Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 11019

Received: 14/12/2020

Respondent: Knight Frank

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy P4E relates to meeting housing needs for older and disabled people. As currently drafted, the policy does not meet the tests of being positively prepared, justified, effective or in accordance with national policy, as it will fail to meet the housing needs for older and disabled people.

The Plan should allocate specific sites for the housing of older people across all tenures, thereby enabling provision that cannot be achieved through open market competition for sites. This would provide
additional flexibility in policy that responds to the difficulty these schemes face in competing with conventional, policy compliant sites.

Object

Representation ID: 11020

Received: 14/12/2020

Respondent: Knight Frank

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Plan to provide additional site allocations solely to assist with meeting identified housing needs for older and disabled people. This could be achieved through additional settlement-based allocation policies.

Site in the Local Plan evidence base under site references 29 (‘The Orchard, Earlswood Road’) and site 210 (‘Land between 79 and 39 Earlswood Road) to be allocated as a Delivery Period 1 site.

Object

Representation ID: 11213

Received: 14/12/2020

Respondent: Knight Frank

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P4E makes no reference to needs figures in the HEDNA or specific targets, nor is there any evidence provided to demonstrate the policy will provide a strategy which, as a minimum, will meet the identified needs for specialist older persons housing within the plan period. The plan therefore does not address specific housing requirements in accordance with para.56 of the NPPF.

Object

Representation ID: 11214

Received: 14/12/2020

Respondent: Knight Frank

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is unclear how the strategy of providing specialist housing for older people on larger residential sites has been selected, justified, or whether is more appropriate than reasonable alternatives such as making specific allocations for specialist housing for older people.