Strategic Objectives paras 96 and 102.

Richborough Estates Limited support the approach of the Local Plan Review to promote patterns of development that focus significant growth in locations that are, or can be made, sustainable. Richborough Estates recognise that previously developed land within urban areas should be exploited which is referred to in the White Paper Fixing our broken housing market.

However, given the nature of Solihull Borough, the recognition that opportunities for non-Green Belt development outside the main urban area and the larger settlements are limited is welcomed. Further, even where such opportunities might be claimed to exist then careful consideration is needed as to whether development could proceed without harming the character of existing areas (e.g. 'town cramming', poor quality backland development, loss of open area, reductions in employment opportunities/land, etc.). There are also questions whether such opportunities are deliverable because of constraints associated with, amongst other matters, ownership, legal restrictions, access, trees, ground conditions, viability implications etc.

Using the available evidence base, the Borough Council can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirement and that there are exceptional circumstances associated with delivering the objectively assessed housing need which fully justify amending the Green Belt boundary at appropriate locations. Such an approach is consistent with the National Planning Policy Framework and the White Paper.

Sequentially, within the Green Belt it is correct to direct growth towards locations that are highly or moderately accessible whether they are greenfield or previously developed sites. Sustainable and accessible locations are those related to public transport corridors (or transport hubs as now referred to in the White Paper) or on the edge of accessible settlements which possess a range of local facilities. The proposed allocations at Frog Lane, Balsall Common (Potential Housing Allocation 2) and West of Dickens Heath (Potential Housing Allocation 4) fully accord with the sequential approach adopted in the Local Plan Review towards directing growth to sustainable locations.

Although superficially attractive, growth on previously developed land in the Green Belt located away from existing public transport corridors or accessible settlements should be resisted because it would fail to deliver sustainable forms of development.

Broad Options for Growth and Development - paras 108 and 109.

Richborough Estates Limited support the broad options for growth and development focusing significant growth in locations that are, or can be made, sustainable as advocated in the Local Plan Review's Strategic Objectives and Guiding Principles.

Using the available evidence base, the Borough Council can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirement and that there are exceptional circumstances associated with delivering the objectively assessed housing need which fully justify amending the Green Belt boundary at the chosen broad locations. Such an approach is consistent with the National Planning Policy Framework and the White Paper Fixing our broken housing market.

The chosen broad option for growth and development provide a balanced approach to accommodate development by dispersing growth to accessible locations across the Borough rather than placing undue reliance upon one or two strategic locations (e.g. The UK Central Hub Area/HS2). A balanced approach to the distribution of housing growth across the Borough enables the identification of a range of different sizes and types of sites in the emerging Local Plan, including those within both the urban area and the Green Belt.

The broad option also enables the Local Plan Review to identify a wide choice of allocations in different locations across the Borough which can be delivered at the same time thereby both fostering competition which will assist with curbing house price inflation and enhancing the prospects of delivering the required dwellings within the plan period to meet the identified housing needs. These identified needs are related to both the local Solihull housing market and addressing part of the shortfall of suitable and available residential land within the wider Housing Market Area.

The White Paper is also clear that 'Policies in plans should allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector' (paragraph 1.29). The ability to identify a wide range choice of housing allocations increases the potential delivery of a mix of high quality homes, provides the opportunity to widen opportunities for home ownership and promotes the ability to create sustainable, inclusive and mixed communities of the type sought by the National Planning Policy Framework.

Larger scale housing allocations on the periphery of Solihull, Shirley and other accessible settlements could incorporate the principles of Garden Cities as advocated in the Framework. Such an opportunity also exists through the allocation of land to the West of Dickens Heath (Potential Housing Allocation 4 (PHA4)) which is a large site at adjacent to an accessible settlement and located along a public transport corridor, specifically adjacent to a transport hub.

As recorded in the Interim Sustainability Appraisal Report (January 2017) there are sites available under this approach capable of contributing towards the meeting housing supply within the next 5-years, including land under the control of Richborough Estates at Frog Lane, Balsall Common (Potential Housing Allocation 2 (PHA2)) and to the West of Dickens Heath (PHA4). The Frog Lane site could be fully delivered within 5-years from when the site is taken out of the Green Belt. There would be new homes delivered during a 5-year period at Dickens Heath but it would be reasonable to assume that the whole scheme would take between 8-10 years to deliver from the date of the first dwelling being occupied.

At both locations, new homes can readily be delivered utilising existing local services and public transport. The opportunity also exists for investment in new or improved facilities and services for the benefit of both existing and future residents, including a Community Sports Hub at Dickens Heath. Further, and as indicated in the White Paper, there are potential
opportunities for compensatory improvements to the environmental quality or accessibility of remaining Green Belt land or land within the vicinity of these broad locations.