Draft Local Plan Review

No

Representation ID: 3888

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Challenge B - agree with objectives, particularly the first three bullet points.
Challenge G - objectives do not seek to address the 'need' for employment land specifically, a fundamental component of economic growth.

No

Representation ID: 3889

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

DLP established a positive economic context and ambition for Solihull.
Support the proactive visioning within the Draft Local Plan.
Concern that this ambition is not matched through other draft polices, including scale of housing to be provided for in Policy P5.

No

Representation ID: 3890

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

DLP established a positive economic context and ambition for Solihull.
Support the proactive visioning within the Draft Local Plan.
Concern that this ambition is not matched through other draft polices, including scale of housing to be provided for in Policy P5.
DLP has more positive approach to support the full economic growth associated with its strategic economic assets than accommodating a more reasonable and justifiable level of overall housing need shortfall in HMA. Significant benefits in ensuring sustainable distribution of housing and employment growth.
Plan fails to adequately align its economic and housing policies, a key NPPF requirements (Para. 158).

No

Representation ID: 3891

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

DLP correctly identifies the significant economic assets captured within UK Central, including UKC Hub, NEC, Airport, Birmingham Business Park, JLR and HS2 Interchange site.
ELR does not specifically set out any 'land requirements' associated with supporting growth, but does acknowledge that job growth will be additional to the baseline forecasts 'because it was considered as something that was not anticipated by the forecast i.e. supergrowth.'

No

Representation ID: 3892

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Economic development ambitions in P1 should be balanced by housing growth in Policy P5.
Important to recognise that in supporting the growth objectives of the WMCA, Solihull is advocating to the Government the capacity to support the delivery of a higher level of job growth on the basis of investment support, and the wider success of the sub-region in attracting greater levels of economic growth.
DLP fails to adequately consider the wider infrastructure implications of the full potential of investment being realised.

No

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.

No

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.

No

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.

No

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.

No

Representation ID: 6462

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Agree with extent of affordable housing threshold proposed by Council, i.e. 11+ residential units or 1,000+ sqm (GIA).
Highly concerned with proposed increase in affordable housing requirement from 40% to 50%.
Annual affordable requirement of 210 dwellings equates either to 31% or 28% of OAN.
50% level has not been evidenced by SHMA or DLP.
Affordable Housing Viability Study from CBRE (2012) is out-of-date.
Viability evidence should be produced by next round of consultation.
Policy should state an upper limit of 50% affordable housing.