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Draft Local Plan - Supplementary Consultation

Representation ID: 7842

Received: 13/03/2019

Respondent: Richborough Estates

Agent: Star Planning and Development

Representation Summary:

Additional housing allocations required to meet housing needs, as there will be circumstances where appropriate to consider whether actual housing need is higher than standard method indicates. The 2,000 additional dwellings contribution toward meeting wider needs of HMA, has yet to be determined as appropriate and may well increase.
The WMCA agreement to increase housing by 2030-2031 is above the standard methodology level and it is unclear how emerging DLP responds to this requirement.
HS2 is likely to increase number of homes needed locally, and the minimum housing provision does not take into account the future impact of HS2.

Full text:

1. Richborough Estates Limited recognise that the standard methodology is the appropriate starting point for the calculation of the minimum annual local housing need figure. Based upon the methodology included in the Planning Practice Guidance the methodology indicate provision of circa 767 dwellings per annum between 2018 and 2035 is the minimum annual local housing need figure for Solihull MBC.

2. However, the calculated figure is only a minimum and there will be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates (Practice Guidance Paragraph: 010 Reference ID: 2a-010-20190220). To date, the only adjustment made is an assumption that some 2,000 additional dwellings will be required within Solihull MBC to provide a contribution towards meeting the wider needs of the Housing Market Area (HMA). Whether this level of provision is appropriate has yet to be formally determined and may well increase.

3. Further, the Mayor of the West Midlands Combined Authority, Andy Street, agreed with the Government in March 2018 a commitment to increase housing in the West Midlands by delivering 215,000 new homes by 2030/31. This target is above the level of new homes for the West Midlands indicated by the standard methodology. There is an intention that by December 2019 the Local Plans within constituent and non-constituent authorities are to be updated as necessary to deliver and accommodate 215,000 homes by 2030/31. From the consultation document, it is unclear how the emerging Solihull Local Plan Review fits into this commitment if it is solely based upon the standard methodology.

4. In addition to the above, HS2 represents a nationally important infrastructure improvement which is likely to drive an increase in the homes needed locally. Although the emerging Local Plan is proposing growth occurs around the proposed interchange at Arden Cross, the minimum housing provision calculated by the standard methodology does not take into account the future impact of HS2 on the local housing market and demand for new homes, including people who may well commute to London.

5. Accordingly, and for the reasons identified, Richborough Estates recommends that the Council does robustly consider all the circumstances where might be appropriate to consider the actual housing need for Solihull MBC being higher than the standard method identifies.