Policy P5 – Provision of Land for Housing

Showing comments and forms 91 to 120 of 217

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14347

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The table at para 220 should be amended according to latest ONS figures –
• Households at 2020- 91,050
• Households at 2030- 96,602
• 10 year difference in number of households- 5,552
• Annual average increase in no. of households- 555
• Median house price- £282,754
• Median workplace earnings- £24,493
• Affordability ratio- 11.54
• Affordability increase- 47.1%
• Adjusted household projections annual average increase (ie the LHN)- 817
• Plan period- 2020-36
• No. of years in plan period- 16
• No. of dwellings required during plan period – Minimum LHN- 13,072

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14356

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Para 221- commuter patterns for employment and employment rates have recently changed therefore is unclear whether or not it is appropriate to adjust the figure (UK Central Hib Area).

Para 222 table-
• The town centre sites figure is lower than what is deliverable within the plan period. The potential for converted office space will allow for an increase in delivery. A modest estimate would put the potential increase at between 200-300 additional dwellings.
• The figure for the UK Central Hub Area to 2036 is based on lower land efficiency than is beneficial. A 10% increase in land efficiency would deliver 3,014 dwellings in the plan period.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14362

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Para 226 Table of allocations-
• BC3 is not deliverable due to the heritage impact on the Berkswell Windmill, unsustainable location, protected species on the site. There is a disproportionate amount of housing located in the Balsall Common/Berkswell area.
• BL1 is unsustainable due to its proximity close to ancient woodland, would reduce the gap between Shirley and Dickens Heath.
• BL2 has no defensible boundaries and leaves a tiny gap between Monkspath and Cheswick Green. The designated public open space threatens the setting of the listed Light Hall Farm, encroaches upon housing in Blackford Road and Tanworth Lane and is prone to flooding.
• BL3 is the highest scoring land on the Green Belt Assessment Report. It provides a necessary gap between Shirley and Dickens Heath. It’s current usage offers significant carbon sequestration.

There is a disproportionate amount of growth proposed (sites BL1-3, site 11 and windfall development in Shirley). The pressure on local health services is unsustainable.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14408

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:

Object to quantum of growth in Policy P5, as 2,105 dwellings is insufficient to address the housing market area shortfall. Plan should test the provision of a minimum of 11,500 additional homes to avoid creating unsustainable patterns of growth and commuting across the HMA.
The housing requirement should be expressed as a minimum requirement, inclusive of any cross-boundary provision to provide certainty as set out in NPPF paragraph 65. Proposed approach equating provision with the difference between local housing need and supply is unsound.
SMBC should allocate around 20% more housing land than required to deliver the housing requirement to provide the necessary flexibility for non-delivery of sites/ boost significantly the supply of housing, equating to a further 3,000 dwellings.
Supply is based upon the local housing need and does not factor any uplift necessary to ensure delivery of the cross boundary provision. The 5 year housing land supply should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
The windfall allowance is not supported as not Plan-led, prevents planning for necessary infrastructure, likely to be overestimate and is unsound.
No evidence to justify blanket introduction of nationally described space standards.
Whilst flexibility on densities is supported, the implications of various policy standards is uncertain and no evidence is provided that this has been taken into account

Change suggested by respondent:

Policy P5 of the Plan should be redrafted to:
- explicitly commit the Council to deliver the additional 2,105 homes (or any updated contribution to the unmet needs of the GBBCHMA) through this Local Plan as part of a comprehensive housing requirement
- include cross-boundary provision in the housing requirement
- incorporate uplift to ensure delivery of the cross boundary provision, with the 5 year housing land supply recalculated
- omit windfalls from housing supply
- remove blanket optional nationally described space standards

Full text:

Land at Damson Parkway - see attachments for full details

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14440

Received: 10/12/2020

Respondent: Arthur Poolton

Representation Summary:

Utilise empty office blocks/ buildings to provide more housing.

