Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14576
Received: 11/02/2021
Respondent: Kendrick Homes Ltd
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
On behalf of our Clients Kendrick Homes Ltd, who have an interest in the site adjacent 84 School Road, Hockley Heath, to make representations to the Solihull Local
Plan Review 2020. It is submitted that Policy P5 is unsound on the basis that insufficient policy weight has been given to encouraging the development of suitable sites within settlements for housing enabling villages to grow and thrive, especially where this will support local services, at densities in keeping with national and local strategic policies in Neighbourhood Areas – contrary to NPPF paragraphs 65, 122 and 123.
To comply with NPPF paragraph 65, it is important that the Neighbourhood Area housing requirement is included within Policy P5 as a strategic policy requirement,
rather than as part of the supporting text explaining and justifying the approach set out in the policy. Currently, Policy P5 makes no reference to the housing requirement being partly attributed to specific Neighbourhood Areas.
Given that there is unlikely to be an opportunity to test the housing requirement at the Neighbourhood Plan stage, it is important to ensure that the proposed Neighbourhood Area housing requirements and supporting text are not overly restrictive jeopardising the NPPF and local plan objective of meeting the minimum housing requirement over the plan period.
A modification is sought to Policy P5 as shown below:
Insert a new paragraph below paragraph 2 of Policy P5, as follows:
‘A proportion of the Borough’s housing requirement will be expected to be delivered in designated Neighbourhood Areas as detailed in the table below. These housing requirement figures are indicative minimum numbers and may be exceeded once detailed permissions have been considered for the sites identified in the land availability assessment, Brownfield Land Register, site allocations within this plan and saved
from the 2013 Local plan and any suitable additional sites which come forward within the settlement boundaries as defined on the Policies Map.’
It is submitted that paragraph 234 should be deleted and replaced by a table of Neighbourhood Areas with the minimum housing requirement listed for each area.
The minimum housing requirement figures currently shown at paragraph 234 should be critically reviewed to reflect the deliverability of the housing land supply sources more realistically. As a minimum, our client submits that an addition of 21% to the numbers proposed at paragraph 234 should be incorporated, to reflect the windfall delivery expectation.