Apply the provisions of NPPF 2018 para 11 titled 'The presumption in favour of sustainable development. Delete the allocations that are proposed what what is now Green Belt and the proposals to change the boundaries of the Green Belt to remove land from it.

Para 15 is titled 'What will happen if we don't identify enough land for new development'. This fails to make clear that Solihull does not have to meet all calculated or claimed needs. 1.1 The Solihull Local Plan Review proposes high levels of housing and removal of land from the Green Belt.

1.2 The Council states that it is meeting calculated housing needs and taking some housing from adjacent local authorities (Birmingham) as national planning policy requires it to.

1.3 The Council has not applied, and has chosen not to make use of, the National Planning Policy Framework policy on sustainable development. This means that policies should provide for assessed needs for housing and other uses unless policies that protect areas of particular importance provide strong reasons for restricting the scale of development. The areas of particular importance in Solihull’s case are the areas of Green Belt. Green Belt designation covers all of Solihull’s countryside and is justification for not meeting the assessed need for housing. See NPPF 2018, paragraph 11.

1.4 The Council has not in its Submission Draft Plan explained why it has disregarded this key national planning policy and is proposing the relase of large areas of Green Belt to meet the assessed housing need, when the NPPF policy on sustainable development states that it is not required to do this.

1.5 Exceptional circumstances for changing Green Belt boundaries (and thus removing land from the Green Belt) cannot be demonstrated where the policy in the NPPF para 11(b) has not been applied.

1.6 The Plan is not sound because the NPPF’s policy has not been applied.