Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15109

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 3
To be Sound, the level of affordable housing proposed needs to be justified by the evidence and currently the Local Plan does not appear to tie in with the more
recent Viability Study. At the current time, there are concerns with some of the details in the Viability Study (the ‘evidence’) that need to be addressed to make
the evidence base robust and the Policy Sound. These are summarised below and explain in more detail in the Bruton Knowles ‘Response the Cushman Wakefield
Study’ attached to these representations:
1. Typologies to include the entire range of potential sites from the largest to the smallest, so that parameters can be tested.
2. Housing mix to reflect need and demand.
3. Consistency regarding Benchmark Land Value.
4. Infrastructure costs to be revised to 2020.
5. Consistency regarding construction costs.
6. Contractors profit to be reinstated for base build costs.
7. Transparency regarding cashflow modelling, enhancements, etc.
8. Consistency with retirement care homes.
9. Sensitivity testing to be undertaken.

Object

Representation ID: 15110

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 6/7/8
These parts of the policy define the amount and type of affordable housing to be delivered.
However, these policies make specific reference to certain types of affordable housing which is not consistent with Part 1 which lists the various types
of affordable housing such as “social rented, affordable rented, intermediate tenure and Starter Homes, which is available at below market price or rent and which is affordable to households whose needs are not met by the market.”
These parts of the policy should be amended to refer to: affordable housing for rent (to include either social and affordable rent) and intermediate housing. The inclusion of Starter Homes is questionable.
With regards to the housing mixes specified for both affordable products, it is considered unnecessary to define these in a policy and certainly not applied to
each and every site that comes forward. The mixes proposed are appropriate for the whole Borough and each site with have different characteristics that may make them more suitable for a certain mix than others (ie central urban sites would be more suitable for 1 and 2 bed homes, whereas greenfield urban sites would be more suitable for larger family homes. The mixes would not be the same for each location, but the blended mix would achieve the needs of the Borough as a whole). Overall, mix should be linked to SMBC latest Strategic Housing Market Assessment (SHMA)/Housing and Economic Development Needs Assessment (HEDNA) (or other future relevant evidence base document) but not applicable in the same mix for each site location. This will ensure this policy aligns with the latest evidence base and remains effective and deliverable over the
lifetime of the Local Plan.

Object

Representation ID: 15111

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans - General comment:
Fair and reasonable that concept masterplans provided to give Council confidence on capacity and delivery of sites.
Status of CMPs in Plan, and weight to be accorded to them, is uncertain.
Text in Concept Masterplans introduction 'indicative broad level masterplans' vary with text in DSP Para. 404. 'Council will require developers to generally accord with principles in CMP.'
Imperative that weight of CMP is clear at development management stage to make Plan sound.

Object

Representation ID: 15112

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para. 242
Concept Masterplans - Site BL2
Taylor Wimpey have a number of concerns about the content of the Concept Masterplan for Site BL2 and need to be clear that either the Concept Masterplan will be modified before the Local Plan is adopted or that there would be the opportunity to present an application that does not respond fully to the Concept Masterplan. The reasons are set out below.
It is considered that the concept masterplan for site BL2 has not been prepared to take into account all available proportionate evidence, or in some instances, the evidence base is not well founded. The comments on the following bullets listed in paragraph 242 are provided below:

Object

Representation ID: 15113

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para. 242. Concept Masterplans - Site BL2
• Bullet 2: key site constraints have been identified:
Flood Risk - Understood that SMBC have defined parcels based on avoiding flood risk following Level 2 SFRA modelling. Modelling was not intended for purpose of defining development parcels. CMP should follow Randall Thorp MP (from site promoters) which includes allocation of space for flood alleviation.

Object

Representation ID: 15114

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans. Para. 242
Bullet Point 2 (in relation to BL2)
Heritage - while the policy for the site allocation (BL2) and the wording of the Concept Masterplan design principles allows for development to come forward on land around the listed building (providing the appropriate design related measures are adopted to safeguard the setting of the heritage asset), the Concept Masterplan identifies an extensive area around Light Hall as ‘public open space and play’. This designation is inconsistent with the draft site allocation policy and, should be removed from this designation and identified for development.

Development parcels based on recommendations from Heritage Impact Assessment, particularly regarding Light Hall, were overly stringent and not based on a sound understanding of how, in what way(s) and to what extent the setting of the designated heritage asset contributes to its significance.

EDP have carried out independent heritage assessment for site. No reason to believe that development around the listed building could not be delivered in accordance with the Council’s statutory duty and in accordance with the relevant provisions of the NPPF so long as it responds positively and appropriately to the masterplan design principles set out above in this Appraisal (see attachment for further detail).

Object

Representation ID: 15115

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans. Para. 242
Bullet Point 2 (in relation to BL2)
Ecology:
Having reviewed SMBC’s ecological evidence base, EDP have a number of concerns with the methodology used and conclusions made. These assumptions have been fed into the site analysis and design principles of the concept masterplan, raising a concern that undue weight has been applied to the retention of existing on-site features.
For example, EDP have concluded that the ecological evidence base lacks sufficient data to provide any informed recommendations regarding the retention of habitat and maintenance/enhancement of ecological connectivity. Additional information regarding the methodologies adopted during any assessment of the Site should be provided, particularly before any weight is given to it within the local plan process.

Object

Representation ID: 15116

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans. Para. 242
Bullet Point 3 (in relation to BL2)
Bullet 3: different land uses/proposals have been identified
The indicative capacity of the site at 1,000 dwellings is supported and it similar to that proposed by Taylor Wimpey through the previous Local Plan consultations and is considered to be deliverable.
A concerns is, however, raised regarding the Concept Masterplan itself and the location and quantum of open space shown.
Open space
It is noted in Policy BL2 that 8.2 hectares of public open space will be required to be delivered on site, however, the area of land shown significantly exceeds this amount and extends south far more extensively than the site ownership of Taylor Wimpey. As noted previously, it also includes the land to the west of Light Hall which while is currently not identified for development, could in future (see comments above).
Unless SMBC have a firm commitment from other landowners that the proposed public open space outside of Taylor Wimpey’s ownership can be delivered, the Concept Masterplan should be amended accordingly.

Object

Representation ID: 15117

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans. Para. 242
Bullet Point 4 (in relation to BL2)
Bullet 4: key access and movement routes through and to the site
The SMBC Concept Masterplan for Site BL2 identified access from three proposed locations; from Dog Kennel Lane, from the A34 Stratford Road/Dog Kennel Lane roundabout and an access direct from the A34 (south of the Dog Kennel Lane junction). These are shown as indicative arrows, however, it is unclear if these are the accesses for any mode, or whether they are intended to represent purely accesses which vehicles can use, with other mode accesses not shown.
It is considered that there is a much greater opportunity to connect to the existing and new communities than shown on the SMBC masterplan. Particularly in the context of the first sentence in the Introduction to the Local Plan, Challenges A, C, H, J and H, Policies P7 and P8, where there is a requirement for masterplans to lead with active travel accesses, for which there are numerous opportunities.
There is also a green buffer shown on the SMBC masterplan through the centre of the site and it is not clear from the plan if this would hinder a vehicular or active travel connection between the development parcels on either side of the green buffer.

Object

Representation ID: 15118

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans. Para. 242
Bullet Point 7 (in relation to BL2)
establishing a clear and logical boundary to identify precisely the land to be released from the Green Belt.
The proposed Green Belt boundary does not follow existing features on the ground and should be modified according to accord with NPPF guidance; this is covered in the reps on the Policies Map.