Full text:

With Covid-19 running rife, high street shops and department stores closing, and office blocks remaining empty (eg. opposite Morrisons – refer Maguire & Co.), I can see no merit in demolishing houses on the corner of Station Road to build even more office blocks !
Therefore, if it is the Council’s intention to provide more living accommodation in the centre of Solihull I cannot see why these empty buildings/spaces cannot be utilised (as was the BT Telephone Exchange on the corner of Station Road and the office block on Streetsbrook Road next to The Travel Lodge).

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14475

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Paragraph 162 of Introduction re housing land supply is supported in principle, but insufficient provision is made to address needs associated with the UKC Hub or the housing market area shortfall. Projections should be continually monitored. Plan dependent on a small number of large allocations requiring significant infrastructure being developed as and when
anticipated, and may not occur. Reserve sites in locations that are, or can be made, accessible and sustainable, which are located on the edge of the urban area or within rural settlements with the greatest range of services must be identified should any allocations not deliver
sufficient housing numbers

Change suggested by respondent:

In order to ensure a supply for fifteen years and a rolling five-year supply of housing land reserve sites
should be identified should any allocations not deliver sufficient housing numbers or sufficient
properties when anticipated.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14485

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Windfall:

A total allowance of 600 windfall units is included within the DSP. It is clear that historically there has been a high level of windfall completions. It is unclear however from the Windfall analysis at Appendix H of the 5YHLS position July 2020, whether the windfall allowance relates to both small and large sites, nor is it clear whether this includes garden land.
There appears to be no compelling evidence (as sought by NPPF Para 70) that this is a reliable source of supply.

Change suggested by respondent:

Based on the evidence we do not accept 600 as a realistic windfall allowance. In the absence of any evidence to the contrary, we consider the tried and tested number set out in the adopted Local Plan, of 150 dpa, should be used.

Full text:

See attached form and written representations

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14490

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Barton Willmore, on behalf of various developers, have carried out a Housing Need Report in response to the DSP, focusing on the calculation of housing need in the DSP 2020-2036 and whether the approach taken in the DSP aligns with the NPPF. The report concluded:

- The minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub, to 1,036 and 1,248 dpa.
- 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 by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered and additional unmet need will be created post 2031.

The DSP indicates a contribution of 2,015 dwellings towards Birmingham’s identified shortfall of 37,900 to 2031. However, the recent Greater Birmingham Black Country Housing Market Area (“GBBC HMA”) study claims the total Birmingham shortfall has diminished to 2,597 dwellings. This appears somewhat a surprising figure considering the SGS minimum shortfall was identified as 28,000 dwellings in 2018 and is considered to be a highly optimistic prediction.
In its conclusions the GBBC HMA study does not state that the scale of the post 2031 shortfall is not yet known and the shortfall for the whole of the combined authorities HMA post 2031 cannot yet be calculated. 2.5 It follows that, for the reasons summarised here the DSP is clearly unsound by reference to all of the tests set out in paragraph 35 of the NPPF.

Full text:

See attached form and written representations

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14491

Received: 10/02/2021

Respondent: Mr David Roberts

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Questions the amount of housing to be absorbed by Solihull needed for Birmingham and other surrounding areas.

Full text:

See attachment

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14494

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The identification of housing need greater than the Standard Methodology minimum in Policy P5 is supported in principle, but given the need to significantly boost housing, economic growth at the UKC Hub and the housing market area need growth significantly exceeded past trends is required. There is overreliance on large complex sites with significant infrastructure needs, many in close proximity, a high windfall rate with significant Green Belt and little brownfield land, and significant growth at the UKC Hub and town centres.
Policy does not allow for contingency or flexibility so SMBC should identify reserve housing sites
for release if monitoring indicates that they are required for 5 year land supply or shortfall outside the Borough

Change suggested by respondent:

Plan should identify additional reserve housing sites and the mechanisms for their release, should they be
required, through an appropriately worded additional policy.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14495

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 housing allocations in paragraph 226 should have an approximate capacity rather than a fixed maximum to provide flexibility.

