Policy P5 – Provision of Land for Housing

Showing comments and forms 31 to 60 of 217

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13758

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:

Policy P5 is unsound in respect of the housing land supply identified.

Sites identified in land availability assessments and in the brownfield register are not secured via any planning permissions or allocation and are at risk of not coming forward.

There is a substantial reliance on windfall developments which should be justified by evidence taking into account future trends.

Without a detailed site-specific trajectory for the UK Central Hub Area, relating to the delivery of infrastructure and the relocation of existing land uses, it is difficult to determine the delivery timeframe. The Arden Cross proposals are reliant upon significant infrastructure coming forward, which is a risk that should be considered in identifying the need for further flexibility.

No detailed site-specific trajectories for allocated sites are provided. Land assembly and infrastructure issues could potentially impact upon the timing and phasing of delivery.

A stepped requirement for the housing requirement means that should there be delays to the larger site allocations this will exacerbate the shortfall in meeting needs.

Change suggested by respondent:

Further housing land supply should be identified to provide flexibility to the housing requirement.

Further detail and evidence is required to justify the windfall allowance, the housing trajectory overall and sites specific trajectories should be provided.

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: 13763

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:

Policy P5 Point 5, which requires all new homes to meet nationally described space standards, is considered unsound. There is no evidence providing justification for this taking full account of need, viability and timing, as required by national planning policy.

Change suggested by respondent:

The requirement should be removed.

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: 13768

Received: 11/12/2020

Respondent: Ms J Williamson

Agent: Felsham Planning & Development

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is an over reliance on large sites and over optimistic assumptions about windfall sites. Large sites rarely come forward at the rate that is originally envisaged and there is no control of the delivery of windfall sites.

Change suggested by respondent:

Additional allocations are necessary to produce a balanced land supply as a likely shortfall will emerge.

Full text:

Dear Sir/Madam,

Please find the attached objection to the Submission Draft Solihull Local Plan (October 2020) on behalf of J Williamson for site – 145 Old Station Road, Hampton-in-Arden.

Please do not hesitate to contact Philip Neaves on 07446 897144 should you wish to discuss this further.

Yours Sincerely

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13769

Received: 11/12/2020

Respondent: Ms J Williamson

Agent: Felsham Planning & Development

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The effectiveness of the Site SLP24 (Meriden Road, Hampton in Arden) should be questioned as it has not been developed since being allocated in the 2013 Adopted Local Plan.

Full text:

Dear Sir/Madam,

Please find the attached objection to the Submission Draft Solihull Local Plan (October 2020) on behalf of J Williamson for site – 145 Old Station Road, Hampton-in-Arden.

Please do not hesitate to contact Philip Neaves on 07446 897144 should you wish to discuss this further.

Yours Sincerely

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13789

Received: 14/12/2020

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Council have not provided evidence of the unmet need expected to 2036. It is reasonable to assume that the unmet need to 2036 will be much higher than the 2,600 dwellings to 2031.

Solihull should be seeking to make a higher provision towards the Greater Birmingham Housing Market Area unmet need than the 2,105 currently proposed. Solihull should seek to accommodate at least 6,000 dwellings of the HMA shortfall.

Change suggested by respondent:

The Council should undertake further joint work with adjoining authorities to ensure the duty to co-operate is properly discharged. Evidence of joint working and an indication of how any shortfall in meeting objectively assessed housing needs will be met is required.

The amount of housing to be accommodated within the Borough needs to be increased to a figure significantly higher than the 15,017 for the period 2020-2036. It should accommodate at least 1,200 dwellings on Sustainable Urban Extensions removed from the Green Belt south of Tidbury Green.

Full text:

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13823

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The housing requirement should be clearly set out within Policy P5 and should form the basis of the Council’s monitoring of land supply.

If a ‘stepped’ approach to the housing requirement be taken forward, that should be clearly set out within Policy P5.

HS2 must be considered an exceptional circumstance to boost housing delivery within the Borough above that minimum local housing need. The scale employment growth proposed means the actual housing need will be higher than that derived from historic household projections.

Change suggested by respondent:

A considerable uplift should be implemented to take account of the economic growth / infrastructure provision and to allow for flexibility in the housing supply.

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: 13824

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The intention to make provision to meet the unmet housing needs arising within the Greater Birmingham should be set out within Policy P5.

