Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14124

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Paragraph 160. Plan is not future-proofed to provisions of White Paper and underlying principles to achieve affordable housing. Fails to recognise & potentially excludes almshouse charities as form of affordable housing. Requires almshouse charities to provide financial contribution or provision of affordable housing and considers almshouse charities as unsuitable to provide affordable housing for developers. This approach leads to fewer almshouses being built and adds to costs, contrary to need to boost affordable housing

Object

Representation ID: 14127

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy P4A paragraph 2 should clarify that almshouse charities are a form of affordable housing, as they satisfy the NPPF eligibility criteria, and fall within the definition of social housing. Without this the policy is potentially discriminatory and work against the provision of almshouse properties in Berkswell Parish

Object

Representation ID: 14129

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Paragraph 168/Policy P4A is prejudicial to some registered social housing providers such as almshouse charities as developers may be reluctant to enter discussions with an almshouse charity if it may seek to house those from the local community, which could be excluded by Borough wide need.

Object

Representation ID: 14131

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Paragraph 242/544. A concept masterplan should be prepared for Riddings Hill, Balsall Common (SLP2013 Site 19), which should include the provision of almshouses

Object

Representation ID: 14132

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Paragraph 531. The Trustees should be a key stakeholder as Berkswell C of E school is vested in the charity, and all housing proposals within Balsall Common fall within the terms of the charity scheme. Need for education strategy recognising other schools in area. Plan lacks detail of new school proposal, such as size, location, delivery, trigger point, community use, access/parking, constraints & design issues. Lack of Special Education Needs (SEN) provision. No indication of phasing of school to meet needs of housing across settlement. Does not factor in potential extra 300 homes at BC1.

Object

Representation ID: 14134

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy BC6. Berkswell C of E school is the nearest to this site, but a footpath/cycleway link is required. This would be consistent with the aim to support walking and cycling strategies

Object

Representation ID: 14135

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Call for Site 43 Old Lodge Farm, Kenilworth Road should be included in the table of sites proposed for allocation, as it is above the threshold for small sites in the NPPF. A new policy including contribution for cycling/walking access provision to Berkswell C of E school is required

Object

Representation ID: 14137

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Call for Site 43 Old Lodge Farm Kenilworth Road should be included as allocated site with policy requiring financial contribution to cycling/walking access provision to link to Berkswell C of E school

Object

Representation ID: 14164

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

P4B
1. The draft submission Plan fails to identify if the green belt land referred to includes the land that SMBC seek to release from the Green Belt or whether this is additional green belt land that SMBC would support the release of to meet a Local Need for housing. This policy is unclear and needs clarification.
2. If the policy is proposing the release of additional green belt land, it is unsound and fails to consider the provisions of the NOP whereby the view is that Brownfield sites should be considered at first instance
3. P4B ii is contrary to principles of freedom of choice to limit those in need of accommodation to allocated housing sites before access to a local needs' provider can be accessed.
4. The "local connection to the parish" provisions cannot override the terms of Trusts established within Charity Schemes as governed by the Charity Commission to which Charities are open public scrutiny, to do so fetters Trustees discretion which is an integral part of Charity Law. An exclusion within this clause should be applied in respect of registered Almshouse Charities.
5. The provision of Community-Led Housing is supported by the Parish Council to meet the needs of the local populace within the allocated sites.
6. By implication, green belt site allocation would not be within easy access of the local amenities or transport which is prejudicial and discriminatory to the local parish community whose personal circumstances may require accommodation nearer to amenities but which would not be available due to them by virtue of their characteristics.
7. A community-led housing project for those who are in the older age bracket, as is typically the case for the Almshouse Model, could risk being considered under the rural exceptions policy despite being a registered affordable housing provider for the most vulnerable in society as the Local Plan is currently drafted
8. The allocation of Local needs via the Rural Exceptions Policy demonstrates a total lack of community engagement regarding the need to respect and listen to the needs of the community. Any development envisaged by the rural exceptions rule by the Local Plan appears to be the only mode that Local Housing needs can be met and such a project would likely be under the umbrella of a Community-Led Housing Scheme. Yet the benefits of Community-Led Housing, the Strategic Vision for Solihull 2020-2025 and Partnerships with Birmingham together with the White Paper, "Planning for the Future" have been inadequately and woefully addressed within the Local Plan.
9. Policy 4(b) is contrary to the provisions of the Community Right to Build Orders and the Localism Act 2011
10. The Local Plan discriminates against Almshouse Charities who provides Affordable Housing via the Almshouse Model, the definition of which is recognised by the Central Government.

Object

Representation ID: 15171

Received: 06/12/2020

Respondent: Berkswell Charities

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Call for Site 43 Old Lodge Farm, Kenilworth Road should be included in the table of sites proposed for allocation, as it is above the threshold for small sites in the NPPF. A new policy including contribution for cycling/walking access provision to Berkswell C of E school is required