Policy P5 – Provision of Land for Housing

Object

Representation ID: 14659

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Affordability uplift: The housing requirement should also be increased to take account of affordability within the Borough, consistent with national guidance. The identified affordable housing need is 578 homes per annum (HEDNA para 35). However, the Council has reached the conclusion that the maximum amount that can be viably sought is 40% on any given scheme. This top line is substantially less than the evidence suggests, and in reality, 322 per annum is unlikely given the sources of supply, despite the Housing Topic paper (Paragraph 73) noting other methods for maximising affordable housing provision. The Housing Topic paper notes at footnote 10 that this reduced to 224dpa if households already in accommodation are excluded, however the HEDNA is clear that the figure is theoretical and should not be seen to minimise the acute housing need in the borough.

Allocated Sites: The absence of any evidence in relation to housing trajectories for the proposed allocated sites means that the figure of 5,270 homes to be delivered by 2036 is not justified.

Windfalls: The estimated level of windfalls at 2,800 homes completed over 14 years is not justified. Firstly, whilst it is stated that windfalls are not included for the first 3 years (to avoid double counting with extant planning permissions) only 2 years have been discounted. Secondly, the annual average level of windfall is substantial for an authority significantly constrained by Green Belt. Reliance is placed on historic trends, but there is no certainty that past sources of supply are likely to continue. The evidence should be so compelling that it is a source of supply that can be relied upon for delivering the housing requirement.
Five Year Supply on adoption: The Plan will not provide for a five year housing land supply upon adoption. The Plan assumes that 1,170 homes will be delivered on allocated sites within the first five years but there is no evidence to support this

Object

Representation ID: 14660

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Unmet needs: The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. Paragraph 227 of the Plan advises that Birmingham has unmet needs (37,900 homes), and paragraph 228 advises that the Plan is proposing a contribution of 2,105 homes towards unmet needs. However, there is no evidence that this level of contribution is agreed with Birmingham or other neighbouring authorities, or that the unmet needs that remain are to be addressed elsewhere. There is no evidence as to why the contribution is only 2,105 homes.
In addition to Birmingham’s needs, it is also noted the Black County Authorities estimate unmet housing needs of 29,260 homes and up to 570ha of employment land to 2038, and have written to the Council notifying them. The Council has suggested their unmet needs can be dealt with as part of the next review of the Local Plan. However, that is not evidence of effective joint working, but rather deferring its consideration which is evidence of an unsound Plan in being contrary to paragraph 35 c) of the Framework.

Object

Representation ID: 14669

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

PARAGRAPH 228 -
BC expect a shortfall in the BC of 27,000 homes to 2038, and a shortfall of employment land of between 287-567ha.
BC previously commented that SMBC’s previously stated contribution of 2,000 was disappointing Contribution to the HMA should be to 2036, not just to 2031.
The 2,105 contribution is disappointing, given the strong physical and functional relationship of Solihull to the conurbation, and in the context of the Strategic Growth Study (SGS) that identified options (for further exploration) south of the airport and for a new settlement at Balsall Common
Further clarity sought on why only 2,105. Plan should consider HMA shortfalls over full period of the plan.
2,740 dwellings in the UKC appears a proportionate response to the SGS, but 1,615 at Balsall Common is short of being a ‘new settlement’. Not explained how limits of the environment and attractiveness of the Borough prevent allocation of further housing, and not all reasonable alternatives have been explored.

Support

Representation ID: 14670

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

PARAGRAPH 241
The table of indicative densities in paragraph 240 identifies a series of locally-derived density assumptions ranging from 90 – 150dph for apartments in town centres and at UK Central to 30 – 35dph for houses in limited settlement expansions.
ABCA would wish to be satisfied that these represent the most appropriate and robust densities for all locations through seeing evidence for the adoption of the identified levels. The HMA Growth Study recommends testing and adopting densities of at least 35dph outside the Birmingham and Black Country urban areas, where higher densities of 40dph are promoted.