Change suggested by respondent:

The references to housing requirements in the site allocations should be expressed as ‘approximate’
to ensure that the policy isn’t overly prescriptive, with the details to be determined as part of the
consideration of the planning applications.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14496

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

No reference is made under Policy P5 or within its supporting text as to the status of the Concept
Masterplans referenced in paragraph 242, which are contained within a supplementary document.

Change suggested by respondent:

In order for the associated policy (Policy P5) to be effective the status of the Concept Masterplans should be made more explicit, as they are within the policies associated with each allocation.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14500

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The DSP relies on the BFLR to help make up the overall numbers in the plan, equating to 77.

The Council have only completed Part 1 of the
BFLR and so any Green Belt sites coming forward could only be delivered under 145(g) of the NPPF. Para 145(g), whilst allowing for redevelopment, does so on the basis there is no additional impact on the openness of the Green Belt.

As the Council does not have Part 2
of the register in place there is no mechanism to deliver the numbers
allocated by the BFLR. Only one site has come forward so far, with an application for 49 extra care apartments (the site was not in GB).

Change suggested by respondent:

Therefore 29 units identified need to be discounted.

Full text:

See attached form and written representations

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14514

Received: 14/12/2020

Respondent: St Philips - Coleshill Heath Road

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Local authorities must deliver in excess of the minimum local housing need calculated using the 2018 standard methodology if Government’s targets are to be achieved. The new standard methodology from 2020 if introduced would mean the Council needs to recalculate and identify additional land to deliver its increased local housing need. This would lead to a requirement to release more land from the Green Belt to be allocated to housing.

Change suggested by respondent:

The housing target should be expressed as a minimum.

Full text:

Dear Spatial Planning Team

Please find attached representations made on behalf of St Philips on the Solihull MBC Local Plan Publication Stage.

This includes a completed set of Regulation 19 forms and supporting representation, plus appendices, included in a single pdf file.

I would be grateful if you could confirm receipt.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14515

Received: 14/12/2020

Respondent: St Philips - Coleshill Heath Road

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Overall Approach Topic Paper sets out a summary of the positions adopted by various LPAs and is not a definitive assessment of housing land supply based on commitments in adopted plans. This does not form an appropriate basis of justification for the Council’s proposed contribution to the delivery of unmet need in the HMA.

The Council has no formalised arrangement with any of its neighbouring authorities. This is contrary to the requirement to have entered into a SoCG by this. The new standard methodology when introduced will lead to additional unmet needs in the HMA, something the Council will need to address.

The Sustainability Appraisal concludes that a contribution of 3,000 dwellings towards the HMA shortfall would lead to impacts being largely the same as those from a contribution of 2,000 dwellings. Therefore clarification is required on how the Council has concluded that it could not deliver more than 2,000 dwellings.

Change suggested by respondent:

The contribution to meeting HMA needs should be increased.

Full text:

Dear Spatial Planning Team

Please find attached representations made on behalf of St Philips on the Solihull MBC Local Plan Publication Stage.

This includes a completed set of Regulation 19 forms and supporting representation, plus appendices, included in a single pdf file.

I would be grateful if you could confirm receipt.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14519

Received: 14/12/2020

Respondent: St Philips - Coleshill Heath Road

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The housing land supply has been over-estimated.

There has been double counting, arising from several sources of supply (windfalls, BLR, sites identified in availability assessments and town centre sites). There is a lack of evidence to demonstrate why the sites fall into only one category and not several.

There is a lack of evidence to demonstrate why allocated sites in the adopted 2013 Local Plan will deliver units in the new plan period (Simon Digby site, Riddings Hill site and Meriden Road site).

There is a lack of evidence to demonstrate why a 10% discount figure has been applied and not a higher figure.

