Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14654
Received: 14/12/2020
Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)
Agent: Marrons Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The housing requirement is not sound as it is not positively prepared, justified, effective or consistent with national policy for the following reasons.
LHN: The minimum Local Housing Need (LHN) has been calculated using the standard method which is well established and is not disputed. However, the Council will need to be mindful of any changes arising from the Government’s stated intention to change the method for calculating LHN prior to submission of the Plan.
Plan Period: It is highly unlikely that the Local Plan will be adopted in 2021, thereby providing a plan period of 15 years post adoption as recommended by the Framework. On the basis that it is already December 2020 and the Plan has not been submitted, it is more likely to be adopted in 2022, and therefore the housing requirement and the Plan should be extended to 2037.
The housing requirement should be amended to take account of the likely realistic date of adoption; a more sustainable balance between the jobs uplift and commuting patterns; unmet housing needs; and an affordability uplift. The housing requirement should also be expressed as a minimum figure. The exact figure will need to be informed by further assessment by the Council.
The housing supply should be justified with evidence, and assumptions in relation to windfalls should be reviewed and amended. The housing supply should contain a buffer of 10% over the housing requirement to ensure delivery and that housing needs can be met should some sources of supply slip.
There is an insufficient portfolio of sites, in particular small sites, that can deliver quickly ensuring a five year housing land supply is achieved upon adoption. National planning guidance advises where a stepped trajectory is used local authorities could identify a priority of sites that could come forward earlier in the plan period in order to ensure housing needs are met. This emphasises the imperative to release further small sites within Solihull that can deliver quickly.
Policy P5 and the table of allocated sites should be amended to include land west of Stratford Road, Hockley Heath.
see attached representation form