Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Solihull Town Centre & Mature Suburbs
Representation ID: 14780
Received: 14/12/2020
Respondent: Schools of King Edward VI in Birmingham
Agent: Avison Young
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Site 111 is located immediately adjacent to the Solihull urban area and is well-related to it. The site is accessible to bus and rail which provide access to jobs and facilities. There are a range of education, health and shopping facilities which can be accessed by car and public transport.
The site is almost entirely located in Flood Zone 1 and at low risk of flooding. It does not comprise Best and Most Versatile Agricultural Land. There are no designated heritage assets located on it, or in close proximity to it.
The site occupies a sustainable location that it is suitable for new residential development.
Criticism of how Site 111 has been assessed by SMBC.
Object
Solihull Local Plan (Draft Submission) 2020
Policy P5 – Provision of Land for Housing
Representation ID: 14781
Received: 14/12/2020
Respondent: Schools of King Edward VI in Birmingham
Agent: Avison Young
Legally compliant? No
Sound? No
Duty to co-operate? No
The Council’s calculation of LHN, which is based on the 2018 SM, will soon be obsolete. Emerging Government policy suggests that Solihull’s LHN will increase, leading to a requirement to release more land from the Green Belt.
The Housing Position statement is a summary of the broad direction of travel rather than a definitive assessment of housing land supply. It cannot be relied upon by SMBC to justify its very modest proposed contribution to unmet need in the HMA. SMBC has no formalised arrangement with any of its neighbours and no evidence to justify the figure proposed.
The SA concludes that SMBC could make a contribution of 3,000 dwellings to the shortfall in the HMA, without the impacts being materially more negative.
No statements of common ground to support the approach demonstrates a lack of constructive engagement and failure in the duty to cooperate.
P5 General.
Housing supply has been overestimated. There has been double counting, lack of evidence to demonstrate deliverability, overestimation of windfall, over-reliance on delivery from UCK Hub area.
A revised supply table is provided which demonstrates that the Council is some 551 dwellings short of the identified housing need for the Borough
Policy P5 and its supporting text at Paragraphs 220 to 232, is not positively prepared, because, on a proper assessment of housing supply, it does not meet the housing needs of the Borough.
These deficiencies in supply could be remedied through the Council revisiting its supply of sites and identifying additional land for allocation.
Object
Solihull Local Plan (Draft Submission) 2020
Policy P17 Countryside and Green Belt
Representation ID: 14782
Received: 14/12/2020
Respondent: Schools of King Edward VI in Birmingham
Agent: Avison Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
LHN is likely to increase as a result of the new standard methodology. There is no agreement over HMA need and no assessment of whether more dwellings could be delivered.
Local Plan should remove additional land from the Green Belt for allocation, as well as safeguard land for residential development at the appropriate time. Failure to do so will inevitably create the need to release more land from the Green Belt when the Local Plan is next reviewed.
The Plan fails the test of soundness in respect of meeting housing needs and ensuring that Green Belt boundaries in the borough will remain beyond the proposed plan period.