Solihull Local Plan (Draft Submission) 2020

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Solihull Local Plan (Draft Submission) 2020

Spatial Strategy

Representation ID: 14450

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Representation Summary:

The Spatial Strategy, which seeks to focus significant development in locations that are, or can be
made, accessible and sustainable is achievable. Given the Borough's characteristics, development on the edge of the urban area or in accessible locations within/on the edge of rural settlements is supported.
HS2 will ensure that the Borough and surrounding area are even more well-connected, making urban area of Solihull and its surrounding villages even more sustainable. The challenge of maximising the economic and social benefits and opportunities of High Speed 2 is key to the Borough’s success, alongside protection
of natural assets and rural setting whist safeguarding high performing Green Belt areas

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Spatial Strategy

Representation ID: 14468

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Consideration of the Green Belt Assessment is flawed and inconsistently assessed in the Site Selection process. Definition of parcels in the GBA include areas of different character within the same parcel. RP25 includes land north and east of Meriden which perform differently. The area to the north performs less well against Purpose 1 to check unrestricted sprawl as it is confined by A45 to the north, and should be lower performing.
Sites that perform similarly to allocated sites have been dismissed. RP29 and RP31 are similarly moderately performing, but RP29 is assessed as a single site, whereas only small portions of RP31 are assessed, resulting in a very different conclusion
A further review of Sites is required in the context of the overreliance on large sites and housing need.

Change suggested by respondent:

The methodology / site identification contained within the Green Belt Assessment should be reviewed.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14475

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Paragraph 162 of Introduction re housing land supply is supported in principle, but insufficient provision is made to address needs associated with the UKC Hub or the housing market area shortfall. Projections should be continually monitored. Plan dependent on a small number of large allocations requiring significant infrastructure being developed as and when
anticipated, and may not occur. Reserve sites in locations that are, or can be made, accessible and sustainable, which are located on the edge of the urban area or within rural settlements with the greatest range of services must be identified should any allocations not deliver
sufficient housing numbers

Change suggested by respondent:

In order to ensure a supply for fifteen years and a rolling five-year supply of housing land reserve sites
should be identified should any allocations not deliver sufficient housing numbers or sufficient
properties when anticipated.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Providing Homes for All

Representation ID: 14478

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The mix of social rented and shared ownership housing proposed in Policy P4A 7 and 8 differs from that proposed in the referendum version of the Balsall Parish NDP and the HEDNA, which propose ranges of unit size. The policy contains factors influencing provision which suggest that a range is more pragmatic, and that the approach is overly prescriptive and inflexible.
The mix range should be provided in a table contained within the supporting text which accompanies the policy, as opposed to the policy wording itself.

Change suggested by respondent:

The specific set percentage figures should be removed and a range of unit sizes, as justified and evidenced within the HEDNA [Paragraph 8.30] provided instead within a table contained in the explanatory text which accompanies Policy P4A.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4C – Meeting Housing Needs - Market Housing

Representation ID: 14482

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The market dwelling mix detailed within Policy P4C 3 differs from the range in the referendum version of the Balsall Parish NDP and the HEDNA. The policy notes the factors that influence housing mix. A specific mix is counterintuitive and contradictory to other Plan policies, such as design. Paragraphs 186 – 190 state that a more flexible approach should be taken in relation to the policy, reflecting the findings of the HEDNA.
The mix range should be provided within a table contained within the supporting text which
accompanies the policy, as opposed to the policy wording itself.

Change suggested by respondent:

The provision of a specific set percentage figures should be removed from Policy P4C and a range of unit sizes, as justified and evidenced within the HEDNA [Paragraph 8.32] provided instead within a table contained in the explanatory text which accompanies the policy.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding

Representation ID: 14488

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The requirement for self and custom build plots in Policy P4D is not supported by the HEDNA, unduly onerous and not justified. SMBC should provide a robust assessment of demand including an assessment and review of data held on the Council’s Register, which should be
supported by additional data from secondary sources to understand and consider future need for this type of housing. There is no evidence for the threshold at which provision is required or the percentage requirement, or clarity on the position if plots are unsold. This restrictive burden is contrary to national guidance which will lead to viability, delivery and management issues and similar proposals have been removed at examinations

Change suggested by respondent:

Policy P4D should either be deleted from the Local Plan in full or amended to remove the requirement for developers of allocated sites to contribute to self and custom build housing.
Should the self and custom housebuilding policy remain, it should be amended so as to be supportive and encourage such forms of building. The provision of such plots on allocated development sites should only be at the discretion of the developer and based on the market requirements at the time.
If the Council believe the policy is justified it is requested that the policy be amended to allow for either
self-build or custom build plots, thus partly reducing the onerous nature of the policy whilst allowing
developers to adequately plan and manage sites.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14494

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The identification of housing need greater than the Standard Methodology minimum in Policy P5 is supported in principle, but given the need to significantly boost housing, economic growth at the UKC Hub and the housing market area need growth significantly exceeded past trends is required. There is overreliance on large complex sites with significant infrastructure needs, many in close proximity, a high windfall rate with significant Green Belt and little brownfield land, and significant growth at the UKC Hub and town centres.
Policy does not allow for contingency or flexibility so SMBC should identify reserve housing sites
for release if monitoring indicates that they are required for 5 year land supply or shortfall outside the Borough

Change suggested by respondent:

Plan should identify additional reserve housing sites and the mechanisms for their release, should they be
required, through an appropriately worded additional policy.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14495

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The housing allocations in paragraph 226 should have an approximate capacity rather than a fixed maximum to provide flexibility.

Change suggested by respondent:

The references to housing requirements in the site allocations should be expressed as ‘approximate’
to ensure that the policy isn’t overly prescriptive, with the details to be determined as part of the
consideration of the planning applications.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14496

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

No reference is made under Policy P5 or within its supporting text as to the status of the Concept
Masterplans referenced in paragraph 242, which are contained within a supplementary document.

Change suggested by respondent:

In order for the associated policy (Policy P5) to be effective the status of the Concept Masterplans should be made more explicit, as they are within the policies associated with each allocation.

Full text:

See attached

Object

Solihull Local Plan (Draft Submission) 2020

Policy BC3 - Kenilworth Road/Windmill Lane, Balsall Common

Representation ID: 14497

Received: 14/12/2020

Respondent: Catesby Estates Limited

Agent: Terence O'Rourke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Site BC3 is, in principle, supported, but should not be overly prescriptive. Should be allocated for ‘approximately’ 120 dwellings as opposed to a set figure to provide flexibility. Policy BC3 2vi requirement for self and custom build plots is onerous and unjustified.
Site performs poorly in the Green Belt Assessment and has defined boundaries so removal from Green Belt is justified. Site is accessible to village centre and schools, with good connectivity with Meeting House Lane for walking/cycling.
A full assessment of the extent of harm to the setting and significance of Berkswell Windmill, and whether it can be acceptably mitigated should be undertaken at the time of a planning application in accordance with the NPPF tests. The reduction in area/capacity from the Supplementary Consultation is supported.
Whilst the ecological evidence contains errors and the existence of ‘areas with significant habitat value’ is disputed, the north-south and east-west ecological corridors are accepted and any potential constraints can be mitigated

Change suggested by respondent:

Policy BC3 1 should be amended so that the allocation is for ‘approximately’ 120 dwellings as opposed to a
set figure which wouldn’t allow the required flexibility.
Policy BC3 2 (vi) requirement to provide Self and Custom Build Plots should be removed.

Full text:

See attached

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