Draft Local Plan Review

No

Representation ID: 4109

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Council not meeting OAHN.

No

Representation ID: 4110

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

DLP should be clearer about its definition of affordable housing rather than deferring to a Supplementary Planning Document.
No viability assessment has been produced.
50% level of affordable housing should be texted along with whole plan viability and CIL charging schedule rates and zones.
50% level should be justified as only 26.9% is required.
According to Housing White Paper the 20% requirement for Starter Homes is no longer mandatory.

No

Representation ID: 4111

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

50% level should be justified as only 26.9% is required.
According to Housing White Paper the 20% requirement for Starter Homes is no longer mandatory.

No

Representation ID: 4112

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

HBF preference is for Option 1.
HBF would be opposed to alternative.
If the Council decides to pursue this alternative option then it should be justified by robust evidence.

No

Representation ID: 4113

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Number of concerns about Council's proposed housing requirement figure:
SHMA report is not an OAHN for whole HMA. Council acknowledges there is no OAHN for wider HMA, and that the SHNS (2015) is out of date as it relies on 2012 SHNP;
Assessment of worsening market signals, affordable housing need, and supporting economic growth have been calculated for Solihull only, not wider HMA;
No evidence to justify 2000 dwellings;
No justification for discounting the 10% uplift for worsening market signals from this unmet need;
Proposed uplift of 10% is overly conservative;
No adjustment to support HS2 Hub economic growth.

No

Representation ID: 4114

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Council should provide further evidence that the proposed 8% contingency provides sufficient flexibility for the District.
Should consider mechanisms for bringing forward, if necessary, reserve sites and/or safeguarded land during as well beyond the plan period.
A higher housing requirement will necessitate a commensurate increase in the overall HLS.
Any phasing set out in Policy P5 should not be a brake on bring forward sustainable development.
To maximise housing supply, widest possible range of sites, by size and market location should be allocated.
Key to increased housing supply is number of sales outlets and wide range of products and locations.

No

Representation ID: 4115

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

For the DLP to be found sound, it is recommended that the Council reconsiders the following matters:
The assessment of OAHN within the context of the Greater Birmingham HMA;
The assessment of Housing land supply against a higher housing requirement;
The justification and viability testing of the proposed increase to 50% affordable housing provision;
Excessiveness of requirements proposed in Policies P7, P11 and P15.

No

Representation ID: 4116

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Policy P7 -
Bullet points 2&3 requiring developments to be within 30 minute frequency bus service is overly onerous, which may frustrate the development of otherwise sustainable sites.
Policy requirements should reflect NPPF (Para. 17). This 'can be made sustainable' focus is missing from Policy P7.

No

Representation ID: 6282

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Contend that 15,029 dwellings is based on under estimation of the OAHN.
Known that alternative OAHN calculations range up to 23,700 dwellings for Solihull excluding any unmet needs from elsewhere in the HMA.
Council should reconsider its housing requirement based on a full OAHN for the HMA.
Housing requirement should be expressed as a minimum.

No

Representation ID: 6283

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Policy P11 -
Should delete higher optional water efficiency standard of 110 litres per day per person.
NPPG is explicit that higher water efficiency standards should only be proposed in identified areas of water stress.
It is noted that the Water Cycle Study by the EA and STW has not identified Solihull as a water stress area (see Para.'s 303 and 304).