Policy P2 Maintain Strong, Competitive Town Centres

Object

Representation ID: 10695

Received: 07/12/2020

Respondent: Mrs Helen Bruckshaw

Legally compliant? No

Sound? No

Duty to co-operate? No

Shirley High Street - objective to reduce congestion - the plan for so many new homes in Shirley will add to congestion which has already seen a drastic increase following Dickens Heath being built and all the other new developments in Shirley.

Objective regarding public transport - I do not travel to Birmingham or Stratford on the train, despite living close by as the car parks at Shirley & Whitlocks end are full (disabled therefore would need to drive to the station) .

Object

Representation ID: 10696

Received: 07/12/2020

Respondent: Mrs Helen Bruckshaw

Legally compliant? No

Sound? No

Duty to co-operate? No

Shirley:
Addressing safety for all users including improved facilities for pedestrians and cyclists and addressing accident hotspots. - Extra vehicles on already congested roads, will not improve safety.

Support economic recovery by improving the efficiency of the highway network through a range of interventions and technology improvements. - the 'improvements' already made have resulted in roads being more congested not less.

Object

Representation ID: 11140

Received: 12/12/2020

Respondent: Natural England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

N.B. more of a comment on a potential recommendations than objection.
The policy recognises a need for diversification. Consider inclusion of new natural environment provision? - the natural environment can have a role in ensuring these areas remain focus for community interaction .

Object

Representation ID: 11250

Received: 14/12/2020

Respondent: Mr T Khan

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Solihull Town Centre was identified as a location for housing in the adopted Plan. Identified locations within the town centre and subsequent Masterplans have yet to come to fruition.
From the conclusions which can be drawn from the adopted Plan and the experience and complexities of town centre redevelopment the housing figure proposed is over ambitious and unachievable within the Plan period.
To ensure the delivery of the appropriate number of dwellings within the Plan period additional allocations within the Plan should be provided.

Object

Representation ID: 13777

Received: 14/01/2021

Respondent: Ellandi LLP

Agent: Williams Gallagher Town Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objects to wording of P2. The local plan is not based on up to date evidence on retail and leisure need. It is significantly out of date and does not reflect the scale of development now proposed for the Borough and the timing of that development. Timing of this growth will influence the phasing for when and where retail led development should be directed and the preferred strategy. This will also impact on the sequential and impact tests needed through the NPPF. At present the policy defers to NPPF which is a missed opportunity to provide a robust and locally focused strategy that fosters investor confidence.

SMBC should undertake an assessment of thresholds to identify a locally set threshold or thresholds over which impact assessment will be required for retail uses. The NPPF threshold of 2,500 sqm is too high, particularly in areas where town centres are vulnerable. A small out of centre scheme could have a disproportionate effect on the vitality and viability of the centre.

Thresholds for impact assessment in relation to town centre uses at Arden Cross, Birmingham Business Park and Blythe Valley Business Park should be set. Otherwise there is no mechanism by which to assess whether the scale of development is commensurate with serving those developments only.

Objective 15 of P2 is not effective or consistent with national policy. It seeks to encourage new development on the edge of the town centre for a diverse range of uses. This has the potential to undermine the strength of Chelmsley Wood Shopping Centre if this is effectively giving support to competing retail and leisure town centre uses in an edge of centre location. The policy needs to be redrafted to give clarity to its purpose.

Object

Representation ID: 14021

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objection to Policy P2 as it fails to sufficiently recognise the potential opportunity for new residential development in ensuring the vitality of Shirley town centre.

