Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14371

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is agreed that Hockley Heath should be a settlement where limited and proportionate development is accepted.
However, it is considered that the site on land r/o 2214 Stratford Road Hockley Heath, submitted originally as part of the Solihull DLP 2016 consultation (site 121) is located in a more central location within the settlement and exhibits equal if not better credentials in respect of Green Belt, accessibility, landscape and deliverability than Site 25, Land off School Road Hockley Heath

Object

Representation ID: 14378

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Moat Lane Depot was first identified as a housing allocation in the Solihull Local Plan 2006. Concerns over relocation of the current uses on the site and the timing of such a relocation, have remained an ongoing issue and concern ever since
No site has been identified for the relocation of the depot or referred to in the DSP, which merely states that the site is expected to become available during the Plan period.
There are also particular issues which need to be resolved regarding flood risk, contamination and the removal/relocation of the telecommunications mast before the site can be redeveloped.

Object

Representation ID: 14380

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Draft Submission again refers to the Town Centre as a location to provide for 861 dwellings within the Plan period.

From the conclusions that can be drawn from the adopted Plan and the experience and complexities of town centre redevelopment, it is considered that the housing figure is over ambitious and unachievable within the Plan period.

Object

Representation ID: 14454

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The DSP plan fails to set out the current or future need for specialist housing for older people, in the form of 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.
Depending on larger sites to deliver specialist housing for the elderly will not address the current need and is likely to only exacerbate the need going forward.
Rosconn support providing a choice of housing for all, however consider delivery of housing for the elderly is a specialist area.

Object

Representation ID: 14485

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Windfall:

A total allowance of 600 windfall units is included within the DSP. It is clear that historically there has been a high level of windfall completions. It is unclear however from the Windfall analysis at Appendix H of the 5YHLS position July 2020, whether the windfall allowance relates to both small and large sites, nor is it clear whether this includes garden land.
There appears to be no compelling evidence (as sought by NPPF Para 70) that this is a reliable source of supply.

Object

Representation ID: 14490

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Barton Willmore, on behalf of various developers, have carried out a Housing Need Report in response to the DSP, focusing on the calculation of housing need in the DSP 2020-2036 and whether the approach taken in the DSP aligns with the NPPF. The report concluded:

- The minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub, to 1,036 and 1,248 dpa.
- The deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered and additional unmet need will be created post 2031.

The DSP indicates a contribution of 2,015 dwellings towards Birmingham’s identified shortfall of 37,900 to 2031. However, the recent Greater Birmingham Black Country Housing Market Area (“GBBC HMA”) study claims the total Birmingham shortfall has diminished to 2,597 dwellings. This appears somewhat a surprising figure considering the SGS minimum shortfall was identified as 28,000 dwellings in 2018 and is considered to be a highly optimistic prediction.
In its conclusions the GBBC HMA study does not state that the scale of the post 2031 shortfall is not yet known and the shortfall for the whole of the combined authorities HMA post 2031 cannot yet be calculated. 2.5 It follows that, for the reasons summarised here the DSP is clearly unsound by reference to all of the tests set out in paragraph 35 of the NPPF.

Object

Representation ID: 14499

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

With this uncertainty and wide variation in figures and even accepting that Solihull is confirming that a contribution will be made to the shortfall there appears to be no confirming documentary evidence that Solihull’s figures have been agreed by the HMA authorities and that Solihull has met its duty to cooperate either in its evidence base or confirmed within the DSP

Object

Representation ID: 14500

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The DSP relies on the BFLR to help make up the overall numbers in the plan, equating to 77.

The Council have only completed Part 1 of the
BFLR and so any Green Belt sites coming forward could only be delivered under 145(g) of the NPPF. Para 145(g), whilst allowing for redevelopment, does so on the basis there is no additional impact on the openness of the Green Belt.

As the Council does not have Part 2
of the register in place there is no mechanism to deliver the numbers
allocated by the BFLR. Only one site has come forward so far, with an application for 49 extra care apartments (the site was not in GB).

Object

Representation ID: 14868

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Omission site - Site 13/340 Three Maypoles Farm Dickens Heath (in Part)
Rosconn worked with the Council and other
landowners to produce a masterplan that responded positively to issues raised by local residents. The master plan sought to;
a) Ensure a firm and defensible Green Belt boundary to avoid coalescence of Shirley with Dickens Heath,
b) Avoid a narrow corridor between Shirley and Dickens Heath and reducing the gap between settlements,
c) Remove the potential for vehicular access through adjacent residential development on the edge of Shirley,
d) Avoid any perception of narrowing the gap between Shirley and Dickens Heath along Dickens Heath Road and
e) Avoid loss of public open space and safeguarding the amenities of adjoining property owners.

In brief, the site is highly accessible, of medium landscape value and
within a moderately performing parcel of Green Belt. It has a recognisable firm and defensible Green Belt Boundary and would accommodate appropriate levels and areas of public open space to satisfy the Councils concerns over coalescence and narrow POS
corridors. The site is marketable, readily available and achievable within the Plan period.