Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14760

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The evidence demonstrates that site 207 has limited constraints and is in a very accessible and sustainable location. The allocation of the site could provide additional market and affordable housing to meet Solihull and the Greater Birmingham Housing Market Area’s housing needs (see response to Policy P5) as well as providing land for a community use or other community facility and public open space. It is consider that the benefits of allocating this site within the Local Plan Review far outweigh any potential concerns SMBC have relating to the narrowing of the gap between Bentley Heath and Solihull. We therefore consider that this land should be released from the Green Belt and allocated within the Local Plan Review.

Object

Representation ID: 14761

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Does not provide developers with enough flexibility to consider the mix of housing at the planning application stage. The HEDNA sets out a range of mixes for each dwelling size. We support the Council providing some guidance on housing mix but this should accord with the mix proposed in the HEDNA.
The HEDNA has identified that there is a need for affordable rent within the Borough but there is no provision in the policy. Request the is amended to refer to both affordable rent and social rent.

Object

Representation ID: 14762

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Point 3 sets out specific requirements for housing mix. This is not effective as it does not provide developers with flexibility. Housing mix should be considered at application stage in accordance with the HEDNA 2020.
The housing mix proposed in the HEDNA provides a range for each dwelling type which reflects the ‘latest’ evidence in 2020. However, market demand changes so this ‘latest’ evidence may not be representative of need when planning applications are submitted in the future. As developers and national housebuilders have vested interests in building products that are deliverable and meet market needs, Solihull should not have a fixed size and type guidance, as this could affect development viability, lead to inflexibility and result in obstructing development.

Object

Representation ID: 14763

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence to justify the percentage requirement for self and custom build. No requirement in the PPG for such plots to be provided as part of allocations.
Whilst the Self Build register may provide an indication of the level of interest, this needs to be analysed further to uncover the specific requirements of respondents.
The register does not test whether people have the means to acquire the land and privately construct their own property. Without this exercise having been undertaken and supporting the Council’s conclusions, the Policy is not justified.
Practical issues of having multiple individual sites within one development need to be considered.

Object

Representation ID: 14764

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Exceeding minimum building regulation standards is optional and should be justified by evidence.
Requiring all new dwellings to be built to the Category M4(2) standards, will result in larger dwellings and in turn less dwellings being delivered on sites, and inefficient use of land on the Green Belt sites proposed
In terms of flexible application of the policy, none of the criteria in point 5 make reference to the suitability of a site to accommodate accessible dwellings, for example their topography or local demographic.
No justification why 300+ dwellings is threshold for care bedspace provision. No consideration of whether sites may be suitable for such provision or whether providers will be interested.

Object

Representation ID: 14765

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

18% of the proposed housing requirement for the Borough is at the UKC Hub. The majority of dwellings delivered will be apartments. No evidence that the amount of apartments proposed at UK Central Hub is needed, especially when there is an existing family demographic.
The UKC Hub will be unlikely to deliver 2,740 dwellings up to 2036 which could leave a shortfall of circa 700 – 1,000 dwellings . Evidence documents also show different housing figures for the sites.
The revised Standard Methodology could increase the Council’s minimum housing need by 25%. The range of housing growth options that may be derived from changes to the standard method and wider HMA growth requirements should be tested and planned for.
The proposed contribution towards the HMA shortfall is not a sufficient or justified contribution in light of the identified shortfall post-2031 which should be addressed in the Local Plan Review. Additional sites will be required.
Over-reliance on windfall. Council should identify additional sites and allocate and/or safeguarded for residential development.
Contrary to NPPF, point 6 makes no reference to local market conditions and viability when identifying appropriate density and mix for each site.

Object

Representation ID: 14766

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Additional requirements on development sites in order to reduce energy demand and minimise carbon dioxide emissions are over and above the requirements of PPG. The PPG states that Local Plans can set higher standards “but only up to the equivalent of Level 4 of the Code for Sustainable Homes”.
In considering viability, Solihull has not sufficiently justified why a 30% uplift is proposed.
The capital cost and land take to achieve the requirement for at least 15% of energy from renewables, should be considered. There is no evidence of this.
With regard to viability, £6000 per dwelling just to meet energy requirements without any other requirements being taken into account is considered significant.

Object

Representation ID: 14767

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council should identify areas of land that could be released from the Green Belt in this Local Plan Review and safeguarded for future development should the Council not be able to meet their housing needs or the housing needs of the HMA during the next plan period.
A significant HMA housing shortfall is expected from 2031 so it is likely that Solihull will need to contribute additional dwellings to assist in addressing this.
When identifying potential sites to release from the Green Belt and safeguard,
sites in lower performing Green Belt parcels, which are adjacent to sustainable settlements, accessible and considered suitable, achievable and deliverable in the Council’s SHELAA should be chosen, such as Site 207.

Object

Representation ID: 14768

Received: 09/12/2020

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council should set out Green Belt compensation projects which can be paid for through CIL. Communities could then identify projects that compensation could fund.
Where compensation cannot be provided on site or would result a reduced net developable area, there should be an effective strategy to enable off site contributions to be made in other locations e.g. through the identification of donor sites.
No indication of how the level of compensation will be determined. A formula or calculation should be provided to allow developers to plan for this requirement on top of the other contributions sought.