Object

Representation ID: 14206

Received: 14/12/2020

Respondent: IM Properties - Employment Land

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No specific reference is made to Mell Square within this policy. Clause (7) of Policy P2 states that “A range of opportunity sites will be identified under this policy”. However, it is not clear where these sites will be identified. There seems to be no link made to the emerging Town Centre Masterplan, and it is not clear whether it is intended that the Masterplan will contain relevant information about these ‘opportunity sites’. IM would suggest that clause (7) is clarified, and that reference is made to the Town Centre Masterplan or any other documents as appropriate
The supporting text is inconsistent in how it refers to the ‘Town Centre’. At paragraph 116, bullet four, reference is made to the ‘Heart of Solihull’ area, but it is not clear from the text what area this relates too. Paragraph 116 of the Plan sets out a list of the “primary retail frontages” where retailing activity should remain the main street level use. Specific reference is made within bullet four of point two to ‘Mell Square’.IM are concerned that this approach to protecting retail frontage is too restrictive to allow delivery of the flexibility that is referred to within the main Policy.
It would be more appropriate for this supporting text to refer to ‘active uses’ rather than ‘retail use’. This would allow for alternative uses to be brought forward that would retain street level activity, and contribute to the vibrancy of the centre.

IM welcomes the preparation of the masterplan, and the additional guidance that this gives in terms of more specific proposals and high level design. Would suggest that reference to the Masterplan being “updated by the end of the year” (paragraph 120) are removed. There appear to be inconsistencies between figures quoted within the SLPDS Plan, and the Town Centre Masterplan:

The presence of a comma at the end of paragraph 128 may indicate that it was intended to further clarify the position with further text. IM would welcome further text to avoid any confusion regarding what level of delivery is anticipated during the Plan period. Early feasibility work has indicated that Mell Square could accommodate 400 units.

Paragraph 129 of the supporting text makes reference to an economic appraisal and market analysis undertaken by Amion in 2020. In reviewing this IM consider in the context of current and forecast market conditions the potential for 50,000sqft of office floorspace to be brought forward to be ambitious.

It is therefore important that the Plan and the Town Centre Masterplan contain sufficient flexibility to allow for this to ‘shift’ to other uses if it can be demonstrated that there is a need for them. This is the case in policy P4a and the supporting text to Policy P4c which make specific reference to the fact that town centre residential development may result in a different mix, type or size of housing being provided by new development in these locations.

Object

Representation ID: 14313

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P2 Criteria 10 – Economic activity already exists to the east of the Stratford Road. Defining what is meant by “substantial” would assist future planning determinations.

Policy P2 Criteria 12- Who will be coordinating the promotion of public realm improvements?

Policy P2 Criteria 13- there is potential for mixed residential/commercial development at Chelmsley Wood Town Centre.

Policy P2 Criteria 16– Proposals for main town centre uses in Solihull Town Centre has the potential for detrimentally impacting Hobs Moat.

Object

Representation ID: 14314

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Para 116 bullet point 1- Homer Road and Princes Way are good locations for residential properties. With more “working from home” repurposing existing and planned offices to residential or mixed developments should be encouraged.

Para 120- the train station isn’t moving and is no longer incorporated in the new Solihull Town Centre masterplan.

Para 128- the updated masterplan now shows 1,178 new homes in the Town Centre. It is unclear how many of these are deliverable within the plan period.

Para 130- The level of residential development that can be accommodated in the town centre has not been exceeded but has fallen short.

Para 133- social housing is only deliverable on sites in public ownership, whether or not this is intended should be clarified.

Para 138- the A34 Stratford Road has the highest concentration of road traffic accidents in the Borough.
Para 139 bullet point 1- further explanation of objective required.

Para 140- a masterplan is needed for Chelmsley Wood Town Centre to determine viability of level of housing growth proposed.

Object

Representation ID: 14380

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Draft Submission again refers to the Town Centre as a location to provide for 861 dwellings within the Plan period.

From the conclusions that can be drawn from the adopted Plan and the experience and complexities of town centre redevelopment, it is considered that the housing figure is over ambitious and unachievable within the Plan period.

