.
It is acknowledged that the methodology is imposed at national level and that utilising the 2014 based figures produces a higher figure than the latest projections (2016) indicate are necessary. This is a matter that the Council should continue to press the government on bearing in mind that it has potentially significant consequences for the loss of green belt, the protection of which is also a government priority.
The methodology produces an annual rate of house building for the Borough of 885 dwellings per year, allowing for a 2000 house contribution to the HMA shortfall. This rate of delivery is above the highest rate that has been achieved in the Borough in one year which was in 2005 leading up to the height of the boom. It is double the average rate of delivery over the last 10 years and it is above the cap that would apply if the calculation related solely to Solihull's housing need. It is inconceivable that such a high rate of delivery can be sustained as an average over the life of the Local Plan, not least because the house building industry does not have the resources to deliver such a rate even if planning permissions were quickly forthcoming.
It is noted that there is no change in the assumption that the draft Local Plan will make a 2000 house contribution to meeting the HMA shortfall. This will not be reviewed until the Submission version of the DLP. It is widely believed that the Council will have to increase this number. If this number is increased, it will lead to a further, potentially significant, increase in the housebuilding rate per annum which will be at a rate well in excess of the government cap. How will this be achieved without substantial further loss of Green Belt and ruining the character of the Borough? More practicably, how can such a high number be delivered year on year? It is simply not credible or realistic.
It is considered that the cap that is applied to housebuilding in respect of Borough's need should take account of any HMA shortfall contribution. It is illogical to do otherwise. Such considerations justify the Council making a case of exceptional circumstances to the government. In addition, or alternatively, the Council should reduce any contribution to the HMA shortfall to ensure that the total rate of annual delivery is within the overall cap, provided that it can be demonstrated that this is deliverable. The exceptional circumstances case should also demonstrate the substantial harm that would result from such a scale of development on the character and distinctiveness of the Borough's communities arising from the large scale loss of Green Belt and unacceptable transportation and infrastructure impacts.