Site Selection Methodology

See letter and attachments.
Reference Sites 134, 205 and 308 (Amber Site A7)
Questions Nos 2, 34, 37 and 38
I am attaching a Summary and Response to the above questions. I add my name to this. In addition I am attaching three supporting copy documents:
* The Planning Inspectorate: Appeal Decision dated 19 April 2011
* Assessment of Green Belt Submissions, October 2011
* Agreement between Mar City Developments Limited and The Metropolitan Borough of Solihull
I confirm my strong objection to the removal of these areas from the Green Belt. Site 134 was the subject of a Planning Application (2010/2) which was refused. The Appeal which followed was dismissed at the Inquiry. Nothing has changed which would now justify the removal of these sites from the Green Belt.

We do not want any building on Widney Manor road between the college and the station. There is too much traffic now

site selection does not meet NPPF2 standards. Council need to review Sustainability appraisal in line with the critria set out in the Government scorecard

I agree with the methodology adopted for the site selection process: it is objective, logical and based on planning merit. It is notable, however, that the refinement of each site is based on a more subjective assessment of each site. It is reasonable to expect the promoters of each site to provide sufficient evidence on which the refinement should be based. It may not be possible to determine the relative value of those submissions against each other in an objective manner.

Methodology.
I do not agree if Balsall Common station is counted as equal to Dorridge.
Infrastructure
We need infrastructure. Green spaces, sports facilities, parking,improvements to very limited.centre.

Site 1 Barrett's Farm
I reluctantly agree to its inclusion.
Site 2 and 3
I do not agree to their inclusion as they are do far from amenities.my neighbour has to get a taxi to the shops.also they have considerable worth as greenfield and wildlife havens.
Trevallion Stud and Pheasant oak Farm.
Yes to being included as
Used as part brownfield.
Concept plans. Good idea but need much more work especially in guarding development from existing gardens

Shirley seems to have born the brunt of the housing plans which is grossly unfair seeing as how there have already been developments in that area which have adversely affected traffic flows, parking demand and school/medical services.
I feel that there should be a much fairer spread on other areas of the borough.
It does appear that the more wealthy areas have been spared whilst Shirley is being "dumped-on"

Please see attached document March 2019 Persimmon Reps Draft Solihull LPR

In broad terms I agree with the methodology. However, the application of the methodology to certain sites assessed is flawed.

In particular, the presumption that ribbon development, no matter how well established it may be or how limited it may be in extent, should result in a scoring down on character and quality is not appropriate. Intrinsic qualities of unbuilt development should be taken into account, as should the visual amenity to local residents.

As an example, the assessment of Site 413 (Amber - ref A5) is flawed in this regard.

Spatial Strategy - The sites referred to in Knowle, Dorridge and Bentley Heath (KDBH) are stated as being consistent with Option G of the Spatial Strategy but this option was the WORST performing in the Sustainability Appraisal. 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.
Methodology - There are significant inconsistencies in the application of the methodology which undermine the integrity of the selection process but I refer in particular to the Hampton Road site. Site 213 north of Hampton road is (presumably?) assessed as blue in Step 1 since it qualifies as being either category 6 or 7 but then becomes green, despite performing highly in terms of purpose 1 of Green Belt. Its Green Belt assessment for purpose 3 should also be higher as a category three rather than the category two which has been ascribed to it. It is assessed as having medium/high accessibility even though there is no bus service and large parts of the site are approx. 1km from the High Street. How was this assessment arrived at? The other two northern parcels (sites 214 and 215) which are immediately adjacent, are assessed as red i.e. NOT suitable for development although it is proposed they would become the site of the new sports hub. Again, how was this assessment arrived at and how can it be justified? Siting a community sports hub in a remote location which has no access to public transport is surely contrary to the Council's accessibility and sustainability policies. The above is only one example of the many sites around KDBH which have similar scores but which vary considerably in their assessment as green red or amber. We need a clearer explanation of the assessment process in order to justify the current allocations, otherwise the credibility and robustness of the process is undermined.
Government advice is that a mix of sites should be encouraged but the Council seems to have looked only at two large sites. Other smaller sites should be looked at to see if they can contribute to the housing growth in a more sensitive way which would have a less detrimental impact upon the Green Belt and the character of KDBH.

Question 2 - We do not agree with the methodology of the site selection process. On the basis the Council have identified sites to assess, assessed them against the site hierarchy and categorised the sites as an allocation, potential allocation, unlikely allocation and no allocation, it is not 'good planning' to then ignore this assessment and consult on the Amber omitted sites.
Paragraph 390 confirms that 'the Council believe it is helpful to identify these 'less harmful' sites (that are shown as amber) so that residents and stakeholders are able to comment on their omission, and whether this is justified'. We object to this further consultation being undertaken on sites that the Council have assessed and rejected. We are also unclear how the Council have concluded these sites are less harmful. In the case of the land at the rear of 114 to 118 Widney Manor Road, Solihull, the Council themselves refused a planning application (2010/648/S) for residential purposes in 2010, and the subsequent appeal was dismissed in 2011. The local and national planning policy position has not changed in the intervening period and there are no material changes on the site to reach a different conclusion; we consider these points in greater detail below.
The inclusion of Amber omitted sites gives the promoters of these sites a 'way in' which in our view is contrary to the Council's own assessment and conclusions reached. We live in fear of this further attempt to garden grab. There must be better sites, outside of using back gardens to provide the housing needed.
In our view, the Council should not have included the Amber omitted sites as part of the supplementary consultation.

