Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14692
Received: 14/12/2020
Respondent: Rainier Developments Limited (School 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.
Employment uplift: LHN is afforded an employment uplift of nine dwellings per annum to take account of the substantial job growth at UK Central of around 13,000 net additional jobs. This is a figure which could increase as plans crystallise, and it is noted that the Council’s Viability Study (2020) predicts up to 77,500 jobs by 2040. The Plan also justifies the small uplift from LHN on the assumption that only 25% of the jobs will be filled by people residing in Solihull, with the remainder in commuting from neighbouring areas. Taking this approach will ‘bake-in’ inward commuting reflecting an historic pattern of movement rather than shaping growth to be more sustainable by locating homes close to where work is
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.
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