Local Housing Need

Showing comments and forms 1 to 30 of 117

Support

Draft Local Plan - Supplementary Consultation

Representation ID: 6629

Received: 06/02/2019

Respondent: Mr Harry Siggs

Representation Summary:

The borough does not exist in isolation. It is part of the Birmingham conurbation and largely is providing dormitory facilities for the wider community.
Plan should be more holistic looking at needs and land stock across the region, not apportioned mathematically by local authority. Warwickshire has huge reserves of land without compromising green belt and labour shortages, but transport infrastructure prohibits integration with urban centres. Additional accommodation could be provided if suitable transport integration was prioritised. This should be addressed by the WMCA.

Full text:

The borough does not exist in isolation. It is part of the Birmingham conurbation and largely is providing dormitory facilities for the wider community.

Other more rural parts of the region in Warwickshire could provide suitable additional accommodation without compromising green belt if suitable transport integration was prioritised.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 6649

Received: 08/02/2019

Respondent: Councillor J Tildesley

Representation Summary:

Solihull can only grow to a certain size due to limited land available. Birmingham must do more to meet its own housing need.

Full text:

See Letter

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 6691

Received: 14/02/2019

Respondent: Gillian Griggs

Representation Summary:

There is no clear justification for using the 2014 based household projection figures to establish local housing need. The 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

Full text:

.
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.

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 6790

Received: 24/02/2019

Respondent: Mrs Sarah Bridge

Representation Summary:

I understand that Solihull is above average for air quality standards.
I also think too much develoment is happening at once in the shirley area of the borough. No extra provision of being made for infrastructure-eg doctors and train station parking capacity/as well as being able to get on an actual train (I already struggle with both issues at whitlocks end)
I am also concerned about flooding as we already have major issues in Cheswick Green

Full text:

I understand that Solihull is above average for air quality standards.
I also think too much develoment is happening at once in the shirley area of the borough. No extra provision of being made for infrastructure-eg doctors and train station parking capacity/as well as being able to get on an actual train (I already struggle with both issues at whitlocks end)
I am also concerned about flooding as we already have major issues in Cheswick Green

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 6829

Received: 26/02/2019

Respondent: Mr David Roberts

Representation Summary:

It is now recognised that the projected housing requirement nationally is incorrect and less than originally envisaged see the National Office Of Statistics reduction of national number reduced to 248000 from 300000. Birmingham for its part has reduced the actual number on their housing list significantly and you are not recognising this. I have discussed this at length with officers in Birmingham.

Full text:

I am perplexed at the housing number proposed in Knowle Dorridge and Bentley Heath ,and in fact the Borough .
As a result of " duty to cooperate " with neighbouring Birmingham Solihull is allowing itself to be bullied into providing more overspill housing .
It is now recognised that the projected housing requirement nationally is incorrect and less than originally envisaged see the National Office Of Statistics reduction of national number reduced to 248000 from 300000 . The 300000 per annum being the number the Government / James Brokenshire keeps banging on about ,it's a much higher number than is necessary.
Birmingham for their part have reduced the actual number on their housing list significantly and you are not recognising this . I have dicussed this at length with officers in Birmingham .
Please explain why Bromsgrove escapes the " duty to cooperate " . Could it be something to do with who represents them in Parliament ?

The local plan is a complete ignorance of local infrastructure . Arden School has 1500 places in 1-5th years and is at capacity It Can't take 1800 .No new secondary school,capacity envisaged !
The Station current car parking can not cope .NO PLan to alleviate this .
Public transport is not properly assessed in your "plan "

The Doctors are overwhelmed .NO Plan to alleviate this .
In adequate schooling at junior and infant levels . Not thought out !
3 exits onto Warwick road from the proposed Arden Triangle development will relieve Station Road says you document - who thought that one out ? It is completely unrealistic. The A41 through Knowle is the busiest trunk road through a village in the country .See pervious surveys ,only Canned when the M42 was built .

The overdevelopment of Knowle with Hampton Road will create an enormous traffic jam at rush hour times with no consideration of the extra traffic caused by the envisaged developments .

