Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14408

Received: 14/12/2020

Respondent: L&Q Estates - Damson Parkway

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to quantum of growth in Policy P5, as 2,105 dwellings is insufficient to address the housing market area shortfall. Plan should test the provision of a minimum of 11,500 additional homes to avoid creating unsustainable patterns of growth and commuting across the HMA.
The housing requirement should be expressed as a minimum requirement, inclusive of any cross-boundary provision to provide certainty as set out in NPPF paragraph 65. Proposed approach equating provision with the difference between local housing need and supply is unsound.
SMBC should allocate around 20% more housing land than required to deliver the housing requirement to provide the necessary flexibility for non-delivery of sites/ boost significantly the supply of housing, equating to a further 3,000 dwellings.
Supply is based upon the local housing need and does not factor any uplift necessary to ensure delivery of the cross boundary provision. The 5 year housing land supply should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
The windfall allowance is not supported as not Plan-led, prevents planning for necessary infrastructure, likely to be overestimate and is unsound.
No evidence to justify blanket introduction of nationally described space standards.
Whilst flexibility on densities is supported, the implications of various policy standards is uncertain and no evidence is provided that this has been taken into account

Change suggested by respondent:

Policy P5 of the Plan should be redrafted to:
- explicitly commit the Council to deliver the additional 2,105 homes (or any updated contribution to the unmet needs of the GBBCHMA) through this Local Plan as part of a comprehensive housing requirement
- include cross-boundary provision in the housing requirement
- incorporate uplift to ensure delivery of the cross boundary provision, with the 5 year housing land supply recalculated
- omit windfalls from housing supply
- remove blanket optional nationally described space standards

Full text:

Land at Damson Parkway - see attachments for full details