Support

Representation ID: 14674

Received: 11/12/2020

Respondent: Coventry City Council

PARAGRAPH 228

Welcome the allocation of additional sites within Solihull Borough, which go towards meeting development needs within the Birmingham HMA. We recognise the need for on-going discussions across the wider HMA regarding growth beyond 2031, particularly in relation to accommodating unmet need from a neighbouring HMA.

Object

Representation ID: 14680

Received: 01/12/2020

Respondent: Lichfield District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

PARAGRAPH 228
Lichfield District Council is concerned that given the approach taken within the Draft Submission Plan, Solihull Council is not committed to fully addressing the GBHMA shortfall and this is particularly significant given the geographic context and transport links between Solihull Borough and Birmingham.
Whilst the approach towards calculating the Borough’s own local housing requirement and the site selection process is noted and appears to be soundly based, Lichfield District Council is conscious that the contribution of 2,105 dwellings towards the GBHMA shortfall is lower than the contribution proposed by neighbouring authorities such as Lichfield District and North Warwickshire. Therefore, further sites may need to be identified and released from the Green Belt.

Object

Representation ID: 14684

Received: 10/12/2020

Respondent: South Staffordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraph 228

Reiterate concerns previously expressed about the scale of the contribution being proposed by SMBC towards meeting the housing shortfall identified in the GBHMA. It is considered that continuing with this approach risks the plan failing in meeting statutory requirements. Specifically, South Staffordshire considers that the post 2031 shortfall should be considered as part of this present Local Plan review rather than being deferred.
Concern that SMBC’s approach to utilising Green Belt may not be broadly consistent with that taken by other authorities in the HMA. Specifically of classifying ‘moderately performing’ GB land as unlikely to be allocated. This is in contrast to BC approach that otherwise sustainable sites should only be automatically excluded from site selection on Green Belt/Landscape grounds if they were in both ‘Very High harm’ Green Belt land and ‘Moderate-High sensitivity’ landscape areas.
Should the examination of Solihull’s approach suggest that other deliverable land is available within the Borough, we would strongly encourage this being brought forward in order to avoid the deferral of the GBHMAs post 2031 shortfall.

Object

Representation ID: 14692

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement is not sound as it is not positively prepared, justified, effective or consistent with national policy for the following reasons.
LHN: The minimum Local Housing Need (LHN) has been calculated using the standard method which is well established and is not disputed. However, the Council will need to be mindful of any changes arising from the Government’s stated intention to change the method for calculating LHN prior to submission of the Plan.
Plan Period: It is highly unlikely that the Local Plan will be adopted in 2021, thereby providing a plan period of 15 years post adoption as recommended by the Framework. On the basis that it is already December 2020 and the Plan has not been submitted, it is more likely to be adopted in 2022, and therefore the housing requirement and the Plan should be extended to 2037.
Employment uplift: LHN is afforded an employment uplift of nine dwellings per annum to take account of the substantial job growth at UK Central of around 13,000 net additional jobs. This is a figure which could increase as plans crystallise, and it is noted that the Council’s Viability Study (2020) predicts up to 77,500 jobs by 2040. The Plan also justifies the small uplift from LHN on the assumption that only 25% of the jobs will be filled by people residing in Solihull, with the remainder in commuting from neighbouring areas. Taking this approach will ‘bake-in’ inward commuting reflecting an historic pattern of movement rather than shaping growth to be more sustainable by locating homes close to where work is
Affordability uplift: The housing requirement should also be increased to take account of affordability within the Borough, consistent with national guidance. The identified affordable housing need is 578 homes per annum (HEDNA para 35). However, the Council has reached the conclusion that the maximum amount that can be viably sought is 40% on any given scheme. This top line is substantially less than the evidence suggests, and in reality, 322 per annum is unlikely given the sources of supply, despite the Housing Topic paper (Paragraph 73) noting other methods for maximising affordable housing provision. The Housing Topic paper notes at footnote 10 that this reduced to 224dpa if households already in accommodation are excluded, however the HEDNA is clear that the figure is theoretical and should not be seen to minimise the acute housing need in the borough.