There has been no assessment of the extra load being imposed on M42 by the developments that will inevitably feed onto the motorway ,let alone the possibilities caused by Arden Cross and HS2 .

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7280

Received: 10/03/2019

Respondent: Mr Trevor Vaisey

Representation Summary:

Why is there a need for so many houses in the Shirley area ?

Full text:

Why is there a need for so many houses in the Shirley area ?

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7318

Received: 10/03/2019

Respondent: Pauline Daniels

Representation Summary:

Why are there so many homes proposed near Shirley.

Full text:

Why are there so many homes near Shirley.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 7358

Received: 11/03/2019

Respondent: Mr Esak Shabudin

Representation Summary:

Why are there so many homes earmarked for Solihull?

Full text:

Why are there so many homes earmarked for Solihull?

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7370

Received: 11/03/2019

Respondent: Golden End Farms

Agent: Delta Planning

Representation Summary:

We agree with the adoption of the Governments Standard Methodology for assessing the Borough's housing need and the use of the 2014 based household projections.

Where we disagree is the contribution that the Plan is currently seeking to make towards the wider Housing Market Area which is clearly insufficient. By only proposing to accommodate 2,000 homes, SMBC is falling way short of its responsibilities in addressing housing requirements across the HMA.

Please see full representation.

Full text:

We agree with the adoption of the Governments Standard Methodology for assessing the Borough's housing need and the use of the 2014 based household projections.

Where we disagree is the contribution that the Plan is currently seeking to make towards the wider Housing Market Area which is clearly insufficient. We note that this issue is not part of the current supplementary consultation but consider this is a missed opportunity and the Council should be more realistic in the contribution it needs to make. At present the plan is offering to provide for 2,000 additional homes towards addressing the HMA shortfall (approximately 5% of the market area deficit). This is simply not enough. There are very close links between Solihull and Birmingham given the Borough's proximity to the city and extensive shared boundary, established travel-to-work patterns and complementary nature of housing and employment provision. It is widely accepted that the edge of the conurbation offers the most obvious and sustainable option to meet Birmingham's shortfall. By only proposing to accommodate 2,000 homes, SMBC is falling way short of its responsibilities in addressing housing requirements across the HMA.

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7390

Received: 11/03/2019

Respondent: Mrs Wendy Murphy

Representation Summary:

why are there so many homes proposed for Shirley?

Full text:

why are there so many homes proposed for Shirley?

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 7406

Received: 11/03/2019

Respondent: Mr Kevin Thomas

Representation Summary:

Cannot think of any reason to support special circumstances being required.

Full text:

Cannot think of any reason to support special circumstances being required.

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7427

Received: 13/03/2019

Respondent: Mr Geoffrey Wheeler

Representation Summary:

Paragraph 45 states that it is prudent to use the higher projections. This is wrong. It is very dangerous to release too much land as stated by Government Advisor Professor Wenban-Smith in his report of 27 Jan 2016 - "Critique of West Midlands Housing Needs Assessment" paragraphs 24/25. Over provision can never be corrected; under provision can be corrected later when needs are better defined.
I look forward to the submission version of the plan and expect to see reduced numbers leading to significant sites being removed from the allocations in the Green Belt. .

Full text:

Paragraph 45 states that it is prudent to use the higher projections. This is wrong. It is very dangerous to release too much land as stated by Government Advisor Professor Wenban-Smith in his report of 27 Jan 2016 - "Critique of West Midlands Housing Needs Assessment" paragraphs 24/25. Over provision can never be corrected; under provision can be corrected later when needs are better defined.
I look forward to the submission version of the plan and expect to see reduced numbers leading to significant sites being removed from the allocations in the Green Belt. .

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7482

Received: 11/03/2019

Respondent: Portland Planning Consultants

Representation Summary:

The global promotion of UK Central Hub will generate migration demand likely to be different to the historical demand. Thus the migration trends arising from the UK Central Hub initiative are wholly different to the norm represented by the 2014 based housing projections. Analysis of a parallel project centred on Ebbsfleet on the HS1 route indicates extraneous migration is likely to be much higher than historical migration. Exceptional circumstances are considered to prevail as a result of the UK Central Hub, which need to be taken into account in the overall housing requirement.

