Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14075

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The Vision and its supporting text makes reference to UK Central and is drafted positively in accordance with paragraph 15 of the NPPF. These principles are supported however this section could be improved by making the role and purpose of UK Central and the Hub Area within it clearer as it represents such as important component of the plan. This should reflect both the continued success of key economic assets and the additional growth that can be attracted by virtue of the new allocations including Arden Cross, which will have a sub-regional role

Object

Representation ID: 14079

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The spatial strategy plan at paragraph 70 of the Submission Draft illustrates Arden Cross intersected by HS2 within the UKC Hub Area and removed from the Green Belt. This is welcomed and strongly supported by ACL.
The spatial strategy should distinguish more clearly between economic and housing growth and how both have been accommodated. It should identify Growth Option E (UK Central Hub Area and HS2) as a core component of the spatial strategy, as this is a strategic choice to capitalise on the arrival of HS2 and to support the key economic assets in this area.
This would bring the spatial strategy more into line with paragraph 35(b) of the NPPF

Object

Representation ID: 14085

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The policy and its supporting text need updating and editing for consistency with new Policy UK1 and to provide clarity on the criteria against which proposals will be judged.
There is interchanging reference to ‘UK Central Solihull’ and ‘UK Central Solihull Hub Area’, both of which have different geographies. It is recommended that each is clearly defined in the pre-text to avoid misinterpretation of the scope of Policy P1. Reference to Blythe Valley, North Solihull and Solihull Town Centre should be contained to the opening section of this chapter as each is subject to separate planning policy.

The pre text to policy P1 is broadly supported however references to outdated documents should be removed. The policy should refer to WMCA’s Recharge the West Midlands (June 2020), the updated Midlands HS2 Growth Strategy (November 2020) published since the Submission Draft was finalised, and the Council’s own Economic Recovery Plan (May 2020).

A number of key development principles in the policy are drawn from a number of UGC non statutory documents. Whilst supporting the thrust of these documents, would urge consistency and clarity in how these policies will be applied in practice, in particular through a review, ideally in liaison with ACL and others, before final submission of the plan.
The following site specific elements in P1 relating to Arden Cross should be addressed: Passenger facilities no longer feature in the Birmingham Airport Masterplan 2018 and should be deleted. The phasing set out in the Hub Growth and Infrastructure Plan (January 2018) is now superceded and does not align with the current LPR plan period (2036).
The reference to the preparation of an SPD needs further clarification. It was originally envisaged there would be an update and formalisation of the Hub Framework Plan to be prepared alongside the local plan. Given the subsequent preparation of the Arden Cross Masterplan by ACL, and the more detailed combination of policies P1 and UK1, the purpose and timing of an SPD needs clarifying.

Object

Representation ID: 14087

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Supports specific policy for allocation but needs editing for consistency and to avoid overlap with P1. Following clarifications / amendments are needed:
A distinction needs to be made on the difference in purpose and effect between Policy P1 and Policy UK1.
The pre-text and explanatory text supporting the policy is too lengthy. There is merit in rationalising the policy context to avoid repetition and inconsistency
Reference to the provision of 2,500 new homes at UKC Hub over the plan period at paragraph 830 of the Submission Draft contradicts the figure of 2,740 quoted elsewhere in the plan. A thorough review of all quoted figures (including those at paragraph 828) should be undertaken to ensure accuracy and consistency with the evidence base.
The references to ‘garden community’ principles at paragraph 838 and 842 is misleading and confusing given the array of other development principles drawn from the UGC documents and Arden Cross masterplan. Some simplification would assist clarity when applying the policy.
There is overlap between the place-making principles and development principles at Policy UK1 (2) and (3) and these should be rationalised to accord with the Arden Cross Masterplan and Policy P1.
In general, there are far too many policy principles (23), which is overly prescriptive for decision-making purposes, particularly when accounting for the development principles in Policy P1.
The Arden Cross Masterplan, being the more recent and subject to public consultation, should take precedence as forming the guiding principles behind Policy UK1.
The previous iteration of the UKC Topic Paper should be updated to rationalise and reduce the amount of explanatory text for Policy UK1 and Policy P1.

It is not clear why reference is made to the preparation of an SPD for UKC Hub, including Arden Cross, in Policy P1 but omitted from Policy UK1. Clarification is needed on the role and purpose of an SPD at this stage.
The proposed allocation should be renamed ‘Policy UK1 – Arden Cross’ for the purpose of accuracy.

Object

Representation ID: 14093

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

ACL acknowledges the policy requirement for Green Belt compensation in accordance with paragraph 138 of the NPPF.
The proportionality of any compensatory improvements to Green Belt should be consistent with its performance in the SGBA, the degree to which its development has already been accepted, and the provision of on-site compensation in the form of green and blue infrastructure and public accessibility. The hierarchical approach set out in Policy P17A using the ‘concept masterplans’ for most sites identified in the plan is supported in principle and reference should therefore be made to the Arden Cross Masterplan.
It is considered that these measures proposed in the masterplan are proportionate and will significantly contribute to the protection and enhancement of the Green Belt’s environmental quality and accessibility. ACL welcomes further discussions with SMBC on the scope of compensatory improvements in line with the PPG.
It is recommended that Policy P17A(4) incorporates reference to viability given the possible tension with other costs associated with delivering physical and social infrastructure via CIL and/or Section 106 obligations, in accordance with paragraph 57 of the NPPF.

Support

Representation ID: 14094

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

ACL considers the evidence base to be sound, and supports the policy framework established for the Hub Area and Arden Cross site itself. To ensure that policies are clear and unambiguous, and therefore ‘effective’ for the purpose of the test of soundness, we will be working with SMBC to prepare a Statement of Common Ground. This will contribute towards the approach to the provision of strategic infrastructure and developer contributions in accordance with Policy21

Object

Representation ID: 14095

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The table accompanying this policy identifies Land at HS2 Interchange (Policy P1 and UK1) as providing circa 140ha.
The Housing and Economic Development Needs Assessment (“HEDNA”) dated October 2020 sets out the assumed employment floorspace figures derived from the UGC and Arden Cross masterplanning work.
Paragraph 145 of the plan states that “evidence indicates that Site UK1 is likely to have a role to play in meeting local employment needs, especially later in the Plan period.” This refers to evidence in the HEDNA regarding the upper end of the need for office accommodation which ACL considers to be realistic

Support

Representation ID: 14096

Received: 14/12/2020

Respondent: Arden Cross Ltd

Agent: Turley

The contribution of Arden Cross to the housing supply is not specified in Policy P5 although the table after paragraph 222 includes as category 9: UK Central Hub Area by 2036 – 2,740. The 500 homes from Arden Cross is included in this figure and can be included in the trajectory from 2026.
The housing requirement assumptions in the HEDNA anticipate a positive impact from new supply on improving affordability and, as a result, the likelihood of younger households being able to access housing. It also builds in a reasonable interpretation of the latest 2018 sub-national population projections. This is welcomed by ACL as the residential component of Arden Cross is expected to appeal to and serve a demographic which sees the benefits of the location.
The development of Arden Cross will be delivered in line with the principles set out at Policy P5(6) in relation to density as ACL intends to maximise the efficient use of Arden Cross given it will be well served by public transport in line paragraph 123(a) of the NPPF. The table after paragraph 240 indicates the UKC Hub Area being developed at comparable densities to the Town Centre between 40dph and 150dph