Policy UK1 - HS2 Interchange

Object

Representation ID: 10668

Received: 02/12/2020

Respondent: Mrs Jenny Corcoran

Legally compliant? No

Sound? No

Duty to co-operate? Yes

I object to the use of greenbelt land to build 15000 homes Arden Cross development. This will result in the loss of valuable wildlife habitat and corridor between Catherine De Barnes and Chelmsley Wood. This will also impact on climate change removing carbon absorbing trees and vegetation. I also object to use of greenbelt to build homes beyond the budget of local people. Why cannot brownfield sites be used. I would like the Arden cross development removed totally and improved housing provided on Chelmsley wood.

Support

Representation ID: 13704

Received: 12/12/2020

Respondent: Environment Agency

EA are already closely engaged with the elements of the HS2 proposals controlled via specific Government Bills and associated legislation, and as such are satisfied that matters in relation to the tracks and the river diversion will have satisfactory controls via this route.
In terms of the development within the scope of the Local Plan, we welcome the policy proposals in relation to flood risk and water quality.
Urge the Local Plan to carry through aspiration of BREEAM Excellent rating for the HS2 station, and extend to wider area. A key part of the station’s BREEAM measures is sustainable transport, with non-car travel solutions such as a cycle route over the M42 being integral to the success of the station.
Note and welcome the policy commitment to promote ‘sustainable movement patterns to enable site wide and beyond connectivity’, but not been explicitly referenced within the plan. Therefore must be included within The Hub Framework Plan and Arden Cross Masterplan to be effective.

Object

Representation ID: 13953

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Development of Arden Cross requires the removal of land from the Green Belt with no compensatory measures being identified which is in conflict with national and local planning policy. There is no local plan policy requirement, Concept Masterplan or supporting evidence setting out any Green Belt compensatory measures.

Object

Representation ID: 13955

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In respect of Arden Cross there is no site-specific policy, no Concept Masterplan and no allocation within the Policies Map to identify the location or quantum of housing contribution. That site scored badly within the Sustainability Appraisal- matters on social infrastructure and achieving a satisfactory solution with regards heritage need to be considered.

The Green Belt Assessment identifies a refined area (reference RP13). If the site had been considered as part of the wider area, its performance against the purposes of the Green Belt would have been assessed differently.

The Archaeological Assessment states that the proposals will likely have a significant negative archaeological impact. There does not appear to have been an ecological assessment.

Delivering the necessary infrastructure will be a challenge. There are major constraints to development, including managing the construction land-take and impacts of construction works. There are issues with provision of social infrastructure such as schools and health care facilities which would place residents at a disadvantage if occupation precedes infrastructure delivery.

Support

Representation ID: 13960

Received: 14/12/2020

Respondent: Urban Growth Company

Agent: Mott MacDonald

The UGC continues to fully support and welcome the Local Plan and corresponding policy and allocation for the UK Central Hub, without which the wider potential economic and social benefits presented by High Speed 2 (HS2) and Interchange Station would fail to be realised.
The plan clearly aligns with the Infrastructure Vision , Framework Plan and Arden Cross Masterplan, which reflect the phased growth ambitions for The Hub

UGC supports Policy P1 and the corresponding objectives and welcomes the commitment to high quality design across the UK Central Hub. Policy P1 provides a flexible approach that supports the future development of each of the key assets within the UK Central Hub and facilitates this in a holistic and integrated manner. It provides policy support for development of the Arden Cross site through release of the land from the Green Belt.

The UGC is pleased to see their previous representations reiterating the need to provide high quality place making across The Hub consistent with the overarching place making principles set out in the Framework and the need for a flexible based policy approach are reflected within both Policy P1 and Policy UK1.

UGC supports the evidence based approach to Policy UK1 which will provide for a range of
uses to be accommodated, flexibility as to how the site will be developed and resilience to any future changes that may be required throughout the plan period.

An alternative arrangement for car parking in the form of multi storey car parking is being progressed by the UGC that would release land for development to deliver the masterplan for Arden
Cross. This alternative design to consolidate surface level car parking associated with Interchange
Station is currently being progressed by the UGC and will be submitted as a planning application in due course. Significant work has already been undertaken in relation to the design of this. The alternative parking arrangement is an essential enabling element in bringing forward the development at Arden Cross to deliver the associated social, economic and environmental benefits presented by HS2 and Interchange Station.



The UGC is currently in the process of bringing forward a scheme to redevelop Birmingham
International Station to accommodate additional passenger movement and increase passenger capacity to meet the forecast growth associated with the UK Central Hub. Birmingham International Station will provide a high quality gateway linking key assets in the area, including Birmingham Airport, the NEC, Interchange Station and Birmingham Business Park. Will encourage a greater modal shift alleviating congestion in the surrounding area. The justification text accompanying Policy P1 confirms that Birmingham International Station should be protected for its important interchange purpose.

