Solihull Local Plan (Draft Submission) 2020

Search representations

Results for CPRE Warwickshire Branch search

New search New search

Object

Solihull Local Plan (Draft Submission) 2020

Introduction

Representation ID: 10988

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The Plan is not sound because NPPF 2018 provisions set out in para 11 (b) (i) and (ii) have not been applied in its preparation.

Object

Solihull Local Plan (Draft Submission) 2020

Challenges

Representation ID: 10992

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Challenge B is falsely stated. The Council has not applied, and has chosen not to make use of, the National Planning Policy Framework policy on sustainable development. This means that policies should provide for assessed needs for housing and other uses unless policies that protect areas of particular importance provide strong reasons for restricting the scale of development. The areas of particular importance in Solihull’s case are the areas of Green Belt. Green Belt designation covers all of Solihull’s countryside and is justification for not meeting the assessed need for housing. The Plan is not sound.

Object

Solihull Local Plan (Draft Submission) 2020

Spatial Strategy

Representation ID: 10994

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The Spatial Strategy is not sound. The Council has not applied, and has chosen not to make use of, the National Planning Policy Framework policy on sustainable development. This means that policies should provide for assessed needs for housing and other uses unless policies that protect areas of particular importance provide strong reasons for restricting the scale of development. The areas of particular importance in Solihull’s case are the areas of Green Belt. Green Belt designation covers all of Solihull’s countryside and is justification for not meeting the assessed need for housing. See NPPF 2018, paragraph 11.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 11005

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Provision of housing to meet the increase in households projected by ONS for Solihull up to 2036 can be achieved without any removal of Green Belt or allocation of housing on land now Green Belt, except at the UK Central Hub north of the A45.
The housing strategy is wrongly based on allocation of a small number of large housing sites, on land now Green Belt. Replacement of these by a strategy of small sites would enable the increase in households to 2036 to be catered for without the scale of loss of Green Belt that the Plan proposes.

Object

Solihull Local Plan (Draft Submission) 2020

Improving Accessibility & Encouraging Sustainable Travel

Representation ID: 11007

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The Chapter titled 'Improving Accessibility and Encouraging Sustainable Travel' was written before the Transport Study produced by Mott Macdonald was prepared and long before it was published. The Policies listed (P7, P8, P8A) are not a transport policy or strategy for the Borough. The requirement of the Planning Practice Guidance for Local Plans is that there should be a transport assessment carried out, at the main stages of Plan preparation. There is still no transport assessment as required by the PPG.
In the absence of a formal transport assessment the Plan is not sound.

Object

Solihull Local Plan (Draft Submission) 2020

Challenges

Representation ID: 14954

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Challenge B:
- Clear that Solihull cannot meet its housing requirement of 15,270 homes without significant adverse harm to Green Belt and environment
- SM is not suitable basis for housing requirement and assumption is there are no constraints to meeting full requirement
- SM does not take into account in-and-out commuting of the Borough
- NPPF Para 11(b) should be invoked

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14955

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

- Clear that Solihull cannot meet its housing requirement of 15,270 homes without significant adverse harm to Green Belt and environment
- SM is not suitable basis for housing requirement and assumption is there are no constraints to meeting full requirement
- SM does not take into account in-and-out commuting of the Borough
- Citing Govt advisor Professor Wenban-Smith, it is dangerous to release too much land: ‘over provision can never be corrected, under provision can be corrected later when needs are better defined.’
- Proposed delivery rate of 938dpa is a huge step-up for construction industry to achieve in the Borough – not been achieved in a single year since 2001 (highest being 836 in 2005/06)
- Average delivery rate over last 5 years is 706 dpa.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14956

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Housing Land Supply:
- Development should be focused on brownfield first, in accordance with Government advice
- More work needs to be done on capacity of final version of Solihull town Centre masterplan and capacity at Arden Cross.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 14957

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Windfall:
As an impact of Covid-19, likely to be small reduction in office use as more people choose to work from home or shared offices. Therefore there will be an increase in windfall sites as offices become redundant, which will be more than enough to omit the most unsustainable site allocations from the Plan.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Spatial Strategy

Representation ID: 14958

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

- Strongly challenge scale of proposed development in Blythe, Knowle and Balsall Common.
- Disproportionate and not justified by site selection methodology, or consistent with its spatial strategy and objectives
- Proposed site allocations perform poorly against sustainability measures, with adverse effect in these areas.
- In addition to previous comments, we add to this analysis following the updated information in the supporting documentation of the Plan below:
o Strategy fails to link adequately housing distribution to its economic and transport policies. These emphasise growth in accessible corridors inc. A45, A34 and Solihull town centre, as well as the corridor linking the town centre to the A45 hub.
o Spatial strategy does not reflect findings of assessment work, as demonstrated by large scale allocations in Balsall Common, Knowle & Dickens Heath.

Attachments:

For instructions on how to use the system and make comments, please see our help guide.