Local Housing Need

Hockley Heath can not support further development due to lack of services ie. shops and there is no medical facilities. Localised flooding is already causing problems within the village. We need to protect the natural environment. There is a high bird population (owls, woodpeckers, sparrows, buzzards, blue tits) plus oak trees which provide essential oxygen and help diffuse heavy ground moisture.

The standard methodology has landed us with a housing crisis. Too many expensive houses which are unaffordable (e.g. £200,000 houses in new development at Arran Way, Smith's Wood), plus a proliferation of social housing in certain Wards. Social and Co-operative housing needs to be the priority - people and communities must prevail over private profit. In addition, affordable private housing ( market prices of below £90,000) should also be sought. This will be difficult, but that is the job of the Plan to alleviate the issues we are facing. We cannot go on as normal; 'normal' is failing our residents.

I do believe there are fundamental flaws in the methodology used to calculate the local housing need, the most significant of which is the use of affordability ratios and targeting a ratio of 4, as per section 43 of the Supplementary Consultation.

The affordability ratios referenced, define the house price to earnings ratio as follows: "By dividing the house price for a given area by its earnings, we produce a ratio which serves as an indicator of relative affordability. A higher ratio indicates that on average, it is less affordable for a resident to purchase a house in their local authority district. Conversely, a lower ratio indicates higher affordability in a local authority. While there are many more factors that influence affordability, the simple ratio provides an overview of geographic differences across England and Wales."
In using an affordability ratio as outlined it is essentially benchmarking affordability of housing based upon people already living within the region, based on their earnings. I would therefore question the relevance of this ratio, given that the population upon which it is based already live in the region, but also that in many cases earnings may be derived from outside of the region, for instance Birmingham City Centre.

In addition, the Supplementary Consultation is setting the local housing need based on house prices and earnings at a set point in time (2018), yet the Local Plan is based on an allocation over a period 2018 to 2035. With the prospect of HS2 and other factors, there is potential for significant earnings growth within the region during this period, therefore I would suggest the position should be reviewed at set intervals throughout the period to ensure the housing need remains relevant.

It might be better for the council to use the up to date method for calculating the housing requirement rather than using the 2014 method. This would see the actual requirement in the borough reduced.

Please see attached document
Kier Living own the majority of 'Land at the Rear of 74 - 108 Coleshill Heath Road', as it is referred to within the Solihull Strategic Housing and Employment Land Availability Assessment 2016 ("SHELAA")
(site ref. 193). This site has been promoted through the Call for Sites process (with a submission made in January 2018) and through the initial Regulation 18 consultation.

See Letter

See Letter

Birmingham City Council agree that there are no special circumstances justifying an alternative approach.
In accordance with the NPPF (para 60), any needs that cannot be met within neighbouring areas should also be taken into account in addition to the local housing need figure in establishing the amount of land to be planned for. The provision of 2000 additional dwellings to meet the HMA Shortfall was identified in the Draft Local Plan published in 2016 and remains an important contribution towards the HMA shortfall and the Table on Page 13 of the Consultation document shows that sufficient land supply has already been identified to meet local housing need as well as those 2,000 additional homes.
However, Birmingham City Council (BCC) has some concerns that this Consultation does not specifically address any potential revision to the contribution that Solihull is making towards the HMA shortfall as stated in Paragraph 5 of the Consultation Document.
A large amount of evidence has come forward since the last consultation (Draft Local Plan Stage (2016)) including the addition of more than 70 sites considered in this consultation as well as the publication of the West Midlands Strategic Growth Study (February 2018) carried out by GL Hearn. Scenarios which test the validity of the existing spatial strategy and the possibility of significantly higher housing provision and growth have yet to be fully considered and assessed through a sustainability appraisal process (even if this approach and evidence may go on to show that such higher levels are not justifiably achievable or deliverable).
Since the GL Hearn Study was published in February 2018, local planning authorities such as South Staffs and Lichfield have presented and tested scenarios within their local plan consultation documents for significant levels of growth over and above their local Housing Need in line with the Study. The Solihull Supplementary Consultation states that any potential to revise the contribution towards the HMA shortfall beyond the 2,000 dwellings already identified would be done as part of the Submission Draft Plan stage.
BCC would therefore need assurances that this course of action has been fully considered and implemented prior to Submission Draft Plan stage to demonstrate that Duty to Co-operate obligations have been fully considered and met in line with NPPF requirements. Such options would also need to be considered through the Sustainability Assessment process and the potential effects (positive or negative) any options may have on adjoining areas.

