Draft Local Plan Review

Yes

Representation ID: 3583

Received: 16/02/2017

Respondent: Gladman Developments

Agree with Borough Vision.
Need Council will and policies to follow them through.
Particularly supportive of approach to consider needs of Rural Area (Para. 83).

No

Representation ID: 4254

Received: 16/02/2017

Respondent: Gladman Developments

Support the settlement strategy.
Support principle of looking for wide range of sites to meet housing needs, more deliverable than just large urban extensions.
Concerns about Para. 104 and guiding principles.
Small and medium sites can support early stages of plan.
Too vague.
Need overarching assessment to consider whether proposed developments can be considered sustainable as per NPPF.
Support dispersal approach but concerns about evidence base supporting Green Belt release.

No

Representation ID: 4255

Received: 16/02/2017

Respondent: Gladman Developments

Support need to provide affordable housing.
Need to robustly test the viability of 50% so that it does not prejudice delivery of other necessary infrastructure.
Require significant additional evidence to justify increase from 40% to 50%.
Approach on tenure and types of affordable housing is not supported by evidence in text; neither has impact on viability and deliverability been considered.

No

Representation ID: 4258

Received: 16/02/2017

Respondent: Gladman Developments

Levels of need identified by Council's self-build register have not been outlined.
Formal requirement that sites of 100+ dwellings provide 5% self/custom build is likely to be problematic, and could allocate far more land than is required.
Potential negative impact on site delivery, build-out rates and overall viability.
Suggest allocating specific sites, e.g. on public sector land.

No

Representation ID: 4259

Received: 16/02/2017

Respondent: Gladman Developments

SHMA (2016) significantly underestimates OAN:
Would not support proposed levels of employment growth.
Suppressed household formation.
Market signals adjustment is insufficient to address chronic affordability issue.

Need to take implications of Housing White Paper into account through next stages.

Insufficient evidence of Duty to Cooperate on addressing HMA shortfall.

No

Representation ID: 4260

Received: 16/02/2017

Respondent: Gladman Developments

Broadly support approach of spreading housing sites and different sizes.
Consider further allocations will be required as OAN is underestimated and apportionment of HMA shortfall has not concluded.
Unclear how Green Belt sites have been chosen from SHELAA and Green Belt Assessment.
Agree that some windfall may come forward, but amount in DLP is overestimate.
Release of large amounts of Green Belt will discourage recycling of brownfield land at previous rates. Not sustainable over 15 years of Plan.
Need far greater detail on housing trajectory in next stage of Plan.

No

Representation ID: 4261

Received: 16/02/2017

Respondent: Gladman Developments

Policy P10 - the landscape part of the policy does not seem to meet criteria in NPPF.

No

Representation ID: 4262

Received: 16/02/2017

Respondent: Gladman Developments

Policy P15 - We support importance of good design. Need to ensure that such stringent policies are in accordance with NPPF and do not adversely impact site deliverability.
Policy P17 - Wording on BMV agricultural land does not accord with NPPF policy. Considers as a more constraining factor.

No

Representation ID: 4263

Received: 16/02/2017

Respondent: Gladman Developments

Do not find the DLP sound or legally compliant.
In particular with regard to following:
Duty to Cooperate
Sustainability Appraisal
OAN assessment
Spatial Strategy
Policies P4, P5, P10, P15, P17.

No

Representation ID: 4269

Received: 16/02/2017

Respondent: Gladman Developments

Duty to Cooperate

Not simply a question of consultation, but effective cooperation.
Key issue likely to be unmet need of 37,900 homes from Birmingham.
Plan notes that discussions have taken place, and 2,000 figure to help meet the shortfall, but does not evidence these discussions of plans for future ones.
Lack of MoU, joint Green Belt or SHELAA or SHMA methodologies.
DLP does not meet requirements of Legal Compliance.