Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding

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Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10718

Received: 09/12/2020

Respondent: Mr Charles Ayto

Representation Summary:

While I wholehearted support your plan to assist the self and custom build sector there must be safe guards put in place. If self builders are being allocated plots already assigned to major house builders, then to preserve the ethos of self builders not wanting 'run of the mill' house styles and not being forced to build something 'in keeping' with the local vernacular as dictated by the big builders. By their very nature self builders are more artistic/eco friendly by nature. This individuality needs to be taken into consideration when the planning department looks at their planning application.

Full text:

While I wholehearted support your plan to assist the self and custom build sector there must be safe guards put in place. If self builders are being allocated plots already assigned to major house builders, then to preserve the ethos of self builders not wanting 'run of the mill' house styles and not being forced to build something 'in keeping' with the local vernacular as dictated by the big builders. By their very nature self builders are more artistic/eco friendly by nature. This individuality needs to be taken into consideration when the planning department looks at their planning application.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10790

Received: 12/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

While there is cleraly a need to make provision for self and custom build most housing allocations will be taken up by volume house builders. There is no mechanism put forward to explain how the Council will definitely ensure that appropriate parts of those sites will be specifically allocated for this purpose. Realistically volume house builders will earnestly resist having to provide sites for self or custom building.

Change suggested by respondent:

Each allocation should include a specific requirement for the developer to allocate land for those purposes and to facilitate those that wish to build houses that way.

Full text:

While there is cleraly a need to make provision for self and custom build most housing allocations will be taken up by volume house builders. There is no mechanism put forward to explain how the Council will definitely ensure that appropriate parts of those sites will be specifically allocated for this purpose. Realistically volume house builders will earnestly resist having to provide sites for self or custom building.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10889

Received: 14/12/2020

Respondent: Richborough Estates

Agent: Star Planning and Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Objection is made to Policy 4D on the basis that a more refined approach to the location of self and custom build plots across the Borough, reduce reliance on allocated housing sites delivering plot and specific self and custom build plots across the Borough. The trigger for self and custom build plots being based upon the number of market dwellings not all dwellings on a site. The submission of a ‘sales strategy’ for self and custom build plots.

Change suggested by respondent:

It is recognised that some of the matters raised in this objection may be suggested by the Council to be included in the proposed Supplementary Planning Document (SPD) but the policy context must be properly established in the Local Plan. Accordingly, the changes sought to make Policy P4D more effective are:
a) A more refined approach to the location of self and custom build plots across the Borough, reduce reliance on allocated housing sites delivering plot and specific self and custom build plots across the Borough.
b) The trigger for self and custom build plots being based upon the number of market dwellings not all dwellings on a site
c) Submission of a ‘sales strategy’ for self and custom build plots. This would apply to all sites where such housing is provided. The content of what might be in a strategy can be included in the SPD.
d) Deletion of any valuation requirement in favour of the ‘sales strategy’. If the valuation requirement is maintained then the purchaser must pay.

Full text:

1. Richborough Estates Limited supports the principle of the Council meeting its statutory duty to provide plots for self-build and custom homes on the register. However, the approach being adopted is crude and lacks any real thought about what types of sites people on the register may wish to build upon. Accordingly, an objection is made to Policy P4D which requires amendment to make it more effective.

2. The supply of plots for self-builders and those wishing to erect custom homes is fundamentally based upon a requirement for developers of allocated sites (of over 100 dwellings) to make the plots available based upon 5% of open market dwellings. The policy does include some criteria which may result in a different provision being made. However, there are 5 matters which justify further consideration being given to the supply of self and custom build plots.

3. Firstly, although a Borough wide figure is provided, there is no analysis of where the greatest demand for such plots exist. Someone living at Tidbury Green may not want a plot a Meriden and visa versa. A refinement is required whereby the provision of plots, up-to a maximum of 5% on allocations if this remains the approach to delivery, reflects demand based upon the register.

4. Second, consideration will need to be given to the cumulative number of market dwellings being provided within a particular locality. For example, is there sufficient demand for self and custom build plots to be provided on all the allocated sites at Balsall Common or within Blythe Ward?

5. Thirdly, an important factor is that will those people included on the register who want to build their own homes be happy erecting their property in the middle of a large housing allocation? Will there be the demand for such plots and where is the evidence to demonstrate this will be the case when drafting Policy P4D? As already noted, such allocations are the only source of supply of self and custom build plots under Policy P4D.

6. Fourthly, it can reasonably be expected that a Design and Access Statement and potentially a Design Code will be required for any large allocation. Such documents will establish the design and architectural approach to the development of a housing site. Will the parameters and constraints associated with a Design Code be conducive and attractive to those on the register wanting a self or custom build plot? The architectural freedom of the prospective self-builders will be curtailed.

7. A related point will be that the self-builders would be the subject of the same implementation conditions and planning obligations as the housebuilder. The Council will need to consider how this interaction would work if a self-builder failed to satisfy a condition of the outline consent or meet an obligation. Purchasers of market dwellings do not have to be concerned about such matters because they are generally the responsibility of the housebuilder to satisfy.

8. Finally, the requirement for self and custom build plots is based upon 5% of the market dwellings being provided on a site. It would, therefore, be more appropriate if the policy referred to the size threshold triggering the requirement being based upon 100 market dwelling rather than all dwellings. This would ensure a consistent approach otherwise there should be provision for 5% of the affordable homes being self-build.

9. In Richborough Estates’ view, it would be more appropriate for the Council to give consideration to the diversification of supply by the specific allocation of a range of smaller sites across the Borough for self and custom builders. These sites can be targeted to where there is a known demand based upon the register. The provision of dedicated sites is the approach adopted by Stratford on Avon District Council in its emerging Sites Allocations Plan (it has reached Regulation 18 stage).

10. The drafting of Policy P4D also needs to be revisited, specifically Criterion 2. As part of a larger allocation it may not be possible to offer such plots into the market fully serviced to the boundary and with unconstrained access to the highway. The development of the plots would need to follow the phasing of a scheme which may mean that the plots have to be sold in advance of these requirements being met. Further, it is also the case that what happens if plots are left vacant for 12 months because there is no interest and how would a traditional housebuilder be able to come back and erect their own houses?

11. It would be more appropriate, by a condition, for a ‘sales strategy’ to be submitted and approved as part of the first reserved and for the self and custom build plots to be brought forward in accordance with the approved details.

12. There is no justification as to why the value of the plots will need to be the subject of an independent valuation by a Registered Surveyor. If the plots are offered to the market in an agreed form via the ‘sales strategy’ (e.g. via approaching people on the register, posting details on a specialist website, asking a local agent to market the plots or placing plots in a specialist Auction) then the market will determine what price is paid. Incidentally, who will pay for the independent valuation the seller or the purchaser? It will need to be the purchaser.

13. Although unlikely to be a significant issue for the majority of allocations, sight should not be lost of viability considerations because, if it is necessary, at application stage an assumption would need to be made about the likely revenue from the sale of self and custom build plots.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11217

Received: 14/12/2020

Respondent: Mr Mark Horgan

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We do not support Policy P4D and the requirement of allocated sites of 100 dwellings or more to contribute 5% of open market dwellings in the form of self and custom build plots. National guidance does not require allocated sites to contribute land for self and custom build plots (Planning Practice Guidance (PPG) Reference ID: 57-025-201760728).

The Council’s ‘Self Build and Custom Housebuilding Register’ provides an indication of the level of interest, but further analysis is required on the specific requirements of respondents. There is no robust evidence provided as to how the threshold of 100 dwellings was calculated nor the provision of 5%.

Change suggested by respondent:

The self and custom build requirement should be removed from the Local Plan. The Council should only encourage landowners to provide these plots where appropriate.

Full text:

Dear Sir / Madam,
On behalf of Mark Horgan, please find attached a response to the Draft Submission version of the Local Plan Review in regards to his land interests at Winterton Farm, Blythe Valley (SHELAA reference 173).
We have submitted the following:
• Covering letter;
• Five Consultation Response Forms;
o Policy P4C
o Policy P4D
o Policy P4E
o Policy P5
o Policy P17
• Promotion Document (January 2016).
Please contact me if you have any queries with the submission.
Kind regards
Jess

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13717

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

P4D. We accept that the Council is justified in making provision for self and custom build housing in order to comply with the Self and Custom Housebuilding Act, the Housing and Planning Act, Planning Policy Guidance and the needs identified on the self-build register.
However, having considered the justification for Policy P4D and the Council’s ‘Meeting Housing Needs Topic Paper’, we disagree that the Council has sufficiently evidenced its proposed requirement for 5% of open market dwellings on residential sites of 100 units or more to comprise self and custom build plots.
Such a policy needs to be justified with robust evidence of need in order to be found sound. Currently, there are limited details provided as to how the 5% requirement has been derived and how this figure relates to local need and demand for self and custom build plots across the borough.
This prescriptive, borough-wide requirement to provide 5% threatens the Council’s ability to meet its local housing need requirement if there is no localised need or demand for such plots and so they remain vacant, as opposed to being built out and offered to the market as part of a more traditional developer build offering.
If self or custom build plots are not built out and remain vacant for a long period, this has adverse implications for viability and other Local Plan objectives and is also harmful to the visual and residential amenity of those living in close proximity to them.

Change suggested by respondent:

We propose that an additional criterion is added to the policy, to allow flexibility and to ensure that there is evidence of local demand before this is required as part of a planning application proposal. We also propose an additional criterion whereby if there is no firm interest in self and custom build plots on a site within 6 months of the marketing of those plots, they could then be developed for open market housing instead.

This approach will enable the provision of self and custom housebuilding if local demand exists, but also ensure that homes are delivered to the market if such demand does not materialise in practice. This will maximise the ability of the Council to deliver its overall local housing need requirement.

Full text:

See attachment

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13753

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The requirement in Policy P4D goes beyond the guidance provided in the PPG which seeks local authorities to "engage" with landowners and "encourage" them to consider self-build and custom housebuilding. There is an over-reliance upon the Self Build Register to justify the requirement, with the criteria for expressing an interest being relatively limited.

Change suggested by respondent:

The requirement to provide 5% on allocated sites of 100 dwellings or more should be replaced with an ‘encouragement’ to provide self-build on allocated sites of 100 dwellings or more having regard to the latest robust evidence.

Criteria 2 of Policy P4D should make it clear that after the marketing period (which should be less than 12 months), any unsold plots should revert back to the original developer.

Full text:

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13819

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

An individual showing interest via a Housing and Custom Build Registers rarely equates to a genuine desire / ability to build on a Self / Custom Build plot. The actual demand is likely to be significantly lower.

The blanket policy approach, requiring 5% of open market dwellings to be delivered in the form of Self and Custom Build Plots on sites of 100 dwellings or more, does not take account of localised needs or site specific constraints to delivery.

Change suggested by respondent:

The policy should be revoked as it is fundamentally unsound.

Full text:

Dear Sir / Madam,

Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').

I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.

