Draft Local Plan Review

No

Representation ID: 4861

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

50% target is inconsistent with 28.7% in SHMA. Should be revised.
Determine on site by site basis and not blanket policy approach.

No

Representation ID: 4862

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Advise Option 1.
5% significant proportion of larger sites.
Renders delivery more difficult in masterplanning process. Less efficient use of land. Less design consistency.
Sites currently being promoted have been negotiated on existing planning policies and values.
Proposed policy change of Option 2 would have an impact on values and potentially affect the deliverability of the site.

No

Representation ID: 4863

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Alternative 'policy off' Chelmer model work been undertaken. Demographic scenarios are consistent with SHMA suggesting a need of ca. 12,000 dwellings. In order to meet economic needs an additional 8-12K homes are recommended to OAN.
Not propose additional market uplift to this economic uplift. Need to consider Cambridge Econometrics job growth data.
8-12K does not include:
- 2011-2014 shortfall.
- Additional housing required to enable economic growth at UK Central which is over and above the baseline economic forecast.
- Additional uplift for Birmingham's unmet need.
Consider the LPEG recommendation to allocate an additional 20% of the dwelling requirement.

No

Representation ID: 4865

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Generally agree with housing supply assumptions.
SLP sites should be re-evaluated, as some sites not likely to come forward.
Windfall supply is over generous.
Land for 20% over OAN should be allocated in line with LPEG recommendations.
Considered correct OAN is 20,000-24,000.
Should not apply phasing to sites, market is very tight with low vacancy rate.
Concern about inconsistencies in SHELAA scoring.

No

Representation ID: 4866

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Further explanation required on location and source 1000 figure.
Site 19 has only been assessed as housing and not an employment site in SHELAA.
Inaccuracies in measuring amount of Grade 1-3b land. Impact of Site 19 on SSSIs in vicinity has not been assessed.
Compares less favourably with other sites including flooding, biodiversity and heritage concerns as well as impact of HS2 safeguarded land.

No

Representation ID: 4867

Received: 17/02/2017

Respondent: St Francis Group

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.

No

Representation ID: 4868

Received: 17/02/2017

Respondent: St Francis Group

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.

No

Representation ID: 4869

Received: 17/02/2017

Respondent: St Francis Group

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.

No

Representation ID: 4870

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Policy should be clear that pooling of planning obligations would be undertaken in accordance with the CIL Regulations.

No

Representation ID: 4871

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

SHELAA Employment Site 80, Land at Wyckhams Close.
SHELAA identifies that 47% of site is impacted by overhead buffer. Indicative Masterplan submitted for St Francis Group excludes overhead buffer and HS2 safeguarded land.
Several discrepancies between SHELAA Site 80 and Allocation 19 in SHELAA and Sustainability Appraisal. E.g. SHELAA Site 80 entirely in Flood Zone 1 and has no biodiversity or heritage concerns.
Allocation 19 has only been assessed as housing and not an employment site in SHELAA. Inaccuracies in measuring amount of Grade 1-3b land. Impact of Allocation 19 on SSSIs in vicinity has not been assessed.