Solihull Local Plan (Draft Submission) 2020

Support

Representation ID: 14162

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Support the allocation with some objections to the policy and the masterplan.
Policy goes beyond the PPG by requiring that developments “should” provide the list of eight enhancements identified.
Disagree with the proposed Green Belt boundary - a revised boundary is suggested.
Dwelling numbers should be a minimum. A range of 250 – 275 dwellings could be delivered.
Object to:
-The open space requirement being included in the policy. This will require further negotiation and progression of the final masterplan.
-2 vii which should be deleted (see reps to policy 4D).
-The size of the heritage buffer and the proposed use (see separate heritage response submitted).
- The reduction in housing numbers which impact contributions for infrastructure improvements.
Support the principle of a care home, with clarification that C3 dwellings are equally as acceptable.
The reduction in housing numbers will impact on contributions to infrastructure improvements.
Object to conclusions of the Concept masterplan and do not wish for this to be taken forward as a basis for development of the site through its allocation in the local plan or an outline application. Revised masterplan submitted.

Object

Representation ID: 14163

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Likely that a very high level of delivery will be required to develop out 2,740 units across the UKC Solihull Hub area to 2036 as per paragraph 89 of the Plan. This has not been adequately demonstrated as being deliverable.
In 2018, the Hub Framework stated up to 550 homes as being delivered at the NEC up to 2022. No application for residential development at the NEC has been made. The levels of delivery envisaged, even in the early stages of the plan period are overambitious and the policy is not effective in the way that it is currently drafted.

Object

Representation ID: 14165

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Does not provide developers with enough flexibility to consider the mix of housing at the planning application stage. Support the Council providing some guidance on housing mix but this should accord with the mix proposed in the HEDNA.
The HEDNA highlights the requirement for both social and affordable rent but recommends that the Council do not propose a rigid mix on the split. The housing mix should be updated and included in supporting text, rather than policy so a suitable amount of weight can be applied to the mix on a site by site basis.
The NPPF definition of affordable housing should be used.
Support recognition of the need to deliver more two and three bed homes than is set out in the Housing Needs SPD.

Object

Representation ID: 14166

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to setting a market dwelling mix on a borough wide basis and consider it unduly onerous. Consideration of mix should be determined at the planning application stage, following consideration of a range of site specific circumstances.
There are differences between the mix requested by the Local Plan versus the requirements of the made KDBH Neighbourhood Plan. Clarification on which mix should be taken forward if there is a situation in which both housing mixes are part of the Development Plan, is required.
Conclusions drawn from the HEDNA should be taken into account to form a policy which provides advice on the likely mix, but not rigidly apply the mix to all development sites, rather, housing mix should be bespoke to specific sites.

Object

Representation ID: 14167

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to the onerous approach being applied to the delivery of custom and self-build housing. Whilst it may widen housing choice, on large scale allocations there is a risk that the delivery of housing could be slowed.
Having reference to the PPG there is no requirement for self or custom build to be provided as part of larger allocated sites.
Applying the 5% requirement leads to potentially multiple separate contracts that would need to be agreed with interested parties.
Whilst the Self Build register may provide an indication of the level of interest, this needs to be analysed further to uncover the specific requirements of respondents. Where suitably evidenced, specific sites could be allocated for self-build and/or custom housebuilding.

Object

Representation ID: 14168

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Criterion 2 & 3 are onerous as they go above what is required through the Building Regulations. Standards can be exceeded where there is a justified need. The requirement to build all dwellings to Category M4(2) standards should be evidenced and balanced against the need to make the most efficient use of land.
Criterion 4 does not consider existing specialist housing or care provision in the locality and whether any additional provision is needed.
Criterion 5 does not include reference to the suitability of a site to accommodate accessible dwellings, for example topography or local demographics. The policy should be amended to accord with the PPG (Reference ID: 56-008-20160519) or provide evidence which justifies the position.

Object

Representation ID: 14169

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Criterion 5 should be amended to remove the requirement to comply with Nationally Described Space Standards. This should be something that “should” be complied with, as it is not always possible.
There has been a large increase in the level of windfall allowance included in the estimations of capacity compared to previous versions of the Plan. This appears to correlate with the capacity that has been lost on allocated sites.
There is no certainty regarding the delivery of windfall and it is not clear where in the Borough and in what form these dwellings will be delivered.
Rather than windfall, as many dwellings as possible should be provided through the Plan’s allocations.
Do not consider that 200 dwellings per annum of windfall dwellings is realistic or an effective way to plan for the future.

Object

Representation ID: 14170

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At 3 i, it is not for the planning system to place requirements over and above building regulations. The PPG states that Local Plans can set higher standards but only up to the equivalent of Level 4 of the Code for Sustainable Homes”. If this is required, changes to Building Regulations should be brought forward.
In 3ii, the government does not require net zero carbon dwellings now or from April 2025. It is unclear what the rationale of this requirement is.
In 3 iv, the practicality of requiring at least 15% of energy to be provided form renewable sources should be considered.
In 4 ii, it should be noted that it is not always possible (for example due to site constraints) to orientate every home to enhance natural ventilation and lighting. This is unjustified.
With regard to viability, £6000 per dwelling just to meet energy requirements without any other requirements being taken into account is considered significant.

Object

Representation ID: 14171

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Not clear whether the Council intend to bring a 10% “net gain” in biodiversity requirement ahead of the Environment Bill being passed, which would not be justified unless it can demonstrate evidence of this requirement being evidence based.
Support reference to Natural England standing advice in relation to ancient woodland and veteran trees.
In point 16 i, clarification of what tranquillity is, and how the impact on tranquillity will be measured. We are unsure how this will be assessed as part of a planning application. Without this evidence we do not consider the policy as written to be justified or effective.

Object

Representation ID: 14172

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

1 ix makes reference to development proposals being required to demonstrate that they have considered impact on tranquillity. We request that the Council clarify what is meant by this, we are unsure how this will be assessed as part of a planning application.
We note that paragraph 123 of the NPPF references that planning policies and decisions should aim to “identify and protect” areas of tranquillity. It is however not clear where the Council considers these areas to be with the Borough, and requirements for consideration of tranquillity within a planning application. We request this clarification to ensure that the policy requirement is effective and justified.