Site Selection Methodology

Solihull conurbation is slowly becoming a suburb of Birmingham, Coventry, Redditch etc. Soon, if building at this rate continues, there will be no green spaces of value left. Our local infrastructure will be overwhelmed & the current problems of congestion / state of the roads, horrendous waiting times to see a GP, Dentist, hospital specialists, etc will worsen. Classes in school will soon be over 50 pupils per class. No teacher can teach 50 kids at one go. Parking outside schools is bad now, imagine how it will be.

Area 4 has numerous sports fields at present and it is not in the public interest to build on these and reduce sporting facilities.
The infrastructure is already unable to cope with traffic and parking in the area - insufficient spaces already at Whitlocks End and at the shops in Dickens Heath.
The muntjac deer are protected in the UK under the 1991 Deer Act and the building of houses where they are seen daily (rear of Old Yardleians) will kill them.
The fields currently already flood every Winter and whenever there is heavy rainfall

The council does not appear to follow its own recommendations.

Balsall Common is clearly identified with existing traffic congestion issues, poor transport integration with the wider area and low local employment opportunities, all of which are supposed to be factors in considering development locations.

Adding 1500 home and around 6000 inhabitants will strain local services and add great pressure to the local road network as most residents will have to travel by car to places of work outside the village.

The representations of the Knowle Dorridge and Bentley Heath KDBH) Neighbourhood Forum (NF) to the 2016 DLPR raised objections, inter alia, on the basis that;
* The Council's spatial strategy is not clear or coherent.
* There were inconsistencies in the site selections with the Spatial Strategy, the Strategic Transport Strategy and with the Council's own evidence base, particularly the Landscape Assessment, the Interim Sustainability Appraisal and the Green Belt Assessment.
* There was inadequate consideration of infrastructure impacts, particularly traffic impacts.
These comments still apply. In addition:
Spatial Strategy: The Supplementary Update does not revisit the Spatial Strategy. Both the HMA shortfall contribution and the alternative considerations raised by the Strategic Growth Study necessitate revisiting the Spatial Strategy. It is unacceptable to leave these fundamental issues to the Submission stage.
The Spatial Strategy and the site hierarchy assessment (at Appendix D) refer in places to sites in KDBH being consistent with Option G of the Spatial Strategy. However, this Option was one of the worst performing in the Interim Sustainability Appraisal. It is not clear which of the Options is the basis of the Spatial Strategy - it appears to be a mix of all the Options with no clear approach. Notwithstanding this, the aim of the Spatial Strategy is to ensure a sustainable pattern of development and to protect the character and distinctiveness of the Borough. This is inconsistent with the proposed scale of growth in KDBH.
There is no change in the assumption that the Local Plan will make a 2000 house contribution to meeting the HMA shortfall. This will not be reviewed until the Submission version of the DLP. It is widely believed that the Council will have to increase this number which could have significant implications for the overall Spatial Strategy. At present it appears that the Council is considering the amber sites as possible further releases. However, bearing in mind the flaws in the Spatial Strategy outlined in the previous response of the Neighbourhood Forum (NF) it is even more important to revisit the Spatial Strategy should the HMA number increase. Simply adding more amber sites will not provide the strategic approach that is necessary.
Methodology: There are flaws in the methodology and in the application of the methodology.
Step 1 of the hierarchy identifies those sites with a score of 1 to 4 as green. However, the Step 2 diagram appears to concentrate on refining only the yellow and blue sites. This is confirmed in para 68 which says that Step 2 is principally concerned with confirming whether the yellow and blue sites should be reallocated in the hierarchy. This suggests that if a site is assessed as green in Step 1, there is no proper assessment of how such sites fit with the overall spatial strategy or of site constraints.
The methodology gives insufficient weight to the impact and mitigation of site constraints, particularly in respect of 'green' sites. Step 2 must apply to all sites and should be given equal weight to Step 1 as compliance with strategy and the assessment of constraints are of vital importance to the assessment of all sites.
There are significant inconsistencies in the application of the methodology which undermine the integrity of the whole selection process. The following are a few examples where further explanation of the conclusion of the assessment process is required:
* Arden Triangle sites (nos. 148, 149, 150,151,152,153 and 154 and 157 excluding the Academy site) all appear in Appendix D to score 6 in step 1 and be assessed as blue (ie 'unlikely allocations') but are then assessed as green via Step 2. Without sight of impacts and proposed mitigation, it is not possible to understand how these sites fall into the green category ie that they have no or relatively low impact on relevant considerations; or that severe impacts can be mitigated. Such information is essential to enable residents and businesses to make informed responses to this consultation.
* Further apparent anomalies within the Arden Triangle include parcel 148 Lansdowne, assessed as medium/high accessibility and parcel 157 Land east of Knowle forming part of the Arden Triangle assessed as very high accessibility. Similar issues arise in the Interim Sustainability Appraisal in which the Arden Triangle is assessed as highly positive in terms of proximity to buses and trains and to convenience stores, positive in terms of healthcare and leisure, and neutral in relation to landscape. However, most of the Arden Triangle site lying beyond the Academy is not easily accessible and has valued landscape characteristics as demonstrated by both the Council's Landscape Assessment and the Landscape Study commissioned by the NF.
* Site 213 north of Hampton Rd is assessed as blue in Step 1 and then becomes green, despite performing highly in terms of purpose 1 of Green Belt. It is also assessed as having medium/ high accessibility even though there is no bus service and large parts of the site are a long walk from the High St. The other two northern parcels (sites 214 and 215) are assessed as red ie not suitable for development although they would become the site of the sports hub development.
* Yet further questions arise in respect of Site 244, part of Copt Heath Golf Course, which is only assessed as medium accessibility despite being close to a bus route. It is assessed as yellow in Step 1 but is red after Step 2: Jacobean Lane sites 323 and 324 score reasonably well but one is red and the other amber: and site 413 Land at Oak Green, Dorridge performs well with high accessibility but is assessed as amber.
These are a few examples which aim to demonstrate the point that many if the sites around KDBH have very similar scores but vary considerably in their assessment as green, red or amber. A clearer explanation is required of the assessment process to justify the draft allocation sites. Without this, the credibility and robustness of the process is undermined.
It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. The Strategy continues to focus only on large scale Green Belt releases around KDBH which is not consistent with government advice that a mix of sites should be encouraged. Some of the smaller sites should be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character.
Infrastructure impacts and mitigation. See answer to Q22, 23, and 24