The origin of the contribution of 2,105 dwellings to the Greater Birmingham Housing Market Area is unclear.

Change suggested by respondent:

A 3,000 dwelling contribution should be made to the wider HMA in the plan period to 2036.

The total housing requirement should be at least 15,912 dwellings in the plan period and should be expressed in Policy P5 as a minimum housing requirement.

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: 13825

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Insufficient evidence of 10% non delivery rate that is applied to sites within planning permission that have not yet started construction, sites identified in land availability assessments, the Brownfield Land Register and the extant Solihull Local Plan.

The windfall allowance of 200dpa is a considerable figure. Development on windfall sites may well become increasingly limited / depleted.

The supply is dominated by large sites, which often experience delay. The deliverability of a number of sites is uncertain.

The Council must provide clear evidence of the trajectories and build-out rates of all sites.

The Council should allocate additional housing above its housing requirement to represent a buffer and ensure flexibility. SMBC should identify a further 4,077 dwellings (20% uplift) on small-medium sized sites in sustainable settlements.

Old Station Road, Hampton in Arden is suitable, available and achievable within the first five years of the plan period. Technical and environmental assessments have been undertaken, demonstrating there are no insurmountable constraints.

Change suggested by respondent:

The housing supply should be increased to at least 19,094 dwellings (a 20% buffer on its requirement). Land off Old Station Road, Hampton in Arden should be allocated.

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: 13828

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The indicative densities should be included within the body of Policy P5.

Clarity is needed on the distinction between a “limited extension of urban or larger village edge”, which would allow for a residential density of 30-35dph, and a “significant extension of urban or larger village edge”, which would allow for a residential density of 30-40dph.

Change suggested by respondent:

A separate policy should be drafted in relation to density. The policy should give more clarity on what qualifies as “limited” / “significant” extensions, and which settlements are classed as “urban or larger villages”.

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: 13862

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Insufficient evidence has been provided on cross-boundary collaboration in respect of the housing land supply shortfall. A Statement of Common Ground has not been published, contrary to Paragraph 27 of the National Planning Policy Framework.

It is unsound for the council to make no policy provision to address the expected need arising from outside the administrative area within the current plan period.

Change suggested by respondent:

A Statement of Common Ground should be published which addresses the cross- boundary land supply shortfall. Housing delivery target number should be modified if/as appropriate.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13865

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The plan does not sufficiently take into account anticipated growth over the plan period and beyond.

The standard method for assessing housing need would increase the housing requirement to 1011 dwellings per annum.

It is unsound to propose phasing delivery of the housing requirement. If the requirement is not delivered effectively/timely, house prices could escalate reducing affordability.

It is unsound that there are no ‘safeguarded’ sites proposed which is inconsistent with national policy. This would speed up the Local Plan review process and ensure a deliverable supply of housing land.

Change suggested by respondent:

Small and medium sized sites for residential development should be allocated.

The phased housing delivery target table at paragraph 224 should be removed.

Policy P5 should be modified to state ‘1. The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing land supply to deliver a minimum 15,017 additional homes in the period 2020-2036… '

Two new paragraphs beneath paragraph 4 of Policy P5 should be included-

‘Reserve Housing Sites providing flexibility to ensure that the Borough can meet in full any increase in housing numbers arising from any change to the standard method for assessing housing need, and respond to the need to meet housing need arising from within the HMA. Reserve sites will have the capacity to deliver at least 20% of the total housing requirement to 2036. Re-serve sites will be released in the following circumstances: • To rectify any identified shortfall in housing delivery in order to maintain a 5-year supply of housing land in Solihull MBC area; • To contribute to meeting any housing needs arising outside the Borough accepted through co-operation between the relevant councils.’

‘Land identified on the Policies Map will be removed from the Green Belt and safeguarded for potential future development needs beyond the plan period to ensures that Green Belt boundaries will last beyond the end of the Local Plan period. The status of the safeguarded sites will only change through a review of the local plan.’

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13874

Received: 14/12/2020

Respondent: Councillor A Hodgson

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

No numbers are provided within the Draft Submission Plan on the proposed housing provision in Solihull Town Centre, Arden Cross and the National Exhibition Centre. This is a significant omission. These sites could take significant pressure off the Green Belt areas proposed for growth.

