Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15031

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.
(See also Para. 18 of Introduction).

Object

Representation ID: 15032

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para. 21 – Council may wish to update this section to reflect NPPF Para. 30 which sets out that most recently adopted policies will take precedence, therefore LPR will take precedence over currently adopted Neighbourhood Plans.

Object

Representation ID: 15033

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Wording relating to meeting housing needs of HMA should be more positively worded to reflect NPPF Para. 59 ‘significantly boost housing supply’.
- Para. 50 should be reworded to state lower performing parcels of Green Belt could released to protect higher performing parcels whilst meeting needs.

Object

Representation ID: 15034

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Object to inflexible market housing mix prescribed within this policy.
- Individual sites should cater for a wide range of housing types and sizes.
- Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long-term sustainable communities, rather transient communities where people will not be able to form long-term neighbourhoods as homes cannot be adapted as their circumstances change.
- Council should focus on building strong healthy communities, not for short-term ownership.
- Do not consider this is good planning
- Prescribed housing mix runs counter to criterion also in policy that allows a number of factors to be taken into consideration.
- Plan has long-term lifespan, therefore should not have same market mix for whole plan period.
- Pandemic has shown how external factors can influence people’s lifestyle choices.

Object

Representation ID: 15035

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Unreasonable and unjustified to require 5% SCB plots on sites of 100+ dwellings. This would equate to 761 SCB plots on draft allocations. Latest AMR shows only 374 entries on the self-build register.
- Imposition of mandatory requirement goes beyond guidance in PPG to ‘encourage’ SCB.
- See also extracts (attached) from Bedford’s Local Plan Inspector’s Report – recommended deletion of similar policy. Same principle applies here in that amount being sought is double that on register.

Object

Representation ID: 15036

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Need evidence in 2020 HEDNA:
- PPG state that SM only minimum
- Expected growth at UKC Hub meets criteria in PPG to increase SM
- HEDNA state 13,000 jobs at UKC Hub, over 10,000 Experian baseline
- HEDNA assume only 25% of jobs occupied by Solihull residents.
- Barton Willmore carried out own analysis at 0.93 and 0.98 commuting ratios
- Demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario
- HEDNA identifies acute affordable housing need in Borough, BW analysis conclude HEDNA housing need should increase to meet this component of need.

Object

Representation ID: 15037

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 15038

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 15039

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 15040

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.