Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14694
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
Unmet needs: The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. Paragraph 227 of the Plan advises that Birmingham has unmet needs (37,900 homes), and paragraph 228 advises that the Plan is proposing a contribution of 2,105 homes towards unmet needs. However, there is no evidence that this level of contribution is agreed with Birmingham or other neighbouring authorities, or that the unmet needs that remain are to be addressed elsewhere. There is no evidence as to why the contribution is only 2,105 homes.
In addition to Birmingham’s needs, it is also noted the Black County Authorities estimate unmet housing needs of 29,260 homes and up to 570ha of employment land to 2038, and have written to the Council notifying them. The Council has suggested their unmet needs can be dealt with as part of the next review of the Local Plan. However, that is not evidence of effective joint working, but rather deferring its consideration which is evidence of an unsound Plan in being contrary to paragraph 35 c) of the Framework.
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