Full text:

Please accept below my response to the Local Plan Review Consultation.

My initial comment is that distribution of new housing in the Borough is biased towards two geographic areas resulting in 31% of the total being proposed in the Balsall Common area within the Meriden ward and 39% within the Shirley South and Blythe ward areas that are geographically adjacent. The majority of the land involved is within the Green Belt. The Shirley South site is site 11 within the previous iteration of the Local Plan document, which is in the process of being built.
There are proposals included in other wards which are not particularly significant in terms of housing numbers and consequent impact on those local areas.
The document refers to proposed housing provision within Solihull town centre and the Arden Cross and National Exhibition areas adjacent to the proposed HS2 railway station. No numbers are provided within the current iteration of the Local Plan document for either of these locations. This is a significant omission from this version of the document as it means that inclusion of the detail for these sites could take a significant amount of pressure off the areas detailed above and reduce the amount of Green Belt that is currently committed within the document.
A further significant impact of the proposals is the situation regarding local school places at the primary level. This is a particular issue within the Blythe ward area. Primary schools exist at Cheswick Green, Dickens Heath and Tidbury Green. All are currently single form entry with nursery units. The sites in the Local Plan document within the catchment areas of these schools are BL1 in Dickens Heath, BL2 at Dog Kennel Lane and BL3 also in Dickens Heath. Two sites currently being built which have an impact are site 11 from the previous iteration of the Local Plan and a further development at the Blythe Valley Business Park site.
Dickens Heath school is single form entry with no scope for expansion. Both Cheswick Green and Tidbury Green primary schools are in the process of being extended to two form entry. A further two form entry primary school is proposed as part of site BL2.
My main concern regarding primary level schooling in the area is that the increased number of houses will generate significant traffic level increases in the surrounding area on what are already busy roads with some effectively being country lanes. This will also significantly increase already high traffic pollution during school drop off and pick up periods. This will have an impact on the Council’s developing Net Zero Carbon plan.
Congestion is already a problem around both Dickens Heath and Cheswick Green schools as there is no off road parking provision at those two locations.
Another concern is that the Local Plan proposals in its current form will add to the existing significant pressures on the local health service provision. There are no documented proposals to enhance the existing local health service provisions to support the increased number of residents.
The proposals also cause merging of the existing settlements within Blythe ward.
Potential flooding in the area is also a concern. Rainfall run off from the sites discussed feed into the river Cole to the north and the river Blythe to the south. The river Cole impacts on roads within Shirley West ward, particularly Nethercote Gardens. The area has suffered from two one in a hundred years flooding incidents within the last 15 years. The river Blythe impacts on Cheswick Green village In Blythe ward and the lower part of the village has also been impacted by two one in a hundred years flooding incidents within the last 15 years.
The proposed local plan does not conform totally with the sentiments of the National Planning Policy Framework which contends that brown field sites should be considered ahead of Green Belt land for housing. The Arden Cross area and Solihull town centre fall into this category and their use to support housing should be considered ahead of use of Green Belt land.
The climate change agenda suggests that locations for housing should be sustainable and not car dependant. Within Blythe ward all roads are very busy and not conducive the cycling and walking. Local bus services are infrequent and follow circuitous routes which are not conducive to encouraging large numbers of users. Consequently there is a high dependency on the use of private cars in all of the settlements within the area. The proposed developments will only make the current situation worse with consequential increase in local pollution.
There is no defensible boundary identified between site BL2 and Cheswick Green village.
My final concern is that there are mainly inaccuracies within the issued Local Plan.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13889

Received: 13/12/2020

Respondent: Councillor T Hodgson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The loss of Green Belt is too great considering that brownfield sites at Solihull Town Centre and Arden Cross (HS2 Interchange) are being under-utilised for housing and masterplans for both locations are not included in the plan.

Full text:

See attached letter.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13911

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P5 has not undertaken the necessary steps regarding the legal Duty to Cooperate and is unsound. The deliverability and developability of the proposed residential land supply has not been robustly demonstrated. There is an immediate need to identify additional and/or alternative sites.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13926

Received: 10/12/2020

Respondent: Sport England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Concept Masterplans paragraphs 242-243. Welcome inclusion of clause in site policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities. It is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites. Larger sites fail to make on-site provision for playing pitches or ancillary facilities. This is contrary to NPPF paragraph 96 and Plan objectives F and J.

