Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14575

Received: 11/02/2021

Respondent: Kendrick Homes Ltd

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Summary
Paragraphs: 222, 225 & 226
An objection is submitted to Policy P5 ‘Provision of Land for Housing’, paragraph 222 ‘Solihull Housing Land Supply 2020-2036’, Paragraph 225 ‘Maintaining Housing Land Supply’ and Paragraph 226 ‘Allocated Sites’. It is contended that insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).
There is also an undue reliance on larger site allocations. The smallest of the allocations being for 50 units. This is contrary to the recommendations in NPPF paragraph 68
In order to ensure deliverability, our Client contends that the small and medium size SHELAA sites with an estimated ‘major’ development capacity of 10 units or more, should be specifically allocated in the SLP This would be a mechanism to provide greater certainty of deliverability and speed up delivery.
There is no evidence to demonstrate that there is a reasonable prospect of all the sites identified in the BLR coming forward for development
Our Client questions the basis on which the windfall allowance has been calculated without evidence to demonstrate that the historic rates. There is no commentary in the evidence documentation to explain if/how an allowance has been made in the historic windfall rates to remove a proportion, which would have come forward through the more recent SHELAA and BLR site identification mechanisms
It is also important to note that the proposed delivery on SHELAA sites, proposed in the Publication version of the SLP, paragraph 225 table, anticipates 200 dwellings to be delivered on SHELAA sites in 5-years from April 2020. This would effectively double the 5-year housing land supply delivery rate proposed in the 2013 SLP’s first 5 years.

Object

Representation ID: 14576

Received: 11/02/2021

Respondent: Kendrick Homes Ltd

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

On behalf of our Clients Kendrick Homes Ltd, who have an interest in the site adjacent 84 School Road, Hockley Heath, to make representations to the Solihull Local
Plan Review 2020. It is submitted that Policy P5 is unsound on the basis that insufficient policy weight has been given to encouraging the development of suitable sites within settlements for housing enabling villages to grow and thrive, especially where this will support local services, at densities in keeping with national and local strategic policies in Neighbourhood Areas – contrary to NPPF paragraphs 65, 122 and 123.

To comply with NPPF paragraph 65, it is important that the Neighbourhood Area housing requirement is included within Policy P5 as a strategic policy requirement,
rather than as part of the supporting text explaining and justifying the approach set out in the policy. Currently, Policy P5 makes no reference to the housing requirement being partly attributed to specific Neighbourhood Areas.

Given that there is unlikely to be an opportunity to test the housing requirement at the Neighbourhood Plan stage, it is important to ensure that the proposed Neighbourhood Area housing requirements and supporting text are not overly restrictive jeopardising the NPPF and local plan objective of meeting the minimum housing requirement over the plan period.

Object

Representation ID: 14579

Received: 11/02/2021

Respondent: Kendrick Homes Ltd

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

site 49
Whilst our Client supports the proposed removal of Site No. 49 (Land adjacent 84 School Road, Hockley Heath) from the Green Belt and the proposed settlement boundary amendment at Hockley Heath (as shown on the Policies Map), our Client specifically objects to Paragraph 671 as currently worded and we make the case that the site 49 (Land adjacent 84 School Road, Hockley Heath) should be formally allocated for housing development or at the very least the current uncertainty that the wording of paragraph 671 should be amended.
The land is available now, offers a suitable location for development now, and has a realistic prospect that housing will be delivered on the site within five years.
Paragraph 674 of the SLP accepts the case for the existing ribbon of development on the north side of School Road, which is without any significant gaps warrants removal from the Green Belt, which would include our Client’s site.