Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14925
Received: 14/12/2020
Respondent: The Home Builders Federation Midland Region
Legally compliant? No
Sound? No
Duty to co-operate? No
Para. 227-228
Housing Market Area, DtC:
- Council should identify cross-boundary matters to be addressed and the progress of co-operation in addressing these matters in Statements of Common Ground, to comply with NPPF Para.’s 24-27.
- SoCGs should be publicly available to provide transparency.
- HBF notes no SOCGs accompany the Draft Submission Plan consultation, contrary to PPG. Therefore impossible to assess if Council has satisfied legal requirements of DtC.
- GBBCHMA Position Statement (July 2020) is not a SoCG.
- It is misleading for GBBCHMA Position Statement to conclude that residual HMA shortfall is only 2,597 dwellings. This compares figures against the Strategic Growth Study (Table 5) rather than adopted housing requirements and unmet needs (Table 2).
- Figures do not account for Black Country shortfall
- Figures are not based on standard methodology
- Housing requirement should be 12,598 dpa under revised standard methodology not 10,399 dpa as in Table 5.
- Estimated housing land supply includes allowances from proposed allocation in draft Plan, as yet untested at Examination, plus other sources from non-allocations.
- Lack of agreement on how GBBCHMA housing needs will be met in full, four years after adoption of Birmingham Development Plan.
- Before DSP is submitted for Examination, the HBF expects the GBBCHMA authorities to produce an agreed SoCG setting out:
o Where unmet housing need will be met
o Each authority will meet its own LHN, and a defined amount of unmet LHN. This cumulative figure will be the housing requirement for each respective authority.
o Acknowledgement that need additional land supply over and above LHN for flexibility
o Agreement that is housing requirement figures materially change due to the Government’s standard methodology, a revised SoCG will be agreed within 6 months.
- If strategic matter of meeting full HMA housing needs is not set out in an agreed SoCG, then DtC will not be met, and plan is unsound.
- Council should embark on another stage of public consultation after publication of SoCG, to invite further comments on Council’s compliance with DtC. In absence of such an opportunity, HBF will submit further comments either written or orally during Examination.
See attached letter