Solihull has had an affordability for many years - I was born and raised here, and returned to raise my own family following graduation and my marriage. Building thousands of houses, whether so called "affordable" houses or not, will not help this - forcing people to move to an area of high density, with poor infrastructure and transport facilities will lead to community adhesion issues and isolation.

Modern developments leave little green space, walls with narrow pathways and miniscule front gardens, all of which lead to a feeling of being trapped. Add into this the fact that there is little new employment in Solihull, and major employers are struggling, people have to commute much further for work, meaning anyone "left" in the new developments has no means of creating a life for themselves in an area they potentially didn't know before. This puts pressure on the entire system - isolation leading to mental health issues, lack of support for families, boredom for teenagers and crime hotspots as these sites are targetted.

Q1 Answer: Yes. As the number of houses will be beyond what we have previously demonstrated being able to do, we may have to explore the possibility of reducing the numbers.
There are 4 components that are presenting challenges to reaching the numbers expected under the methodology used here:
1. The Housing Market Area shortfall, which requires urgent attention. A contribution of 2000 houses to the shortfall will almost certainly be
challenged by neighbouring authorities. To be able to make a more significant contribution to the shortfall we may have to look for ways to reduce the number of dwellings expected under the current methodology or deviate from it.
2. Using the 2014 based household projections published in 2016 to form our baseline, as opposed to the 2016 based household projections published in 2018. The 87 additional houses per year (increase from 680 to 767 dwellings per annum) may not seem significant on their own, but in the context of them pushing our plans from the deliverable into uncharted territory means that we may fail in what we set out to do. This level of housebuilding presents significant challenge to the resources of the Local Authority, will meet with significant opposition in some areas of the borough and brings with it reputational risk that hasn't been faced before.
3. Most significantly, the affordability uplift makes a big difference to the number of houses Solihull Council are expected to deliver (130 or 146 additional houses per annum, depending on which year's ONS projections are used). Whilst I am in agreement that affordability needs to be addressed, I am not convinced that simply building more houses alone will have any beneficial impact on homes becoming affordable to those in need. Whilst there are numerous factors at government level that present challenges in delivery of affordable homes (a guaranteed 20% profit margin for developers being front and centre in achieving improvements), there are local challenges. Affordable land is a significant challenge to delivery, at a local level. Whilst we have alternative mechanisms that are attempting to address our contribution to this issue of affordability, I see no reason why doing more by way of delivering affordable housing shouldn't offer some flexibility on overall numbers. Surely that is the ultimate objective of the government in creating this methodology. If we had binding targets on affordable housing, in absolute numbers, rather than as ratios (that can be avoided by developers), I can see a way in which as a Local Authority, we are able to make a greater contribution towards addressing the housing crisis, whilst also protecting more of our greenbelt.
4. Finally, the demographic composition of Solihull Borough means that there is a significant proportion of new building is for retirement/extra care properties. As these properties are exempt from affordable provisions, there is limited downsizing happening. Most worryingly, it means that the limited downsizing that is happening, is confined to vacating the least affordable properties. This is creating a compound problem.
These issues need attending to in conjunction and some are out of the remit of the Local Authority. Those outside the remit of the Local Authority need attention from Government. Failure to do so will run the risk of a spate of housebuilding that addresses none of the associated/underlying issues.

Please see covering letter

Please see covering letter

Please see covering letter

Please see covering letter

Please see covering letter

Barton Willmore LLP is instructed by Rainier Developments Ltd (the 'Client') to submit representations to Solihull Metropolitan Borough Council's Draft Local Plan Regulation 18 Supplementary consultation (the 'draft Plan') in relation to their land interests at land south of Park Lane, Balsall Common (hereafter referred to as the 'site'). Prior to our Client's involvement promoting this site, it was
previously promoted for residential development and assessed by the Council in their Site Assessment Document as Site 305. We enclose a new Call for Sites submission alongside these representations which proposes employment development on the site.

see attached document

Its important new property is developed, but Solihull should take its share as an authority. THere a re too many proposed in this area

I believe there are exceptional circumstances that should inform Solihull's approach to its plan. These are specifically: a) the agreement made with Birmingham to provide 2000 dwellings of their shortfall identified in their 2018 Gtr Birmingham growth study up to 2033. In addition, the assumptions within this document assume a density within Solihull of 36dph which is the highest density of any rural areas surrounding Birmingham, the lowest being 15-20.

we need to provide houses

Local housing may be needed but NOT at the detriment of the local people

Housing should be allocated fairly

I support the opinions cited by the KDBH Neighbourhood plan reponse to this and other questions dated 12.03.19
In addition personally I believe there are exception circumstances in arriving at the housing need. Given that methodolgy generates rates of annual housing completion which have practically never been achieved in the Borough an alterative approach should be used.

