Draft Local Plan - Supplementary Consultation

Support

Representation ID: 8546

Received: 14/03/2019

Respondent: Gladman Developments

Gladman agrees with the Council that the Standard Method represents the most appropriate
approach to defining the minimum housing needs of the authority

Comment

Representation ID: 8551

Received: 14/03/2019

Respondent: Gladman Developments

Gladman is unable to conclude with any reasonable degree of certainty that the supply proposed
through the Local Plan is deliverable. This is due to the absence of site-specific information
regarding the timescales for delivery. The Council should publish a Housing Trajectory before it
submits the Local Plan review for examination

Comment

Representation ID: 8552

Received: 14/03/2019

Respondent: Gladman Developments

in order to
minimise the potential effect no or delayed delivery at any allocated site would have, Gladman
consider that there is a need for additional allocations to be identified.

Object

Representation ID: 8553

Received: 14/03/2019

Respondent: Gladman Developments

In setting out the sources of housing supply the 10% deduction made towards sites which have not yet commenced but benefit from planning consent, sites identified within the SHLAA and sites identified on the Brownfield Register is welcomed to account for non / under delivery. Council should provide evidence on windfall delivery in order to clearly demonstrate that the 2,250 dwelling windfall allowance made by the Local Plan Review is justified and realistic. The Council should review its existing allocations before rolling forward the allocation of these sites through the Local Plan Review as these were first identified in the Core Strategy which was adopted 5 years ago and have still not come forward. The allocation of a site within a development plan is not on its own enough evidence to demonstrate reasonable prospect. Is concerned that there is insufficient flexibility provided within the supply to ensure full and consistent delivery of the housing requirement. The absence of a detailed housing trajectory within the Local Plan means that it is difficult to provide any comments on the deliverability of the housing requirement. It is unclear what assumptions the Council is making in terms of the lead-in time and build out rate for each of the sites identified within the supply. There is a need for the level of flexibility within the supply to be increased to at least 20%.
Agree in principle with the two step site selection process which applies a sequential preference towards non green belt sources of supply. However considers that step 1 and step 2 assessments should be applied to all sites which do not score red. Whilst national planning policy sets out that Green Belt land is to be considered sequentially, this should not be at the cost of other sustainability factors, site suitability and deliverability. Does not object in principle to any allocation shortlisted by the Council but considers that the amount of allocations will need to substantially increase.
Considers that the Council should consider the identification of safeguarded land through the Local Plan review. The benefit of Safeguarded Land being to ensure the longevity and permanence of the Green Belt, whilst providing flexibility for future needs to be accommodated if necessary.

Object

Representation ID: 8555

Received: 14/03/2019

Respondent: Gladman Developments

Supports the use of the Standard Methodology for assessing local housing need however believes there is a strong case for the requirement to be uplifted above this point. HS2 and associated transport infrastructure improvements will enhance connections between the Borough and wider urban area. The UK Central Hub proposals aims to secure long term benefits to regional economy and sufficient homes should be planned for in the authority and wider HMA area to support this. Failure to plan for this could lead to affordability pressures, unsustainable commuting patterns and reduce the economic benefits which might be secured from HS2. Questions basis for the 2,000 increase above the standard methodology figure to accommodate HMA needs and why a larger figure has not been pursued. There is no discussion to the wider shortfall of which 70% declared unmet need within the HMA remains. It is clear that in order to secure a successful outcome across the HMA authorities will need to come together and adopt a memorandum of understanding to set out how the unmet need will be addressed. There are strong justifications for Solihull to accommodate a larger proportion of this unmet need, migratory links between Solihull and Birmingham are amongst strongest in HMA, Solihull will benefit significantly from improvements to the quality and frequency of public transport connections, benefitting directly from HS2. Is the location for over 100,000 jobs as well as Birmingham Airport and the NEC. The role of Solihull within the West Midlands economy will evolve with the UK Central Hub.