Kind regards

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13868

Received: 14/12/2020

Respondent: Barratt David Wilson Homes - Land south of Broad Lane

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to P4D. Requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision for 7,605 houses through allocations above 100 houses/ UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations, against 374 entries on register. PPG advises Councils to engage and encourage provision. Alternatively, Plan could identify custom build sites. Similar policy elsewhere has been deleted at examination

Change suggested by respondent:

Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites

Full text:

Introduction
Paragraph 18 sets out that the site allocations from the Solihull Local Plan (December 2013) will be brought forward. We consider that the automatic allocation of these sites which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach. We address this in more detail under our comments in respect of Policy 4.
Finally, Paragraph 21 refers to neighbourhood plans and the importance SMBC places on these. Paragraph 30 of the National Planning Policy Framework (NPPF) sets the most recently adopted policies will take precedence. SMBC may wish to set this out within this section, to make it clear that the LPR will take precedence upon adoption over any currently adopted Neighbourhood Plans.
Soundness – The Plan is not:
- Justified
Change Sought:
- Existing allocations should be tested for deliverability prior to re-allocation
- The hierarchy of neighbourhood plans should be made clear
Vision
Given that paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positively worded.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- The vision should be more positively worded in order to significantly boost the supply of housing
- The need to release lower performing green belt to meet identified needs, and preserve higher performing parcels, should be set out
Providing Homes for All
Policy P4C Meeting Housing Needs – Market Housing
We object to the inflexible market housing mix which is prescribed within this policy. The NPPF encourages provision of balanced and mixed communities catering for a wide range of the population.
Individual sites should cater for a wide range of housing types and sizes. Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long term sustainable communities. Instead it will result in a transient community where people will not be able to form long term neighbourhoods as they will need to move on as their circumstances change if there are insufficient homes of the right size on a site to accommodate them. We do not consider that this represents good planning and consider that the focus should be on building strong healthy communities which can cater for all, rather than simply planning for short term ownership.
The inclusion of a prescribed housing mix runs counter to the criterion elsewhere within the policy which allow a number of factors to be taken into consideration. This plan has a significant lifespan and to prescribe a housing market mix which is to remain in place for the whole of plan period does not provide sufficient flexibility for adaptation to current housing need and demand. We have seen with the current pandemic the way external factors can influence people’s choice of lifestyle.
Soundness – The Plan is not:
• Justified
• Effective
Change Sought:
• Amendment of policy to allow for housing mix based on up to date market evidence
Policy P4D Meeting Housing Needs – Self and Custom Housebuilding
The latest Annual Monitoring Report (March 2020), covering the period 2018/19, sets out that for the period November 2018 – October 2019 there were 374 entries on the Self-build register.
As such, requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision is being made for 7,605 houses through allocations above 100 houses and the UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations.
The Planning Practice Guidance (PPG) advises that the Council should engage with landowners who own sites that are suitable for housing and ‘encourage’ them to consider self-build and custom housing and who are interested in provision. Imposition of mandatory requirement goes beyond encouragement.
Following the example of Stratford District for example, the Council have specifically identified custom build sites which are discreet standalone small sites.
We also include extracts from the Bedford Local Plan Inspector’s Report (Appendix 4) where the Inspector recommended deletion the policy akin to that being proposed here as the policy was not justified with reference to the self-build register. The same principle applies here in that the amount being sought is over double that on the register.
Soundness – The Plan is not:
• Justified
• Consistent with national policy
Change Sought:
• Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites
Policy P5 Provision of Land for Housing
Policy P5 sets out the Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing supply to deliver 15,017 additional homes in the plan period. This would result in an average annual housing land provision target of 938 net additional homes per year. This annualised target is made up of a stepped requirement with 851 homes per year delivered between 2020-2026 and 991 dwellings delivered between 2026-2036.
Demand
A Housing Need Technical Report has been provided (December 2020) (Appendix 5) and should be read in conjunction with our commentary on Policy P5. In summary, this Note makes the following key points:
• Planning Practice Guidance (PPG) states the Standard Method (SM) figure represents the minimum housing need, and there may be circumstances whereby need is higher;
• The Draft Plan identifies the clear economic growth aspirations for the Borough, including the nationally significant growth planned for the UK Central Hub. This is a circumstance where housing need may exceed the minimum need. If it does, housing delivery must be of a quantum to support these aspirations;
• The Council’s 2020 HEDNA confirms that the calculation of housing need is underpinned by the growth at the UK Central Hub. The Hub is projected to generate an additional 13,000 jobs to the baseline Experian job growth forecast (10,000 jobs) included in the HEDNA;
• The HEDNA tests several economic-led housing need scenarios. However, the UK Hub Scenario assumes only 25% of the additional 13,000 jobs created by the Hub are to be taken up by Solihull residents. This results in the housing need (816 dpa) underpinning the Plan;
• However, this ignores the ‘Growth A’ scenario which concludes that 908 dpa would be required based on the ‘Adjusted Local Growth’ scenario. This scenario assumes that strong industries in Solihull will outperform the baseline Experian forecast, resulting in an additional 5,680 jobs to the baseline (10,000 jobs) over the Plan period, with Solihull residents taking up these jobs;
• However, no scenario is presented to show what the housing need would be based on the UK Central Hub scenario being fulfilled in full by Solihull residents. It is important to understand this so that the duty to cooperate discussions referred to in the HEDNA are well informed;
Barton Willmore provide these sensitivity scenarios based on two approaches to commuting, and two approaches to underlying demographic rates (mortality, fertility, and migration);
• The results of our testing are summarised in Table 7.1:
Table 7.1: Solihull Borough – Barton Willmore Demographic Forecasting 2020-2036 Scenario Demographic rates Jobs per annum 2020-2036 Dwellings per annum 2020-2036
Dwelling-constrained:
Standard Method
2016 ONS rates
7721 – 8132
807
2018 ONS rates
1,0141 – 1,0682
Employment-constrained:
UK Central Hub
2016 ONS rates
1,437
1,1991 – 1,2482
2018 ONS rates
1,0361 – 1,0852
Source: Barton Willmore Development Economics
1 Commuting Ratio 0.98
2 Commuting Ratio 0.93
• Growth of between 1,036 and 1,248 dpa would be required to support the UK Central Hub scenario (between 16,576 and 19,968 dwellings in total);
• This represents an increase of between 220 dpa and 432 dpa on the housing need calculated by the HEDNA (816 dpa), or an additional 3,520 to 6,912 dwellings over the Plan period;
• Our analysis of historic levels of job growth in Solihull 1991-2019 shows a range of 1,225 and 1,650 jobs per annum (jpa). This highlights that the UK Central Hub scenario (1,437 jpa) is a realistic assumption;
• The HEDNA identifies an ‘acute’ situation in respect of affordable housing need. Our analysis suggests that the HEDNA’s conclusion on overall need (816 dpa) should be increased to meet as much affordable need as possible.
• Furthermore, our analysis of unmet need in the wider GBBCHMA suggests that the 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031, and for Birmingham alone the deficit in unmet need is between 11,294 and 13,101 dwellings up to 2031;
• In addition, there is significant unmet need up to 2031 based on the existing Standard Method coming from Birmingham City and the Black Country. This amounts to unmet need of between 25,543 and 27,350 dwellings up to 2031. If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031. This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect once Birmingham’s Local Plan becomes older than 5 years in 14 months’ time;
Adoption of the proposed changes to Standard Method consulted on by Government in summer 2020 would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
• Furthermore, the unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.
• In summary, the analysis in this report results in the following broad conclusions:
1. The SM’s minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub and the ‘acute’ need for affordable housing in the Borough;
2. Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario;
3. Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered. Additional unmet need will be created post 2031.
As such, in order to ensure the LPR is positively prepared, SMBC should seek to plan for more housing, and should allocate further sites.
SUPPLY
Further to the above, and as set out above, we also consider that some elements of the supply should be reviewed:
Dealing with the supply side of the equation, we make the following objections to the various components of supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’. Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.
Solihull Local Plan sites
We question the automatic inclusion of Solihull Local Plan sites which have yet to be granted planning permission. The current Plan was adopted in 2013 and the Council cannot currently demonstrate a 5-year supply of housing. In this situation, the Council should be encouraging every suitable site to come forward. The fact that these sites have not come forward despite the housing shortfall, suggests that these should not be considered ‘deliverable’ housing sites without significant justification as to why they will now come forward when they have not to date.
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply. We consider that any sites to be delivered in this way should be considered as windfall developments.
Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.
UK Central Hub
We consider that given the scale of the UK Central Hub proposals, the rate of delivery assumed by the Council is overly optimistic. The Council have not provided any trajectory for the Site, and we note that the August 2020 consultation did not contain any firm commitments to delivery timescales or set out any delivery partners.
This assertion is supposed by the findings of the Lichfields’ Report1 that sets out the average time from outline planning application to the first delivery of homes is 8.4 years. The average build out rate is 160dpa.
As such, taking this into account, and based on a LPR adoption date of 20222, we consider the first completions will likely be C.2030. With an average build out rate of 160dpa, this means that approximately 960 dwellings will be delivered during the Plan Period, assuming that the housing is within the first delivery phases (the August 2020 consultation referenced a mix of uses coming forward). While more outlets may increase the speed of delivery, the amount of infrastructure required also needs to be taken into account. The type of supply also needs to be considered, with UK Central Hub likely to be geared towards apartments.
As such, we consider that 1,780 houses should be removed to take into account the likely delivery timescales.
Trajectory
We also note that SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase. The Inspector assessing the Guildford Local Plan set out:
39. In the submitted plan, the combined effect of the stepped trajectory in Policy S2 together with the “Liverpool” methodology (in which the delivery shortfall accumulated over the first 4 years of the plan (2015/16 to 2018/19) is spread over the whole plan period), would have deferred a significant proportion of the housing requirement to the later years of the plan. Set against the (then higher) housing requirement, this would not have met the Government’s objective to boost the supply of housing in the shorter term. (our emphasis)
We consider that SMBC should take the same approach as Guildford and allocate further sites to meet need early in the Plan Period. The existence of the UK Central Hub is not of a sufficient size to warrant a different approach (i.e. it is not akin to a new settlement).
Further, as with the withdrawn Uttlesford Local Plan, this stepped trajectory may create a fragile 5 year housing land supply position, taking into account the ambitious delivery targets of the UK Central Hub and the delivery concerns relating to the draft allocations set out below. The Inspectors’ letter relating to the withdrawn plan states:
29. This calculation relies on the use of a reduced annual requirement of 568 dpa for most of the years, as it is based on the stepped trajectory set out in Policy SP3. It is also based on what we consider to be unrealistic commencement/housing delivery dates for two of the Garden Communities (North Uttlesford and Easton Park, as set out above). So, whilst the Council can, in theory, demonstrate a 5.65 year HLS, we are concerned that if the housing delivery at North Uttlesford and Easton Park slips by just one year, as seems very likely, this would result in 100 less dwellings in this 5 year period. This would result in a very fragile 5 year HLS position.
There are comparisons that can be drawn here based on the stepped trajectory and the anticipated 5.37 year supply upon adoption.
The Inspectors for the withdrawn Uttlesford Local Plan also referenced the need to meet the full objectively assessed need for market and affordable housing in the housing market area (NPPF Paragraph 47). The HEDNA states there is a ‘clearly acute’ shortage of affordable housing. The proposed stepped trajectory therefore may worsen the affordability problem as it would delay the provision of housing until late years of the plan period.
Taking the above into account, we consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
This is a reduction of 3,521 and, as such, to meet the increased demand set out above, and take into account the concerns relating to a stepped trajectory, a review of the supply is required and additional sites allocated.
The Council should also ensure that a large number of these sites can be delivered early on in the Plan Period in order to take account of the likely later delivery of some other sites.
Soundness – The Plan is not:
• Positively prepared
• Justified
• Effective
• Consistent with national policy
Change Sought:
• Review of demand and amendment to the strategy
• Review of supply and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible
Improving Accessibility and Encouraging Sustainable Travel
Policy P7 Accessibility and Ease of Access
We consider that the requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- Policy should be clarified that there are other ways of ensuring sustainable transport options are available
Policy P8 Managing Travel Demand and Reducing Congestion
Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.
Soundness – The Plan is not:
• Consistent with national policy
Change Sought:
• Point 2(ii) should be deleted
Protecting and Enhancing our Environment
Policy P11 Water and Flood Risk Management
With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Deletion of point relating to confirmation from relevant infrastructure owner
• Clarification as to obligation requirements and the necessary tests
Promoting Quality of Place
Policy P17 Countryside and Green Belt
Within Point 1 of the policy, SMBC is seeking to safeguard best and most versatile agricultural land (BMVAL) unless there is an overriding need for development that outweighs the loss. BMVAL is referenced within the NPPF at Paragraph 170 which states that planning policies should contribute to and enhance the natural and local environment by taking into account a number of criteria. One of these is:
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.
Firstly, we consider that including reference to BMVAL within a policy relating to Green Belt seeks to conflate two separate issues. Further, as can be seen above, the test set out by the NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL. As such, we consider this point should be deleted.
SMBC have set out, within Point 4, a number of different factors that may be taken into account when considering very special circumstances.
Further to this, point 5 sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given Green Belt is a spatial designation, designed to prevent sprawl, we consider that this requirement goes beyond the scope of the Green Belt, as set out in the NPPF. The LPR contains policies relating to protecting landscape, where necessary, and as such, this point should be deleted.
Soundness – The Plan is not:
• Positively prepared
• Consistent with National Policy
Change Sought:
• Deletion of point 1
• Inclusion of further factors which may create very special circumstances
• Deletion of point 5
Policy P17A Green Belt Compensation
Paragraph 138 of the NPPF sets out that ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.
Policy P17 is seeking to require this by requiring development on sites removed from the Green Belt to provide appropriate compensatory improvements to environmental quality and accessibility of remaining Green Belt in the form of a Section 106 Agreement utilising the below hierarchy:
1. Compensatory requirements as set out as part of the Local Plan masterplans
2. Where no compensation has been set out within the Local Plan masterplan, improvements are provided as:
i. Improvements within the Green Belt adjacent to, or in close proximity to, the development site;
ii. Improvements within the Green Belt adjacent to, or in close proximity to, the settlement or area accommodating the development;
iii. Improvements within the Green Belt in an area identified for environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.
3. In the event it is robustly demonstrated that none of the above options can be satisfied then the Council will accept a commuted sum.
Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.
Soundness – The Plan is not:
• Consistent with National Policy
Change Sought:
• Reconsideration of the policy to ensure that it is evidenced based, does not impact upon viability of schemes, and is in accordance with national policy
Delivery and Monitoring
Policy P21 Developer Contributions and Infrastructure Provision
Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Confirmation that digital infrastructure provision allows for viable development
Settlement Chapters
Policy BC1 Barratt’s Farm, Balsall Common
We note that 1,756 new homes are proposed for Balsall Common across the plan period with the sole justification seemingly being that it contains both a primary and secondary school and has a full range of retail and associated facilities. However, it is still described as a rural settlement with no significant areas of employment and the distribution strategy remains one of “proportional distribution”. 1,756 dwellings to a single rural village would be completely disproportionate. There is discussion in the document regarding delivery of a by-pass; provision a station car park; improved public transport and a new primary school. However, there is no discussion as to how these are to be funded / delivered relative to the level of growth identified. In addition, there is discussion regarding the scope to enhance the existing local centre and the provision of a village centre masterplan. However, this land is in multiple ownerships and there are no proposals for what these enhancements could entail or how they could function – particularly with a by-pass in place which could actually draw trade away from the existing centre.
