Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14710
Received: 11/12/2020
Respondent: Mr James Mc Bride
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy BL1 is unsound on the basis that insufficient evidence has been provided to demonstrate there is a mechanism to facilitate relocation of the existing sports provision south of Tythe Barn Lane to a suitable site in the vicinity and thereby facilitate development on the site, contrary to the deliverability and developability requirements for site allocations set out in National Planning Policy Framework (NPPF) Appendix 2: Glossary and it fails to satisfy NPPF paragraphs 67 and 175.
The ‘Developer Site Proposal’ plan included on page 48 of the Concept Masterplan Document, suggests the replacement pitches could be accommodated
to the north and east of Shirley Town football club (including on land currently occupied by Akamba Garden Centre and shown retained on the SMBC illustrative concept masterplan). However, the developer’s proposal shows the replacement playing pitches on a ‘Local Wildlife Site’. This would not be suitable, achievable or deliverable as it would be contrary to Policy BL1.
The proposal to use a LWS for playing pitches would also be contrary to the requirements of Policy P10 ‘Natural Environment’ part 18
It is contended that there are suitable alternative options to the proposal to allocate BL1 land West of Dickens Heath for 350 dwellings, for example: allocating more small and medium sized sites; allocating brownfield land; making more minor amendments to larger village boundaries to facilitate additional small-scale development; and ensuring densities of development on sites brought forward for development (including those removed from the Green Belt and included in the urban area) are developed at densities which make the most efficient use of land.
Our Client, Mr Mc Bride, contends that insufficient evidence has been provided to demonstrate there is a mechanism to facilitate relocation of the existing
sports provision south of Tythe Barn Lane to a suitable site in the vicinity and thereby facilitate development on the site. This proposed allocation is, therefore, contrary to the deliverability and developability requirements for site allocations set out in NPPF Appendix 2: Glossary and it fails to satisfy NPPF paragraphs 67 and 175.
Our Client contends that evidence is required to justify Policy BL1 West of Dickens Heath, to robustly demonstrate that:
• the multiple complex land assembly issues have been overcome and there is agreement by all landowners to the site being brought forward on the development basis set out in the Concept Masterplan document; and
• there is a fully developed strategy with mechanisms in place to ensure playing pitches are replaced to release the land for residential development.
If these issues of soundness cannot be overcome our Client recommends that paragraphs 225 and 226 should be amended to remove the estimated contribution of
proposed site allocation BL1 from Delivery Phases I and II and Policy BL1 amended as necessary in the light of the findings of additional evidence gathering, negotiations
with landowners, playing field search and masterplan work.
see attached representation forms