Local Housing Need

Comment

Representation ID: 9303

Received: 15/03/2019

Respondent: Spitfire Bespoke Homes

Agent: Ridge and Partners LLP

Within the document that has been issued for consultation, there appears to be no justification for moving away from the standard methodology. SMBC needs to be confident that there is sufficient supply of sites to meet both the Borough's housing need and the wider HMA shortfall contribution.

Support

Representation ID: 9326

Received: 13/03/2019

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

Use of the 2014 based household projections, together with a contribution of 2,000 dwellings towards the Housing Market Assessment (HMA) shortfall, would lead to a required annual delivery rate of 885 dwellings. This is double the rate achieved over the last 10 years and is unrealistic. If the HMA shortfall contribution were to increase, this rate would be even higher and above the Government cap. It would be undeliverable. Bearing in mind also the unsuitability of the sites proposed in KDBH, the housing requirement and the HMA contribution will need to be reduced.
There is justification for an alternative approach.

Support

Representation ID: 9334

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

St Philips agrees with the approach of applying the Standard Method for calculating housing need for the Plan period, but notes that the calculation provides a minimum figure and a starting point for the preparation of the Local Plan.
Although not consulted on, St Philips does not consider the 2,000 contribution is sound.
In terms of housing supply:
Council should provide full schedule of sites in the housing supply and proposed trajectory, inc. permissions.
Do not consider there is sufficient evidence for inclusion of BLR sites in the supply assumptions.
Need further evidence to justify continued inclusion of SLP sites.
More justification required for UKCHub and NEC figures.
Question deliverability of windfall sites at 150dpa over plan period.
Should provide more information on 1ha sites in accordance with NPPF.

Object

Representation ID: 9340

Received: 21/03/2019

Respondent: Halford Holdings

Agent: Tyler Parkes Partnership Ltd

Support proposed housing distribution, review of green belt boundaries and reassessment of washed over green belt settlements. Object to lack of justification/agreement for scale of contribution to wider HMA shortfall. Insufficient deliverable sites to meet needs and more small/medium sites required.
Contends that despite use of Standard Methodology based on 2014
household projections, there is still no signed Statement of Common Ground,
(contrary to NPPF).

Comment

Representation ID: 9362

Received: 15/03/2019

Respondent: Mr J Kimberley

Agent: Tyler Parkes Partnership Ltd

Support proposed distribution, review of green belt boundaries, use of standard methodology, but concerned at lack of justification/agreement for contribution to wider HMA shortfall. Insufficient deliverable sites allocated to meet needs. Some green/allocated sites have significant questions over deliverability and compliance with national policies/sustainability considerations, meaning some 1,060 dwellings may not be delivered.

Object

Representation ID: 9363

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Consideration of HMA shortfall at Regulation 19 stage inappropriate/unlawful as may require revised strategy or propose additional green belt releases, which ought to require further Regulation 18 consultation. Otherwise this would be a completely new strategy resulting in a plan that has not been previously consulted upon. This approach would lead to a challenge to the lawfulness of the process and possible intervention by the Secretary of State. Any preferred options that may derive from a revised HMA contribution should be subject to consultation prior to stage 3 submission as described in the SCI and plan making regulations. Regulations make a distinction between Regulation 18 and Regulation 19 in order to aid sound plan making and to ensure that there is an appropriate opportunity for all those concerned to contribute to it and influence it.
Insufficient and unjustified contribution to wider HMA shortfall which reasonably should be more significant than 3,790 dwellings proposed by North Warwickshire BC, given Solihull's proximity to Birmingham and public transport links. Suggest 6,500 (17% of shortfall). Site 313 Fulford Hall Farm, Tidbury Green could make significant contribution to part of this shortfall, due to sustainable location as demonstrated by Mobility and Transport Strategy.

Comment

Representation ID: 9372

Received: 15/03/2019

Respondent: Mr. James McBride

Agent: Tyler Parkes Partnership Ltd

Support proposed distribution, review of green belt boundaries, use of standard methodology, but concerned at lack of justification/agreement for contribution to wider HMA shortfall. Insufficient deliverable sites allocated to meet needs. Some green/allocated sites have significant questions over deliverability and compliance with national policies/sustainability considerations, meaning some 1,060 dwellings may not be delivered.

Comment

Representation ID: 9395

Received: 15/03/2019

Respondent: Mr M Trentham

No.

