Solihull Local Plan (Draft Submission) 2020

Object

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.

Support

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.

Support

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.