Object

Representation ID: 10364

Received: 14/03/2019

Respondent: Gladman Developments

Considers that the need and justification for the proposed approach does not reflect the evidence base supporting the Local Plan. Questions justification for 50% affordable housing requirement when evidence provided within the Part 2 SHMA would appear to indicate that affordable housing needs are much lower at 210 dwellings per annum (roughly 25% of future housing need). No data provided as part of the consultation to illustrate the mix of housing delivered within the Borough in recent years. The Part 2 SHMA sets out that the largest proportion of future housing need is for 4 bedroom dwellings or more. There is not a significant need for smaller housing stock. Concern over how the Council would monitor the implementation of the proposed approach for affordable housing. The total number of dwelling secured would be on a case by case basis therefore the Council would be unable to conclude how effective the Local Plan would be in responding to affordable housing need. This is more problematic for outline planning applications where details relating to the number of
bedrooms, habitable rooms, and floorspace are more likely to be determined later through the detailed application stage. As a result, for outline planning applications the principle of development will be secured without information on the amount of affordable housing to be
provided. The Council is unlikely to know what impact the implementation of this policy would have on viability, harming the soundness of the Local Plan. This absence of viability evidence, together with the variation of conditions in which the policy would be applied would mean that applications would need to be viability tested on a site by site basis. This would substantially increase the length of time it would take for the Council to determine planning applications. A percentage-based policy based on the number of homes delivered, as currently adopted, gives
more certainty and clarity as to the Council's requirements and provides a measurable target for the Council to consider the performance of housing delivery against. The perceived shortage in the delivery of smaller housing types could be more effectively addressed through the application of other policy tools. Starter homes now form part of the definition of affordable housing but do not remain as affordable homes in perpetuity and as such will one day form part of the Borough's supply of market dwellings. Given the restrictions placed on starter homes in terms of price paid, size and type this will increase the supply of smaller stock within the Borough. Density requirements may also be effective in securing a higher proportion of smaller dwellings.

Object

Representation ID: 10365

Received: 14/03/2019

Respondent: Gladman Developments

Considers that the need and justification for the proposed approach does not reflect the evidence base supporting the Local Plan. Questions justification for 50% affordable housing requirement when evidence provided within the Part 2 SHMA would appear to indicate that affordable housing needs are much lower at 210 dwellings per annum (roughly 25% of future housing need). No data provided as part of the consultation to illustrate the mix of housing delivered within the Borough in recent years. The Part 2 SHMA sets out that the largest proportion of future housing need is for 4 bedroom dwellings or more. There is not a significant need for smaller housing stock. Concern over how the Council would monitor the implementation of the proposed approach for affordable housing. The total number of dwelling secured would be on a case by case basis therefore the Council would be unable to conclude how effective the Local Plan would be in responding to affordable housing need. This is more problematic for outline planning applications where details relating to the number of
bedrooms, habitable rooms, and floorspace are more likely to be determined later through the detailed application stage. As a result, for outline planning applications the principle of development will be secured without information on the amount of affordable housing to be
provided. The Council is unlikely to know what impact the implementation of this policy would have on viability, harming the soundness of the Local Plan. This absence of viability evidence, together with the variation of conditions in which the policy would be applied would mean that applications would need to be viability tested on a site by site basis. This would substantially increase the length of time it would take for the Council to determine planning applications. A percentage-based policy based on the number of homes delivered, as currently adopted, gives
more certainty and clarity as to the Council's requirements and provides a measurable target for the Council to consider the performance of housing delivery against. The perceived shortage in the delivery of smaller housing types could be more effectively addressed through the application of other policy tools. Starter homes now form part of the definition of affordable housing but do not remain as affordable homes in perpetuity and as such will one day form part of the Borough's supply of market dwellings. Given the restrictions placed on starter homes in terms of price paid, size and type this will increase the supply of smaller stock within the Borough. Density requirements may also be effective in securing a higher proportion of smaller dwellings.