Full text:

The proposals within the Local Plan Review include substantial provision of housing at the UK Central Hub comprising an estimated 2500 dwellings to be delivered within the Plan period. The Council have advised that their housing figures are based on the standard methodology. The standard methodology comprises two elements. The first is the 2014 based estimates of numbers of households projected by the Department of Housing, Communities and Local Government which are essentially and extrapolation of household formation based on the existing and forecast demographic structure taken together with past known trends of inter regional, intra regional and international migration. The second is an adjustment to take account of affordability deficiencies.
The UK Central Hub is an initiative aimed at exploiting the advantages of the new HS2 infrastructure in the interest of furthering the economic well being of the West Midlands Conurbation.
The Overview download from the promotional web site states the hub area is :-
The economic powerhouse of UK Central, The Hub offers inward investors a central and globally connected location to grow their business. Realising the development potential of the High Speed Rail Interchange, a 140 hectare site within The Hub is planned to become a sustainable garden city for the 21st century.
Other promotional material is delivered in Mandarin confirming the global targeting of the project's economic advantages.
Given this global linkage it can be reasonably supposed that a material proportion of new residents will be migrating in a manner that is materially different from the patterns used in the standard methodology. The circumstances of the development of UK Central Hub are therefore not covered by the trend material which underlies the standard methodology and as an exception to the trend the development of UK Central Hub represents an exceptional circumstance. It is necessary therefore for the additional population arising from this to be taken into account as failure to do so will result in under provision of housing and a corresponding exacerbation of affordability problems which the standard methodology was designed to do.
When measured against Government policy which seeks to meet all strategic development needs (See NPPF 2019 paragraph 23) this would therefore represent a breach of the NPPF. Any breach of the NPPF represents a failure to secure sustainable development. The breach of the NPPF amounts to a situation where the plan would be unsound but more importantly would amount to a breach of the statutory duty on Local Planning Authorities under Section 39 of the Planning and Compulsory Purchase Act the 2004.
The nearest example of the efforts to exploit the High Speed hub in the UK is Ebbsfleet International near Dartford in Kent. Like the ambitions for UK Central Hub the authorities there have sought to exploit the new economic opportunities afforded by a high speed rail link. Their advantages do not include ready access to international air transport as is the case of UK Central.
In order to consider the weight that should be attached to this objection I have checked the figures for housing need in Dartford Borough (where most of the Ebbsfleet development will be located).
The Core Strategy for Dartford proposes (at table 2 on Page 58) that during the period 2016-2026 some 9900 dwellings will be delivered - an annualised rate of 990. The base level 2014 table indicates a housing need of 778 dwellings per annum. This last figure includes the trend based migration evident before the Ebbsfleet initiative started to deliver additional houses. Thus the non trend migration which appears to flow from the Ebbsfleet initiative totals, over the period 2016-2026, some 2120 dwellings [(990-778) x 10].
If a similar pattern were to be repeated in the case of UK Central Hub then this would indicate that the majority of the UK Central development in the plan period would be attributable to non trend migration not hitherto absorbed into the 2014 base household forecasts.
In this context, and to avoid potential unsoundness and breach of statutory duty, the Council is invited to examine closely the impact of UK Central Hub on deviation from the migration trends evident from the 2014 forecasts.
Consideration of the overall housing need in the conurbation, and potential delivery within the conurbation of the conurbation needs has been assessed in the context of the 2014 based household projections. These point to the overall conurbation needs being about the same as when Solihull earmarked the figure of 2000 dwellings to meet conurbation needs. Thus the move to a figure derived from the 2014 based household projections is not materially different from the figures derived from the former housing need calculations. There is no overall change from the underly sub regional figures which will allow the UK Central Hub generated addition migration flows to be offset against changes arising from a move to the standard methodology.
In the context of the foregoing it is submitted that the overall housing requirement needs to take into account this exceptional circumstance presented by the advent of UK Central Hub. The evidence from Ebbsfleet is that it could be very substantial. A failure to take this into account points to a breach of statute and unsoundness through being inconsistent with national policy for delivery of the housing needs of an area having regard to all sources of need.

