Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

Introduction

Representation ID: 13736

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Introduction needs to be modified to indicate that, following adoption of the Local Plan, neighbourhood plans will still be part of the development plan. In addition, neighbourhood plan policies that provide a more appropriate local expression should be identified in the related settlement chapter / allocation policy and not left to the decision maker.

Change suggested by respondent:

Amend para 20 as suggested in the submission attachment which confirms that neighbourhood plans that are ‘made’ are still part of the development for the Borough.
Amend para 21 as suggested in the submission attachment which states that Neighbourhood plan policies that provide a more appropriate local expression should be specifically identified in the related settlement chapter / allocation policy.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4A Meeting Housing Needs – Affordable Housing

Representation ID: 13737

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy P4A does not address occupation by households with a strong local connection. Whilst the local needs of households are covered in Policy P4B, this is only in relation to rural exception sites. There is a failure to recognise the presence of neighbourhood plan policy dealing with local needs affordable housing on allocated housing sites. In addition, differences regarding the tenure split are not acknowledged.

Change suggested by respondent:

Addition of a new paragraph in Policy P4A after paragraph 8 as follows:
The provision of affordable housing on allocated sites to meet the needs of households in that Parish or Neighbourhood will be supported where it is consistent with a neighbourhood plan.
Amend paragraph 175 in the justification to P4A to include the following:
In determining planning applications, regard shall also be paid to relevant neighbourhood plan provisions.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4C – Meeting Housing Needs - Market Housing

Representation ID: 13738

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The recommended market mix in this policy differs from Policy H3 Market Mix of the Knowle Dorridge and Bentley Heath Neighbourhood Plan. This was ‘made’ in April 2019 and is up to date and relevant. It is noted that para 187 states that relevant policies in neighbourhood plans will be taken into consideration along with other matters. However, the other matters are also referenced within the policy. In view of the role and status of neighbourhood plans, they should also be included in the policy.
The policy indicates that concept masterplans will include details of the likely required profile of household types. This is missing from the Masterplans.

Change suggested by respondent:

Add to policy P4C, after point 1vi:
1vii any relevant policies in neighbourhood plans.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 13739

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection relates to Housing Requirement for Designated Neighbourhood Areas - The housing number identified for the Knowle, Dorridge and Bentley Heath Neighbourhood Area (808) is derived from the estimated capacity of the selected sites. The Forum has raised issues around the policies and concept masterplans for these sites which seek modification to that number. The Forum would oppose any further site allocations to compensate for reduced capacities on allocated sites.

Change suggested by respondent:

In the event that the Forum’s representations on the Knowle site allocations and concept masterplans lead to a revised housing capacity, a consequential modification will be required to the Knowle, Dorridge and Bentley Heath Neighbourhood Area housing number in Para 234.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 13740

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection relates to density - The content of the Plan in relation to density is not clear and unambiguous. The application of Policy P5 and the indicative density tables are inconsistent with site allocation polices KN1 and KN2 and their concept masterplans. The provisions do not reflect the Neighbourhood Plan policies nor the published evidence base relating to local character and masterplanning.
The density table at Paragraph 240 indicates that mixed development density should be 40-50 dph for limited or significant extensions at the edge of larger villages. However, proposed densities in Knowle above 40 dph on site allocations would be out of character with the area and its surroundings.

Change suggested by respondent:

None required to the policy.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 13741

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Concept masterplans are discussed in the justification to Policy P5. However, they are not addressed within the policy itself. Given their importance, key provisions should be included within the strategic policy. The provisions also need to be strengthened so as to give confidence to the public and a clear steer to developers. The status of the concept masterplans as part of the Local Plan needs to be confirmed.

Change suggested by respondent:

Policy P5 - additional paragraph (Para 7)
Concept Masterplans
7. Development on allocated housing sites shall be carried out in accordance with the related concept masterplan and the principles set out in the housing allocation policies. The content shall be as prescribed in the Local Plan.
Para 242 – additional text to specifically state that concept masterplans for each site form part of the Local Plan.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Knowle, Dorridge & Bentley Heath

Representation ID: 13742

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Representations are made relating to, amongst other things, lack of clarity over application of Neighbourhood Plan policies; the deliverability of the Knowle site allocations, in particular the community facilities; effectiveness of infrastructure mitigation measures; and concerns around concept masterplans, design and densities.
Modifications to the Knowle, Dorridge and Bentley Heath (KDBH) Settlement Chapter are needed regarding public transport; highway improvements; community access; affordable housing; primary health care; and densities.

Change suggested by respondent:

