Draft Local Plan - Supplementary Consultation

We agree with the adoption of the Governments Standard Methodology for assessing the Borough's housing need and the use of the 2014 based household projections.

Where we disagree is the contribution that the Plan is currently seeking to make towards the wider Housing Market Area which is clearly insufficient. We note that this issue is not part of the current supplementary consultation but consider this is a missed opportunity and the Council should be more realistic in the contribution it needs to make. At present the plan is offering to provide for 2,000 additional homes towards addressing the HMA shortfall (approximately 5% of the market area deficit). This is simply not enough. There are very close links between Solihull and Birmingham given the Borough's proximity to the city and extensive shared boundary, established travel-to-work patterns and complementary nature of housing and employment provision. It is widely accepted that the edge of the conurbation offers the most obvious and sustainable option to meet Birmingham's shortfall. By only proposing to accommodate 2,000 homes, SMBC is falling way short of its responsibilities in addressing housing requirements across the HMA.

We object to the site selection methodology in that it has not allowed for sufficient growth for Meriden, a sustainable location which is well located for the HS2 Interchange Station and should have been allocated a higher growth priority than it is currently in the draft plan.

We also maintain a fundamental concern over the Site Selection Methodology because Step 1 of the process is reliant on a flawed Green Belt Assessment report.

We disagree with the infrastructure requirements identified for Meriden and consider they should include provision for an expansion of the Primary School which is understood to be at capacity. This could be facilitated with the release of land north of Meriden between the existing settlement (and school) and the A45, including Site 81.

We submit that Site 81, Land North of Fillongley Road, Meriden, should not be omitted and should be included in the Submission Draft Local Plan.

This site immediately adjoins Meriden to the east and offers a highly sustainable option to bring forward additional housing growth as outlined in the Proposal Site Supporting Statement submitted with this response.

The site could be brought forward either on its own or as part of a larger sustainable northern expansion of the village between the existing settlement and the A45. Such a wider proposal could also facilitate an expansion to the primary school, as land to the rear of the school is also being promoted for development (Site ref 144).

The evidence base documents prepared to inform the Local Plan Review (including the Sustainability Appraisal, Accessibility Mapping Report, SHELAA, Green Belt Assessment, Landscape Character Assessment and Topic Papers) demonstrated that Meriden provides a sustainable development location. The village offers a number of community facilities, can be easily accessed by public transport and, given the village's location off the A45, is within good proximity to major employment centres. It is also very close the HS2 Interchange Station. New development at the edge of the village would have no higher landscape impacts and effects on the function of the Green Belt than other village locations. It is therefore inadequate for the Draft Local Plan Review to only include one housing allocation (Site10) for Meriden. This site was originally for 50 dwellings although is now suggested for 100 dwellings. This is still insufficient and we consider that the village provides far greater scope to accommodate housing needs. It is not clear from the Draft Local Plan Review evidence base or this latest Supplementary Consultation why the decision has been taken to only focus a very modest amount of development at Meriden. For example, a much larger allocation has been identified in the Draft Local Plan Review in Hampton-in-Arden, a similar sized settlement to Meriden with a similar level of accessibility and service provision. We note from the Meriden Housing Needs Survey dated August 2018 that the demand for local housing itself is 45 units. This is before any allowance is given for district or market area needs. Overall, it is clear to us that Meriden should have a far higher housing allocation than 100 units.

As set out in the Supporting Statement, Site 81 is well contained and would have a very moderate impact on the Green Belt. It is well located within easy walking distance of the centre of the village and the primary school. It is highlighted as a highly accessible site in the Council's Accessibility Mapping Report. It would have very limited ecological or landscape impact. The main constraint noted in the SHELAA is the lack of road access, but this can be overcome as the promoter controls a property fronting Fillongley Road where suitable access can be provided. This is set out further in the Supporting Statement. There are no other technical constraints to the development of this site.

Accordingly, it is requested that the Local Plan Review should include Site 81 as an additional allocation, either on its own or in combination with other sites between the settlement and the A45.

No. Such an approach is highly complex and open to abuse.

We disagree that the existing approach of a percentage calculated on unit numbers leads to an incentive on developers to increase the size of units and reduce numbers. Developers ultimately seek to build houses and will bring forward schemes that reflect market demand and what they can sell in terms of size and mix of new homes. Oversizing of units is not in a developer's interest. The existing Meeting Housing Needs SPD for affordable housing requires the private and affordable to be similar in size and this is a more straightforward way of securing more smaller units and higher densities.

An affordable housing target calculated based on floorspace has been tried by Stratford-upon-Avon Council for example, but was dropped in favour of the more straightforward and equally effective approach based on unit numbers and separate policy on unit type and mix.

It is also important to bear in mind that a high density development will not be the best option for every housing development in every location across the District. Other considerations need to be taken into account such as the need to respect local character. There clearly needs to be a balanced approach to ensure that the right size and mix of both affordable and market housing is provided across the district without overriding other policy priorities.

Do not agree with the approach.

Do not agree with the approach.

A strong policy on housing type and mix which is enforced at planning application stage.