Policy P5 – Provision of Land for Housing

Deduct at least 2,000 greenbelt homes.

I believe that the plan for housing on greenbelt exceeds government targets because of the failure to take into account the additional housing planned for the HS2 Interchange White Elephant.

See attachment

The Council should identify more small sites to cater for small builders who otherside cannot secure sufficient land to carry them forward.

Paragraph 68 of the NPPF sets out that small and medium sized sites can make an important contribution to meeting thehousing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant planpolicies, that there are strong reasons why this 10% target cannot be achieved.

Council should include more small and meduim sites for local house builders many of which were submitted for consideration at Call for Sites stage and have been summarily discounted in favour of large sites for volume housbuilders. Each has their place and more small and medium sites should be allocated.

Paragraph 68 of the NPPF sets out that 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. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant planpolicies, that there are strong reasons why this 10% target cannot be achieved

1. Add further analysis to seek to quantify extraneous in migration generated by UK Central hub.
2. Add land at rear of 114 - 118 Widney Manor Road to the table of residential allocations.

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 pre submission plan takes into account deficits in supply in the Birmingham HMA but does not take into account growth over and above this from attraction to the UK Central Hub from outside the region. 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. Land at 114 – 118 Widney Manor Road is well placed to contribute to the likely underestimate of need given that the SA found the site to be classified as ‘reasonable alternative. The site should be added to the table of residential allocations.

Change the housing requirement to the annual figure of household increase projected by ONS (632 pa).

Delete the large housing sites on what is now Green Belt allocated in the Plan listed in the Table at para 226.

Revise the housing supply at Solihull Town Centre to the higher figure now likely to be achievable.

Replace the policy of a small number of large new housing sites with a larger number of small sites, only a few of which would be in current Green Belt land.

Policy P5 and the accompanying tables propose a high level of housing provision over 15/16 years (2020-2036) - 15,000, or nearly 1,000 per year. This is much higher than any past rate for housing completions except in occasional years. The total is well in excess of the ONS projection for increase in number of households in the Borough. The annual increase is given (Table at para 220) as 632 households/ year 2020-230. The ONS projection beyond 2030 is not shown; if the rate of increase is the same the growth in households 2020-2036 would be about 9,500. That may be too high.

Without allocating any new sites which are on Green Belt and without including any housing at the UK Central Hub area to 2036, the Solihull Housing Land Supply table (Table at para 222) shows a total supply of 7,000 new dwellings. This is from summating all figures in lines 1 to 8 of that table. The entry for line 5, Town Centre Sites, of 961, seems likely to be underestimated because capacity of Solihull Town Centre and scope for additional dwellings there seems likely to be higher than the Plan quotes (861 dw, see footnote 29).

Provision of housing to meet the increase in households projected by ONS for Solihull up to 2036 can be achieved without any removal of Green Belt or allocation of housing on land now Green Belt, except at the UK Central Hub north of the A45. That land is proposed for removal from the Green Belt for the HS2 station and development around it. If 2,740 dwellings are delivered there by 2036, the total supplied housing by 2036 would be 9,750.

The housing strategy is wrongly based on allocation of a small number of large housing sites, on land now Green Belt. Replacement of these by a strategy of small sites, which would require much less removal of land from the Green Belt, would enable the increase in households in the Borough to 2036 to be catered for without most of the removal of land from the Green Belt that the Plan proposes.

A good example is that residential allocation BC3, Windmill Lane Balsall Common of 120 houses - which would be very damaging to the setting of the Grade II* Berkswell Windmill - can be replaced by small sites in the Balsall Common area, notably Site 82 north of Derngate Drive, west side of Kenilworth Road (capacity 60-70 dw). Site 82 is Green Belt but partly surrounded by other houses and heavily screened on the west side. Similar examples where small changes to the Green Belt boundary would allow small housing development without harm to the general Green Belt have been identified by other objectors.

The housing requirement should be increased to ensure the plan meets the housing needs arising from the HS2/UKC proposals and as well as providing a greater contribution to meet HMA housing shortfalls. We estimate that the Local Plan needs to make provision for the delivery of at least 17,500 dwellings over the plan period, and probably nearer 20,000 dwellings to ensure the sustainable growth of the area and contribution to the wider HMA needs.