Object

Representation ID: 14695

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Allocated Sites: The absence of any evidence in relation to housing trajectories for the proposed allocated sites means that the figure of 5,270 homes to be delivered by 2036 is not justified.
Windfalls: The estimated level of windfalls at 2,800 homes completed over 14 years is not justified. Firstly, whilst it is stated that windfalls are not included for the first 3 years (to avoid double counting with extant planning permissions) only 2 years have been discounted. Secondly, the annual average level of windfall is substantial for an authority significantly constrained by Green Belt. Reliance is placed on historic trends, but there is no certainty that past sources of supply are likely to continue. The evidence should be so compelling that it is a source of supply that can be relied upon for delivering the housing requirement.
Five Year Supply on adoption: The Plan will not provide for a five year housing land supply upon adoption. The Plan assumes that 1,170 homes will be delivered on allocated sites within the first five years but there is no evidence to support this

Object

Representation ID: 14698

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario.
Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered. Additional unmet need will be created post 2031.

Object

Representation ID: 14720

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Council will not be able to meet its assessed Housing Need and the Plan is unsound.
There is evidence that the Housing Need figure for Solihull of 13,056 (Para 221) is in fact too low and should be adjusted upwards.
The Windfall Allowance (as of 1st April 2020) is disputed and not based on sound evidence.
No small sites are allocated.
Some sites in the SHELAA are not deliverable e.g. St George and St Teresa school as relocation is no longer an option.
Some sites on the Brownfield Land Register are not reasonable allocations and would fail the site assessment or are not deliverable.
Approach to housing density in the plan is not clear and inconsistent with the masterplans and the KDBH neighbourhood plan.

Object

Representation ID: 14725

Received: 11/12/2020

Respondent: Mr James Mc Bride

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P5 ‘Provision of Land for Housing:
Paragraph 222 Solihull Housing Land Supply 2020 – 2036, Paragraph 225 Maintaining Housing Land Supply and Paragraph 226 Allocated Sites

Insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).

There is a lack of credible evidence to demonstrate that the 861 dwellings identified for Solihull Town Centre under Policy P5 can be delivered. It is considered
that insufficient evidence has been provided to demonstrate that there is a mechanism to facilitate the quantum and timing of development proposed via Policies P2 and P5:, contrary to the deliverability and developability requirements for site allocations set out in NPPF Appendix 2: Glossary. It also fails to satisfy paragraphs 67 and 175 of the NPPF.
Our Client therefore contends that Policy P5 is unsound the number of dwelling proposed to be delivered in the Town Centre should be significantly reduced to reflect more realistically its capacity based on the constraints to development.

Insufficient evidence has been provided to demonstrate the ability to deliver the 2,740 dwellings from the UK Central Hub within the Plan period (2020-2036), as set out within Policy P5 (Provision of Land for Housing), contrary to the deliverability and developability requirements for ‘site allocations’ set out in the NPPF Appendix 2: Glossary. Accordingly, the ‘allocation’ of the
UK Central Hub sites fails to satisfy the NPPF paragraphs 67 and 175.

The definition of the ‘UK Central Hub Area’ as referenced in Policy P5 (Provision of Land for Housing) is imprecise and inconsistently applied within the SLP and supporting evidence

The housing contribution from within the ‘UK Central Hub Area’ is not clearly defined within the draft SLP documents (i.e. the SLP, Policies Map or Concept Masterplan Document) There is a reliance on documents provided in evidence (but not to be adopted) which are subject to change. This leads to uncertainty on achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period.

The quantum of dwellings and timeframe for delivery as quoted within the SLP and supporting evidence is inconsistent, leading to uncertainty in achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period.

Delivery of The UK Central Hub (including residential elements of Arden Cross and NEC) is extremely complex, requiring the co-ordination of several landowners and implementation of necessary infrastructure; in the absence of a clear Policy and/or Concept Masterplan identifying relevant details, and as noted elsewhere discrepancies in the quantum and timetabling, this raises uncertainty on achieving the housing delivery stated in SLP Policy P5 (Provision of Land for Housing) within the Plan period

Object

Representation ID: 14730

Received: 11/12/2020

Respondent: Les Edwards

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy P5 is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed 2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP).
There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60.
Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Plan/ Green Belt review, and ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).

