Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14925

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? No

Sound? No

Duty to co-operate? No

Para. 227-228
Housing Market Area, DtC:
- Council should identify cross-boundary matters to be addressed and the progress of co-operation in addressing these matters in Statements of Common Ground, to comply with NPPF Para.’s 24-27.
- SoCGs should be publicly available to provide transparency.
- HBF notes no SOCGs accompany the Draft Submission Plan consultation, contrary to PPG. Therefore impossible to assess if Council has satisfied legal requirements of DtC.
- GBBCHMA Position Statement (July 2020) is not a SoCG.
- It is misleading for GBBCHMA Position Statement to conclude that residual HMA shortfall is only 2,597 dwellings. This compares figures against the Strategic Growth Study (Table 5) rather than adopted housing requirements and unmet needs (Table 2).
- Figures do not account for Black Country shortfall
- Figures are not based on standard methodology
- Housing requirement should be 12,598 dpa under revised standard methodology not 10,399 dpa as in Table 5.
- Estimated housing land supply includes allowances from proposed allocation in draft Plan, as yet untested at Examination, plus other sources from non-allocations.
- Lack of agreement on how GBBCHMA housing needs will be met in full, four years after adoption of Birmingham Development Plan.

Object

Representation ID: 14926

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

LHN (Para. 220) & Housing Requirement (Para. 228):
- PPG clearly state standard methodology is the minimum starting point for determining housing need, it does not produce a housing requirement figure.
- The Council has decided to plan for 22,998 jobs growth by 2036 based on Baseline jobs forecast plus UK Central Hub Scenario.
- Other evidence published by the Council (Midlands HS2 Growth Strategy & UKC Hub Growth and Infrastructure Plans quoted in the Viability Study) identifies potential for much higher job numbers. Council should confirm there are no inconsistencies in the evidence, and HEDNA is not under-estimating the additional jobs growth from the UKC Hub.
- HBF query assumptions on commuting patterns for the Borough and UK Central Hub jobs, given Para. 26 of HEDNA also states that commuting ratios are known to have likely changed.
- The derivation of the 2,105 contribution to HMA shortfall is not defined, and not included in a SoCG. Seems to be just difference between LHN and Housing Land Supply.
- Affordable housing need figures for Solihull are significant, PPG states an increase in total housing figures may be considered to help deliver affordable housing.
- Govt has confirmed its intention to review standard methodology, proposed revision would increase LHN to 1,011 dpa.
- Govt committed to ensuring more homes are built, and supports Councils planning for growth. HEDNA has demonstrated that circumstances exist to justify a housing need higher than the standard methodology. PPG does not set any limitations on a higher figure.
- HBF believe Council should be more ambitious and significantly boost housing supply (NPPF Para. 59)
- Housing requirement in Policy P5 not set out as a minimum figure.

Object

Representation ID: 14927

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Land Supply (and Spatial Strategy):
- Limited information available to assess the robustness of the Council’s overall HLS.
- Council should set out in details its assessment of the capacity of SHLAA, Brownfield Register, Town centre and UK Central Hub Area sites.
- Deliverability of these locations will be dependent on viability of PDL and demand for high density urban living post Covid-19.
- HBF not wish to comment on individual sites, but notes the Council has provided no data on a site by site analysis of the deliverability of individual site allocations; critical the Council’s housing trajectory is correct and realistic based on lapse rates, lead in times and delivery rates, supported by site promoters.
- Lack of contingency in Council’s housing supply, as land supply and requirement are same figure, with only 10% lapse rate.
- HBF advocates as large a contingency as possible, and housing requirement should be treated as a minimum rather than a maximum, to provide optimum flexibility, changing circumstances and flexibility to provide greater choice and competition.
- Overall land supply should include a wide mix of sites, short and long-term supply, strategic and non-strategic allocations; housebuilding companies require widest possible range of products and diversified portfolio of housing sites for range of household types.
- None of proposed allocations are less than 1ha, which is inconsistent with 10% requirement in NPPF.
- Notes the housing delivery phases for sites
- Notes that housing trajectory is stepped
- Surplus in 5YLS is only 329 dwellings, can be easily eroded by changes in circumstances. If Council cannot demonstrate 5YLS on adoption of Local Plan it shall be found unsound.

