Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 15026
Received: 14/12/2020
Respondent: Kier Living Ltd - Coleshill Road
Agent: Mr Hywel James
Legally compliant? No
Sound? No
Duty to co-operate? No
Housing Supply - lack of buffer
The total buffer (taking into account the 10% lapse rate) above the minimum housing requirement is only 1.9%, providing insufficient flexibility, should sites not reach full capacity, delayed/deleted, or windfall delivery rate falls.
Conflicts with NPPF Para. 11.
Insufficient buffer could result in DSP unable to meet its minimum housing requirement, contrary to NPPF Para. 35a and 59.
See recent examples:
- Rugby Local Plan (June 2019) include 17.5% buffer (which includes unmet needs);
- Nuneaton and Bedworth Local Plan (June 2019) include 5.5% buffer, which Inspector called 'very modest' but cautiously considered acceptable in report.
• An increased buffer above the minimum housing requirement must be provided;
• A more realistic windfall delivery rate should be assumed, having regard to fact that the supply
will have diminished based on recent high delivery rates;
• Additional housing allocations are required, including smaller sites such as the CFS 193, to boost the
supply and offer better resilience.
See attached letter