Dear Sir / Madam

Thank you for consulting Lichfield District Council on the Local Plan Review. The comments below focus on the primary areas of concern Lichfield District Council have. It remains the case that Lichfield District Council would welcome Duty to Cooperate meetings to address such matters prior to the regulation 19 publication version of the Solihull Local Plan.

* There remains concern that Solihull is not committed to fully addressing the Greater Birmingham Housing Market Area (GBHMA) shortfall. The supplementary consultation does not seek to provide justification as to how Solihull has arrived at providing an additional 2000 dwellings in addition to its OAN as a ceiling towards the shortfall, and does not have regard to the housing requirement options set out in the further strategic growth study.
* That whilst the recognition of the potential need to revise the housing requirement figure in the regulation 19 publication version is welcome, the concern regarding failure to meet the commitments associated with cross boundary cooperation remains as it is indicated that Solihull will only be updating their position in the version that is published. Without cooperation with authorities in the Housing Market Area, it remains the case that any finalised figure has not had appropriate assessment.
* That the land supply of 726 more than the OAN plus the 2000 identified to meet the shortfall in Birmingham is noted, but that it is not known if the provision provides a sufficient buffer to meet the need because, the requirement has not been justified.
* The refinements regarding methodology and approach to site selection appear to be soundly based on a sustainable approach to allocating sites based on their previously developed / greenfield status, accessibility to services and impacts for the Green Belt in line with the NPPF approach. However, the flaw remains that the identification of the additional 2000 to meet the shortfall has not been justified for the reasons previously set out. Accordingly, further sites may need to be identified and released.
* That the Local Plan should look to identify requirement and provision to 2036 which is the end date for the Strategic Growth Study and not to 2035. This ensures consistency in meeting provision across the HMA authorities.
* That the sustainability appraisal has not been updated to take account of the changes proposed in the supplementary consultation to the Draft Local Plan. Lichfield DC is also concerned that without agreement through duty to cooperate in respect of how the Greater Birmingham Housing Market Area shortfall requirement is apportioned in the most appropriate way, the SA assessment will not have properly considered suitable alternatives and established the most sustainable strategy.

Account should be taken of the impact on Infrastructure in the initial identification - sites should be preferred only if they can be delivered with minimal/no impact on infrastructure.

As the M42 already reduces the quality of sites close to it, then sites closer to the Motorway should be preferred over high quality Green Belt further away from the Motorway.

UK Central is effectively a new settlement area and so should be considered as higher priority as it does not impact on existing residential areas.
UK Central area should be treated differently. This is effect

The site selection process ONLY identifies sites. They are then almost exclusively allocated for the great God of Housing.

Greater attention needs to be given, and sites allocated, for the provision of community infrastructure, for example additional health care space, parking, recreational facilities (not just open spaces), traffic management, (particularly bus and heavy vehicle traffic), and shopping and community facilities.

Particularly in the Balsall Common and Dickens Heath areas with old and/or very limited facilities.

The Council deems Call for Sites the most efficient way to select sites; I believe this can mean sites are not chosen because they are the best sites for the local community, but for the benefit of the landowners or developers who own the land.
Particularly building on former Greenbelt land which has been offered by developers will irrevocably change the character of an area from a semi-rural to a built up conurbation.
Specifically building on what is known as Arden Triangle benefits developers and land-owners whilst destroying a green and rural entry, rich in trees and wildlife, into Knowle village centre.
It was queried at the recent consultation meeting at Arden School why land close to the M42 was not being considered - given also that it is near the motorway and would reduce traffic going through the village. Apparently this had not been offered in the Call for Sites.

Please see attached letter.

The criterion for selection appears to be to select the areas already heavily populated to leave untouched large areas of countryside

why is so much housing been concentrated in such a small area, almost 40% in the Shirley/Blythe Villages area on Green belt land encroaching on the much needed gaps between villages. The small narrow roads in this area are already at a standstill at peak times.