There is no assessment of the ability of Balsall Common to deliver this level of growth in such a small area. Whilst clearly some sites (i.e. Barratts Farm) will be able to have multiple outlets, the ability of the market to absorb and deliver multiple sites at any one time in a rural location should be reviewed; particular when Balsall Common will be acutely affected by HS2 – both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
We also note that Barratts Farm is in multiple ownerships and these are described as “complex” in paragraph 541. This is the single largest site and the one which is proposed to deliver the by-pass. Within the previous draft of the Plan, it was stated that this site would only be taken forward if the landowners / promoters could demonstrate they are working on a collaborate and comprehensive basis. Reading paragraph 541, this collaborate working has clearly not been secured in the way it was envisaged and nothing additional is suggested to demonstrate that joint / collaborative working is possible.
The relief road is identified as being necessary for Barratts Farm in particular with the policy advising that is required early in the plan period. The road is provisionally to be funded via CIL payments; and grant funding which “may” be possible through the WMCA. Firstly, CIL payments can only be secured through those sites which will come forward in the future however these sites are Green Belt sites and cannot therefore be delivered until the Local Plan Review is completed and the subsequent CIL schedule is adopted. Secondly, there is no grant funding proposal in place to fund the road. As it currently stands this road is not deliverable. The road is required to be delivered early in the plan period i.e. before there are significant CIL funds in place and, potentially, at a point where, in order to receive grant funding, applications should be being made now / near future.
There has to be serious doubt over the ability of Barratts Farm to be delivered within the anticipated timeframes and therefore places serous doubt over the plan as a whole given the scale of this allocation.
The Sustainability Appraisal notes that there are limited employment opportunities within Balsall Common and that people travel outside of the settlement to work. As such, it is noted that the expansion of this settlement would fly in the face of sustainability objectives of reducing the need to travel to areas of employment. Whilst such a case could be made for the majority of the rural areas of the Borough, it is heightened especially here when such a large proportion of future growth is identified for one rural settlement.
At this stage, the level of growth attributed to Balsall Common is disproportionate and that inadequate research has been undertaken into the deliverability of this level of growth and the associated aspirations; and the ability of the market to deliver this level of growth in a rural area is considered to be unrealistic.
On the basis that we do not consider the sites identified to be deliverable and the significant shortfall in supply identified by the more realistic timescales we have identified for UK Central, we propose an alternative site – Land at Hawkshurst (Site 544) as an alternative to meeting part of this need. To date this site has been inappropriately assessment by the Council and a more appropriate evaluation of the site is given in the section below.
Policy BL1 – West of Dickens Heath
The policy requires that the proposal for BL1 secures the relocation of the existing sports provision to a suitable site in the local vicinity. Until such time as these facilities are relocated or a plan is in place to secure timely relocation (which should include the grant of planning permission in our view, given that any site will be in the Green Belt), then the site cannot come forward for development. Our key concern here relates to Site 4 (West of Dickens Heath). It is noted that the identification of a Local Wildlife Site within the site hampers re-provision within the site itself and therefore alternative options will need to be pursued outside of the site. We consider that these alternatives should be considered now as clearly, as it currently stands, the pitches will be lost with no alternative in place (and therefore no guarantee of any re-provision). This is all the more important given that the land in the area is all located within the Green Belt and therefore any proposals which may, for example, include floodlighting, will have to be carefully considered against the Green Belt ‘tests’. We understand that the loss of these facilities is causing significant local concern particularly with no proposals for replacement.
The Council have had ample time to identify and secure alternative provision and therefore the fact that this is not identified within the plan, suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Policy KN1 Hampton Road, Knowle
As with the Site West of Dickens Heath, this draft allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable. However, this pre-judges any application, for which the detail is not known, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Site Assessment Criteria
We consider that a more dispersed growth option should be considered and, as set out previously, consider that the land at Broad Lane, Hawkshurst (Site 544) is ideally suited to make an important contribution to the Council’s housing need. Following the Council’s own site selection criteria, we set out why this site is a suitable and deliverable alternative site which can be delivered utilising existing infrastructure:
We object strongly to the manner in which Site 544 has been assessed in the site selection process for the reasons which are set out below – and on that basis, object to the inconsistent application of the methodology.
Firstly, in assessing Site 544, the Council deemed that the site did not pass ‘Step 1’ – which is the initial, high-level sieving process. Sites which are not taken forward at this stage are then not subject to the more refined ‘Step 2’ analysis. We consider the manner in which the process was applied is fundamentally flawed and have carried out our own assessment (using the Council’s own analysis) to demonstrate that the site should not have been discounted at Step 1 and should have been included in Step 2.
STEP 1
The first stage in the sieving process is a high-level look at the following:
(i) Brownfield vs greenfield
(ii) Urban areas vs Green Belt
(iii) Accessibility
Sites can be rated from Priority 1 (brownfield in urban area or settlement) to Priority 10 (greenfield in isolated highly performing Green Belt location). A traffic light rating is then applied – sites which falls within Priority 1 to Priority 4 are green sites; Priority 5 sites are yellow; Priority 6, 6b and 7 sites are blue; and Priority 8, 9 and 10 sites are red. Red sites fail Step 1 and are not taken forward to Step 2 for assessment. Site 544 was incorrectly identified as a Priority 9 red site and was not therefore taken forward to Step 2.
In summary, Site 544 is a greenfield and Green Belt site. However, it is accessible (being on the edge of the Coventry urban area) and also within an area with a low GB score of 5. Therefore, it should be allocated a Priority score of no higher than 5 (yellow). We review below the manner in which this initial sieving assessment was flawed - taking Site 544 step by step through the same assessment process as the Council.
Green Belt
In the Green Belt Assessment 2016, Site 544 is identified as part of Refined Parcel RP83:5 which has a combined score of 5, within a range from the highest performing Green Belt sites (12) to the lowest performing sites, scoring as low as 0. With a score of 5, site 544 is clearly a lower performing site. The starting point for consideration as a Priority 5 site is a score of 5 or lower in the Green Belt––Site 544 falls into that category. The results of this assessment are backed up by our own Green Belt assessment which is included with this submission.
Accessibility
The second part of the criteria relates to accessibility and to achieve a Priority 5 ranking, the site is required to be in an accessible location. This is defined as:
(a) On the edge of the urban area or
(b) On the edge of a settlement which has a wide range of services and facilities including a primary school and a range of retail facilities.
Site 544 adjoins the urban edge of Coventry – indeed in the Council’s Site Assessment, the site is identified as possibly being an extension to Coventry.
It should be noted that in relation to the Publication Draft Plan, the Council have updated the Accessibility Study to take account of retail / surgery provision in adjoining LPA areas, however they have then not used this information to re-visit first principles and determine whether sites have been appropriately assessed from the start. Therefore, whilst this site now scores more positively, its ‘priority 9’ status has not been re-evaluated despite an Addendum to the Site Assessments being produced and the Accessibility Study being revisited. It appears that despite the site being on the urban edge of Coventry this has been discounted due to the sites geographical relationship with Coventry as opposed to Solihull. However, accessibility should be based upon spatial location rather than boundaries. The fact that the retail offer is in Coventry will not prevent residents of Hawkshurst using it.
For the absolute avoidance of doubt therefore, we enclose our own submission produced by Phil Jones Associates which demonstrates that the site is in a suitable and sustainable location.
It is fundamentally incorrect for Site 544 to have been ‘sieved out’ at Step 1. The site should have been correctly assessed as a Priority 5 yellow site as it meets the two necessary criteria. The site, therefore, should have been taken forward for a more detailed analysis in Step 2.
On the basis that the site does pass Step 1 – we have carried out the Step 2 assessment using the same table and criteria as the Council. There are no scorings or weightings attributed to the Step 2 analysis – it assessed on a qualitative basis.
STEP 2 – REFINEMENT CRITERIA
FACTORS IN FAVOUR
In accordance with the spatial strategy
(including only proportional additions to lower order settlements (i.e. those without a secondary school or not located close to the urban edge).
The preferred spatial strategy would be to locate development needs close to where they arise. However the Plan identifies that there is limited land available to achieve this and therefore the Council has had to look at alternative options, which includes land released from the Green Belt in the form of urban extensions and also followed a more dispersed strategy for development. They have sought to focus development in locations that are, or can be made, accessible and sustainable. Such locations are identified as typically being on the edge of urban areas (or within ruralsettlements) that have a greater range of services. Potential locations for development include adjoining the urban edge or a highly accessible settlement. This will have the benefit of focusing on urban areas and sustainable urban extensions to provide the best opportunity for achieving accessibility and delivering public transport improvements.
It is abundantly clear that geographically Site 544 adjoins the urban edge of Coventry – Coventry is the second largest City in the West Midlands, after Birmingham. Site 544, as confirmed in the SHELAA assessment, would be viewed as an urban extension to Coventry and there is, therefore, no doubt that Site 544 is in accordance with the Spatial Strategy, which seeks to locate development in the most accessible locations. Coventry is clearly such a location and there is nothing within the Spatial Strategy which would rule against this.
Therefore, it can only be concluded that the development of Site 544 would be in accordance with the Spatial Strategy.
Any hard constraints only affect a small proportion of the site and/or can be mitigated.
The SHELAA does not identify any hard constraints – we concur with this assessment.
The site would not breach a strong defensible boundary to the Green Belt.
There are no strong existing defensible Green Belt boundaries that would be breached. The existing boundaries to Bannerbrook Park comprise simply hedgerows, some of which were planted in conjunction with the existing development. The same form of boundary treatment can therefore be replicated on this site and indeed is proposed within the masterplan included with this submission.
Any identified wider planning gain over and above that which would normally be expected.
Following discussions with local undertakers regarding the lack of burial space available within the Borough, the landowners are willing to offer land for a multi faith burial space which will provide a much needed facility for the Borough and also secure the long term permanence of the Green Belt boundary in this location.
Sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
See above.
If finer grain accessibility analysis (including output from the Accessibility Study) shows the site (or the part to be included) is accessible.
The Accessibility Study is flawed when it comes to assessment of sites on the Solihull / Coventry boundary. The Study provides a scoring for accessibility for facilities within 1,200m of a site, however when assessing facilities beyond the administrative area of Solihull only facilities within 800m of the boundary are assessed, this is despite an updated assessment being provided in 2020 which proposed to apply some adjustment of standards and yet makes no sensible adjustment to standards for cross boundary provision. Sites in such locations are not therefore being assessed on a comparable basis. Furthermore, the assessment is only being undertaken of walking distances and makes no allowance for accessing facilities by bike. The document references ‘shared cycle’ routes but then makes no consideration of people actually using them for cycling. Clearly were cycling to be factored in, especially for those sites, which adjoin major settlements and therefore have access to a good cycleway network (such as Site 544) then their accessibility criteria would be much improved.
Whilst it is noted that some provision is now taken off cross boundary retail provision and public transport which has moved Site 544 to a higher scoring position; it is still not being assessed on a comparable basis.
There is a shared footway/cycleway through the Bannerbrook Park development which can be extended into Site 544. Furthermore, opportunities will be considered to accommodate a bus route through Site 544 and on through Bannerbrook Park.
It is therefore clear that the proposal can only be defined as being in an ‘accessible location’.
FACTORS AGAINST
Not in accordance with the Spatial Strategy
As set out above, the development of this site is in accordance with the Spatial Strategy
Overriding hard constraints that cannot be mitigated.
There are no hard constraints identified.
SHELAA Category 3 sites unless demonstrated that concerns can be overcome.
The site is not identified as a Category 3 site in the SHELAA. We make comments below in respect of the flaws of SHELAA assessment and carry out our own assessment.
Sites that would not use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
As already confirmed, the site uses existing defensible boundaries and proposes to strengthen the defensible boundary and strengthen existing hedgerow planting.
If finer grain analysis shows the site (or the part to be included) is not accessible.
As previously confirmed, the Council have failed to consider the proximity of services in Coventry on a fair basis and because of this, it is not possible to determine how detailed the assessment has been. However, given that the site adjoins a major urban area is it simply not feasible to draw a conclusion that the site is inaccessible.
If the site is in a landscape character area that has a very low landscape capacity rating.
It is wholly unreasonable if the Council have used this criterion to discount this site. According to the Council’s Landscape Character Study (December 2016) this site falls within Landscape Character Area (LCA) 26 – which covers the eastern fringe of the Borough – yet significant Green Belt release is proposed in other areas of the Borough which are in an identical LCA. With one blanket ‘very low’ landscape capacity conclusion for such wide areas it cannot be used to discount some sites and not others – there must be parity in assessment. Furthermore, the study itself (page 49 – text adjoining Table 24) confirmed that it is not possible to establish a baseline sensitivity to change without having details of a given development proposal and therefore the conclusions should be taken as a guide only. On this basis, we do not consider it appropriate to use this criterion as a basis to discount sites given sites with the same assessment have been given a ‘green’ score’.
We enclose with this submission our own detailed, site specific, landscape and visual appraisal which confirms that the site has the ability to accommodate development of scale which is comparable to the surrounding area without compromising the function of the surrounding Green Belt.
If the SA appraisal identifies significant harmful impacts.
The SA identified 2 harmful impacts:
(i) The site contains over 20ha of Grade 1 – 3 agricultural land.
The site is wholly Grade 3 agricultural land – clearly within Grade 3, the site could in fact be Grade 3b land which would mean it is not BMVL. Furthermore, the Regional ALC mapping, which was last updated in November 2018, shows this to be the prevailing land type across the Borough which is not unsurprising. As a result, a number of proposed allocated sites have the same classification. It is not therefore appropriate to identify this as a harmful impact when a consistent approach has not been applied across the board.
(ii) The distance to jobs is identified as 8km within the SA
This is clearly incorrect as the SA treats the administrative boundary between Coventry and Solihull as a line which people will not cross. This is clearly incorrect. As already stated, there is for example a good bus connection to Warwick University which is a key local employer as well as Coventry city centre which offers multiple employment opportunities. The SA has applied the same approach to all services and facilities – relating its conclusions only to Solihull Borough and thus the distances to shops / schooling / healthcare are distorted. In addition, we highlight that this is a specific issue related to Balsall Common also (which is also further away from Coventry) and yet the Council has seen fit to allocate in excess of 1,700 dwellings in Balsall Common.
In summary:
• The site has medium / high accessibility – at the same level as the other ‘green sites’ identified in the Draft Plan.
• The site is in lower performing Green Belt than other ‘green sites’ in the plan.
• The site has existing defensible Green Belt boundaries which can be strengthened.
• The site has no constraints within the development area which cannot be mitigated in the normal way.
• The site has the same landscape character as other ‘green sites’.
• It is not, therefore, credible for Site 544 to be categorised as a ‘red’ site.
• For this reason, we consider the score for Site 544 should be corrected and the Council should re-visit their assessments from first principles.
As is evidenced from the corrected SHELAA commentary the site is rated as a Category 1 – Deliverable Site. Such sites are deemed to be available now, offer a suitable location for housing now and there is a reasonable prospect that housing will be delivered on site within 5 years from the date of adoption of the plan.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13899

