Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7924
Received: 13/03/2019
Respondent: Mrs Elisabeth Hedley
There is no justification for using the 2014 based houshold projections to establish local housing need. This methodology produces an annual delivery rate of 885 dwellings per annum. This is double the annual rate achieved over the last 10 years and is unrealistic. If the contribution to the HMA shortfall is increased this rate will be even higher and well above the government cap. It will be undeliverable An exceptional circumstances case is justified having regard to the unachievable required rate and its unacceptable impact on the Green Belt setting and quality of the Borough. This requirement should be capped.
The methodology produces an annual rate of housebuilding for the Borough of 885 dwellings per annum for a 2000 contribution t 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 tot he height of the boom. It is double the average rate of delivery over the last 10 years and is above the cap which would apply if the calculation related solely to Solihull's own housing need. It is inconceivable that such a high rate of delivery can be sustained as an average over the life of the Draft Local Plan (DLP) 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 DLP will make to the 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 is the case, it will lead to further, potentially significant increase in the housebuilding rate per annum which will be at a rate well in excess of the government cap. How can this be achieved without substantial further loss of Green Belt and ruining the character of the Borough? More practicably, how can such a 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 the Borough's need must take account of any HMA shortfall contribution. it is illogical to do anything else. The council should make a case of exceptional circumstances to the government. The exceptional circumstances case should also demonstrate the substantial harm that would result form such a scale of development on the character and distinctiveness of the Borough's communities arising from such a large scale loss of Green Belt and unacceptable transportation and infrastructure impacts.
Please also see the response of the Forum which I support and fully endorse.