Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Vision
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.
The Vision should refer to ‘protection of the remaining Green Belt (which contains the strategically important Meriden Gap) as necessary, alongside sustainable growth…’
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Spatial Strategy
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.
Additional reasonable alternatives for higher levels of growth (particularly for options between 16,000 and 19,000 dwellings) should be tested.
The identification of additional Green Belt sites for consideration should be based upon a reappraisal of the Site Selection process.
The potential for additional Green Belt release to deliver levels of growth over and above 19,000 dwellings should be considered, as an alternative to the larger scale expansions of Balsall Common and Land South of A45.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Foreword
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.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Spatial Strategy
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.
A more clear and explicit settlement hierarchy should be added.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Spatial Strategy
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.
The Plan should identify safeguarded land in the context of ensuring longer-term development needs are met and that the Green Belt boundaries will not need to be altered at the end of the plan period.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Hampton-in-Arden
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.
The Site Selection process should be reviewed for consistency and transparency to provide a justified evidence base for the draft Plan.
The process should consistently consider the potential for mitigation measures in the assessment of sites.
Issues relating to Site 418 should be addressed, including the incorrect red line boundary area and assumptions around dwelling numbers.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding
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.
The requirement to provide 5% on allocated sites of 100 dwellings or more should be replaced with an ‘encouragement’ to provide self-build on allocated sites of 100 dwellings or more having regard to the latest robust evidence.
Criteria 2 of Policy P4D should make it clear that after the marketing period (which should be less than 12 months), any unsold plots should revert back to the original developer.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People
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.
Policy P4E should reference supporting evidence, to ensure deliverability of development sites is not affected by the requirements of the policy.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
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.
The housing requirement should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios to meet the envisaged jobs growth at UK Central Hub.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
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.
The extent of agreement from the other GBHMA authorities should be detailed in full.
The housing requirement should be increased to provide more flexibility to help meet GBHMA housing shortfall needs up to 2031 and beyond (up to 2036).
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
