Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15137

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

No statements of common ground have been prepared at the publication stage. It is unclear if effective and joint working has been undertaken, particularly in respect of unmet housing needs from the HMA. There is a significant gap in the Council’s evidence base on meeting its legal obligations under the Duty.

The housing need across the HMA beyond 2031 has been overlooked. There could be an emerging unmet need for some 39,605 dwellings for the period 2031 to 2036.

Solihull must engage on how to address the significant shortfall in housing needs of the Black Country. Delaying further consideration does not meet the legal test under the 2011 Act.

Object

Representation ID: 15139

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The amount of growth allocated to Meriden is just 1.2% of the overall total allocation in the Plan. The level of growth proposed does not reflect the need for proportionate growth to the settlement consistent with the spatial strategy. The concentration of growth on a small number of strategic sites goes against the ‘balanced dispersal’ approach.

Object

Representation ID: 15140

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The current estimate of housing need may be insufficient and will require an upward adjustment. The local housing need figure for Solihull is likely to increase from 807 dwellings to 1,011 dwellings under the emerging methodology published in August 2020.Greater measures should be taken to address the scale of affordable housing need, including setting a requirement in excess of the baseline need figure.

Object

Representation ID: 15141

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Disagree with the selection of a single proposed housing allocation in Meriden. The Council has failed to recognise the characteristics of the population and households in Meriden. A higher housing requirement between 187 to 352 new dwellings would support Meriden’s continued role and function as a local service centre.

Object

Representation ID: 15142

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The contribution to the unmet housing needs from the wider HMA should be specifically set out in policy so the Council can be held accountable.

Very little weight should be attributed to the GBBCHMA Housing Position Statement in relation to Birmingham’s housing shortfall until the figures have been properly tested. Reliance should be placed on the current formal position- a base shortfall of 37,900 dwellings.

Object

Representation ID: 15143

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

A stepped trajectory would deliver housing at a lower rate for several years from the date of adoption. Greater consideration should be given to finding more small and medium size sites which would deliver early thus negating the need for a stepped trajectory.

Object

Representation ID: 15144

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Council has not built any measure of flexibility in the overall supply. There is no contingency against under-delivery from delays or slower rates of delivery than anticipated.

There are concerns on the reliance of windfall sites. It is not clear whether there is any site size limit and there is a clear risk of double counting against other components in the supply.

Additional contingency measures should be applied in order to cater for currently unforeseen and unknown circumstances.

Object

Representation ID: 15145

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Council’s own evidence suggests that ‘Land off Main Road, Meriden’ (RP26 in the Green Belt Assessment report) performs less against the Green Belt purposes than the proposed allocation at Meriden (ME1). The preferred direction of growth at Meriden should be south of the settlement, rather than northwards.

Object

Representation ID: 15146

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Site Assessment Report notes that ‘Land off Main Road, Meriden’ (site 522) is within a Minerals Safeguarding Area and has a Public Right of Way running through it- neither should prevent consideration for allocation.

The Site Assessment Report gives a negative sustainability score for the Site, with 15 negative effects and only 1 positive effect. This is inconsistent with the finding of the latest Sustainability Appraisal and needs to be amended.

The basis for excluding the site is flawed and not justified.

Object

Representation ID: 15147

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

‘Land off Main Road, Meriden’ falls within a sub-area which covers an extensive area of the Borough in the Landscape Character Assessment. The site should be considered at the margins of the sub-area. The overall findings do not adequately reflect the potential effects on the wider landscape.