Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

Policy P2 Maintain Strong, Competitive Town Centres

Representation ID: 14021

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Objection to Policy P2 as it fails to sufficiently recognise the potential opportunity for new residential development in ensuring the vitality of Shirley town centre.

Change suggested by respondent:

P2 should be modified to say “Development of residential uses will be supported within the town centre”.

Full text:

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Object

Solihull Local Plan (Draft Submission) 2020

Policy P4A Meeting Housing Needs – Affordable Housing

Representation ID: 14039

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Objection to Policy P4A it fails to differentiate between different types of housing, specifically between C2 and C3 developments, as well as establishing a difference between self-contained housing units and institutional facilities such as care homes. Including C2 Use Class makes it in conflict with NFPPF and PPG.

Change suggested by respondent:

Amend to say
'The Council will require developers of allocated and windfall sites to make a contribution to affordable housing on residential sites of major development delivering self-contained (Use Class C3) dwellings, where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more to meet the housing needs of the Borough'.

Full text:

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Object

Solihull Local Plan (Draft Submission) 2020

Policy P4C – Meeting Housing Needs - Market Housing

Representation ID: 14048

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P4C is not considered to be positively prepared or justified, and is therefore considered not to be sound. Clause 3 of this policy provides requirements for housing mix, which across the Borough this may represent an appropriate housing mix, it is considered unlikely that this will be appropriate in all locations and for all types of development. The HEDNA 2020 (paragraph 47) and the Housing Topic Paper (paragraph 117), both support a ‘flexible approach’ when applying housing mix. This should have regard to factors.

Change suggested by respondent:

Clause 3 of Policy P4C should be deleted and instead should seek to negotiate housing mix on a site by site basis.

Full text:

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Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding

Representation ID: 14049

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P4D as set out makes no differentiation is for flatted schemes, where this is unlikely to be feasible. The should be an additional clause of exemption (vii) where the type of development proposed makes this unfeasible, for example whether flatted development, or specialist housing proposals.

Change suggested by respondent:

Addition of clause (vii): The type of development proposed, for example whether flatted development or traditional housing, or specialist housing proposals.

Full text:

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Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People

Representation ID: 14053

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P4E suggests that new housing developments will be expected to provide a mix of dwelling size and type to meet the identified needs of older people and those with disabilities and special needs, this is unlikely to be feasible on many sites, where site size or constraints mean that only one model of care accommodation is possible to be provided.
The Policy requires all developments greater than 300 dwellings to provide specialist housing, instead, the Council should focus on providing care specific developments in appropriate locations. It is considered that this policy as currently drafted will be ineffective at ensuring the appropriate level of provision of specialist accommodation is achieved in the Borough across the plan period.
This policy also requires applications for specialist housing and care homes to demonstrate that Primary Health Care services will be accessible to serve residents. Whilst this is important for certain types of specialist housing such as sheltered housing, for proposals such as Care Homes it is anticipated that care will be provided by the operator, and will often work alongside rather than utilising the local Primary
Care services and can often support Primary Care services by reducing the level of care required for an individual. Where operators are intending to provide Primary Care services within the development, this should be taken into consideration.
It is considered that this policy as currently drafted will be ineffective at ensuring the appropriate level of provision of specialist accommodation is achieved in the Borough across the plan period.

Change suggested by respondent:

It is suggested that clause 1 should be deleted, or otherwise modified in order to acknowledge that provision of a range of housing types may not always be feasible.
Clause 4 should be modified to the following:
'4. All developments of 300 dwellings or more, where feasible and appropriate, should must provide specialist housing or care bedspaces in accordance with the Council’s most up to date statement of need on older person’s accommodation'.
Within Clause 6 and 7 of the policy relating to specialist housing and care homes respectively, references to access to Primary Health Care services sub-clauses should be modified to recognise the potential for on-site provision.
6 (ii) It can be demonstrated that satisfactory Primary Health Care services will be accessible to serve the residents of the development unless on-site provision is proposed;
7 (iii) There are satisfactory Primary Health Care services to serve the residents of the
development within reasonable proximity unless on-site provision is proposed;

(NB, The numbering within Policy P4E appears to be incorrect with two clause 5s.
Clause 7 referred to above is the clause relating to Care Homes.)

