Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 11091

Received: 14/12/2020

Respondent: Rainier Developments Limited

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 housing growth. Higher levels of growth perform equally as well as the Plan’s preferred approach- Option 2. The Sustainability Appraisal demonstrates that a higher level of housing growth could be accommodated sustainably.

Only two spatial options (at either Balsall Common or land south of the A4) were put forward by the Council to assess the level of growth associated with Option 4 which could skew the conclusions of the Sustainability Appraisal.

The two spatial options were selected from the GBHMA Strategic Growth Study not the Council’s own SHELAA evidence. The Sustainability Appraisal should have assessed options at levels of growth above 16,000 dwellings utilising its own evidence base.

Object

Representation ID: 11102

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There are a number of inaccuracies in the specific assessment of Site 404 (TG3 West of Rumbush Lane) in the Sustainability Appraisal, including the distance to the nearest primary school (should be a light green), landscape sensitivity (should be a grey), distance to greenspace (should be a grey) and distance to a heritage asset (should be a light green). The site performs well and there are no significant adverse effects or reasons to not allocate the land.

Object

Representation ID: 11103

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan should contain strategic policies which set out the overall strategy for development. 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: 11104

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Options A to D propose growth around high frequency public transport corridors and hubs. The definition of 'high frequency' in relation to rail stations is unnecessarily strict and not consistent with Paragraph 102 of the National Planning Policy Framework.

Certain sites might fall within Options E to G as well as under Options A to D. It is unclear whether the three further criteria introduced at paragraph 65 which inform the location of growth take precedence over Options A to G.

Object

Representation ID: 11105

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The site selection methodology which is set out in the Topic Paper departs from national policy in relation to Green Belt. It does not first consider previously developed land and land well served by public transport, and it makes no reference to whether the loss of Green Belt can be offset through compensatory improvements to the remaining Green Belt. The implications of the Spatial Strategy and site selection methodology are that Green Belt sites that perform well in relation to national policy were not selected.

Site 404 (Land west of Rumbush Lane, Tidbury Green) is well served by public transport and offers compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. The Site Assessment completely ignores the existence of Wythall Rail Station and Appeal Decision APP/Q4625/A/14/2220892. The Accessibility Study has also incorrectly assessed the site. The site is a lower performing site in Green Belt terms and should therefore be a Priority 5 site and an allocation.

Object

Representation ID: 11106

Received: 14/12/2020

Respondent: Rainier Developments Limited

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.

Object

Representation ID: 11108

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Solihull Strategic Green Belt Assessment does not make recommendations for amendments to the Green Belt boundary but that it forms the basis for more detailed assessment. There is no evidence of any more detailed assessment. The Assessment was prepared in 2016 and therefore pre-dates the current version of the National Planning Policy Framework.

There are inaccuracies in relation to the assessment of Site 404 (Parcel RP75). Development of the site would not result in the built form of Tidbury Green being any closer to Dickens Heath than exists at present. The site has strong defensible boundaries and should be viewed as a ‘rounding off’ of the settlement. The site should be regarded as ‘lower performing’ in the Assessment.

Object

Representation ID: 11110

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council need to be mindful of any changes arising from the Government’ stated intention to change the method for calculating Local Housing Need prior to submission of the Plan.

Object

Representation ID: 11111

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Local Plan is more likely to be adopted in 2022, and therefore the housing requirement and the Plan should be extended to 2037.

Object

Representation ID: 11112

Received: 14/12/2020

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The employment uplift on the Local Housing Need, to take account of the job growth at UK Central, is based on the assumption that only 25% of the jobs will be filled by people residing in Solihull. The Plan is not sound on the basis of accepting such high levels of inward commuting.