Object

Representation ID: 10366

Received: 14/03/2019

Respondent: Gladman Developments

Considers that the need and justification for the proposed approach does not reflect the evidence base supporting the Local Plan. Questions justification for 50% affordable housing requirement when evidence provided within the Part 2 SHMA would appear to indicate that affordable housing needs are much lower at 210 dwellings per annum (roughly 25% of future housing need). No data provided as part of the consultation to illustrate the mix of housing delivered within the Borough in recent years. The Part 2 SHMA sets out that the largest proportion of future housing need is for 4 bedroom dwellings or more. There is not a significant need for smaller housing stock. Concern over how the Council would monitor the implementation of the proposed approach for affordable housing. The total number of dwelling secured would be on a case by case basis therefore the Council would be unable to conclude how effective the Local Plan would be in responding to affordable housing need. This is more problematic for outline planning applications where details relating to the number of
bedrooms, habitable rooms, and floorspace are more likely to be determined later through the detailed application stage. As a result, for outline planning applications the principle of development will be secured without information on the amount of affordable housing to be
provided. The Council is unlikely to know what impact the implementation of this policy would have on viability, harming the soundness of the Local Plan. This absence of viability evidence, together with the variation of conditions in which the policy would be applied would mean that applications would need to be viability tested on a site by site basis. This would substantially increase the length of time it would take for the Council to determine planning applications. A percentage-based policy based on the number of homes delivered, as currently adopted, gives
more certainty and clarity as to the Council's requirements and provides a measurable target for the Council to consider the performance of housing delivery against. The perceived shortage in the delivery of smaller housing types could be more effectively addressed through the application of other policy tools. Starter homes now form part of the definition of affordable housing but do not remain as affordable homes in perpetuity and as such will one day form part of the Borough's supply of market dwellings. Given the restrictions placed on starter homes in terms of price paid, size and type this will increase the supply of smaller stock within the Borough. Density requirements may also be effective in securing a higher proportion of smaller dwellings.

Object

Representation ID: 10367

Received: 14/03/2019

Respondent: Gladman Developments

Considers that the need and justification for the proposed approach does not reflect the evidence base supporting the Local Plan. Questions justification for 50% affordable housing requirement when evidence provided within the Part 2 SHMA would appear to indicate that affordable housing needs are much lower at 210 dwellings per annum (roughly 25% of future housing need). No data provided as part of the consultation to illustrate the mix of housing delivered within the Borough in recent years. The Part 2 SHMA sets out that the largest proportion of future housing need is for 4 bedroom dwellings or more. There is not a significant need for smaller housing stock. Concern over how the Council would monitor the implementation of the proposed approach for affordable housing. The total number of dwelling secured would be on a case by case basis therefore the Council would be unable to conclude how effective the Local Plan would be in responding to affordable housing need. This is more problematic for outline planning applications where details relating to the number of
bedrooms, habitable rooms, and floorspace are more likely to be determined later through the detailed application stage. As a result, for outline planning applications the principle of development will be secured without information on the amount of affordable housing to be
provided. The Council is unlikely to know what impact the implementation of this policy would have on viability, harming the soundness of the Local Plan. This absence of viability evidence, together with the variation of conditions in which the policy would be applied would mean that applications would need to be viability tested on a site by site basis. This would substantially increase the length of time it would take for the Council to determine planning applications. A percentage-based policy based on the number of homes delivered, as currently adopted, gives
more certainty and clarity as to the Council's requirements and provides a measurable target for the Council to consider the performance of housing delivery against. The perceived shortage in the delivery of smaller housing types could be more effectively addressed through the application of other policy tools. Starter homes now form part of the definition of affordable housing but do not remain as affordable homes in perpetuity and as such will one day form part of the Borough's supply of market dwellings. Given the restrictions placed on starter homes in terms of price paid, size and type this will increase the supply of smaller stock within the Borough. Density requirements may also be effective in securing a higher proportion of smaller dwellings.