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified when considering data from the 2020 AMR. This is far in excess of the need shown and the Council should consider providing specific site/allocations to meet this need, in line with Paragraph 61 of the NPPF.
The provision of such plots on strategic -size housing sites is likely not what those on the register are seeking, meaning they are left empty which could delay the delivery of housing.
This policy should be deleted, and SMBC should either allocate specific provision of this need, or offer general support for this type of housing but not set specific thresholds.

Change suggested by respondent:

Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites.

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14049

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P4D as set out makes no differentiation is for flatted schemes, where this is unlikely to be feasible. The should be an additional clause of exemption (vii) where the type of development proposed makes this unfeasible, for example whether flatted development, or specialist housing proposals.

Change suggested by respondent:

Addition of clause (vii): The type of development proposed, for example whether flatted development or traditional housing, or specialist housing proposals.

Full text:

See attachment

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14060

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Turley

Representation Summary:

Appreciate the flexibility built into the policy to enable an applicant to negotiate the amount and type of provision of self and custom care homes at the point an application is submitted.

Full text:

See attached documents.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14167

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to the onerous approach being applied to the delivery of custom and self-build housing. Whilst it may widen housing choice, on large scale allocations there is a risk that the delivery of housing could be slowed.
Having reference to the PPG there is no requirement for self or custom build to be provided as part of larger allocated sites.
Applying the 5% requirement leads to potentially multiple separate contracts that would need to be agreed with interested parties.
Whilst the Self Build register may provide an indication of the level of interest, this needs to be analysed further to uncover the specific requirements of respondents. Where suitably evidenced, specific sites could be allocated for self-build and/or custom housebuilding.

Change suggested by respondent:

The Council should provide a robust assessment of demand including an assessment and review of data held on the Council’s self-build register. The register may provide an indication of the level of interest, but this needs to be analysed at a deeper level to uncover the specific requirements of respondents. Without this exercise having been undertaken and supporting the Council’s conclusions, the policy is not justified.
The policy should be amended to allow for the provision of such plots to be left to the discretion of the developer based on market trends, which are liable to change over the plan period. On larger sites we consider this requirement should be left to the developer’s discretion. This would ensure that the policy is suitably justified.

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14224

Received: 14/12/2020

Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Considering all the other policy demands, delivery of housing schemes could be compromised by the Self and Custom Housebuilding requirement (Policy P4D). The flexibility provided within the policy, which enables case by case assessment, would only be workable if allowed at planning application stage which is generally discouraged. Evidence on how the matter has been considered in detail and other options should be demonstrated.

Full text:

Representations to the Local Plan Review Regulation 19 consultation: Land at Bickenhill Road, Marston Green
Please find attached representations and their appendices plus the relevant form on behalf of our client L&Q Estates.
I would be grateful if you could acknowledge receipt

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14291

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Taking into account all of the other policy demands, delivery could be seriously compromised by the requirements of the policy. The flexibility provided sounds sensible in principle. However, this would only be workable detailed considerations were allowed at the planning application state.
As the current system discourages the debate on viability at the decision-taking stage, with such matters expected to be addressed when plan-making, it cannot be assumed that this policy would work in practice.
There is nothing in the explanatory text to demonstrate how the matter has been considered in more detail at this point. The Local Authority cannot simply rely upon developers to provide for all self and custom-build housing in fulfilment of its legal duty and should be exploring other options for delivery. Without evidence of other options having been thoroughly explored, L&Q Estates object to this policy.

Full text:

See attachments.

Land at four ashes road dorridge

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14395

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Taking into account all of the other policy demands upon delivering housing schemes, delivery could be seriously compromised by the requirement of Policy P4D. Given that the current system now generally discourages debate on viability at the decision-taking stage, with such matters expected to be addressed when plan-making, it cannot be assumed that this policy would work in practice. SMBC should not be relying upon developers to provide for all self and custom-build housing in fulfilment of its legal duty and should be exploring other options for delivery. Without evidence of other options having been thoroughly explored, L&Q Estates object to this policy.