Having lived in Shirley since 1984 I am concerned at the disproportionate number of new homes that are targeted on the immediate countryside belt surrounding the area. More equitable distribution of homes throughout the borough is required and I am concerned that responsibility is shared

We welcome the fact that some of the omission sites have been recognised as having less harm than others and are being reconsidered as 'Amber sites'.

We do however maintain a fundamental concern over the Site Selection Methodology because Step 1 of the process is reliant on a flawed Green Belt Assessment report which has errors in relation to our client's site at Golden End which need to be rectified. See later response to Question 38 for our representation on this matter.

Please see attached letter

Whilst I accept the need for the proposed housing and I'm not asking for the amount in Shirley to be reduced I would like to know why there's not more sites in Knowle, Dorridge, Hockley Heath, Central Solihull.

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.

Why are so many homes near Shirley?

This site, the land at the rear of 114 to118 Widney Manor Road Solihull has already been assessed and rejected by the council for further residential purposes.This is yet another attempt at 'garden grabbing'

I find the site selection process to be fundamentally flawed due to:
1. A failure to consider the aggregate impact and loss of green belt amenity from additional Coventry build and HS2.
2. Selection of greenfield sites in preference to a number of brownfield sites
3. Insufficient weight given to the poor transport links in the Balsall Common area
4. The rationale for the excessive burden of development for Balsall Common is not given (1690 new homes vs 3900 existing) when only 900 homes ( vs 8000 existing) are proposed for Knowle, Dorridge and Bentley Heath.

Why is site selection focused so much on Shirley were there is already a huge traffic problem

Please see attached letter. My husband and I believe that the methodology of the site selection is flawed and we do not agree that it is logical to consult again on sites that the Council itself has already considered and rejected in recent years. The Amber sites should not have been included in the supplementary consultation. There has been no change to the local and national planning position since the Council's last refusal of planning applications on the land behind 114-118 Widney Manor Road. Garden grab is not the way to provide properly planned housing.

of new local housing proposed 38% is based in Shirley!!! This is way too high, suggest using other areas such as Dorridge, Knowle, Lapworth etc - I believe we have given up enough of our land without the infrastructure to support it.

The Solihull Ratepayers Members Forum and AGM on 8th March considered a presentation on the Solihull Local Plan Review Consultation and the presentations of our views are set out in the attached letter

While the methodology purports to be objective, the application is subjective and inconsistent.
As the number of dwellings is open to revision it is difficult to make a valued judgement on where houses should be built. It is not prudent to release land from Green Belt especially in the 'Meriden Gap'. SMBC are its guardians and erosion must be resisted in this critical location. Land is being removed from Green Belt because of HS2. The west coast main line already runs through the area so there is no justification for such a reduction in the Meriden Gap.

The categorisation on page 18 is based on entirely subjective assessments. The differences between them cannot be judged objectively. Indeed priorities 2 and 6b have identical names.
Sites are judged in isolation with no consideration given to the surrounding area. For example a site in the narrowest part of the Meriden Gap must make a greater Green Belt contribution than one elsewhere.
The methodology places great weight om the Atkins GBA which is not reliable enough to be used as the basis for such far reaching proposals.

2. I find the site selection process to be fundamentally flawed due to:

a. With significant amounts of greenbelt being impacted by competing projects (HS2, Coventry development, etc) the aggregate impact and loss of amenity is not considered at the narrowest part of the greenbelt .
b. It takes greenfield sites in preference to a number of brownfield sites (e.g 1 and 43) which are self-contained and easily developed.
c. It gives insufficient weight to the poor transport links in the area and is inconsistent with the Council's own "Solihull Connected" publication (residents make 70% of daily trips by car vs borough average of 50%
d. The rationale for the proposed burden of development for Balsall Common is difficult to understand (1690 new homes vs 3900 existing) when only 900 homes ( vs 8000 existing) are proposed for Knowle, Dorridge and Bentley Heath. It is particularly difficult to understand why no build is proposed in Dorridge, when it possesses better transport links , a modernised shopping centre and a greater range of schooling.
e. Government policy dictates that property prices are an indicator of unmet housing demand in an area. With average house prices significantly higher in Dorridge than Balsall Common , the absence of building in the former is an indication of a failure in the selection process

No, I object to the method of site selection as no consideration has been given to the infrastructure of the area to support such an obscene number of new homes

please find attached our response to the Solihull Local Plan Review Draft Supplementary Consultation and a site location plan for Site 173 -Winterton Farm

In relation to Balsall Common, I am concerned that the high volume of housing proposed will have a serious impact on this rural location, particularly on its infrastructure which is already under pressure.
Brown field land used by HS2 should be included not ignored.

In terms of site selection methodology I am pleased that its application has been applied appropriately in relation to Grange Farm resulting in it being dismissed for development, as it falls within productively farmed Green Belt and has no defensive boundary against mass development leading to urban sprawl and erosion of the Meriden Gap.

Why are there so many homes being aloccated to the Shirley area?
Green sites in the rest of the borough are not taking their fair share.