Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15006

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

- Support Vision, namely to provide a range of quality homes across the Borough by 2036, whilst setting out opportunity to maximise economic and social benefits of HS2 Interchange
- Vision fails to identify important link between new employment opportunities and requirement to deliver new homes within Borough – therefore unbalanced and uncoordinated Plan.

Object

Representation ID: 15007

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

- Support Para. 63-67 and focus on Options E-G
- Failed to account for specific settlement hierarchy.
- Preferred Growth Options should be accompanied by a settlement hierarchy, that would identify how vision and spatial strategy will be delivered through plan period.
- This should be supported by SA taking into account factors such as public transport
- Would assist Development Management and delivery of windfall sites.

Object

Representation ID: 15008

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Site Selection Methodology (see also Topic Paper):
- Raised concerns previously and these have not been addressed
- Step 1 – Hierarchy criteria does not align with NPPF Para. 138, and preferring Green Belt sites well served by public transport
- Site Hierarchy should reference land well served by public transport
- Step 2 of refinement criteria (p.14 Topic Paper) do not include sites well served by public transport as ‘factors in favour’. Therefore not accord with NPPF.

Object

Representation ID: 15009

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Alternative Site:
CFS 554 at Rumbush Lane (sub-site of CFS 141) should be considered for site allocation as site selection appraisal incorrect:
- CFS 554 would accord with Site Selection methodology, if process complied with NPPF and included criterion as located on main railway line, site would have been classified as green site at Step 1.
- Hard constraint can be mitigated easily and not affect suitability of site.
- Site provide strong defensible GB boundary
- Could provide wider planning gain
- Accessible location with 3 services/hour in morning peak, and 2/hour on weekends.
- SHELAA 2016 classed site as Category 1
- 2016 Landscape Character Assessment states that it’s not possible to establish a definitive baseline sensitivity to change without proposals details – Vision Document provides such assessment.
- SA assessed larger site and identified 3 significant negative effects – loss of high quality agricultural land can be mitigated through presence of exceptional circumstances.
- Smaller parcel submitted in April 2020 was not considered as part of SA.
- Proposed convenience store would mitigate need for short trips

Support

Representation ID: 15010

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

- Pleased to note that SMBC have reverted back to 40% of overall dwellings
- Support built in flexibility to allow negotiations on site by site basis

Object

Representation ID: 15011

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Evidence for alternative site, CFS 554 at Rumbush Lane:
- Single land ownership
- Highly sustainable location, immediately adjacent to Earlswood station
- Development opportunity comprises land located in Stratford-on-Avon’s district boundary.
- Site been promoted in 2016 and 2019 DLP Reg. 18 consultations
- Previous submissions focussed on much wider site area, approx. 90-95 ha around Earlswood station. Site been reduced in scale, see CFS 554 compared to CFS 141 and updated Vision document.
- Vision Document shows site can provide:
o Up to 62 homes for older persons accommodation
o Landscape buffer to prevent coalescence
o Opportunity for community shop with café, shop, hairdressers to support C2/C3 uses
o Up to 5.88ha of public open space
o Enhancements to PROW
o Creation of village green
o Stratified movement hierarchy with multiple points of access
o Adjacent to under-utilised railway station, 25 mins from Birmingham and Stratford upon Avon.

Furthermore, GL Hearn Strategic Growth Study (2018) identified broad, non-specific area between Birmingham and Stratford upon Avon as potential for a new settlement, such as location of CFS 141/554.

Wider potential:
- Opportunity to expand development in SDC – See Vision document and appendix 3. Potential for 74 additional homes.
- Total 136 new homes plus 1.37ha of older persons accommodation, and up to 7.54 ha of public open space OR
- 116 homes, plus 1.94 ha of older persons accommodation and up to 7.54ha of POS

Support

Representation ID: 15012

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

- Barton Willmore report (Jan 2020) states immediate requirement for specialist older person’s accommodation, of 3,612 units.
- Separate analysis state current need for 491 registered care places, rising to 1,229 by 2035, accounting for population growth.
- Agree that applications for specialist older persons housing should be supported
- Review of evidence by SMBC would further strengthen policy
- Beneficial for SMBC to identify areas that would be most suitable for providing specialist housing for older people, such as CFS 554 (141).

Object

Representation ID: 15013

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Housing Land Supply:
- Should refer to additional homes at UK central Hub (2,740) and state 8,010 net additional homes in period 2020-2036.

Object

Representation ID: 15014

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

GBBCHMA housing shortall
- Unmet need of wider GBBCHMA been under-estimated
- See Barton Willmore report ‘Solihull Borough Housing Need Technical Note’ (Dec 2020) in Appendix 4:
o Birmingham’s real deficit is 11,294 – 13,1010 dwellings up to 2031
o SMBC not include HMA shortfall post 2031
o Not consider additional shortfall arising from Black Country Plan review
o Post 2031 unmet need calculated to be a minimum of 17,700 dwellings between 2031 and 2040.
o Should include review policy or trigger to address additional shortfall once tested.
o Limited additional housing requirement arising from UKC Hub Area is at odds with Borough’s ambitious Vision for UK Central Hub Area
o BW report state between 1,036-1,248 homes per annum required to meet UKC scenario, or 3,520-6,912 dwellings increase over plan period.

Object

Representation ID: 15015

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

LHN and Housing Requirement
- IM have concerns about evidence supporting housing requirement.
- Agree that SM is good starting point.
- PPG state this is just a minimum starting point.
- PPG state several circumstances where SM should be exceeded, and these apply to Solihull:
o Potential for ‘Supergrowth’ at UKC Hub area
o Further work required on housing need impacts of planned growth and strategic infrastructure improvements at UK Central Hub
o 2015 Midlands HS2 Growth Strategy state significant potential to deliver growth on nationally significant scale, over and above HS2 construction.
- Concerns been raised at previous consultations