Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Knowle, Dorridge & Bentley Heath
Representation ID: 14618
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object to omission of Site 413 - Land at Knowle Farm, Dorridge.
This site is available, deliverable and suitable for meeting housing need in a sustainable way, early in the Plan period. It should be removed from the Green Belt and identified as a residential allocation.
In the context of the site selection process it is difficult to understand why the site, which is identified as lying within a lower performing Green Belt parcel with defensible boundaries, in a landscape of medium sensitivity, with high accessibility, no significant constraints, and performs comparatively well in SA terms (mainly neutral effects) has not come forward for allocation.
Site could also assist with the costs for new school in Knowle and a Sports Hub in the settlement, if required.
Site size and extent is incorrect in Site Assessment. Vision Document accompanies submission.
The site should be removed from the Green Belt and identified as a residential allocation.
See attached documents
Support
Solihull Local Plan (Draft Submission) 2020
Vision
Representation ID: 14623
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Generally supportive of the Vision. However, note that the reference to ‘protection of the Green Belt’ does not necessarily take into account the fact that there are exceptional circumstances with Solihull Borough which justify the release of appropriate Green Belt sites. The current wording is considered unsound as it is not consistent with national planning policy.
The Vision emphasises the opportunity around HS2-related growth, particularly UK Central. However, there is a disconnect between these economic growth aspirations and the level of housing growth proposed. If this is not addressed, the Vision will not be realised in the most sustainable manner.
The Vision should refer to ‘protection of the remaining Green Belt (which contains the strategically important Meriden Gap) as necessary, alongside sustainable growth…’
The level of housing growth is insufficient in terms of its contribution towards wider unmet needs and to deliver balanced growth alongside UK Central. Without additional numbers the Vision will not be realised. As a minimum, the growth level of 16,000 dwellings should be accommodated (requiring the use of ‘Amber Sites’ as part of the additional supply), which is not considered to have any significant effects over the current preferred option of 15,000 dwellings (Option 3a in the SA).
See attached documents
Support
Solihull Local Plan (Draft Submission) 2020
Spatial Strategy
Representation ID: 14624
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Supportive of the principles of the spatial strategy. ‘Exceptional circumstances’ exist to justify the release of Green Belt via the ‘balanced dispersal’ strategy. However, there is potential for further growth to be accommodated and the level of growth apportioned to settlements is not justified.
SA should test additional options. No justification for preferred level of growth, when a higher level of growth could be accommodated with similar impacts.
The extent to which the spatial strategy is being applied consistently is questionable. There is potential for further growth to be accommodated in rural settlements identified as suitable for development.
A clear and explicit settlement hierarchy should be added to reflect the Council’s approach.
Unrealistic to assume that further Green Belt release will not be necessary beyond the plan period. Safeguarded land should be identified in accordance with the spatial strategy.
The draft SLP should test additional reasonable alternatives for higher levels of growth (particularly for options between 16,000 and 19,000 dwellings) which includes the use of additional Green Belt site releases in accordance with the spatial strategy (over and above the current identified ‘Limited Green Belt Release’). The identification of additional Green Belt sites for consideration should be based upon a reappraisal of the Site Selection process. The potential for additional Green Belt release in accordance with the spatial strategy to deliver levels of growth over and above 19,000 dwellings should also be considered, as an alternative to the larger scale expansions of Balsall Common and Land South of A45 currently tested.
The draft SLP should include an explicit settlement hierarchy within the policy to guide the direction of this additional growth, focusing on those settlements identified as appropriate for development via the spatial strategy approach to date. This should reflect the range of facilities and services available with higher priority given to those settlements with sustainable transport links, particularly railway stations.
The draft SLP should identify safeguarded land in accordance with the spatial strategy to ensure longer term development needs are met.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Spatial Strategy
Representation ID: 14628
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Site Selection approach not fully justified. Concerns with the application of the methodology in terms of its transparency and consistency. Some Green Belt sites rejected unjustifiably and capacity for further Green Belt release in accordance with the spatial strategy has been unduly constrained.
Not clear from the site assessment commentary on what grounds a site has been rejected.
Inconsistencies between the different evidence base documents used to inform the Site Selection process e.g. the SA and accessibility study. Site Assessment commentary does not appear to reflect the most up to date SA commentary i.e. in terms of the number of effects and whether these are positive or negative.
Inconsistencies between why some sites allocated others not. E.g. site Policy KN1 notes Grimshaw Hall as a constraint. The site assessment makes no reference to it under constraints.
The draft SLP Site Selection process should be reviewed for consistency and transparency to provide a justified evidence base for the draft SLP. We consider this would give rise to the conclusion that further Green Belt sites are suitable for allocation in accordance with the spatial strategy.
The draft SLP Site Selection process should be more fully justified by consistently considering the potential for mitigation measures in the assessment of sites, potentially enabling the identification of further Green Belt sites that are suitable for allocation in accordance with the spatial strategy.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding
Representation ID: 14629
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The 5% requirement for self and custom build plots is unsound. It places the burden on developers only, and goes beyond the PPG which seeks local authorities to "engage" with landowners and "encourage" them to consider self-build and custom housebuilding.
