Draft Local Plan Review

Yes

Representation ID: 3439

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Very relevant and appropriate but concern that subsequent policies (as drafted) will not deliver.
Concern that OAN inappropriate and insufficient sites allocated.
Inadequate housing provision will lead to: rise in inequality between North and South, increase commuting, stifle economic growth due to lack of labour force.

No

Representation ID: 4852

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Relevant and appropriate but concern that policies will not deliver.
Timescales of Local Plan contradict Council Plan, which states that UKC will be delivered in 2020.
Para. 73 contrary to spirit NPPF as it implies there will remain an unmet need for housing.
Should be amended to read 'responded and met the Borough's local housing need...'.

No

Representation ID: 4853

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Welcome Council using land use powers to maximise economic benefits of HS2 and acknowledgement of need to release Green Belt.
Insufficient land allocated in Plan. Green Belt boundaries will not be permanent. Requirements of NPPF not met.
Potential to release more for safeguarded land.
Concern that 'managed' part of Managed Growth is overly restrictive and outdated planning policy approach.
Sequential approach not in accordance with NPPF. Sustainable land should be identified regardless of existing policy constraints.
Support growth in most sustainable locations, but a wider dispersal strategy would meet local needs and provide housing in short term.

Yes

Representation ID: 4854

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

General support.
Key assets are important; should encourage other employment growth/land opportunities to support chain of businesses.
Local Plan states delivery of UKC Hub will be after plan period for housing policy, but immediately in economic policy. ELR stated 5,400 new jobs from UKC to be delivered 2026-2033. SHMA states job growth from UKC not to be included in analysis.
Contradiction should be clarified.
Should clarify if 1000 dwellings in UKC Hub are part of or in addition to OAN.

No

Representation ID: 4855

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Unclear how Objective B (in Challenges), meeting housing needs, will be delivered if uplift is not included to meet economic needs.

Yes

Representation ID: 4856

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Concept of Policy P2 is worthy, but difficult to deliver mixed use and high density residential. E.g. apartment development requires significant capital as entire development must be completed prior to completion and occupation.
Advise surplus contingency housing sites are identified due to risk of delivery in town centre.
LPEG recommends 20% surplus.

No

Representation ID: 4857

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Concept of Policy P2 is worthy, but difficult to deliver mixed use and high density residential. E.g. apartment development requires significant capital as entire development must be completed prior to completion and occupation.
Advise surplus contingency housing sites are identified due to risk of delivery in town centre.
LPEG recommends 20% surplus.

No

Representation ID: 4858

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Concern the Council has taken a precautionary approach to identifying land, particularly from the Green Belt for employment purposes. Suggest a plan, monitor, manage approach to avoid over-allocating land and unnecessary Green Belt loss.
Employment Land Study used 2014 BRES data. Since updated with 2015 BRES data, which show 6% increase in job numbers in Solihull. Experian forecasts therefore underestimated future job growth.

No

Representation ID: 4859

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Risk that job growth underestimated and consequently insufficient sites have been allocated.
Additional development and choice is required. Should include a number of small scale sites, including those that support Airport, JLR etc. E.g. SHELAA Site 80.
SHELAA Site 80 compares favourably in SHELAA and Sustainability Appraisal against Site 19 at UKC Hub. Could exclude HS2 safeguarded zone and overhead buffer line.
More difficult to regenerate older sites. Recycle vacant sites & identify replacements elsewhere.
Policy P3 should align with UK Industrial Strategy.

No

Representation ID: 4860

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Support reference to Starter Homes. Policy should be sufficiently flexible to accommodate wider array of affordable housing products in the future.
Meeting Housing Needs SPD is out of date and should be redrafted on latest evidence.
SPD should not influence viability of schemes.
50% target is inconsistent with 28.7% in SHMA. Should be revised.
Determine on site by site basis and not blanket policy approach.