I believe this plan does meet the standards set out in the NPPF2, the analysis of sustainability on the whole process needs to be looked at again. Why have so many retirement homes been build along the A34 where the air quality is very poor.

We do not agree with the methodology of the site selection process. We object to this further consultation being undertaken on sites that the Council have assessed and rejected. The inclusion of Amber omitted sites gives the promoters of these sites a way in which in our view is contrary to the Councils own assessment and conclusions reached. We live in fear of this further attempt to 'Garden Grab'. In our view the Council should not have included the Amber omitted sites as part of the Supplementary Consultation.

Please see attached letter

There are far too many housing sites being planned for the area, without Allocation Plan 26, in the Blythe Ward. Why is this case? In addition why is the Ward to received 38% of the proposed housing allocation? This is estimated at putting some extras 4,000 more cars on the areas roads. This is a disproportionate amount of housing for the Ward compared to others in the Borough.
The whole environment will become one huge concrete housing estate and car park. At present the area around Bills Lane has a good balance of housing and open areas for the benefit of all. There is fauna, flora and wildlife and places for people and children to roam: thus enhancing the quality of life in the area. Why is this not been taken into consideration?
When the local authority are stating in the press that they are intending to spending ratepayers money on enhancing the existing borough with bulbs etc., maintain areas of greenbelt why are they then so intent on building all over the open spaces in Shirley forever changing the environment to the detriment of all residents?
Additional housing is needed, but Shirley is taking the brunt of the allocation, when KDBH is not. This is grossly unfair allocation and seems that postcode B90 is treated as the poor relation that can be ridden roughshod over. What park Shirley did have has been reduced and there is little other open land in this area of the Borough. The allocations are not being evenly distributed across the borough.
Yes, we need more houses but they should be the right type and in the right place. With no new employment areas proposed in the Local Plan and little existing local employment, residents have to drive to their work, which is predominantly located to the east of the Borough, causing commuter chaos in this area along rural roads that were not designed for such volumes of traffic. This is an unsustainable situation now without the additional proposed developments exacerbating this situation.The area is already gridlocked, heavens knows how much worse the area will become if the proposed allocation goes ahead. Extra people/traffic will exacerbate congestion through the Dickens Heath Village, on the A34 and surrounding roads including Bills Lane especially at peak times when surrounding roads are used as rat runs. This is not being addressed by SMBC and the new Local Plan does not seem to realise the scale of this problem (or even that it exists).
The pollution, disruption, reduction in POS and the effect on the environment will be immense.
Bills Lane, Shakespeare Drive, Haslucks Green Road, Tanworth Lane struggle to manage now and the problem will only be shunted further into the area. The recent fractured gas main in Shakespeare Drive is a case in point: because the infrastructure is already heavily overloaded the whole area was gridlocked and even backed up into the neighbouring Birmingham Yardley Wood. The current infrastructure cannot cope at present and can therefore take no further increase. Even if significant sums were to be put into the project, the existing infrastructure will be able to cope, thus people's lives will be dramatically affected.
The overall quality of life of the people already living here will be grossly affected. Asthma is already a huge problem for people and children; Asthmas sufferers have had their conditions worsen over the years with the level of additional traffic in the area. The incidents of childhood asthma are on the rise and this is only going to become significantly worse with the additional volumes of traffic.
In the introduction of council document under 370. V 11 ( Health and Supporting Local Communities), it states that;
There are many factors which contribute to creating healthy communities and the NPPF recognises the importance of promoting healthy communities and the role that the Local Plan can play in creating healthy, inclusive communities. The Health and Social Care Act (2012) gave local authorities new duties and responsibilities for health improvement and requires every local authority to use all the levers at its disposal to improve health and wellbeing, and the Local Plan is one such lever.
How is this case; when open spaces and green fields are to be built all over, people to be crammed in like sardines, the volume of traffic to be increased and the quality of air and life in general will be dramatically affected?
371. The health of Solihull residents is generally good and is getting better, however, good health is not consistent across the borough, and the health of some of our residents is significantly below an acceptable level. Premature deaths, work limiting illness and disability and acute morbidity are issues that still disproportionately affect some parts of our population.
This is a case in point; the general good heath of the residents will be dramatically affected, e.g. Asthma. Should the proposed developments go ahead life for people in this area of the borough will regress rather than improve.
375. The draft Local Plan contributes to supporting communities and promotes health through its spatial strategy and policies. These include policies relating to the location of new development, sustainable development, infrastructure, provision of new homes, jobs, town centres and sustainable travel (promoting public transport, walking and cycling). These policies demonstrate that improved health outcomes are integral to the local plan and meeting its vision and objectives.
People in Shirley Blyth ward do not feel in the slightest supported by the SMBC or the Local Plan; instead we feel we are being significantly let down and completely ignored in favour of the more affluent areas like Hampton in Arden and KDBH (whom the council seem to listen to as per the newspaper article the 7th March 2019) We are being ridden rough-shod over and housing developments are being foisted upon us regardless of SMBC's above statement.
Where are we to walk and cycle? How is our health to be improved by increased traffic, pollution, flooding and density of dwellings? In addition may have a huge motorway service station imposed on us at junction 4 of the M42 yet.
All of the points in the Policy P18 Health and Safety are being purposely disregarded by the housing proposals for Shirley. The people of Shirley Blyth ward are being actively discriminated against as we are to be disregarded by this policy. The housing proposals are prejudiced to the health and welfare of the local community. This flies in the face of the councils '
374. The Council recognises the importance of health and wellbeing and the Local Plan has a key role to play in implementing strategies to help people lead healthier, active lifestyles. Many of the policies in the Local Plan will have an impact on health and wellbeing and in drafting the local plan policies, this has been given due consideration to ensure that, the overall impact of any new development should result in positive health outcomes.
The proposed areas are known flood plains-the over spill ending up on to the junction of Haslucks Green Road/Snowford Close and Bills Lane. The road under the railway bridge in Bills land floods regularly with heavy rain.
The local sports club recently wanted to improve amenities for residents by building new facilities and more pitches, however, this was reused by SMBC on the grounds of the detrimental effect it would have on the local fauna, flora and wildlife. The council have now 'about-faced' totally ignoring this policy and want to build all over the area. This is gross hypocrisy as the proposed housing will cause far more environmental damage, add to the flooding problems and wildlife will be devastated.

