Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15061

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

GBBCHMA Unmet Housing Need:
o Barton Willmore analysis of unmet need in wider GBCCHMA suggests that 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031; Birmingham’s deficit alone is between 11,924 – 13,101 dwellings up to 2031.
o Furthermore, if using the current standard methodology, then significant unmet need from Birmingham City and Black Country between 25,543 and 27,350 dwellings up to 2031.
o If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031.
- This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect in January 2022.
o Taking into consideration the proposed changes to Standard Method (consulted on by Government in summer 2020), this would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
o Unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.

Change suggested by respondent:

• Review of demand and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15062

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’.
Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.

Change suggested by respondent:

Consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
Therefore: Amend supply and spatial strategy in Plan.

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15063

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
Consider automatic allocation of 2013 Solihull Local Plan sites, which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach.
Sites not come forward despite Council lacking a 5YLS, points to deliverability issues with sites.

Change suggested by respondent:

Existing 2013 Local Plan site allocations should be tested for deliverability prior to re-allocation

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15064

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply.
We consider that any sites to be delivered in this way should be considered as windfall developments.

Change suggested by respondent:

Amend supply and spatial strategy in Plan. Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15065

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.

Change suggested by respondent:

Amend supply and spatial strategy in Plan. Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15066

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
- Consider scale and delivery rates of UK Central hub proposals are unrealistic, and neither details on trajectory and delivery timescales, nor commitments from delivery partners, have not been included in consultation documentation.
- Based on LPR adoption date of 2022, we consider first likely completions to be ca. 2030. This is based on Lichfields’ Report (‘Start to Finish’, Feb 2020) analysis that concludes the average time from outline planning app to first completion is 8.4 years.
- Given information within the August 2020 consultation {Arden Cross?}, we consider a 160dpa build out rate between 2030-2036 is reasonable, to delivery 960 dwellings. Type of supply should also be considered, as geared towards apartments. Amount of infrastructure required also needs consideration.

Change suggested by respondent:

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15067

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Note that the 10% lapse rate applied does not take into account windfall, the UK Central Hub
Area or allocated sites. We consider that a 10% lapse rate is suitable, but that it should be applied
to future development as well.

Change suggested by respondent:

10% lapse rate should be applied to future development as well.

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

Object

Solihull Local Plan (Draft Submission) 2020

Policy P5 – Provision of Land for Housing

Representation ID: 15068

Received: 14/12/2020

Respondent: IM Land - Land at Jacobean Lane, Knowle

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vulnerability of housing supply:
Trajectory:
- SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase.
- We refer you to Guildford Local Plan Inspector’s report, which concludes the Liverpool method does not meet the Government’s objective to boost housing supply in the shorter term.
- Consider Solihull should follow same approach as Guildford and allocate more sites.
- As with withdrawn Uttlesford Local Plan, a stepped trajectory may create a fragile 5 year land supply.
- Stepped trajectory may worsen the affordability problem as it delays delivery.

Change suggested by respondent:

Amend housing supply and strategy Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible

Full text:

See attachments. LAND AT JACOBEAN LANE, KNOWLE

Attachments:

Appendix 1 (412.77 KB)
Appendix 2 (2.00 MB)
Appendix 4 (2.14 MB)
Appendix 7 (229.18 KB)
Appendix 8 (3.72 MB)
Representation Form (334.19 KB)
Appendix 3 - Vision Statement_Redacted (5.13 MB)
Appendix 5 (655.25 KB)
Appendix 6 (10.52 MB)

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