Object

Representation ID: 14731

Received: 11/12/2020

Respondent: Les Edwards

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P5 paragraphs 222 and 225-226. Insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).

Object

Representation ID: 14734

Received: 11/12/2020

Respondent: Mr James Mc Bride

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy P5 ‘Provision of Land for Housing’ is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed
2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP). There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60

Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Local Plan with accompanying Green Belt review, and
ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).

Object

Representation ID: 14738

Received: 11/12/2020

Respondent: Nicolas & Timothy Underwood

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy P5 is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed 2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP).
There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60.
Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Plan/ Green Belt review, and ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).

Object

Representation ID: 14739

Received: 11/12/2020

Respondent: Nicolas & Timothy Underwood

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P5 paragraphs 222 and 225-226. Insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).

Object

Representation ID: 14745

Received: 11/12/2020

Respondent: Sonia Smith

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy P5 is unsound on the basis that insufficient evidence has been provided to demonstrate cross-boundary collaboration under the legal Duty to Cooperate in respect of the proposed 2,105 dwelling contribution towards the housing land supply shortfall (paragraphs 227 to 228 of the SLP).
There is no published statement of common ground to demonstrate effective and on-going joint working – contrary to National Planning Policy Framework (NPPF) paragraphs 11, 24, 26, 27 and 60.
Insufficient account has been taken of the need to plan effectively for delivery of the anticipated growth over the plan period and beyond to avoid the need for an early Plan/ Green Belt review, and ensure timely delivery of development – contrary to NPPF paragraphs 33 and 139 c).

Object

Representation ID: 14746

Received: 11/12/2020

Respondent: Sonia Smith

Number of people: 4

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P5 paragraphs 222 and 225-226. Insufficient ‘deliverable’ sites and ‘developable’ sites and broad locations have been identified to maintain a 5-year housing land supply over the plan period or to accommodate the scale of growth projected up to 2036, undermining the deliverability of P5 – contrary to the requirements of National Planning Policy Framework (NPPF) paragraph 67, 70, and 72 d).

Object

Representation ID: 14750

Received: 11/12/2020

Respondent: Mr James Mc Bride

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P5 is unsound on the basis that insufficient policy weight has been
given to encouraging the development of suitable sites within settlements for housing enabling villages to grow and thrive, especially where this will support local services, at densities in keeping with national and local strategic policies in Neighbourhood Areas – contrary to National Planning Policy Framework (NPPF) paragraphs 65, 122 and 123.

To comply with NPPF paragraph 65, it is important that the Neighbourhood Area housing requirement is included within Policy P5 as a strategic policy requirement, rather than as part of the supporting text explaining and
justifying the approach set out in the policy. Currently, Policy P5 makes no reference to the housing requirement being partly attributed to specific Neighbourhood Areas.

Given that there is unlikely to be an opportunity to test the housing requirement at the Neighbourhood Plan stage, it is important to ensure that the proposed Neighbourhood Area housing requirements and supporting text are not overly restrictive jeopardising the NPPF and local plan objective of meeting the minimum housing requirement over the plan period.

Object

Representation ID: 14751

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Concept Masterplans - Their status of as part of the Local Plan needs to be confirmed as it is presently unclear. All important development principles should be a matter of policy, not relegated to being consistent with concept masterplans. The concept masterplans are central to the delivery of housing development and each allocated housing sites has a concept masterplan. The development of some 5,270 dwellings is dependent upon their provisions. As such, it is important that their contribution in meeting the Borough’s housing requirement is recognised in the policy; also, for local communities to be confident that what is shown in the concept masterplans is broadly what will be delivered and will not be subject to material change.

Object

Representation ID: 14752

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Concept Masterplan document - It should be made clear that the concept masterplans are an integral part of the Local Plan and that adherence to key principles will be required; also, that only minor changes are envisaged in the future.
Essential matters and key principles of development should be clearly stated requirements and distinguished from any material that might be illustrative.
Densities differ between what is contained in the MP document and table at para 240 of the Local Plan.

