Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14300

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

In previous versions of the Local Plan Review site 246 (Sharmans Cross Road) was included as an allocation in the Plan. Representation seeks the sites re-inclusion as an allocated site in order to assist in ensuring the plan delivers certainty and ultimately success as a tool for meeting its housing needs.
A concept master plan is included with the representations which demonstrates how the site could be developed to make best and efficient use of the land available in accordance with the council’s proposed density aspirations for sustainable sites in urban areas. Ia technical Transport note is also included.

Object

Representation ID: 14301

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing target should be a minimum.
As the plan period base date is likely to be close to being the adoption date, the plan period extends some way into the future. This brings into sharp focus the difference between the annual housing target being proposed in the Local Plan Review and the latest figure set out within the Government’s standard methodology. Based on the latest emerging position, the Local Plan Review will be falling significantly short of housing need for the Borough.
Should the plan proceed in its current form, there is a significant period where there will be less open market and affordable housing being delivered than the latest evidence would indicate is required for the Borough which has a significant adverse impact in relation to the economic, social and environmental dimensions to sustainability.

Object

Representation ID: 14302

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy as drafted does not include low-cost market housing. That is housing which is specifically designed to cater for the needs of the significant part of the market whose income excludes them from the traditional affordable tenures but does not enable them to viably enter the open market as a private renter.

Object

Representation ID: 14303

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy lacks sufficient flexibility. Imposing a borough wide housing mix on all sites is not appropriate.
The 2020 HEDNA is not the only measure to determine the market mix on sites. The policy should include flexibility to allow developers to provide their own evidence depending on specifics of location.
Criterion 1. ii needs to have regard to the emerging standard methodology which will influence needs assessment.
Criterion 1. iii) may provide unwelcome justification for resisting certain types of development because they do not conform with the prevailing characteristics of a particular area even if the need for that type of development is proven.
Criterion 3. prescribed mix is too rigid and does not allow for development to respond to the specific characteristics.

Support

Representation ID: 14304

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

This policy is supported. It is indeed of utmost important to ensure that all new development should be focused in the most accessible locations. This evidently underpins one of the main strategic aims of the plan, which is to ensure that the existing urban area should be the initial focus for accommodating development.
We submit again that the omission as an allocation of the land at Sharman’s Cross Road serves to indirectly undermine the credibility of this policy given its obvious alignment with the fundamental aim of both the spatial strategy and this policy.

Support

Representation ID: 14306

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Whilst the general thrust of policy P14 is supported, submit that criterion vii, which seeks to protect, amongst other things, community facilities and open space from the introduction of incompatible development, is too rigidly drafted. It does not for example allow for the loss of such facilities through development where the benefits of that development significantly outweigh the dis-benefits of the loss.

Support

Representation ID: 14307

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Thrust of policy generally supported.
However, yhe policy as drafted lacks the flexibility to encourage and deliver designs which are innovative and bring about change.
Criteria 1 and 2 refers the need to conserve local character. Good design does not need to conserve every facet of what makes a place distinctive or indeed conserve every aspect of local character.
There will be instances where in order to secure high standards of design quality, a departure from obvious local character will be necessary and as drafted, the policy would stifle innovation and ultimately the ability to secure such high design standards.

Support

Representation ID: 14308

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Spirit of the policy is supported but as drafted it lacks the flexibility.
In Criterion 3 there is no definition of 'of value to the local community'. This could be used to unduly object to a scheme which results in the loss of a community facility which has little or no value simply because a third-party claims that it is of value to them.
In the exceptions at i – v it is unclear whether all criteria should be met or just one. It is submitted that it should be just one of the five criteria, with the conjunction 'or' after each sub criteria.
Criteria 4 as drafted requires the loss of any existing facility to be replaced by another physical facility. If evidence demonstrates no existing need for that facility, there should be no requirement to provide an alternative one.
It will not always be possible or appropriate to provide alternative provision. It may be more appropriate to make a contribution to an existing or planned new facility.

Object

Representation ID: 14309

Received: 14/12/2020

Respondent: Oakmoor (Sharmans Cross Road) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

All obligations need to meet the relevant community infrastructure levy tests set out in CIL regulation 122. That is, the obligation must be necessary to make the development acceptable in planning terms, directly related to development and fairly and reasonably related scale unkind to the development.