Object

Representation ID: 14926

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

LHN (Para. 220) & Housing Requirement (Para. 228):
- PPG clearly state standard methodology is the minimum starting point for determining housing need, it does not produce a housing requirement figure.
- The Council has decided to plan for 22,998 jobs growth by 2036 based on Baseline jobs forecast plus UK Central Hub Scenario.
- Other evidence published by the Council (Midlands HS2 Growth Strategy & UKC Hub Growth and Infrastructure Plans quoted in the Viability Study) identifies potential for much higher job numbers. Council should confirm there are no inconsistencies in the evidence, and HEDNA is not under-estimating the additional jobs growth from the UKC Hub.
- HBF query assumptions on commuting patterns for the Borough and UK Central Hub jobs, given Para. 26 of HEDNA also states that commuting ratios are known to have likely changed.
- The derivation of the 2,105 contribution to HMA shortfall is not defined, and not included in a SoCG. Seems to be just difference between LHN and Housing Land Supply.
- Affordable housing need figures for Solihull are significant, PPG states an increase in total housing figures may be considered to help deliver affordable housing.
- Govt has confirmed its intention to review standard methodology, proposed revision would increase LHN to 1,011 dpa.
- Govt committed to ensuring more homes are built, and supports Councils planning for growth. HEDNA has demonstrated that circumstances exist to justify a housing need higher than the standard methodology. PPG does not set any limitations on a higher figure.
- HBF believe Council should be more ambitious and significantly boost housing supply (NPPF Para. 59)
- Housing requirement in Policy P5 not set out as a minimum figure.