Object

Representation ID: 14159

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

P4E
1. The HEDNA (2020) significantly underestimates need, principally because it assumes provision rates that are too low.
2. The HEDNA significantly underestimates the proportionate requirement from owner-occupiers for specialist provision
3. There is a clear immediate requirement for specialist older people’s housing within Solihull. Greater emphasis should be placed on increasing the supply of specialist housing that suits older people’s needs and preferences.
4. By providing housing more suitable to this age group that addresses its needs and preferences (for leasehold accommodation in particular), the family homes that they presently under occupy will become available to the market, in addition to new build family homes, thereby addressing the significant need for family housing that the Solihull Local Plan seeks to address.
5. P4E will not deliver the level of provision required. The policy does not actually guarantee deliver of any specialist housing for older people. There is a need to allocate specific sites for specialist provision.
6. The Policy seeks to provide for specialist housing for both older and disabled people. This conflates the two different and specific needs. The requirement for M4(2) or M4(3) housing does not provide specialist housing for older people as it will not create the types of housing needed as set out by the HEDNA
7. These additional requirements are not seen as viable within the Council’s viability testing. As such, if this requirement is to be retained for specialist housing, it
should be evidenced that it will not impact upon viability/deliverability. Wording should also be
included setting out it may not be required/feasible in certain instances
8. The Policy also requires provision of specialist accommodation in line with the SMBC’s most up to date statement of need. This does not appear to be available. We would question how the policy complies with Paragraph 34 of the NPPF in showing what contributions will be expected
9. The rate of delivery also needs to be considered. The HEDNA sets out that the majority of the shortfall is needed by 2026. SMBC’s stepped trajectory assumes the majority of housing will be delivered during Phases II and II of the Plan Period (2026-2036). As such, there is a risk with the current mechanism that any specialist housing delivered will not come forward in line with when the need occurs.
10. The Site at Jacobean Lane is well placed to provide for this need, and the technical information shows it can be delivered early in the Plan Period.