Draft Local Plan Review

No

Representation ID: 6463

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Variant of Option 2 would be preferable.
Variation recommended by IM would be for developers of allocated sites to make a 5% contribution to Self and Custom Build on larger residential sites of 500+ units or via voluntary agreement between developer and SMBC on sites falling below this threshold.
Only 91 people on register.
5% of larger units would yield 109 plots, i.e. a 20% buffer.
More practical to deliver serviced plots on larger sites. Where impractical could supply commuted sum.
Should prepare viability evidence for policy.
Plots should be marketed for 12 months, but returned to developer if unused.

No

Representation ID: 6464

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Part of consortium which has instructed Barton Willmore to critique SHMA methodology:
No positive adjustment to address household suppression in younger households;
Not adequately addressed fact that housing has become absolutely less affordable over long-term;
Not adequately addressed balance between job growth and population growth;
Target should be increased to a minimum of 890-987 homes p.a., for OAN, 12.5% higher than currently provided for. Housing numbers exceeding 1,000 homes p.a. would be required to support UKC Hub scenario.

No

Representation ID: 6465

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Recommend that Solihull progress an MoU with Birmingham on accommodating shortfall; including an evidenced justification of the scale required based on the socio-economic links between the two authorities.
Need to reconsider role in accommodating Birmingham's shortfall; 6% is insufficient.
North Warwickshire report states Solihull provides the largest single inflow of people commuting into Birmingham, and should take a greater share.

No

Representation ID: 6466

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Solihull plays an important role in realising the growth objectives of the WMCA with the planned infrastructure investment through HS2, in particular representing a fundamentally different context for attracting investment and business expansion.
However, DLP fails to adequately consider the wider infrastructure implications of the full potential of investment being realised. Needs a more pro-active response to planning for growth.

No

Representation ID: 6467

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Shortfalls in Evidence Base.
SHMA and ELR:
Analysis of Experian forecasts and alternative baseline forecast by Oxford Economics within the ELR show a different picture between as to the relationship between jobs and population growth.
SHMA appears to recognise these uncertainties noting this needs to be kept under review, acknowledging that job growth may be higher and the labour market in the FEMA may tighten.
Suggests notably different labour-force behaviour assumptions in each of forecasts.
DLP does not adequately reflect this uncertainty in proposing a more flexible approach to housing provision.

No

Representation ID: 6468

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Supergrowth assumptions:
SHMA includes job forecasts from UKC HS2 Interchange Station Growth strategy Strategic Outline Case (May 2015). Assumes a total net growth of 11,900 jobs within Solihull, with 5,336 up to 2033.
Appears to contrast significantly with DLP justifying text on the scale of ambition for the area and significant costs of infrastructure.
Experian labour force behaviour changes do not reflect acknowledgement in ELR that supergrowth jobs will be concentrated in professional and private services.
Experian model assumes a significant increase in net in-commuting to Solihull to satisfy job growth. Unclear whether implications for Birmingham have been considered.

No

Representation ID: 6469

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Supergrowth assumptions contd:
Significant concern that evidence presented in SHMA does not align with wider strategy and policy based approach in DLP or other Council documents.
UKC Hub supergrowth form part of a wider strategy of supergrowth at sub-regional level, e.g. WMCA Strategic Economic Plan (SEP). 'Economy Plus' aims to create 500K additional jobs by 2030, and calls for significantly greater housebuilding than currently provided in Plans or being delivered across West Midlands HMAs.
No justification has been provided for why the ELR, Para. 5.16 'does not consider the SEP scenarios in detail.'
Modern Industrial Strategy also names Midlands Engine

No

Representation ID: 6470

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Should consult on revised draft SPD for 'Meeting Housing Needs' alongside the Draft Local Plan.
Would be beneficial to development industry to understand SMBC's approach to expenditure of financial contributions collected. Specifically how such contributions will be spent and whether expenditure will be tied to locations in proximity to the contribution development site or focused in specific geographic locations across the Borough.

No

Representation ID: 6471

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

West Midlands Land Commission (WMLC) was set up in 2016 to help West Midlands Combined Authority (WMCA) unlock land for development.
WMLC published a report to WMCA in Feb 2017 which sets out a number of mechanisms to improve developable supply of land in West Midlands.
Acknowledge this report does not represent policy or necessarily inform policy, it does identify scale of some of challenges faced in Region and SMBC need to understand consequences it may have on DLP.
Findings of report suggest additional 50,000 homes required in West Midlands over and above Local Plan requirements.

No

Representation ID: 6483

Received: 17/02/2017

Respondent: IM Properties

Agent: Turley

Critique of Employment Land Review:
Only published in January 2017, post-dating publication of the consultation version of the DLP.
Obvious disjoint between evidence base and policy; lack of detail on OAN for Employment Land within justification text under Policy P3.
Absence of employment land requirement means we are unable to judge the adequacy of the supply of identified employment land, e.g.
sufficient scale/flexible portfolio of sites/land to accommodate varied future demand.
Need for 22.6ha of employment land in ELR relies solely upon baseline Experian forecast.