Q12. Do you agree with the level of affordable housing being sought in Policy P4? If not why not, and what alternative would you suggest?

5. Question 11/12: Do you agree with Policy 4? If not why not and what alternative would you suggest? Do you agree with the level of affordable housing being sought in Policy 4? If not why not and what alternative would you suggest?
5.1 Policy P4 seeks the provision of 50% affordable housing on sites of 11 dwellings or more/ 1000sq m. Affordable housing is defined as social rented, affordable rented, intermediate tenure and starter homes all of which should be available at costs that are affordable to households whose needs are not met in the open market.
5.2 The level of affordable housing is justified on the basis that the Council has a high level of unmet housing need, as set out in the Strategic Housing Market Assessment (SHMA)Strategic Housing Market Assessment) Objectively Assessed Need for Affordable Housing.
5.3 The supporting text explains that the policy target is set at 50% on the basis that this will include 20% Starter Homes, with the remaining 30% split between rent(22%) and shared ownership (8%). The supporting text at paragraph 193 explains that the Council anticipate that the greater values derived from delivery of starter homes will be able to support this approach, "but further evidence will be pursued to justify this."
5.4 In this respect, the level of affordable housing sought through Policy P4 assumes that Starter Homes should be over and above provision of other tenures of affordable housing. BDW and Gallagher Estates Ltd are unable to support this position in principle for the following reasons.
5.5 The Strategic Housing Market Assessment (SHMA) Strategic Housing Market Assessment) Objectively Assessed Need for Affordable Housing advises at 7.1-7.3 that;
"On completion of the calculation of the need for affordable housing, the PPG says, at Reference ID: 2a-029-20140306:
The total affordable housing need should then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes. It is clear that a Planning Authority should consider whether or not the housing target in the Local Plan should be increased to assist with meeting the need for affordable housing.
The total annual affordable housing need in Solihull of 210 households per year (as calculated in Chapter 5, Table 5.10) represents 28.7% of the annual projected household growth in the Borough between 2014 and 2033 (732 households per year as identified within the full OAN calculations14). This proportion of new housing as affordable appears achievable to deliver in Solihull.
It is clear that the Council can be confident that the affordable housing requirement can be met by the OAN identified and no adjustment is required to this figure. The figure of 28.7% is similar to the proportion of new affordable housing required within the LTBHM model, 26.9% as indicated in Table 4.3, providing further evidence that the assumptions reflect the realities of the current housing market locally."
5.6 The actual need for affordable housing to meet needs arising in the Borough over the plan period is therefore, around 28.7% and not the 50% included under Policy P4.
5.7 Additionally, the Housing and Planning Act 2016 amends the definition of "affordable housing" with regards to planning obligations under the Town and Country Planning Act 1990 (as amended) to include starter homes (as defined in Part 1 of the Act).
"159. Planning obligations and affordable housing.
(1)After section 106ZA of the Town and Country Planning Act 1990 (inserted by section 158 above) insert—
106ZB Enforceability of planning obligations regarding affordable housing
(4) In this section "affordable housing" means new dwellings in England that—
(a) are to be made available for people whose needs are not adequately served by the commercial housing market, or
(b) are starter homes within the meaning of Chapter 1 of Part 1 of the Housing and Planning Act 2016 (see section 2 of that Act)."
5.8 To date Government guidance has not been updated in the NPPF and the existing definition of affordable housing continues to apply. Notwithstanding, it is clearly the Governments' intention to do so and therefore, the provision of Starter Homes will be included in the national policy definition of affordable housing in due course.
5.9 The Draft Local Plan is seeking to apply the provision of Starter Homes as additional to identified need for affordable housing. In effect this is double counting, given that some of the need identified through the SHMA will be met by the delivery of Starter Homes.
5.10 On this basis, Policy P4 as drafted would not be sound and would not be either "positively prepared" to meet the identified need for affordable housing or justified, based upon evidence from the SHMA. Additionally, the policy would not be consistent with national policy.
5.11 The Policy text should be amended to accord with the national policy definition and that set out in Section 159 of the Ac.t
Viability
5.12 Whilst it is noted that Policy P4 includes provision for an off-site financial contribution where on site delivery is not viable or feasible, this ignores the fact that it may not be viable to secure delivery of affordable housing in particular circumstances or a financial contribution.
5.13 In fact, it remains that there is no evidence to test delivery of affordable housing across a range of site/development scenarios.
5.14 Paragraph 173 of the NPPF is clear that, "Plans should be deliverable. Therefore the sites and scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be delivered viably is threatened"
5.15 The need for effective assessment of the impact of such obligation is set out at paragraph 174, which advises that;
"They should assess the likely cumulative impact on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk"
5.16 In the absence of any such assessment of viability and deliverability, BDW and Gallagher Estates Ltd are concerned that Policy P4 in unduly onerous and would place an undue burden on new development, that would threaten the ability for developers to be able to bring sites forward.
5.17 As such Policy P4 would also fail the test of soundness on the basis of non-compliance with national policy.
5.18 The impact of such a significant requirement for the delivery of affordable housing, coupled with need for new education and community facilities, open space and physical drainage and utility infrastructure, as well as investment in highways and accessibility will threaten deliverability.
5.19 This is almost certainly likely to be the case in respect of larger greenfield schemes which will need to deliver significant levels of new infrastructure early through the development process.
5.20 The real issue is how to deliver more housing, including affordable across the market. This can only be achieved by significantly increasing the supply of new homes, which in turn will require a very substantial increase in the amount of land coming through the planning system for residential development.
Actions required to achieve soundness
5.21 Policy P4 should be amended to set the requirement for affordable housing to be 29% to meet the identified needs set out in the SHMA. The policy text should be amended to;
"Contributions will be expected to be made in the form of 29% affordable dwelling units on each development site, but will take account: (policy text continues)".
5.22 The policy should also specifically define affordable housing to include Starter Homes or defer to the national definition given the evolving position in this respect. The policy text should be amended to;
"Affordable housing includes social rented, affordable rented, intermediate tenure or starter homes"
5.23 Additionally the policy text should be amended from;
"Where on site provision is not feasible or viable there will be a financial contribution towards the provision of affordable housing that would not otherwise be provided within the Borough"
to
"The requirement for the provision of affordable housing is subject to viability. Where it is not viable to secure delivery of affordable housing through development, planning applications should be supported by a Viability Assessment to demonstrate as such."