Support

Representation ID: 9450

Received: 15/03/2019

Respondent: Hampton Road Developments Ltd

Agent: Savills

We do not believe that there are exceptional circumstances that would justify the Council using an alternative
approach to the new standard methodology as set out.
We note the Council's intention to respond to the potential additional support towards the Greater Birmingham
Housing Market Area ('HMA') will be dealt with at the Regulation 19 Pre-Submission stage.

Comment

Representation ID: 9474

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Lichfields

St Philips do not believe there are exceptional circumstances that would justify the Council using an alternative approach, but nonetheless consider the Council have not appropriately addressed the requirement to contribute to the unmet need of the wider HMA. Use of standard methodology and 2014-based projections welcomed. Evidence of lack of agreement across HMA authorities, with NWBC raising concerns. Lack of clarity over mechanism to agree distribution and delivery of shortfall. Solihull well placed to deliver greater proportion, procrastination will result in unmet housing needs, stifle economic growth, and failure to include will mean Plan unsound.

Comment

Representation ID: 9486

Received: 15/03/2019

Respondent: Catesby Estates Limited

Agent: WYG

Use of the 2014 Household Projections and standard methodology is considered appropriate. However, this figure should be a minimum.
It is also imperative that Solihull not only meets its own targets but also provides for an agreed amount of housing to fulfil a proportion of the unmet housing need arising from the wider HMA.
It is an accepted position that Solihull MBC has failed to meet the (now quashed) housing target set out in the current Solihull Local Plan. To address this, supply should be frontloaded. Failure to respond to SGS means Plan not underpinned by relevant and up-to-date evidence.

Object

Representation ID: 9496

Received: 14/03/2019

Respondent: IM Properties

Agent: Marrons Planning

Concern that sites have been disregarded when the overall housing requirement remains unknown. Some amber/red sites should be proposed for the Plan period and/or longer term development. Need for sufficient supply and mix to meet the requirement and provide a realistic trajectory, to provide greater flexibility than 5% given the reliance on larger allocations, and to include more smaller allocations. Lack of compelling evidence for level of windfalls proposed.

Comment

Representation ID: 9507

Received: 15/03/2019

Respondent: The Knowle Society

Supply of new homes is governed by demand and as the past average annual rate achieved over the last 10 years is half the suggested requirement, it is argued the proposed requirement rate is completely unrealistic.
Any later changes in the 2020 projections will have an impact on future building rates but if it is less, then this raises the question of whether there is a need to demonstrate such land availability now. The overall land availability should be provided over a much longer term than this local plan suggests.

Comment

Representation ID: 9518

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

No exceptional circumstances to deviate from the standard methodology as that is a requirement in the NPPF.
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 ('LHN') figure.

The figure of 109% deems that no action is required. However, the MHCLG is committed to boosting the supply of housing and although the housing delivery test score requires no action we consider that assessed need housing numbers should be seen as minima.

Comment

Representation ID: 9532

Received: 15/03/2019

Respondent: Richard Lloyd

Yes.
The population is of above average age, therefore the standard method artificially
inflates the rate of household formation. In addition, the high proportion of retired
people with substantial resources creates distortion in the affordability ratio.
A more accurate assessment of local need could be based on actual demographics
based on records of births, marriages, and deaths

Comment

Representation ID: 9551

Received: 15/03/2019

Respondent: Richard Cobb Planning

The methodology imposed at national level and using the 2014 based figures probably produces a higher figure than the latest projections (2016) indicate are necessary. The Council are yet to reach agreement with adjoining Councils in terms its contribution to the HMA shortfall, and unless the Council make additional provision in their Local Plan it is likely that the Council will not be able to fulfil its duty to cooperate. More housing land may need to be allocated in the green belt. The proposed rate of delivery is far above the highest that has been achieved in Borough and unlikely this can be sustained. The 2016 based projection from GL Hearn is more realistic. It is likely that some of the sites will not be capable of delivery because of ownership and infrastructure issues. The Council hasn't allocated smaller sites and is relying on a handful of larger sites which are unlikely to deliver the housing numbers. Failed to consider wider components of growth, omitting areas of employment such as in Balsall Common, Knowle and Dickens Heath. No provision is made to encourage employment sustainability.

Comment

Representation ID: 9568

Received: 15/03/2019

Respondent: IM Land

Agent: Stansgate Planning LLP

There are exceptional circumstances that would justify an alternative approach. These are the economic growth aspirations of the Council and resultant expected job growth.
The Standard Methodology minimum of 777dpa to meet local need needs to be increased to between 825 and 1,127dpa to account for economic growth aspirations and expected job growth set out in the evidence base, and based on GBSLEP aspirations.
Solihull has duty to deliver a share of the unmet need fro the wider HMA, ranging from 28,000 to 2031 and 80,000 to 2036.

