Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13996
Received: 11/12/2020
Respondent: Messrs Benton & Neary
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The table at paragraph 225 ‘Maintaining Housing Land Supply’ is unsound as there is a lack of robust evidence to demonstrate there has been no double counting across the sources or to demonstrate the deliverability of the capacity numbers.
There is no evidence to demonstrate Brownfield Land Register sites will come forward for development. Stage 2 has not been undertaken and none of the sites have permission in principle. There is no evidence on how the windfall allowance has been calculated to demonstrate that historic rates excluded sites identified in the SHELAA and Brownfield Land Register (ensuring no double counting).
There are concerns in relation to the developability of SHELAA site 245 Former Rugby Club, Sharmans Cross Road. There is no mechanism for replacement of the sports pitches which would be lost as a result of residential development as required by Policy P20.
Evidence is required to:
• demonstrate which of the SHLAA sites identified as contributing towards the 5 and 16 year housing land supply in the 2013 SLP have been delivered.
• extrapolate the windfall, Brownfield Land Register and SHLAA site completions.
• robustly demonstrate the deliverability and developability of all Brownfield Land Register sites, SHELAA sites, and proposed housing allocations.
If justification cannot be provided, those site allocations, SHELAA sites, Brownfield Land Register sites and planning permissions should be deleted from the Plan and housing land supply information.
Dear Sir/Madam,
Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.
We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.
We look forward to hearing from you.