Policy P5 – Provision of Land for Housing

Object

Representation ID: 14926

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

LHN (Para. 220) & Housing Requirement (Para. 228):
- PPG clearly state standard methodology is the minimum starting point for determining housing need, it does not produce a housing requirement figure.
- The Council has decided to plan for 22,998 jobs growth by 2036 based on Baseline jobs forecast plus UK Central Hub Scenario.
- Other evidence published by the Council (Midlands HS2 Growth Strategy & UKC Hub Growth and Infrastructure Plans quoted in the Viability Study) identifies potential for much higher job numbers. Council should confirm there are no inconsistencies in the evidence, and HEDNA is not under-estimating the additional jobs growth from the UKC Hub.
- HBF query assumptions on commuting patterns for the Borough and UK Central Hub jobs, given Para. 26 of HEDNA also states that commuting ratios are known to have likely changed.
- The derivation of the 2,105 contribution to HMA shortfall is not defined, and not included in a SoCG. Seems to be just difference between LHN and Housing Land Supply.
- Affordable housing need figures for Solihull are significant, PPG states an increase in total housing figures may be considered to help deliver affordable housing.
- Govt has confirmed its intention to review standard methodology, proposed revision would increase LHN to 1,011 dpa.
- Govt committed to ensuring more homes are built, and supports Councils planning for growth. HEDNA has demonstrated that circumstances exist to justify a housing need higher than the standard methodology. PPG does not set any limitations on a higher figure.
- HBF believe Council should be more ambitious and significantly boost housing supply (NPPF Para. 59)
- Housing requirement in Policy P5 not set out as a minimum figure.

Object

Representation ID: 14927

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Land Supply (and Spatial Strategy):
- Limited information available to assess the robustness of the Council’s overall HLS.
- Council should set out in details its assessment of the capacity of SHLAA, Brownfield Register, Town centre and UK Central Hub Area sites.
- Deliverability of these locations will be dependent on viability of PDL and demand for high density urban living post Covid-19.
- HBF not wish to comment on individual sites, but notes the Council has provided no data on a site by site analysis of the deliverability of individual site allocations; critical the Council’s housing trajectory is correct and realistic based on lapse rates, lead in times and delivery rates, supported by site promoters.
- Lack of contingency in Council’s housing supply, as land supply and requirement are same figure, with only 10% lapse rate.
- HBF advocates as large a contingency as possible, and housing requirement should be treated as a minimum rather than a maximum, to provide optimum flexibility, changing circumstances and flexibility to provide greater choice and competition.
- Overall land supply should include a wide mix of sites, short and long-term supply, strategic and non-strategic allocations; housebuilding companies require widest possible range of products and diversified portfolio of housing sites for range of household types.
- None of proposed allocations are less than 1ha, which is inconsistent with 10% requirement in NPPF.
- Notes the housing delivery phases for sites
- Notes that housing trajectory is stepped
- Surplus in 5YLS is only 329 dwellings, can be easily eroded by changes in circumstances. If Council cannot demonstrate 5YLS on adoption of Local Plan it shall be found unsound.

Object

Representation ID: 14928

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Deliverability & Viability Study:
- HBF have concerns about Council’s standard inputs including (but not exhaustively):
o Using BCIS lower quartile costs. All new build housing is built to a high specification therefore median should be used.
o Blended developer return of 17% may not reflect the risk profile of development
o HBF recommend finance cost of 6.5-7%, not 6%
o Professional fees should be 8-10% for simple sites, and up to 20% for complex sites.
o Sales and marketing costs should be 3-5%
o Concern that not an accurate assessment of cumulative impact of compliance with all policy requirements, including at least:
 Policy P4D,
 Policy P4E (M4(2) & M4(3) compliant homes
 Policy P5 for NDSS
 Policy P9 for FHS and EVCPs
 Policy P10 (net biodiversity gain)
 Policy P11 (water efficiency standard)
- HBF notes that following typologies are unviable:
o North Solihull greenfield and PDL
o Mature Suburbs PDL
o Windfall sites in low value areas (North Solihull)
o Retirement developments

