Revise Challenge B wording to make clear that the NPPF 2018 policy 'The presumption in favour of sustainable development' (para 11 (b) (i) and (ii) applies. And that the Council will not be altering Green Belt boundarires of allocating new housing sites on land that is now Green Belt.

Challenge B is stated to be meeting housing needs across the Borough, including the Borough's own needs and, where possible, assisting with accommodating the HMA wide shortfall.

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 release 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.