Draft Local Plan - Supplementary Consultation

Comment

Representation ID: 9633

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Barton Willmore Housing Need Technical Note to SDLPR.
Summary of findings:
- The revised NPPF introduces the Standard Method (SM) for calculating housing need, the relevant Planning Practice Guidance (PPG) has been amended (February 2019) to state that the 2014-based MHCLG projections must be used for the calculation, and not the 2016-based ONS projections. The current SM calculated housing need figure for Solihull stands at 777 dwellings per annum (dpa) as of March 2019;
* Notwithstanding this, revised Planning Practice Guidance (PPG) states the SM figure represents the minimum housing need, and actual need may be higher;
* The Supplementary Consultation document identifies the clear economic growth aspirations for the Borough, including the significant development planned for High Speed 2 and the Interchange in the Borough. Housing delivery must be of a quantum to support these aspirations;
* Alongside this, the Council need to consider the aspirations of the GBSLEP in which they are located;
* The Council's evidence base provides a relatively recent (January 2017) assessment of baseline job growth prospects for Solihull, post-Brexit referendum, alongside a scenario which takes into account the potential job growth created by the HS2 Hub Interchange;
* These scenarios show annual job growth of between 800 and 1,080 jobs per annum. It is therefore imperative that the housing requirement for Solihull supports at least 800 jobs per annum, and more realistically the upper end of this range.;
* Our own sensitivity testing has established how the baseline population growth used to underpin the Standard Method would only support circa 450 jobs per annum;
* Furthermore the final Standard Method housing figure (777 dpa) would only support between 594 and 729 jobs per annum;
To support the range of job growth identified in PBA's 2017 report (baseline job growth of 800 per annum, and job growth to support the UK Hub of 1,080 jobs per annum), housing need for the Borough alone would need to be between 825 and 1,127 dpa;
* There is significant unmet need from the GBBCHMA. Solihull Borough Council acknowledge their role in helping to meet this unmet need;
* The most detailed and recent evidence in respect of unmet need comes from the Greater Birmingham HMA Strategic Growth Study (SGS). In addition the Black Country Urban Capacity Report (BCUCR) provides more recent analysis of capacity and need in that area;
* These reports suggest unmet need across the two areas ranging from a minimum of 28,000 dwellings up to 2031 (based on demographic need) and up to 80,000 dwellings (based economic need and unmet need from the Black Country identified by the BCUCR) up to 2036.

Object

Representation ID: 9634

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

We strongly object to the way in which SHELAA Site 209 has been assessed in the site selection process for the reasons set out below - and on that basis, object to the inconsistent application of the methodology.
SHELAA Site 209 should be Priority 5 (yellow) as it is accessible in a lower scoring Green Belt location.
Site 209 scores lower in GB terms than proposed allocation Site 4.
Site has existing strong defensible Green Belt boundaries.
Would provide significant amenity open space above requirements.
Medium/High Accessibility location.
Site therefore would accord with the Spatial Strategy in DLP 2016.
SHLEAA scoring should be amended as contaminated land issues can be overcome. N.B. TPOs would be unaffected.

Object

Representation ID: 9635

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

We strongly object to the way in which Site 209 has been assessed in the site selection process for the reasons which are set out below - and on that basis, object to the inconsistent application of the methodology.
see detail in letter

Object

Representation ID: 9636

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Objection to scale of development in Balsall Common:
1,700 dwellings to a single rural village appears completely disproportionate.
No discussion on how proposed new infrastructure such as school, bypass, station car park and improved public transport will be funded. No capacity study carried out for the area.
Balsall Common will be acutely affected by HS2 - both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
Site 1 in multiple ownerships adding to complexity.

Comment

Representation ID: 9637

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Site 4 - West of Dickens Heath poses particular concern. Well-used existing sporting pitches cannot be re-provided on-site and will require alternative provision. Alternative sites would still need to meet Green Belt tests, e.g. for floodlighting.
SHELAA Site 209 performs much more highly in comparison, no LWS, no Ancient Woodland, no playing pitches, no hard constraints, and no soft constraints that will affect development.

Comment

Representation ID: 9638

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

As shown on the 'Masterplan Document' published with the consultation, David Wilson Homes had some previous involvement with the Moat Lane site .They are no longer actively involved with this site due the difficulties in delivering a commercially viable scheme.
We do not consider this site to be a deliverable site and it should therefore removed from the draft Plan.

Support

Representation ID: 9639

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Support proposal.
Significant areas of growth are now proposed for these settlements with the likely result being small pockets of land which no longer fulfil a Green Belt function.
For this reason, we do not consider it appropriate to remove just the built-up areas of the settlements themselves but to review the Green Belt boundaries as a whole in this area. Green Belt is a function and if adjoining parcels of land no longer serve that function then they should be removed from the Green Belt - adequate protection can be provided without the need for a formal Green Belt designation.
Given this is a non-statutory consultation, any review should occur with the identification and allocation of sites.

Object

Representation ID: 9640

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Do not support proposal to switch from a percentage based affordable housing calculation to a floorspace percentage calculation.
The justification for this is given as a need to drive up the proportion of smaller properties being delivered. However, the Council has not published any analysis of its assumptions which underpin the comments made in this section; and appears to be confusing matters relating to housing mix; housing size and matters relating to affordable housing provision. These are separate matters.
No evidence that such an amendment will have effect of providing smaller market housing.

Object

Representation ID: 9641

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Floorspace calculation will not provide certainty to developers and landowners at point of site acquisition.
This is one of the reasons that Stratford District moved away from this policy to a standard percentage of units-based policy, which was supported during their last Local Plan review.
Change in approach will slow down planning application process, and bring viability matters into play more frequently.
Note that this approach would run counter to the WMS on affordable housing which does not seek contributions on sites of 10 dwellings or fewer (i.e. based on dwelling numbers and not floorspace calculations).

Object

Representation ID: 9642

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Not supported - should keep to a units based policy.