Draft Local Plan Review

No

Representation ID: 6306

Received: 17/02/2017

Respondent: IM Land

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: 6307

Received: 17/02/2017

Respondent: IM Land

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: 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.

No

Representation ID: 6309

Received: 17/02/2017

Respondent: IM Land

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Affordable Housing Viability Study from CBRE (2012) is out-of-date.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.

No

Representation ID: 6310

Received: 17/02/2017

Respondent: IM Land

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: 6311

Received: 17/02/2017

Respondent: IM Land

Agent: Turley

Aware of critique Barton Willmore have made of the 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 homes p.a., and exceeding 1,000 homes p.a. to support UKC Hub scenario.
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. (NW taking 10%).

No

Representation ID: 6312

Received: 17/02/2017

Respondent: IM Land

Agent: Turley

As part of aspiration to delivery development tin accessible locations, particular consideration should be given to existing transport hubs, e.g. Earlswood.
Settlements that perform well against accessibility criteria should be afforded significant weight when seeking to allocated development.

No

Representation ID: 6314

Received: 17/02/2017

Respondent: IM Land

Agent: Turley

SHELAA Ref. 141. Land around Earlswood Station.
51ha site crossing boundary with Solihull and Stratford upon Avon district.
Could deliver up to 3000 dwellings, shop, school, extension to Earlswood station carpark.
Will help encourage use of rail network and reduce need to travel by private vehicle.
Accords with 'Public transport corridor' spatial option in SHNS Stage 3 report.
Location performs poorly in Green Belt Assessment.
SA impacts would be mitigated by on-site shop.
Key opportunity for land release in this and next plan period.
Stratford have signed MoU with Birmingham to look to contribute 3,300 dwellings towards Birmingham's shortfall.

No

Representation ID: 6315

Received: 17/02/2017

Respondent: IM Land

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: 6316

Received: 17/02/2017

Respondent: IM Land

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.