Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14669

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

PARAGRAPH 228 -
BC expect a shortfall in the BC of 27,000 homes to 2038, and a shortfall of employment land of between 287-567ha.
BC previously commented that SMBC’s previously stated contribution of 2,000 was disappointing Contribution to the HMA should be to 2036, not just to 2031.
The 2,105 contribution is disappointing, given the strong physical and functional relationship of Solihull to the conurbation, and in the context of the Strategic Growth Study (SGS) that identified options (for further exploration) south of the airport and for a new settlement at Balsall Common
Further clarity sought on why only 2,105. Plan should consider HMA shortfalls over full period of the plan.
2,740 dwellings in the UKC appears a proportionate response to the SGS, but 1,615 at Balsall Common is short of being a ‘new settlement’. Not explained how limits of the environment and attractiveness of the Borough prevent allocation of further housing, and not all reasonable alternatives have been explored.

Support

Representation ID: 14670

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

PARAGRAPH 241
The table of indicative densities in paragraph 240 identifies a series of locally-derived density assumptions ranging from 90 – 150dph for apartments in town centres and at UK Central to 30 – 35dph for houses in limited settlement expansions.
ABCA would wish to be satisfied that these represent the most appropriate and robust densities for all locations through seeing evidence for the adoption of the identified levels. The HMA Growth Study recommends testing and adopting densities of at least 35dph outside the Birmingham and Black Country urban areas, where higher densities of 40dph are promoted.

Object

Representation ID: 14671

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

The Plan has made no contribution to the Black Country in respect of employment land. The reasoning behind the lack of a contribution to meeting employment land needs arising in the Black Country, equivalent to housing needs, is unclear, and at this stage this represents a failure to meet the requirements of the Duty to Co-operate.

Support

Representation ID: 14672

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

SMBC approach generally supported and BC acknowledge that Solihull provides for over 90% of the recent-most Local Aggregate Assessment (LAA) production target for the Metropolitan Area. BC note SMBC that policy may need to be reviewed, but is should acknowledge that the review should consider increased demand.