Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14935

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Policy P4E - Bullet Point 3 - M4(3):
- 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.
- Para. 209:
M3(2a) distinction not included in Policy, only in supporting text.

Object

Representation ID: 14936

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 points 4 & 5:
- HBF recognise that all households should have access to different housing types to meet their housing needs.
- Council should not prescribe housing mix on individual sites above a specified site threshold, should ensure suitable sites available for a wide range of developments across a wide choice of appropriate locations.

Object

Representation ID: 14937

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Nationally Described Space Standards (NDSS):
- Council should provide a local assessment evidencing case for Nationally Described Space Standards to accord with NPPF Para. 31, Para 127(f) & FN 46, and PPG.
- No such evidence supplied.
- Must be based on need not ‘nice to have’ basis, otherwise Government would have made mandatory in Building Regulations.
- Council should recognise customers have different budgets and aspirations; could lead to customers purchasing larger homes in floorspace, but less bedrooms to meet need. Could lead to overcrowding and reducing quality of living environment.
- Inflexible approach will impact on affordability and affect affordable home ownership products such as First Homes.
- Viability Assessment only test one average house type size, not all 16 NDSS compliant house typologies. Not robust approach.
- No assessment on impact on affordability. Council should assess potential adverse impacts on affordable home ownership products such as First Homes.
- Knock on effect to slow or reduce delivery rates.
- If NDSS carried forward, Council should put forward transitional arrangements.

Object

Representation ID: 14938

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P9 (Bullet point 3 (i, ii & iv):
- Commendable that Council seeks to achieve a reduction in energy demand and deliver renewable and low carbon energy.
- Important Council’s proposed policy approach does not conflict with or go beyond Govt’s proposals for Building Regulations.
- HBF and its Members favour a stepped and incremental approach to achieve Govt’s FHS ambitions, because of need for supply chain, infrastructure investment and skills training.
- Consensus of HBF members is to implement Option 1 (-20%) first, with Option 2 (-31%) implemented 2-3 years later.

Object

Representation ID: 14939

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Council should be aware that some decentralised energy supply consumers do not have comparable levels of satisfaction as consumers on gas and electricity networks, and pay a higher price.
- Currently no sector specific protections for such consumers, unlike gas, electric, water utilities.
- Customers lack same opportunities to switch supplier.
- Consumers should have ready access to information on heat network details.
- Monopolistic nature of heat networks
- Require future price regulations to protect domestic consumers.
- Competition & Markets Authority found a significant proportion of suppliers and managing agents provide none or limited information on pre-transaction documents, ongoing costs, with poor transparency. CMA have concluded a statutory regulatory framework should be set up that underpins regulation of all heat networks.

Object

Representation ID: 14940

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P9 Bullet Point 3 (viii):
- HBF recognise that electric vehicles will be part of solution to transitioning to a low carbon future.
- Given Govt’s proposals for Part S of Building Regs, this requirement is unnecessary and should be deleted.
- If retained, HBF consider physical installation of fixed EVCPs is unnecessary; automotive technology is evolving quickly, therefore cable and duct approach is a more sensible & future-proofed solution. Negates potential installation of obsolete technology.
- HBF and Members have serious concerns about capacity of existing electrical network in UK.
- Major network reinforcement will be required across power network to facilitate introduction of EVCPs and the move from gas to electric heating as proposed under FHS.
- Costs can be substantial and drastically affect viability of developments.
- If developers are funding potential future reinforcement of National Grid network, this will come at significant cost and jeopardise future housing delivery.
- Viability assessment does not include costs for upgrading network, just installation. Capped figure of £3,600 should be included in viability assessment.

Object

Representation ID: 14941

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P10 Bullet Points 8 & 9:
- HBF opine that Council should not deviate from Govt’s biodiversity net gain proposals as set out in Environment Bill of a 10% national mandatory requirement.
- Council should not specify above 10%.

Object

Representation ID: 14942

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P10 Bullet Point 12:
- Approach is inconsistent with Environment Bill.
- Govt will make provision for statutory biodiversity units in the Environment Bill, purchasable at a standard cost.
- This approach will allow Councils, landowners and organisations to set up local habitat compensation schemes, where they wish to do so; if this is not the case, the Govt will provide a last-resort supply of biodiversity units, which will prevent delays to development.
- Viability assessment should fully account for additional costs associated with biodiversity gain, HBF view that Council’s viability evidence significantly underestimates costs.
- Govt has said more work needs to be done to address viability concerns of net gain by the housebuilding industry.
- DEFRA Biodiversity Net Gain and Local Nature Recovery Strategies Impact Assessment (Table 14) sets out costs of £18,527 - £63,725 per hectare of development for the West Midlands region (based on 2017 prices).
- Environment Bill makes provision for a 2 year transition period, and will work with stakeholders on guidance, what will be required and when.

Object

Representation ID: 14943

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P11 (Bullet Point 3):
- Insufficient evidence to justify adoption of optional standard of 110L pppd. Should follow PPG guidance.
- Council’s 2017 Water Cycle Study demonstrates that proposed development can be delivered without significant water and sewerage improvements. Study recommends adoption of optional water efficiency standard because Solihull is identified as an area of moderate water stress.
- Viability assessment explicitly excludes cost of water efficiency standard. Cost may be minimal but it should be included as part of cumulative impact of compliance with all policy requirements.

Object

Representation ID: 14944

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P14A (Bullet Point 4):
- Council should not impose new electronic communications requirements beyond provision of infrastructure as set out in statutory Building Regulations.
- March 2020 Budget confirmed future legislation will ensure new build homes are built with gigabit-capable broadband, amending Part R of Building Regs.
- DCMS has outlined its intentions on the practical workings of this policy, which will apply to all new builds.