Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 15027
Received: 14/12/2020
Respondent: Kier Living Ltd - Coleshill Road
Agent: Mr Hywel James
Legally compliant? No
Sound? No
Duty to co-operate? No
Windfall allowance:
- Constitutes 18% of the Emerging Plan’s housing supply
- Windfall sites are a finite resource and
the high delivery of windfall developments in recent years will have diminished the supply of sites.
- Particularly relevant in Solihull Borough given its Green Belt constraints
- Council keeps separate brownfield land register
- Given NPPF’s restrictions, no windfall contributions can come from Green Belt land
- Uncertain whether the past rates of windfall delivery can be sustained up to 2036
- Windfall allowance is based purely on historic trends, not SHELAA delivery trajectory, and this approach is inconsistent with NPPF para. 70
- DSP assumes annual windfall development rates will be required in full during the period 2022-2036 in order to meet minimum housing requirement, given the lack
of flexibility in the housing supply.
• An increased buffer above the minimum housing requirement must be provided;
• A more realistic windfall delivery rate should be assumed, having regard to fact that the supply
will have diminished based on recent high delivery rates;
• Additional housing allocations are required, including smaller sites such as CFS 193, to boost the
supply and offer better resilience.
See attached letter