Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14616

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The strategy lacks focus and is a random combination of locations based on multiple growth options rather than a coherent strategy; many sites are large or complex
and need new infrastructure or relocation of existing uses that makes them slow to deliver; smaller sites in sustainable villages can redress an over reliance on large or complex sites and will deliver the housing requirement. There is greater potential in the villages within the Borough than currently recognised, particularly in respect of Meriden, which is in a highly
accessible location with a good level of services including a primary school that can easily
be extended to accommodate increased capacity.
The spatial strategy in the DSLP appears to be a combination of every option set out in the Scoping consultation rather than a focus on any specific elements such as high frequency public transport corridors and the expansion of sustainable settlements. As a result, the strategy lacks focus and has become a collection of approaches driven largely now by where land is available. A range of types of sites and locations are needed to allow the best chance of the housing requirement being met. The proposed allocations do provide a range from the urban area, edge of urban area, UKC and village sites, but many are large scale and will need new infrastructure to allow site delivery or have existing uses such as business or sports that need relocating. Smaller scale greenfield sites should be identified to ensure the delivery of housing in the short term to avoid any
shortfall in housing land supply. Only 2,135 of the total allocation of 7,700 are sites that can be easily delivered, which equates to just 27%. There is greater potential in the villages for unconstrained sites than currently acknowledged by the Local Plan Strategy. For example, land north of Main Road Meriden

Object

Representation ID: 14647

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Comments on Draft topic paper on overall approach

There is no explanation why only rail and not bus is included as high frequency travel corridors in rural areas within Option A and no explanation why certain villages are categorized as limited or significant expansion within Options F and G.
Growth Option A – High Frequency Public Transport Corridors misses an opportunity as it refers solely to rail in the rural areas. Meriden has a high frequency bus service, as well as a local service, between Coventry and Birmingham. It is an express service with limited stops, it runs approximately every 20 minutes almost 24 hours a day, 7 days a week and there is a bus stop within 100m walking distance of the site proposed north of Main Road. The bus runs via the NEC and airport and will pass the HS2 interchange station presenting many employment opportunities. Meriden is a settlement that has a good level of services and facilities and is highly accessible. Growth Option F allows for the settlement to take proportionate growth and IM Land consider it is suitable and capable of accommodating a higher level of growth than the 100 houses proposed.
The Topic Paper concludes in respect of Meriden village, a medium to high accessibility rating and land to the east moderately performing in Green Belt terms but it is only included for limited expansion. The land promoted north of Main Road lies to the east so is not covered by mineral safeguarding constraint.
There is however no explanation in the Topic Paper or in the Topic Paper 4 of the previous consultation plan how the rural settlements have been split into two groups between Growth Options F and G as either for limited expansion or significant expansion of rural settlements.
It would appear that for significant expansion a settlement could be highly accessible or have a wider range of services including a secondary school, it does not have to have both. Dickens Heath for example is not as accessible as Meriden and has no secondary school. The Topic Paper provides a very similar assessment to that of Meriden but on capacity finds that Dickens Heath has capacity for significant growth. It gives no explanation how it reaches the conclusion. The accessibility study finds sites in Meriden to be highly accessible scoring higher than Dickens Heath. Meriden has a wide range of facilities and services. It is suggested that the settlement is constrained by lack of capacity at the primary school however no evidence has been out forward to comment on this. IM Land has therefore sought its own evidence and Turley have
prepared a report Education Assessment. This indicates that the primary school is already operating over capacity and neither the allocation of 100 houses in Policy ME1 or the land north of Main Road Meriden can be accommodated without school expansion. The level of demand for primary places generated by Policy ME1 West of Meriden (100 houses) and land north of Main Road (100 houses) together at 50 primary school places could be accommodated through expansion of the existing school. Meriden is capable of taking additional growth over and above that proposed and has site opportunities potentially more accessible and less constrained than other locations in the Borough.

Object

Representation ID: 14665

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy is neither justified or effective as the Local Plan is over reliant on the housing numbers that can be delivered from UK Central Hub Area in the plan period. It is unclear what part is being referred to as part of UKC.
It has been assumed that across the whole UKC Solihull Hub Area there will be 2,740 dwellings coming forward in the plan period split 2,240 at the NEC and 500
at Arden Cross. It is unclear why North Solihull, the Town Centre and Blythe Valley are not included as they are also stated to be UKC. Furthermore, elsewhere in the DSLP completions of 2,500 are stated, not 2,740 which needs clarification. Further evidence is needed to justify the delivery timescale and the trajectory for the housing numbers. The number of houses to be completed in the plan period from NEC and Arden Cross is too high. Even if the necessary road and social infrastructure is available to allow housing completions
from 2026, this assumes a high completion rate of 274 houses per annum. The nature of the developments being largely apartment based means it is more likely, the whole amount will be delivered on block at the end of the plan period leaving a shortfall early on.This could leave a significant shortfall in delivery to meet OAN and housing delivery in the first 5 years of the Local Plan period. Therefore, to add flexibility to the plan, the number of completion at UKC Hub should be reduced and a smaller scale allocation north of Main Road Meriden should be added to compensate for
this overreliance on large sites dependent on significant infrastructure and to ensure housing need is met as set out above through the plan period.

