Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14769

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year, and has therefore not been informed by the SA in accordance with the Framework.
Very little difference between Options 2 and 3 and the SA conclusions are inconsistent.
The SA demonstrates that a higher level of housing growth than 15,000 dwellings can be
accommodated sustainably.
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options.
The SA does not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement.

Object

Representation ID: 14770

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Ambiguity and confusion within the Options and which Option a site may fall within. For instance, a limited expansion of a rural village/settlement (F) could well be near a high frequency public transport corridor and hub (A).
Paragraph 65 adds confusion by introducing three further criteria which inform the location of growth but don’t relate in any way to Options A to G. It is unclear which takes precedence (A to G or Paragraph 65).
No definition of urban edge/ highly or less accessible settlements.
The absence of a clear Spatial Strategy and settlement hierarchy makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.

Object

Representation ID: 14771

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No reference or consideration given to safeguarding land within the Green Belt. It is considered necessary for the Plan to safeguard land in order to meet longer-term development needs and ensure there is a degree of permanence to the boundaries proposed within this Plan. Exceptional circumstances do exist.

Object

Representation ID: 14772

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 419 of the Plan makes reference to the Solihull Strategic Green Belt Assessment, and that its findings have been used to help justify the removal of land from the Green Belt. That statement is inconsistent with the Assessment itself which states on page 2 that it does not make recommendations for amendments to the boundary but that it forms the basis for more detailed assessment. There is no evidence of any more detailed assessment.
Disagree with the results of the Green Belt assessment for RP32. It should be a lower performing parcel.

Object

Representation ID: 14773

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The housing requirement and the Plan should be extended to 2037 based on likely adoption date.
Housing to reflect employment growth at UKC Hub not considered. Assumption that jobs filled by in-commuters is not sustainable. Housing requirement should be increased to account for employment uplift.
Housing requirement should be increased to take account of affordability issues.
Unmet housing needs of HMA not fully addressed. No agreement with other authorities on the approach and no evidence to support the figure proposed.
Unacceptable to propose an early review before a plan is submitted. In any event, additional Green Belt release will be required at this stage so land must be safeguarded.
Housing requirement should be expressed as a minimum.
Objections to how supply has been calculated. No evidence to support timely delivery of residential development at UKC, question deliverability of town centre allocation, issues with windfall assumptions, calculation errors in existing sites, no allocation of small sites.
The Plan will not provide for a five year housing land supply upon adoption. For all sites, there needs to be clear evidence that housing completions will begin within 5 years.

Object

Representation ID: 14776

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 407 (Land at Widney Manor Road) -The negative effects identified in the SA can be mitigated for example ecology, amenity and distance to local services. There are no significant adverse effects that would mean the site should not be allocated.
The site clearly falls within the first tier of the Spatial Strategy (Option A), not Option G as in the Site Assessment. The site selection has not fairly considered the site and includes no sound reasons for not allocating it.
The Green Belt parcel within which the site is located is wide and does not reflect the site.
The site is suitable for nine dwellings as shown on the illustrative masterplan appended. It is:
a. is developable, available and achievable;
b. is low performing in Green Belt terms when correctly assessed
c. has a low impact in landscape terms due to its enclosed nature;
d. is sustainable being within walking distance of Widney Manor Rail Station and Solihull Town Centres.
As a site of 1ha, it would make a contribution to addressing the failure of the Plan to identify sufficient small sites.