There has been an over estimation of delivery from windfall sites. How can the Council assume that this number of windfalls will be delivered in an area where non-Green-Belt opportunities have been exhausted.

There is an over reliance on the UK Central Hub Area and a lack of evidence to demonstrate delivery of infrastructure requirements to facilitate development. A sensible assumption is that delivery will begin in 2028, with 800 dwellings completed by 2036.

If the supply is adjusted to remedy these issues, the Council would not meet its own needs or make any contribution to the HMA unmet needs, or demonstrate a five-year supply on adoption of the Plan.

Change suggested by respondent:

Additional sites should be included in the ‘Summary Table of Residential Allocations’. Land at Coleshill Heath Road should be allocated for housing.

Full text:

Dear Spatial Planning Team

Please find attached representations made on behalf of St Philips on the Solihull MBC Local Plan Publication Stage.

This includes a completed set of Regulation 19 forms and supporting representation, plus appendices, included in a single pdf file.

I would be grateful if you could confirm receipt.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14542

Received: 11/12/2020

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

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council is only proposing to deliver 15,017 dwellings which would meet the minimum requirement for housing including delivery of a small element of cross boundary growth. Additionally, a stepped delivery trajectory is proposed, which would result the delay in delivery of homes to meet needs in the early part of the plan period. As a result the DSP would fail to be “sufficiently flexible to adapt to rapid change” (Para 11) as required by the NPPF. At present, the Council’s proposed growth strategy would only just meet the proposed 15,017- dwelling housing requirement. It does not allow for any flexibility to respond to changing circumstances.

Government intention to review the standard methodology, revising the standard method for assessing housing numbers in strategic plans. This increases the minimum LHN for Solihull to 1,011 dwellings per annum, which is above the Council’s proposed housing requirement of 938 dwellings per annum. Although the Council intends to submit the DSP prior to the transitional arrangements, any delay to the plan-making or submission process means the Council will need to have regard to the revised standard method figure. It would therefore be prudent for the Council to build in a buffer at this stage and seek to begin considering a number of additional sites that could deliver sufficient capacity to meet this increased figure. This should include circa 5-10% headroom in the housing requirement (P5), to facilitate the delivery of between circa 750–1,500 dwellings

Change suggested by respondent:

5-10% headroom should be included in the housing requirement set out under Policy P5(1). In doing so, the Council will need to identify and sites to facilitate the delivery of circa 700–1,500 dwellings.

A detailed, site-specific housing trajectory is prepared, setting out the anticipated delivery rates of the larger strategic allocations and Town Centre Sites proposed pursuant to Policy P5(1). The anticipated delivery rates for large sites including UK Central Hub should be realistically set to reflect the lead in time for the delivery of projects of this scale.

The windfall allowance is decreased from 200 dpa to 150 dpa. At 150 dpa, a resultant capacity of 2,100 dwellings from 2022-2036 would warrant the Council to identify sites to facilitate the delivery of a further 700 dwellings.

Full text:

see attached submission document

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14551

Received: 11/12/2020

Respondent: Bloor Homes

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed number of homes allocated has decreased from the 2019 Draft, whilst 600 dwellings have been added to the windfall category, which does not meet test of a Plan-led approach. Object to reduction in the number of allocated sites and in site capacity for seven of the proposed allocations, which fails to make most efficient use of Green Belt land.
Object to 18% of housing provision in one location and all potentially high density living of a type which doesn’t meet the needs of most families. Do not consider that 2,740 dwellings will be delivered at the NEC/Arden Cross by 2036, so this figure should be reduced and evidenced. Evidence shows different capacities and timescales, no applications to date for NEC and HS2 likely to delay delivery.
Do not consider that 200 dwellings per annum of windfall dwellings is realistic or an effective way to plan for the future. There is no compelling evidence for a higher rate given Borough's constraints. Rather than relying on windfall provision, the Plan should have identified additional sites.
Proposed contribution to housing market area shortfall is insufficient compared with North Warwickshire's and there is no evidence to justify figure. Does not take account of needs for 2031-36. There should be an agreement between the HMA Authorities and a Statement of Common Ground.
Local housing need should be kept under review given Government White Paper and revised standard methodology. Should plan for this growth using 2 scenarios and identify additional housing allocations for higher figure if required.
Support flexibility in density policy but the criteria listed under Policy P5 6 should be the same criteria as NPPF paragraph 122. Proposed density at Arden Cross is significant increase on current achieved densities and Plan will need to ensure that the impact of these densities is reflected and considered.

