Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 10994
Received: 14/12/2020
Respondent: CPRE Warwickshire Branch
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The Spatial Strategy is not sound. 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.
Revise the Policy 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 boundaries of allocating new housing sites on land that is now Green Belt.
The spatial strategy stated at paras 56-59 is to develop and expand the Borough for the reasons given in paras 56, 57 and 58. Para 59 states that "to deliver the level of growth envisaged will require significant releases of land from the Green Belt".
This is contrary to national planing policy. Under the NPPF 2018, para 11 'The presumption if favour of sustainable development', Solihull does not have to meet all calculated or claimed needs.
The Solihull Local Plan Review proposes high levels of housing and removal of land from the Green Belt. The Council states that it is meeting calculated housing needs and taking some housing from adjacent local authorities (Birmingham).
The Council has not applied, and has chosen not to make use of, the National Planning Policy Framework policy on sustainable development. This is 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.
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.
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.
The Plan is not sound because the NPPF’s policy has not been applied; in fact it has been ignored.