Solihull Local Plan (Draft Submission) 2020

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Solihull Local Plan (Draft Submission) 2020

Policy P15 Securing Design Quality

Representation ID: 14174

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Representation Summary:

Generally support the approach to this draft policy but suggest that amendments are required to 2iv to make the policy more effective as follows:
“Where possible, make appropriate provision for water management within development, without causing unacceptable harm to retained features, utilising innovative design solutions.” “Where possible” should be added to this policy to ensure that recognition is given to constraints such as ground conditions that may be present preventing delivery of SuDS.

Change suggested by respondent:

Request that the following amendments are made to the wording of this policy:
Point 2 iv of this policy should be amended as follows: “Where possible, make appropriate provision for water management within development, without causing unacceptable harm to retained features, utilising innovative design solutions.” “Where possible” should be added to this policy to ensure that recognition is given to constraints such as ground conditions that may be present preventing delivery of SuDS.

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P16 Conservation of Heritage Assets and Local Distinctiveness

Representation ID: 14175

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy goes beyond the protection of heritage assets to encompass (in paragraphs 2. and 3 of Policy P16) the protection of landscape character and local distinctiveness outside the settings of conservation areas and listed buildings.
The landscape character and distinctiveness that would be protected by draft Policy P16 should not be equated with the settings of these heritage assets or the contribution of settings to the heritage assets’ significance. In terms of considering the significance of Grimshaw Hall and the contribution of its setting, paragraphs 2 and 3 of Policy P16 are not relevant, and in paragraph 3 the use of the word “significance” is misleadingly ambiguous, as it does not specifically mean the ‘significance’ of heritage assets.

Change suggested by respondent:

To ensure that is effective, the policy should reworded to ensure it does not go beyond the protection of heritage assets to encompass the protection of landscape character and local distinctiveness outside the settings of conservation areas and listed buildings.
The landscape character and distinctiveness that would be protected by Policy P16 should not be equated with the settings of these heritage assets or the contribution of settings to the heritage assets’ significance. The policy should be reworded to reflect this.

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P17A Green Belt Compensation

Representation ID: 14176

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Council should set out Green Belt compensation projects which can be paid for through CIL. Communities could then identify projects that compensation could fund.
Where compensation cannot be provided on site or would result a reduced net developable area, there should be an effective strategy to enable off site contributions to be made in other locations e.g. through the identification of donor sites. It is not clear from item 4 of this policy where the Council will be using section 106 funds to make compensatory improvements.
No indication of how the level of compensation will be determined. A formula or calculation should be provided to allow developers to plan for this requirement on top of the other contributions sought.

Change suggested by respondent:

Request that the Council amend Policy P17A to refer to the use of CIL as well as S106 agreements to set out the Green Belt compensation projects. We also seek confirmation from the Council as to the level of compensation that will be requested for sites removed from the Green Belt.
This policy should make reference to land which the Council has identified as “donor sites” for compensatory improvements to be made via section 106 contributions secured by the Council for off-site contributions. This would make the policy more effective and justified. This change would also assist in making policy P10, in respect of biodiversity net gain more effective and justified.
We consider that this policy is unduly onerous and should be amended to allow for flexibility in the application of concept plans. As set out above there are a range of compensatory improvements that could be provided. The concept plans included within this Local Plan should not be relied upon to provide such detailed information because the Council’s evidence base is considered to be high level, whereas the evidence prepared on behalf of the landowners is more detailed. In particular the Council’s heritage advice is strongly objected to. HRD have had two separate opinions on the report prepared by David Burton Pye which concludes that the concerns and restrictions raised in respect of Grimshaw Hall are both inaccurate and unnecessarily restrictive. During the preparation of the local plan significant landscape and heritage detail was provided to the council to justify the proposals being promoted by HRD and it was requested that this detail be considered further at the planning application stage.

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P18 Health and Wellbeing

Representation ID: 14177

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to the requirement at 2 vii for all new development to deliver new and improved health services. This is not justified and not effective due to requirement being placed on all development sites without site specific consideration. New health facilities should not be a blanket requirement.
Where improvements are needed, but a new building or facility is not required, then financial contributions could be sought to improve existing facilities.
Recommend the policy is amended to allow for financial contributions where improvements are identified as the necessary mitigation to make development acceptable in planning terms.
Supports the principle of this policy.

Change suggested by respondent:

Propose that the policy is amended to allow for financial contributions where improvements are identified as the necessary mitigation to make development acceptable in planning terms.

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P20 Provision for Open Space, Childrens Play, Sport, Recreation and Leisure

Representation ID: 14178

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to the policy wording that a minimum standard should be applied across the whole Borough in relation to green space. This should be something that is informed by ward level data, as set out in the open space assessment and taking into consideration at a site by site basis at the planning application stage. Strategic priorities can be set, but to provide a specific green space standard at a Borough wide level is unduly onerous.
Object to the requirement in point 10 that new development should look to accommodate the needs of existing population. Any contribution or enhancement to be agreed through a section 106 agreement should be directly related to the development.

Change suggested by respondent:

Point 10 of the policy should be amended to remove the reference to a Borough wide minimum standard of Green Space, as this is does not allow the policy to be effective.
Reference should also be removed providing for the open space needs of the existing population as this would be contrary to regulation 122 of the Community Infrastructure Levy Regulations (2010).

Full text:

See attached documents.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P21 Developer Contributions and Infrastructure Provision

Representation ID: 14179

Received: 14/12/2020

Respondent: Hampton Road Developments Ltd

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion 4 of the policy states that the plan has been subject to a Viability Assessment to ensure the policies are deliverable.
Disagree with the viability conclusions regarding site KN1 and request the viability assessment is re-run taking into account concerns identified.
The Council should seek to respond to this critique either with robust evidence or make the changes proposed within their assessment.

Change suggested by respondent:

The Council should seek to amend the draft viability report to take account of the concerns raised by Savills.

Full text:

See attached documents.

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