Support

Draft Local Plan - Supplementary Consultation

Representation ID: 7592

Received: 11/03/2019

Respondent: Solihull Ratepayers Association

Representation Summary:

support the council using the standard methodology

Full text:

The Solihull Ratepayers Members Forum and AGM on 8th March considered a presentation on the Solihull Local Plan Review Consultation and the presentations of our views are set out in the attached letter

Attachments:

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 7619

Received: 12/03/2019

Respondent: Mr William Cairns

Representation Summary:

The apparent fudge on the required housing numbers clearly shows that SMBC are running scared of demands that will be placed on them from the HMA. Failure to use the latest housing forecast data reveals a state of mind commensurate with fear of being run over by developers again in the courts and the demands of neighbouring councils in the HMA.
I am concerned about the uncertainty and anxiety that the preliminary estimates have introduced into the process of commenting on the draft plan given that revision is all but certain to occur.

Full text:

This is my response to the above document. I have presented my comments it in the order of the sections and paragraphs in the Draft. I have restricted my comments to those sections that particularly relate to me.
see letter for full text

Support

Draft Local Plan - Supplementary Consultation

Representation ID: 7643

Received: 12/03/2019

Respondent: Mrs Fiona Somerville

Representation Summary:

This would be open to a variety of interpretations by Planning Officers and we are well aware of the problems caused by Planning Officers interpreting policies to justify their recommendations.

Full text:

This would be open to a variety of interpretations by Planning Officers and we are well aware of the problems caused by Planning Officers interpreting policies to justify their recommendations.

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7646

Received: 12/03/2019

Respondent: Mr N Walters

Representation Summary:

There is no fomally recognised definition of Affordable housing. SMBC have guidance making developers provide affordable housing on most new sites, but these homes are usually targeted towards Housing Associations and council housing waiting lists, there is no consideration towards provision of standard family housing for young families who are above the threshold criteria for HA affordable housing or entry onto council housing lists, they are a forgotten and under represented cohort that get overlooked.

Full text:

There is no fomally recognised definition of Affordable housing. SMBC have guidance making developers provide affordable housing on most new sites, but these homes are usually targeted towards Housing Associations and council housing waiting lists, there is no consideration towards provision of standard family housing for young families who are above the threshold criteria for HA affordable housing or entry onto council housing lists, they are a forgotten and under represented cohort that get overlooked.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 7690

Received: 12/03/2019

Respondent: Landowner Winterton Farm

Agent: Savills

Representation Summary:

We do not consider there are exceptional circumstances to deviate from standard methodology.
The Council should be using the standard methodology to determine the minimum number of homes needed and the 2014 based household projections should be used for standard methodology calculations to establish the Local Housing Need.
Insufficient contribution to wider HMA shortfall.

Full text:

please find attached our response to the Solihull Local Plan Review Draft Supplementary Consultation and a site location plan for Site 173 -Winterton Farm

Attachments:

Object

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.

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7876

Received: 13/03/2019

Respondent: Persimmon Homes Central

Representation Summary:

No exceptional circumstances to justify the Council using an alternative approach to the Government's standard methodology.
This figure is only the minimum starting point. Any ambitions to support economic growth, to deliver affordable housing and to meet unmet housing needs from elsewhere are additional to the local housing need figure.
No clear justification for 2,000 dwellings as the chosen figure for Solihull's contribution to the HMA shortfall.

Full text:

please refer to supporting document March 2019 Persimmon Reps Draft Solihull LPR

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 7893

Received: 13/03/2019

Respondent: Diane Duftane

Representation Summary:

I believe the council has based it's calculation on the 2014 Office of National Statistics figures and there is a clear case that the 2016 figures could be used which shows a lower calculation. With the current proposals the council would need to build 885 homes per year, a target that has never been obtained.

