Object

Representation ID: 9363

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Consideration of HMA shortfall at Regulation 19 stage inappropriate/unlawful as may require revised strategy or propose additional green belt releases, which ought to require further Regulation 18 consultation. Otherwise this would be a completely new strategy resulting in a plan that has not been previously consulted upon. This approach would lead to a challenge to the lawfulness of the process and possible intervention by the Secretary of State. Any preferred options that may derive from a revised HMA contribution should be subject to consultation prior to stage 3 submission as described in the SCI and plan making regulations. Regulations make a distinction between Regulation 18 and Regulation 19 in order to aid sound plan making and to ensure that there is an appropriate opportunity for all those concerned to contribute to it and influence it.
Insufficient and unjustified contribution to wider HMA shortfall which reasonably should be more significant than 3,790 dwellings proposed by North Warwickshire BC, given Solihull's proximity to Birmingham and public transport links. Suggest 6,500 (17% of shortfall). Site 313 Fulford Hall Farm, Tidbury Green could make significant contribution to part of this shortfall, due to sustainable location as demonstrated by Mobility and Transport Strategy.