Object

Representation ID: 14937

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Nationally Described Space Standards (NDSS):
- Council should provide a local assessment evidencing case for Nationally Described Space Standards to accord with NPPF Para. 31, Para 127(f) & FN 46, and PPG.
- No such evidence supplied.
- Must be based on need not ‘nice to have’ basis, otherwise Government would have made mandatory in Building Regulations.
- Council should recognise customers have different budgets and aspirations; could lead to customers purchasing larger homes in floorspace, but less bedrooms to meet need. Could lead to overcrowding and reducing quality of living environment.
- Inflexible approach will impact on affordability and affect affordable home ownership products such as First Homes.
- Viability Assessment only test one average house type size, not all 16 NDSS compliant house typologies. Not robust approach.
- No assessment on impact on affordability. Council should assess potential adverse impacts on affordable home ownership products such as First Homes.
- Knock on effect to slow or reduce delivery rates.
- If NDSS carried forward, Council should put forward transitional arrangements.

Object

Representation ID: 14955

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Clear that Solihull cannot meet its housing requirement of 15,270 homes without significant adverse harm to Green Belt and environment
- SM is not suitable basis for housing requirement and assumption is there are no constraints to meeting full requirement
- SM does not take into account in-and-out commuting of the Borough
- Citing Govt advisor Professor Wenban-Smith, it is dangerous to release too much land: ‘over provision can never be corrected, under provision can be corrected later when needs are better defined.’
- Proposed delivery rate of 938dpa is a huge step-up for construction industry to achieve in the Borough – not been achieved in a single year since 2001 (highest being 836 in 2005/06)
- Average delivery rate over last 5 years is 706 dpa.

Object

Representation ID: 14956

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Land Supply:
- Development should be focused on brownfield first, in accordance with Government advice
- More work needs to be done on capacity of final version of Solihull town Centre masterplan and capacity at Arden Cross.

Object

Representation ID: 14957

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Windfall:
As an impact of Covid-19, likely to be small reduction in office use as more people choose to work from home or shared offices. Therefore there will be an increase in windfall sites as offices become redundant, which will be more than enough to omit the most unsustainable site allocations from the Plan.

Object

Representation ID: 14974

Received: 11/12/2020

Respondent: Mrs Jean Walters

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Land capacity:
Covid 19 consequences not been taken into account.
Likely there will be less need for offices, and an increase in windfall sites as offices become redundant.
Additional capacity in Solihull Town Centre for residential use and at Arden Cross is likely above that in Plan.
These sites should be considered ahead of destroying sensitive Green Belt, in conformity with Para. 68 of the NPPF.
Quoting Professor Wenban-Smith: “Over provision can never be corrected; under provision can be corrected later when needs are better defined.”

Object

Representation ID: 15013

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Housing Land Supply:
- Should refer to additional homes at UK central Hub (2,740) and state 8,010 net additional homes in period 2020-2036.

Object

Representation ID: 15014

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

GBBCHMA housing shortall
- Unmet need of wider GBBCHMA been under-estimated
- See Barton Willmore report ‘Solihull Borough Housing Need Technical Note’ (Dec 2020) in Appendix 4:
o Birmingham’s real deficit is 11,294 – 13,1010 dwellings up to 2031
o SMBC not include HMA shortfall post 2031
o Not consider additional shortfall arising from Black Country Plan review
o Post 2031 unmet need calculated to be a minimum of 17,700 dwellings between 2031 and 2040.
o Should include review policy or trigger to address additional shortfall once tested.
o Limited additional housing requirement arising from UKC Hub Area is at odds with Borough’s ambitious Vision for UK Central Hub Area
o BW report state between 1,036-1,248 homes per annum required to meet UKC scenario, or 3,520-6,912 dwellings increase over plan period.

Object

Representation ID: 15015

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

LHN and Housing Requirement
- IM have concerns about evidence supporting housing requirement.
- Agree that SM is good starting point.
- PPG state this is just a minimum starting point.
- PPG state several circumstances where SM should be exceeded, and these apply to Solihull:
o Potential for ‘Supergrowth’ at UKC Hub area
o Further work required on housing need impacts of planned growth and strategic infrastructure improvements at UK Central Hub
o 2015 Midlands HS2 Growth Strategy state significant potential to deliver growth on nationally significant scale, over and above HS2 construction.
- Concerns been raised at previous consultations

Object

Representation ID: 15016

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Windfall Sites
- 2,800 dwellings on non Green Belt sites appears ambitious, even in context of past delivery.