Full text:

I would like to register my concerns and objections to the current draft local plan.
Shirley and Blyth Valley has now 38% of the proposed housing which is more than the lions share and will link many areas together i.e. Cheswich Green, Dickens Heath, & Tidbury Green. All will become just another hugh conurbation with no identity.

I believe the council has based it's calculation on the 2014 Office of National Statistics figures and there is a clear case that the 2016 figures could be used which shows a lower calculation.
There has been no consideration of increase of traffic on the current road system and public transport system, the Mott Macdonald plan was not obtained. The council state that public transport will be improved, however if there is no public transport now how can that be improved.
There is already a lack of local GP's and pupils are already travelling far and wide due to lack of schools in the appropriate areas. There are no plans in the current draft for extra GPs and schools.
With the current proposals the council would need to build 885 homes per year, a target that has never been obtained.
Site 4 an extension of Dickens Heath, proposed as it is near a station. Dickens Heath which won best village was based on all houses being within a 10 minute walk to shops, this is something which is already null and void. Site 4 states that improvements will be made to the infrastructure however roads cannot be improved as there are ancient hedgerows, which again the council appeared not to have done their homework. The council has asked for alternative sites, if being near a station is all that is required, have the fields to the east of Widney Manor Station been considered. Widney Manor Station is much better linked.
Site 26 I have no objections providing that the level of housing is kept as per the plan however the increase in traffic on Bills Lanes would need the Mott Macdonald plan being obtained prior to any permissions being granted.
However with this development then site 13 is the mitigation against the loss of green belt and would be beneficial for the community if this was designated a Village Green/ Nature Reserve.
What is quite frightening is that the HSR report into the historic past of Blyth Valley has not been acknowledged by Solihull Council, A report that was widely available and already printed. A Report that could have considerable bearing on future housing.

Support

Draft Local Plan - Supplementary Consultation

Representation ID: 7900

Received: 13/03/2019

Respondent: Stratford on Avon District Council

Representation Summary:

Stratford-on-Avon District Council is supportive of Solihull's conclusion that the standard methodology should be used. Should SMBC wish to use an alternative methodology, careful consideration would need to be given to the potential wider and possibly consequential implications on other authorities within the Greater Birmingham Housing Market Area.

Full text:

see attached representation

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 7924

Received: 13/03/2019

Respondent: Mrs Elisabeth Hedley

Representation Summary:

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.

Full text:

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.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 8022

Received: 13/03/2019

Respondent: Mrs Christine Thorp

Representation Summary:

It is not clear to me that environmental and pollution impacts have truly been taken into consideration in the methodology.
In many cases farm land is being used/seized. What limited farm land we had created a necessary boundary between blocks of development. There is no vision for a green sustainable Solihull.

Full text:

It is not clear to me that environmental and pollution impacts have truly been taken into consideration in the methodology.
In many cases farm land is being used/seized. What limited farm land we had created a necessary boundary between blocks of development. There is no vision for a green sustainable Solihull.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 8027

Received: 13/03/2019

Respondent: Mrs Christine Thorp

Representation Summary:

There are areas of Solihull which are very badly congested and polluted. There are circumstances where the Council should be intervening in building plans to alleviate congestion and not add to already existing problems. Traffic congestion is a huge problem in the area.

Full text:

There are areas of Solihull which are very badly congested and polluted. There are circumstances where the Council should be intervening in building plans to alleviate congestion and not add to already existing problems. Traffic congestion is a huge problem in the area.

Support

Draft Local Plan - Supplementary Consultation

Representation ID: 8052

Received: 14/03/2019

Respondent: Countryside Planning Services Limited

Agent: Countryside Planning Services Limited

Representation Summary:

The standard methodology adopted to find the local housing need for the Development Plan accords with both the National Planning Policy Framework and Planning Policy Guidance. This methodology takes account of the Borough's needs and those of neighbouring Authorities, who are unable to meet their own needs. There are, therefore, no exceptional circumstances that would warrant an alternative approach to be adopted or factors that mean that the standard methodology would require additional adjustment.