Object

Representation ID: 14928

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Deliverability & Viability Study:
- HBF have concerns about Council’s standard inputs including (but not exhaustively):
o Using BCIS lower quartile costs. All new build housing is built to a high specification therefore median should be used.
o Blended developer return of 17% may not reflect the risk profile of development
o HBF recommend finance cost of 6.5-7%, not 6%
o Professional fees should be 8-10% for simple sites, and up to 20% for complex sites.
o Sales and marketing costs should be 3-5%
o Concern that not an accurate assessment of cumulative impact of compliance with all policy requirements, including at least:
 Policy P4D,
 Policy P4E (M4(2) & M4(3) compliant homes
 Policy P5 for NDSS
 Policy P9 for FHS and EVCPs
 Policy P10 (net biodiversity gain)
 Policy P11 (water efficiency standard)
- HBF notes that following typologies are unviable:
o North Solihull greenfield and PDL
o Mature Suburbs PDL
o Windfall sites in low value areas (North Solihull)
o Retirement developments

Object

Representation ID: 14929

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4A (Bullet Point 6):
The 2019 NPPF promotes affordable home ownership by requiring at least 10% of new dwellings built to be available for this tenure leaving only the remainder for other affordable housing tenures (para 64). The Council’s policy approach to affordable housing tenure set out in Bullet Point 6 is inconsistent with national policy. Furthermore, the Government’s consultation on Changes to the Current Planning System (ended on 1st October 2020) proposed further changes to deliver First Homes.

Support

Representation ID: 14930

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Policy P4A (Bullet Point 7):
The Council’s policy approach on social rented mix is inflexible and overly prescriptive. The HEDNA 2020 set out a range of housing mixes.

Object

Representation ID: 14931

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4C (Bullet Point 8):
Council’s policy approach on shared ownership mix is inflexible and overly prescriptive. HEDNA provides a range of figures.
Inconsistent with national policy.

Object

Representation ID: 14932

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4D (Bullet Point 1):
- HBF supportive of policies to encourage self & custom build.
- Not supportive of policy requirements for 5% SCB on developments of 100+ dwellings.
- Council should not seek to burden developers with responsibility for delivery of SCB – contrary to national guidance.
- Council role should be to engage with landowners and encourage them to consider SCB, and not go beyond that.
- No rational for 100 dwelling threshold, or 5% provision.
- Could result in mis-match of provision, and oversupply of plots on larger housing sites in urban locations against demand for single plots in rural areas.
- Provision of self & custom build serviced plots must be justified by credible and robust evidence.
- Self build register may indicate a level of expression of interest in SCB but it cannot be reliably translated into actual demand, should such plots be made available.
- Council policy approach should be realistic and deliverable, and not remain unsold.
- Vacant plots could affect Council’s HLS.
- SCB serviced plots on larger developments adds complexity and slows delivery and difficult to coordinate different construction logistics.
- Where plots are unsold, policy should be clear these revert to the original developer. Reversion timescale should be as short as possible, 12 months is too long.
- Disagree with the Viability evidence on self-build plots, does not take into account all the cost.
- Policy will cause delay to processing planning applications and slow housing delivery.
- No robust evidence for demand for plots on larger housing sites.

Support

Representation ID: 14933

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Policy P4C (Bullet Point 3):
- The Council’s policy approach is inflexible and overly prescriptive.
- All households should have access to different types of dwellings to meet their housing needs. Market signals are important in determining the size and type of homes needed.
- Policy inconsistent with national policy (NPPF Para. 31, 61 and 62)
- The Council’s policy approach should acknowledge that not all sites will be able to meet an overly prescribed housing mix requirement because of site size, proposed development typology, site specific circumstances and viability.

Object

Representation ID: 14934

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4E - Bullet Point 2 - M4(2):
- Optional standards for accessible & adaptable dwellings should be done in accordance with NF (Para. 127 (f) & FN 46), and latest PPG critieria for evidence. Council has provided no evidence on accessibility & adaptability of existing housing stock.
- HBF acknowledge Solihull’s population will ‘age’, but this issue not specific to Borough. And not all health issues require adaptations to homes. If Govt had intended that ageing population was sufficient justification then standards would have been made mandatory in Building Regulations.
- Recent research by Savills ‘Delivering New Homes Resiliently’ (Oct 2020) shows only 7% of over-60s inclined to buy a new home. Adapting existing stock likely to form part of solution as much larger proportion of overall stock.
- M4(1) Building Reg standards already an improvement on older housing stock, so likely to be suitable for most residents.
- Absence of robust evidence, policy approach is inflexible and fails to take account of site-specific circumstances and viability, therefore impeding effectiveness.