No
The site selection process does not follow the NPPF2 sustainability analysis and could be subject to a legal challenge. The council should re-evaluate site 4 in particular using the government approved scorecard process.
The selection focuses on large-scale green belt releases, which goes against government advice that a mix of sites should be selected.
We've already see an increase in flooding in and around Shirley with the proposed plans put new & current properties more at risk of flooding
Mott McDonald traffic surveys not conducted prior to site inclusion into DLP

In the report you state that "The majority of sites submitted are not included as a compelling case for their inclusion has not been made; largely because they are located in the Green Belt...." However, this is resulting in what look like common sense sites (eg parts of 33, set amongst existing housing developments) being removed from the plan while green belt such as the land to the south of Dog Kennel Lane (site 12, or122 on the map) is now included in the plan.

Site selection place's 38% of the total in Shirley/Blythe which given the size of the borough seems disproportionate

It is not clear what methodology was used to plan for so many houses to be built in Shirley. It is unclear what the reasoning is for this.The infrastructure we have in Shirley is struggling with the housing that exists already. It is disproportionate. More use of brown land and less addition to existing housing estates would help to create more open areas and help limit the "sprawl" merging into one mass.

See attached document

We object to the site selection methodology in that it has not allowed for sufficient growth for Meriden, a sustainable location which is well located for the HS2 Interchange Station and should have been allocated a higher growth priority than it is currently in the draft plan.

We also maintain a fundamental concern over the Site Selection Methodology because Step 1 of the process is reliant on a flawed Green Belt Assessment report.

SMBC may have to release land from Green Belt status but the main purpose of Green Belt to stop urban sprawl between settlements must be paramount. The advent of HS2 is not a reason to release land from Green Belt otherwise the whole length of the line would be built on.
The methodology purports to be objective but its application is subjective and inconsistent.
Sites are judged in isolation with no consideration given to the cumulative effects on loss of green belt especially in the narrowest part of the Meriden Gap.

Please find attached Tidbury Green Parish Council's response to the Draft Local Plan Supplementary Consultation, along with the appendices referred to within our response.

The Greenbelt review is questionable. It appears to undervalue the importance of the Meriden Gap.

Any Greenbelt analysis that allows housing in the narrowest part of the Meriden Gap would appear seriously flawed

Please see attached letter

There is a disproportional amount of houses allocated for Shirley South (38% of Solihull's allocation).
With the advent of HS2 Shirley South is one of the furthest areas from it and will therefore contribute greatly to travel congestion.
Shirley does not have a vast amount of parkland, which whilst it is on the edge of the green belt has masked this. Once a conurbation is built on this green belt the lack of green space in Shirley will become more evident.
When Site 13 was removed it should of been replaced elsewhere in the borough not with Site 26.

See attached letter

Why are so many new homes being built in Shirley

I object to the inclusion of Amber omitted sites, particularly in the case of the land at the rear of 114 to 118 Widney Manor Road, Solihull, where a planning application (2010/648/S) for residential purposes in 2010, and the subsequent appeal was dismissed in 2011.
The inclusion of such Amber omitted sites gives the promoters of these sites a 'way in' to challenge a previous decision upheld on appeal.

Why are so many new homes being built in Shirley