Object

Representation ID: 14677

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst IM Land are
supportive of the principle of self and custom build, it is considered a better approach would be to allocate specific smaller sites for up to 5 dwellings for self-build rather than require a proportion of general housing allocations to accommodate this provision. The nature of self and custom build is that it is better related to smaller more individual sites to reflect individual and unique design rather than being part of larger housing developments. NPPG offers other ways local authorities can facilitate self build such as such using LA land or other land suitable for housing in the ownership of other landowners. The Policy is unsound as it may not be effective in delivering suitable self-build and custom
housing. The Policy should be reconsidered.

Object

Representation ID: 14693

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst IM Land are committed to meeting needs for all, the requirements for specialist housing are set out in Building Regulations and do not need to be repeated in plan policies. It is recognised there are optional national standards over and above the minimum Building Regulations requirement that can be applied through plan policy where there is a need. National planning guidance highlights the need to consider a range of factors such as such as accessibility
and adaptability of the existing stock, needs across tenures and impact on viability as well
as site specific matters such as flood risk and topography. The Council point to the HEDNA for some evidence and Policy P4E is to be applied flexibility taking into account site specific factors and viability, but more detail is required to justify the blanket approach of Policy P4E that relates to all major sites for parts 2 and 3 and sites over 300 for part 4.

Object

Representation ID: 14698

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario.
Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered. Additional unmet need will be created post 2031.

Support

Representation ID: 14699

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

IM Land support removal of the Minerals Safeguarding Area from the Plan. The Minerals safeguarding topic paper accords with the case submitted on behalf of IM Land to the previous stages of the local plan preparation in that as Daw Mill Colliery from which coal was being extracted, has closed and there are no plans for working of the coal resource. It also concurs that alternative sources of energy are now sought to meet climate change targets. The minerals safeguarding area for coal is rightly no longer in the Plan.

Object

Representation ID: 14872

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation is not justified or effective as the site does not have the capacity to accommodate this amount of housing without significant harm to the landscape character on the approach into the settlement, and through loss of vegetation and impact on its designation as a potential Local Wildlife Site. To achieve 100 dwellings a density of 50 dwellings per hectare would be needed which conflicts with the council’s approach to density. It would require 3 storey blocks that would be difficult to screen.
Despite part of the site being identified as an area of flood risk the council’s site analysis does not adequately deal with flood risk. There is a strong likelihood that less units will be delivered or the density will increase further
to accommodate 100 houses. Site ME1 was originally planned for 50 dwellings which was already high given the constraints such as its designation as a Potential Local Wildlife Site, its significant trees and water body; and its prominent location on the approach to the village. The Landscape and Visual Appraisal with Green Belt Review August 2020 prepared for IM Land identifies that the site is well vegetated and forms part of the
green gateway to Meriden. High density development within this parcel of land on the approach
to Meriden would be uncharacteristic.
Site constraints restrict its capacity, 1ha of 4 ha site is designated for public open space and there is no reference to the pLWS. Site area is considered to be 3ha rather than 4ha and the required density to accommodate 100 dwellings is too high and more suited to transport corridors and more urban areas. Housing provided at ME1 should be at a lower density relative to its landscape setting.
Policy ME1 should be modified to remove the site or reduce the site from 100 houses to up to 50 houses and a new site or additional site should be allocated for up to 100 houses on land north of Main Road, Meriden.

Land North of Main Road performs better in the site assessment. It has ‘very high’ accessibility, compared to Site ME1, has no potential Local Wildlife Site designation, is a within an overall low/moderate performing Green Belt parcel, compared to
Site ME1 within a moderately performing parcel and performs better in the Sustainability Appraisal.

Land north of Main Road, Meriden should be an allocated site. It is highly accessible; has moderate impact on Green Belt; can provide about 6 hectares of new Green Infrastructure; is not constrained by minerals safeguarding; is visually well contained; and
has the maximum SHELAA score. There are no known technical constraints. The Council’s
evidence base demonstrates land north of Main Road, Meriden is a highly sustainable location that is suitable for delivery of up to 100 houses in the plan period. It is available now, offers a suitable location and is achievable without significant new infrastructure. Housing
can be delivered in the short term.

The development proposal can provide 3.4 hectares of residential development for up to 100 dwellings and 6 hectares for public open space, recreation, local play provision and community gardens
IM Land has provided a full set of technical information including an Arboriculture Survey; Archaeological and Heritage Assessment; Ecological Appraisal; Preliminary Biodiversity Impact Assessment; Education
Assessment; Drainage Strategy; LVAGBR; Minerals Resource Assessment Report; Transport Report to demonstrate the deliverability of the site.
The overall conclusion is that Meriden can take more development. The Site performs well against the DLP evidence base. To add to this IM Lands’ evidence has taken the high-level strategic assessments to a more detailed stage and demonstrates the Site is highly accessible; has ‘Some to Limited’ impact on Green Belt; is not constrained by minerals safeguarding;
is visually well contained; the landscape has ‘Medium’ capacity to accommodate change; and it has the maximum SHELAA score. There are no known technical constraints and land north of Main Road, Meriden (Site 556) should be allocated.