Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14729

Received: 11/12/2020

Respondent: Les Edwards

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P17A is unsound on the basis that no evidence, methodology, sustainability appraisal or viability assessment has been provided to justify the strategy proposed in the policy and linked site allocation policies. There is no evidence that alternative approaches have been considered. There is no clear link between the size
of allocated sites and scale of compensation required.
No mechanism has been set out to demonstrate how the proposed compensation measures sought on Green Belt land outside the ownership of the developer would be delivered – contrary to the requirements of NPPF paragraphs 31 and 35 d) and PPG Paragraph 003 Ref ID: 64-003-20190722.

Change suggested by respondent:

Proportionate, robust evidence needs to be produced for the Green Belt compensation requirements appropriate for each site allocation where Green Belt land would be lost. The evidence should ensure that the most appropriate strategy is adopted, taking into account reasonable alternatives.
The Viability Study and Sustainability Assessment reports should be updated to take into consideration the implication of Policy P17A and associated site allocation policies where Green Belt loss is proposed.
Once the evidence has been provided, Policy P17A and all the site allocation polices which sit beneath this overarching policy, should be amended accordingly.
As a minimum:
• Any reference to Green Belt compensation/ enhancement requirements which fall within the site should be removed – only compensatory improvements to the environmental quality and accessibility can be required in the remaining Green Belt land.
• Any reference to a requirement which is on land outside the control of the site landowners/developer or the council, should be either deleted, or the mechanism for delivery should be set out.
• Details of the Green Belt compensation measures required on the site resulting in the most significant loss of Green Belt, i.e. 140ha at HS2 Inter-change (Site UK1), should be set out in Policy UK1 and on an agreed mas-terplan.

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