1. Do you believe that there are exceptional circumstances that would justify the Council using an alternative approach, if so what are the exceptional circumstances and what should the alternative approach be?

The method used by the Council to determine the housing requirement for the Plan is not suitable. It uses a national methodology and outdated household projections. It is based on the assumption that there is no constraint to meeting the full projected requirement (now called 'Local Housing Need' in NPPF 2018).
The NPPF 2018 sets out at para 11 the principle for Plan-making:
Plans and decisions should apply a presumption in favour of sustainable development.
For Plan-making this means that:
a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas (footnote 5), unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area (footnote 6); or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.
Footnote 5 As established through statements of common ground (see paragraph 27).
Footnote 6 The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.

Solihull Borough, outside its built-up areas, is all land designated as Green Belt. The Green Belt is of greater than usual strategic (geographic) significance because it separates two cities, Birmingham and Coventry, by the area known as the Meriden Gap, which is only 6 miles wide and risks becoming narrower. It has been established policy in successive development plans and in regional strategies to retain the Green Belt between the two cities and to maintain very strong planning policies to prevent urbanisation of the land between them. This policy dates from the 1950s and has been supported by successive Solihull development plans - the UDPs adopted in 2000 and 2006, and the Solihull Local Plan adopted 2013. The Green Belt in Solihull provides a very strong reason for restricting the overall scale of development in the Plan area. The 'objectively assessed need' or 'local housing need' identified by the standard method cannot be met without undermining the Green Belt, listed as a policy in Footnote 6 of the NPPF..
A second policy to protect an area and asset of particular importance is that for the Knowle Village Conservation Area. Knowle is the most important Conservation Area is the Borough, and the designation aims to preserve its village character. Proposals to surround Knowle village with extensive housing to its north and southeast would undermine the Conservation Area's character and setting because Knowle would become a town in terms of population size and urban extent. Conservation Areas are listed in the NPPF's Glossary as Designated Heritage Assets. Designated Heritage Assets, like land designated as Green Belt, are included in NPPF Footnote 6 as one of the grounds for restricting development below the 'objectively assessed need'.
A further exceptional circumstance which makes Solihull unusual and justifies an alternative approach is the degree to which the Borough is the location for a large number of jobs taken by people who do not live there, and who commute in.
Solihull has a population of 210,400 (2015). The Draft Local Plan states at para 30 that the number of jobs in the Borough is 100,000, and that 50% of them are taken by people who do not live there. Thus 50,000 people commute into the Borough daily. There is also substantial commuting out of the Borough to Birmingham. The extent of commuting in and out of Solihull makes estimating 'local housing need' under the NPPF 2018 and PPG difficult and contentious. Solihull's employment growth has never been dependent on provision of housing and has not been held back by limitations on housing or on its price. The long-standing policy of the Council to encourage employment growth has been in the full knowledge that many of the jobs are filled by people living outside the Borough.
The conclusion to draw from para 30-31 of the Plan is that Solihull's housing requirement should not include provision for more than 50% of those who work in the Borough, perhaps less; but should include some provision for the needs of Birmingham. While this may appear paradoxical, it reflects the reality of the employment pattern and the interrelationship of Solihull and Birmingham.

The alternative approach to the standard method specified in the NPPF and PPG should therefore be capacity-led. The level of new housing in the Plan period should in principle be limited to the urban capacity on land which is not Green Belt, or whose development would not undermine the specific village character and conservation status of Knowle village and its setting.

There is scope for some changes to the Green Belt boundary in locations which do not affect the openness and rural character of the Meriden Gap, and do not undermine the village character and rural setting on the north, east and southeast of Knowle village. However these should be limited. The Solihull Green Belt Study gives some guidance on which areas of the Green Belt make the most and least contribution to its purposes; its status is however limited by the fact that it is a consultants' report and not a planning document that has been subject to public consultation or involvement in its preparation.

Housing Market Area

In the section 'Housing Market Area' (para 49-52), it is stated (para 49):
The Draft Local Plan included a commitment to accommodate 2,000 dwellings from the shortfall that is occurring in the wider Housing Market Area. Using the same contribution, the overall housing requirement to be addressed in the Local Plan Review would, using the standard methodology outlined above, be 15,039 dwellings over the period 2018 to 2035, or 885 dwellings per year.

