Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15041

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.

Object

Representation ID: 15042

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
- Consider scale and delivery rates of UK Central hub proposals are unrealistic, and neither details on trajectory and delivery timescales, nor commitments from delivery partners, have not been included in consultation documentation.
- Based on LPR adoption date of 2022, we consider first likely completions to be ca. 2030. This is based on Lichfields’ Report (‘Start to Finish’, Feb 2020) analysis that concludes the average time from outline planning app to first completion is 8.4 years.
- Given information within the August 2020 consultation {Arden Cross?}, we consider a 160dpa build out rate between 2030-2036 is reasonable, to delivery 960 dwellings. Type of supply should also be considered, as geared towards apartments. Amount of infrastructure required also needs consideration.

Object

Representation ID: 15043

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Trajectory:
- SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase.
- We refer you to Guildford Local Plan Inspector’s report, which concludes the Liverpool method does not meet the Government’s objective to boost housing supply in the shorter term.
- Consider Solihull should follow same approach as Guildford and allocate more sites.
- As with withdrawn Uttlesford Local Plan, a stepped trajectory may create a fragile 5 year land supply.
- Stepped trajectory may worsen the affordability problem as it delays delivery.

Object

Representation ID: 15044

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Consider that 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: 15045

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

NPPF Para. 109 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: 15046

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P11 (Bullet Point 6):
- It should be made clear that planning permission can be granted prior to confirmation of discharge into a public sewer (under Section 106 of the Water Industry Act 1991) being confirmed, as it falls within a different regulatory regime.

Object

Representation ID: 15047

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P11 (Bullet Point 14):
- It should be clarified that a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.

Object

Representation ID: 15048

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P17 (Bullet Point 1):
- Council seeks to safeguard best and most versatile agricultural land (BMVAL), unless there is an overriding need for development that outweighs the loss.
- BMVAL is referenced in NPPF Para. 170 (b) in relation to natural capital and ecosystem services in the countryside.
- We consider reference to BMVAL in Green Belt policy conflates separate issues of natural environment and Green Belt.
- Consider planning policies are required in NPPF to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL, the test is not to safeguard BMVAL.
- As such point should be deleted.

Support

Representation ID: 15049

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Policy P17 (Bullet Point 4):
- Council set out a number of different factors that may be taken into account when considering very special circumstances.

Object

Representation ID: 15050

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P17 (Bullet Point 5):
- Sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given that Green Belt is a spatial designation, designed to prevent sprawl, we consider this requirement goes beyond the scope of the Green Belt, as set out in NPPF.
- As LPR contains policies to protect landscape, where necessary, as such, this point should be deleted.