Object

Representation ID: 14758

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Concept masterplans are discussed in the justification to Policy P5. However, they are not addressed within the policy itself. Given their importance, key provisions should be included within the strategic policy. The provisions also need to be strengthened so as to give confidence to the public and a clear steer to developers.
The status of the concept masterplans as part of the Local Plan needs to be confirmed.

Object

Representation ID: 14765

Received: 09/12/2020

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

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

18% of the proposed housing requirement for the Borough is at the UKC Hub. The majority of dwellings delivered will be apartments. No evidence that the amount of apartments proposed at UK Central Hub is needed, especially when there is an existing family demographic.
The UKC Hub will be unlikely to deliver 2,740 dwellings up to 2036 which could leave a shortfall of circa 700 – 1,000 dwellings . Evidence documents also show different housing figures for the sites.
The revised Standard Methodology could increase the Council’s minimum housing need by 25%. The range of housing growth options that may be derived from changes to the standard method and wider HMA growth requirements should be tested and planned for.
The proposed contribution towards the HMA shortfall is not a sufficient or justified contribution in light of the identified shortfall post-2031 which should be addressed in the Local Plan Review. Additional sites will be required.
Over-reliance on windfall. Council should identify additional sites and allocate and/or safeguarded for residential development.
Contrary to NPPF, point 6 makes no reference to local market conditions and viability when identifying appropriate density and mix for each site.

Object

Representation ID: 14773

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The housing requirement and the Plan should be extended to 2037 based on likely adoption date.
Housing to reflect employment growth at UKC Hub not considered. Assumption that jobs filled by in-commuters is not sustainable. Housing requirement should be increased to account for employment uplift.
Housing requirement should be increased to take account of affordability issues.
Unmet housing needs of HMA not fully addressed. No agreement with other authorities on the approach and no evidence to support the figure proposed.
Unacceptable to propose an early review before a plan is submitted. In any event, additional Green Belt release will be required at this stage so land must be safeguarded.
Housing requirement should be expressed as a minimum.
Objections to how supply has been calculated. No evidence to support timely delivery of residential development at UKC, question deliverability of town centre allocation, issues with windfall assumptions, calculation errors in existing sites, no allocation of small sites.
The Plan will not provide for a five year housing land supply upon adoption. For all sites, there needs to be clear evidence that housing completions will begin within 5 years.

Object

Representation ID: 14781

Received: 14/12/2020

Respondent: Schools of King Edward VI in Birmingham

Agent: Avison Young

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council’s calculation of LHN, which is based on the 2018 SM, will soon be obsolete. Emerging Government policy suggests that Solihull’s LHN will increase, leading to a requirement to release more land from the Green Belt.
The Housing Position statement is a summary of the broad direction of travel rather than a definitive assessment of housing land supply. It cannot be relied upon by SMBC to justify its very modest proposed contribution to unmet need in the HMA. SMBC has no formalised arrangement with any of its neighbours and no evidence to justify the figure proposed.
The SA concludes that SMBC could make a contribution of 3,000 dwellings to the shortfall in the HMA, without the impacts being materially more negative.
No statements of common ground to support the approach demonstrates a lack of constructive engagement and failure in the duty to cooperate.
P5 General.
Housing supply has been overestimated. There has been double counting, lack of evidence to demonstrate deliverability, overestimation of windfall, over-reliance on delivery from UCK Hub area.
A revised supply table is provided which demonstrates that the Council is some 551 dwellings short of the identified housing need for the Borough
Policy P5 and its supporting text at Paragraphs 220 to 232, is not positively prepared, because, on a proper assessment of housing supply, it does not meet the housing needs of the Borough.
These deficiencies in supply could be remedied through the Council revisiting its supply of sites and identifying additional land for allocation.

