Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14873

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Solihull has offered up a figure of around 2,000 homes but has provided no links to the evidence nor any rationale behind this offer.
This is welcomed as a starting point, but as the attached Paper (Pegasus Group Housing and Economic Growth Paper Appendix 2) demonstrates, the figure should be far higher than this, with at least 11,500 additional homes being provided for to address the shortfall.
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 also appears to contradict the approach taken by other LPAs within the HMA who have advanced local plan reviews

Object

Representation ID: 14874

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The explanatory text to the policy suggests a somewhat 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’.
However, these figures are only included in the supporting text. 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 is clearly evidenced, and to provide certainty in terms of the context and justification for the need to deliver additional land for housing.

Object

Representation ID: 14875

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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’).

Support

Representation ID: 14876

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

This policy 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.

Support

Representation ID: 14877

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

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: 14878

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

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 to make a 5% contribution to Self and Custom Build Housing (offered for sale with outline planning permission, fully serviced to the boundary, with unconstrained access to the highway. The plots would be offered for sale for a period of 12 months to those registered on Solihull’s Self and Custom-build Housing Register)
Taking into account all of the other policy demands upon delivering housing schemes, delivery could be seriously compromised by such a requirement. The flexibility provided within the policy, which enables case by case assessment of matters such as viability and the impact upon other requirements of the scheme (such as the ability to deliver an appropriate housing mix) sounds sensible in principle. However, this approach would only be workable if such detailed consideration on a case by case basis was to be allowed at the planning application state.
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.
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.

Object

Representation ID: 14879

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is understood that these are the recommendations of the HEDNA, 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 decisiontaking 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: 14880

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the quantum of growth, L&Q Estates object as the 2,105 home additional contribution, whilst welcomed as a starting point, is simply not sufficient to address the shortfall in the wider Greater Birmingham and Black Country Housing Market Area (‘the HMA). The Paper (Appendix 2) concludes that the Solihull Local Plan should be, at the very least, testing the provision of a minimum of 11,500 additional homes to address the unmet need across the HMA instead of the circa 2,000 it is currently proposing.
Policy P5 falls short of committing to the delivery of 2,105 dwellings to meet needs arising within the wider HMA – instead this element of the full housing requirement equates to the flexibility in supply proposed. Such an approach is not consistent with national policy and the firm commitment that should be made in order to satisfy the duty-to-cooperate.
Trajectory - The housing land supply position is based upon the LHN and does not factor any uplift necessary 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.
Windfall - The inclusion of a windfall allowance of 200 units per annum in respect of supply is not supported. This equates to nearly 20% of the proposed housing land supply to 2036. If the Council is promoting a fully Plan-led approach to delivering growth, then there is no need to include an allowance in the housing supply from windfall sites. The Council references the increase in windfall supply within the Borough since 1992.
Nationally Described Space Standards - There does not appear to be any evidence to justify a blanket introduction of such standards, and the viability assessment simply states ‘applies to all sites’ (page 9). The policy is clearly not compliant with national guidance which requires evidence to justify policy.
Density - The flexibility afforded to the section of Policy P5 on density is supported. However, it is not certain how such a policy would be impacted should all of the various standards be implemented, including Nationally Described Space Standards. The Council should be demonstrating how this policy will be implemented in practice, and should be providing evidence to show that it has allocated enough land to deliver the stated number of homes

Object

Representation ID: 14881

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The MSA boundary extends to the edge of the southernmost part of Meriden, encompassing our client’s site off Berkswell Road which is being promoted as an extension to the existing settlement. It is considered inappropriate to allocate a minerals safeguarding area which runs so close to the boundary of an existing settlement. It would not be appropriate for minerals extraction to operate so close to existing residential development, nor would it be appropriate to potentially sterilise land which could provide much needed housing growth in a sustainable location

Object

Representation ID: 14882

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Part 2 of this policy references Green Belt designation as identified on the Policies Map. However, this 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 as set out elsewhere in these representations. The Policies Map would therefore need to reflect this.
As set out in the Housing and Economic Growth Paper at Appendix 2, it is clear that there is a significant and unresolved 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. 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.