Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13904

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

Given that none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that P17A is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.

Object

Representation ID: 13905

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 8 requires well -designed new and improved open space and their maintenance as an integral part of new development (including care homes). It is unclear if this requirement is for public or private open space.
Whilst open space provision is included within the viability testing for residential sites this is not the case for care homes where the Section 106 buffer only includes biodiversity net gain and primary care contributions.
Given specialist housing for older people serves a specific need, and there is a requirement set out within point 12, the requirement for care homes to provide for open space should be deleted.
Given the users of specialist housing for older people would have limited need for some types of open space, if this is retained, it should be clarified what provision is required.

Object

Representation ID: 13906

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

Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development (especially specialist housing for older people) unviable.

Object

Representation ID: 13907

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Concern that the Site will not be delivered within the required period, given the infrastructure requirements and land assembly issues.
No clear plan how the relief road will be delivered early as funded by CIL payments, which are only collected after a scheme has been commenced (or later).
Lack of employment within the village will increase the need to travel, which raises questions as to the suitability of the settlement to provide for 31% of all proposed allocations.
Question whether developments can be delivered in Balsall Common, taking into account the infrastructure requirements and funding. Additional sites may be needed.

Object

Representation ID: 13915

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

This Site proposes the redevelopment of the existing sports pitches and the current land use also contains a Local Wildlife Site and designated Ancient Woodland as well as historic hedgerows.
SMBC should ensure their assessments are fair, robust and objective and the site is sequentially acceptable when weighed against others.
The work required in connection with replacement of the displaced pitches has not moved forward since the previous consultation.
SMBC should ensure that replacement pitches of equivalent or better quality in a suitable location are shown. This should be shown to be feasible before the Site is allocated for development. Another option would be to reduce the capacity of the Site in order to retain the pitches.

Object

Representation ID: 13916

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is noted that the policy states that this may be suitable for specialist housing for older people, and has been subject to a recently dismissed appeal for such uses. However, given the Site is allocated for unrestricted housing, and is below the 300 home threshold of Policy P4e, there is no guaranteed this will include any specialist provision and this should not be relied upon.

Object

Representation ID: 13917

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 allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable.
However, this pre-judges any application, for which the detail is not know, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.

Object

Representation ID: 14110

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 affordable provision for C2 development is held within the justification rather than within the policy.

It is not specifically defined what types of C2 development will require to provide affordable housing (either on-site or off-site). The reference to ‘self-contained units’ does not allow for any distinction between the types of C2 uses.

The Viability Study only tests one C2 typology which is a 30 (one and two bedroom) unit retirement apartment housing scheme and it is unclear the level of communal area that has been assumed. The viability study scenarios also show that this is not viable when CIL is also included.

The HEDNA does not justify that 40% affordable provision is required on C2 uses and that the affordable need is lower. This indicates that requiring a 40% affordable housing obligation would be unjustified. This point is further evidenced by the Older People’s Housing Need Report (January 2020) produced by Barton Willmore.

NPPG Paragraph 64 confirms that specialist accommodation is exempt from the requirement for 10% of homes (as part of the affordable housing contribution) are to be made available for affordable home ownership.

Object

Representation ID: 14159

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

P4E
1. The HEDNA (2020) significantly underestimates need, principally because it assumes provision rates that are too low.
2. The HEDNA significantly underestimates the proportionate requirement from owner-occupiers for specialist provision
3. There is a clear immediate requirement for specialist older people’s housing within Solihull. Greater emphasis should be placed on increasing the supply of specialist housing that suits older people’s needs and preferences.
4. By providing housing more suitable to this age group that addresses its needs and preferences (for leasehold accommodation in particular), the family homes that they presently under occupy will become available to the market, in addition to new build family homes, thereby addressing the significant need for family housing that the Solihull Local Plan seeks to address.
5. P4E will not deliver the level of provision required. The policy does not actually guarantee deliver of any specialist housing for older people. There is a need to allocate specific sites for specialist provision.
6. The Policy seeks to provide for specialist housing for both older and disabled people. This conflates the two different and specific needs. The requirement for M4(2) or M4(3) housing does not provide specialist housing for older people as it will not create the types of housing needed as set out by the HEDNA
7. These additional requirements are not seen as viable within the Council’s viability testing. As such, if this requirement is to be retained for specialist housing, it
should be evidenced that it will not impact upon viability/deliverability. Wording should also be
included setting out it may not be required/feasible in certain instances
8. The Policy also requires provision of specialist accommodation in line with the SMBC’s most up to date statement of need. This does not appear to be available. We would question how the policy complies with Paragraph 34 of the NPPF in showing what contributions will be expected
9. The rate of delivery also needs to be considered. The HEDNA sets out that the majority of the shortfall is needed by 2026. SMBC’s stepped trajectory assumes the majority of housing will be delivered during Phases II and II of the Plan Period (2026-2036). As such, there is a risk with the current mechanism that any specialist housing delivered will not come forward in line with when the need occurs.
10. The Site at Jacobean Lane is well placed to provide for this need, and the technical information shows it can be delivered early in the Plan Period.

Object

Representation ID: 15060

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

Housing Need evidence in 2020 HEDNA:
- PPG state that SM only minimum
- Expected growth at UKC Hub meets criteria in PPG to increase SM
- HEDNA state 13,000 jobs at UKC Hub, over 10,000 Experian baseline
- HEDNA assume only 25% of jobs occupied by Solihull residents.
- Barton Willmore carried out own analysis at 0.93 and 0.98 commuting ratios
- Demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario
- HEDNA identifies acute affordable housing need in Borough, BW analysis conclude HEDNA housing need should increase to meet this component of need.