Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15099

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support principle of allocation, but a number of changes required to make Policy BL2 sound:
Part 5
In principle, it would be agreeable to Taylor Wimpey if the Concept Masterplans formed the starting point for future planning applications for the site. However, as set out in the representations submitted in relation paragraphs 242/243 and the Concept Masterplan for this site, a number of amendments would be required to ensure it has been prepared in accordance with national policy (e.g. establishing the Green Belt boundary) and the evidence prepared on behalf of SMBC and Taylor Wimpey’s appointed consultants (note concerns relating to the SMBC heritage and ecology evidence base).
This representation should be read in conjunction with those submitted by Taylor Wimpey in relation to the Proposals Map and the Concept Masterplans.

Object

Representation ID: 15100

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Positive that Council seeks to meet housing needs in full and contribute to wider HMA shortfall.
However, following elements of policy are unsound and would need amendment:
Part 1
• A buffer of 5-10% should be incorporated in order to meet the housing requirement and Greater Birmingham and Black Country Housing Market Area (GBBCHMA) contribution and not 5-year housing land supply. This is to ensure there is flexibility to respond to failures to deliver the required dwellings in the allotted time frames and across the whole plan period.
• To this end, the Council would therefore need to identify additional suitable land supply, in the order of c.750-1,500 dwellings.

Object

Representation ID: 15101

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Positive that Council seeks to meet housing needs in full and contribute to wider HMA shortfall.
However, following elements of policy are unsound and would need amendment:
P5(1) and (3) Windfall Sites (and para 223)
• An assumed supply of 200 dpa is made for windfall sites, up from 150 dpa within the adopted Solihull Local Plan (2013).
• The Plan purports that ‘there is compelling evidence that windfall sites consistently become available in Solihull’ (para 223), but although the 5YHLS (July 2019) sets out the number of annual completions from windfall sites, these are not set out on a site-by-site basis and therefore it cannot be concluded on the evidence available these provide a reliable source of supply, as required by NPPF paragraph 70.
• Additionally, although the 5 year annualised average appears sufficient, the level of fluctuation (2015/16: 190; 2016/17: 200; 2017/18: 158) suggest supply may not be sufficient enough to justify a proposed 200 dpa assumption.
• At 150 dpa, a resultant capacity of 2,100 dwellings from 2022-2036 would warrant the Council to identify to facilitate the delivery of a further 700 dwellings.

Object

Representation ID: 15102

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Positive that Council seeks to meet housing needs in full and contribute to wider HMA shortfall.
However, following elements of policy are unsound and would need amendment:
Part 2
• The trajectory fails to set out the anticipated rate of development for specific sites, against the requirements of NPPF paragraph 73.

Object

Representation ID: 15103

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey accepts Policy P4E, in principle, and its focus on ensuring new developments provide a mix of dwelling size and type to meet the identified needs of older people and those with disabilities and special needs.
However, with regard to Parts 4 and 5 of this policy there is an inconsistency in how the Council will seek to enforce the policy. Part 5 suggests that this will be applied flexibility and, on a site-by-site basis. This position is supported by Taylor Wimpey. In contrast, Part 4 states that ‘all developments of 300 dwellings or more must provide specialist or care bedspaces…’ (Lichfields emphasis). This is not supported by Taylor Wimpey as the provision of this type of accommodation and/or facilities should be directed to those areas where there is an identified need.
The need for and location of the provision of such accommodation should be considered having regard to a range of factors - such as need at that time, market demand, location of similar facilities, location of the site etc.- and this is not necessary on all large, strategic sites.