Comment

Representation ID: 9573

Received: 15/03/2019

Respondent: Bloor Homes

Agent: Savills

No exceptional circumstances that would justify the Council using an alternative approach.
Support the Council's use of the 2014 based household projections in their LHN calculations. However, the figures result in a contribution of only 24 dwellings per annum to the Greater Birmingham Housing Market Area. This is not sufficient to meet the shortfall.

Comment

Representation ID: 9582

Received: 15/03/2019

Respondent: Mr J Allen

Agent: Cerda Planning Ltd

No exceptional circumstances to deviate from the standard methodology, but this is only the minimum starting point. Ambitions to support economic growth and to deliver affordable housing are additional to the local housing need figure. Important to recognise that the standard methodology is intended to deal with housing requirements arising only within Solihull. The wider Housing Market Area is a separate issue to be planned for.
Regrettable that this has not been addressed, given that a 2000 contribution to HMA shortfall is not evidence based and the figure has significant objections.
Solihull should contribute 5000-6000 dwellings to the shortfall.

Comment

Representation ID: 9598

Received: 15/03/2019

Respondent: Walsall Metropolitan Borough Council

The Black Country are disappointed that your supplementary consultation statement does not appear to have considered the full implications of the GL Hearn Study and taken the opportunity to test the findings with regards to the growth scenarios within the study. Would like to seek clarity as to whether the new 'call for sites' sites, which has been published as part of the consultation, will be an additional allocation to the 2,000 dwellings. Solihull has a strong functional relationship with the Great Birmingham/Black Country HMA. Current work / evidence shows the Black Country cannot accommodate all of its needs within its urban area leading to a shortfall in the region of 22,000 dwellings and 300ha of employment land. We would expect Solihull to undertake work to establish whether you can increase the contribution. Seek assurances that the full implications of the call for sites and the GL Hearn Study have been fully tested and justified. If this exercise results in increases in the housing numbers which can be accommodated within Solihull and/or a change in the overall Strategy, than there may be a need to include a further consultation stage prior to Publication.

Comment

Representation ID: 9600

Received: 15/03/2019

Respondent: Greenlight Developments

PPG is clear that standard methodology does not consider impact of future government policies or changing economic circumstances, and that higher figures may be appropriate on the basis of employment/infrastructure. No evidence produced to demonstrate that housing figure is sufficient taking account of implications of employment growth at UKC Hub Area.

DLP defers further consideration of the HMA shortfall figure (2000) to Reg19 stage, which is not consistent with NPPF, as such matters should be "dealt with rather than deferred". Given strong economic/demographic links between Birmingham and Solihull, should demonstrate consideration of higher figure.

SHMA concludes significant need for specialist housing and care home spaces, but neither DLP or Supplementary Consultation address need.

Comment

Representation ID: 9615

Received: 15/03/2019

Respondent: Albanwise Ltd

Agent: Barton Willmore

- Plan period end date should be extended to 2036 to align with GL Hearn Strategic Growth Study
- Plan may be delayed, and will ensure a minimum 15 year time horizon
- Cites Para. 60-61 of NPPF on housing need assumptions
- Urge SMBC suitably considers contribution to unmet housing need in wider GBBBC HMA

Comment

Representation ID: 9617

Received: 15/03/2019

Respondent: Balsall Parish Council

Balsall parish has exceptional circumstances that justify an alternative approach.

The draft Balsall Parish Neighbourhood Development Plan contains Community Aspiration CA1: 'Development on allocated Solihull Local Plan housing sites that will utilise the same construction routes as HS2 contractors should be avoided at the same time as HS2 construction because of the potential disruption to existing residents caused by avoidable increased congestion.'

This consideration affects Frog Lane and Windmill Lane sites.

