Policy P5 – Provision of Land for Housing

Object

Representation ID: 15140

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The current estimate of housing need may be insufficient and will require an upward adjustment. The local housing need figure for Solihull is likely to increase from 807 dwellings to 1,011 dwellings under the emerging methodology published in August 2020.Greater measures should be taken to address the scale of affordable housing need, including setting a requirement in excess of the baseline need figure.

Object

Representation ID: 15142

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The contribution to the unmet housing needs from the wider HMA should be specifically set out in policy so the Council can be held accountable.

Very little weight should be attributed to the GBBCHMA Housing Position Statement in relation to Birmingham’s housing shortfall until the figures have been properly tested. Reliance should be placed on the current formal position- a base shortfall of 37,900 dwellings.

Object

Representation ID: 15143

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

A stepped trajectory would deliver housing at a lower rate for several years from the date of adoption. Greater consideration should be given to finding more small and medium size sites which would deliver early thus negating the need for a stepped trajectory.

Object

Representation ID: 15144

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Council has not built any measure of flexibility in the overall supply. There is no contingency against under-delivery from delays or slower rates of delivery than anticipated.

There are concerns on the reliance of windfall sites. It is not clear whether there is any site size limit and there is a clear risk of double counting against other components in the supply.

Additional contingency measures should be applied in order to cater for currently unforeseen and unknown circumstances.

Object

Representation ID: 15220

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

No statements of common ground have been prepared at the publication stage. It is unclear if effective and joint working has been undertaken, particularly in respect of unmet housing needs from the HMA. There is a significant gap in the Council’s evidence base on meeting its legal obligations under the Duty.

The housing need across the HMA beyond 2031 has been overlooked. There could be an emerging unmet need for some 39,605 dwellings for the period 2031 to 2036.

Solihull must engage on how to address the significant shortfall in housing needs of the Black Country. Delaying further consideration does not meet the legal test under the 2011 Act.

Object

Representation ID: 15226

Received: 14/12/2020

Respondent: Mr S Kelly

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Minimum housing need should be increased to account for UK Central job growth and ‘acute’ need for affordable housing.
Uncertainty and wide variation of figures about HMA shortfall. No evidence that Solihull’s contribution has been agreed or that it meets duty to cooperate obligations. No Statement of Common Ground so no real commitment to resolving the shortfall within the GBBC HMA.
Numbers from the Brownfield Land Register are unreliable given no part 2 register and no guarantee that sites will yield the capacity identified.
Past trends are not compelling evidence that windfall is a reliable source of supply.

Object

Representation ID: 15235

Received: 14/12/2020

Respondent: Mr J Green

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Minimum housing need should be increased to account for UK Central job growth and ‘acute’ need for affordable housing.
Uncertainty and wide variation of figures about HMA shortfall. No evidence that Solihull’s contribution has been agreed or that it meets duty to cooperate obligations. No Statement of Common Ground so no real commitment to resolving the shortfall within the GBBC HMA.
Numbers from the Brownfield Land Register are unreliable given no part 2 register and no guarantee that sites will yield the capacity identified.
Past trends are not compelling evidence that windfall is a reliable source of supply.