Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14261

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

No evidence that higher housing target than minimum has been considered, which is insufficient to meet appropriate contribution to national target. The new version of the Standard Methodology proposed in the White Paper means the methodology used in the Plan will soon be obsolete.
There is no agreement between the Housing Market Area authorities and SMBC has no formal arrangement/ with neighbours notwithstanding Birmingham/Black Country shortfalls. No evidence of rationale to justify testing only 2000. Whilst Sustainability Appraisal of Growth Options identifies greater significant positive and negative effects, but concludes that Option 3 (additional 3000) should not generate further significant effects. Failure to provide Statements of Common Ground with neighbours means Duty to Cooperate not demonstrated.
Failure to safeguard Green Belt land for future development contrary to NPPF.

Object

Representation ID: 14264

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

Table at paragraph 225.
Sites with planning permission include sites refused/lapsed meaning 44 dwellings should be discounted. No evidence to show that sites identified in land availability assessments/Brownfield Land Register are deliverable or that these are not double counted with windfalls, so 277 dwellings should be discounted. Evidence for town centre sites not available. No evidence of testing of capacity of Chelmsley Wood town centre or that these are not double counted with windfalls, so 100 dwellings should be discounted. Carrying forward of SLP2013 sites not justified. No evidence to justify why a higher discount percentage than 10% not applied, or to support high reliance on windfalls. No evidence to show that UK Central capacity will be delivered in Plan period, as research into large complex sites indicates maximum of 800 dwellings. If addressed, total supply would be 12,361, 551 dwellings short of meeting local housing need and fail to meet 5 year housing supply

Object

Representation ID: 14265

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

(i) the need to remove additional land from the Green Belt for allocation for residential development to comply with the requirements of paragraph 136 of the NPPF and to meet local housing need; and
(ii) the need to identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs beyond the plan period to comply with the requirements of paragraph
139(c) of the NPPF.

Object

Representation ID: 14266

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Land north of Balsall Street Balsall Common should be allocated for residential development, as demonstrated by technical evidence and application of the Council’s site
selection methodology. Site performs less well than wider parcel in Green Belt Assessment. Sustainability Appraisal is opposed as site is smaller than AECOM76 and scoring for factors 4a Soils, 10 Landscape and 11 Greenspace should be re-assessed. Performs better in SA than allocated sites, other than Site BC2 Frog Lane. Site has lower impact of Green Belt than others to east, not reliant on by-pass or affected by HS2

Object

Representation ID: 14267

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Balsall Common chapter of Plan is not considered justified or effective. Land North of Balsall Street (Site 233) should be allocated as performs less well than wider parcel in Green Belt Assessment. Sustainability Appraisal is opposed as site is smaller than AECOM76 and scoring for factors 4a Soils, 10 Landscape and 11 Greenspace should be re-assessed. Performs better in SA than allocated sites, other than Site BC2 Frog Lane. Site has lower impact of Green Belt than others to east, not reliant on by-pass or affected by HS2

Object

Representation ID: 14269

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site BC1 Barratt’s Farm (875 dwellings) is not justified or effective. Land is partly higher performing in Green Belt Assessment and should have been 6 blue in site hierarchy criteria. Site performs poorly in Sustainability Appraisal with 3 significant negative effects. Site dependent on 2 major infrastructure projects, Relief Road and HS2 and delivery is uncertain

Object

Representation ID: 14270

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy BC2 is not considered justified or effective. Disagree with Green Belt Assessment of refined parcel 59 which performs a highly important role for Purpose 1. Site should have been categorised as 6 blue in site hierarchy. Concept masterplan shows lack of frontage and required habitat buffer, inadequate buffer to existing housing and landscape, ecological, flood risk and heritage constraints have potential to further impact
capacity.

Object

Representation ID: 14271

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy BC3 is not considered justified or effective. Disagree with Green Belt Assessment as refined parcel 57 performs a more important Green Belt role for Purposes 1 and 3. Site should be categorised as 6 blue in site hierarchy. Site performs poorly in Sustainability Appraisal and has significant ecological and heritage constraints which will restrict the area for development in terms of building height, capacity and access.

Object

Representation ID: 14272

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy BC4 is not considered justified or effective. Site inappropriately designated as brownfield as part agricultural and part greenfield. Site performs important Green Belt role. Incorrectly categorised in site hierarchy and should be at best 7 blue, not 3 green. No strong and defensible Green Belt boundary to east. Performs poorly in Sustainability Appraisal

Object

Representation ID: 14276

Received: 14/12/2020

Respondent: L&Q Estates - Land North of Balsall Street, Balsall Common

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy BC5 is not considered justified or effective. Site inappropriately designated as brownfield, as much of land is greenfield. Site performs an important Green Belt role protruding into the countryside and would result in unrestricted sprawl. Inappropriately identified as 3 green in site hierarchy. Site performs poorly in Sustainability Appraisal