Full text:

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Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14061

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy P5 as currently drafted is not considered to be consistent with national policy, in that it is not striving to significantly boost the supply of housing. This is particularly relevant to windfall sites, where the policy suggests that proposals will only be supported where they contribute towards meeting borough-wide housing needs and towards enhancing local character and distinctiveness. It is considered that this seeks to conflate two issues of delivering housing and ensuring design quality.

Clause 6 of this policy relates to density, confirming that it will be informed by a number of factors, including the need to maximise the efficient use of land, an appropriate
housing mix, responding to local character and distinctiveness, and scale, type and location of development. There is the potential for some of these factors to conflict, notably the need to efficiently use land in accessible locations, whilst responding to local character and distinctiveness.

The Framework at Paragraph 123 requires plans to contain policies that optimise the use of land and meet as much of the identified need for housing as possible. In a Borough with high levels of housing need and that is constrained by the Green Belt, it is particularly important that the Council is aspirational and encourages proposals that comprise higher density developments in order to maximise housing delivery.

Change suggested by respondent:

'3. New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs particularly where proposals involve the redevelopment of suitable brownfield sites. Unless there are exceptional circumstances, new housing will not be permitted in locations where accessibility to employment, centres
and a range of services and facilities is poor'.

'Density
6. The Council will seek to make most effective use of land, by seeking to ensure an appropriate density of new housing that will be based on a number of factors,
and measured on the developable area of a site'.

Full text:

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Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People

Representation ID: 14065

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Representation Summary:

P4E - The Council’s requirement in Paragraph 216 for care homes and specialist housing to be provided in accessible locations is supported, as it is important that such developments are sustainably located. However, it is noted that this may conflict with the requirement for specialist housing or care bedspaces to be provided on
all sites over 300 dwellings, as this may result in such developments being provided on the edge of developments isolated from any form of local facilities, public transport and other services.

Full text:

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Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14067

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Representation Summary:

P5 - MACC Group supports the Council’s assertions in the supporting text that where proposals fall significantly below ‘indicative densities’ justification must be provided
through the supporting information. This demonstrates a commitment to achieving high density schemes, particularly in town centre and urban redevelopment
locations.

Full text:

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Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Policy P9 Mitigating and Adapting to Climate Change

Representation ID: 14068

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Representation Summary:

Policy P9 is highly aspirational in seeking to ensure development is mitigating and adapting to the effects of climate change, however, in order to be fully consistent with national policy, the policy should identify that exemptions will apply where meeting these standards is not viable or feasible. The requirement for one electric vehicle charging point per residential dwelling, is not appropriate in all circumstances.

Change suggested by respondent:

Amend Policy P9 as follows:
'3. At a site level, where feasible and viable, development must apply the ‘energy hierarchy’
to reduce energy demand for heating, lighting and cooling and minimise carbon dioxide emissions as follows:
viii For residential development of new dwellings: provide at least one charging
point for electric vehicles per dwelling. For non-residential development, 1 charging point will be provided per 10 parking spaces. On development sites
without allocated parking or where less than one space per dwelling is provided, a contribution will be made to the Council’s Charging Infrastructure Fund and/or provision to be made through a commercial rapid charging point.

Full text:

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Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P14 Amenity

Representation ID: 14069

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is considered that the policy as currently drafted is not considered to be justified or consistent with national policy. Whilst the Framework strongly encourages good design and creating high quality buildings and places, Paragraph 130 provides that permission should be refused for development of poor design that fails to take opportunities available for improving the character and quality of an area and the way it functions. This does not mean that only development that secures high quality design should be permitted, but rather that good design should be encouraged. Furthermore,
Policy P15 seeks to deliver high quality design, and so it is not considered necessary to include this requirement in P14, with clause I of this policy instead restricted
to dealing with issues of amenity to ensure the emerging Plan is effective.

Change suggested by respondent:

'1. (i) Permit development that respects the amenity of existing and future occupiers; and the character of the surrounding area;'

Full text:

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Attachments:

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