2. Question 1: Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?
2.1 The following responses are made in respect of Section 3: Challenges;
Challenge B- Meeting housing needs across the Borough, including the Borough's own needs and where possible assisting with accommodation the Housing Market Area (HMA) wide shortfall
2.2 Challenge B identifies the need for the Council to meet the Full Objectively Assessed Housing Need (FOAN) and accommodating some of the needs of the HMA shortfall.
2.3 The Council sets its objective of ensuring that provision for an "appropriate proportion" of the HMA shortfall is made within the Borough, whilst maintaining the other objectives of the plan with regard to achieving sustainable development.
2.4 Fulfilling the Duty to Cooperate will require the Borough Council to reach agreement with the other authorities throughout the HMA on how it can assist, in accommodating an appropriate portion of the unmet housing needs from across the HMA (as identified in the SHNS).
2.5 It is understood that the Spatial Plan for Growth (SPG) will comprise the vehicle to deliver this agreement, but it is unclear how this will be achieved in practice, bearing in mind that the SPG is in the hands of the GBSLEP and that it will be the responsibility of the relevant authorities to reach formal agreement on distribution of the unmet needs.
2.6 Whilst the Council has proposed to accommodate a further 2000 dwellings of the HMA shortfall beyond its own FOAN, there is no agreement between the other HMA authorities to demonstrate cooperation or any agreement to a distribution of the shortfall. The lack of such agreement if highlighted by the emerging response of North Warwickshire Borough Council included at Appendix II and which expresses concern that the Borough should accommodate a greater proportion of wider HMA growth.
2.7 In the absence of such effective collaboration, the Draft Local Plan is unsound and would potentially fail to ensure that the wider HMA housing requirement is met. The Plan would not satisfy the Duty to Co-operate under paragraph 178 of the NPPF and would therefore not be "positively prepared" in accordance with the requirements of paragraph 182 .
Objectives
2.8 We are also concerned about the lack of clarity over the mechanism to agree how the unmet HMA housing needs are going to be distributed and delivered. Any such agreement should be open to public scrutiny and should be based upon a clear evidential basis.
2.9 Within the GBSLEP Strategic Housing Needs Study Stage 3 (SHNS) report it is concluded (para 2.45) that "Of these 'missing dwellings', most should be within easy reach of Birmingham and to a lesser extent Solihull. This is where the largest imbalances between need and supply are found".
2.10 As such, the SHNS provides a clear steer towards Solihull accommodating a significant portion of the HMA Shortfall, bearing in mind that Birmingham itself is unable to meets its own needs (as tested through Examination).
2.11 There are a number of compelling reasons why Solihull is well placed to accommodate a significant part of the HMA shortfall:
* Economic Growth - the SHNS identifies the Borough as having the greatest rate of projected job growth of all the authorities within the HMA (25%) (Table 7.1 from Stage 3 Report). Furthermore, HS2 would provide a spur to economic growth which is recognised in the SHNS as "supergrowth" in respect of the UK Central initiative (see paras. 7.16 - 7.19 of Stage 3 Report).
* Public Transport Links - Solihull has strong public transport linkages with Birmingham which accounts for the greatest part of the HMA deficit and is where the SHNS suggests most of the missing dwellings should be within easy reach. The SHNS indicates that 8,345ha of land is available within the Borough within 3.75km of railway stations which is not affected by "absolute" constraints, which indicates that significant sustainable land is available if the Green Belt is reviewed.
* Lack of "Absolute Constraints" - Although the Borough is heavily constrained by Green Belt, this is a policy constraint which can be reviewed.
* An attractive and aspirational housing market - the Borough is one of the most attractive and aspirational places to live in the HMA. This is reflected in average house prices (third highest authority in HMA), affordability ratios (third worst in HMA) and low vacancy rates (1%- lowest in HMA).
2.12 As set out throughout our responses, there are strong grounds to suggest that Solihull Borough is well placed to deliver a significant portion of the unmet needs and this should be provided for through the Local Plan Review. It is critically important to the social and economic interest of the GBSLEP area that the HMA authorities provide a clear strategy and programme for joint working to effectively agree ("resulting in a final position", para. 181 of the NPPF) the distribution of unmet housing needs across the HMA.
2.13 Unless this is achieved it is highly likely that the Draft Local Plan will be found unsound and the Duty to Cooperate will not be met. Procrastination on this issue will delay the preparation of other Local Plans resulting in housing needs being unmet which will have significant adverse impacts across the HMA and risks stifling economic growth.
Action required to ensure "soundness"
2.14 The Council should amend the text under Challenge B second bullet to give greater certainty of approach with regard to the need to satisfy the "duty to co-operate" test with the other HMA authorities to;
"To satisfy the Duty to Cooperate test set out in the NPPF which will be achieved through accommodating an appropriate proportion of the HMA wide housing shortfall, in a manner which satisfies the principles of sustainable development."
2.15 The second bullet point under Objectives should be amended to;
"To ensure that provision is made for an appropriate provision of HMA shortfall in new housing land. This will be delivered based upon achieving formal agreement with the HMA authorities and based upon unique position of the Borough to assist in delivering new homes and economic growth as recommended in the GBSLEP SHNS."
Challenge D- Securing sustainable economic growth
2.16 Challenge D identifies under Key Economic Assets (fourth bullet) the potential impact of congestion arising from additional growth/housing upon Solihull's important regional and sub-regional role.
2.17 We are concerned that the Council's stated objectives do not reflect the important role that Solihull can deliver in terms of managing the threat of congestion on the road/ rail networks that would be caused through its failure to accommodate an appropriate level of housing growth upon the wider HMA as a result of unnecessary inward commuting to the Borough.
2.18 As a result, the text under challenge D would fail to result in a Draft Local Plan that is "positively prepared" or consistent with achieving sustainable development.
Action required to ensure "soundness"
2.19 The objectives under Challenge D should be amended with a new bullet to state;
"Maximise the opportunity for reducing congestion on motorways, the strategic rail network and rail through delivery of an appropriate level of new housing to meet the shortfall across the HMA within the Borough, where this can be achieved to deliver sustainable development."
Challenge E- Protecting key gaps between urban areas and settlement
2.20 Challenge E seeks to ensure that in meeting housing needs for Solihull and the wider HMA, that the integrity of the Green Belt and rural setting of the Borough is maintained.
2.21 The objectives underpinning the challenge fail to reflect the nature of technical assessments undertaken to provide justification for site release to ensure that environmental protection is achieved.
2.22 As a result, Challenge E of the Draft Local Plan does not set out to ensure that it is "justified" in accordance with the NPPF and that it is therefore, based upon the most appropriate strategy and a proportionate evidence base.
Action required to ensure "soundness"
2.23 The objective should be amended to state;
"Justification for the release of land from the Green Belt to meet the need to new development should be focused on those sites which perform least well against the functions of Green Belt and outcomes from the Borough's Green Belt Assessment."