Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14659
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
Affordability uplift: The housing requirement should also be increased to take account of affordability within the Borough, consistent with national guidance. The identified affordable housing need is 578 homes per annum (HEDNA para 35). However, the Council has reached the conclusion that the maximum amount that can be viably sought is 40% on any given scheme. This top line is substantially less than the evidence suggests, and in reality, 322 per annum is unlikely given the sources of supply, despite the Housing Topic paper (Paragraph 73) noting other methods for maximising affordable housing provision. The Housing Topic paper notes at footnote 10 that this reduced to 224dpa if households already in accommodation are excluded, however the HEDNA is clear that the figure is theoretical and should not be seen to minimise the acute housing need in the borough.
Allocated Sites: The absence of any evidence in relation to housing trajectories for the proposed allocated sites means that the figure of 5,270 homes to be delivered by 2036 is not justified.
Windfalls: The estimated level of windfalls at 2,800 homes completed over 14 years is not justified. Firstly, whilst it is stated that windfalls are not included for the first 3 years (to avoid double counting with extant planning permissions) only 2 years have been discounted. Secondly, the annual average level of windfall is substantial for an authority significantly constrained by Green Belt. Reliance is placed on historic trends, but there is no certainty that past sources of supply are likely to continue. The evidence should be so compelling that it is a source of supply that can be relied upon for delivering the housing requirement.
Five Year Supply on adoption: The Plan will not provide for a five year housing land supply upon adoption. The Plan assumes that 1,170 homes will be delivered on allocated sites within the first five years but there is no evidence to support this
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