Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14542
Received: 11/12/2020
Respondent: St Philips - Land at Stratford Road, Hockley Heath
Agent: Lichfields
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Council is only proposing to deliver 15,017 dwellings which would meet the minimum requirement for housing including delivery of a small element of cross boundary growth. Additionally, a stepped delivery trajectory is proposed, which would result the delay in delivery of homes to meet needs in the early part of the plan period. As a result the DSP would fail to be “sufficiently flexible to adapt to rapid change” (Para 11) as required by the NPPF. At present, the Council’s proposed growth strategy would only just meet the proposed 15,017- dwelling housing requirement. It does not allow for any flexibility to respond to changing circumstances.
Government intention to review the standard methodology, revising the standard method for assessing housing numbers in strategic plans. This increases the minimum LHN for Solihull to 1,011 dwellings per annum, which is above the Council’s proposed housing requirement of 938 dwellings per annum. Although the Council intends to submit the DSP prior to the transitional arrangements, any delay to the plan-making or submission process means the Council will need to have regard to the revised standard method figure. It would therefore be prudent for the Council to build in a buffer at this stage and seek to begin considering a number of additional sites that could deliver sufficient capacity to meet this increased figure. This should include circa 5-10% headroom in the housing requirement (P5), to facilitate the delivery of between circa 750–1,500 dwellings
5-10% headroom should be included in the housing requirement set out under Policy P5(1). In doing so, the Council will need to identify and sites to facilitate the delivery of circa 700–1,500 dwellings.
A detailed, site-specific housing trajectory is prepared, setting out the anticipated delivery rates of the larger strategic allocations and Town Centre Sites proposed pursuant to Policy P5(1). The anticipated delivery rates for large sites including UK Central Hub should be realistically set to reflect the lead in time for the delivery of projects of this scale.
The windfall allowance is decreased from 200 dpa to 150 dpa. At 150 dpa, a resultant capacity of 2,100 dwellings from 2022-2036 would warrant the Council to identify sites to facilitate the delivery of a further 700 dwellings.
see attached submission document