Draft Local Plan - Supplementary Consultation

Object

Representation ID: 8932

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Lichfields

St Philips consider that Site 503, 1.7ha of land east of Stratford Road, Hockley Heath should be removed from the Green Belt and allocated for development to meet the future housing needs of the settlement, in conjunction with land off Aylesbury Road in Warwick District, which will be promoted through the review of the Warwick District Local Plan.

Comment

Representation ID: 9333

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

Site ref 131: Birmingham Business Park, adj. Coleshill Heath Road.
St Philips is promoting the allocation of the land for the delivery of up to 135 dwellings within the first five years
of the new Local Plan period.

Support

Representation ID: 9334

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

St Philips agrees with the approach of applying the Standard Method for calculating housing need for the Plan period, but notes that the calculation provides a minimum figure and a starting point for the preparation of the Local Plan.
Although not consulted on, St Philips does not consider the 2,000 contribution is sound.
In terms of housing supply:
Council should provide full schedule of sites in the housing supply and proposed trajectory, inc. permissions.
Do not consider there is sufficient evidence for inclusion of BLR sites in the supply assumptions.
Need further evidence to justify continued inclusion of SLP sites.
More justification required for UKCHub and NEC figures.
Question deliverability of windfall sites at 150dpa over plan period.
Should provide more information on 1ha sites in accordance with NPPF.

Object

Representation ID: 9335

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

St Philips does not disagree with the general approach of providing a RAG classification to each site assessment.
Stage 2: No explanation is given, however, as to how the significance of potentially harmful impacts is to be assessed in the exercise of planning judgement.
More generally, no guidance is provided on how the Factors in Favour and Factors Against are ranked and/or weighted. Without such an explanation it is not clear how the individual, or relative, merits of sites are assessed. This is a weakness given that Step 2 is used to either include or reject sites for allocation.

Object

Representation ID: 9336

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

Do not agree that SHELAA Site 131 should be red but green after the Step 2 refinement criteria.
We assume that the Step 2 Assessment will have scored the site highly in terms of 'Factors in Favour' given the lack of hard constraints (and limited soft constraints) and that it comprises part of a 'Lower Performing Refined Parcel' (with a combined score of 3 against the 'threshold' score for lower performing parcels of a
combined score of 5).
The site complies with the Spatial Strategy in the 2016 DLP:
Not subject to any overriding hard constraints
Category 2 not 3 SHELAA site - Vision document shows how concerns can be mitigated.
Site would not breach strong defensible Green Belt boundaries, as not GB parcel boundaries not considered strong in the Green Belt assessment.
Site is in accessible location.
Landscape Character does not have very low capacity.
Sustainability Appraisal is generally favourable, and negative impacts can be overcome.

Comment

Representation ID: 9474

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Lichfields

St Philips do not believe there are exceptional circumstances that would justify the Council using an alternative approach, but nonetheless consider the Council have not appropriately addressed the requirement to contribute to the unmet need of the wider HMA. Use of standard methodology and 2014-based projections welcomed. Evidence of lack of agreement across HMA authorities, with NWBC raising concerns. Lack of clarity over mechanism to agree distribution and delivery of shortfall. Solihull well placed to deliver greater proportion, procrastination will result in unmet housing needs, stifle economic growth, and failure to include will mean Plan unsound.

Comment

Representation ID: 9475

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Lichfields

Whilst proposed site has not been tested against the Accessibility Study and Green Belt Assessment, its suitability can be compared with the scoring of site 38 Ashford Manor Farm, Stratford Road given its proximity. Site 38 is considered medium/high in accessibility and lower performing parcel in terms of Green Belt with a combined score of 5. However, the Site Assessment Commentary notes that 'it would be difficult to establish a logical and defensible Green Belt boundary.' Disagree as Site 38 self contained and bound by permanent physical features.

Comment

Representation ID: 9476

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Lichfields

Fulfilling the Duty to Cooperate will require the Council to reach agreement with the other authorities throughout the HMA on how it can assist in accommodating an appropriate portion of the unmet housing needs from across the HMA. Responses from North Warwickshire Borough Council/Coventry City Council to the Draft Local Plan consultation in 2016 raise concern over how Solihull are addressing their contribution to the HMA shortfall. North Warwickshire Position Statement demonstrates that concern over lack of agreement. Solihull well placed to deliver significant proportion, and failure to do so will result in unsound Plan.

Comment

Representation ID: 9518

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

No exceptional circumstances to deviate from the standard methodology as that is a requirement in the NPPF.
The Council should be using the standard methodology to determine the minimum number of homes needed and the 2014 based household projections should be used for standard methodology calculations to establish the Local Housing Need ('LHN') figure.

The figure of 109% deems that no action is required. However, the MHCLG is committed to boosting the supply of housing and although the housing delivery test score requires no action we consider that assessed need housing numbers should be seen as minima.

Object

Representation ID: 9519

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

We object to the assessment of our client's site (207) in the Site Assessment document. As a priority 5 site, the land should fall within the 'potential inclusions' (yellow sites) category.
Do not support the Step 2 'refining criteria' and the lack of clarity on how sites have been assessed against the factors listed in the table.
Requires more clarity on step 2 assessment.