Change suggested by respondent:

The Concept Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision.
The site policies should be amended to state:
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Full text:

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13947

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Insufficient ‘deliverable’ sites, ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or accommodate the scale of growth projected up to 2036. There are significant doubts over the deliverability and suitability of several proposed site allocations.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13948

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The number of new dwellings proposed in Solihull Town Centre is not achievable. The Council are relying on outdated historic figures from the 2016 draft Solihull Town Centre Masterplan.

The ‘Areas of Change’ set out in the 2020 Solihull Town Centre Masterplan covers a physically smaller area than the 2016 draft. However the proposed housing numbers are largely maintained, which will result in an increased density of development which is unlikely to be acceptable.

The Plan only sets out the total number of dwellings to be delivered within the town centre as a whole. Policy P5 should identify specific sites.

No detailed work on concept masterplans for the proposed development sites in Solihull Town Centre has been undertaken, implying it does not have the same level of confidence as the ‘Allocated Sites’.

No accurate capacity testing has been undertaken with inconsistencies to the 2019 Brownfield Land Register.

The proposed provision of largely apartments in Solihull Town Centre would seem unrealistic, in light of the clear need for family housing in the Borough.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13949

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? No

Sound? Yes

Duty to co-operate? No

Representation Summary:

There have been/are issues that are preventing deliverability of dwellings in Solihull Town Centre, with only 10 dwellings approved in the last 7 years. There are current infrastructure requirements on which new development is dependent.

There are multiple landowners and multiple existing land uses on the proposed housing redevelopment sites. Land assembly may also be required to ensure sites can be developed comprehensively. ‘Deliverability’ and ‘developability’ has not been demonstrated with evidence.

There is a reliance on larger site redevelopments in Solihull Town Centre, contrary to the NPPF paragraph 68.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13950

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The capacity of Solihull Town Centre’s redevelopment sites has been overestimated, due to heritage considerations, the need for family housing and compliance with spacing standards. The absence of detailed Concept Masterplan work has failed to justify the densities of development.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13956

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The housing capacity of some of the proposed allocations will be reduced to fully meet the minimum public open space requirement set out in Policy P20. The POS requirement in the Policy and concept masterplan document is incorrect (for sites BL1, BL3, HA1, HH1) when compared to the actual requirement set out in the Open Space Topic Paper dated October 2020.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13958

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The table at paragraph 225 ‘Maintaining Housing Land Supply’ is unsound as there is a lack of robust evidence to demonstrate there has been no double counting across the sources or to demonstrate the deliverability of the capacity numbers.

There is no evidence to demonstrate Brownfield Land Register sites will come forward for development. Stage 2 has not been undertaken and none of the sites have permission in principle. There is no evidence on how the windfall allowance has been calculated to demonstrate that historic rates excluded sites identified in the SHELAA and Brownfield Land Register (ensuring no double counting).

There are concerns in relation to the developability of SHELAA site 245 Former Rugby Club, Sharmans Cross Road. There is no mechanism for replacement of the sports pitches which would be lost- as required by Policy P20.

Change suggested by respondent:

Evidence is required to:
• demonstrate which of the SHLAA sites identified as contributing towards the 5 and 16 year housing land supply in the 2013 SLP have been delivered.
• extrapolate the windfall, Brownfield Land Register and SHLAA site completions.
• robustly demonstrate the deliverability and developability of all Brownfield Land Register sites, SHELAA sites, and proposed housing allocations.

If justification cannot be provided, those site allocations, SHELAA sites, Brownfield Land Register sites and planning permissions should be deleted from the Plan and housing land supply information.

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13968

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

- Need additional work to test justification level of housing. - - Potential town centre regeneration in Solihull, given Covid-19 impacts on retail patterns, could provide additional housing capacity, as well as windfalls, densification and other supply sources.

