Solihull Local Plan (Draft Submission) 2020

Support

Representation ID: 14014

Received: 14/12/2020

Respondent: West Midlands HARP Consortium

Policy P4A - Definition of affordable housing should be changed to that in NPPF. This should be replaced with a sentence which refers readers to the definition set out within the NPPF, and perhaps in this region, the local definition set by the West Midlands Combined Authority.

Pleased to see that a Housing and Economic Development Needs Assessment (HEDNA) and that the HEDNA (2020) does not include the private rented sector in its calculation of affordable housing need even with Local Housing Allowance.

Pleased to see that the Council sets an ambitious threshold of 40% affordable housing on site from qualifying residential developments. This will assist in the Council delivering as much affordable housing as viability allows in order to meet the HEDNA (2020) identified need of 578 affordable homes per annum over the plan period.

Welcomes the inclusion of paragraph 177 which shows support for entry-level exception sites; a policy approach which was introduced by the NPPF revision

Support

Representation ID: 14015

Received: 14/12/2020

Respondent: West Midlands HARP Consortium

Policy P4B - Suggest that text should be added to Policy P4(B) or to the supporting text accompanying the policy which allows for the delivery of affordable housing through cross-subsidy where it can be demonstrated that affordable housing development cannot be achieved without an element of open market housing.

Support

Representation ID: 14016

Received: 14/12/2020

Respondent: West Midlands HARP Consortium

Policy P4E – The policy states that all new build housing on major development sites must be built to Category M4(2). It is not clear if the viability study (October 2020) has assessed the impacts of these standards alongside all of the other policy requirements of the Draft Local Plan against affordable thresholds higher than 40%. It is quite common for housing associations to deliver up to 100% of housing on site as affordable and therefore this requirement should be subject to viability. Without these viability studies for these kinds of developments, implementing such technical standards is likely to threaten future delivery of affordable housing on schemes with developers having to negotiate its reduction to achieve viability on schemes.

Object

Representation ID: 14017

Received: 14/12/2020

Respondent: West Midlands HARP Consortium

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P5 - Policy P5 requires all new residential development to adhere to Nationally Described Space Standards (NDSS). The blanket application of the NDSS across all residential development, including affordable tenures, will undermine the viability of many 100% affordable development schemes. Many eligible households in Solihull may not desire, or require housing that meets the NDSS, as it may result in for example, higher rental and heating costs. A blanket application of NDSS should also be demonstrated to be viable across various development scenarios through robust viability testing.