Q11. Do you agree with Policy P4? If not why not, and what alternative would you suggest?
No
Draft Local Plan Review
Representation ID: 6308
Received: 17/02/2017
Respondent: IM Land
Agent: Turley
Recognise need for both affordable and market housing across the Borough.
Support recognition of social and economic importance of housing to the Borough.
Welcome inclusion of Vacant Building Credit, forms a valuable incentive for redevelopment of brownfield sites.
Overriding concern is that P4 will threaten viability and deliverability of residential development:
Untested and un-evidenced increase from 40% to 50%;
Absence of upper limit on requirement;
Ambiguity on wording;
Untested proposed tenure split.
Should not seek to dictate or negotiate types and sizes of open market housing; SHMA not provide necessary evidence. Existing SPD on weak evidence base.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Land.
No
Draft Local Plan Review
Representation ID: 6319
Received: 17/02/2017
Respondent: IM Land
Agent: Turley
Draft policy states that Council will take into account following factors:
Site size - what does the flexibility entail? Will smaller sites be permitted to provide reduced affordable housing?
Accessibility - does this suggest that sites with limited accessibility will be permitted to provide off-site contributions?
Economics - agree with statement, but encourage use of term 'financial viability' instead.
A range of house types and sizes - unclear how this will be applied, e.g. less AH in areas with higher proportion of AH in existing housing stock such as North Solihull?
Support financial contributions in lieu - needs greater clarity.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Land.
No
Draft Local Plan Review
Representation ID: 6321
Received: 17/02/2017
Respondent: IM Land
Agent: Turley
Tenure mix is only set out in policy justification, not policy itself.
If this is to allow flexibility, it should be stated within the policy that the affordable tenure mix will be set out within SPD.
Unclear how Council has utilised SHMA to arrive at a division of 22% rented and 8% shared ownership. Should be further justified in text or explanatory note.
Unclear if 'rented' is social and/or affordable.
Recommend rented to incorporate affordable rent, to improve deliverability and provide choice.
20% Starter Homes premature as Housing White Paper confirms Government will not introduce statutory requirement at this time.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Land.
No
Draft Local Plan Review
Representation ID: 6445
Received: 08/12/2016
Respondent: Mr Matthew Taylor
In the allocation of houses there should be a fair distribution of sizes at all developments not limited to what the open market wants. The recent TW development in Knowle was disappointing in that only two 3 no. bedroom houses were available for general release on such a large site. The rest went to forms of social housing.
I think it is vital to have an allocation of homes spread out over the borough but that in areas such as Berkswell, Hampton, Catherine DB etc. there should be a level of protection so just to add small developments. These areas are historically important and should be protected.
In the allocation of houses there should be a fair distribution of sizes at all developments and not limit that which comes to the open market. The recent TW development in Knowle was disappointing in that only two 3 no. bedroom houses were available for general release.
No
Draft Local Plan Review
Representation ID: 6458
Received: 17/02/2017
Respondent: IM Properties
Agent: Turley
Recognise need for both affordable and market housing across the Borough.
Support recognition of social and economic importance of housing to the Borough.
Welcome inclusion of Vacant Building Credit, forms a valuable incentive for redevelopment of brownfield sites.
Overriding concern is that P4 will threaten viability and deliverability of residential development:
Untested and un-evidenced increase from 40% to 50%;
Absence of upper limit on requirement;
Ambiguity on wording;
Untested proposed tenure split.
Should not seek to dictate or negotiate types and sizes of open market housing; SHMA not provide necessary evidence. Existing SPD on weak evidence base.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Properties and IM Land.
No
Draft Local Plan Review
Representation ID: 6459
Received: 17/02/2017
Respondent: IM Properties
Agent: Turley
Draft policy states that Council will take into account following factors:
Site size - what does the flexibility entail? Will smaller sites be permitted to provide reduced affordable housing?
Accessibility - does this suggest that sites with limited accessibility will be permitted to provide off-site contributions?
Economics - agree with statement, but encourage use of term 'financial viability' instead.
A range of house types and sizes - unclear how this will be applied, e.g. less AH in areas with higher proportion of AH in existing housing stock such as North Solihull?
Support financial contributions in lieu - needs greater clarity.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Properties and IM Land.
No
Draft Local Plan Review
Representation ID: 6460
Received: 17/02/2017
Respondent: IM Properties
Agent: Turley
Tenure mix is only set out in policy justification, not policy itself.
If this is to allow flexibility, it should be stated within the policy that the affordable tenure mix will be set out within SPD.
Unclear how Council has utilised SHMA to arrive at a division of 22% rented and 8% shared ownership. Should be further justified in text or explanatory note.
Unclear if 'rented' is social and/or affordable.
Recommend rented to incorporate affordable rent, to improve deliverability and provide choice.
20% Starter Homes premature as Housing White Paper confirms Government will not introduce statutory requirement at this time.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Properties and IM Land.
No
Draft Local Plan Review
Representation ID: 6461
Received: 17/02/2017
Respondent: IM Properties
Agent: Turley
Suggest SMBC consider opportunity for Private Rented Sector (PRS) development to come forward in Borough. As BCC have done, SMBC should also acknowledge difference in terms of viability in PRS schemes compared to open market housing.
PRS schemes differ from traditional housing schemes as returns are long term and not short term; the impacts on viability should be included in viability evidence.
P4 should specifically refer to taking account of specific characteristics of developments which look to longer term rather than short-term 'market' gains, when assessing viability and considering provision of affordable housing.
In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Properties and IM Land.
No
Draft Local Plan Review
Representation ID: 6520
Received: 16/03/2017
Respondent: BDW and Gallagher Estates Ltd
Agent: Avison Young
Actual affordable housing need is 28.7% and not 50%.
Provision of Starter Homes as additional to identified need for affordable housing will result in double-counting. Unsound.
Concerned by absence of any viability testing of policy.
Larger greenfield sites, with high infrastructure requirements, may not be able to deliver 50% affordable homes. Contrary to NPPF.
Text should be amended to state 29% affordable dwellings should be provided.
Should include starter homes in definition of affordable housing.
Should include option for off-site contributions when on-site affordable provision is unviable or unfeasible.
Include reference to Viability Assessments for planning applications.
see attached document to supplement online submissions