Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13692

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Support allocation of Site BC4, which is primarily brownfield land for housing. Site can deliver 270 dwellings making more effective use of land whilst still according with environmental and design requirements, see Barwood masterplan.
Concept masterplan contains errors, Relief Road corridor incorrectly shown. Reference to bypass providing Green Belt boundary is incorrect and contradicts paragraph 560 of Plan, which refers to eastern boundary of site. Object to BC4.2.iv reference to public open space east of site to Relief Road as shown on Concept Masterplan as unreasonable and undeliverable as outside promoter's control. BC4.2.vi should be removed as unnecessary and insufficient evidence. BC4.3 requirements should be subject to meeting CIL tests. Object to BC4.4.i and paragraph 560 requirement for open space between site and Relief Road. BC4.4.ii requirement should be within site. Should reference potential Green Belt enhancements to be agreed at planning application stage.

Object

Representation ID: 13693

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Insufficient evidence to justify the compensatory improvements required by Policy P17A. Green Belt enhancements should be reasonable and proportionate to avoid jeopardising viability. Requirements outside the control of land promoters are undeliverable. Hierarchy in criterion 3 lacks robust evidence, and Green Infrastructure Opportunity Mapping not in evidence base. Policy should be based on robust evidence identifying deliverable land for enhancement, managed through S106 procedure.

Support

Representation ID: 13711

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

P4A. The Council should take into account any updated and wider definition of affordable housing which may emerge as national policy evolves, as well as ensuring that the implications of any policy on viability are fully tested. In this regard, we are pleased to note that Policy P4A confirms that a Meeting Housing Needs Supplementary Planning Document (SPD) will be produced and periodically updated to ensure that the local affordable policy remains up to date and can respond effectively to changing circumstances.

Object

Representation ID: 13713

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

P4A. Whilst we recognise that criteria 7 and 8 of Policy P4A set out expectations in terms of what “should be provided” in terms of social rented and shared ownership housing, we are pleased to note that both criteria state that the specific tenure mix “will take into account site circumstances”. We consider that such flexibility is critical to ensure that the Policy can be found sound as ultimately affordable housing needs will vary between different areas of the borough and may change over the plan period. It is important that any provision of affordable housing takes account of evidence of local needs and market demand defining tenure mix.

For it to be sound, a more flexible approach is needed to the wording of Policy P4A, which enables local and site specific circumstances to be reflected when defining the affordable housing mix and for this to be considered and assessed at the decision-making stage.

Object

Representation ID: 13715

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

P4C. The mix of market housing at any given site must take account of evidence of local needs and market demand. Whilst criterion 1 of Policy P4C suggests that there is some flexibility for housing mix depending on site specific circumstances, criterion 3 seeks to fix a very specific housing mix, using the terminology “shall be provided”.

Ultimately, housing needs vary between areas of the borough and may change over the plan period. Matters in relation to the most appropriate market housing mix for a site can be considered and assessed by the LPA at the decision-making stage once a planning application for development has been submitted.

Object

Representation ID: 13717

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

P4D. We accept that the Council is justified in making provision for self and custom build housing in order to comply with the Self and Custom Housebuilding Act, the Housing and Planning Act, Planning Policy Guidance and the needs identified on the self-build register.
However, having considered the justification for Policy P4D and the Council’s ‘Meeting Housing Needs Topic Paper’, we disagree that the Council has sufficiently evidenced its proposed requirement for 5% of open market dwellings on residential sites of 100 units or more to comprise self and custom build plots.
Such a policy needs to be justified with robust evidence of need in order to be found sound. Currently, there are limited details provided as to how the 5% requirement has been derived and how this figure relates to local need and demand for self and custom build plots across the borough.
This prescriptive, borough-wide requirement to provide 5% threatens the Council’s ability to meet its local housing need requirement if there is no localised need or demand for such plots and so they remain vacant, as opposed to being built out and offered to the market as part of a more traditional developer build offering.
If self or custom build plots are not built out and remain vacant for a long period, this has adverse implications for viability and other Local Plan objectives and is also harmful to the visual and residential amenity of those living in close proximity to them.

Object

Representation ID: 13720

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst we support the principle of Policy P4E and its objective to provide a variety of homes to meet the needs of different groups in the community, we are concerned that it does not consider the particular locational requirements of older people and those with disabilities and special needs.

Policy P4E does not consider the location or which operators will be providing specialist care provision.

Given their land requirements, developments of 300 dwellings and more will typically be on the edge of existing settlements, rather than in more central, urban locations which are typically in closer proximity to local services and facilities. Older persons and specialised living accommodation usually needs to be in the most sustainable and accessible locations, in close proximity to a good range of services, facilities and transport links, given that residents tend to be less mobile and more reliant on public transport. Furthermore, the larger, mainstream housebuilders which typically build developments of 300 dwellings or more also tend to have less experience or expertise in operating specialist housing or care accommodation.

Object

Representation ID: 13721

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council has provided insufficient evidence to justify policy P4E.

Support

Representation ID: 14784

Received: 10/12/2020

Respondent: Barwood Development Securities Ltd

Agent: stantec

Support the general thrust of Policy P15. However, the numerous design principles set out are too prescriptive and risk local distinctiveness being overlooked in favour of achieving generic design objectives which may not be appropriate to local context.
Design principles should reflect only what is necessary to ensure the creation of high quality spaces within individual development sites and their local context, as opposed to generic principles which may not necessarily lead to the development of well-designed places.
In criterion 9 it is important to state that any infrastructure or planning obligation requirements to ensure the comprehensive delivery of sites should meet the statutory tests in Regulation 122(2) of the Community Infrastructure Levy.