Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14765
Received: 09/12/2020
Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
18% of the proposed housing requirement for the Borough is at the UKC Hub. The majority of dwellings delivered will be apartments. No evidence that the amount of apartments proposed at UK Central Hub is needed, especially when there is an existing family demographic.
The UKC Hub will be unlikely to deliver 2,740 dwellings up to 2036 which could leave a shortfall of circa 700 – 1,000 dwellings . Evidence documents also show different housing figures for the sites.
The revised Standard Methodology could increase the Council’s minimum housing need by 25%. The range of housing growth options that may be derived from changes to the standard method and wider HMA growth requirements should be tested and planned for.
The proposed contribution towards the HMA shortfall is not a sufficient or justified contribution in light of the identified shortfall post-2031 which should be addressed in the Local Plan Review. Additional sites will be required.
Over-reliance on windfall. Council should identify additional sites and allocate and/or safeguarded for residential development.
Contrary to NPPF, point 6 makes no reference to local market conditions and viability when identifying appropriate density and mix for each site.
The UK Central Hub area will not deliver 2,740 dwellings in this plan period, an additional contribution should be made towards the HMA shortfall and the revised standard methodology requirement should be taken into consideration by the Council before submitting the Local Plan for Examination. In light of this the Council need to allocate additional sites that have performed well against the Council’s evidence base criteria and are in sustainable locations. The land being promoted by St Philips (Site Reference 207) should be considered for a residential allocation as a high performing site adjacent to the sustainable settlement of Bentley Heath.
Amend Point 6 of Policy P5 to accord with the criteria listed in NPPF Paragraph 122 and amend the indicative densities table on page 76 to set out more realistic densities for the UK Central Hub area if 5,000 dwellings are going to be delivered on the UK Central Site (paragraph 830 of the Submission Draft document).
See attached documents