The methodology of the site selection process is not agreed.
Section 39 of the Planning and Compulsory Purchase Act 2004 requires planning authorities preparing Local Plans "must exercise the function with the objective of contributing to the achievement of sustainable development". In exercising this duty they are required under the same section to "have regard to national policies and advice contained in guidance issued" by the Secretary of State.
Key advice of national policy National Planning Policy Framework (NPPF) 2019 is as follows:-
 Significant adverse impacts on key economic, social and environmental objectives should be avoided, in the context of a Sustainability Appraisal designed to inform the plan making process. Alternative options which reduce or eliminate such impacts should be pursued. (NPPF paragraph 33)
 Policies for development contributions should not undermine the deliverability of the plan.(NPPF paragraph 34)

 Plans will be examined to assess whether they are sound, and measures of soundness include being justified by an appropriate strategy taking into account reasonable alternatives and based on proportionate evidence. A further relevant soundness measurement is consistency with national policy to enable delivery of sustainable development in accordance with the National Planning Policy Framework. (NPPF paragraph 35 )
 Patterns of growth should be focussed on locations which offer genuine choices of transport mode. (NPPF paragraph 103)
 Plans should contain policies that optimise use of land in their area. (NPPF paragraph 123[a])
 When reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. (NPPF paragraph 138)
National guidance advises as follows:-
 Policies need to be justified by evidence and support of the Planning Advisory Service is tabled as of assistance in this having regard to this need for evidence based justification. (Planning Practice Guidance Reference ID: 61-031-20180913) [It is appropriate to note that PAS offer specific help in relation to Green Belt Review]
 When updating a plan [in full or part] Local Planning Authorities should ensure the resultant plan meets the tests of soundness. (Planning Practice Guidance Reference ID: 61-050-20180913)
 In relation to transport the evidence base should identify opportunities for a shift to more sustainable patterns of transport. Reference should be made to Department for Transport Circular 02/2013(Planning Practice Guidance Reference ID: 54-001-20141010)
 Circular 02/ 13 paragraph 16 is as follows:-
"Promoting sustainable transport solutions through Local Plans
16. Through the production of Local Plans, development should be promoted at locations that are or can be made sustainable, that allow for uptake of sustainable transport modes and support wider social and health objectives, and which support existing business sectors as well as enabling new growth. "
 A robust evidence base can inform sustainable approaches to transport. (Planning Practice Guidance Reference ID: 54-002-20141010)
 A range of key issues need to be evaluated and alternate scenarios of differing alternative site or mitigations proposed in order to articulate and arrive at the delivery of sustainable growth. (Planning Practice Guidance Reference ID: 54-003-20141010)

In the context of the foregoing it is considered the approach to site selection is flawed to the extent that it does not meet the statutory obligations under the Planning and Compulsory Purchase Act 2004, and it will fail key tests of soundness.
The nub of the problem relates to the Green Belt element of the selection process. This involved a two stage procedure - the first a broad selection of areas of potential development or non development. The earlier consultation involved a submission (January 2016) on behalf of my clients (promoters of the development at the land rear of 114 - 118 Widney Manor Road) by reference to the Inspector comments in respect of the suspension of the Examination of the Chippenham Site Allocations. Plan.
The Inspector doubted the soundness of that plan for two reasons material to Solihull's work. Firstly (number (i)/second in the Inspector's letter of 16-11-2015 [furnished in the objectors January 2016 submission] is the two stage approach to sieving potential development sites on the basis of a narrative broad area analysis which the Inspector felt would not give confidence that those area rejected in the first round have been subject to robust evaluation. This potentially leads to the view that reasonable alternatives have not been given proper consideration. This rendered that emerging plan subject to legal challenge. The Inspector did not spell it out but the underlying view appears to be that the 'justified' soundness test would not be met and thus any approval would be subject to a failure on legal grounds through the application of Tesco v Dundee City Council [2012 UKSC 13] which requires a proper understanding of policies as the heart of legally robust decisions.
The second issue in the Chippenham case is that the Sustainability Appraisal fell foul of the same logic.
It is considered that the same problem as referred to in the Chippenham case is present in the approach adopted by Solihull. The Policy and Guidance referred to above contains several discrete aspects which by virtue of S39 of the Planning and Compulsory Purchase Act 2004 are obliged to consider are precluded in the case of discrete areas of land. Of particular concern in the instant case is the fact that the Sustainability Appraisal lumped my clients land (rear of 114 - 118 Widney Manor Road) together with 3 other parcels of land having very different characteristics.
It is submitted that the two tier approach to Green Belt site selection, together with the specific Sustainability Appraisal flaw referred to above would render the resultant Local Plan review in breach of legal duties and the publication of a plan which would not pass the soundness tests of justified and compliance with national policies.
Modern database technology renders it a fairly simple process to articulate a database which facilitates interrogation by an algorithm which can test individual development sites against the wide range of Government policies and advice required in law (and set out in brief above) to render a plan compliant with legal duty and passing the tests of soundness.