Full text:

Land at Damson Parkway - see attachments for full details

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14488

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The requirement for self and custom build plots in Policy P4D is not supported by the HEDNA, unduly onerous and not justified. SMBC should provide a robust assessment of demand including an assessment and review of data held on the Council’s Register, which should be
supported by additional data from secondary sources to understand and consider future need for this type of housing. There is no evidence for the threshold at which provision is required or the percentage requirement, or clarity on the position if plots are unsold. This restrictive burden is contrary to national guidance which will lead to viability, delivery and management issues and similar proposals have been removed at examinations

Change suggested by respondent:

Policy P4D should either be deleted from the Local Plan in full or amended to remove the requirement for developers of allocated sites to contribute to self and custom build housing.
Should the self and custom housebuilding policy remain, it should be amended so as to be supportive and encourage such forms of building. The provision of such plots on allocated development sites should only be at the discretion of the developer and based on the market requirements at the time.
If the Council believe the policy is justified it is requested that the policy be amended to allow for either
self-build or custom build plots, thus partly reducing the onerous nature of the policy whilst allowing
developers to adequately plan and manage sites.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14544

Received: 11/12/2020

Respondent: Bloor Homes

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to requirement for self and custom build plots on each of the development sites over 100 dwellings as threshold and proportion not justified, and goes beyond advice in PPG. Policy has no regard to the potential for negative impacts.
The register may provide an indication of the level of interest, but this needs to be analysed further to uncover the specific requirements of respondents and test whether people have the means to acquire the land/ construct their own property or location on a large housing development is suitable.
There are practical issues to consider in providing self and custom building such as the day to day operation of such sites, consideration of potential health and safety issues of having multiple individual construction sites within one development and the subject of a design code.

Change suggested by respondent:

The requirement for allocated sites of 100 units or more to provide 5% of open market dwellings in the form of self or custom build plots should be removed.
Provision of self or custom build plots should be the subject of discussion with those expressing an interest, and once the Council has an understanding of the type and range of sites that are sought allocations (for example in the form of clusters) should be identified and allocated.

Full text:

Policy BL1
References contained at point 5 of the policy clearly indicate that there is a significant question
mark over its deliverability. The policy states “Until such time as these facilities [existing sports
facilities south of Tythe Barn Lane] are appropriately relocated or robust plans have been
confirmed to secure a timely relocation that would prevent the closure of any associated
clubs….development of the site will not be supported”. Until the relocation of the sports
pitches that enable the deliverability to take place on site BL1 (land West of Dickens Heath) it
cannot be justified in policy terms. There are significant delays associated with resolving this
issue; firstly suitable alternative locations have to be found for the pitches to be relocated to;
and secondly, those sports pitches have to be laid out and often that takes a 2 to 3 year time
span to set them up because of the need for specialist grass and proper drainage and sub soil
preparation for that grass to be laid.
Paragraph 16 of the National Planning Policy Framework (‘NPPF’), requires plans to “be
prepared positively, in a way that is aspirational but deliverable”. Savills emphasis
This reference provides a very real risk to the deliverability of this allocation and something we
consider the Council should not be leaving to aspiration or fortune. The proposed allocation of
the 350 homes is being put at jeopardy where alternative locations cannot be found for the
existing sports pitches and on this basis the site should only be safeguarded at this stage and
an alternative site such as site 192 (land east of Tilehouse Lane, Tidbury Green) be included
in the plan as this site is not the subject of these deliverability concerns and performs lower in
Green Belt terms than BL1.

We consider that there are several options the Council have to make this allocation sound.
Firstly they should confirm the latest position on the progress made on the relocation of the
sports pitches required to make BL1 deliverable. As written BL1 is not justified or effective as
the text (bullet 5) is clear that until these facilities are relocated or robust plans the relocation
has not been confirmed “development of this site will not be supported”. This is not positive
planning and puts much needed housing delivery at risk. Secondly the Council could consider
whether a larger area of land around Tidbury Green such as land east of Tilehouse Green
land could be considered as part of the comprehensive strategy to deliver the housing as it
does not require the relocation of sports pitches. This could mean that some or all of the
sports pitches remain in situ. Until the position regarding the sports pitches is made clear then
either the allocation should be downgraded to safeguarded land or an alternative allocation is
provided that is deliverable site such as the site to the south (site 192 ) - land east of
Tilehouse Lane, Tidbury Green.
In Green Belt terms site 192 scores 6 which is less (i.e. lower performing in Green Belt terms)
than the proposed allocation BL1 (score of 7). In landscape sensitivity terms site 192 scores
the same (as they are in the same sub area - LCA2) as BL1.
In allocating site 192 and safeguarding site BL1, we consider the plan would be more effective
and sound. This representation should be read in conjunction with representations made to
policies P1 and P5 which are fundamental to the Borough’s housing strategy.

Policy P1
Officially, the Government state that the HS2 Interchange station will be completed by 2026. Given delays that often happen on large infrastructure project, we consider that this timescale is likely to be pushed back. Paragraph 280 of the draft plan states that the HS2 line is ex-pected to open between 2029 – 33. Paragraph 89 of the plan refers to 2,740 homes being delivered up to 2036. If the plan is adopted in early 2022, with two years lead in for planning and a year for site works, development may not begin until 2025. This allows for eleven years to develop out the 2,740 units. If this was spread out over eleven years equally, this would equate to 249 dwellings per annum. This is a very high level of delivery, that we do not con-sider has been adequately demonstrated as being deliverable, considering delays in delivery of the HS2 Station.
It should be noted that in 2018, the Hub Framework stated that delivery of 2,240 homes during the plan period would include up to 550 homes being delivered at the NEC up to 2022. We have reviewed Solihull’s online application register and cannot see reference to an application for residential development at the NEC. We therefore consider that the levels of delivery en-visaged, even in the early stages of the plan period are overambitious. We therefore consider that this policy is not effective in the way that it is currently drafted. Furthermore, we under-stand that UK Hub requires a new connector road from the Coventry Road to a new motorway junction on the M42, being a “just in time” for JLR and its Damson Parkway units. Whilst it has received in-principle go-ahead, the land has to be purchased and the road has to be built which could involve a significant delay.
We have requested further information form the Council in relation to the planned trajectory and stages of delivery of these housing numbers. We understand that such details are not available. We are therefore also not aware of how much of this housing delivery the Council considers will be required to be delivered before the HS2 station is completed.

We therefore request further information in relation the planned delivery of the site and reas-surance that the delivery of the HS2 station does not prejudice the delivery of the 2,740 homes to be delivered up to 2036. Notwithstanding we challenge the assumed delivery rate proposed by the Council in this location and the provision of circa 20% of the overall dwelling provision in a single location in a high density format which does not accord with the Bor-ough’s housing requirement for predominantly family housing.
We request confirmation from the Council of the amount of housing and related infrastructure that will be coming forward for completion before this date. A whole community is needed to be formed from scratch. Although this is not beyond the realms of possibility, we request further evidence from the Council to ensure that conclusions regarding housing delivery are effective to deliver a sound plan.
The proposals for circa 20% of the housing target in a single location should be reviewed as they are not considered to be sound, deliverable or provide an effective or justified strategy.

Policy P4A
We do not consider that this policy is effective (NPPF paragraph 35) as it does not provide
developers with flexibility and the mix of housing should be considered at the application stage
in accordance with the Housing and Economic Development Needs Assessment 2020 (‘HEDNA’).
For example, as stated under point 9 of Policy P4A, it may be appropriate for sites that
are within the town centre to provide a higher percentage of 1 and 2 bedroom dwellings compared
to a site on the edge of a rural settlement. The HEDNA sets out a range for of mixes for
each dwelling size. We support the Council providing some guidance on housing mix but this
should accord with the mix proposed in the HEDNA.
The NPPF (Annex 2) sets out a definition of affordable housing and identifies affordable housing
tenures which includes: affordable housing for rent, starter homes, discounted market
sales and affordable routes to home ownership. Policy P4A sets out a proposed tenure requirement
for 65% social rent and 35% shared ownership within the Borough. The HEDNA
has been used as the evidence base to support this policy. The HEDNA has identified that
there is a need for affordable rent within the Borough (paragraph 7.101). The HEDNA also
states that there is a clear requirement for both social and affordable rent but has recommended
to the Council that they do not propose a rigid mix on the split between social and
affordable rented housing. Furthermore, shared ownership is a narrow offer of affordable
housing that is not social rented. Intermediate housing is considered to be a more appropriate
definition to use.
Affordable Rent is also encouraged by Homes England and should be included in the Council’s
list of tenures. Nevertheless, Policy P4A makes no provision for affordable rent. Therefore we request that the Policy P4A is amended to refer to both affordable rent and social rent.

The HEDNA sets out range for the proposed affordable housing mix which provides flexibility,
it is not clear how or why the Council has chosen to apply fixed percentage requirements for
social rented and shared ownership homes. Each application for residential development
should be considered on its merits and the type and mix of affordable housing should be discussed
with the Council’s housing and planning departments at the pre-application stage. We
consider that this will make the policy more effective than simply applying a fixed blanket approach
across all residential sites in the borough.
Policy P4A (bullet 6) should be amended to include reference to a requirement for social and
affordable rent rather than purely social rent. The policy should also be amended to replace
“shared ownership” with “intermediate housing” which includes Shared Ownership, Shared
Equity, Discounted Market Housing for Sale etc

Policy P4C
Point 1 of Policy P4C lists a range of criteria that the Council will have regard to when negotiating housing mix on allocated and windfall major development sites. Within the list it notes that the “current indicative Borough-wide needs assessment” and “the existing mix of market housing and local housing demand” will be taken into account. Point 3 of Policy P4C goes on to set out specific requirements for housing mix. We do not consider that this policy is effective (NPPF paragraph 35) as it does not provide developers with flexibility and the mix of housing should be considered at application stage in accordance with the Housing and Economic Development Needs Assessment 2020 (‘HEDNA’).
Paragraph 122 of the National Planning Policy Framework (NPPF) sets out the importance of planning policies to make efficient use of land taking into account: the identified need for different types of housing, local market conditions and viability, the availability and capacity of infrastructure, the desirability of maintaining an area’s character and setting and the importance of securing well-designed and attractive places. The housing mix proposed in the HEDNA provides a range for each dwelling type which reflects the ‘latest’ evidence in 2020. However, many sites are different in character and surroundings and therefore a blanket approach to the unit mix is not considered appropriate or sound. Furthermore, market demand can change and so this ‘latest’ evidence may not be representative of need when planning applications are submitted in the future. As developers and national housebuilders have a focus on building and products that are deliverable and meet market needs, the policy should not provide a fixed dwelling mix and a blanket approach to the size and mix should be avoided as not all residential sites will be appropriate for this mix. A rigid approach to mix and house type could have a negative effect on development viability, leading to inflexibility and result in unnecessary delays to developments coming forward.
In addition to the above, the policy does not make any reference to the approach that may be required where there is an existing proposed housing mix set out in ‘made’ Neighbourhood Plans (‘NP’).

We request that the Council removes reference to mix (point 3) from Policy P4C and instead refer indicative housing mix ranges in accordance with the HEDNA within the explanatory text. Developers should be ‘encouraged’ and not ‘required’ to accord with the mixes set out in the explanatory text. This is the approach the LPA has taken to density requirements (Policy P5) in the Submission Draft and we consider this flexible approach should be used for market housing mix. Market demand at the time of the application should play an important role in determining the mix of dwellings delivered on a site.

