the Future" have been inadequately and woefully addressed within the Local Plan.
9. Policy 4(b) is contrary to the provisions of the Community Right to Build Orders and the Localism Act 2011
10. The Local Plan discriminates against Almshouse Charities who provides Affordable Housing via the Almshouse Model, the definition of which is recognised by the Central Government.