Object

Representation ID: 15025

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing Supply:
Do not expect that all sites can deliver number of houses set out in Plan.
Significant proportion of housing supply from small number of large sites – notwithstanding site-specific developability issues, inherent deliverability concerns with infrastructure, or complex site ownership etc.
Supply vulnerable is only one of sites failed or is delayed.
To address this Plan should allocate wider range of sites, inc. CFS 193.

Object

Representation ID: 15026

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing Supply - lack of buffer
The total buffer (taking into account the 10% lapse rate) above the minimum housing requirement is only 1.9%, providing insufficient flexibility, should sites not reach full capacity, delayed/deleted, or windfall delivery rate falls.
Conflicts with NPPF Para. 11.
Insufficient buffer could result in DSP unable to meet its minimum housing requirement, contrary to NPPF Para. 35a and 59.
See recent examples:
- Rugby Local Plan (June 2019) include 17.5% buffer (which includes unmet needs);
- Nuneaton and Bedworth Local Plan (June 2019) include 5.5% buffer, which Inspector called 'very modest' but cautiously considered acceptable in report.

Object

Representation ID: 15027

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Windfall allowance:
- Constitutes 18% of the Emerging Plan’s housing supply
- Windfall sites are a finite resource and
the high delivery of windfall developments in recent years will have diminished the supply of sites.
- Particularly relevant in Solihull Borough given its Green Belt constraints
- Council keeps separate brownfield land register
- Given NPPF’s restrictions, no windfall contributions can come from Green Belt land
- Uncertain whether the past rates of windfall delivery can be sustained up to 2036
- Windfall allowance is based purely on historic trends, not SHELAA delivery trajectory, and this approach is inconsistent with NPPF para. 70
- DSP assumes annual windfall development rates will be required in full during the period 2022-2036 in order to meet minimum housing requirement, given the lack
of flexibility in the housing supply.

Object

Representation ID: 15028

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Build out rates/trajectory:
- Lichfields' 'Start to Finish' assessment concludes that sites of more than 500 dwellings take on average 5 to 8.3 years from the date that an outline application is registered.
- Given that unlikely Plan will be adopted before Spring 2022, and factoring another 12 months to submit an application, sites of 500+ dwellings in Plan may not start delivery until 2031.
- Lichfields' assess that build out rates are:
• 500-999 dwellings – ca 150 dpa;
• 1,000-1,499 dwellings – ca 175dpa;
• 1,500-1,999 – ca 210dpa;
• 2,000+ dwellings – ca 290dpa.
Therefore even with most ambitious build out rates, some sites will not be completed by end of plan period.

Object

Representation ID: 15029

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Local Housing Need and Standard Methodology:
- Correct to use SM to calculate housing requirement in accordance with NPPF Para. 60.
- Govt published revised standard method figures for consultation in August 2020. Projects a 25% increase in Solihull’s housing need up from 804 to 1,011 dpa, or 12,901 to 16,176 over plan period. Strong likelihood this will be adopted. Therefore DSP unlikely to meet housing need over plan period.
- Would need to review in less than 5 years, further Green Belt would need to be released as Borough 67% GB with little brownfield land available.
- NPPF Para. 146 – GB boundaries should endure beyond plan period. Review so soon would be inconsistent with NPPF, and unsound.
- DSP should release more land, or at very least identify safeguarded land.

Object

Representation ID: 15030

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Birmingham City unmet housing need:
- Birmingham Development Plan has shortfall of 37,900 dwellings, and 20,440 shortfall against current SM.
- Para. 227 of DSP acknowledges Birmingham HMA shortfall and contribution of 2,105 dwellings.
- Not considered proportionate given functional relationship between Birmingham and Solihull Metropolitan Borough Council: shared boundary, good public transport and road connectivity.
- 2011 Census data demonstrates 887 net people migrated from Birmingham to Solihull between 2001 and 2011, 28% of Birmingham’s net migration.
- DSP should seek to accommodate 28% of HMA’s unmet need, not just 2,105.
- Disproportionate accommodation of unmet needs is contrary to NPPF Para. 35(a)
- Solihull clearly most sustainably located authority in the HMA
- Contrary to NPPF Para. 60 and 136.

