Land at Oakes Farm should be allocated within the plan

Policy P5 Provision of Land for Housing
This policy is not considered sound or legally compliant for the following reasons
Whilst Spitfire Homes welcomes the increase in housing numbers from the previous Supplementary Consultation
Document, it is not felt that this goes far enough. A separate representation has been prepared by Barton Willmore on behalf of Barratt David Wilson Homes, IM Land, Spitfire Bespoke Homes, Heyford Developments, and Generator Strategic Land on the Borough’s Housing Need. The conclusions of this representation are supported.
In summary, this representation makes the following conclusions. The NPPF is clear at paragraph 59 that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward”. Paragraph 60 further states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing needs assessment, conducted using the standard method in national planning guidance……. In addition to the local housing need figure, any need that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing planned for”.
In the case of SMBC, policy P5 proposes the following:
• The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing
land supply to deliver 15,017 additional homes in the period 2020-2036. The allocations will be part of the
overall housing land supply detailed in the table below.
• The average annual housing land provision target is 938 net additional homes per year (2020-2036). A
trajectory showing how this target will be delivered from all sources of housing land supply is shown below.
It will be subject to annual review through the AMR.
This is based on the minimum identified need of 807dpa and a contribution of 2,015 dwellings across the plan period to help meet the unmet need within the Housing Market Area. This gives a total of 938dpa.
However, as is made clear in the NPPF and within the representations from Barton Willmore and the House Builders Federation (HBF) that this housing need over the plan period has been underestimated. Equally the housing need figure in policy H5 should be expressed as a minimum which is currently is not.
The Borough has significant ambitions over this plan period as identified as Challenge D and Challenge M.
Challenge D looks to secure sustainable and inclusive economic growth including:
• Meeting Solihull’s important regional and sub-regional role
• Meeting aspirations of key businesses to enable them to maintain competitiveness (Birmingham Airport,
National Exhibition Centre, Birmingham Business Park, Blythe Valley Park, Jaguar Land Rover) whilst
contributing to sustainable development.
• Retaining and developing a high skilled workforce.
• Provide a range of housing to attract inward investment
Challenge M looks to maximise the economic and social benefits of the High Speed 2 Rail Link and UKC Hub Area
including:
• Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and
development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills,
environment and infrastructure.
• To provide an appropriate planning framework so as to ensure that the potential economic and social benefits
of growth enabled by the HS2 rail link and interchange station are delivered.
These ambitions are of course welcomed, but equally they have implications on ensuring appropriate housing is
delivered within the Borough.
The representation prepared by Barton Willmore makes the following conclusions:
• As has been set out above, the policy fails to make it clear that the housing numbers proposed are a
minimum figure.
• The Standard Methods minimum need for Solihull (807dpa) will need to be increased to account from
expected job growth within the Borough.
• Modelling carried out by Barton Willmore shows that between 1,036 and 1,248 dpa. are required to support
the UK Central Hub scenario
• Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being
delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031,
a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases
when the unmet need from the Black Country is considered. Additional unmet need will be created post
2031.
As a result, this raises significant concerns on the housing numbers set out within policy P5. Therefore, settlements such as Balsall Common which have been identified as being able to accommodate housing growth beyond its own needs should have further land allocated within it to meet housing needs.
In this case, further consideration needs to be given to Land at Oakes Farm, Balsall Common. The NPPF is clear at paragraph 68 that “small and medium sized sites can make an important contribution to the meeting the housing requirement of the area and are often built out relatively quickly”.
Spitfire Homes has an option on Land at Oakes Farm, Balsall Common (site 304 in the Site Assessment October 2020). This site could help to meet the additional housing need identified within the representations from Barton Willmore. This site is located to the south west of Balsall Common and would sit comfortably within the built form of the settlement having regard to both existing development and proposed allocations. The chapter on Balsall Common within the Draft Submission Plan sets out at paragraph 521 that “Balsall Common is one of two rural settlements in the Borough that has a full range of facilities including both secondary & primary schools, health services and a range of retail and associated facilities. As such it is well placed to accommodate levels of growth in excess of just its own local needs.”
The Site Assessment document in respect of this site sets out that the “Settlement identified as suitable for
significant expansion, although site would have no defensible green belt boundary”. An accompanying vision
document has been prepared which demonstrates how development could be sensitively located on this site having regard to the site constraints. The site as it currently stands has very clear boundaries with Fernhill Lane marking the western boundary, Oakes Farm shop and hedgerows marking the southern boundary, and hedgerows on the eastern boundary with the B4101 running along the northern boundary of the settlement. Whilst in planning terms the site may be regarded as open countryside, its current and surrounding land use and visual character is such that it does not form part of the more functionally intact agricultural landscape to the south.
The Site Assessment document suggests that it “is within moderately performing parcel in the Green Belt
Assessment and would result in indefensible boundaries to the south and west
An Environmental Appraisal of the site has been undertaken by EDP and in respect of Green Belt when the site is considered on its own merits, it scores significantly lower than suggest in the Council site assessment. A summary of the table is attached.
It is acknowledged that land is proposed to be developed as part of this plan at Frog Lane for 110 dwellings (policy
BC2). As part of the assessment prepared by EDP, they have also assessed the Frog Lane site, and this
demonstrates that the Frog Lane site performs a stronger purpose against three of the tests compared to the Oakes
Farm site. With regard to those performances, it was considered that development of the site is likely to have a
particular effect on the rural character and setting of Frog Lane to the south and east.
The Oakes Farm site is in a highly sustainable location with a bus stop within 400 metres of the site, and the centre of Balsall Common within a 10-15 minute walk, and both a primary and secondary school no more than 1.3km from the site. As is set out within the vision document there is currently an abrupt settlement edge to Balsall Common in this location and development at Oakes Farm would allow this to be softened albeit clearly defined and defensible.
The strategy within the masterplan provides a number of key principles including a significant landscape buffer,
which provides a transition from urban to rural as well as ensuring there is a robust and defensible boundary to the
Green Belt. Within the site, it is proposed to integrate existing public rights of way ensuring good connections to
the centre of Balsall Common village centre. In addition, there are opportunities to provide significant ecological
improvements to the site.
This site is available immediately and is being actively promoted by Spitfire Homes. Apart from the site’s location within the Green Belt, there are no known constraints which would prevent development of the site. This site can easily be delivered within the next five years providing much needed additional housing within the Borough. As has been demonstrated within the accompanying appraisal by EDP, the Oakes Farm site could reasonably be removed from the Green Belt and developed in accordance with the sound masterplanning principles without harm to the integrity of the Green Belt overall.

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the
housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within
the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.