Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14649

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Sustainability Appraisal:
The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year, and has therefore not been informed by the SA in accordance with the Framework.

Option 2 (15,000 dwellings) is the Plan’s preferred approach in light of the SA, and yet higher levels of growth perform equally as well. The only tangible difference between Option 3 (16,000 dwellings) and Option 2 is that Option 3 has a negative effect in relation to resource efficiency (resulting from greater generation of waste) whereas Option 2 is regarded as neutral
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options. Only considering two spatial options for this higher level of growth clearly has the potential to skew the conclusions of the SA.

It is acknowledged that the SA has to be manageable, and cannot consider endless alternatives and permutations. However, given the importance of testing higher levels of housing growth in light of the scale of unmet need arising from the neighbouring authority, the SA should have undertaken a finer grain analysis of options at levels of growth above 16,000 dwellings utilising its own evidence base of available and suitable sites.

The SA does therefore not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement

In relation to the specific assessment of Site 417 (AECOM59a West of Stratford Road, Hockley Heath), there are a number of effects identified that can easily be mitigated and avoided. The SA has indicated a number of significant negative effects for some of the proposed allocations (not least UK Central), but that on-site mitigation has been taken into consideration in the selection of the allocations.

Object

Representation ID: 14650

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan should contain strategic policies which set out the overall strategy for development, and therefore the Plan is not sound on this basis.
The absence of a clear Spatial Strategy and indeed settlement hierarchy therefore makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.
Furthermore, within the evidence base, the Site Selection Topic Paper includes an entirely new set of hierarchy criteria, which has been used to inform the site selection.

Object

Representation ID: 14652

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hockley Heath certainly contains a range of facilities for everyday needs, and includes a primary school. The one key service lacking in the village is a doctors surgery as noted in the Plan8 . However, there are no proposals within the Plan to address the lack of this facility which is a missed opportunity to create a more sustainable pattern of development. In fact, in proposing an allocation of only 90 dwellings and nothing else, the existing problem is only compounded by increasing the population in the settlement.
Based on the Spatial Strategy as drafted, a proportionate addition is supported by the Plan. Again, proportionate is not defined within the Plan. Hockley Heath has a population in excess of 2,000 with circa 800 households, and yet only one allocation is proposed for 90 dwellings and overall only 141 dwellings are expected to be delivered in the Plan period9 . An increase in the size of the settlement by circa 15% is a relatively small proportionate increase, and it is noted that the proposed increase in the size of Hockley Heath is significantly less than other settlements of similar size (such as Cheswick Green which is proposed to accommodate 1,000 dwellings).
The Spatial Strategy would therefore appear to support a much higher level of growth in Hockley Heath than has been allocated in the sites selected.
It is considered therefore that selecting one site of 90 dwellings in Hockley Heath does not reflect the Spatial Strategy, unnecessarily constrains growth in a sustainable location, and misses an opportunity to enhance the sustainability of the settlement through the delivery of key services in the form of land for a doctors surgery and new two form entry primary school on Site 417.

Object

Representation ID: 14653

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy P17 makes no reference to safeguarding land within the Green Belt. There is no reference to any consideration being given to safeguarding land.
It is considered necessary for the Plan to safeguard land in order to meet longer-term development needs. Exceptional circumstances exist in that:
a. the local authority is significantly constrained by Green Belt with opportunities outside it very limited;
b. unmet needs within the Housing Market Area already exist (see representations under the housing requirement and the Council propose to deal with them through the next review of the Plan); and,
c. there are no neighbouring Councils who have expressed a willingness to take any unmet needs arising from Solihull thereby meaning the next review of the Plan will need to release land from the Green Belt.
This Plan should therefore be safeguarding land in order to ensure there is a degree of permanence to the boundaries proposed within this Plan.

Object

Representation ID: 14654

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement is not sound as it is not positively prepared, justified, effective or consistent with national policy for the following reasons.
LHN: The minimum Local Housing Need (LHN) has been calculated using the standard method which is well established and is not disputed. However, the Council will need to be mindful of any changes arising from the Government’s stated intention to change the method for calculating LHN prior to submission of the Plan.

Plan Period: It is highly unlikely that the Local Plan will be adopted in 2021, thereby providing a plan period of 15 years post adoption as recommended by the Framework. On the basis that it is already December 2020 and the Plan has not been submitted, it is more likely to be adopted in 2022, and therefore the housing requirement and the Plan should be extended to 2037.

Object

Representation ID: 14656

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Employment uplift: LHN is afforded an employment uplift of nine dwellings per annum to take account of the substantial job growth at UK Central of around 13,000 net additional jobs. This is a figure which could increase as plans crystallise, and it is noted that the Council’s Viability Study (2020) predicts up to 77,500 jobs by 2040. The Plan also justifies the small uplift from LHN on the assumption that only 25% of the jobs will be filled by people residing in Solihull, with the remainder in commuting from neighbouring areas. Taking this approach will ‘bake-in’ inward commuting reflecting an historic pattern of movement rather than shaping growth to be more sustainable by locating homes close to where work is

Object

Representation ID: 14659

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Affordability uplift: The housing requirement should also be increased to take account of affordability within the Borough, consistent with national guidance. The identified affordable housing need is 578 homes per annum (HEDNA para 35). However, the Council has reached the conclusion that the maximum amount that can be viably sought is 40% on any given scheme. This top line is substantially less than the evidence suggests, and in reality, 322 per annum is unlikely given the sources of supply, despite the Housing Topic paper (Paragraph 73) noting other methods for maximising affordable housing provision. The Housing Topic paper notes at footnote 10 that this reduced to 224dpa if households already in accommodation are excluded, however the HEDNA is clear that the figure is theoretical and should not be seen to minimise the acute housing need in the borough.

Allocated Sites: The absence of any evidence in relation to housing trajectories for the proposed allocated sites means that the figure of 5,270 homes to be delivered by 2036 is not justified.

Windfalls: The estimated level of windfalls at 2,800 homes completed over 14 years is not justified. Firstly, whilst it is stated that windfalls are not included for the first 3 years (to avoid double counting with extant planning permissions) only 2 years have been discounted. Secondly, the annual average level of windfall is substantial for an authority significantly constrained by Green Belt. Reliance is placed on historic trends, but there is no certainty that past sources of supply are likely to continue. The evidence should be so compelling that it is a source of supply that can be relied upon for delivering the housing requirement.
Five Year Supply on adoption: The Plan will not provide for a five year housing land supply upon adoption. The Plan assumes that 1,170 homes will be delivered on allocated sites within the first five years but there is no evidence to support this

Object

Representation ID: 14660

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Unmet needs: The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. Paragraph 227 of the Plan advises that Birmingham has unmet needs (37,900 homes), and paragraph 228 advises that the Plan is proposing a contribution of 2,105 homes towards unmet needs. However, there is no evidence that this level of contribution is agreed with Birmingham or other neighbouring authorities, or that the unmet needs that remain are to be addressed elsewhere. There is no evidence as to why the contribution is only 2,105 homes.
In addition to Birmingham’s needs, it is also noted the Black County Authorities estimate unmet housing needs of 29,260 homes and up to 570ha of employment land to 2038, and have written to the Council notifying them. The Council has suggested their unmet needs can be dealt with as part of the next review of the Local Plan. However, that is not evidence of effective joint working, but rather deferring its consideration which is evidence of an unsound Plan in being contrary to paragraph 35 c) of the Framework.