Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14387

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P1 should include the amount of residential development to be delivered by the hub and specific reference to where it will be located to provide certainty in terms of the context and justification for the need to deliver additional land for housing

Object

Representation ID: 14390

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4A should be worded more flexibly to account for any further changes which the Government may make (for example in relation to ‘first homes’).
The scale of affordable housing required highlights the duty of Solihull in needing to deliver additional housing over and above the standard method baseline and the requirement currently being proposed.

Object

Representation ID: 14392

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4B is supported, however as shown through the attached paper on housing (Appendix 2) 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.

Object

Representation ID: 14394

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The principle of Policy P4C 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: 14395

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Taking into account all of the other policy demands upon delivering housing schemes, delivery could be seriously compromised by the requirement of Policy P4D. Given that the current system now generally discourages 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. SMBC should not be relying 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.

Object

Representation ID: 14397

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is understood that Policy P4E is based on the recommendations of the HEDNA, and the flexibility in the policy is welcomed in principle to allow case-specific matters to be considered. However, 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: 14408

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to quantum of growth in Policy P5, as 2,105 dwellings is insufficient to address the housing market area shortfall. Plan should test the provision of a minimum of 11,500 additional homes to avoid creating unsustainable patterns of growth and commuting across the HMA.
The housing requirement should be expressed as a minimum requirement, inclusive of any cross-boundary provision to provide certainty as set out in NPPF paragraph 65. Proposed approach equating provision with the difference between local housing need and supply is unsound.
SMBC should allocate around 20% more housing land than required to deliver the housing requirement to provide the necessary flexibility for non-delivery of sites/ boost significantly the supply of housing, equating to a further 3,000 dwellings.
Supply is based upon the local housing need and does not factor any uplift necessary to ensure delivery of the cross boundary provision. The 5 year housing land supply should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
The windfall allowance is not supported as not Plan-led, prevents planning for necessary infrastructure, likely to be overestimate and is unsound.
No evidence to justify blanket introduction of nationally described space standards.
Whilst flexibility on densities is supported, the implications of various policy standards is uncertain and no evidence is provided that this has been taken into account

Object

Representation ID: 14415

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Given the significant and unresolved housing need across the housing market area stretching in to the latter years of the plan period, and far reaching consequences in relation to the growth agenda as set out by the White Paper, Policy P17 2 should be amended to safeguard land for future needs by releasing further Green Belt.

Object

Representation ID: 14416

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P17A should be removed, as it is for the Plan to demonstrate compensatory provision relative to the Green Belt release, not for the developer to undertake this exercise at the planning application stage.

Object

Representation ID: 14418

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Omission Site 195/528 should be allocated for residential development of 9 hectares consisting of a range of dwelling types and sizes including Extra Care residential development and affordable housing, together with public open space and private land. Site is accessible, close to significant employment areas, available, suitable and achievable.
Dispute conclusions of Site Assessment. Green Belt is moderately performing and clear physical boundaries can be provided, with landscape and green infrastructure to provide further containment. Site would have low impact on criteria in SHELAA and Sustainability Appraisal.
As a minimum, site should be safeguarded for future needs, but given urgent unmet needs should be allocated now