Modifications as proposed in the representations which include:
- Deleting references to the settlement being well served by public transport at para 685 and 690.
- Adding that traffic lights would be inappropriate at para 698
- Additional paragraph after para 700 to read:
"The Neighbourhood Plan has two policies that are particularly relevant. Policy ECF2 requires consideration of dual use, by the community, of school buildings and outdoor recreational facilities. Policy ECF6 provides for the submission of a Community Access Statement and agreement regarding the extent of public access. Both of these policies are applicable to the new education provision in Knowle."
- Para 703 add text to end of paragraph as follows:
"Neighbourhood Plan Policy ECF6 provides for the submission of a Community Access Statement and agreement regarding the extent of public access. This policy will be applicable to the proposed new sports provision."
- Para 707 add text to end of paragraph as follows:
"The Neighbourhood Forum’s affordable housing policy (Policy H2) requires 25% of affordable housing to be occupied by household with a strong local connection with KDBH. This is different from the Borough-wide provisions in this Local Plan. However, given its local credentials, Policy H2 is the policy to be applied in KDBH. With regard to the required affordable housing tenure split (Policy P4A 6), regard will be paid to the Neighbourhood Forum’s preference for a higher percentage of shared ownership."
- Additional paragraph after paragraph 707 as follows:
"Primary Health Care - The three doctors’ surgeries within KDBH are all under stress. As such, proportionate developer contributions will be required towards improvements to the local primary health care system. An appropriate location to meet the need will be identified."
- Additional para after Para 709 as follows:
"The density of future development will need to reflect a number of factors. It will be appropriate to make efficient use of land and exploit proximity to existing services and amenities. At the same time, avoidance of a cramped appearance will be important as will the characteristics and distinctiveness of the area, the landscape setting and proximity to listed buildings."

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy KN1 - Hampton Road, Knowle

Representation ID: 13743

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There is an ‘in principle’ concern about the lack of evidence to demonstrate the viability and deliverability of this allocation, including the ability of the football club to relocate. A raft of measures are needed to add to or strengthen policy provisions in relation to the allocation. They concern densities; Grimshaw Hall; trees and hedgerows; footpaths; engineering works; community use; primary health care; highway improvements; and concept masterplans.

Change suggested by respondent:

Modifications as proposed in the representations for Policy KN1 which include:
- Setting out densities specifically.
- Identifying that the area between Hampton Road and the limits of the development shall be landscaped as amenity areas and that mitigation should significantly reduce harm.
- Retention of on-site trees is required.
- Need reference to the sports pavilion when talking about the relocation of Knowle Football Club.
- Retention of public footpath along its current alignment.
- Minimising harmful visual impacts as a result of the engineering works necessary to create the housing and playing fields.
- Need reference to Neighbourhood Plan community access policies in the Policy.
- Need reference to development contributions to local primary care.
- Need reference to specific highway improvement at junction of Arden Vale Road and Warwick Road.
- There should be no departure from the principles set out in the concept masterplan.
- There shall be no commencement of development until a planning obligation has been executed governing the nature of the development; its timing and phasing; and the funding of all aspects. No more than 20% of the housing shall be occupied before the playing fields and sports pavilion are brought into use.
- Additions to paragraph 713 and 714.
- Deletion of paragraph 715
- Correction in paragraph 716 to say that the former hedge line still exists.
- Additional paragraph after paragraph 716:
"Given the need to respect the setting of Grimshaw Hall, and the density characteristics of the surrounding area, low and medium residential densities (up to 35dph) will be appropriate on the northern part of the site. The southern part of the site is closer to the amenities of Knowle village and to higher density development at Wootton Close. Given also the prospect of a care village or retirement complex on the site of the existing football club, a higher density would be acceptable in this location for such a use."
- Amend accessibility commentary in paragraph 718.
- Say that development is consistent with Option F for the limited expansion of rural villages in paragraph 719.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy KN2 : South of Knowle (Arden Triangle)

Representation ID: 13744

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

These representations address firstly, an objection to the lack of evidence regarding the deliverability of this allocation: and secondly, a raft of measures that are needed to add to or strengthen policy provisions in relation to site KN2: South of Knowle (Arden Triangle). They concern densities; community access; highway access; trees and hedgerows; structure planting; primary health care; bus services; footpaths; and concept masterplans.

Change suggested by respondent:

Modifications as proposed in the representations for Policy KN2 which include:
- Setting out densities specifically.
- Referencing Neighbourhood Plan policies relating to community access to school.
- No vehicular access to the schools off Station Road.
- Important landscape features specifically mentioned.
- Need for a landscaping strategy to include screen planting along Warwick Road
- Developer contributions will be required for related improvements to the local primary health care system;
- Provision shall be made for access to enhanced bus services;
- Retention of exiting rights of way along current alignment
- No departure from the principles and other requirements applying to Site KN2
- No commencement of development until a planning obligation has been executed governing the nature of the development; its timing and phasing; and the funding of all aspects.
- Additional para after Para 720 as follows:
"That part of the site adjacent to Station Road is closer to bus routes and to the amenities of Knowle and Dorridge. Higher densities would be appropriate. Elsewhere, the landscape setting and proximity to the listed Rotten Row Farm dictate a lower density of housing, reducing in a southerly and easterly direction reflecting the transition to countryside."
- Additional para after Para 724 as follows:
"Policy KN2 requires access to enhanced bus services. As a minimum, applicants will be expected to negotiate with providers to achieve a meaningful diversion of existing services into the site. Increased frequency and the provision of new services shall also be considered and addressed where feasible."
- Valued landscape features should be named.

Full text:

See attachments.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Foreword

Representation ID: 13745

Received: 10/12/2020

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Relates to Masterplan Document - The status of the masterplan document is ambiguous. It should be made clear that the concept masterplans are an integral part of the Local Plan and that adherence to key principles will be required; also, that only minor changes are envisaged in the future.
Essential matters and key principles of development should be clearly stated requirements and distinguished from any material that might be illustrative.
Densities differ between what is contained in the MP document and table at para 240 of the LP.

Change suggested by respondent:

Modifications as proposed in the representations for the Concept Masterplan document which include:
- Clarification that the document forms an integral part of the Local Plan, are not illustrative and subject to only minor change.

Full text:

See attachments.

Attachments:

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