Policy P4D
Policy P4D requires allocated sites of 100 dwellings or more to contribute 5% of open market
dwellings in the form of self and custom build plots on each of the development sites. We
object to this requirement and do not consider that the Council has provided sufficient
evidence to justify a threshold of 100 dwellings or for these sites to contribute 5% self and
custom build homes. The PPG (Reference ID: 57-025-201760728) sets out ways in which the
Council should consider supporting self and custom build homes which includes: developing
policies in their Local Plan for self-build and custom housebuilding and “engaging with
landowners who own sites that are suitable for housing and encouraging them to consider
self-build and custom housebuilding” [Savills emphasis]. There is no requirement in the PPG
for self or custom build plots to be provided as part of new housing allocations and landowners
should only be ‘encouraged to consider’ promoting their land for self and custom build
housing. The policy has been prepared without any regard to the potential for unintended
consequences arising from this approach which could have a negative impact on the policy
delivering the 5% self or custom built homes. We consider the policy to be ineffective.
Paragraph 195 of the Submission Draft states that there are 370 individual entries on the
Council’s ‘Self Build and Custom Housebuilding Register’. The register may provide an
indication of the level of interest, but this needs to be analysed in further detail to uncover the
specific requirements of respondents. Furthermore, this register does not test whether people
have the means to acquire the land and privately construct their own property or whether their
requirements align with being located on a large new housing development. Without this
exercise having been undertaken and supporting the Council’s conclusions, we do not
consider that Policy P4d to be justified or effective.
Furthermore, there are also practical issues to consider in providing self and custom building housing plots on an allocated site. For example, the day to day operation of such sites and
consideration of potential health and safety issues of having multiple individual construction
sites within one development. Other considerations that do not appear to be factored in
include where a large housing site is the subject of a design code. What approach in the
Council expecting self-build projects to take in the design of their “bespoke” self or custom
built home?

Policy P4E
Policy P4E requires major residential development sites to be built to Category M4(2) building regulations and at least 5% of dwellings to be wheelchair user friendly. The Planning Practice Guidance (PPG) states that Councils have the option to “set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access” where there is a justified need (Savills emphasis) for this requirement (Reference ID: 56-002-20160519). The PPG does not state what level of provision should be required within Local Plan policies.
Requiring all new dwellings to be built to the Category M4(2) standards will result in larger dwellings and in turn less dwellings being delivered per net developable hectare. The NPPF is clear that planning policies should support development that makes efficient use of land (Paragraph 122). Furthermore, as a Green Belt authority with limited brownfield redevelopment opportunities (Housing Land Supply table on page 69 of the consultation document) and part of a Housing Market Area with a shortfall in housing (NPPF Paragraph 123), Solihull Council should be making the most efficient use of land on the Green Belt sites proposed to be released in order to avoid significant Green Belt release in future Local Plan Reviews. We therefore consider that 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 available. Without this approach, the policy will not be consistent with national planning policy or effective, making Policy P4E unsound.
In addition to the above, the PPG is clear that “Local Plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable, neither of the Optional Requirements in Part M should be applied” (Reference ID: 56-008-20160519) [Savills emphasis]. Policy P4E includes 4 criteria (Point 5) for how the policy will be applied flexibly which relate to: viability; the need to achieve a successful development; and whether the standards would prejudice the realisation of other planning objectives. However, none of the criteria make reference to the suitability of a site to accommodate accessible dwellings, for example their topography or local demographic requirements. We consider that the policy should be amended to accord with the PPG guidance or evidence provided which justifies the position being proposed in the policy.
Policy P4E also requires developments of 300+ dwellings to provide specialist housing or care bed spaces. By taking this approach it is appears that there is a disconnect between the Council’s housing strategy and the health and well-being of the various communities with differing specialist and health requirements across the Borough. Although the policy does not state how many dwellings or care bed spaces should be provided as part of the development, the viability appraisal has assumed that 0.5ha of land on each site will be delivered and has concluded that this will improve viability on the site as the land can be sold to a specialist provider. No evidence is provided to justify 0.5ha provision. In our experience a full care village will require sites larger than this and so the requirement put forward in this policy may only cover part of the specialist housing requirement it needs to.
We consider that this requirement is ambiguous and not shaped by effective engagement between the Council, developers and specialist care providers (NPPF paragraph 16) for the following three reasons:
1. There is no clear evidence which demonstrates or justifies how the Council has cho-sen the 300 dwellings threshold;
2. Point 6 of Policy P4E lists criteria where applications for specialist housing will be supported, for example, the site needs to be accessible to shops and services and the specialist housing needs to meet specialist building regulations. It is not clear whether this criteria will also be used to determine whether the 300+dwelling sites are actually suitable locations for specialist housing or care bed spaces; and
3. It is unclear whether all specialist and senior living providers will be interested in sites as small as 0.5ha and whether it is appropriate for specialist sites to be dispersed around the borough rather than provision being met on a few specifically allocated sites in suitable and accessible locations. Providers of open market housing and spe-cialist / senior living accommodation are usually different. Therefore, it is not as sim-ple as seeking these specialist requirements to be provided as part of the larger resi-dential allocations. Careful consideration of the demographic and health needs of each community need to be assessed and understood to enable appropriate sites to be identified that will meet the specialist and elderly care accommodation needs that is required for each community.
We consider that the requirement for 300+ dwellings sites to deliver specialist housing or care bed spaces should be removed from this policy and instead specific and suitable sites which accord with Point 6 of Policy P4E should be allocated within the plan to deliver this provision.

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.
The requirement for 300+ dwellings to deliver specialist housing or care beds paces should be removed from this policy and specific sites for specialist and senior living should be allocated to deliver this specialist provision. This will ensure that the requirements of Point 6 are met.

Policy P5
Policy P5 states that the Council will allocate at least 5,270 dwellings to meet their housing
requirement of 15,017 dwellings between 2020 – 2036. This equates to 938 dwellings per
annum. The proposed number of allocated dwellings has decreased by 1,040 dwellings
between the Draft version of the Local Plan Review document (January 2019) (6,310
dwellings) and the Submission Draft (5,270 dwellings). From our understanding, three
allocations have been removed since the Draft version (Sharmans Cross Road, Jensen House
and TRW/The Green) for 790 dwellings, four allocations have increased their capacity (East of
Solihull, Lavender Hall Farm, Oak Farm and Pheasant Oak Farm) by 235 dwellings and seven
of the remaining allocations have seen a reduction in their capacity by 485 dwellings.
Furthermore, 600 dwellings have been added to the windfall category. Given that this is
meant to be a plan-led process we do not consider this approach to meet the test of the plan
being positively prepared.
We do not support the proposed reduction in the number of allocated sites and the reduction
in site capacity for seven of the proposed allocations. As we have stated in our separate
response to Policy P4E, the NPPF is clear that planning policies should support development
that makes efficient use of land (Paragraph 122). Furthermore, as a Green Belt authority with
limited brownfield redevelopment opportunities (Housing Land Supply table on page 69 of the
consultation document) and part of a Housing Market Area with a shortfall in housing (NPPF
Paragraph 123), the Council should be making the most efficient use of land on the Green Belt
sites proposed to be released in order to avoid significant Green Belt release in future Local
Plan Reviews.
The Housing Land Supply in the table of page 69 of the Submission Draft document states
that across the plan period the UK Central Hub area is expected to deliver 2,740 dwellings;
2,240 dwellings at the NEC and 500 dwellings at Arden Cross. This equates to around 18% of
the proposed housing requirement for the Borough (15,017 dwellings). Due to the amount of
development proposed in this area, we consider that the majority of dwellings delivered will be
apartments. The Council should be seeking to deliver a balanced housing portfolio across the
Borough. By relying on 18% of the provision in one location and all potentially high density
living which doesn’t meet the needs of most families, we do not consider the Council to be
presenting a positively prepared plan nor is this strategy considered to be justified or effective.
Furthermore, having reviewed the evidence base for the UK Central Hub area, we do not
consider that 2,740 dwellings will be delivered at the NEC and Arden Cross between now and
2036. Firstly, the evidence documents seem to show different housing figures for the sites For
example, the NEC masterplan (2018) states that 2,500 dwellings could potentially be
accommodated on the site (page 34) whereas the Hub Framework Plan (2018) states that
1,780 dwellings could be delivered at the NEC. The Hub Framework Plan also sets out
potential timescales for development coming forward. Table 1 sets out a land use trajectory
which states that between 2018 – 2033 only 1,675 dwellings are expected to be delivered on
the Arden Cross and NEC sites. Between 2018 – 2022, circa 130 - 550 dwellings were
expected to be delivered at the NEC. With no planning application submitted at the NEC, we
consider it unlikely that any dwellings will be delivered by 2022. In light of this, we do not
consider that the expected housing delivery for UK Central of 2,740 dwellings up to 2036 to be
justified or supported by any of the Council’s evidence base and is therefore considered
unsound. We consider that the target for the anticipated number of houses to be delivered at
UK Central should be reduced to a more realistic level and additional housing sites added to
the portfolio rather than being overly focussed around UK Central or simply added to the
windfall provision. If almost 20% of the Council’s housing target is to be met by high density
accommodation in a single location, then this needs to be evidenced and justified as it
represents a departure from the Borough’s previous housing strategy and prevailing demand
for family housing. The constraints associated with the timing in the delivery of HS2 are also
not clear or explained.
Windfall provision has increased by 600 dwellings between the Draft version of the Local Plan
Review document and the Submission Draft and is 50 dwellings per annum more than the
adopted Local Plan. The NPPF states that there must be “compelling evidence” that windfall
sites will provide a reliable and realistic source of supply having regard to the strategic
housing land availability assessment, historic windfall delivery rates and expected future
trends (paragraph 70). As Solihull is constrained by Green Belt and there are only limited
deliverable brownfield land opportunities (77 dwellings identified on page 69 of the Submission
Draft document), we do not consider that 200 dwellings per annum of windfall dwellings is
realistic or an effective way to plan for the future. Rather than relying on windfall provision, the
Council should have additional sites identified and allocated and/or safeguarded for residential
development.
In relation to the contribution towards the HMA’s housing need, Solihull is currently proposing
to contribute 2,105 dwellings towards the Housing Market Area shortfall (paragraph 2.28 of the
Submission Draft document). We do not consider that this is a sufficient contribution from
Solihull Council towards the contributions (North Warwickshire is contributing an additional
3790 dwellings to support the Greater Birmingham HMA shortfall) and there is no evidence to
justify how the 2,105 dwelling “offer” was calculated. The most recent HMA Position Statement
states that the remaining shortfall up to 2031 is now estimated to be 2,597 dwellings.
However, it is now apparent that there will be a shortfall post-2031 (minimum 29,260
dwellings). As the plan period for the Submission Draft will cover up to 2036, we consider that
this should be addressed within the Local Plan Review. Once an agreement is in place
between the HMA authorities as to the distribution of the shortfall, a Statement of Common
Ground should be prepared to demonstrate to the Inspector that Solihull has complied with the
duty to cooperate (PPG Reference ID: 61-010-20190315) and that Solihull has addressed key
strategic matters through effective joint working and not deferred them to a subsequent Local Plan Review (PPG Reference ID: 61-022-20190315).
The housing need figure should be calculated at the start of the plan-making process and kept
under review until the Local Plan Review document is submitted for Examination (PPG
reference 2a-008-20190220). This is important for Solihull as at the same time as consulting
on the ‘White Paper – Planning for the Future’ document (August 2020), the Government has
also confirmed its intention to review the standard methodology. Using the Government’s
revised standard methodology that was published for consultation, the minimum housing need
figure for Solihull could increase by 25% to 1,011 dwellings per annum (16,176 dwellings
between 2020-2036). This could equate to a total minimum housing requirement of 3,264
more dwellings than the proposed housing requirement figure between now and 2036.
We consider that the Council could plan for this additional growth by considering the two
scenarios that may emerge from the Standard Method calculations. The first option could be
what the Council is currently planning for which is using the current Standard Method figure of
807 dwellings. The second option that the Council should also consider is the revised
Standard Method which could see the annual housing need increasing to 1,011 dwellings. In
order to demonstrate a robust approach at Examination and to be able to present a positively
prepared Local Plan (NPPF paragraph 35), we consider that the Council should plan for
additional growth than currently proposed and identify additional sites which could be
allocated if the Inspector requires the Council to plan for growth in accordance with the revised
standard methodology figure or if they agree with our findings set out above, that the UK
Central Hub area is unlikely to deliver 2,740 dwellings by 2036. The Council should recognise
and test a range of housing growth options that may be derived from changes to the standard
method and wider HMA growth requirements and plan for these options.
Point 6 of Policy P5 sets out that appropriate density of new housing will be based on a variety
of factors which are listed in the policy. We support the flexibility provided within this policy,
however, in order to comply with national policy, we consider that the criteria listed under Point
6 should be the same criteria that are listed under paragraph 122 of the NPPF. Paragraph 122
states that in order to make efficient use of land, planning policies should consider: the
identified need for different types of housing, local market conditions and viability, the
availability and capacity of infrastructure, the desirability of maintaining an area’s character
and setting and the importance of securing well-designed and attractive places. Currently,
Point 6 makes no reference to local market conditions and viability which we consider is an
important consideration that should be taken into account when identifying the appropriate
density and mix for each site.
In addition to the above, the indicative densities set out under paragraph 240 of the
Submission Draft state that the Council will seek to achieve indicative densities of 40dph for
houses, 90dph – 150dph for apartments and 50-70dph mixed areas at the UK Central Hub
area. The Arden Cross Masterplan shows 13.04ha of land designated for residential use
(Page 47). 500 dwellings are expected to be delivered during this plan period once HS2 is
completed. Although they are not expected to all be delivered in this plan period, if 3,000
dwellings are expected on the Arden Cross site, densities will need to be circa 250dph –
300dph in order to achieve the Council’s target. This is a significant increase on the densities
of development currently achieved in Solihull and the Council will need to ensure that the
impact of these densities is reflected and considered in the Local Plan Review document.
In summary, we consider that the Council should seek to allocate additional sites for
residential development within the plan because we consider that:
1. the UK Central Hub site will be unlikely to deliver 2,740 dwellings up to 2036 which
could leave a shortfall of circa 700 – 1,000 dwellings;
2. the revised Standard Methodology could increase the Council’s minimum housing
need by 25%; and,
3. the proposed contribution towards the HMA shortfall is not a sufficient or justified contribution
in light of the identified shortfall post-2031 which should be addressed in the Local Plan Review as the plan period runs until 2036.
In light of the above, the Council will need to identify additional sites to meet their increased
housing need requirements. Our client’s site at land east of Tilehouse Lane, Tidbury Green
(Site reference 192) is being promoted for circa 300 dwellings and public open space. The site
is located immediately adjacent to Dickens Heath and Tidbury Green in area which has been
expanded and is identified for further expansion in the Submission Draft given its accessibility
and sustainability.
In the Council’s evidence base site 192:
 is located within a lower performing Green Belt parcel;
 is located within a Medium / Low landscape parcel;
 has ‘Medium / High’ accessibility;
 is a Category 1 site in the Site Assessment Paper as it performs well against the suitability,
availability and achievability assessments.
In summary, our client’s site is strongly performing potential development site in the Council’s
evidence base and should be considered for a residential allocation to assist the Council in
meeting their housing needs. It would provide a logical extension to the proposed allocation
(BL1) land West of Dickens Heath.

