Object

Representation ID: 14880

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the quantum of growth, L&Q Estates object as the 2,105 home additional contribution, whilst welcomed as a starting point, is simply not sufficient to address the shortfall in the wider Greater Birmingham and Black Country Housing Market Area (‘the HMA). The Paper (Appendix 2) concludes that the Solihull Local Plan should be, at the very least, testing the provision of a minimum of 11,500 additional homes to address the unmet need across the HMA instead of the circa 2,000 it is currently proposing.
Policy P5 falls short of committing to the delivery of 2,105 dwellings to meet needs arising within the wider HMA – instead this element of the full housing requirement equates to the flexibility in supply proposed. Such an approach is not consistent with national policy and the firm commitment that should be made in order to satisfy the duty-to-cooperate.
Trajectory - The housing land supply position is based upon the LHN and does not factor any uplift necessary to ensure the delivery of the cross boundary provision. The 5 year housing land supply calculation should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
Windfall - The inclusion of a windfall allowance of 200 units per annum in respect of supply is not supported. This equates to nearly 20% of the proposed housing land supply to 2036. If the Council is promoting a fully Plan-led approach to delivering growth, then there is no need to include an allowance in the housing supply from windfall sites. The Council references the increase in windfall supply within the Borough since 1992.
Nationally Described Space Standards - There does not appear to be any evidence to justify a blanket introduction of such standards, and the viability assessment simply states ‘applies to all sites’ (page 9). The policy is clearly not compliant with national guidance which requires evidence to justify policy.
Density - The flexibility afforded to the section of Policy P5 on density is supported. However, it is not certain how such a policy would be impacted should all of the various standards be implemented, including Nationally Described Space Standards. The Council should be demonstrating how this policy will be implemented in practice, and should be providing evidence to show that it has allocated enough land to deliver the stated number of homes