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
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.
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
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.
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
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.
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
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.
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
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.
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
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.