Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 14142
Received: 14/12/2020
Respondent: Lavender Hall Fisheries Ltd
Agent: Cerda Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Local Plan Review is being brought forward during an ongoing review of the Government’s standard methodology for calculating housing need. In the latest consultation version Solihull is required to deliver 1,011 houses per annum. The Local Plan Review will be falling significantly short of housing need for the Borough.
The Council should commit to the inclusion of a series of reserve sites within the Local Plan Review identified to meet housing requirements in the event that the Government’s standard methodology continues to indicate that housing need is significantly higher than that set out within the submission draft plan.
The alternative would be to include a policy within the Local Plan Review requiring the commencement of a separate Site Allocations document, such work to be commenced no later than six months after the adoption of the Local Plan Review, to include a series of reserve sites and to be read in conjunction with the Local Plan Review including adherence to the development strategy.
One of the advantages is that the site allocations could deal with any deficiency in five year housing land supply, and where it was felt that Green Belt release was required, land could continue to be safeguarded and Green Belt policies apply until such time as any given site was required.
Dear Sir / Madam,
Please see attached Representations in relation to Regulation 19.
Please don’t hesitate to get in touch if you have any queries.
Many thanks,
Clare Garrad
Object
Solihull Local Plan (Draft Submission) 2020
Policy P16 Conservation of Heritage Assets and Local Distinctiveness
Representation ID: 14143
Received: 14/12/2020
Respondent: Lavender Hall Fisheries Ltd
Agent: Cerda Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy P16 Criteria 3 is imprecise and requires greater clarity as to what the recognised process is. The hierarchical approach set out in the NPPF (paragraphs 195, 196 and 197) is more precise and provides more clarity in a development management context.
Criteria 3 to Policy P16 should be replaced with the provisions of paragraphs 195, 196 and 197 of the NPPF; alternatively, a simple cross-reference within the policy to the provisions of the NPPF could also be appropriate.
Dear Sir / Madam,
Please see attached Representations in relation to Regulation 19.
Please don’t hesitate to get in touch if you have any queries.
Many thanks,
Clare Garrad
Object
Solihull Local Plan (Draft Submission) 2020
Policy P17 Countryside and Green Belt
Representation ID: 14144
Received: 14/12/2020
Respondent: Lavender Hall Fisheries Ltd
Agent: Cerda Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Council have not given due consideration to revisiting Green Belt boundaries where land no longer fulfils a Green Belt function.
‘Lavender Hall Fisheries, Berkswell’ will be separated by HS2 from the wider Green Belt and the adjacent land is proposed as a residential allocation (site BC6).
The Council should give much greater consideration to Green Belt boundaries and whether these should be redrawn, not solely in relation to the provision of positive allocations of land but instead to reflect the change in circumstances which justifies a review as to the extent land fulfils a Green Belt function.
Lavender Hall Fisheries, Berkswell is one such example whereby the lack of any change to Green Belt boundaries undermines the permanence of Green Belt and the robustness of policy seeking to maintain openness.
Dear Sir / Madam,
Please see attached Representations in relation to Regulation 19.
Please don’t hesitate to get in touch if you have any queries.
Many thanks,
Clare Garrad
Object
Solihull Local Plan (Draft Submission) 2020
Policy P17A Green Belt Compensation
Representation ID: 14145
Received: 14/12/2020
Respondent: Lavender Hall Fisheries Ltd
Agent: Cerda Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy P17A Criteria 1 wrongly seeks to place the burden upon individual applicants to set out ways in which the impact of removing land from the Green Belt will be offset. This responsibility should be at the plan making not the decision taking stage. The Local Plan Review allocates housing sites currently within the Green Belt which is then undermined by Policy P17A which removes the in principle support for such sites.
There is reference to Green Infrastructure Opportunities Mapping at 3 (iii) however we can find no such mapping.
We consider that Policy P17A is not required and simply undermines the overarching objectives and requirements of the Local Plan Review.
Dear Sir / Madam,
Please see attached Representations in relation to Regulation 19.
Please don’t hesitate to get in touch if you have any queries.
Many thanks,
Clare Garrad
Object
Solihull Local Plan (Draft Submission) 2020
Policy P21 Developer Contributions and Infrastructure Provision
Representation ID: 14146
Received: 14/12/2020
Respondent: Lavender Hall Fisheries Ltd
Agent: Cerda Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The provisions of Policy P21 can only be promoted where the developer contributions and infrastructure provision meet the three CIL tests. As currently drafted the policy is not explicit whether its operation would be discordant and at variation with the CIL provisions.
The policy should be modified to expressly refer to the three CIL tests in regulation 122 of the 2010 Regulations, and furthermore make clear that developer contributions and infrastructure provision will only be required where each of the three tests are demonstrably met.
Dear Sir / Madam,
Please see attached Representations in relation to Regulation 19.
Please don’t hesitate to get in touch if you have any queries.
Many thanks,
Clare Garrad