Change suggested by respondent:

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.
Reduction in capacities of some sites and increase in windfall allowance should be reviewed.
Allocate additional housing sites which have performed well against the evidence base criteria and are in sustainable locations.
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

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: 14565

Received: 11/12/2020

Respondent: Bloor Homes

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Plan should identify areas of safeguarded land in order to meet longer term development needs beyond the plan period, which should be released from Green Belt now. This is encouraged by the NPPF and would recognise that Green Belt release would otherwise be required to meet housing need in future reviews. This is particularly important given proposed changes to the standard method and the shortfall in the housing market area, especially between 2031-36.
Sites should be in lower performing Green Belt parcels, adjacent to sustainable settlements, accessible and be suitable, achievable and deliverable, including Site 192 land east of Tilehouse Lane

Change suggested by respondent:

Plan should identify areas of land that could be released from the Green Belt now and safeguarded for future
development should the Council not be able to meet its housing needs or the housing needs of the HMA during the next plan period.
Additional allocations and/or safeguarded ;and should be identified including Site 192 (land east of Tilehouse Lane, Tidbury Green)

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: 14575

Received: 11/02/2021

Respondent: Kendrick Homes Ltd

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Summary
Paragraphs: 222, 225 & 226
An objection is submitted to Policy P5 ‘Provision of Land for Housing’, paragraph 222 ‘Solihull Housing Land Supply 2020-2036’, Paragraph 225 ‘Maintaining Housing Land Supply’ and Paragraph 226 ‘Allocated Sites’. It is contended that insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).
There is also an undue reliance on larger site allocations. The smallest of the allocations being for 50 units. This is contrary to the recommendations in NPPF paragraph 68
In order to ensure deliverability, our Client contends that the small and medium size SHELAA sites with an estimated ‘major’ development capacity of 10 units or more, should be specifically allocated in the SLP This would be a mechanism to provide greater certainty of deliverability and speed up delivery.
There is no evidence to demonstrate that there is a reasonable prospect of all the sites identified in the BLR coming forward for development
Our Client questions the basis on which the windfall allowance has been calculated without evidence to demonstrate that the historic rates. There is no commentary in the evidence documentation to explain if/how an allowance has been made in the historic windfall rates to remove a proportion, which would have come forward through the more recent SHELAA and BLR site identification mechanisms
It is also important to note that the proposed delivery on SHELAA sites, proposed in the Publication version of the SLP, paragraph 225 table, anticipates 200 dwellings to be delivered on SHELAA sites in 5-years from April 2020. This would effectively double the 5-year housing land supply delivery rate proposed in the 2013 SLP’s first 5 years.

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, BLR and SHLAA site completions.
robustly demonstrate the deliverability and developability of all BLR sites, SHELAA sites, and proposed housing allocations.

Where the necessary justification cannot be provided, those SLP housing site allocations, SHELAA sites, BFR sites and planning permissions should be deleted from the SLP and housing land supply information (paragraphs 222 and 225).

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14576

Received: 11/02/2021

Respondent: Kendrick Homes Ltd

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

On behalf of our Clients Kendrick Homes Ltd, who have an interest in the site adjacent 84 School Road, Hockley Heath, to make representations to the Solihull Local
Plan Review 2020. It is submitted that Policy P5 is unsound on the basis that insufficient policy weight has been given to encouraging the development of suitable sites within settlements for housing enabling villages to grow and thrive, especially where this will support local services, at densities in keeping with national and local strategic policies in Neighbourhood Areas – contrary to NPPF paragraphs 65, 122 and 123.

