Draft Local Plan Review
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Draft Local Plan Review
Q1. Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?
Representation ID: 1584
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Amend text under Challenge/Objective B second bullet to give greater certainty of approach regarding the need to satisfy the "duty to co-operate" test with other HMA authorities in making provision for the shortfall in new housing land
as recommended in the GBSLEP SHNS.
Add new point under objectives for Challenge D to maximise the opportunity for reducing congestion on motorways, the strategic rail network and rail through delivery of an appropriate level of new housing.
Amend objective for Challenge E to ensure justification for green belt releases is based on green belt functions and outcomes from the Green Belt Assessment.
Please refer to our uploaded attachments
No
Draft Local Plan Review
Q2. Do you agree with the Borough Vision we have set out? If not why not, and what alternative would you suggest?
Representation ID: 1601
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Para. 83 fails to define how justification of release of Green Belt land for sustainable extensions will be made.
Should be amended to include reference to evidence base.
Para. 84 should be amended to refer to evidence base.
Please see to the uploaded attachement
No
Draft Local Plan Review
Q3. Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?
Representation ID: 1602
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Welcome approach in Plan. Agree development should be focused in most accessible locations and ensure necessary infrastructure is delivered.
DLP does not define how Council proposes to assess alternative locations for development. Absence of such criteria renders DLP unsound.
Para. 101 should be amended to refer to evidence base.
Para. 107 includes inconsistencies on spatial distribution. Should be reworded to ensure equal consideration of alternative development.
Strongly object to Reviewing the Options paper.
Lack of comparative analysis.
Overestimated site delivery timescales.
Should make more reference to Neighbourhood Plans, e.g. KDBH, and amend Para. 108.
Please see to the uploaded attachements
No
Draft Local Plan Review
Q11. Do you agree with Policy P4? If not why not, and what alternative would you suggest?
Representation ID: 1603
Received: 17/02/2017
Respondent: Heyford Developments 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.
Please see attached uploaded attachment.
No
Draft Local Plan Review
Q12. Do you agree with the level of affordable housing being sought in Policy P4? If not why not, and what alternative would you suggest?
Representation ID: 1604
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Should be amended to 29% and not 50%. See response to Q11.
Please see uploaded attachment
No
Draft Local Plan Review
Q14. Do you agree that we are planning to build the right number of new homes? If not why not, and how many do you think we should be planning to build?
Representation ID: 1605
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Disagree.
Not produced a HMA-wide SHMA.
Evidence that 2000 figure for HMA shortfall is not agreed.
Lack of clarity over mechanism for agreement of distribution of HMA shortfall.
37,900 shortfall.
Solihull well placed to take further growth:
Economic growth,
Public transport links,
Lack of Absolute constraints,
Attractive and aspirational housing market.
SHMA has taken insufficient account of different needs of population; underestimates level of housing required to support economic growth ambitions; inaccurate conclusion about multiple jobs, % of HMA shortfall.
Housing requirement in Policy P5 should be increased to at least 25,023 or 1,317 p.a.; including 36% of HMA shortfall.
Please see uploaded attachments
No
Draft Local Plan Review
Q20. Do you agree with the policies for quality of place? If not why not, and what alternatives would you suggest?
Representation ID: 1607
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Policy 15 should be amended by omitting reference to the need to achieve compliance with Building Regulations as this is a requirement of other legislation.
Reference to Secured by Design should be omitted as this is now addressed through Building Regulations
Please see uploaded attachment
No
Draft Local Plan Review
Q22. Do you agree with the Policy P21? If not why not, and what alternatives would you suggest?
Representation ID: 1611
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Need for evidence base to test the impact of infrastructure provision or the requirements of the IDP upon the viability of residential development in DLP.
Viability assessment needs to be carried out.
In the absence of viability modelling, Policy P21 is unsound. Should be amended to state:
"Where it is viable to do so, new development will be expected to provide or contribute towards provision of: ..."
Please see uploaded attachment
No
Draft Local Plan Review
Q15. Do you believe we are planning to build new homes in the right locations? If not why not, and which locations do you believe shouldn't be included? Are there any other locations that you think
Representation ID: 1625
Received: 17/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Welcome release of land from Green Belt for housing.
Concerned that insufficient land allocated.
Object to inclusion of Site 8 and 9 ahead of SHELAA site 104, land at Blue Lake Road, Dorridge.
Concerned Site 19 will not deliver sufficient homes.
Concerned that scoring of sites is erroneous.
Disagree with findings in GBA, Sustainability Appraisal, Landscape Character Assessment in relation to SHELAA Site 104.
Please see uploaded attachments
No
Draft Local Plan Review
Alternative Site Suggested (Call for Sites)
Representation ID: 2569
Received: 16/02/2017
Respondent: Heyford Developments Ltd
Agent: Avison Young
Support SHELAA Site 104 - Land Blue Lake Road, Dorridge.
Disagree with findings in GBA, Sustainability Appraisal, Landscape Character Assessment in relation to SHELAA Site 104.
Site compares favourably with proposed allocations 8 and 9.
Our findings should be reflected in DLP and site included for development.
see attached and online submissions