Object

Representation ID: 14550

Received: 11/12/2020

Respondent: St Philips - Land at Stratford Road, Hockley Heath

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para 222: The Plan anticipates the delivery of 961 dwellings through ‘Town Centre Sites’. Solihull Town Centre sites are allocated through site 8 of the Local Plan (2013),
No site-specific allocations are proposed through the DSP in order to deliver the Solihull Town Centre sites. However paragraphs 126-128 (which support Policy P2) confirm that the Illustrative Town Centre Masterplan (2016) indicates 1,500 new homes could be delivered in Solihull Town Centre, with 861 of these expected to be delivered in the plan period.
Whilst the Council’s ambitions to adopt the Masterplan as a Supplementary Planning Document following Local Plan adoption are noted, St Philips questions the specific timing of development coming forward early in the Plan period. Given that such sites have benefitted from housing allocations in the extant Local Plan, the adoption of the Illustrative Town Centre Masterplan SPD will not in itself result in delivery in the early plan period where housing need is most critical.
Crucially, this further substantiates the need for the Council to undertake detailed, site-specific housing trajectory, setting out the anticipated delivery rates of the Town Centre Sites pursuant to Policy P5(1).

Support

Representation ID: 14632

Received: 14/12/2020

Respondent: Sheila Cooper

Why was the Solihull Centre Master Plan not given a starring role as part of the Plan?

Object

Representation ID: 15230

Received: 14/12/2020

Respondent: Mr S Kelly

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Solihull Town Centre was identified as a location for housing in the adopted Plan. Identified locations within the town centre and subsequent Masterplans have yet to come to fruition.
From the conclusions which can be drawn from the adopted Plan and the experience and complexities of town centre redevelopment the housing figure proposed is over ambitious and unachievable within the Plan period.
To ensure the delivery of the appropriate number of dwellings within the Plan period additional allocations within the Plan should be provided.

Object

Representation ID: 15239

Received: 14/12/2020

Respondent: Mr J Green

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Solihull Town Centre was identified as a location for housing in the adopted Plan. Identified locations within the town centre and subsequent Masterplans have yet to come to fruition.
From the conclusions which can be drawn from the adopted Plan and the experience and complexities of town centre redevelopment the housing figure proposed is over ambitious and unachievable within the Plan period.
To ensure the delivery of the appropriate number of dwellings within the Plan period additional allocations within the Plan should be provided.

Object

Representation ID: 15251

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

- Policy P2 ‘Maintain Strong, Competitive Town Centres is unsound on the basis that it is contended that given the scale and type of development proposed in Solihull Town Centre, there should be express reference in the policy to the need for financial contributions towards the additional expenditure burden placed on West Midlands Police; as an element of social infrastructure required to deliver sustainable development, to ensure that safety and security can be maintained across the Borough, as anticipated in the Draft Solihull Town Centre Masterplan (TCM) 2020.
- West Midlands Police has a statutory duty to secure maintenance of efficient and effective police force for its area
- Council statutorily required to consider crime, disorder and community safety in exercise of its duties, with aim to reduce crime. Planning policies therefore require the theme of community safety and crime prevention be given prominence in the Solihull Local Plan Review, which is vital in the context of creating sustainable communities. Policy P2 and its supporting text omits any reference to the fact that development proposals within Solihull Town Centre should be expected to demonstrate how they have considered security and safety and how they achieve Secured by Design standards across the entirety of the area.
- NPPF and PPG refer to designing out crime, supporting safe communities, working with police and security agencies, importance of considering and addressing crime and disorder, and fear of crime.
- PPG provides for planning obligations in policy requirements, understanding infrastructure evidence and costs and guidance for CIL.
- Vital that Police are not deprived of legitimate sources of funding so they’re not under-resourced
- If additional infrastructure for WMP is not provided, then Police’s ability to provide a safe and appropriate level of service will be seriously impacted by level of growth in the DSP.
- Important to note that increase in local population or number of households does not directly lead to an increase in central government funding or local taxation.
- Viability Assessment shows that police contributions are viable.
- Considered therefore contributions to policing are essential for delivery of DSP, and should be expressly stated in site policies and P21, not just Draft Infrastructure Delivery Plan.
- It is submitted that the omission of a reference to the evening economy within the wording of Policy P2 renders the policy inconsistent with national policy and, therefore, is unsound.