Draft Local Plan - Supplementary Consultation

Dear Sir / Madam

Thank you for consulting Lichfield District Council on the Local Plan Review. The comments below focus on the primary areas of concern Lichfield District Council have. It remains the case that Lichfield District Council would welcome Duty to Cooperate meetings to address such matters prior to the regulation 19 publication version of the Solihull Local Plan.

* There remains concern that Solihull is not committed to fully addressing the Greater Birmingham Housing Market Area (GBHMA) shortfall. The supplementary consultation does not seek to provide justification as to how Solihull has arrived at providing an additional 2000 dwellings in addition to its OAN as a ceiling towards the shortfall, and does not have regard to the housing requirement options set out in the further strategic growth study.
* That whilst the recognition of the potential need to revise the housing requirement figure in the regulation 19 publication version is welcome, the concern regarding failure to meet the commitments associated with cross boundary cooperation remains as it is indicated that Solihull will only be updating their position in the version that is published. Without cooperation with authorities in the Housing Market Area, it remains the case that any finalised figure has not had appropriate assessment.
* That the land supply of 726 more than the OAN plus the 2000 identified to meet the shortfall in Birmingham is noted, but that it is not known if the provision provides a sufficient buffer to meet the need because, the requirement has not been justified.
* The refinements regarding methodology and approach to site selection appear to be soundly based on a sustainable approach to allocating sites based on their previously developed / greenfield status, accessibility to services and impacts for the Green Belt in line with the NPPF approach. However, the flaw remains that the identification of the additional 2000 to meet the shortfall has not been justified for the reasons previously set out. Accordingly, further sites may need to be identified and released.
* That the Local Plan should look to identify requirement and provision to 2036 which is the end date for the Strategic Growth Study and not to 2035. This ensures consistency in meeting provision across the HMA authorities.
* That the sustainability appraisal has not been updated to take account of the changes proposed in the supplementary consultation to the Draft Local Plan. Lichfield DC is also concerned that without agreement through duty to cooperate in respect of how the Greater Birmingham Housing Market Area shortfall requirement is apportioned in the most appropriate way, the SA assessment will not have properly considered suitable alternatives and established the most sustainable strategy.

Dear Sir / Madam

Thank you for consulting Lichfield District Council on the Local Plan Review. The comments below focus on the primary areas of concern Lichfield District Council have. It remains the case that Lichfield District Council would welcome Duty to Cooperate meetings to address such matters prior to the regulation 19 publication version of the Solihull Local Plan.

* There remains concern that Solihull is not committed to fully addressing the Greater Birmingham Housing Market Area (GBHMA) shortfall. The supplementary consultation does not seek to provide justification as to how Solihull has arrived at providing an additional 2000 dwellings in addition to its OAN as a ceiling towards the shortfall, and does not have regard to the housing requirement options set out in the further strategic growth study.
* That whilst the recognition of the potential need to revise the housing requirement figure in the regulation 19 publication version is welcome, the concern regarding failure to meet the commitments associated with cross boundary cooperation remains as it is indicated that Solihull will only be updating their position in the version that is published. Without cooperation with authorities in the Housing Market Area, it remains the case that any finalised figure has not had appropriate assessment.
* That the land supply of 726 more than the OAN plus the 2000 identified to meet the shortfall in Birmingham is noted, but that it is not known if the provision provides a sufficient buffer to meet the need because, the requirement has not been justified.
* The refinements regarding methodology and approach to site selection appear to be soundly based on a sustainable approach to allocating sites based on their previously developed / greenfield status, accessibility to services and impacts for the Green Belt in line with the NPPF approach. However, the flaw remains that the identification of the additional 2000 to meet the shortfall has not been justified for the reasons previously set out. Accordingly, further sites may need to be identified and released.
* That the Local Plan should look to identify requirement and provision to 2036 which is the end date for the Strategic Growth Study and not to 2035. This ensures consistency in meeting provision across the HMA authorities.
* That the sustainability appraisal has not been updated to take account of the changes proposed in the supplementary consultation to the Draft Local Plan. Lichfield DC is also concerned that without agreement through duty to cooperate in respect of how the Greater Birmingham Housing Market Area shortfall requirement is apportioned in the most appropriate way, the SA assessment will not have properly considered suitable alternatives and established the most sustainable strategy.

