Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14655

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 requirement in point 8 goes beyond the guidance of the NPPF, which encourages developers to provide net gains.
Points 9 and 12 applies net gain to all developments on site, but net gain may not be achievable on all sites in-situ, for example due to site constraints and/or viability. This may
constrain delivery of development land.
Whilst Point 12 allows for the provision to be off-set this is considered a ‘last resort’. The Natural Environment Topic Paper (paragraph 42) refers to a Local Nature Recovery Network evidence base being in production to support implementation of the policy. This should be used to support strategic, plan-level solutions on net gain, rather than potentially less beneficial site by site solutions.

Object

Representation ID: 14658

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

Point 3 refers to site specific planning obligations being sought where appropriate. Point 5 refers to Community Infrastructure Levy (CIL) developer contributions being used to fund strategic infrastructure. Point 6 notes that planning obligations from more than one development may be pooled to fund infrastructure. The Policy does not make reference to the Infrastructure Funding Statement to help inform these judgements regarding the use of planning obligations and pooling. This is unsound.
The PPG states that where CIL is in place for an area, charging authorities should work proactively with developers to ensure they are clear about the authority’s infrastructure needs. Authorities can choose to pool funding from different routes to fund the same infrastructure provided that authorities set out in the infrastructure funding statements which infrastructure they expect to fund through CIL.

Object

Representation ID: 14661

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

Concerns around the level of growth directed to Balsall Common compared to Knowle and Dorridge.
Potential inability to deliver the Balsall Common relief road and therefore the deliverability of the housing allocations that rely on it.
The Viability Study does not specifically mention the relief road, bypass or any additional infrastructure costs for Balsall Common besides secondary school contributions. This brings into question the robustness of the Viability Study.
The Council’s evidence base appears to question whether this is the appropriate location for a relief road. The Transport Study suggests that the western route for the bypass should also be considered, however it is not clear from the SA that this has been explored as a reasonable alternative for growth in the draft SLP.

Support

Representation ID: 14662

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Support the principle of the allocation but query whether 180 dwellings can be delivered given extent of constraints.
Proposed Green Belt boundary does not include the proposed Sports Hub, meaning it would rely on very special circumstances being demonstrated for its delivery. If mitigation is required to offset the loss of pitches, its deliverability should be assessed and agreed at the allocation stage.
A financial contribution towards the new all through school on KN2. has not been tested within the Viability Study, nor has delivery of the Sports Hub. The ability for this site to be delivered, let alone with a full policy-compliant affordable housing provision, has not been demonstrated.

Support

Representation ID: 14663

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Support the principle of the KN2 allocation but have significant concerns that the level of growth identified is not deliverable.
The relocation and delivery of an all through school is not listed in the IDP -it only refers to requirement for primary school places. If the new school will be part funded by developer contributions and other sources, this should be made clear as it will be key to establishing that the school and housing is deliverable. Delivery of an all through school should be assessed through the Viability Study in order to determine whether the site can be delivered at all, let alone with a policy-compliant affordable housing provision and other infrastructure requirements.
The site has a number of landowners which could affect assembly and deliverability. Lack of evidence is submitted to demonstrate availability and deliverability.

Object

Representation ID: 14666

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Some sites have not been considered within the SA as reasonable alternatives without explanation. In the Supplementary Consultation (2019) ‘amber site’ A1 was consulted upon as part of the consideration for further site options (identified in step 1 of the site selection process as ‘likely allocation’). However, the Site Assessment document (site reference 345) states that the SA does not assess the site. Therefore, the SA could not have informed the overall conclusions of the Site Assessment process (which for this site concludes it is ‘red’ – no allocation).
At Section 7.2 the SA provides ‘outline reasons’ for the selection of proposed housing sites at the plan level, however the SA does not provide any outline reasons for individual sites in terms of why they have or have not been selected for allocation. This is not fully in accordance with the Strategic Environmental Assessment Regulation h) which requires an ‘outline of the reasons for selecting the alternatives dealt with’.

Object

Representation ID: 14667

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Five new Sports Hubs are required across the Borough to deal with replacement / new provision. The Plan is unclear on the precise location and deliverability of this mitigation, and it is unclear whether the land is available to deliver these hubs, or the cost and timing of when they will be delivered. It is implied that in some instances very special circumstances will be required at the application stage. We object to this approach. The draft SLP should clearly state what mitigation is required and how it can be delivered, with support from the evidence base – for instance transport, Green Belt, landscape, viability. It cannot be considered an afterthought.