Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15148

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’ (site 522)’ performs well against most of the Sustainability Appraisal Objectives, with no significant negative effects. The site should have not been scored ‘neutral’ against SA Objective 16, as the call for sites submission was made on behalf of the landowner clearly indicating it could come forward in the next five years.

Object

Representation ID: 15149

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 concluded that ‘Land off Main Road, Meriden’ (site 522) should not be included in the plan under Step 2 of the Site Selection Process. This does not represent a fair reflection of the attributes and characteristics of the Site and contradicts the Council’s own evidence. Defensible boundaries to the green belt can be achieved and be secured through policy criteria. The merits of the site in landscape terms has not been fairly judged.

Object

Representation ID: 15150

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 figure of 2,240 dwellings to be built at the NEC is not justified based on the evidence.

This level of growth will be dependent on the establishment of a new sub-housing market and on the delivery of HS2.

It is unclear whether it’s realistic to expect the provision of apartment accommodation proposed to deliver the amount of affordable housing required.

It is assumed that the delivery of 2,500 homes at NEC will cover the entire NEC masterplan period up to 2047. Therefore, the expected delivery over the plan period would indicate a total of up to 1,380 homes could be delivered by 2036 (a reduction of 860 dwellings) based on the assumed level of growth in the masterplan.

Object

Representation ID: 15151

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 approach to Policy P4A Criteria 11 in terms of the following sentence ‘The cost of the Council’s qualified valuer will be met by the applicant’. This could lead the decision-taker to conclude that viability of development is threatened, and that the policy requirement should not be sought based on that evidence. In such cases the costs should be shared fairly between the applicant and the Council.

Policy P4A Criteria 12 is contrary to national policy and practice guidance which clearly define supplementary planning documents as not forming part of the development plan but which provide detail in support of it.

Object

Representation ID: 15152

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P4C prescribes a specific mix of open market housing on all allocated and other major development sites. This is inflexible, not positively prepared, and therefore not soundly-based.

Object

Representation ID: 15153

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to Policy P4D criteria 2. This is overly restrictive and onerous as demand for plots is likely to reflect wider demand for housing and may change over time. The demand for specific plots should be established prior to installing the necessary infrastructure connections.

Object

Representation ID: 15154

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P7 is not consistent with national policy and is not soundly based. The Policy draws no distinction between urban and rural locations in devising the criterion for assessing proposals in terms of accessibility. This results potentially in the unfair treatment of proposals brought to meet the needs of the rural area.

Object

Representation ID: 15155

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is no reasoned justification for Policy P9 Criteria 3i and 3ii. It does not recognise that not all proposals will be able to achieve these new standards without undermining their viability.

Object

Representation ID: 15156

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P17 Criteria 1 seeks to apply a blanket protection to all areas of the countryside regardless of their ‘intrinsic’ character or ‘value’. Any protections must be in response to an identified value or something intrinsically important to that location.

The Council seeks the protection of best and most versatile agricultural land without identifying those areas it considers worthy of safeguarding. National policy does not seek to prevent development on the best and most versatile agricultural land, but states that policies should recognise its economic and other benefits.

Object

Representation ID: 15220

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.