Draft Local Plan Review

No

Representation ID: 6205

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

DLP fails to meet NPPF requirements for Duty-to-Cooperate:
Much of necessary evidence has not been completed (contrary to Para. 182).
None of evidence available at Cabinet meeting when Members supported consultation.
Evidence includes numerous inaccuracies.
Evidence difficult to interpret as different numbering systems and boundaries.
Official evidence published after 5th December on website.
Calls into question how robust site choices were made.
Representors unable to make fully informed comments.
SHELAA Site 64 omitted from Interim SA.

No

Representation ID: 6206

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Lack of options to give local communities involvement and choice when considering potential housing sites, contrary to NPPF and neighbourhood planning.
Proposed strategy will result in over-dependence on large housebuilders.

No

Representation ID: 6207

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Proportionate evidence not been provided in support of Council's proposed housing allocations or to justify the rejection of other sites which perform equally well.
Much of the submitted evidence is subject to challenge due to omission of sites within reports and mistakes made during site assessments.

No

Representation ID: 6208

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Many of rejected sites from SHELAA:
Do not have existing viable community or recreational facilities,
Moderate to low value to the purposes of including land within the Green Belt,
Relatively sustainable,
Less landscape impact,
Partly brownfield/previously developed land,
Perform better when judged against Council's guiding principles (p.35 of DLP).

No

Representation ID: 6209

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Rural Exception Sites:
None in the DLP, in spite of a continuing and increasing need for affordable housing.
A larger site than currently proposed as a Rural Exception Site has been assessed for open market housing, whilst promoting the site as Rural Exception Site in DLP under the supporting text of Policy P4.

No

Representation ID: 6210

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Need for affordable housing:
DCLG document on affordable housing supply published 17/11/16 confirms that affordable housing delivery in 2015/2016 was 52% lower than previous year.
Government White Paper acknowledge that housing is increasingly unaffordable.
DLP confirms that house prices are high in Solihull's Mature Suburbs and Rural Areas; with a severe shortage of affordable homes and options for elderly and/or those wishing to downsize.
Reflected in Challenge B.
Reiterated in latest SHMA.
SLP proposed 2 Rural Exception Sites.
Allocated Rural Exception Sites will conform with NPPF.

No

Representation ID: 6211

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Council not provided the public with necessary annual monitoring information for an objective assessment to be made of the success of the affordable housing policy, including the effectiveness of the Rural Exception Sites policy.
Localism Act requires Councils to publish this information direct to the public annually in the interests of transparency.
Should form critical evidence feeding into the DLP.

No

Representation ID: 6212

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P4(A) - Supported insofar it confirms the threshold for sites which should provide affordable housing; in line with Government guidance and Court of Appeal judgement May 2016.
Contradiction in wording, however, as Starter Homes is not included in Meeting Housing Needs SPD, but states that definition is set out therein.
Needs to provide greater clarity on proportions of types of housing tenures to be included in definition of affordable housing.
50% target needs to be tested through Viability Study.
Support reference to provision of affordable housing developments on Green Belt land if meet local needs and is supported locally.

No

Representation ID: 6213

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P4(b)
Imperative that DLP makes specific provision for affordable housing sites, particularly in the Rural areas, where provision is so lacking.
Supported by NPPF Para. 54.
Plan must provide greater support for rural exceptions in absence of viability testing for 50% target.
Suggest proposed policy is not predicated on local Parish Council or Neighbourhood Forum support as such a clear need.
Propose SHELAA Site 19 is put forward as a Rural Exceptions Site under this policy.

No

Representation ID: 6214

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Over-concentration of growth in south-west of Borough with sites 4, 11, 12 and 13.
800 more dwellings than Dickens Heath (1,642 units).
Land to south of Sites 12 and 13 has no clear defensible Green Belt boundary.
Significant extension to Shirley area.
Will cause coalescence of settlements in Shirley, Dickens Heath, Cheswick Green, Majors Green and Whitlocks End.
Adverse impact on existing communities and infrastructure.
Landscape character in this area sensitive to change (LCA, 2016), cannot accommodate development of this scale.