Comment

Representation ID: 9633

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Barton Willmore Housing Need Technical Note to SDLPR.
Summary of findings:
- The revised NPPF introduces the Standard Method (SM) for calculating housing need, the relevant Planning Practice Guidance (PPG) has been amended (February 2019) to state that the 2014-based MHCLG projections must be used for the calculation, and not the 2016-based ONS projections. The current SM calculated housing need figure for Solihull stands at 777 dwellings per annum (dpa) as of March 2019;
* Notwithstanding this, revised Planning Practice Guidance (PPG) states the SM figure represents the minimum housing need, and actual need may be higher;
* The Supplementary Consultation document identifies the clear economic growth aspirations for the Borough, including the significant development planned for High Speed 2 and the Interchange in the Borough. Housing delivery must be of a quantum to support these aspirations;
* Alongside this, the Council need to consider the aspirations of the GBSLEP in which they are located;
* The Council's evidence base provides a relatively recent (January 2017) assessment of baseline job growth prospects for Solihull, post-Brexit referendum, alongside a scenario which takes into account the potential job growth created by the HS2 Hub Interchange;
* These scenarios show annual job growth of between 800 and 1,080 jobs per annum. It is therefore imperative that the housing requirement for Solihull supports at least 800 jobs per annum, and more realistically the upper end of this range.;
* Our own sensitivity testing has established how the baseline population growth used to underpin the Standard Method would only support circa 450 jobs per annum;
* Furthermore the final Standard Method housing figure (777 dpa) would only support between 594 and 729 jobs per annum;
To support the range of job growth identified in PBA's 2017 report (baseline job growth of 800 per annum, and job growth to support the UK Hub of 1,080 jobs per annum), housing need for the Borough alone would need to be between 825 and 1,127 dpa;
* There is significant unmet need from the GBBCHMA. Solihull Borough Council acknowledge their role in helping to meet this unmet need;
* The most detailed and recent evidence in respect of unmet need comes from the Greater Birmingham HMA Strategic Growth Study (SGS). In addition the Black Country Urban Capacity Report (BCUCR) provides more recent analysis of capacity and need in that area;
* These reports suggest unmet need across the two areas ranging from a minimum of 28,000 dwellings up to 2031 (based on demographic need) and up to 80,000 dwellings (based economic need and unmet need from the Black Country identified by the BCUCR) up to 2036.

Comment

Representation ID: 9697

Received: 15/03/2019

Respondent: Landowners Wootton Green Lane

Agent: Tyler Parkes Partnership Ltd

Support distribution of housing and review of green belt boundaries. Lack of evidence that contribution to wider HMA shortfall is adequate, given increased scale of need, or of necessary Statement of Common Ground. No evidence that SGS growth options investigated, so potential capacity has not been objectively tested. Should allocate more land than minimum required for local and wider housing need, and identify a range of small/medium sized sites to ensure meet housing delivery test.

Comment

Representation ID: 9712

Received: 15/03/2019

Respondent: NaCSBA

The document does not make a single reference to custom or self build or those wishing to build their own homes. SMBC should publish the level of demand for self build as demonstrated through the self build register. This will inform the Local Plan review to ensure sufficient plots are available. Ascertain a target for self build provision for the Borough. A policy promoting self build must be included in the emerging plan to comply with the NPPF, the Housing and Planning Act, and the Right to build. In line with paragraph 119 of the NPPF allocate sites in the plan to meet the needs of those wishing to self build. Washed over area of green belt should not be removed however a policy should be included stating Custom, self build, starter and affordable homes will be considered acceptable as part of limited infill within existing ribbon developments within the Green Belt where it is demonstrated that they do not have an adverse impact upon the openness and integrity of the wider Green Belt.

Comment

Representation ID: 9715

Received: 15/03/2019

Respondent: Avison Young

Agree with approach of applying the Standard Method for calculating housing need for the Plan period.
Should note the Government seeks to review in next 18 months, which may impact housing figure.
In order to ensure Draft Local Plan is found sound, LPA must agree on robust mechanism to secure meeting unmet need in HMA.
Evidence for assumptions on housing supply, urban capacity including densities and windfall provision will need to kept up-to-date.

Object

Representation ID: 9722

Received: 13/03/2019

Respondent: Mrs A Kidson

Other parts of the borough need to make a contribution towards the housing targets set by government.

Comment

Representation ID: 9723

Received: 15/03/2019

Respondent: Mrs Jean Walters

Acknowledged that SM imposed at national level. Council should continue to press on government as it has potentially significant consequences for loss of highly performing Green Belt.
Annual dwelling rate of 885dpa is above the highest rate ever achieved by the Council except 2005, double average delivery rate of last 10 years, and above the 40% cap.
2016 based household projections of 550dpa, and in GL Hearn study, is more realistic and deliverable.
Council can use exceptional circumstances to justify using the 2016 household projections under Para. 60 of the NPPF.

Support

Representation ID: 9735

Received: 15/03/2019

Respondent: Heyford Developments Ltd

Agent: Harris Lamb

Agree approach to calculating housing need and welcome calculation on both 2014/2016 based household projections. Any additional housing requirement for wider HMA shortfall should be provided in addition to local need.