Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14523

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land South of Park Lane

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Sustainability Appraisal has not fairly considered reasonable alternatives in respect of levels of
employment growth. Fails to appraise alternative levels or locations for employment growth. In fact, 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 NPPF.
Site 534 has not been assessed other than as part of a broad area

Object

Representation ID: 14525

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land South of Park Lane

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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. This makes it difficult to understand how the sites selected relate to the Strategy. No sites fall within Options A to D despite these being the 'starting position'. The Site Selection methodology departs from national policy by not first considering previously developed land and land well served by public transport, and not making reference to whether loss of Green Belt can be offset through compensatory improvements.
Site 534 south of Kenilworth Road/Park Lane,
Balsall Common is in part previously developed arising from its use by HS2, is well served by public transport given its proximity to Berkswell Rail Station, and offers compensatory improvements to environmental quality on the balance of land that cannot be developed. Site not assessed through Site Assessments despite only 2 constraints in SHELAA. There is a need for employment land and this area should be an option listed in paragraph 69

Object

Representation ID: 14526

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land South of Park Lane

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P17 makes no reference to safeguarding land within the Green Belt, indeed there is no reference to any consideration being given to safeguarding land. The Plan should safeguard land in order to meet longer-term development needs, as Solihull is significantly constrained by Green Belt and there are no neighbouring Councils who have expressed a willingness to take any unmet needs arising from Solihull.

Object

Representation ID: 14527

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land South of Park Lane

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, which should have been undertaken for
Site 534 (land south of Kenilworth Road and Park Lane, Balsall Common).

Object

Representation ID: 14531

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land South of Park Lane

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P3 fails to make sufficient provision of employment land to meet the needs of the area, including unmet needs of neighbouring areas, is overreliant on two large allocations whose delivery and land availability is uncertain, fails to match the spatial strategy of the Plan and has no regard to supply and demand in the HEDNA.
Policy is not consistent with national planning policy. It fails to provide a choice for businesses who wish to invest and expand, and fails to align with the locations for growth in housing leading to a less sustainable pattern of
development.
Plan fails to provide a strategic policy that sets out the overall scale of development for employment. The minimum employment land requirement should be 15,680 jobs. There are limited opportunities for businesses in Balsall Common, existing supply is lower than stated but no reference is made to the shortfall of land for employment.
There is no evidence within the Plan of any contribution being made to meet the needs of neighbouring areas, such as the Black Country Authorities. Dealing with unmet needs through a review is contrary to the NPPF. Land should be safeguarded for future development needs to ensure that Green Belt boundaries endure.
Existing supply of 6.4ha of employment land is wholly inadequate.
The proposed allocations are complex with significant infrastructure requirements (Site UK1), there is no Concept Masterplan (Site UK2) and no trajectory for delivery of either. Neither site has any relationship with Spatial Strategy or housing growth