Object

Representation ID: 14087

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Supports specific policy for allocation but needs editing for consistency and to avoid overlap with P1. Following clarifications / amendments are needed:
A distinction needs to be made on the difference in purpose and effect between Policy P1 and Policy UK1.
The pre-text and explanatory text supporting the policy is too lengthy. There is merit in rationalising the policy context to avoid repetition and inconsistency
Reference to the provision of 2,500 new homes at UKC Hub over the plan period at paragraph 830 of the Submission Draft contradicts the figure of 2,740 quoted elsewhere in the plan. A thorough review of all quoted figures (including those at paragraph 828) should be undertaken to ensure accuracy and consistency with the evidence base.
The references to ‘garden community’ principles at paragraph 838 and 842 is misleading and confusing given the array of other development principles drawn from the UGC documents and Arden Cross masterplan. Some simplification would assist clarity when applying the policy.
There is overlap between the place-making principles and development principles at Policy UK1 (2) and (3) and these should be rationalised to accord with the Arden Cross Masterplan and Policy P1.
In general, there are far too many policy principles (23), which is overly prescriptive for decision-making purposes, particularly when accounting for the development principles in Policy P1.
The Arden Cross Masterplan, being the more recent and subject to public consultation, should take precedence as forming the guiding principles behind Policy UK1.
The previous iteration of the UKC Topic Paper should be updated to rationalise and reduce the amount of explanatory text for Policy UK1 and Policy P1.

It is not clear why reference is made to the preparation of an SPD for UKC Hub, including Arden Cross, in Policy P1 but omitted from Policy UK1. Clarification is needed on the role and purpose of an SPD at this stage.
The proposed allocation should be renamed ‘Policy UK1 – Arden Cross’ for the purpose of accuracy.

Support

Representation ID: 14195

Received: 13/12/2020

Respondent: Louise Rhind-Tutt

Appreciates the need for new homes in the region.
Supports the new village close to the NEC/HS2 aka UK1 which would give residents access to some of the best transport links in the country.
Has potential of being a 'showcase' village.

Object

Representation ID: 14464

Received: 14/12/2020

Respondent: Councillor Max McLoughlin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy UK1- too few homes are planned on this allocation in total and are being within the plan period. It is strategically right to focus additional housing here and it is one of the most sustainable locations. The capacity could be 1,000 homes higher.

Object

Representation ID: 14484

Received: 10/02/2021

Respondent: Mr David Roberts

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The impact of this extra traffic in south east solihull will be enormous.

Object

Representation ID: 14553

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

DSP fails to set out a detailed, site-specific housing trajectory outlining the anticipated delivery rates of all the strategic allocations, which fails to demonstrate the rate at which UK Central Hub will deliver.
The proposed growth strategy is largely predicated on the delivery of UK Central Hub - 2,740 units in the plan period up to 2036 (18% of supply).
For clarity, it should be noted that whilst an anticipated housing supply of 2,740 dwellings within the plan period is referenced at paragraph 89 and 222, Policy UK1 does not itself explicitly state the dwelling capacity allowed for by the allocation.
Notably, neither the Hub Framework Plan nor the Arden Cross Masterplan provide an up-to date trajectory for the delivery of housing within the allocation for within the plan period.
The site represents wholly unrealistic delivery rates which not only justifies the need for the Council to present a more detailed, site-specific housing trajectory, but warrants the Council to decrease the 2,740-dwelling figure assumed for supply within the plan period.
Start to Finish (Second Edition) identifies that the average timescale of validation of an outline application to completion of the first dwelling for sites of over 2,000 dwellings is 8.4 years. Notwithstanding that an outline planning application on land at UK Central Hub has yet to be submitted, the research also finds that the average build-out rate for sites of over 2,000 dwellings is 160 dpa. Consequently, even if an outline planning application for the proposals at UK Central Hub were to be submitted to align with the Examination in Public, the build-out rates implied by the Council, as above, are wholly unrealistic. The assumed delivery by the Council of 2,740 dwellings by 2036 should therefore be decreased to a more realistic rate equating to 160 dpa from 2029, or 1,120 dwellings.

Object

Representation ID: 14915

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

- West Midlands Police has a statutory duty to secure maintenance of efficient and effective police force for its area
- Council statutorily required to consider crime, disorder and community safety in exercise of its duties, with aim to reduce crime.
- NPPF and PPG refer to designing out crime, supporting safe communities, working with police and security agencies, importance of considering and addressing crime and disorder, and fear of crime.
- PPG provides for planning obligations in policy requirements, understanding infrastructure evidence and costs and guidance for CIL.
- Vital that Police are not deprived of legitimate sources of funding so they’re not under-resourced
- If additional infrastructure for WMP is not provided, then Police’s ability to provide a safe and appropriate level of service will be seriously impacted by level of growth in the DSP.
- Important to note that increase in local population or number of households does not directly lead to an increase in central government funding or local taxation.
- Viability Assessment shows that police contributions are viable.
- Considered therefore contributions to policing are essential for delivery of DSP, and should be expressly stated in site policies and P21, not just Draft Infrastructure Delivery Plan.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Object

Representation ID: 15217

Received: 14/12/2020

Respondent: Archaeology Warwickshire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As highlighted on pg. 19 of the 2020 Archaeological Assessment undertaken by the Warwickshire County Council Archaeological Information and Advice team on behalf of SMBC*, this site has significant archaeological potential. This potential, and the need for further archaeological assessment in advance of the submission of any planning application is not referenced in this policy. As the results of the assessment may influence the final form of the development across this area, it should be.

*Warwickshire County Council, 2020. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan. Additional Sites, 2020'. Warwick: Archaeological Information and Advice