Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14575
Received: 11/02/2021
Respondent: Kendrick Homes Ltd
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Summary
Paragraphs: 222, 225 & 226
An objection is submitted to Policy P5 ‘Provision of Land for Housing’, paragraph 222 ‘Solihull Housing Land Supply 2020-2036’, Paragraph 225 ‘Maintaining Housing Land Supply’ and Paragraph 226 ‘Allocated Sites’. It is contended that insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).
There is also an undue reliance on larger site allocations. The smallest of the allocations being for 50 units. This is contrary to the recommendations in NPPF paragraph 68
In order to ensure deliverability, our Client contends that the small and medium size SHELAA sites with an estimated ‘major’ development capacity of 10 units or more, should be specifically allocated in the SLP This would be a mechanism to provide greater certainty of deliverability and speed up delivery.
There is no evidence to demonstrate that there is a reasonable prospect of all the sites identified in the BLR coming forward for development
Our Client questions the basis on which the windfall allowance has been calculated without evidence to demonstrate that the historic rates. There is no commentary in the evidence documentation to explain if/how an allowance has been made in the historic windfall rates to remove a proportion, which would have come forward through the more recent SHELAA and BLR site identification mechanisms
It is also important to note that the proposed delivery on SHELAA sites, proposed in the Publication version of the SLP, paragraph 225 table, anticipates 200 dwellings to be delivered on SHELAA sites in 5-years from April 2020. This would effectively double the 5-year housing land supply delivery rate proposed in the 2013 SLP’s first 5 years.
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, BLR and SHLAA site completions.
robustly demonstrate the deliverability and developability of all BLR sites, SHELAA sites, and proposed housing allocations.
Where the necessary justification cannot be provided, those SLP housing site allocations, SHELAA sites, BFR sites and planning permissions should be deleted from the SLP and housing land supply information (paragraphs 222 and 225).