Full text:

The standard methodology adopted to find the local housing need for the Development Plan accords with both the National Planning Policy Framework and Planning Policy Guidance. This methodology takes account of the Borough's needs and those of neighbouring Authorities, who are unable to meet their own needs. There are, therefore, no exceptional circumstances that would warrant an alternative approach to be adopted or factors that mean that the standard methodology would require additional adjustment.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 8069

Received: 13/03/2019

Respondent: Redditch Borough Council

Representation Summary:

Concerns remain over justification for commitment to test potential for 2,000 dwellings towards wider HMA needs. This level does not adequately respond to HMA shortfall, given Solihull's relationship with Birmingham. Figure not agreed by HMA authorities and is not a firm basis for development strategy and site allocations. This is a fundamental issue that will need to be addressed in Statement of Common Ground. Addressing this at Submission stage is too late in process as this will have significant implications for the development strategy, and knock on effects for neighbouring areas. Urge progression of Statement of Common Ground.

Full text:

see letter
RBC has read the Supplementary Consultation (January 2019) with interest and wishes to comment on the parts of the draft plan that are relevant to the district and the wider Greater Birmingham Housing Market Area (GBHMA).

Attachments:

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 8072

Received: 13/03/2019

Respondent: Bromsgrove District Council

Representation Summary:

Concerns remain over lack of clear justification for commitment to provide for 2,000 dwellings towards wider HMA needs. Figure not agreed by HMA authorities and is not a firm basis for development strategy and site allocations. This is a fundamental issue that will need to be addressed in Statement of Common Ground, have the support of HMA authorities and be based on an apportionment methodology. Addressing this at Submission stage is too late in process as this will have significant implications for the development strategy, and knock on effects for neighbouring areas. Urge progression of Statement of Common Ground.

Full text:

see letter
BDC has read the Supplementary Consultation (January 2019) with interest and wishes to comment on the parts of the draft plan that are relevant to the district and the wider Greater Birmingham Housing Market Area (GBHMA).

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Representation ID: 8091

Received: 14/03/2019

Respondent: Terra Strategic

Agent: Delta Planning

Representation Summary:

We agree with the adoption of the Governments Standard Methodology for assessing the Borough's housing need and the use of the 2014 based household projections.

Where we disagree is the contribution that the Plan is currently seeking to make towards the wider Housing Market Area which is clearly insufficient.

By only proposing to accommodate 2,000 homes, SMBC is falling way short of its responsibilities in addressing housing requirements across the HMA.

Please see full representation.

Full text:

We agree with the adoption of the Governments Standard Methodology for assessing the Borough's housing need and the use of the 2014 based household projections.

Where we disagree is the contribution that the Plan is currently seeking to make towards the wider Housing Market Area which is clearly insufficient. We note that this issue is not part of the current supplementary consultation but consider this is a missed opportunity and the Council should be more realistic in the contribution it needs to make. At present the plan is offering to provide for 2,000 additional homes towards addressing the HMA shortfall (approximately 5% of the market area deficit). This is simply not enough. There are very close links between Solihull and Birmingham given the Borough's proximity to the city and extensive shared boundary, established travel-to-work patterns and complementary nature of housing and employment provision. It is widely accepted that the edge of the conurbation offers the most obvious and sustainable option to meet Birmingham's shortfall. By only proposing to accommodate 2,000 homes, SMBC is falling way short of its responsibilities in addressing housing requirements across the HMA.

Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 8116

Received: 14/03/2019

Respondent: Tidbury Green Parish Council

Representation Summary:

SMBC should press Government on use of latest projections to reduce unnecessary loss of highly performing green belt. Local need plus HMA contribution is above highest level achieved in Borough and double average, and above cap that would apply if solely local need. Inconceivable that this rate can be delivered, or that industry could build even if permissions granted. Using 2016 projection would produce more realistic figure and can be justified as exceptional circumstances.

Full text:

Please find attached Tidbury Green Parish Council's response to the Draft Local Plan Supplementary Consultation, along with the appendices referred to within our response.