I feel that every 11th house to be affordable is probably to little however I feel that the % proposed is a little high, some first time buyers like myself are looking for new build but will not be looking at the affordable housing option. I would suggest that a middle option is considered possibly every 6th house. as this still gives builders a mixture of plot sizes instead of building the remanding properties for larger families.

The level of affordable housing seems very high at levels only justifiable in the exceptional circumstances of the London Housing Market. The actual level of the different types of affordable housing, including those emerging as a result of the recent White Paper, that are to be sought need to be tested in a robust way. This testing should be alng tow perspectives - (a) dimensioning need and (b) assessing viability for different classes of site. The testing results need to be spelt out in the reasoned justification and backed up by an appropriate evidence base

Please see uploaded attachment

We acknowledge the need for some affordable housing within Solihull however this is an expensive place to live due to the environment and amenities that the Borough has to offer and consider that affordable housing (as defined in the SPD) in its current form is not a sustainable approach, i.e. market rates will prevail after the first occupant resulting in further need in future years. This view is supported by our recent consultation event (14th January 2017) where attendees acknowledged that we need some affordable housing but consider that providing a mix of housing that addresses the needs of a wider profile of household types, e.g. elderly, single persons etc., would encourage better rotation of starter homes and houses suitable for families. HHPC would urge SMBC to include, as planning policy, provisions to ensure Affordable Housing remains affordable (e.g. the "staircasing" out is prevented so that the unit is accessible beyond the first tenancy).

We know with the ever extending population more housing is needed. But where to put them is the main concern.

Partially agree with this policy, but property should be occupied by owner of the property, or tenant of the property, owned and managed by a housing association or local authority. So often now low cost housing is built ,and bought by a private landlord who then charges the tenant an excessive rent ,to pay the landlords mortgage on that property.

50% is excessive. 40% seems to have been working.

As outlined in the response to Question 11, there should be a lower affordable housing requirement on brownfield sites situated in sustainable locations in the first five years of the Local Plan period to encourage such sites to come forward for development.
Policy P4 should offer a greater incentive to the redevelopment of brownfield sites. This should include a requirement for a reduced affordable housing contribution on brownfield sites that are situated in sustainable locations in the first five years of the Local Plan period. This will encourage the early delivery of sites that can make a more immediate contribution towards housing land supply. This will help to offset the lead in time needed to prepare the large greenfield allocation sites that will require the provision of major infrastructure and therefore take longer to deliver. The promotion of the redevelopment of brownfield sites in the early years of the Local Plan period will result in a more balanced supply of new homes throughout the plan period.
This would be achieved by reducing the affordable housing contribution required from brownfield sites in sustainable locations to 40% in line with the previous Local Plan policy under which many of these sites will have been acquired. By reducing the affordable housing contribution to this level and allowing the use of Vacant Building Credit, there is a real incentive for the early delivery of sustainable brownfield sites that will make a more immediate contribution towards meeting housing needs. This approach complements the overall spatial strategy outlined in the emerging Local Plan, provides a greater period of time to prepare and to begin housing delivery on the larger greenfield allocations and makes the most efficient use of existing services, infrastructure and land.

I acknowledge the need for some affordable housing within Solihull however this is an expensive place to live due to the environment and amenities that the Borough has to offer and consider that affordable housing (as defined in the SPD) in its current form is not a sustainable approach, i.e. market rates will prevail after the first occupant resulting in further need in future years. This view is supported by Hockley Heath's recent consultation event (14th January 2017) where attendees acknowledged that we need some affordable housing but consider that providing a mix of housing that addresses the needs of a wider profile of household types, e.g. elderly, single persons etc., would encourage better rotation of starter homes and houses suitable for families. I would urge SMBC to include, as planning policy, provisions to ensure Affordable Housing remains affordable (e.g. the "staircasing" out is prevented so that the unit is accessible beyond the first tenancy).

