Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Policy P4A Meeting Housing Needs – Affordable Housing
Representation ID: 11036
Received: 13/12/2020
Respondent: Golden End Farms
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Support the general approach of securing 40% affordable housing but disagree with paragraph 6 which does not comply with national policy and is therefore unsound.
Paragraph 6 is not consistent with paragraphs 1 and 2 of the policy or paragraph 177. It does not reflect national guidance to ensure that the provision that is secured caters for all tenure needs to enable mixed and balanced communities to be created. It is inflexible as it refers only to social rent and shared ownership, not other tenures that may be supported by the Council.
Policy P4A paragraph 6 should be amended to make clear that the suggested split of affordable tenures will relate only to the element of affordable housing that is not provided as discounted market products. This will ensure the policy is flexible enough to respond to emerging Government Policy and accommodate discounted market products such as the emerging policy on First Homes. An additional paragraph in the policy also needs to be included to set out the appropriate mix of unit sizes within this category.
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Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 11038
Received: 13/12/2020
Respondent: Golden End Farms
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Provision of housing land significantly underprovides for the housing needs arising from the growth strategy. HS2 and UKC will have a profound effect on the Borough but the Plan fails to accommodate the housing need that will arise from it. Whilst historically there may have been significant in-commuting, this likely results from previously constrained housing supply. The Council should seek to reverse historic commuting patterns and provide housing to meet more of the forecasted jobs growth.
Also questions whether the plan does enough to help meet the wider housing shortfall in the housing market area, particularly beyond 2031.
The housing requirement should be increased to ensure the plan meets the housing needs arising from the HS2/UKC proposals and as well as providing a greater contribution to meet HMA housing shortfalls. We estimate that the Local Plan needs to make provision for the delivery of at least 17,500 dwellings over the plan period, and probably nearer 20,000 dwellings to ensure the sustainable growth of the area and contribution to the wider HMA needs.
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Object
Solihull Local Plan (Draft Submission) 2020
Knowle, Dorridge & Bentley Heath
Representation ID: 11044
Received: 13/12/2020
Respondent: Golden End Farms
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The site selection process is unsound. Additional land releases should be included in the plan to support sustainable patterns of growth and meet needs. Golden End Farm is more suitable than proposed allocations in the settlement.
Both allocations in Knowle have complex issues. No confidence that these sites can deliver the housing and infrastructure proposed, or what stage in the plan period they would come forward. Viability of these sites is also questionable.
Golden End Farm should be included as an allocation. It is in a highly sustainable location and can provide an immediate contribution to housing delivery.
In circumstances where the Examination is provided with insufficient levels of comfort that either of sites KN1 or KN2 are deliverable and viable, the relevant allocation should be removed.
Whether or not KN1/KN2 are removed, a new policy KN3 and associated justification text should be inserted into the Knowle, Dorridge and Bentley Heath Settlement Chapter allocating land at Golden End, Knowle for some 250 dwellings. The justification can be taken from the commentary taken from the Council’s Site Assessment summary dated November 2020.
Example of the Policy text is provided in supporting information.
See attachments
Object
Solihull Local Plan (Draft Submission) 2020
Policy KN1 - Hampton Road, Knowle
Representation ID: 11045
Received: 13/12/2020
Respondent: Golden End Farms
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Securing the benefit of an improved football club may not be achievable and only housing north of Hampton Road would be delivered.
Uncertainty over whether a comprehensive development is achievable and concern over deliverability and viability.
Site faces many challenges including topography, site capacity (due to site constraint mitigation), timing of club relocation. The site is complex and housing will not be delivered until later in the plan period.
If no co-ordinated approach to delivery of the whole site can be demonstrated, including viability regarding relocation of the Football Club, the allocation is not sound and should be removed.
In circumstances where the site promoters cannot demonstrate during the examination a co-ordinated approach to delivery of the whole site, and a high degree of confidence that the relocation of the football club is viable, then the site allocation should be considered not sound and removed.
In circumstances where the above can be satisfied and the policy is retained, the wording of Policy KN1 and accompanying text should be amended to ensure the club relocation is delivered. In these circumstances Policy KN1 be amended as follows:
- Paragraph 1 should be amended as follows: “The site is allocated for 180 dwellings together with the re-provision of Knowle Football Club”.
- Paragraph 4(iii) should be amended as follows: “The preferred site for the relocation of the existing football club is between the new development and the canal as shown on the concept masterplan. No housing development on any part of the site shall be allowed to commence until such time as the final football club site has been selected, and a commitment and timescale for re-provision is secured.
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Object
Solihull Local Plan (Draft Submission) 2020
Policy KN2 : South of Knowle (Arden Triangle)
Representation ID: 11046
Received: 13/12/2020
Respondent: Golden End Farms
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Questionable whether a comprehensive development is achievable, deliverable or viable. The school is promoted as a key benefit but concern that this may not be realised and that only the housing off Warwick Road or Grove Road is ever delivered.
Site faces complex issues meaning that much of the housing will not be delivered until the later in the plan period.
If there is no co-ordinated approach to delivery of the whole site and a high degree of confidence that the future redevelopment of the existing school is viable, then the site allocation should be considered not sound and removed.
In circumstances where the Council and site promoters cannot demonstrate during the examination a comprehensive and co-ordinated approach to delivery of the whole site can be achieved and that it is viable in line with paragraph 709 of the Plan, then the site allocation should be considered not sound and removed.
In circumstances where the comprehensive treatment and viability of the site can be satisfied and the policy is retained, the wording of Policy KN2 and accompanying text should be amended to ensure the critical education infrastructure is delivered. In these circumstances the policy should be amended as follows:
- Policy KN2 Paragraph 3(i) should be replaced with the following: “Re-provision of the existing Arden Academy and provision of new primary school as an ‘all through school. The preferred site for the school is on land immediately south of the existing school as shown on the concept masterplan. No housing development on any part of the site shall be allowed to commence until such time as the final site has been selected, and a commitment and timescale for the school development is secured, in addition to the necessary financial contributions”.
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