Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11005

Received: 14/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Provision of housing to meet the increase in households projected by ONS for Solihull up to 2036 can be achieved without any removal of Green Belt or allocation of housing on land now Green Belt, except at the UK Central Hub north of the A45.
The housing strategy is wrongly based on allocation of a small number of large housing sites, on land now Green Belt. Replacement of these by a strategy of small sites would enable the increase in households to 2036 to be catered for without the scale of loss of Green Belt that the Plan proposes.

Change suggested by respondent:

Change the housing requirement to the annual figure of household increase projected by ONS (632 pa).

Delete the large housing sites on what is now Green Belt allocated in the Plan listed in the Table at para 226.

Revise the housing supply at Solihull Town Centre to the higher figure now likely to be achievable.

Replace the policy of a small number of large new housing sites with a larger number of small sites, only a few of which would be in current Green Belt land.

Full text:

Policy P5 and the accompanying tables propose a high level of housing provision over 15/16 years (2020-2036) - 15,000, or nearly 1,000 per year. This is much higher than any past rate for housing completions except in occasional years. The total is well in excess of the ONS projection for increase in number of households in the Borough. The annual increase is given (Table at para 220) as 632 households/ year 2020-230. The ONS projection beyond 2030 is not shown; if the rate of increase is the same the growth in households 2020-2036 would be about 9,500. That may be too high.

Without allocating any new sites which are on Green Belt and without including any housing at the UK Central Hub area to 2036, the Solihull Housing Land Supply table (Table at para 222) shows a total supply of 7,000 new dwellings. This is from summating all figures in lines 1 to 8 of that table. The entry for line 5, Town Centre Sites, of 961, seems likely to be underestimated because capacity of Solihull Town Centre and scope for additional dwellings there seems likely to be higher than the Plan quotes (861 dw, see footnote 29).

Provision of housing to meet the increase in households projected by ONS for Solihull up to 2036 can be achieved without any removal of Green Belt or allocation of housing on land now Green Belt, except at the UK Central Hub north of the A45. That land is proposed for removal from the Green Belt for the HS2 station and development around it. If 2,740 dwellings are delivered there by 2036, the total supplied housing by 2036 would be 9,750.

The housing strategy is wrongly based on allocation of a small number of large housing sites, on land now Green Belt. Replacement of these by a strategy of small sites, which would require much less removal of land from the Green Belt, would enable the increase in households in the Borough to 2036 to be catered for without most of the removal of land from the Green Belt that the Plan proposes.

A good example is that residential allocation BC3, Windmill Lane Balsall Common of 120 houses - which would be very damaging to the setting of the Grade II* Berkswell Windmill - can be replaced by small sites in the Balsall Common area, notably Site 82 north of Derngate Drive, west side of Kenilworth Road (capacity 60-70 dw). Site 82 is Green Belt but partly surrounded by other houses and heavily screened on the west side. Similar examples where small changes to the Green Belt boundary would allow small housing development without harm to the general Green Belt have been identified by other objectors.