Whilst housing will be affordable in first instance, land prices are likely to rise to 1-2million GBP per hectare once residential use. On resale these houses won't be affordable as will be sold presumably at full market value. They may well be sold at a discount in the first instance, but long term they won't be affordable so doesn't address the problem long term.

I am submitting my comments to the Local Plan Review.

I am unable to submit my comments by your preferred method of the portal because that does not work properly, I am unable to access that (a matter which is subject to a separate complaint).

My comments are as follows

1 Firstly, the document is very long, there is no summary and it is full of jargon. In my opinion it fails the "plain English" test. It is full of obfuscation which makes it quite difficult to understand what is being proposed. If the Council really wishes to have meaningful consultation with council tax payers then there needs to be simpler communication.

Specific and general comments on the document are :-

2 I disagree with "Challenge G" - Gypsy & Traveller issues. I fundamentally object to the massively disproportionate amount of Council time and effort and council tax payers money that is expended on this very small section of the "community". These people are not part of the community, they do not wish to be part of the community, they just want to take advantage of the community.

3 Opening up of Green Belt Land around Damson Parkway/Old Damson Lane for use by JLR and other companies associated with car manufacturing. - I object to this proposal ( and I have objected to the planning submission by JLR for their LOC). There is no need for this suggested development to be immediately adjacent to the JLR plant, anywhere reasonably close would be perfectly suitable. I am very concerned by the inference in the document that because the despatch facility which has recently been built used green belt land then it is acceptable to use more green belt land for JLR convenience. That is in my view completely wrong. Obviously there was no other practical option for the despatch facility than the one approved (which I why I commented in support - with reservations - about that application).

4 New Housing developments - by the time I got to this section of the document I had already spent about an hour trying to understand earlier sections of the report, so I was beginning to lose the will to live, therefore I am not fully clear as to what is being proposed here. However I am clear that the plans for housing development, particularly affordable homes, are completely inadequate. The country as a whole faces a massive shortage in affordable housing and much more land needs to be released to provide major developments. I would much rather see further housing development around the periphery of the town than the proposed industrial development

LDP - Proposed Housing Allocation 18
I wish to formally register my comments and objections based on the following main items of which there are so many.

'Affordable Homes' invariably generate tenants of doubtful personal standards It would appear that the inclusion of a substantial quantity of such houses is disproportionate to most sympathetic developments of this kind.
Sharmans Cross Road and the adjacent junction already generates road risks by way of congestion and layout. Additional usage will undoubtedly create further potential danger to pedestrians and in particular children who are likely to be around in abundance. Greater numbers of vehicles means increased environment pollution....do we really want this!!
The list of negative factors highlighting the weakness of the proposal is almost endless and Planning is respectfully urged to deny the application.
Most will concede the national demand for housing is acute, however, this particular site does not lend itself to such a project which is unreasonable and inconsiderate. The present infrastructure and local amenities would require enormous upgrade the cost of which ultimately falling on the tax payer. This is incongruous in it's entirety.

see attached letter

see attached letter

see attached letter

see response from agent

On behalf of the forum, I am submitting the attached document as the considered view of the Neighbourhood Forum members in response to the consultation to Solihull Council's Draft Local Plan. The response relates in particular to the implications for the KDBH area.

In order to capture and then reflect the views of forum members and residents, the forum has held three public meetings; in December 2016 and January and February of this year. Feedback has been gathered on each occasion and we have also invited and received comments via e-mail.

We also have a body of evidence that reflects residents' general views, concerns and aspirations for the area from the residents survey conducted in 2016.

In addition, we have reviewed the proposed housing allocations, for the KDBH area as outlined in the draft plan against the Council's published methodologies and evidence base to try to understand how they were determined.

We believe that the document is a balance and objective representation of the Forum member's views.

We have also encourage members to submit their own individual responses, following the instructions on your website. This should ensure that you have the full spectrum of views.

see attached report
Balsall Parish Council resolved at the Council meeting on 15 February 2017 to submit this report in response to the Solihull Draft Local Plan Consultation ending 17 February 2017

see attached letter and graphics

see attached letter and supporting statement

see letter and supporting statement

My view on the Proposed sites for Balsall Common is that ..... : I lived in Balsall Common up until 5 months ago (48 years) and am currently Chairman of Berkswell Cricket Club who thrive in the Centre of the village.
Its great the see the demographic growing in Balsall Common as from a purely selfish point of view it will help increase our membership. The Oakes Farm development stands out from other proposed developments in the village as it is slightly on the fringes and does not impose on any existing 'green' and leisure areas within Balsall Common which, to be frank, other proposals do. Balsall Common has never been abundant with affordable housing and to see 50% of the proposal catering for this is really pleasing. I lived opposite Oakes Farm for 10 years and can safely say that the proposed area for development can only compliment what is there already. Out of all the proposals in Balsall Common, it is the stand out and obvious choice.

see letter

see attached letter

see letter from agent on behalf of landowner

original responses not received - copy provided
see attached letter

see letter

see attached letter and supporting document (The UK Central Hub Growth and Infrastructure Plan)

see attached documents