Having reviewed the evidence base, we consider that the UK Central Hub area will not deliver
2,740 dwellings in this plan period, an additional contribution should be made towards the
HMA shortfall and the revised standard methodology requirement should be taken into
consideration by the Council before submitting the Local Plan for Examination. Furthermore,
the most recent reduction in some allocations and an the revised plan strategy of adding
another 600 homes to the windfall provision should be reviewed. We consider that the
Council should allocate additional housing sites and select those which have performed well
against the Council’s evidence base criteria and are in sustainable locations.
The land being promoted by Bloor Homes (site 192) should be considered as an additional
allocation being a high performing site adjacent to the proposed allocation (BL1) land west of
Dickens Heath.
Amend Point 6 of Policy P5 to accord with the criteria listed in NPPF Paragraph 122 and
amend the indicative densities table on page 76 to set out more realistic densities for the UK
Central Hub area if 5,000 dwellings are going to be delivered on the UK Central Site
(paragraph 830 of the Submission Draft document).

Policy P9
Policy P9 proposes to set additional requirements on development sites in order to reduce energy demand and minimise carbon dioxide emissions. The requirements include all new dwellings having to:
 achieve a 30% reduction in energy demand over and above the requirements of Build-ing Regulations Part L;
 be net zero carbon from 2025;
 provide at least 15% of energy from renewables; and,
 provide at least 1 charging point for electric vehicles.
To justify the proposed 30% uplift, the Council’s ‘Protecting the Environment’ Topic Paper (October 2020) refers to paragraph 148 of the NPPF which states that “the planning system should support the transition to a low carbon future in a changing climate… It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions…and support renewable and low carbon energy and associated infrastructure”. These requirements are considered to be over and above the requirements of the PPG which states that Local Plans “can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes” (Reference ID: 6-012-20190315).
The PPG also states that if a Council is “considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development” (Reference ID: 6-009-20150327). Viability has been tested on the Governments preferred interim standard which shows that 30% uplift is “generally viable at 2020 land and sales values” (paragraph 113 of the Protecting the Environment Topic Paper). The Protecting the Environment Topic Paper refers to precedents set elsewhere in the UK. Having reviewed the examples given, London seeks 35% uplift but Milton Keynes and Reading only seek a 19% uplift. We do not consider that Solihull has sufficiently justified why it is proposing an uplift of 30%.
In relation to developments providing at least 15% of energy from renewables, consideration should be given to the capital cost and land take involved to achieve this requirement which we do not consider has been undertaken in the Council’s evidence base. Furthermore, it should be noted that it is now the case that sourcing energy from the National Grid can actually, in some cases be more sustainable than small scale renewable energy production as each year they are sourcing more of their energy from renewable sources.
The Council’s viability appraisal sets out that circa £6,000 per dwelling has been allowed for in order to meet the future homes standard and provide electric vehicle charging required by Policy P9. We consider that this is a significant amount of money per dwelling just to meet energy requirements without any of the other requirements being sought in the plan to be taken into account e.g. affordable housing, specialist housing, accessible dwellings, Green – Belt compensation and other S106 contributions and CIL monies that will be sought by the Council and statutory consultees.

Amend Policy P9 to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimise carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage. The requirement to reduce energy demand to over and above Building Regulations Part L should be removed as this does not comply with the PPG.

Policy P10
We note that reference is made to the requirement for a “net gain” in biodiversity of at least
10% compared with the pre-development baseline. It is not clear whether the Council intend to
bring a 10% requirement in ahead of the Environment Bill being passed, which is potentially
before the Plan’s scheduled adoption. We do not consider that the Council is justified in
bringing this requirement forward ahead of the Bill being progressed through parliament, and
secondary legislation has been passed and brought into effect.
We support reference to Natural England standing advice in relation to ancient woodland and
veteran trees. This is the most appropriate guidance to take note of in respect of these trees.
16 i makes reference to development proposals being required to demonstrate that they have
considered impact on tranquility. We request that the Council clarify what is meant the
reference to “tranquility”, and how the impact on tranquility can be effectively measured. We
are unsure how this will be assessed as part of a planning application. Without this evidence
we do not consider the policy as written to be justified or effective.

The requirement for a biodiversity net gain of 10% should be removed from this
policy and any requirements left to SPD once the Environment Bill is passed and
secondary legislation has been brought in.

Policy P15
Bloor Homes consider that climate change considerations should be a ‘fabric first’ approach to build i.e. building in such efficiencies to new homes that reduce the call on energy demand in the first place and avoids ‘retro fits’.
We generally support the approach to this draft policy but suggest that amendments are required to 2iv and 7 to make the policy more effective.

We request that the following amendments are made to the wording of this policy:
Point 2 iv of this policy should be amended as follows: “Where possible, make appropriate provision for water management within development, without causing unacceptable harm to retained features, utilising innovative design solutions.” The reason for adding “where possible” is to ensure that allowance can be made for site specific constraints such as ground conditions that may be present preventing delivery of SuDS.

Policy P17
When defining Green Belt boundaries, the NPPF states that Local Plans should “be able to
demonstrate that Green Belt boundaries will not need to be altered at the end of the plan
period” (Paragraph 139e). The Council’s evidence base acknowledges that there are limited
brownfield opportunities left in Solihull and so to meet their housing needs Green Belt release
is needed for this Local Plan Review and may therefore will be needed again in future reviews.
The NPPF encourages Councils to identify areas of safeguarded land in order to meet longerterm
development needs beyond the plan period (paragraph 139c). However, the Council has
not sought to safeguard any land for development as part of the Local Plan Review. This is
particularly surprising where the housing requirement for the Borough has been the subject of
several key influences, including proposed changes to the standard method and the HMA
shortfall (Birmingham and Black Country).
In order to be consistent with national policy, we consider that the Council should identify
areas of land that could be released from the Green Belt in this Local Plan Review and
safeguarded for future development should the Council not be able to meet their housing
needs or the housing needs of the HMA during the next plan period.
As stated in our separate response to Policy P5, a significant HMA housing shortfall is
expected from 2031 so it is likely that Solihull will need to contribute additional dwellings to
assist in addressing this shortfall. Therefore, safeguarding land for the future is needed in
order to meet the longer term development needs of the HMA.
When identifying potential sites to release from the Green Belt and safeguard, the Council
should choose sites in lower performing Green Belt parcels, which are adjacent to sustainable
settlements, accessible and considered suitable, achievable and deliverable in the Council’s SHELAA (Category 1). Our client’s land at Our client’s site at land east of Tilehouse Lane,
Tidbury Green (Site reference 192) is being promoted for circa 300 dwellings and public open
space. The site is located immediately adjacent to Dickens Heath and Tidbury Green in area
which has been expanded and is identified for further expansion (BL1 – Land west of Dickens
Heath) in the Submission Draft given its accessibility and sustainability.
In the Council’s evidence base site 192:
 is located within a lower performing Green Belt parcel;
 is located within a Medium / Low landscape parcel;
 has ‘Medium / High’ accessibility;
 is a Category 1 site in the Site Assessment Paper as it performs well against the suitability,
availability and achievability assessments.

To provide a plan which is more effective and responsive to these variables we consider that
the Council should have tested a number of scenarios and provided appropriate allocations
and safeguarded areas to enable them to flexibly respond to the ever changing
circumstances. We request that the Council consider identifying areas of land that could be
released from the Green Belt in this Local Plan Review and safeguarded for future
development should the Council not be able to meet their housing needs or the housing needs
of the HMA during the next plan period.
We consider that additional allocations and/or safeguarded ;and should be identified and in
that regard we consider that site 192 (land east of Tilehouse Lane, Tidbury Green) is a
suitable and sustainable opportunity that is deliverable.

