Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14207

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Plan fails to set out the current or future need for specialist housing for older people, for either care beds or extra care units required. Whilst Policy P4E requires sites of over 300 units to provide specialist housing or care bed spaces in accordance with the Council’s most up to date statement of need on older persons accommodation, there is no mechanism for delivery. Needs Report (January 2020) concludes there is a compelling need for both care bed spaces and extra units now, which will increase substantially over the next 10 years. Plan should be much more supportive of specialist housing

Object

Representation ID: 14208

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A Housing Need Report (Barton Willmore) identifies a major housing shortfall over the Plan period. Between 1,036 and 1,248 dpa are required to support UK Central. The deficit from the HMA is a minimum of 11,294 and 13,101 dwellings to 2031, a significant increase from 2,597 dwellings in the 2020 position statement.
29 units identified in the Brownfield Land Register should be discounted as there is no mechanism to deliver the numbers in the Green Belt.
Analysis of windfall supply in the Five Year Housing Land Supply Review (Lichfields, Nov 2020) concludes there is no evidence both large site windfalls and garden land will come forward.

Object

Representation ID: 14210

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence is provided to show that the complex land assembly issues associated with Site BC1 have been addressed, so doubtful that numbers can be delivered in the Plan period. No certainty over timing of HS2 or Relief Road. No evidence that the Relief Road can be delivered by the quantum of development proposed. Without HS2/Relief Road the site would have an indefensible Green Belt boundary, especially as part of site is within highly performing Green Belt in the Green Belt Assessment. Unclear whether eastern boundary is HS2 or the West Coast mainline

Object

Representation ID: 14212

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence that complex land assembly issues associated with Site BC4 have been addressed. Allocation not justified by Site Assessment that draws attention to part being higher performing Green Belt, in the Green Belt Assessment, low accessibility, should be subject to clear firm Green Belt boundaries.
Uncertainty over building of this section of Relief Road casts doubt over provision of firm eastern boundary. Plan and concept masterplan inconsistent over Green Belt boundary and line of Relief Road. Site cannot be considered available, achievable and deliverable

Object

Representation ID: 14213

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence that complex land assembly issues addressed for Site BC5, and firm defensible Green Belt boundaries will only be created if the site is considered in a comprehensive manner.
The site is identified as having high visual sensitivity in the Landscape Character Assessment and it is clearly evident that the land extends significantly out into open
countryside, impacting considerably on the openness of the Green Belt at this point and contrary to the purpose to assist in safeguarding the countryside from
encroachment.

Object

Representation ID: 14238

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site BC6 is unsuitable as an allocation, as it contradicts the assessment criteria. Site is completely divorced from the settlement with no link or appropriate setting, is within the highest performing Green Belt in the Green Belt Assessment, whilst the Landscape Character Assessment identifies that the site has medium visual sensitivity. A narrow belt between 2 highly used railway lines is unsuitable due to noise, vibration and visual sensitivity. Site breaches firm and defensible Green Belt boundary as applied to other sites in the settlement.

Object

Representation ID: 14239

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 19 Riddings Hill, Hall Meadow Road was allocated in the adopted Local Plan 2013. There has been no movement on bringing the site forward for development which raises doubts over its future delivery within the Plan period. It has not been demonstrated that this site is available, achievable and deliverable. Its continued inclusion as an allocation in the Plan is unsound.

Object

Representation ID: 14240

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Omission Site 338 should be allocated for 100-130 dwellings. This site is supported by technical reports and being in one ownership without major infrastructure requirements, there would be no uncertainty about its delivery unlike the allocated sites. Sites that are better performing than Site 338 in the Green Belt Assessment have been allocated. Although higher performing, recent development in this part of the Green Belt parcel means it is likely to perform more moderately. Site is accessible, is surrounded on three sides by development with a defensible Green Belt boundary to the south that is more substantial than that for Site BC3 and does not extend further into the countryside than the existing settlement. There are no landscape, heritage or ecology issues.

Object

Representation ID: 14241

Received: 14/12/2020

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Omission Site 338 should be allocated for 100-130 dwellings. This site is supported by technical reports and being in one ownership without major infrastructure requirements, there would be no uncertainty about its delivery unlike the allocated sites. Sites that are better performing than Site 338 in the Green Belt Assessment have been allocated. Although higher performing, recent development in this part of the Green Belt parcel means it is likely to perform more moderately. Site is accessible, is surrounded on three sides by development with a defensible Green Belt boundary to the south that is more substantial than that for Site BC3 and does not extend further into the countryside than the existing settlement. There are no landscape, heritage or ecology issues.