Draft Local Plan Review

REPRESENTATIONS ON BEHALF OF RED ELK HOLDINGS
Red Elk Holdings support the identification of Knowle as a location for significant new development to take place on the edge of the settlement (paragraph 84 of the Draft Local Plan). However it is considered that site 234 in the Strategic Housing & Employment Land Availability Assessment (SHELAA) has not been properly considered as a reasonable alternative to the sites selected for development.
Site 234, located at Lady Byron Lane, Knowle, is a well-contained parcel of land immediately adjacent to the built-up area. It is entirely surrounded by roads, including the M42 and A4141. The perimeter of the site is also visually enclosed by trees. The site is too small and cut off from wider farmland to be productively used for agriculture and the site does not exhibit the qualities of a rural landscape due to the surrounding roads. The site would appear to have been given very limited consideration in the evidence base for the Draft Local Plan, despite being submitted through the Call for Sites in February 2016.
The site has not been included in the Sustainability Appraisal and for some reason it has only been assessed in terms of its suitability for employment development in the SHELAA. The site was put forward in the Call for Sites for a range of potential uses, including residential. We are therefore unable to understand the Council's reasoning for rejecting the site.
The site forms part of parcel RP33 in the Green Belt Assessment. This parcel achieved an overall score of 5 in terms of its contribution to Green Belt purposes. The proposed site allocations for housing in this area are on parcels of similar or higher value Green Belt. There is no explanation as to why site allocation ref 8 has been chosen over other reasonable alternatives, particularly in view of the fact that it is assessed as having Green Belt scores of 7 and 11 in the Green Belt Assessment - the highest scores in this area.

The Solihull Accessibility Mapping Methodology Report (6th December 2016) demonstrates areas within 400 metres of bus stops with a daytime frequency of services of 15 minutes or better (Figure 1D). Site 234 is not identified as falling within this catchment, despite the site being within 100 metres of bus stops on Warwick Road served by the S3, 87, 88, 513 and 514 bus services. These services combine to provide at least 4 buses per hour in each direction. It is therefore considered that the assessment of the site's accessibility is incorrect and the site should be reviewed in terms of its suitability for development.
We have been engaged with the preparation of the Knowle, Dorridge & Bentley Heath (KDBH) Neighbourhood Plan in respect of site 234. We participated in the Developer Showcase on 16th July 2016, which was attended by over 400 local residents who gave their feedback on the 45 different sites offered for development in the area. The feedback received is summarised on the KDBH Neighbourhood Forum website http://www.kdbh-np.org/home.html
Our site received a lot of positive feedback - it was 2nd most supported out of all the sites. Generally people felt that the site had good access and could be suitable for development in that it is already 'built up' by surrounding roads. The land seems to be viewed by the community as a disused parcel of land, rather than unspoiled countryside.
Various potential uses for the site were discussed and residents fed back that, due to noise from the adjacent motorway, the site may not be suitable for general housing development. However it would be more suitable for commercial development, a hotel or care home, where the development would be designed so that the habitable rooms faced away from the motorway. Taking on board this feedback, our vision for the site is for the provision of a care home for elderly people. The attached concept plan shows how this might be arranged on the site, such that the development is positioned towards the southern end of the site and the habitable rooms face away from the motorway. Formal gardens could be shielded from the motorway by the new building and would present a pleasant aspect to the south. The land to the north of the building would be used for car parking. The majority of the site would remain open, the trees to the perimeter of the site would be retained and the development would relate well to existing development in Knowle, preserving the sense of separation from Solihull.
The site is adjacent to a frequent bus route and with this type of development facilities are provided on site. Such facilities might include healthcare, café, salon, IT space and a small shop selling convenience products for residents such as newspapers and confectionary. The site is also adjacent to another care home development, so the principle of this type of land use in this location seems to have been established.
In view of our representations in response to Question 14 (ID 1450), the proposal for a care home development at site 234 could provide for important unmet needs for accommodation for elderly people. Such a development could preserve the sense of separation between the KDBH area and Solihull and result in a development which responds positively to feedback from the community regarding how they wish to see their area develop. It is therefore considered that site 234 should be included as an allocation for C2 care home development in order to address the issues of soundness raised in response to Question 14 of this consultation.

REPRESENTATIONS ON BEHALF OF RED ELK HOLDINGS
The draft Local Plan sets out an objective (Challenge B) to widen the range of housing options for older people through the provision of accommodation which is designed to meet their needs. It highlights that there is a Borough-wide shortage of homes which are suitable for older people (paragraph 182). The Strategic Housing Market Assessment (2016) published with the draft Local Plan says that, in addition to the objectively assessed need for housing there will be a requirement for residential care home accommodation for the elderly of additional 737 spaces over the next 19 years (paragraph 6.14). The document recommends that the Council plan separately for this accommodation and set out a separate target for new bedspaces within this accommodation. However neither a target nor any provision has been set out in the draft Local Plan and therefore this requirement seems to have been ignored.
It is important that housing provision is made for elderly people, not least to meet the needs of elderly people in society, but also because elderly people currently occupying large homes may wish to move but may not have the option of alternative accommodation within their community. By making provision for elderly people to downsize or move to accommodation which better meets their care needs, this releases large homes back to the market for younger families. This in turn reduces the pressure to build more new homes.
The Draft Local Plan recognises this at paragraph 181 where it states that 'the number of households represented by the over 75s is projected to increase by 7,000 between 2014 and 2033 to comprise 22% of all the Borough's households. This leads to market demand for specialist and supported housing together with homes which can provide opportunities for households to 'downsize', thereby releasing family housing for resale and re-letting'. However the Local Plan does not do anything in terms of making provision to address this requirement.
The National Planning Policy Framework says at paragraph 159 that local planning authorities should, through their Strategic Housing Market Assessment, identify the need for all types of housing, including the needs of older people, and then cater for housing demand and the scale of housing supply necessary to meet this demand. This is a clear national policy expectation that the needs of older people will be both understood and met.
The Planning Practice Guidance paragraph 021 says that the need to provide housing for older people is critical given the projected increase in the number of households aged 65 and over accounts for over half of the new households. Plan makers will need to consider the size, location and quality of dwellings needed in the future for older people in order to allow them to live independently and safely in their own home for as long as possible, or to move to more suitable accommodation if they so wish. The future need for specialist accommodation for older people broken down by tenure and type (e.g. sheltered, enhanced sheltered, extra care, registered care) should be assessed. The assessment should set out the level of need for residential institutions (Use Class C2). Local authorities should also identify particular types of general housing as part of their assessment.
Whilst the Strategic Housing Market Assessment identifies a requirement for residential care home accommodation for the elderly of additional 737 spaces over the next 19 years, the Draft Local Plan does not meet this need. The Draft Local Plan is therefore considered unsound, due to it not being positively prepared. The Draft Local Plan could be made sound by making provision to meet the identified housing needs of older people through specific site allocations for C2 residential care and other types of housing designed to meet the needs of older people.