Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14734
Received: 11/12/2020
Respondent: Mr James Mc Bride
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Policy P5 ‘Provision of Land for Housing’ is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed
2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP). There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60
Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Local Plan with accompanying Green Belt review, and
ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).
Our client submits that the evidence in support of Policy P5 is deficient and, therefore, the policy is unsound and that the council should:
Publish a statement of common ground, which addresses the HMA crossboundary shortfall of sites to meet the minimum housing requirement to satisfy NPPF requirements.
• Modify the housing delivery target number if/as appropriate following scrutiny of the statement of common ground.
• Allocate small and medium sized sites for residential development; and
• Remove of a phased housing delivery target table at paragraph 224.
In order to ensure that any future housing requirement changes can be accommodated within the plan as efficiently and effectively as practicable, to support the
Government’s objective of significantly boosting the supply of homes (NPPF paragraph 59) our clients seek the following proposed modifications to Policy P5 as
shown in ‘bold italics’ below:
‘1. The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing land supply to deliver a minimum 15,017 additional homes in the period 2020-2036…
Insert two new paragraphs beneath paragraph 4 of Policy P5, as follows,
‘Reserve Housing Sites providing flexibility to ensure that the Borough can meet in full any increase in housing numbers arising from any change to the standard method for assessing housing need, and respond to the need to
meet housing need arising from within the HMA. Reserve sites will have the capacity to deliver at least 20% of the total housing requirement to 2036. Reserve sites will be released in the following circumstances:
• To rectify any identified shortfall in housing delivery in order to maintain a 5-year supply of housing land in Solihull MBC area;
• To contribute to meeting any housing needs arising outside the Borough accepted through co-operation between the relevant councils.
‘Land identified on the Policies Map will be removed from the Green Belt and safeguarded for potential future development needs beyond the plan period to ensures that Green Belt boundaries will last beyond the end of the
Local Plan period. The status of the safeguarded sites will only change through a review of the local plan.’
see attached representation forms