Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15027

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Windfall allowance:
- Constitutes 18% of the Emerging Plan’s housing supply
- Windfall sites are a finite resource and
the high delivery of windfall developments in recent years will have diminished the supply of sites.
- Particularly relevant in Solihull Borough given its Green Belt constraints
- Council keeps separate brownfield land register
- Given NPPF’s restrictions, no windfall contributions can come from Green Belt land
- Uncertain whether the past rates of windfall delivery can be sustained up to 2036
- Windfall allowance is based purely on historic trends, not SHELAA delivery trajectory, and this approach is inconsistent with NPPF para. 70
- DSP assumes annual windfall development rates will be required in full during the period 2022-2036 in order to meet minimum housing requirement, given the lack
of flexibility in the housing supply.

Object

Representation ID: 15028

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Build out rates/trajectory:
- Lichfields' 'Start to Finish' assessment concludes that sites of more than 500 dwellings take on average 5 to 8.3 years from the date that an outline application is registered.
- Given that unlikely Plan will be adopted before Spring 2022, and factoring another 12 months to submit an application, sites of 500+ dwellings in Plan may not start delivery until 2031.
- Lichfields' assess that build out rates are:
• 500-999 dwellings – ca 150 dpa;
• 1,000-1,499 dwellings – ca 175dpa;
• 1,500-1,999 – ca 210dpa;
• 2,000+ dwellings – ca 290dpa.
Therefore even with most ambitious build out rates, some sites will not be completed by end of plan period.

Object

Representation ID: 15029

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Local Housing Need and Standard Methodology:
- Correct to use SM to calculate housing requirement in accordance with NPPF Para. 60.
- Govt published revised standard method figures for consultation in August 2020. Projects a 25% increase in Solihull’s housing need up from 804 to 1,011 dpa, or 12,901 to 16,176 over plan period. Strong likelihood this will be adopted. Therefore DSP unlikely to meet housing need over plan period.
- Would need to review in less than 5 years, further Green Belt would need to be released as Borough 67% GB with little brownfield land available.
- NPPF Para. 146 – GB boundaries should endure beyond plan period. Review so soon would be inconsistent with NPPF, and unsound.
- DSP should release more land, or at very least identify safeguarded land.

Object

Representation ID: 15030

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Birmingham City unmet housing need:
- Birmingham Development Plan has shortfall of 37,900 dwellings, and 20,440 shortfall against current SM.
- Para. 227 of DSP acknowledges Birmingham HMA shortfall and contribution of 2,105 dwellings.
- Not considered proportionate given functional relationship between Birmingham and Solihull Metropolitan Borough Council: shared boundary, good public transport and road connectivity.
- 2011 Census data demonstrates 887 net people migrated from Birmingham to Solihull between 2001 and 2011, 28% of Birmingham’s net migration.
- DSP should seek to accommodate 28% of HMA’s unmet need, not just 2,105.
- Disproportionate accommodation of unmet needs is contrary to NPPF Para. 35(a)
- Solihull clearly most sustainably located authority in the HMA
- Contrary to NPPF Para. 60 and 136.