Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15017

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Alternative Site to be considered, CFS 193:
Performs well in accordance with Council's evidence base:
SHELAA - Site performs well except for achievability. Can confirm that site owned by national Housebuilder, Kier Living, who have delivered housing immediately to west. Site achievable and available at earliest opportunity.
SA - Site identified as Ref. 341 for SA. Scores well against SA objectives, achieves 8 positives (2 of which are significant), 10 neutrals and 1 negative.
Green Belt Assessment - Concludes site only contributes to one of GB purposes, therefore has negligible contribution to GB.
Site Assessment Document - Only negative raised is site’s development would narrow the gap between Marston Green and Chelmsley Wood, contrary to conclusions in GBA. No robust reasoning for site to be excluded from Step 2 in site selection process.
Following sites have much greater constraints and deliverability concerns that CFS 193: BL2, BC1, BC3, BC4, KN2, SO1.

Object

Representation ID: 15018

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- Performs moderately in Green Belt terms, scoring highly in relation to purpose 2 ‘to prevent neighbouring towns merging into one another’.
- Does not have a clear contiguous defensible Green Belt boundary to the south (paragraph 609).
- SA concludes that there are several constraints for this allocation including:
i. > 20ha of best and most versatile agricultural land;
ii. up to 50% of the site lies within flood zones 2 or 3,
iii. within an area of high landscape sensitivity to change;
iv. a heritage asset on site; and
v. sources of noise adjacent to the site that could affect the amenity of future occupiers.
As site is heavily constrained, in particular by Flood Zones 2&3, and due to site's landscape sensitivity, doubtful whether it can deliver its full capacity at an appropriate density.
SHELAA indicates that there are numerous land ownerships of this site, which is likely to delay
delivery.

Object

Representation ID: 15019

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- Performs moderately in the Green Belt, with the eastern part falling within a highly performing area of
the Green Belt Assessment.
- GB severance: DSP states that as this parcel will be cut off from the main part of the land by the line of HS2, thus will reduce the sites contribution to Green Belt purposes.
- SA concludes that there are several constraints for this allocation including:
i. > 20ha of best and most versatile agricultural land;
ii. up to 50% of the site lies within flood zones 2 or 3
iii. within an area of medium landscape sensitivity to change;
iv. a heritage asset on site
v. within a mineral safeguarding area;
vi. sources of noise adjacent to the site that could affect the amenity of future occupiers; and
vii. separated from key economic assets.
Doubtful whether it can deliver its full capacity; unclear impact of Flood Zones on site’s ability to come forward. Unclear extent of impact of heritage sites on deliverability. Doubt over ability to deliver 875 homes within plan period.

Object

Representation ID: 15020

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- Located in lower performing parcel in the Green Belt and a mineral safeguarding area.
- Whilst this site is located within Balsall Common, a settlement identified for significant growth, it is preferable for development to be on land that is more highly accessible.
- Site Assessment document concludes that this site has a low level of accessibility.
SA - 4 positive effects and 6 negative with the most significant negative effect being the distance to key
economic assets.
Developability:
Council’s own evidence base identifies that there are a number of constraints, including ecology and heritage, to overcome, which raises significant doubts regarding the suitability of this site for housing.

Object

Representation ID: 15021

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- Western part of the site is located within a lower performing parcel of the Green Belt and the eastern part is within a higher performing area.
- SA identifies 3 positive and 6 negative effects with a significant effect being the distance to key
economic assets and convenience store or supermarket. - Negative effects include the site having
a low level of accessibility, in an area of medium visual sensitivity with low capacity for change.
- Site Assessment document state site has low accessibility and does not provide a strong defensible GB boundary.
As such, we have strong reservations regarding site's suitability.

Object

Representation ID: 15022

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- SA states that there are several constraints for this allocation including:
i. local wildlife site;
ii. protected trees and other valued landscape features;
iii. > 20ha of best and most versatile agricultural land,
iv. impact on the townscape and local distinctiveness due to the site being unscreened and visually
prominent.
Developability compromised by numerous constraints on site, inc. LWS and trees, infrastructure delivery and complex ownership.
Site expected to deliver new through school.
SHELAA identify 9 different landowners.
Unrealistic that site will deliver 400 homes in first 5 years of new local plan period as indicated in SHELAA.

Object

Representation ID: 15023

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Site has several constraints that will compromise deliverability and capacity as set out in DSP:
- Site Assessment document concludes
that development on this site would result in an indefensible GB boundary to the east.
- SA states that there are several constraints including:
i. loss of more than 20 ha of agricultural land;
ii. proximity to a listed building;
iii. within a medium landscape sensitivity area with low capacity for change;
iv. overlaps a local wildlife site.
Developability of site constrained by heritage assets and local wildlife site and multiple site owners.
Consider unrealistic that site can 400 homes in first five years of new local plan period is indicated in SHELAA.

Object

Representation ID: 15024

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Council’s own evidence base raises significant issues with a number of the sites that
are allocated in the Emerging Plan, and their development would therefore conflict with the
Framework. As such, the site selection process is not based on proportionate evidence and the
Emerging Plan is consequently not justified as it fails to propose an appropriate strategy.
Sites include: BL2, BC1, BC3, BC4, KN2, SO1.

Object

Representation ID: 15025

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing Supply:
Do not expect that all sites can deliver number of houses set out in Plan.
Significant proportion of housing supply from small number of large sites – notwithstanding site-specific developability issues, inherent deliverability concerns with infrastructure, or complex site ownership etc.
Supply vulnerable is only one of sites failed or is delayed.
To address this Plan should allocate wider range of sites, inc. CFS 193.

Object

Representation ID: 15026

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing Supply - lack of buffer
The total buffer (taking into account the 10% lapse rate) above the minimum housing requirement is only 1.9%, providing insufficient flexibility, should sites not reach full capacity, delayed/deleted, or windfall delivery rate falls.
Conflicts with NPPF Para. 11.
Insufficient buffer could result in DSP unable to meet its minimum housing requirement, contrary to NPPF Para. 35a and 59.
See recent examples:
- Rugby Local Plan (June 2019) include 17.5% buffer (which includes unmet needs);
- Nuneaton and Bedworth Local Plan (June 2019) include 5.5% buffer, which Inspector called 'very modest' but cautiously considered acceptable in report.