Object

Representation ID: 14873

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Solihull has offered up a figure of around 2,000 homes but has provided no links to the evidence nor any rationale behind this offer.
This is welcomed as a starting point, but as the attached Paper (Pegasus Group Housing and Economic Growth Paper Appendix 2) demonstrates, the figure should be far higher than this, with at least 11,500 additional homes being provided for to address the shortfall.
Statements of Common Ground should be readily available showing that partner authorities are in agreement with any approach being undertaken. The apparent lack of these at this present time is a major issue and implies that there is no agreement. The approach taken by Solihull also appears to contradict the approach taken by other LPAs within the HMA who have advanced local plan reviews

Object

Representation ID: 14880

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the quantum of growth, L&Q Estates object as the 2,105 home additional contribution, whilst welcomed as a starting point, is simply not sufficient to address the shortfall in the wider Greater Birmingham and Black Country Housing Market Area (‘the HMA). The Paper (Appendix 2) concludes that the Solihull Local Plan should be, at the very least, testing the provision of a minimum of 11,500 additional homes to address the unmet need across the HMA instead of the circa 2,000 it is currently proposing.
Policy P5 falls short of committing to the delivery of 2,105 dwellings to meet needs arising within the wider HMA – instead this element of the full housing requirement equates to the flexibility in supply proposed. Such an approach is not consistent with national policy and the firm commitment that should be made in order to satisfy the duty-to-cooperate.
Trajectory - The housing land supply position is based upon the LHN and does not factor any uplift necessary to ensure the delivery of the cross boundary provision. The 5 year housing land supply calculation should be recalculated on the basis of a housing requirement incorporating any cross-boundary commitment.
Windfall - The inclusion of a windfall allowance of 200 units per annum in respect of supply is not supported. This equates to nearly 20% of the proposed housing land supply to 2036. If the Council is promoting a fully Plan-led approach to delivering growth, then there is no need to include an allowance in the housing supply from windfall sites. The Council references the increase in windfall supply within the Borough since 1992.
Nationally Described Space Standards - There does not appear to be any evidence to justify a blanket introduction of such standards, and the viability assessment simply states ‘applies to all sites’ (page 9). The policy is clearly not compliant with national guidance which requires evidence to justify policy.
Density - The flexibility afforded to the section of Policy P5 on density is supported. However, it is not certain how such a policy would be impacted should all of the various standards be implemented, including Nationally Described Space Standards. The Council should be demonstrating how this policy will be implemented in practice, and should be providing evidence to show that it has allocated enough land to deliver the stated number of homes

Support

Representation ID: 14923

Received: 14/12/2020

Respondent: ZF Automotive UK Ltd

Agent: Turley

- Positive that SMBC seek to meet LHN and contribution to Greater Birmingham HMA shortfall.
- Important Site BL2 comes forward as one of largest single contributors to housing supply in Borough.
- Confirm support for Taylor Wimpey’s promotion of BL2

Object

Representation ID: 14925

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? No

Sound? No

Duty to co-operate? No

Para. 227-228
Housing Market Area, DtC:
- Council should identify cross-boundary matters to be addressed and the progress of co-operation in addressing these matters in Statements of Common Ground, to comply with NPPF Para.’s 24-27.
- SoCGs should be publicly available to provide transparency.
- HBF notes no SOCGs accompany the Draft Submission Plan consultation, contrary to PPG. Therefore impossible to assess if Council has satisfied legal requirements of DtC.
- GBBCHMA Position Statement (July 2020) is not a SoCG.
- It is misleading for GBBCHMA Position Statement to conclude that residual HMA shortfall is only 2,597 dwellings. This compares figures against the Strategic Growth Study (Table 5) rather than adopted housing requirements and unmet needs (Table 2).
- Figures do not account for Black Country shortfall
- Figures are not based on standard methodology
- Housing requirement should be 12,598 dpa under revised standard methodology not 10,399 dpa as in Table 5.
- Estimated housing land supply includes allowances from proposed allocation in draft Plan, as yet untested at Examination, plus other sources from non-allocations.
- Lack of agreement on how GBBCHMA housing needs will be met in full, four years after adoption of Birmingham Development Plan.