Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13726

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Reference to ‘protection of the Green Belt’ in the Vision does not take into account the fact that there are exceptional circumstances which justify the release of appropriate Green Belt sites. The current wording is therefore considered unsound as it is not consistent with national planning policy.

Object

Representation ID: 13748

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The level of growth apportioned via the spatial strategy is unsound as it is not justified or consistent with national planning policy. There is potential for further growth to be accommodated within the spatial strategy, including more growth to Hampton in Arden.

There is scope for additional reasonable alternatives for growth options to be identified that lie within Option 3 (16,000 dwellings) and Option 4 (19,000 dwellings). These could be delivered via additional sustainably located Green Belt sites in accordance with the spatial strategy. The Site Assessment methodology has unduly constrained the capacity for further sustainable Green Belt release.

It is unclear why the preferred option (Option 2a) has been selected over additional growth as the SA recognises that Option 3 could be accommodated without generating further significant effects that would not arise under Option 2.

Object

Representation ID: 13749

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Under all of the Options in the Sustainability Appraisal where the UK Central Hub is identified as part of the supply it is for 1,500 dwellings. This is not consistent with the draft plan which identifies the capacity for 2,240 dwellings.

Object

Representation ID: 13750

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No settlement hierarchy is provided which sets out the sustainability credentials and growth potential of individual settlements. This would focus growth on those settlements identified as appropriate for development and reflect the range of facilities and services available.

Object

Representation ID: 13751

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The plan does not consider the longer-term permanence of the Green Belt boundaries beyond the plan period. It is considered unrealistic to assume that further Green Belt release will not be necessary beyond the plan period.

Object

Representation ID: 13752

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We have concerns with the application of the Site Assessment methodology in terms of its transparency and consistency.

The site assessment of Site 418 is based on an incorrect site area and should be updated. The latest Vision Document proposes a capacity for around 292 dwellings rather than 901 dwellings. The Site Assessment process has not considered the ability for the issues identified to be addressed via a lower site capacity.

There are inconsistencies between the different evidence base documents used to inform the Site Selection process for Site 418, in relation to proximity of listed buildings and accessibility.

It is not clear in the Site Assessments what factors have been given greater weight and whether the ability to mitigate adverse effects has been taken into account consistently.

There is no justification why Site 418 is not coming forward alongside HA1 and HA2, based upon the Site Assessment methodology. Mitigation measures are not applied consistently to all sites. Mitigation measures related to accessibility for HA1 have been proposed within the policy, however mitigation measures for defensible boundaries for Site 418 were not similarly considered.

Object

Representation ID: 13753

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The requirement in Policy P4D goes beyond the guidance provided in the PPG which seeks local authorities to "engage" with landowners and "encourage" them to consider self-build and custom housebuilding. There is an over-reliance upon the Self Build Register to justify the requirement, with the criteria for expressing an interest being relatively limited.

Object

Representation ID: 13754

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is unclear whether the evidence base supporting Policy P4E is robust, including around viability and deliverability. The Viability Study does not make reference to P4E in Round 2 testing. Specialist housing may be appropriate on some sites, this should be tested.

Object

Representation ID: 13755

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P5 is unsound in respect of the housing requirement identified.

It is imperative that sufficient homes are provided to support the envisaged economic growth. The HEDNA should test an addition UK Central Hub growth scenario (22,998 jobs) to determine how many homes might be required in Solihull if all jobs are filled by residents of Solihull.

We consider that there is a need for between 16,570 and 19,975 dwellings (2020-2036). A reasonable mid-point suggests that 18,500 dwellings should be provided to deliver the envisaged jobs growth at UK Central Hub.

Object

Representation ID: 13756

Received: 14/12/2020

Respondent: Heyford Developments Ltd

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is no clear evidence on the level of contribution to the unmet housing needs of the Greater Birmingham Housing Market Area (GBHMA) or the extent of agreement with other GBHMA authorities. The Council has not published a separate Duty to Cooperate Statement or any Statements of Common Ground.

We consider that the shortfall against the Birmingham Development Plan unmet need figure is in between 11,294 and 13,101 dwellings up to 2031.

The implications of the Standard Method calculation for local housing needs (2019) should also be considered. Across the GBHMA this would result in a minimum unmet need of 25,543 dwellings up to 2031.

We have concerns with the supply identified up to 2031. Some of the capacity identified in the GBHMA to meet the shortfall is not secured and should not be relied upon.

The Position Statement only addresses the housing market area shortfall up to 2031. A shortfall post-2031 will exist. We consider the existing Standard Method for the GBHMA would create an unmet need of between 17,000 and 18,400 dwellings for the period 2031-2040.