Dear Sir / Madam

Thank you for consulting Lichfield District Council on the Local Plan Review. The comments below focus on the primary areas of concern Lichfield District Council have. It remains the case that Lichfield District Council would welcome Duty to Cooperate meetings to address such matters prior to the regulation 19 publication version of the Solihull Local Plan.

* There remains concern that Solihull is not committed to fully addressing the Greater Birmingham Housing Market Area (GBHMA) shortfall. The supplementary consultation does not seek to provide justification as to how Solihull has arrived at providing an additional 2000 dwellings in addition to its OAN as a ceiling towards the shortfall, and does not have regard to the housing requirement options set out in the further strategic growth study.
* That whilst the recognition of the potential need to revise the housing requirement figure in the regulation 19 publication version is welcome, the concern regarding failure to meet the commitments associated with cross boundary cooperation remains as it is indicated that Solihull will only be updating their position in the version that is published. Without cooperation with authorities in the Housing Market Area, it remains the case that any finalised figure has not had appropriate assessment.
* That the land supply of 726 more than the OAN plus the 2000 identified to meet the shortfall in Birmingham is noted, but that it is not known if the provision provides a sufficient buffer to meet the need because, the requirement has not been justified.
* The refinements regarding methodology and approach to site selection appear to be soundly based on a sustainable approach to allocating sites based on their previously developed / greenfield status, accessibility to services and impacts for the Green Belt in line with the NPPF approach. However, the flaw remains that the identification of the additional 2000 to meet the shortfall has not been justified for the reasons previously set out. Accordingly, further sites may need to be identified and released.
* That the Local Plan should look to identify requirement and provision to 2036 which is the end date for the Strategic Growth Study and not to 2035. This ensures consistency in meeting provision across the HMA authorities.
* That the sustainability appraisal has not been updated to take account of the changes proposed in the supplementary consultation to the Draft Local Plan. Lichfield DC is also concerned that without agreement through duty to cooperate in respect of how the Greater Birmingham Housing Market Area shortfall requirement is apportioned in the most appropriate way, the SA assessment will not have properly considered suitable alternatives and established the most sustainable strategy.

Dear Sir / Madam

Thank you for consulting Lichfield District Council on the Local Plan Review. The comments below focus on the primary areas of concern Lichfield District Council have. It remains the case that Lichfield District Council would welcome Duty to Cooperate meetings to address such matters prior to the regulation 19 publication version of the Solihull Local Plan.

* There remains concern that Solihull is not committed to fully addressing the Greater Birmingham Housing Market Area (GBHMA) shortfall. The supplementary consultation does not seek to provide justification as to how Solihull has arrived at providing an additional 2000 dwellings in addition to its OAN as a ceiling towards the shortfall, and does not have regard to the housing requirement options set out in the further strategic growth study.
* That whilst the recognition of the potential need to revise the housing requirement figure in the regulation 19 publication version is welcome, the concern regarding failure to meet the commitments associated with cross boundary cooperation remains as it is indicated that Solihull will only be updating their position in the version that is published. Without cooperation with authorities in the Housing Market Area, it remains the case that any finalised figure has not had appropriate assessment.
* That the land supply of 726 more than the OAN plus the 2000 identified to meet the shortfall in Birmingham is noted, but that it is not known if the provision provides a sufficient buffer to meet the need because, the requirement has not been justified.
* The refinements regarding methodology and approach to site selection appear to be soundly based on a sustainable approach to allocating sites based on their previously developed / greenfield status, accessibility to services and impacts for the Green Belt in line with the NPPF approach. However, the flaw remains that the identification of the additional 2000 to meet the shortfall has not been justified for the reasons previously set out. Accordingly, further sites may need to be identified and released.
* That the Local Plan should look to identify requirement and provision to 2036 which is the end date for the Strategic Growth Study and not to 2035. This ensures consistency in meeting provision across the HMA authorities.
* That the sustainability appraisal has not been updated to take account of the changes proposed in the supplementary consultation to the Draft Local Plan. Lichfield DC is also concerned that without agreement through duty to cooperate in respect of how the Greater Birmingham Housing Market Area shortfall requirement is apportioned in the most appropriate way, the SA assessment will not have properly considered suitable alternatives and established the most sustainable strategy.