Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Foreword
Representation ID: 13806
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The plan does not allow for a simple and enforceable interpretation, contrary to Paragraph 16d of the National Planning Policy Framework. Longer policies should be separated by topic to ensure they are not too lengthy. For example Policy P5 relates to several key issues within one policy which is not suitable- numerous policies would be more effective.
A review of the policies and supporting text should be carried out, with specific consideration of the policies’ interpretation for development management purposes.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P1 UK Central Solihull Hub Area
Representation ID: 13816
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Support the principle of the approach taken in relation to the UK Central Solihull Hub Area and development adjacent to the HS2 hub.
The Council are heavily reliant on timely delivery from these larger sites however there is uncertainty. The length of the total development process increases with site size. The rate of delivery is wholly unrealistic at the NEC as commencement would not begin until approximately 2030. At Arden Cross, the situation is complex and dependent upon the delivery of HS2. Inefficient delivery of transport and utilities infrastructure represents a significant constraint to delivery.
Additional housing allocations at small to medium sites, such as ‘Land off Old Station Road’, would provide a ‘buffer’ and mitigate against the risk of stalled delivery at larger sites.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4A Meeting Housing Needs – Affordable Housing
Representation ID: 13817
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The viability and deliverability of development sites should not compromised by over ambitious requirements to deliver affordable housing.
The definition of affordable should be set out in the Plan as policies that have a cost implication on development proposals cannot be deferred to a Supplementary Planning Document.
Policy P4A does not allow for First Homes / Discounted Market Sales as part of the mix and is therefore not consistent with Paragraph 35d of the National Planning Policy Framework.
Reconsider approach to affordable housing requirement with a specific emphasis on development viability. Either reduce the overall affordable housing requirement across the Borough, or adopt a varied approach which takes into account less viable development typologies (i.e. based on location, site type etc.)
A definition of “affordable” must be included as part of Policy P4A.
Reconsider the proposed affordable housing tenure split, to allow for First Homes / Discounted Market Sales.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4C – Meeting Housing Needs - Market Housing
Representation ID: 13818
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Do not support the inclusion of a market housing mix within Policy P4C. The housing mix may quickly become out-of-date. The Council should allow flexibility to take into account site specifics and market demand.
The Policy should remove the housing mix, with an indicative mix included in the supporting text.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding
Representation ID: 13819
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
An individual showing interest via a Housing and Custom Build Registers rarely equates to a genuine desire / ability to build on a Self / Custom Build plot. The actual demand is likely to be significantly lower.
The blanket policy approach, requiring 5% of open market dwellings to be delivered in the form of Self and Custom Build Plots on sites of 100 dwellings or more, does not take account of localised needs or site specific constraints to delivery.
The policy should be revoked as it is fundamentally unsound.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People
Representation ID: 13821
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
There is no sufficient evidence, including in the HEDNA, to suggest that 95% of dwellings should be provided to M4(2) standard. Policy requirement should not undermine the deliverability of sites in the Borough.
A requirement of 25% of housing to M4(2) standard, unless delivered to M4(3) standard (a requirement of 5%) should be adopted.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 13823
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The housing requirement should be clearly set out within Policy P5 and should form the basis of the Council’s monitoring of land supply.
If a ‘stepped’ approach to the housing requirement be taken forward, that should be clearly set out within Policy P5.
HS2 must be considered an exceptional circumstance to boost housing delivery within the Borough above that minimum local housing need. The scale employment growth proposed means the actual housing need will be higher than that derived from historic household projections.
A considerable uplift should be implemented to take account of the economic growth / infrastructure provision and to allow for flexibility in the housing supply.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 13824
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The intention to make provision to meet the unmet housing needs arising within the Greater Birmingham should be set out within Policy P5.
The origin of the contribution of 2,105 dwellings to the Greater Birmingham Housing Market Area is unclear.
A 3,000 dwelling contribution should be made to the wider HMA in the plan period to 2036.
The total housing requirement should be at least 15,912 dwellings in the plan period and should be expressed in Policy P5 as a minimum housing requirement.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 13825
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Insufficient evidence of 10% non delivery rate that is applied to sites within planning permission that have not yet started construction, sites identified in land availability assessments, the Brownfield Land Register and the extant Solihull Local Plan.
The windfall allowance of 200dpa is a considerable figure. Development on windfall sites may well become increasingly limited / depleted.
The supply is dominated by large sites, which often experience delay. The deliverability of a number of sites is uncertain.
The Council must provide clear evidence of the trajectories and build-out rates of all sites.
The Council should allocate additional housing above its housing requirement to represent a buffer and ensure flexibility. SMBC should identify a further 4,077 dwellings (20% uplift) on small-medium sized sites in sustainable settlements.
Old Station Road, Hampton in Arden is suitable, available and achievable within the first five years of the plan period. Technical and environmental assessments have been undertaken, demonstrating there are no insurmountable constraints.
The housing supply should be increased to at least 19,094 dwellings (a 20% buffer on its requirement). Land off Old Station Road, Hampton in Arden should be allocated.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Object
Solihull Local Plan (Draft Submission) 2020
Hampton-in-Arden
Representation ID: 13826
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The plan does not provide a Spatial Strategy to clearly specify how development is to be guided, resulting in an illogical approach.
Calculating the housing requirement of Neighbourhood Area wholly on the basis of capacity is not robust and fails to consider the distinction between the specific housing needs of the area, and the ability of the area to meet that need.
Site S01 comprises the bulk of provision in the Hampton in Arden Neighbourhood Area. The site has land assembly issues which could impact upon delivery. Housing in this location will meet the need arising from Solihull town rather than Hampton-in-Arden and Catherine-de-Barnes. Development should be focused on suitable sites within the settlement of Hampton-in-Arden.
The Spatial Strategy should be re-drafted. Hampton in Arden should be given a favourable position in the settlement hierarchy.
The housing requirement should reflect housing need in the Neighbourhood Area, rather than the capacity of the area.
Site SO1 should not be considered as playing a part in meeting the housing requirement in the Hampton in Arden Neighbourhood Area. Land off Old Station Road, Hampton in Arden should be allocated.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
