Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13836

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site 107 - Land at Gentleshaw Lane.
The site should be removed from the Green Belt as it does not perform a Green Belt function. The site reads as forming part of the built up conurbation and does not have an association with the wider countryside beyond or visually reflect its Green Belt designation. The site has urban influences on all boundaries which have increased significantly over time, and serve to reinforce the relationship of the site to the town rather than the rural area. The Green Belt boundary around the site needs to be reviewed and is a distinct exercise from the positive allocation of land.

Object

Representation ID: 13837

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council have explored in detail the changes to Green Belt boundaries in the context of removing land for the purposes of site allocations. However, it has not given due consideration to revisiting Green Belt boundaries where land no longer fulfils a Green Belt function.
One such example is at Gentleshaw Lane, Solihull (site 107), where a process of new development inset within the Green Belt over a period of many decades has taken place. This area no longer fulfils a Green Belt function and as such, Green Belt boundaries should be redrawn to reflect this change in circumstances.

Support

Representation ID: 13838

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Support the principle of the site being removed from the Green Belt. However, it should be clarified that the masterplan is for indicative purposes with a final masterplan formulated as part of the development management process.
Specific details of how open space is to be provided is still to be explored as is Green Belt mitigation / enhancements.
Infrastructure requirements should refer to the provision of 40% affordable housing in accordance with Policy P4A.
Concerns as to the extent to which evidence supports the re-provision of Arden Academy and whether this is a necessary infrastructure requirement arising from the draft allocation.

Object

Representation ID: 13839

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criteria 9 provides a degree of overlap in relation to the provisions of paragraph 243.
Our observations in relation to paragraph 243 apply equally in relation to Policy P15(9).
Here we go further, and seek clarification as to what the Council consider amounts to “demonstration” as to how engagement with other relevant landowners or developers with an interest in any given allocation is evidenced.

Object

Representation ID: 13840

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is a contradiction in terms in paragraph 243. ‘Piecemeal’ means piece by piece, one piece at a time. However, it is important is that there is a unifying approach to the bringing forward of an allocation and that one piece does not prejudice the delivery of another piece.
The Council recognises that an allocation can come forward in phases indicating an acceptance to a piece by piece approach (which is better characterised as a coordinated phased approach); it is the coordination of the bringing forward of pieces which is critical to the successful delivery of an allocation.
In this context, concept master plans are only one way in which an allocation can be brought forward piece by piece provided that there is a demonstration that they will not prejudice the delivery of the remainder.

Support

Representation ID: 13841

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Support the Council’s recognition as to the importance of the historic environment.
However, Criteria 3 sets out a development management policy which refers to a recognised process of assessment, involvement, evaluation and design. It is not clear however what this recognised process is. The policy is imprecise as a result, and requires greater clarity.
The NPPF sets out a clear policy framework for dealing with heritage assets at paragraphs 195, 196 and 197. This hierarchical approach is more precise than the provisions of Policy P16 and provides for more clarity in a development management context.

Object

Representation ID: 14108

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The need for affordable housing is agreed and supported. .

Paragraph 158 of the draft Submission Plan makes clear that affordable housing need is exceptionally high in Solihull, particularly in the mature suburbs and rural areas of the Borough.

40% affordable provision on qualifying sites reflects the requirements in the 2013 Local Plan and has historically ensured affordable housing delivery without creating issues in terms of site viability.

Criteria 3(iv) states that in circumstances where the provision of affordable housing would prejudice the realisation of other planning objectives that need to be given priority in the development of the site, affordable housing will be considered at less than policy compliant 40% provision.

Given the scale of the affordable need in Solihull, and the provisions of the Borough vision which includes Borough residents having access to a range and choice of quality housing accommodation, it is difficult to envisage any circumstances where other planning objectives take precedence over the delivery of affordable housing.

Object

Representation ID: 15078

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Plan being brought forward during time of uncertainty in national policy
- SM consultation increases LHN in Solihull from 807 dpa to 1,011 dpa
- Plan likely to be adopted very close to base date, therefore risk of plan not delivering level of growth set out, within timescales
- Although Local Plan should be reviewed every 5 years, and shorter triggers can be included in Plan, this can take up to 10 years to complete as a process
- Could be distant point in future before Council plans for higher SM levels
- Therefore could be a significant period of time when Plan will be under-delivering open market and affordable housing
- Council should therefore commit to identifying reserve sites as Stratford upon Avon have done, to provide greater flexibility, and avoid delays from partial or whole review.

Object

Representation ID: 15079

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criteria 18 refers to local nature reserves, local wildlife sites or geological sites.
Policy text associated with these designations all refer to the policy implications where development has an adverse impact upon such designations.
Policy is silent on the approach to be taken where a proposal has a positive impact on such designations and how this is to be addressed in any planning
balance.
E.g. Securing appropriate management of otherwise neglected or unsympathetically managed local wildlife sites.
Therefore policy unbalanced, and not accurate representation of development management process.

Object

Representation ID: 15080

Received: 14/12/2020

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Support the provisions of Policy P21 and the need for developer contributions and infrastructure provision in principle.
- However, these provisions can only be promoted where the developer contributions and infrastructure provision meets the three CIL tests, specifically;
• Necessary to make the development acceptable in planning terms;
• Directly related to the development; and
• Fairly and reasonably related in scale and kind to the development.
- As drafted, whilst the policy makes passing reference at various points to the provisions of the CIL tests, these are not explicit.
- As a result, the policy is imprecise and it is not clear whether its operation would be discordant and at variation with the CIL provisions.