Draft Local Plan Review
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Draft Local Plan Review
Q18. Do you agree with the policies for improving accessibility and encouraging sustainable travel? If not why not, and what alternatives would you suggest?
Representation ID: 4809
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Policy P7 objectives are commendable.
Concern that criteria in Policy P7 are unviable, particularly given that Solihull is predominantly rural. Should test viability of P7 to ensure it does not prevent delivery of housing land.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
No
Draft Local Plan Review
Q19. Do you agree with the policies for protecting the environment? If not why not, and what alternatives would you suggest?
Representation ID: 4810
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Recognise importance of protecting the environment.
Policy P10:
'Full ecological survey' and 'net gain or enhancement' to each development is overly arduous and not in spirit of NPPF, which states 'provide net gains in biodiversity where possible.'
Policy P11:
Approach in policy alludes to sequential test, but this is not explicit.
Unreasonable to state 'there are no other viable site at lower risk of flooding'. Viability is a much more restrictive test than availability, which is not in accordance with national guidance and should be revised accordingly.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
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: 4811
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Recognise the importance of quality of place.
Policy P17:
No national policy requirement for development not in the Green Belt to preserve the visual amenity of the Green Belt. Unduly restrictive wording and would limit land development in Solihull.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
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: 4812
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Policy should be clear that pooling of planning obligations would be undertaken in accordance with the CIL Regulations.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
No
Draft Local Plan Review
Q23. Are there any other comments you wish to make on the Draft Local Plan?
Representation ID: 4814
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
SHELAA has a number of flaws, including:
Local planning policy is irrelevant to SHELAA as plan being reviewed.
751dpa figure is less than in the DLP.
Council should do more than just Call for Sites.
Absolute constraints inappropriate.
Scoring system for housing too generalised.
Concern with suitability criteria, e.g. suitability of location is predetermining the plan.
Availability scoring too conservative.
Number of anomalies in the assessments, e.g. LWS
Densities and build out rates too optimistic.
Windfall allowance too generous.
SHELAA provide evidence that sufficient available land in Solihull to meet significant housing needs.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
No
Draft Local Plan Review
Q23. Are there any other comments you wish to make on the Draft Local Plan?
Representation ID: 4815
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Pegasus Review of SHMA:
OAN for wider HMA should be calculated.
Ideally should split Birmingham overspill proportionally between neighbours.
Future projections and migration patterns should not be based on recession.
Should apply 3% vacancy rate.
Should frontload any 2011-2014 shortfall.
Should deliver more housing South of A45 as locus of market pressure.
Should not confuse market signal uplift with HMA shortfall.
Data used in Experian model is out-of-date and outputs too pessimistic in projecting job numbers.
Solihull will continue to have overheated housing market if insufficient housing allocated.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
No
Draft Local Plan Review
Q23. Are there any other comments you wish to make on the Draft Local Plan?
Representation ID: 4816
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Pegasus Review of unmet housing need in HMA and duty to cooperate
Birmingham shortfall of 37,900 dwellings.
Policy TP48 in Birmingham Development Plan places responsibility on Birmingham to ensure unmet housing needs arising in the City are met by other LPAs in the HMA.
Test of effectiveness of Duty to Cooperate.
GBHMA Strategic Growth Study to be commissioned.
Democratic deficit in process of how Study's findings will be published, considered and included in Local Plans.
Council need to be clear about weight of Study in progressing Local Plan.
Lack of credible evidence to support 2,000 contribution.
OAN is underestimated.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden
No
Draft Local Plan Review
Q23. Are there any other comments you wish to make on the Draft Local Plan?
Representation ID: 4818
Received: 17/02/2017
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Pegasus Chelmer Model for Solihull.
Inputs in model include:
Household formation rates used in the DCLG 2014-based household projections.
Labour market activity rates
Unemployment rates from Annual population survey
Adjustments to above for Solihull
3% vacancy rates
Scenario 1 is just the demographic projection and is similar to PBA SHMA.
Scenarios 2 and 2a include Cambridge Econometrics future workplace projections. Markedly different results from Experian model and Scenarios 2 and 2a increase households by ca. 12k and 8K respectively.
Policy off, therefore does not include 2011-2014 shortfall, any other uplifts or HMA contribution.
I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).
The representations comprise of the following submissions:
* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)
* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden