Object

Representation ID: 65528

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

This policy is imprecise, due to it's over-reliance on the SHMA, a document that itself is not a part of the development plan, and is only designed to inform it.

the SHMA is informed by 2011 data. In paragraph 98 the Solihull High Court Decision, the judge mentioned that pre NPPF data must be used with 'Extreme Caution... because of the radical policy change in respect of housing provision effected by the NPPF".

Therefore, a SHMA must be fully reworked with data from April 2012 onwards, and not simply 'refreshed'. We are not convinced that the 2013 SHMA is a full and complete reworking of the process from the ground up, and is therefore fundamentally flawed.

The policy fails to recognise the the differing housing mix requirements of towns and villages and simply argues this will be negotiated on a'case by case' basis. The policy is therefore not robust enough to be considered acceptable throughout the plan area, hence failing the tests of soundness