There is no justification for this commitment to take 2,000 dwellings from the wider HMA, because that conflicts with the principles set out in NPPF para 11 and the Green Belt and Knowle Conservation Area constraints.

We are not aware that the Council has reached an agreement with adjoining Councils regarding its contribution to the HMA shortfall.

The rate of housing delivery suggested in the Consultation text, 885 dwellings/year for 17 years 2018-2035, is far above the highest number of completions in the Borough in any one year except in one year, 2005. It is double the rate of house completions that have been recorded over the last 10 years (2008-2018). It is also above the 'cap' that would apply if the standard method were to be used to calculate Solihull's own local housing need.

The proposed housing policy and projected housing requirement of 15,000 over 17 years is not sound, because it is not deliverable from past evidence. Such a high rate of delivery over the life of the Local Plan could never be achieved - it is double the past rate, the housebuilding industry does not have the resources to built at such a rate, it takes no account of economic cycles or the projected economic downturn of the next few years.

The Council can instead use the 2016-based household projections, which are independently published by the ONS and indicate the most likely household growth in the Borough given the many constraints. This is an annual growth of 550 households, or 9,350 over 17 years 2018-2035.

That level of housing provision is largely achievable within the constraints of the Green Belt and the Designated Heritage Asset of Knowle Village Conservation Area. The Solihull Housing Land Supply table (page 13) shows that housing supply excluding 'Allocated Sites' (6,310 dwellings) and UK Central Hub (2,500 dw) is 7,355. (The 'minus 400' or 10% reduction applied to sites with planning permission and SLP 2013 allocated sites is not justified. Experience in the Borough in recent decades is that generally the number of houses given planning permission at detailed application stage is above the Local Plan number, not below it.) Therefore there is capacity for 13 years of the Plan period, up to 2031, without needing new allocated sites which are now Green Belt, if the most recent household projections for the Borough are used.

Housing Land Supply: Small Sites

The Consultation document at para 56-57 addresses the issue of 'Small Sites' but there is no consultation question attached. In the previous consultation (Dec 2016-Feb 2017) there was significant comment that the Local Plan is relying on large housing allocations and contains very few small sites, despite national policy to encourage small sites which can be developed with short lead-time and quickly, compared to the slow rate at which large sites reach detailed permission stage and then are built out. NPPF 2018 para 68 says: 'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly'.

Para 56-57 seek to justify the Local Plan's preference for large sites by asserting that national policy is complied with if only 1500 houses are proposed on small sites below 1 ha. It says that since windfall sites (2250 dw) and brownfield-register sites (400 dw) would be small sites, 'these sources will comfortably exceed the 10% requirement for small sites'.

NPPF 2018 para 68(a) in fact states that planning authorities should identify land to accommodate 'at least 10%' on sites no larger than 1 ha. But this does not mean that the remainder can therefore be proposed on large site allocations. There are many sites between 1 ha and 5 ha which are 'small or medium' and would not be large allocated sites. Many were advanced by developer or property interests at the call-for-sites stage but have not been accepted.

There are good reasons to maximise the number of small and medium sites:

* They are usually sustainable locations within the existing urban areas
* They are accessible - served by existing public transport
* They are near existing services - schools, shops, community facilities
* Small and medium sites in the urban areas reduce or remove the need to change Green Belt boundaries and remove land from the Green Belt.
* The large sites proposed in the Local Plan can only be 'greenfield' as there are no more old industrial areas to redevelop; hence cause loss of Green Belt.

The Plan's bias in favour of large, greenfield, housing sites remains. It needs to be changed and the focus changed to (a) sites below 1 ha and (b) sites between 1 ha and 5 ha (small-to-medium).

See Letter

See attached letter

Please refer to attached documents.
Lichfields is instructed by Heyford Developments Ltd ('Heyford Developments') to respond formally to the Solihull Draft Local Plan Review supplementary consultation (January 2019 - March 2019).

See Letters

see attached document

see letter
Barton Willmore LLP is instructed by Duchy Homes Ltd (the 'Client') to submit representations to Solihull Metropolitan Borough Council's Draft Local Plan Regulation 18 Supplementary consultation (the 'draft Plan') in relation to their land interests at land east of Grange Road, Dorridge (hereafter referred to as the 'Site 1') and land south of Arden Road, Dorridge (hereafter referred to as the 'Site 2'). Part of Site 1 is referenced in the Council's Site Assessments document as 344 'Land off Grange Road'. Our Client is promoting Site 1 for residential development, which will require the relocation of the village hall to Site 2.