Policy P17A
The planning practice guidance states that compensatory improvements to environmental quality and accessibility of remaining Green Belt will be incorporated into a Section 106 agreement. The NPPF (paragraph 138) does not specifically state that Green Belt compensation has to be sought through S106 contributions. The PPG states that compensation can be secured through CIL or conditions and the S106 can be used to set out the long-term maintenance of sites (Reference ID: 64-002-20190722). As Solihull is a CIL charging authority, we consider that the Council should also set out Green Belt compensation projects which can be paid for through CIL. The PPG states that when setting out policies for compensatory improvements, they may be “informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies, and could for instance include: new or enhanced green infrastructure; woodland planting; landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal); improvements to biodiversity, habitat connectivity and natural capital; new or enhanced walking and cycle routes; and improved access to new, enhanced or existing recreational and playing field provision” (Reference ID: 64-002-20190722). As local communities receive a percentage of the CIL contribution this could enable the local communities to identify the projects that they would like compensation to fund.
In terms of Green Belt compensation, there may be circumstances where the Green Belt compensation cannot be provided effectively on site or it could significantly reduce the net developable area of the proposed allocation. Where these circumstance exist, the Council should have an effective strategy in place that enables off site contributions to be made to Green Belt mitigation in other locations e.g. through the identification of donor sites.
Additionally, the Council has not provided any indication of how the level of compensation will be determined. We request that a formula or calculation be provided in order to determine the level of contribution that may be provided to allow developers to plan for this requirement on top of the other contributions / requirements being sought in the Local Plan Review.

We request that the Council amend Policy P17A to refer to the use of CIL as well as S106 agreements to set out the Green Belt compensation projects. We also seek confirmation from the Council as to the level of compensation that will be requested for sites removed from the Green Belt.

Policy P18
We object to the requirement at 2 vii for all new development to deliver new and improved health services. This is not justified and therefore not effective due to requirement being placed on all development sites without site specific consideration. Delivering new and improved health facilities as part of all new developments. New health facilities should not be a blanket requirement no all new developments and should be considered on a site by site basis. Where improvements are needed in health services or facilities, but a new building or facility is not required, then financial contributions could be sought to improve existing facilities.

We propose that the policy is amended to allow for financial contributions where improvements are identified as the necessary mitigation to make development acceptable in planning terms.

Policy P20
We object to the requirement in point 10 that new development should look to accommodate the needs of existing population. Although it is likely that the existing population will use any open space provided, it should be recognised that any contribution or enhancement to be agreed through a section 106 agreement should be directly related to the development and take account of the tests of Regulation 122 of The Community Infrastructure Levy Regulations (2010) and NPPF paragraph 54 and 56. In essence new development should only seek to mitigate the impacts arising from tat development and not resolve existing deficiencies.

Point 10 of the policy should be amended to remove the reference to providing for the open space needs of the existing population as this would be contrary to Reg122.

Attachments:

  • BL1 (463.91 KB)
  • p1 (309.38 KB)
  • P4a (308.72 KB)
  • p4C (306.95 KB)
  • p4d (309.88 KB)
  • p4e (315.52 KB)
  • p5 (342.90 KB)
  • p9 (395.18 KB)
  • p10 (301.48 KB)
  • p15 (298.09 KB)
  • p17 (385.89 KB)
  • p17a (307.99 KB)
  • p18 (207.29 KB)
  • p20 (315.80 KB)

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14629

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The 5% requirement for self and custom build plots is unsound. It places the burden on developers only, and goes beyond the PPG which seeks local authorities to "engage" with landowners and "encourage" them to consider self-build and custom housebuilding.
The HEDNA suggests an ‘encouragement’ approach alongside a policy requirement for strategic sites. On the basis of the current Register, it identifies that Solihull should be seeking to deliver 116 plots per annum. However, over-reliance upon the Register should be cautioned against in justifying any policy percentage requirement, particularly given the criteria for expressing an interest are relatively limited i.e. whilst an individual may express an interest the degree to which this is a realistic ambition cannot be determined.

Change suggested by respondent:

The following changes are required:
- The requirement to provide 5% on allocated sites of 100 dwellings or more should be replaced with an ‘encouragement’ to provide self-build on allocated sites of 100 dwellings or more having regard to the latest robust evidence.
- Point 2 of the policy should also be clear that after the marketing period (which should be less than 12 months), any unsold plots should revert back to the original developer.

Full text:

See attached documents

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14677

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst IM Land are
supportive of the principle of self and custom build, it is considered a better approach would be to allocate specific smaller sites for up to 5 dwellings for self-build rather than require a proportion of general housing allocations to accommodate this provision. The nature of self and custom build is that it is better related to smaller more individual sites to reflect individual and unique design rather than being part of larger housing developments. NPPG offers other ways local authorities can facilitate self build such as such using LA land or other land suitable for housing in the ownership of other landowners. The Policy is unsound as it may not be effective in delivering suitable self-build and custom
housing. The Policy should be reconsidered.

Change suggested by respondent:

The Policy is unsound as it is not effective in delivering suitable self-build and custom housing.
The Policy should be reconsidered.

Full text:

See attached Land North of Main Road, Meriden

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14763

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

No evidence to justify the percentage requirement for self and custom build. No requirement in the PPG for such plots to be provided as part of allocations.
Whilst the Self Build register may provide an indication of the level of interest, this needs to be analysed further to uncover the specific requirements of respondents.
The register does not test whether people have the means to acquire the land and privately construct their own property. Without this exercise having been undertaken and supporting the Council’s conclusions, the Policy is not justified.
Practical issues of having multiple individual sites within one development need to be considered.

Change suggested by respondent:

The requirement for allocated sites of 100 units or more to provide 5% of open market dwellings in the form of self or custom build plots should be removed from the Local Plan as this policy is not justified or in accordance with national guidance. The provision of self or custom build plots should be the subject of discussion with those who have expressed an interest, and once the Council has an understanding of the type and range of sites that are sought allocations (for example in the form of clusters) should be identified and allocated as self and custom build opportunities around the Borough.

Full text:

See attached documents

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14878

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Taking into account all of the other policy demands upon delivering housing schemes, delivery could be seriously compromised by the requirement to make a 5% contribution to Self and Custom Build Housing (offered for sale with outline planning permission, fully serviced to the boundary, with unconstrained access to the highway. The plots would be offered for sale for a period of 12 months to those registered on Solihull’s Self and Custom-build Housing Register)
Taking into account all of the other policy demands upon delivering housing schemes, delivery could be seriously compromised by such a requirement. The flexibility provided within the policy, which enables case by case assessment of matters such as viability and the impact upon other requirements of the scheme (such as the ability to deliver an appropriate housing mix) sounds sensible in principle. However, this approach would only be workable if such detailed consideration on a case by case basis was to be allowed at the planning application state.
Given that the current system now generally discourages debate on viability at the decision-taking stage, with such matters expected to be addressed when plan-making, it cannot be assumed that this policy would work in practice.
There is nothing in the explanatory text to demonstrate how the matter has been considered in more detail at this point. The Local Authority cannot simply rely upon developers to provide for all self and custom-build housing in fulfilment of its legal duty and should be exploring other options for delivery. Without evidence of other options having been thoroughly explored, L&Q Estates object to this policy.

Full text:

LAND AT BERKSWELL ROAD, MERIDEN see attached documents

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14921

Received: 14/12/2020

Respondent: ZF Automotive UK Ltd

Agent: Turley

Representation Summary:

- Welcome flexibility built into policy to enable an applicant to negotiate amount and type of provision of self and custom homes.
- Welcome marketing period of 12 months.

Full text:

See attached letter.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14932

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy P4D (Bullet Point 1):
- HBF supportive of policies to encourage self & custom build.
- Not supportive of policy requirements for 5% SCB on developments of 100+ dwellings.
- Council should not seek to burden developers with responsibility for delivery of SCB – contrary to national guidance.
- Council role should be to engage with landowners and encourage them to consider SCB, and not go beyond that.
- No rational for 100 dwelling threshold, or 5% provision.
- Could result in mis-match of provision, and oversupply of plots on larger housing sites in urban locations against demand for single plots in rural areas.
- Provision of self & custom build serviced plots must be justified by credible and robust evidence.
- Self build register may indicate a level of expression of interest in SCB but it cannot be reliably translated into actual demand, should such plots be made available.
- Council policy approach should be realistic and deliverable, and not remain unsold.
- Vacant plots could affect Council’s HLS.
- SCB serviced plots on larger developments adds complexity and slows delivery and difficult to coordinate different construction logistics.
- Where plots are unsold, policy should be clear these revert to the original developer. Reversion timescale should be as short as possible, 12 months is too long.
- Disagree with the Viability evidence on self-build plots, does not take into account all the cost.
- Policy will cause delay to processing planning applications and slow housing delivery.
- No robust evidence for demand for plots on larger housing sites.

Change suggested by respondent:

Policy P4D should be deleted.

Full text:

See attached letter

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 15035

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

- Unreasonable and unjustified to require 5% SCB plots on sites of 100+ dwellings. This would equate to 761 SCB plots on draft allocations. Latest AMR shows only 374 entries on the self-build register.
- Imposition of mandatory requirement goes beyond guidance in PPG to ‘encourage’ SCB.
- See also extracts (attached) from Bedford’s Local Plan Inspector’s Report – recommended deletion of similar policy. Same principle applies here in that amount being sought is double that on register.

Change suggested by respondent:

Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites

Full text:

See attachments.ARDEN GREEN – BARRATT DAVID WILSON

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 15105

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Support principle of Policy P4D and the broad approach to encourage self & custom build (SCB) plots.
- Not supportive of the specific policy requirement for the inclusion of 5% self & custom build housing on all site allocations and residential developments of 100 or more dwellings.
- Council should not seek to burden developers with delivery of SCB plots.
- Council should encourage landowners as per national policy.
- Provision of SCB plots must be based on uptodate evidence of demand, as per national policy and guidance.
- Policy approach should be flexible, and realistic, so that where provided they do not remain unsold.
- No rational for 100 dwelling or 5% thresholds.
- Risk of over-supply on large sites and mis-match with actual demand, e.g. single plots in rural locations.
- Larger sites typically more complex to deliver, more logistics and longer time periods. Coordination of SCB plots with wider site will be difficult.
- If evidence to include such a policy is justified, then recommend amendment, that if plots unsold for 12 months then should be built out as market housing.
- Further work required rather than blanket approach.

Change suggested by respondent:

Suggested amendments to the policy are outlined below:
Part 1 (
The Council will require developers of allocated sites to consider contributing to Self and Custom Build Housing on residential sites of 100 units or more.
Contributions should take the form of 5% of open market dwellings, but will take into account…
Part 2
The Council expects these plots to be offered for sale with outline planning permission, fully serviced to the boundary and unconstrained access to the highway for a period of 12 months to those Registered on Solihull’s Self and Custom Build Housing Register. If after 12 months, the self/custom build option(s) are not taken up, the land will revert to being built out for market housing. The value of the plots will be subject to an independent valuation by a Registered Surveyor.

Full text:

See Attachments

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 15123

Received: 13/12/2020

Respondent: Woods Farm (Christmas Trees)

Agent: Twelve Twenty One Planning Services

Representation Summary:

This is supported and is considered to be a key component of housing delivery and provision of choice.

Full text:

See attachments.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 15153

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to Policy P4D criteria 2. This is overly restrictive and onerous as demand for plots is likely to reflect wider demand for housing and may change over time. The demand for specific plots should be established prior to installing the necessary infrastructure connections.

Change suggested by respondent:

The wording in Policy P4D criteria 2 should be deleted or amended.

Full text:

Dear Sir / Madam

Please find attached a copy of representations submitted by RPS on behalf of Redrow Homes to the Solihull Local Plan Draft Submission Plan (Regulation 19) consultation in respect to Land off Main Road, Meriden.

Please can we request a delivery receipt once received, for our records.

Many thanks

Attachments: