Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14168
Received: 14/12/2020
Respondent: Hampton Road Developments Ltd
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Criterion 2 & 3 are onerous as they go above what is required through the Building Regulations. Standards can be exceeded where there is a justified need. The requirement to build all dwellings to Category M4(2) standards should be evidenced and balanced against the need to make the most efficient use of land.
Criterion 4 does not consider existing specialist housing or care provision in the locality and whether any additional provision is needed.
Criterion 5 does not include reference to the suitability of a site to accommodate accessible dwellings, for example topography or local demographics. The policy should be amended to accord with the PPG (Reference ID: 56-008-20160519) or provide evidence which justifies the position.
If differing standards are applied, there is potential for a situation to occur in which decisions about technical appropriateness is considered by planning officers, rather than qualified building inspectors. The policy should be amended to remove any requirements above current building regulations where this is not suitably justified.
The requirement for all dwellings to be built to Category M4(2) standards should be removed, unless evidence can be provided to justify this blanket approach or a percentage requirement that is evidenced based on an appropriate assessment of need to ensure that developments can still make the most efficient use of land in accordance with the NPPF (paragraphs 122 and 123).
The criteria listed under Point 5 of Policy P4E should be amended to state “Site specific factors which may make step-free access unsuitable or unviable”. For example not every site identified is flat and able to accommodate level access in a uniform matter.
Any requirements for specialist housing or care accommodation should be the subject of an evidence based review in conjunction with specialist operators, and appropriate locations identified based on this evidence. This would include reviewing existing provision and the need for further provision based on demographic and health trends.
See attached documents.