Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

Hampton-in-Arden

Representation ID: 13827

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The site assessment and selection methodology has been inconsistently applied in identifying allocation sites.

Significant weight has been attributed to two issues in relation to ‘Land off Old Station Road, Hampton in Arden’ (Site Ref. 6), which is unfounded as these can be effectively mitigated against.

There has been considerable inconsistency with the Council’s interpretation and application of the matter of ‘defensible Green Belt boundaries’ between sites, jeopardising otherwise favourable site assessments.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 13828

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The indicative densities should be included within the body of Policy P5.

Clarity is needed on the distinction between a “limited extension of urban or larger village edge”, which would allow for a residential density of 30-35dph, and a “significant extension of urban or larger village edge”, which would allow for a residential density of 30-40dph.

Change suggested by respondent:

A separate policy should be drafted in relation to density. The policy should give more clarity on what qualifies as “limited” / “significant” extensions, and which settlements are classed as “urban or larger villages”.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P7 Accessibility and Ease of Access

Representation ID: 13829

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The requirement at Policy P7 part 2(ii) is ambiguous and not enforceable for development management purposes. No definition is provided of what constitutes as a “high frequency” service. No justification is given for the requirement for sites to be within 400m and / or 800m
of a bus service or rail station and it does not allow for mitigation by providing transport-related contributions.

The requirement at Policy P7 part 2(iv) is ambiguous and is not considered enforceable
for development management purposes.

Change suggested by respondent:

Part 2(ii) of P7 should either be revoked or re-drafted to provide clarity on “high frequency”, and the choice of 400m and 800m should be justified.

Part 2(iv) of P7 should be revoked or re-drafted to provide clarity on the amount, scope, level or type of on-site transport infrastructure that would be considered acceptable, and how an ‘enhancement’ in accessibility levels would be measured.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P9 Mitigating and Adapting to Climate Change

Representation ID: 13830

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The requirement of Policy P9 3i and 3ii constrain development. Requiring a 30% reduction in carbon reduction would be in conflict with the Government’s adopted Building Regulations.

A fabric first approach’ to ensuring energy efficiency and sustainability as an alternative should be promoted.

Policy P9 3vi lacks the clarity that is required by Paragraph 16d in the National Planning Policy Framework

Change suggested by respondent:

Policy P9 should be re-drafted to require new developments to adhere to the latest Building Regulations or, when adopted, the Future Home Standards / national guidance that requires all new dwellings to be net carbon zero.

The Council should make allowance for a fabric-first approach within Policy P9.

Further information in relation to limb 3vi should be provided to ensure this is enforceable.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P17A Green Belt Compensation

Representation ID: 13831

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy P17A does not provide guidance in relation to what the scope of each form of compensation would have to be in order for a site’s removal from the Green Belt to be considered as appropriate, contrary to Paragraph 16d of the National Planning Policy Framework.

Change suggested by respondent:

Further information should be provided in relation to the scope of the green belt compensation that would be required for a site’s removal from the Green Belt to be considered as appropriate.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P20 Provision for Open Space, Childrens Play, Sport, Recreation and Leisure

Representation ID: 13832

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy P20 would benefit from the inclusion of guidance on the indicative breakdown of the 3.57 hectares of Public Open Space (POS) that are required per 1,000 population. This would assist developers with viability considerations. This should be substantiated on up-to-date and relevant evidence.

The Policy is written somewhat ambiguously, and could be mistakenly interpreted that the POS requirements of new developments should compensate for any prior under-provision.

Change suggested by respondent:

Guidance is required on the indicative breakdown of the 3.57ha of POS that are required per 1,000 population, and include a caveat that final POS provision should respond to localised assessments of demand.

It should be made clear that the POS requirements of new developments are not expected to compensate for any prior under-provision from other developments.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy HA1 - Meriden Road, Hampton in Arden

Representation ID: 13833

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

A planning application submitted on SLP Site 24 in October 2019 suggests that the development of the site will not be considered comprehensively with proposed allocation HA1, contrary to the Council’s intention cited in the Plan. This may reflect the numerous outstanding matters in relation to HA1, in particular the site’s availability as the site remains in use as a storage depot with the existing owners having no plans to vacate the site in the near future.

There are a number of suitability issues associated with the site, threatening its deliverability. The site is located wholly in an area that is considered to be potentially contaminated land, a land contamination assessment is required.

The site has far fewer positive effects when compared to ‘Land off Station Road’ within the Sustainability Appraisal. The site is not located in a suitable location, a significant negative.

The assessment of potential development sites and approach towards allocating land has not been “based on proportionate evidence” or taken into account reasonable alternatives.

Change suggested by respondent:

Land off Old Station Road, Hampton in Arden should be allocated for residential development whether in place of or in addition to allocation site HA1.

Full 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

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy HA2 - Oak Farm, Catherine-de-Barnes

Representation ID: 13834

Received: 14/12/2020

Respondent: William Davis Ltd

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The deliverability of Site HA2 is not assured as it is dependent on either re-housing existing tenants or the applicant being able to agree to purchase the site. The site is significantly constrained, including a high pressure gas pipeline being present on site.
The site is considered to have low / medium accessibility. Catherine-de-Barnes is less suitable for large scale expansion that Hampton in Arden.

Development at Site HA2 would be on one of the Borough’s high scoring Green Belt parcels, contrary to the Council’s proposed Green Belt approach.

Change suggested by respondent:

Site HA2 is not considered to be suitable and Land off Old Station Road should be allocated for residential development whether in place of or as well as site HA2.

Full 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

Attachments:

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