The HEDNA suggests an ‘encouragement’ approach alongside a policy requirement for strategic sites. On the basis of the current Register, it identifies that Solihull should be seeking to deliver 116 plots per annum. However, over-reliance upon the Register should be cautioned against in justifying any policy percentage requirement, particularly given the criteria for expressing an interest are relatively limited i.e. whilst an individual may express an interest the degree to which this is a realistic ambition cannot be determined.
The following changes are required:
- The requirement to provide 5% on allocated sites of 100 dwellings or more should be replaced with an ‘encouragement’ to provide self-build on allocated sites of 100 dwellings or more having regard to the latest robust evidence.
- Point 2 of the policy should also be clear that after the marketing period (which should be less than 12 months), any unsold plots should revert back to the original developer.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People
Representation ID: 14630
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We query whether the evidence base supporting this policy and its requirements is robust, including around viability and deliverability. The Viability Study makes reference to P4d being included in Round 2 testing, but not P4e. This has the potential to undermine delivery of much needed housing and affordable housing. Whilst specialist housing may be appropriate on some sites, this should be tested. Additional sites to deliver this specific need may need to be explored if supported by evidence.
Revise policy, with reference to supporting evidence, to ensure deliverability of development sites is not affected by the requirements of the policy.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 14634
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy P5 is unsound in respect of the housing requirement identified.
Imperative that sufficient homes are provided to support the envisaged economic growth. The HEDNA should test an additional UK Central Hub growth scenario (22,998 jobs) to determine how many homes might be required in Solihull if all jobs are filled by residents of Solihull.
No justification for the HMA contribution and no agreement with other Local Authorities. Birmingham shortfall is significantly higher than position statement suggests.
Housing requirement should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios and to help meet HMA shortfall to 2031. Acute affordability issue need to be addressed, so the recommended local housing need of 816 dwellings per annum within the HEDNA should also be increased.
Question whether the true capacity for further growth has been fully realised.
The draft SLP housing requirement is not currently justified and should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios to meet the envisaged jobs growth at UK Central Hub, tested via our review of the evidence base (HEDNA).
The draft SLP housing requirement should be increased to provide more headroom to help meet GBHMA housing shortfall needs up to and beyond 2031.
More needs to be done to address the acute affordability issue and so the recommended local housing need of 816 dwellings per annum within the HEDNA should also be increased to maximise the contribution towards meeting this need.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 14637
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Housing Land Supply: There are a several issues associated with the identified housing land supply which give rise to concerns that the draft SLP will not be effective in delivering the housing requirements.
No certainty that sites identified in land availability assessments, Brownfield Land Register or Town Centre sites will come forward. Additional flexibility is needed.
Too much reliance on windall.
No evidence to demonstrate that 2,740 dwellings at UKC Hub area can be delivered.
No site-specific trajectories for allocated sites. Assumption underpinning delivery periods are not detailed. Several sites also have complex land ownership issues or dependent on infrastructure, which could impact on timings.
No flexibility / contingency in housing land supply requirement.
Further housing land supply should be identified to provide flexibility to the draft SLP housing requirement. This would serve to provide a contingency in the event of the identified supply not coming forward as anticipated, particularly those which are reliant upon substantial and/or site-specific infrastructure being delivered at the necessary point in time. This should have regard to the levels of flexibility considered appropriate in recent Local Plan examinations.
Further evidence is required to justify the windfall allowance within the housing land supply.
Further detail and evidence is required to justify the housing trajectory overall and site specific trajectories should be provided within the draft SLP.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 14639
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
National Space Standards: Policy P5 - Point 5 requires all new homes to meet nationally described space standards. This element of Policy P5 is considered unsound as it is not justified or consistent with national planning policy. There does not appear to be any evidence providing justification for this taking full account of need, viability and timing, as required by the NPPF, Footnote 46 and the PPG.
The requirement should be removed to ensure the draft SLP is justified and consistent with national planning policy.
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Policy P9 Mitigating and Adapting to Climate Change
Representation ID: 14645
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Requirement for a 30% reduction in energy demand/carbon reduction improvement over and above the requirements of Building Regulations goes beyond the Future Homes Standard (2019) consultation proposals and beyond the current PPG.
Under Point (viii) developments are required to provide one electric charging point per vehicle. Proposals must be supported by evidence to demonstrate that they are deliverable.
In Point 3 (i) energy and carbon reduction are two separate measurements. The Future Homes Standard (2019) refers to carbon emission reductions; this should be clarified.
The Viability Study does not test the impact of the 15% energy from renewable/low carbon sources requirement, contrary to the PPG and the ‘energy efficiency hierarchy’.
Unclear what up to date local evidence informs the requirements.
Policy does not contain sufficient clauses related to site specific viability or site-specific constraints which may impact upon the implementation of the requirements.
The Policy P9 Points 3 (i), (ii) and (iv) requirements should be removed, or at the very least additional clauses should be included within the policy that allow for site specific flexibility in relation to viability and site-specific constraints.
See attached documents