Full text:

See Attached letter.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13975

Received: 14/12/2020

Respondent: Mr Andrew Gnyla

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to inclusion of 'enhancing' in Section 3 of Policy P5:
"New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs and towards enhancing local character and distinctiveness..."
See High Court Ref: CO/4467/2019, with regard to word 'enhancing'.
It is submitted that word 'enhancing' is too subjective.
Soundness tests:
- Not justified as introduces unnecessarily subjective test that could frustrate delivery of windfall sites.
- Not effective as windfall sites key component of housing delivery numbers. Potential delay in delivery. Solihull only authority in HMA to have such a policy. Could put pressure on greenfield sites if less windfall delivery.
- Not consistent - NPPF does not impose such a subjective test on development of backland or windfall sites.
-

Change suggested by respondent:

Modification is suggested to Policy P5:
Either omit the word ‘enhancing’:
“3 - New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs and towards enhancing local character and distinctiveness….”
Or add an additional definition:
“3 - New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs and towards enhancing local character and distinctiveness including through that housing provision.

Full text:

Policy P5 includes a test for the development of windfall sites:
On behalf of our Client Mr A Gynla we are instructed to make representations in connection with the Solihull Local Plan Review 2020. It is submitted that Policy P5 paragraph 3 is unsound.
Paragraph 3 of the Plan states that ‘New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs and towards enhancing local character and distinctiveness. Unless there are exceptional circumstances, new housing will not be permitted in locations where accessibility to employment, centres and a range of services and facilities is poor.’
It is noted that the policy was found sound in the 2013 examination, however, in January 2020 in the matter of high court case Ref at the Queens Bench Division of the High Court Ref: CO/4467/2019, on the application of Fiona Elizabeth Somerville v Solihull MBC, the issue of ‘enhancing’ as included within Policy P5 was the subject of that case.
At the heart of that case was the issue as to whether or not development in residential back gardens could be regarded as ‘enhancing’. The gardens were long but well-maintained and it was argued by the objector’s QC MR R. KIMBLIN that any form of development or building whatsoever could not, on a common-sense interpretation of that word, be regarded as an enhancing.On behalf of our Client Mr A Gnyla, it is submitted that the inclusion of the word ‘enhancing’ in the policy is too subjective.
The tests of soundness are set out in the National Planning Policy Framework (NPPF) (para 35):
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustain
In terms of NPPF paragraph 35 the criterial above are considered below:
b) Justified - the inclusion of the word ‘enhancing’ is unjustified and, therefore, unsound , as it introduces an unnecessarily subjective test that could frustrate the delivery of windfall sites. As it did in the case referred to, for some 12 months. The delivery of development on windfall sites is crucial to providing the housing numbers required and expressed within the Solihull Local Plan Review 2020.
c) Effective – if windfall sites across Solihull Borough are limited or delayed, then those housing numbers to be provided from windfall sites will be required to be made up elsewhere. Few other Local Authorities include the word ‘enhancing’ as an additional test and only Solihull in the Greater Birmingham Housing Market Area includes this. The enhancing test makes Solihull vulnerable to a similar challenge in the future as well as putting the Borough at a disadvantage by comparison. This could result in increased pressure to develop on green field and Green Belt sites to the detriment of the Council, as well as adding a delay through the necessity of identifying such alternative sites, and finally resulting in pressure on adjacent Local Authorities to provide for the shortfall. The delays referred to would affect the deliverability or timing of sites
d) – Consistent with NPPF – does not impose such a subjective test on the development of backland or windfall sites.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13977

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Insufficient evidence has been provided on cross-boundary collaboration in respect of the housing land supply shortfall. A Statement of Common Ground has not been published, contrary to Paragraph 27 of the National Planning Policy Framework.

It is unsound for the council to make no policy provision to address the expected need arising from outside the administrative area within the current plan period.

Change suggested by respondent:

A Statement of Common Ground should be published which addresses the cross- boundary land supply shortfall. Housing delivery target number should be modified if/as appropriate.

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13979

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The plan does not sufficiently take into account anticipated growth over the plan period and beyond to avoid the need for an early review. The standard method for assessing housing need would increase the housing requirement to 1011 dwellings per annum.

It is unsound to propose phasing delivery of the housing requirement. If the requirement is not delivered effectively/timely, house prices could escalate reducing affordability.

It unsound that there are no ‘safeguarded’ sites proposed which is inconsistent with national policy. This would speed up the Local Plan review process and ensure a deliverable supply of housing land.

Change suggested by respondent:

Small and medium sized sites for residential development should be allocated.

The phased housing delivery target table at paragraph 224 should be removed.