To comply with NPPF paragraph 65, it is important that the Neighbourhood Area housing requirement is included within Policy P5 as a strategic policy requirement,
rather than as part of the supporting text explaining and justifying the approach set out in the policy. Currently, Policy P5 makes no reference to the housing requirement being partly attributed to specific Neighbourhood Areas.

Given that there is unlikely to be an opportunity to test the housing requirement at the Neighbourhood Plan stage, it is important to ensure that the proposed Neighbourhood Area housing requirements and supporting text are not overly restrictive jeopardising the NPPF and local plan objective of meeting the minimum housing requirement over the plan period.

Change suggested by respondent:

A modification is sought to Policy P5 as shown below:
Insert a new paragraph below paragraph 2 of Policy P5, as follows:
‘A proportion of the Borough’s housing requirement will be expected to be delivered in designated Neighbourhood Areas as detailed in the table below. These housing requirement figures are indicative minimum numbers and may be exceeded once detailed permissions have been considered for the sites identified in the land availability assessment, Brownfield Land Register, site allocations within this plan and saved
from the 2013 Local plan and any suitable additional sites which come forward within the settlement boundaries as defined on the Policies Map.’

It is submitted that paragraph 234 should be deleted and replaced by a table of Neighbourhood Areas with the minimum housing requirement listed for each area.

The minimum housing requirement figures currently shown at paragraph 234 should be critically reviewed to reflect the deliverability of the housing land supply sources more realistically. As a minimum, our client submits that an addition of 21% to the numbers proposed at paragraph 234 should be incorporated, to reflect the windfall delivery expectation.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14634

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:

Policy P5 is unsound in respect of the housing requirement identified.
Imperative that sufficient homes are provided to support the envisaged economic growth. The HEDNA should test an additional UK Central Hub growth scenario (22,998 jobs) to determine how many homes might be required in Solihull if all jobs are filled by residents of Solihull.
No justification for the HMA contribution and no agreement with other Local Authorities. Birmingham shortfall is significantly higher than position statement suggests.
Housing requirement should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios and to help meet HMA shortfall to 2031. Acute affordability issue need to be addressed, so the recommended local housing need of 816 dwellings per annum within the HEDNA should also be increased.
Question whether the true capacity for further growth has been fully realised.

Change suggested by respondent:

The draft SLP housing requirement is not currently justified and should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios to meet the envisaged jobs growth at UK Central Hub, tested via our review of the evidence base (HEDNA).
The draft SLP housing requirement should be increased to provide more headroom to help meet GBHMA housing shortfall needs up to and beyond 2031.
More needs to be done to address the acute affordability issue and so the recommended local housing need of 816 dwellings per annum within the HEDNA should also be increased to maximise the contribution towards meeting this need.

Full text:

See attached documents

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14635

Received: 11/12/2020

Respondent: Birmingham City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Paragraph 228
BDP establishes BCC’s unmet need of 37,900. Latest HMA position statement indicates unmet need to 2031 is 2,597. Situation beyond 2031 is currently emerging, but envisaged shortfalls will continue beyond 2031, with the BC evidencing a shortfall of 29,260 dwellings between 2019 and 2038 through its 2019 Urban Capacity Review.
Welcomes contribution of 2,105, but unclear why only this level. Reference is made to the SA that doesn’t identify any further significant effects of accommodating 3k compared with 2k (above LHN).
They believe that there is scope to maximise contribution without compromising sustainability, but potential to clearly justify why not more remains.
Given other emerging contributions from elsewhere in the HMA, Solihull’s figure is disappointing, especially given the location close to where the need arises thus being more sustainable.
SMBC needs to commit to an early review, possibly triggered by adoption of the BC plan or progress in reviewing the Birmingham plan - to the point where any housing shortfalls are fully identified and established.

