Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14286

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

Duty to Cooperate Comments - No information on any agreement reached on key strategic matters with partner local authorities or key stakeholders. No Statements of Common Ground are evident. No evidence of why the figure of 2000 has been arrived at.
Statements of Common Ground should be readily available showing that partner authorities are in agreement with any approach being undertaken. The apparent lack of these at this present time is a major issue and implies that there is no agreement. The approach taken by Solihull appears to contradict the approach taken by other LPAs within the HMA who have advanced local plan reviews. This needs to be explored in detail as there are major implications for the plan’s legal compliance otherwise.

Object

Representation ID: 14287

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Explanatory text suggests a confused situation in relation to the delivery of residential development. Paragraph 85 advises that the Hub Framework Plan (2018) could provide ‘up to 4,000 homes’ to 2047 ‘with about 1,000 delivered by 2033’, but that the Urban Growth Company in its Hub Growth and Infrastructure Vision (2019) estimates ‘up to 5,000 new homes’. There needs to be a commitment in policy to quantifying the amount of residential development to be delivered by the hub, and specific referencing to the detail as to where this should go to ensure that the plan’s deliverability.

Support

Representation ID: 14288

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

The flexible wording of the policy, including references to viability, is welcomed. However, it is recommended that further flexibility is built in the policy to account for any further changes which the Government may make (for example in relation to ‘first homes’).
It should be noted that the sheer scale of the affordable housing need highlights the duty of Solihull in needing to deliver additional housing over and above the standard method baseline and the requirement currently being proposed.

Support

Representation ID: 14289

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

This policy is supported, however the scale of the need is much higher than that currently being planned for: not planning sufficiently for affordable housing as part of an increased housing requirement at the necessary strategic scale will place more pressure upon local communities to allow exceptions sites. ‘Exceptions’ should be just that: occasional sites to meet a particular local need, not further sites to address deficiencies in a strategic borough-wide plan.

Support

Representation ID: 14290

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

The principle of the policy is supported, however this needs to be considered in the context of a greatly increased housing requirement over the plan period, as set out in the response to Policy P5 (Provision of Land for Housing) and the accompanying Housing and Economic Growth Paper (Appendix 2).

Object

Representation ID: 14291

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Taking into account all of the other policy demands, delivery could be seriously compromised by the requirements of the policy. The flexibility provided sounds sensible in principle. However, this would only be workable detailed considerations were allowed at the planning application state.
As the current system discourages the debate on viability at the decision-taking stage, with such matters expected to be addressed when plan-making, it cannot be assumed that this policy would work in practice.
There is nothing in the explanatory text to demonstrate how the matter has been considered in more detail at this point. The Local Authority cannot simply rely upon developers to provide for all self and custom-build housing in fulfilment of its legal duty and should be exploring other options for delivery. Without evidence of other options having been thoroughly explored, L&Q Estates object to this policy.

Support

Representation ID: 14292

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

The recommendations of the HEDNA are taken forward, and the flexibility in the policy is welcomed in principle to allow case-specific matters to be considered. However, as with the policy on self and custom-build homes, the current system now generally discourages debate on viability at the decision-taking stage, with such matters expected to be addressed when plan-making. Therefore, it cannot necessarily be assumed that this policy would work in practice. Further justification is required to provide the necessarily elaboration.

Object

Representation ID: 14294

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

2105 contribution the Housing Market Area shortfall is not sufficient. Significantly more housing land is required to meet needs and provide flexibility for non-delivery of sites (see attached Housing and Economic Growth Paper).
Trajectory: No uplift included to ensure the delivery of the cross boundary provision. The 5 year housing land supply calculation should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
Over-reliance on windfall and no certainty of delivery. A supply strategy based upon a heavy windfall allowance is unsound and does not allow for appropriate planning of infrastructure or form a robust spatial strategy.
Technical Housing Standards are optional and can only be introduced where justified. Plan provides no evidence.
Density: Flexibility is supported but uncertainty about how the policy would be impacted should all of the various standards be implemented. Evidence required to show that enough land is allocated to deliver the stated number of homes, taking account the standards.

Object

Representation ID: 14295

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy must be looked at ‘in the round’ with the other matters which the plan must address (including the need to release further Green Belt to address unmet residential need over the plan period). There is a significant and unresolved need across the housing market area stretching in to the latter years of the plan period. It is clearly necessary for the plan to safeguard land, which could be brought forward as a series of reserve options to provide flexibility and a balanced approach for delivering sustainable development both within and beyond the plan period.

Object

Representation ID: 14296

Received: 14/12/2020

Respondent: L&Q Estates - Land at Four Ashes Road Dorridge

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy should be removed. This is a matter to be tested as part of the justification for providing the Exceptional Circumstances to release sites from the Green Belt at the plan- making stage. The Council needs to demonstrate compensatory provision relative to the Green Belt release, it is not for the developer to undertake this exercise at the planning application stage.