See attachments

Increase in Housing figures of between 1,036 and 1,248 dpa
Reduction in windfall allocations from 200 dpa to 150 dpa as per the tried and tested number set out in the adopted Plan.
Reduction in BFLR allocations by 29 – from 77 to 48

See attachments.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The housing requirement should be amended to take account of the likely realistic date of adoption (2022).

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The housing requirement should be increased to take account of the employment uplift, particularly in the absence of any evidence that neighbouring areas are intending to accommodate higher housing numbers as a consequence.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The housing requirement should be increased to take account of affordability within the Borough.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The housing requirement should be amended to take account of unmet housing needs.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The housing supply should be justified with evidence, and assumptions in relation to windfalls should be reviewed and amended.

The housing requirement should be expressed as a minimum figure.

The housing supply should contain a buffer of 10% over the housing requirement.

Policy P5 and the table of allocated sites should be amended to include land west of Rumbush Lane, Tidbury Green.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The housing requirement should be amended to take account of the likely realistic date of adoption (2022).

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The housing requirement should be increased to take account of the employment uplift, particularly in the absence of any evidence that neighbouring areas are intending to accommodate higher housing numbers as a consequence.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The housing requirement should be increased to take account of affordability within the Borough.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The housing requirement should be amended to take account of unmet housing needs

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The housing supply should be justified with evidence, and assumptions in relation to windfalls should be reviewed and amended.

The housing requirement should be expressed as a minimum figure.

The housing supply should contain a buffer of 10% over the housing requirement.

Policy P5 and the table of allocated sites should be amended to include Site 62 for mixed use development.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

Policy P5 should be clear as to what the annual requirement is over the plan period. Where a stepped trajectory is adopted, the plan should make it clear that this is a minimum annual requirement and encourage development to be delivered earlier than the trajectory.

Sirs

Please find attached representations on behalf of Persimmon Homes, comprising Part A and subsequent separate Part B forms relating to each objection/response

We look forward to discussing the attached and suggested amends further with Officers

Regards

Policy P5 should clearly state that the housing requirement figure is a ‘minimum’.

Dear Sir / Madam,
On behalf of Mark Horgan, please find attached a response to the Draft Submission version of the Local Plan Review in regards to his land interests at Winterton Farm, Blythe Valley (SHELAA reference 173).
We have submitted the following:
• Covering letter;
• Five Consultation Response Forms;
o Policy P4C
o Policy P4D
o Policy P4E
o Policy P5
o Policy P17
• Promotion Document (January 2016).
Please contact me if you have any queries with the submission.
Kind regards
Jess

Additional sites should be allocated in the plan in light of the revised Standard Methodology calculation, the identified HMA shortfall up to 2036 and the unrealistic expectations for the UK Central Site.

Dear Sir / Madam,
On behalf of Mark Horgan, please find attached a response to the Draft Submission version of the Local Plan Review in regards to his land interests at Winterton Farm, Blythe Valley (SHELAA reference 173).
We have submitted the following:
• Covering letter;
• Five Consultation Response Forms;
o Policy P4C
o Policy P4D
o Policy P4E
o Policy P5
o Policy P17
• Promotion Document (January 2016).
Please contact me if you have any queries with the submission.
Kind regards
Jess

Increase in Housing figures of between 1,036 and 1,248 dpa.
Reduction in windfall allocations from 200 dpa to 150 dpa as per the tried and tested number set out in the adopted Plan.
Reduction in BFLR allocations by 29 – from 77 to 48.

See attachments.

In the event that the Forum’s representations on the Knowle site allocations and concept masterplans lead to a revised housing capacity, a consequential modification will be required to the Knowle, Dorridge and Bentley Heath Neighbourhood Area housing number in Para 234.

See attachments.

None required to the policy.

See attachments.

Policy P5 - additional paragraph (Para 7)
Concept Masterplans
7. Development on allocated housing sites shall be carried out in accordance with the related concept masterplan and the principles set out in the housing allocation policies. The content shall be as prescribed in the Local Plan.
Para 242 – additional text to specifically state that concept masterplans for each site form part of the Local Plan.

See attachments.

The housing requirement should be increased to a minimum of 18,500 dwellings to reflect the outcomes of additional, realistic economic uplift scenarios to meet the envisaged jobs growth at UK Central Hub.

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,

The extent of agreement from the other GBHMA authorities should be detailed in full.

The housing requirement should be increased to provide more flexibility to help meet GBHMA housing shortfall needs up to 2031 and beyond (up to 2036).

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,

The housing requirement should be increased to maximise the contribution towards meeting the affordable need.

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,