Object

Representation ID: 15031

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Consider automatic allocation of 2013 Solihull Local Plan sites, which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach.
Sites not come forward despite Council lacking a 5YLS, points to deliverability issues with sites.
(See also Para. 18 of Introduction).

Object

Representation ID: 15036

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Need evidence in 2020 HEDNA:
- PPG state that SM only minimum
- Expected growth at UKC Hub meets criteria in PPG to increase SM
- HEDNA state 13,000 jobs at UKC Hub, over 10,000 Experian baseline
- HEDNA assume only 25% of jobs occupied by Solihull residents.
- Barton Willmore carried out own analysis at 0.93 and 0.98 commuting ratios
- Demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario
- HEDNA identifies acute affordable housing need in Borough, BW analysis conclude HEDNA housing need should increase to meet this component of need.

Object

Representation ID: 15037

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

GBBCHMA Unmet Housing Need:
o Barton Willmore analysis of unmet need in wider GBCCHMA suggests that 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031; Birmingham’s deficit alone is between 11,924 – 13,101 dwellings up to 2031.
o Furthermore, if using the current standard methodology, then significant unmet need from Birmingham City and Black Country between 25,543 and 27,350 dwellings up to 2031.
o If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031.
- This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect in January 2022.
o Taking into consideration the proposed changes to Standard Method (consulted on by Government in summer 2020), this would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
o Unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.

Object

Representation ID: 15038

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’.
Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.

Object

Representation ID: 15039

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply.
We consider that any sites to be delivered in this way should be considered as windfall developments.

Object

Representation ID: 15040

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.

Object

Representation ID: 15041

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.

Object

Representation ID: 15042

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
- Consider scale and delivery rates of UK Central hub proposals are unrealistic, and neither details on trajectory and delivery timescales, nor commitments from delivery partners, have not been included in consultation documentation.
- Based on LPR adoption date of 2022, we consider first likely completions to be ca. 2030. This is based on Lichfields’ Report (‘Start to Finish’, Feb 2020) analysis that concludes the average time from outline planning app to first completion is 8.4 years.
- Given information within the August 2020 consultation {Arden Cross?}, we consider a 160dpa build out rate between 2030-2036 is reasonable, to delivery 960 dwellings. Type of supply should also be considered, as geared towards apartments. Amount of infrastructure required also needs consideration.

Object

Representation ID: 15043

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
Trajectory:
- SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase.
- We refer you to Guildford Local Plan Inspector’s report, which concludes the Liverpool method does not meet the Government’s objective to boost housing supply in the shorter term.
- Consider Solihull should follow same approach as Guildford and allocate more sites.
- As with withdrawn Uttlesford Local Plan, a stepped trajectory may create a fragile 5 year land supply.
- Stepped trajectory may worsen the affordability problem as it delays delivery.

Object

Representation ID: 15060

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Need evidence in 2020 HEDNA:
- PPG state that SM only minimum
- Expected growth at UKC Hub meets criteria in PPG to increase SM
- HEDNA state 13,000 jobs at UKC Hub, over 10,000 Experian baseline
- HEDNA assume only 25% of jobs occupied by Solihull residents.
- Barton Willmore carried out own analysis at 0.93 and 0.98 commuting ratios
- Demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario
- HEDNA identifies acute affordable housing need in Borough, BW analysis conclude HEDNA housing need should increase to meet this component of need.

Object

Representation ID: 15061

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

GBBCHMA Unmet Housing Need:
o Barton Willmore analysis of unmet need in wider GBCCHMA suggests that 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031; Birmingham’s deficit alone is between 11,924 – 13,101 dwellings up to 2031.
o Furthermore, if using the current standard methodology, then significant unmet need from Birmingham City and Black Country between 25,543 and 27,350 dwellings up to 2031.
o If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031.
- This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect in January 2022.
o Taking into consideration the proposed changes to Standard Method (consulted on by Government in summer 2020), this would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
o Unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.

Object

Representation ID: 15062

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Vulnerability of housing supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’.
Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.