Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14725
Received: 11/12/2020
Respondent: Mr James Mc Bride
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
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
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 a lack of credible evidence to demonstrate that the 861 dwellings identified for Solihull Town Centre under Policy P5 can be delivered. It is considered
that insufficient evidence has been provided to demonstrate that there is a mechanism to facilitate the quantum and timing of development proposed via Policies P2 and P5:, contrary to the deliverability and developability requirements for site allocations set out in NPPF Appendix 2: Glossary. It also fails to satisfy paragraphs 67 and 175 of the NPPF.
Our Client therefore contends that Policy P5 is unsound the number of dwelling proposed to be delivered in the Town Centre should be significantly reduced to reflect more realistically its capacity based on the constraints to development.
Insufficient evidence has been provided to demonstrate the ability to deliver the 2,740 dwellings from the UK Central Hub within the Plan period (2020-2036), as set out within Policy P5 (Provision of Land for Housing), contrary to the deliverability and developability requirements for ‘site allocations’ set out in the NPPF Appendix 2: Glossary. Accordingly, the ‘allocation’ of the
UK Central Hub sites fails to satisfy the NPPF paragraphs 67 and 175.
The definition of the ‘UK Central Hub Area’ as referenced in Policy P5 (Provision of Land for Housing) is imprecise and inconsistently applied within the SLP and supporting evidence
The housing contribution from within the ‘UK Central Hub Area’ is not clearly defined within the draft SLP documents (i.e. the SLP, Policies Map or Concept Masterplan Document) There is a reliance on documents provided in evidence (but not to be adopted) which are subject to change. This leads to uncertainty on achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period.
The quantum of dwellings and timeframe for delivery as quoted within the SLP and supporting evidence is inconsistent, leading to uncertainty in achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period.
Delivery of The UK Central Hub (including residential elements of Arden Cross and NEC) is extremely complex, requiring the co-ordination of several landowners and implementation of necessary infrastructure; in the absence of a clear Policy and/or Concept Masterplan identifying relevant details, and as noted elsewhere discrepancies in the quantum and timetabling, this raises uncertainty on achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period
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, BFL sites and planning permissions should be deleted
from the SLP and housing land supply information (paragraphs 65, 222 and 225).
Where appropriate evidence is forthcoming, additional site allocations should be set out in the SLP and Policies Map which identify deliverable small and medium
‘major’ development sites.
In particular, it is considered the following modifications are required –
1. The terms for the ‘UK Central Hub’ should be rationalised, clearly defined and
used accordingly.
2. A clear policy on the UK Central Hub housing contribution - the housing contribution should be clearly identified within the Policies Map and a Concept Masterplan for each site, in the same manner as other allocated sites.
3. The quantum of dwellings and timeframe for delivery as quoted within the SLP and supporting evidence should be consistent.
4. The policy and/ or concept masterplan should identify relevant details of coordination of landowners and implementation of necessary infrastructure, including quantum of development and timetable.
5. The development of Arden Cross requires Green Belt compensation.
6. That the NEC and Arden Cross sites are fully assessed for their suitability for
development.
see attached representation forms