Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13894

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site 502 should be allocated specifically as a site suitable for specialist housing for older people in need of care (over 55s), given the evidenced need in Solihull. The site is suitable, available and deliverable which will meet the housing needs of the District, both general and specialist, as well as the wider region. The landscape and area can be enhanced through good urban design and a strong landscape-led approach. It is feasible to provide a footpath from Jacobean Lane to Warwick Road, and the sustainable transport options that are available there. A concept masterplan for the site is provided.

Object

Representation ID: 13895

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The introduction should reference the diverse needs of the population within Paragraph 8 in order to ensure sustainable development.
Reallocation of sites in Solihull Local Plan (December 2013) without any justification as to their deliverability, is an incorrect approach.
With regard to Neighbourhood Plans, the NPPF sets out that the most recently adopted Policies will take precedence. The LPR will take precedence upon adoption.

Object

Representation ID: 13896

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Challenge B – Bullet point 6 should be split into separate points with the housing needs for older people, including the need for a range of typologies, as a separate bullet point. This is in order to not conflate two separate issues that the plan will have to address.
Challenge E - Should reference meeting other types of development beyond just meeting housing needs.
Challenge J -should reference the requirement for high quality housing and accommodation require for elderly people within its objectives.

Object

Representation ID: 13897

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Meeting the housing needs of older people should be expressly included within the SMBC’s vision.
Given Paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positive.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.

Object

Representation ID: 13898

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to the specific housing mix requirements set out by this policy which is weighted towards smaller (3 bedroom or fewer) houses. This approach does not take into account the length of the Plan Period and that market requirements may change over this period. Further, the specific requirement does not accord with Paragraph 62 of the NPPF which seeks to create mixed and balanced communities.
As such, we consider that a more pragmatic and flexible approach is taken, utilising latest market evidence. This is the approach taking for other matters wi thin this policy, and should be extended to the mix.

Object

Representation ID: 13899

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified when considering data from the 2020 AMR. This is far in excess of the need shown and the Council should consider providing specific site/allocations to meet this need, in line with Paragraph 61 of the NPPF.
The provision of such plots on strategic -size housing sites is likely not what those on the register are seeking, meaning they are left empty which could delay the delivery of housing.
This policy should be deleted, and SMBC should either allocate specific provision of this need, or offer general support for this type of housing but not set specific thresholds.

Object

Representation ID: 13900

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.

Object

Representation ID: 13901

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.

Object

Representation ID: 13902

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.

Object

Representation ID: 13903

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Point 1 - reference to best and most versatile agricultural land (BMVAL) within a Green Belt policy seeks to conflate two separate issues. The NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL.
Point 4 – In considering very special circumstances, a further factor should include providing for a clearly evidenced need. For specialised housing for older people, this factor was taken into account in two recent appeals.
Point 5 –Requirement goes beyond the scope of Green Belt as set out in the NPPF.