Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14720
Received: 14/12/2020
Respondent: Mr Ian Williams
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The Council will not be able to meet its assessed Housing Need and the Plan is unsound.
There is evidence that the Housing Need figure for Solihull of 13,056 (Para 221) is in fact too low and should be adjusted upwards.
The Windfall Allowance (as of 1st April 2020) is disputed and not based on sound evidence.
No small sites are allocated.
Some sites in the SHELAA are not deliverable e.g. St George and St Teresa school as relocation is no longer an option.
Some sites on the Brownfield Land Register are not reasonable allocations and would fail the site assessment or are not deliverable.
Approach to housing density in the plan is not clear and inconsistent with the masterplans and the KDBH neighbourhood plan.
The delivery of the Housing Need for Solihull should be re-assessed so the Plan is sound.
The Local Plan must be modified so that is will meet the currently assessed Housing Need, for the Borough and each area (even if delivery is reduced based on representations).
Windfall allowance should be reduced unless demonstrated by compelling evidence.
The Local Plan should be modified to specifically allocate small sites to comply with the NPPF.
It is submitted that Site 127 should be allocated in the Local Plan/counted in the housing delivery numbers.
St George and St Teresa Catholic School should be deleted from the Land Availability Assessment in Schedule E of SHELAA as there is no (or insufficient) evidence that it is deliverable in the Plan.
Brownfield Land Register sites Blythe House, 1806 Warwick Road and 1817 Warwick Road should be deleted as allocations. Site 127 should be included as a replacement site, albeit not currently in the BLR, Site 127 does not need to be BLR (even though it meets all the requirements to be included in the BLR) to be allocated under the Local Plan.
See attachments.