Policy P5 should be modified to state ‘1. The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing land supply to deliver a minimum 15,017 additional homes in the period 2020-2036…

Two new paragraphs beneath paragraph 4 of Policy P5 should be included-
‘Reserve Housing Sites providing flexibility to ensure that the Borough can meet in full any increase in housing numbers arising from any change to the standard method for assessing housing need, and respond to the need to meet housing need arising from within the HMA. Reserve sites will have the capacity to deliver at least 20% of the total housing requirement to 2036. Re-serve sites will be released in the following circumstances: • To rectify any identified shortfall in housing delivery in order to maintain a 5-year supply of housing land in Solihull MBC area; • To contribute to meeting any housing needs arising outside the Borough accepted through co-operation between the relevant councils.’

‘Land identified on the Policies Map will be removed from the Green Belt and safeguarded for potential future development needs beyond the plan period to ensures that Green Belt boundaries will last beyond the end of the Local Plan period. The status of the safeguarded sites will only change through a review of the local plan.’

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13984

Received: 14/12/2020

Respondent: Transport for the West Midlands

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Representation Summary:

- Transport masterplanning needs to be undertaken in addition to concept masterplans
- This needs to be carried out prior to planning approval, to ensure sites are sustainable, both in terms of environment and infrastructure impacts.
- Should accord with overarching Solihull MBC and WMCA goals (see TfWM Response to Solihull Masterplan Consultation: 16/05/2018).
- This is particularly important as a number of sites are not in existing urban, highly accessible locations.
- New housing sites should be either mixed use or be close to a major source of jobs, education, health facilities and key amenities like shops and services; reducing the need to travel and providing opportunities to work, learn, shop, play and socialise locally.
- Future-proofed digital infrastructure, including superfast fibre broadband, should be provided for all new development
- Transport masterplans (for sites or clusters of sites) should scope out transport network and connectivity with all transport modes; bus corridors & network, rail, walking & cycling links (including LCWIPs), shared spaces, interchanges, stops and shelters, as well as full consideration of transport innovation measures, services and infrastructure.
- TfWM can help with this process.

Change suggested by respondent:

RECOMMENDATION:
- Transport masterplans should be undertaken for each development site, or where there are clusters of sites in close proximity to one another (with likely cumulative impacts).
- request that the undertaking of transport masterplans be built into policy P5 – and echoed throughout other policy areas within the plan.

Full text:

See Attached Letter and Representation Form.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13986

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Insufficient ‘deliverable’ sites, ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or accommodate the scale of growth projected up to 2036. There are significant doubts over the deliverability and suitability of several proposed site allocations.

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13987

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The number of new dwellings proposed in Solihull Town Centre is not achievable. The Council are relying on outdated historic figures from the 2016 draft Solihull Town Centre Masterplan.

The ‘Areas of Change’ set out in the 2020 Solihull Town Centre Masterplan covers a physically smaller area than the 2016 draft. However the proposed housing numbers are largely maintained.

The Plan only sets out the total number of dwellings to be delivered within the town centre as a whole. Policy P5 should identify specific sites.

No detailed work on concept masterplans for the proposed development sites in Solihull Town Centre has been undertaken, implying it does not have the same level of confidence as the ‘Allocated Sites’.

No accurate capacity testing has been undertaken with inconsistencies to the 2019 Brownfield Land Register.

The proposed provision of largely apartments in Solihull Town Centre would seem unrealistic, in light of the clear need for family housing in the Borough.

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13988

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There have been/are issues that are preventing deliverability of dwellings in Solihull Town Centre, with only 10 dwellings approved in the last 7 years. There are current infrastructure requirements on which new development is dependent.

There are multiple landowners and multiple existing land uses on the proposed housing redevelopment sites. Land assembly may also be required to ensure sites can be developed comprehensively. ‘Deliverability’ and ‘developability’ has not been demonstrated with evidence.

There is a reliance on larger site redevelopments in Solihull Town Centre, contrary to the NPPF paragraph 68.

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13989

Received: 11/12/2020

Respondent: Messrs Benton & Neary

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The capacity of Solihull Town Centre’s redevelopment sites has been overestimated, due to heritage considerations, the need for family housing and compliance with spacing standards. The absence of detailed Concept Masterplan work has failed to justify the densities of development.

Full text:

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.