Object

Representation ID: 14519

Received: 14/12/2020

Respondent: St Philips - Coleshill Heath Road

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

The housing land supply has been over-estimated.

There has been double counting, arising from several sources of supply (windfalls, BLR, sites identified in availability assessments and town centre sites). There is a lack of evidence to demonstrate why the sites fall into only one category and not several.

There is a lack of evidence to demonstrate why allocated sites in the adopted 2013 Local Plan will deliver units in the new plan period (Simon Digby site, Riddings Hill site and Meriden Road site).

There is a lack of evidence to demonstrate why a 10% discount figure has been applied and not a higher figure.

There has been an over estimation of delivery from windfall sites. How can the Council assume that this number of windfalls will be delivered in an area where non-Green-Belt opportunities have been exhausted.

There is an over reliance on the UK Central Hub Area and a lack of evidence to demonstrate delivery of infrastructure requirements to facilitate development. A sensible assumption is that delivery will begin in 2028, with 800 dwellings completed by 2036.

If the supply is adjusted to remedy these issues, the Council would not meet its own needs or make any contribution to the HMA unmet needs, or demonstrate a five-year supply on adoption of the Plan.