Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 11148

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Sustainability Appraisal has not fairly considered reasonable alternatives in respect of levels of housing and employment growth. Higher levels of growth perform equally as well as the Plan’s preferred approach- Option 2. The Sustainability Appraisal demonstrates that a higher level of growth could be accommodated sustainably.

Only two spatial options (at either Balsall Common or land south of the A4) were put forward by the Council to assess the level of growth associated with Option 4 which could skew the conclusions of the Sustainability Appraisal.

The two spatial options were selected from the GBHMA Strategic Growth Study not the Council’s own SHELAA evidence. The Sustainability Appraisal should have assessed options at levels of growth above 16,000 dwellings utilising its own evidence base.

Local employment needs are being addressed through existing commitments and the allocation of Employment Site 20. No appraisal has been undertaken of any reasonable alternatives in relation to employment.

Object

Representation ID: 11149

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There are a number of inaccuracies in the specific assessment of Site 62 (AECOM 114 CG4 Stratford Road/Creynolds Lane) in the Sustainability Appraisal, including the effects in relation to ecology (should be neutral not negative), landscape sensitivity (should be neutral), amenity and noise (should be neutral) and access to leisure and play facilities. The site performs well and there are no significant adverse effects or reasons to not allocate the land.

Object

Representation ID: 11150

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan should contain strategic policies which set out the overall strategy for development. The absence of a clear Spatial Strategy and settlement hierarchy makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.

Object

Representation ID: 11151

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Options A to D propose growth around Shirley Town Centre and the A34 corridor. The A34 Corridor runs from Junction 4 of the M42 to the northern boundary of the Borough.

Certain sites might fall within Options E to G as well as under Options A to D. It is unclear whether the three further criteria introduced at paragraph 65 which inform the location of growth take precedence over Options A to G.

Object

Representation ID: 11152

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The site selection methodology which is set out in the Topic Paper departs from national policy in relation to Green Belt. It does not first consider previously developed land and land well served by public transport, and it makes no reference to whether the loss of Green Belt can be offset through compensatory improvements to the remaining Green Belt. The implications of the Spatial Strategy and site selection methodology are that Green Belt sites that perform well in relation to national policy were not selected.

Object

Representation ID: 11153

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 62 (Land west of Stratford Road) is well served by public transport and should be regarded as having a ‘High’ Accessibility Score within the Council’s evidence.

The site offers compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. Releasing the site from the green belt would not lead to any meaningful reduction in distances between neighbouring towns.

It is inconsistent and unreasonable for Site 62 to be assessed as ‘red’ with severe impacts in the Landscape Character Assessment, as proposed allocated sites within the same Assessment area are assessed as ‘green’.

Stratford Road is no longer an appropriate boundary for the Green Belt. Properties on the northern side of Creynolds Lane should not be designated in the Green Belt.

Object

Representation ID: 11154

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P17 makes no reference to safeguarding land within the Green Belt. The Plan should be safeguarding land in order to ensure there is a degree of permanence to the boundaries proposed within this Plan in accordance with the National Planning Policy Framework.

Object

Representation ID: 11155

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Solihull Strategic Green Belt Assessment does not make recommendations for amendments to the Green Belt boundary but that it forms the basis for more detailed assessment. There is no evidence of any more detailed assessment. The Assessment was prepared in 2016 and therefore pre-dates the current version of the National Planning Policy Framework.

There are inaccuracies in relation to the assessment of Site 62 (Parcel RP62). Development of the site would not result in the gap between Solihull and Cheswick Green being any smaller than exists at present.

The Strategic Green Belt Assessment takes no account of any compensatory improvements to the remaining Green Belt that may arise from the release of land. Any release of the land from the Green Belt at Site 62 would give an injection of resources that would enable investment in improving facilities.

Object

Representation ID: 11156

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P3 fails to match the spatial strategy of the Plan and has no regard to the evidence of the HEDNA in relation to supply and demand along the A34 corridor.

It is unsound for the Council to suggest that an early review of the Plan is an appropriate response in addressing unmet needs- deferring cross-boundary strategic matters.

Other factors need to be taken into consideration in informing the employment land requirement- the existing stock available, pattern of supply, and evidence of market demand.

The land currently available on the five existing allocations is less than what is stated within the Plan. The existing supply amounts to 6.4ha of employment land on three sites, but soon to fall to 3.4ha on two sites.

The delivery of two large employment allocations is uncertain and their trajectory is likely to be much later in the plan period.

Object

Representation ID: 11157

Received: 14/12/2020

Respondent: IM Properties - Land west of Stratford Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council need to consider the Government’ stated intention to change the method for calculating Local Housing Need.