Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14021

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 14039

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 14048

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 14049

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 14053

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 14061

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Support

Representation ID: 14065

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

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.

Support

Representation ID: 14067

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

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.

Support

Representation ID: 14068

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

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.

Object

Representation ID: 14069

Received: 09/12/2020

Respondent: MACC Group

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.