Full text:

See Attached Document

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14637

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:

Housing Land Supply: There are a several issues associated with the identified housing land supply which give rise to concerns that the draft SLP will not be effective in delivering the housing requirements.
No certainty that sites identified in land availability assessments, Brownfield Land Register or Town Centre sites will come forward. Additional flexibility is needed.
Too much reliance on windall.
No evidence to demonstrate that 2,740 dwellings at UKC Hub area can be delivered.
No site-specific trajectories for allocated sites. Assumption underpinning delivery periods are not detailed. Several sites also have complex land ownership issues or dependent on infrastructure, which could impact on timings.
No flexibility / contingency in housing land supply requirement.

Change suggested by respondent:

Further housing land supply should be identified to provide flexibility to the draft SLP housing requirement. This would serve to provide a contingency in the event of the identified supply not coming forward as anticipated, particularly those which are reliant upon substantial and/or site-specific infrastructure being delivered at the necessary point in time. This should have regard to the levels of flexibility considered appropriate in recent Local Plan examinations.
Further evidence is required to justify the windfall allowance within the housing land supply.
Further detail and evidence is required to justify the housing trajectory overall and site specific trajectories should be provided within the draft SLP.

Full text:

See attached documents

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14639

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:

National Space Standards: Policy P5 - Point 5 requires all new homes to meet nationally described space standards. This element of Policy P5 is considered unsound as it is not justified or consistent with national planning policy. There does not appear to be any evidence providing justification for this taking full account of need, viability and timing, as required by the NPPF, Footnote 46 and the PPG.

Change suggested by respondent:

The requirement should be removed to ensure the draft SLP is justified and consistent with national planning policy.

Full text:

See attached documents

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14640

Received: 11/12/2020

Respondent: Birmingham City Council

Representation Summary:

Paragraph 241

The Submission Plan helpfully provides indicative masterplans for all of the proposed development allocations to indicate the levels of housing growth for each one. These show that, although gross density levels appear low, net density levels are in line with those recommended in the West Midlands Strategic Housing Study to promote additional growth. However, given that the masterplans provided are indicative, the Submission Plan should specify that the housing figures indicated for each site are therefore minima.

Change suggested by respondent:

The Submission Plan should specify that the housing figures indicated for each site are therefore minima.

Full text:

See Attached Document

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14648

Received: 11/12/2020

Respondent: Mr & Mrs Nelson Smith

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Policy P5 is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed 2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP).
There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60.
Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Plan/ Green Belt review, and ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).

Change suggested by respondent:

The evidence in support of Policy P5 is deficient, requiring
• Publication of a statement of common ground, which addresses the HMA cross-boundary shortfall of sites to meet the minimum housing requirement to satisfy NPPF requirements.
• Modification of the housing delivery target number if/as appropriate following scrutiny of the statement of common ground.
• Allocation of small and medium sized sites for residential development; and
• Removal of a phased housing delivery target table at paragraph 224.

Proposed modifications to Policy P5 as shown below:
‘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…
Insert two new paragraphs beneath paragraph 4 of Policy P5, as follows,
‘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:

See attached

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14654

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The housing requirement is not sound as it is not positively prepared, justified, effective or consistent with national policy for the following reasons.
LHN: The minimum Local Housing Need (LHN) has been calculated using the standard method which is well established and is not disputed. However, the Council will need to be mindful of any changes arising from the Government’s stated intention to change the method for calculating LHN prior to submission of the Plan.

Plan Period: It is highly unlikely that the Local Plan will be adopted in 2021, thereby providing a plan period of 15 years post adoption as recommended by the Framework. On the basis that it is already December 2020 and the Plan has not been submitted, it is more likely to be adopted in 2022, and therefore the housing requirement and the Plan should be extended to 2037.