Object

Representation ID: 15104

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey accepts Policy P4E, in principle, and its focus on ensuring new developments provide a mix of dwelling size and type to meet the identified needs of older people and those with disabilities and special needs.
However, with regard to Parts 4 and 5 of this policy there is an inconsistency in how the Council will seek to enforce the policy. Part 5 suggests that this will be applied flexibility and, on a site-by-site basis. This position is supported by Taylor Wimpey. In contrast, Part 4 states that ‘all developments of 300 dwellings or more must provide specialist or care bedspaces…’ (Lichfields emphasis). This is not supported by Taylor Wimpey as the provision of this type of accommodation and/or facilities should be directed to those areas where there is an identified need.
The need for and location of the provision of such accommodation should be considered having regard to a range of factors - such as need at that time, market demand, location of similar facilities, location of the site etc.- and this is not necessary on all large, strategic sites.

Object

Representation ID: 15105

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support principle of Policy P4D and the broad approach to encourage self & custom build (SCB) plots.
- Not supportive of the specific policy requirement for the inclusion of 5% self & custom build housing on all site allocations and residential developments of 100 or more dwellings.
- Council should not seek to burden developers with delivery of SCB plots.
- Council should encourage landowners as per national policy.
- Provision of SCB plots must be based on uptodate evidence of demand, as per national policy and guidance.
- Policy approach should be flexible, and realistic, so that where provided they do not remain unsold.
- No rational for 100 dwelling or 5% thresholds.
- Risk of over-supply on large sites and mis-match with actual demand, e.g. single plots in rural locations.
- Larger sites typically more complex to deliver, more logistics and longer time periods. Coordination of SCB plots with wider site will be difficult.
- If evidence to include such a policy is justified, then recommend amendment, that if plots unsold for 12 months then should be built out as market housing.
- Further work required rather than blanket approach.

Object

Representation ID: 15106

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

support the overall thrust of Policy 4C which recognises that the Council will negotiate the housing mix on allocated sites. This is a proactive approach that enables the plan to be flexible and adapt to rapid change, as required by paragraph 11 (a), and ultimately effective in meeting the Borough’s housing needs.
However, Part 2 of the policy appears to conflict with this positive approach in that it states that “concept masterplans will include details of the likely profile of housing types requiring market housing”. This approach is considered unnecessary and would be too prescriptive for large, complex sites that will be built over a long period of time. It would also be in inconsistent with paragraph 11 (a) as noted above in that it would not allow for sufficient flexibility to adapt and continue to meet the needs of the Borough over the time period the scheme is delivered.
It is not appropriate to apply a borough wide mix to each and every site. Development sites will have different locational and site characteristics which will influence the appropriate mix.

Object

Representation ID: 15107

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

support the overall thrust of Policy 4C which recognises that the Council will negotiate the housing mix on allocated sites. This is a proactive approach that enables the plan to be flexible and adapt to rapid change, as required by paragraph 11 (a), and ultimately effective in meeting the Borough’s housing needs.
However, Part 2 and Part 3 of the policy appears to conflict with this positive approach in that it states that “concept masterplans will include details of the likely profile of housing types requiring market housing”.
This approach is considered unnecessary and would be too prescriptive for large, complex sites that will be built over a long period of time. It would also be in inconsistent with paragraph 11 (a) as noted above in that it would not allow for sufficient flexibility to adapt and continue to meet the needs of the Borough over the time period the scheme is delivered.
It is not appropriate to apply a borough wide mix to each and every site. Development sites will have different locational and site characteristics which will influence the appropriate mix.

Object

Representation ID: 15108

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strongly support delivery of affordable housing as part of residential developments. However, a number of concerns over the detail (or lack of) contained
within Policy P4A which are considered unsound as drafted.
Part 2
This part of the policy states that the definition of ‘affordable’ will be set out in a Meeting Housing Needs Supplementary Planning Document (SPD), which will be
updated periodically to ensure it is up to date. While in principle this is accepted, due to the significant viability implications affordable housing can have on a
development, the SPD should be made available now or the contents of the document included in the Local Plan and available for review/comment. It is not a
sound approach to not publish a fundamental part of the evidence base prior to the submission and adoption of the Local Plan.