1. Add further analysis to seek to quantify extraneous in migration generated by UK Central hub.
2. Add land at rear of 114 - 118 Widney Manor Road to the table of residential allocations.

The proposals within the Local Plan Review include substantial provision of housing at the UK Central Hub comprising an estimated 2500 dwellings to be delivered within the Plan period. The Council have advised that their housing figures are based on the standard methodology. The standard methodology comprises two elements. The first is the 2014 based estimates of numbers of households projected by the Department of Housing, Communities and Local Government which are essentially and extrapolation of household formation based on the existing and forecast demographic structure taken together with past known trends of inter regional, intra regional and international migration. The second is an adjustment to take account of affordability deficiencies.
The UK Central Hub is an initiative aimed at exploiting the advantages of the new HS2 infrastructure in the interest of furthering the economic well being of the West Midlands Conurbation.
The Overview download from the promotional web site states the hub area is :-
The economic powerhouse of UK Central, The Hub offers inward investors a central and globally connected location to grow their business. Realising the development potential of the High Speed Rail Interchange, a 140 hectare site within The Hub is planned to become a sustainable garden city for the 21st century.
Other promotional material is delivered in Mandarin confirming the global targeting of the project’s economic advantages.
Given this global linkage it can be reasonably supposed that a material proportion of new residents will be migrating in a manner that is materially different from the patterns used in the standard methodology. The circumstances of the development of UK Central Hub are therefore not covered by the trend material which underlies the standard methodology and as an exception to the trend the development of UK Central Hub represents an exceptional circumstance. It is necessary therefore for the additional population arising from this to be taken into account as failure to do so will result in under provision of housing and a corresponding exacerbation of affordability problems which the standard methodology was designed to do.
When measured against Government policy which seeks to meet all strategic development needs (See NPPF 2019 paragraph 23) this would therefore represent a breach of the NPPF. Any breach of the NPPF represents a failure to secure sustainable development. The breach of the NPPF amounts to a situation where the plan would be unsound but more importantly would amount to a breach of the statutory duty on Local Planning Authorities under Section 39 of the Planning and Compulsory Purchase Act the 2004.
The nearest example of the efforts to exploit the High Speed hub in the UK is Ebbsfleet International near Dartford in Kent. Like the ambitions for UK Central Hub the authorities there have sought to exploit the new economic opportunities afforded by a high speed rail link. Their advantages do not include ready access to international air transport as is the case of UK Central.
In order to consider the weight that should be attached to this objection I have checked the figures for housing need in Dartford Borough (where most of the Ebbsfleet development will be located).
The Core Strategy for Dartford proposes (at table 2 on Page 58) that during the period 2016-2026 some 9900 dwellings will be delivered – an annualised rate of 990. The base level 2014 table indicates a housing need of 778 dwellings per annum. This last figure includes the trend based migration evident before the Ebbsfleet initiative started to deliver additional houses. Thus the non trend migration which appears to flow from the Ebbsfleet initiative totals, over the period 2016-2026, some 2120 dwellings [(990-778) x 10].
If a similar pattern were to be repeated in the case of UK Central Hub then this would indicate that the majority of the UK Central development in the plan period would be attributable to non trend migration not hitherto absorbed into the 2014 base household forecasts.
In this context, and to avoid potential unsoundness and breach of statutory duty, the Council is invited to examine closely the impact of UK Central Hub on deviation from the migration trends evident from the 2014 forecasts.
Consideration of the overall housing need in the conurbation, and potential delivery within the conurbation of the conurbation needs has been assessed in the context of the 2014 based household projections. These point to the overall conurbation needs being about the same as when Solihull earmarked the figure of 2000 dwellings to meet conurbation needs. Thus the move to a figure derived from the 2014 based household projections is not materially different from the figures derived from the former housing need calculations. There is no overall change from the underly sub regional figures which will allow the UK Central Hub generated addition migration flows to be offset against changes arising from a move to the standard methodology.
In the context of the foregoing it is submitted that the overall housing requirement needs to take into account this exceptional circumstance presented by the advent of UK Central Hub. The pre submission plan takes into account deficits in supply in the Birmingham HMA but does not take into account growth over and above this from attraction to the UK Central Hub from outside the region. The evidence from Ebbsfleet is that it could be very substantial. A failure to take this into account points to a breach of statute and unsoundness through being inconsistent with national policy for delivery of the housing needs of an area having regard to all sources of need. Land at 114 – 118 Widney Manor Road is well placed to contribute to the likely underestimate of need given that the SA found the site to be classified as ‘reasonable alternative. The site should be added to the table of residential allocations.