Change suggested by respondent:

The housing requirement should be amended to take account of the likely realistic date of adoption; a more sustainable balance between the jobs uplift and commuting patterns; unmet housing needs; and an affordability uplift. The housing requirement should also be expressed as a minimum figure. The exact figure will need to be informed by further assessment by the Council.
The housing supply should be justified with evidence, and assumptions in relation to windfalls should be reviewed and amended. The housing supply should contain a buffer of 10% over the housing requirement to ensure delivery and that housing needs can be met should some sources of supply slip.
There is an insufficient portfolio of sites, in particular small sites, that can deliver quickly ensuring a five year housing land supply is achieved upon adoption. National planning guidance advises where a stepped trajectory is used local authorities could identify a priority of sites that could come forward earlier in the plan period in order to ensure housing needs are met. This emphasises the imperative to release further small sites within Solihull that can deliver quickly.
Policy P5 and the table of allocated sites should be amended to include land west of Stratford Road, Hockley Heath.

Full text:

see attached representation form

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14656

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Employment uplift: LHN is afforded an employment uplift of nine dwellings per annum to take account of the substantial job growth at UK Central of around 13,000 net additional jobs. This is a figure which could increase as plans crystallise, and it is noted that the Council’s Viability Study (2020) predicts up to 77,500 jobs by 2040. The Plan also justifies the small uplift from LHN on the assumption that only 25% of the jobs will be filled by people residing in Solihull, with the remainder in commuting from neighbouring areas. Taking this approach will ‘bake-in’ inward commuting reflecting an historic pattern of movement rather than shaping growth to be more sustainable by locating homes close to where work is

Change suggested by respondent:

The housing requirement should be amended to take account of the likely realistic date of adoption; a more sustainable balance between the jobs uplift and commuting patterns; unmet housing needs; and an affordability uplift. The housing requirement should also be expressed as a minimum figure. The exact figure will need to be informed by further assessment by the Council.
The housing supply should be justified with evidence, and assumptions in relation to windfalls should be reviewed and amended. The housing supply should contain a buffer of 10% over the housing requirement to ensure delivery and that housing needs can be met should some sources of supply slip.
There is an insufficient portfolio of sites, in particular small sites, that can deliver quickly ensuring a five year housing land supply is achieved upon adoption. National planning guidance advises where a stepped trajectory is used local authorities could identify a priority of sites that could come forward earlier in the plan period in order to ensure housing needs are met. This emphasises the imperative to release further small sites within Solihull that can deliver quickly.
Policy P5 and the table of allocated sites should be amended to include land west of Stratford Road, Hockley Heath.

Full text:

see attached representation form

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14657

Received: 11/12/2020

Respondent: Mr & Mrs Nelson Smith

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P5 paragraphs 222 and 225-226. Insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).

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, BLR and SHLAA site completions.
• robustly demonstrate the deliverability and developability of all BLR sites, SHELAA sites, and proposed housing allocations.
Where the necessary justification cannot be provided, those SLP housing site al-locations, SHELAA sites, BFL sites and planning permissions should be deleted from the SLP and housing land supply information (paragraphs 65, 222 and 225).
Where appropriate evidence is forthcoming, additional site allocations should be set out in the SLP and Policies Map which identify deliverable small and medium ‘major’ development sites.
In particular, it is considered the following modifications are required –
1. The terms for the ‘UK Central Hub’ should be rationalised, clearly defined and used accordingly.
2. A clear policy on the UK Central Hub housing contribution - the housing contribution should be clearly identified within the Policies Map and a Concept Masterplan for each site, in the same manner as other allocated sites.
3. The quantum of dwellings and timeframe for delivery as quoted within the SLP and supporting evidence should be consistent.
4. The policy and/ or concept masterplan should identify relevant details of coordination of landowners and implementation of necessary infrastructure, including quantum of development and timetable.
5. The development of Arden Cross requires Green Belt compensation.
6. That the NEC and Arden Cross sites are fully assessed for their suitability for development.

Full text:

See attached

Attachments: