Policy P1 UK Central Solihull Hub Area

Waste management area needs to be re homed in a more appropriate place which has suitable access and away from residential homes.

My objection is to the siting of Waste management facilities to Damson Parkway.
Also this is close to a residential area on Damson Parkway
This is not a very good idea considering the traffic that will be using the JLR LOC and the JLR factory.
There are already queues of cars waiting for access to the site at Bickenhill that trail up the service road, this would create havoc at shift changeover times at JLR and for everyday people to go about their business and for residents of Damson Parkway area.

The 2nd sentence in para 105 must be removed (I.e “Part of this land has also been identified as an option for a relocated Household Waste and Recycling Centre and Council Depot. Further justification for this proposal is included in Policy P12.” be deleted).

In para 105, there is reference to land on the south eastern side of Damson Parkway/Old Damson Lane having been identified as an option for a relocation of HWRC. Policy is that this land should only be removed from Green Belt for very special circumstances (I.e. support growth of JLR). Relocation of HWRC is not special circumstances- the SMBC commissioned report identified 3 more suitable sites and recommended this site be discounted. Furthermore there has not been the required consultation to allow the specific reference to this site for relocation of the HWRC. A petition has strong strong objections.

Removal of specific reference to the combined and expanded HWRC and Depot being located in the Jaguar Land Rover (JLR) Area.
This area is designated for Jaguar Land Rover (automotive) and related developments. A combined Waste Recycling Centre and Council Depot cannot be said to fall into this category.

Failing this, SMBC should indicate within the Local Plan, all of the other locations on their shortlist that are being considered for an Expanded HWRC and Depot.
Otherwise, this would be demonstrably unfair to local residents in the Damson Parkway area who have not been consulted on this late inclusion.

Re. Jaguar Land Rover (JLR) - 106: 'The exceptional circumstances to justify this approach are as follows'...

Relocation of (a) the Household Waste and Recycling Centre (HWRC) and (b) Depot to this (JLR) area was not included in previous iterations of this Local Plan, nor have local residents had the opportunity to object or comment on its last-minute inclusion in the final version of the Plan.
Furthermore, SMBC has not included other potential sites on their shortlist for a new combined HWRC & Depot in this Draft Local Plan, thereby giving the impression that this is the only agreed site.

See Attached Word doc.

See Attached Letter.

Policy P1 should be amended to include reference to development for Airport related uses proposed
by Birmingham Airport only and the development of urban mobility. This ensures that the future of a
key economic asset is safeguarded.

Reference should also be made to West Car Park, which may be required to provide
additional capacity for Airport related development beyond the 15-year horizon outlined within the
Airport Master Plan. The Local Plan is currently silent on its intentions for this site.

Thank you for consulting Birmingham Airport Limited (hereafter referred to as ‘BAL’) in respect of the Solihull Metropolitan Borough Council (hereafter referred to as ‘SMBC’) Local Plan – Draft Submission Plan (hereafter referred to as the ‘Local Plan’).
Birmingham Airport: Key Economic Asset

As stated within the Local Plan, Birmingham Airport is a key economic asset and therefore its ability to grow sustainably and support both the national and local economy should be supported. The Birmingham Airport Master Plan 2018 remains relevant despite the short-term impact COVID 19 has had on the aviation sector. The Airport Master Plan included three growth scenarios (Government, balanced and high). Under the balanced growth scenario, the Airport is expected to grow to 18 million passengers by 2033. In the longer term, BAL expects to recover from the impact of COVID 19 and continue to have a positive impact on the regional economy increasing both the density and frequency of route networks to provide more choice for passengers in core catchment area and beyond.
Birmingham Airport’s regional significance is reinforced by the excellent connectivity to surface access it enjoys. This will be further enhanced with HS2, Metro and Sprint providing an opportunity for Birmingham Airport to increase the positive impact it can have on the region and the wider UK economy.
Pre COVID 19 estimates suggest that the economic activity associated with intra-UK connectivity at Birmingham Airport is worth approximately 4,500 jobs and £225m of GVA per year. In terms of extra
UK connectivity, Birmingham Airport is associated with approximately 47,700 jobs and £2.4bn of GVA each year (source: Oxera 2019).
BAL will continue to capitalise on its strong position within UK Central, as a regional airport providing
aviation services to the local community. This reduces the need for surface access travel to other airports which may be further away and has a range of benefits including reduced congestion on the road network, and lower CO2 emissions, air pollution and road traffic accidents.
BAL is committed to achieving a net zero carbon target by 2033 and will work collaboratively with SMBC to help achieve this.
Comments on the SMBC Local Plan – Submission Draft

This representation is informed by the Birmingham Airport Master Plan 2018 and the tests of soundness which are set out in the National Planning Policy Framework (hereafter referred to as ‘NPPF’) (para 35): “Local Plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound.”

Plans are ‘sound’ if they are:
1. Positively Prepared: providing a strategy which, as a minimum, seeks to meet the area’s
objectively assessed needs; and is informed by agreements with other authorities, so that unmet
need from neighbouring areas is accommodated where it is practical to do so and is consistent with
achieving sustainable development.

2. Justified: an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence This means that the Local Plan should be based on a robust and credible
evidence base involving:
• Research/fact finding: the choices made in the plan are backed up by facts.
• Evidence of participation of the local community and others having a stake in the area; and
• The Local Plan should also provide an appropriate strategy when considered against reasonable
alternatives. These alternatives should be realistic and subject to sustainability appraisal.
• The Local Plan should show how the policies and proposals help to ensure that the social,
environmental, economic and resource use objectives of sustainability will be achieved.
3. Effective: deliverable over the plan period and based on effective joint working on cross-boundary
strategic matters.
4. Consistent with national policy: enabling the delivery of sustainable development in accordance
with the policies in the NPPF. The NPPF is considered to be the government’s explanation of what
sustainable development means for planning policy therefore compliance with the NPPF is key
unless a locally justified departure is clearly evidenced.

Whilst BAL are supportive of the Local Plan and concur with the exceptional circumstances outlined in Policy P1 for releasing land from the Green Belt, BAL consider that minor amendments should be made to the wording of planning policies P1 and UK2 to help deliver a sound Local Plan.

Furthermore, additional policies should be included to ensure that West Car Park (circled in red
below) is safeguarded for future Airport use and any future development near the Airport boundary
does not harm Birmingham Airport’s aerodrome or airspace. These issues will be discussed in turn
below.
The plan below is taken from the Local Plan Proposals Map and shows the Airport, the UK2 site and
West Car Park.
Extract taken from SMBC Local Plan – Draft Submission
Policy P1 states that following in respect of Birmingham Airport:
“Policy P1 – UK Central Solihull Hub Area

ix. The Council will support and encourage further development needed for operational purposes such as passenger and freight facilities, terminals, transport facilities and other development that supports operational needs, or which allows the capacity of the extended runway to be maximised.
x. The Council will also support a broad range of ancillary and complementary facilities including hotels, administrative offices car parks and other appropriate facilities needed to serve the needs of air travellers using the Airport.

Proposals should be justified in terms of scale and in terms of supporting the Airport function and be appropriately located so as not to detract from Airport function.

xi. Where justified, development for Airport related uses beyond the Airport boundary will be permitted, providing that it accords with other policies in the Plan, including Green Belt policy. This will include opportunities within the allocated employment site (UK2).”

BAL Comment
Policy P1 should be amended to include reference to development for Airport related uses proposed
by Birmingham Airport only and the development of urban mobility. This ensures that the future of a
key economic asset is safeguarded.
Furthermore, reference should also be made to West Car Park, which may be required to provide
additional capacity for Airport related development beyond the 15-year horizon outlined within the
Airport Master Plan (see circled site above). The Local Plan is currently silent on its intentions for
this site.

Policy UK2 states the following:
“1. This site is allocated for employment development to meet local employment needs, needs associated with the key economic assets in the UK Central Solihull Hub Area, and for a potential relocated Household Waste and Recycling Centre and Depot.
2. Development of this site should be consistent with the principles of a Concept Masterplan for this site, which is expected to include the following:
i. No development within any area of higher flood risk zones;
ii. Relocation of the existing sports provision off Damson Parkway to a suitable site in the vicinity (see below);
iii. The existing sports provision off Damson Parkway will not be available for development until a suitable alternative site
is provided and ready for use, within the vicinity of the existing sites;
iv. The alternative site must be agreed with the governing bodies and Sport England;
v. The alternative site must be in accordance with the relevant policies of the plan, in particular Policy P20;

3. Likely infrastructure requirements will include:
i. Development of the site should provide flood alleviation to Damson Lane;
ii. The Low Brook corridor shall be significantly improved and turned into a high quality linear attenuation and water quality improvement area for SuDS;
iii. Highway improvements as required and access improvements along Damson Parkway and Damson Lane;
iv. Appropriate measures to promote and enhance sustainable modes of transport including pedestrian and cycle connectivity to surrounding residential areas;
4. Green Belt enhancements will include:
i. Improvements to environmental quality of remaining Green Belt between the main urban area and Damson Parkway;
ii. Improvements to the environmental quality of Green Belt to the east to enhance/extend the important grassland habitats to the east of the site.

5. The Concept Masterplan document should be read alongside this policy. Whilst the concept masterplans may be subject to change in light of further work that may need to be carried out at the planning application stage, any significant departure from the principles outlined for Site UK2 will need to be justified and demonstrate that the overall objectives for the site
and its wider context are not compromised.

BAL Comment
In accordance with intended connotations of the above mentioned policy, it is recommended that the
following clauses should be added to the policy:

“6. The concept Masterplan document should be submitted alongside evidence of meaningful
engagement with key stakeholders, landowners and interested parties.
7. The concept Masterplan should not prejudice Birmingham Airport’s ability to achieve it’s
sustainable growth aspirations and serve the region as a key economic asset.”

Policy UK2 continued:
This is an employment led land release of c94ha which will provide additional employment land to meet local needs, including future expansion for JLR and JLR related activities and ancillary development for Birmingham Airport. It will also provide an option for a relocated Household Waste and Recycling Centre and Depot, which will address needs set out in Policy P12 and enable the delivery of Site SO2 housing allocation. The release of the site from the Green Belt will meet
local employment and waste management needs, and needs associated with the key economic assets within the UK Central Solihull Hub Area.
The area east of Damson Parkway lies in a moderately performing parcel whilst the land to the west is lower performing in the Green Belt Assessment. Both parcels have been affected by development by JLR permitted under very special circumstances, so their contribution to Green Belt purposes is reduced. The site is in an area that has low capacity to accommodate change in the Landscape Character Assessment. The site performs reasonably well in the Sustainability Appraisal with three times as many positive or neutral effects than negative, and the only significant negative effect due to the size of the site.
A Level 2 Strategic Flood Risk Assessment has been undertaken for this site, as a small part adjacent the eastern boundary in the corridor of Low Brook lies within higher flood zones. This area is included within the green infrastructure proposals for the site, and development will be restricted to areas within flood zone 1 and should ensure that flood risk is not increased
to surrounding land uses. The low point on Damson Lane is known to flood significantly during rainfall events, so development at this point will be required to provide flood alleviation benefits to protect existing and proposed infrastructure.
The Low Brook corridor on the south eastern boundary of the site has the potential to be significantly improved and turned into a high quality linear attenuation and water quality improvement area for SuDS.
The exceptional circumstances justifying its release are set out in Policy P1. Compensatory improvements will be required for the loss of Green Belt as set out in the policy.
A concept masterplan will be developed to help guide development of this site.”

BAL Comment
In line with the Local Plan soundness criteria set out above, in order to ensure that the Local Plan is
fully justified, BAL consider that the above mentioned policy should provide more clarity on how the
Masterplan will be developed. This includes guidance on significant stakeholder and landowner
engagement and how such engagement will be recorded and addressed.

Aerodrome Safeguarding
As a statutory consultee, BAL is consulted on developments that are likely to impact on aerodrome
safeguarding. BAL is responsible for protecting the airspace around an aerodrome to ensure no
buildings or structures cause danger to aircraft either in the air or on the ground. This is achieved
through the ‘Obstacle Limitation Surfaces’ (OLS).
Whilst BAL support local and regional growth, this must be balanced against the need to safeguard
the Airport aerodrome and airspace. This is done through the aerodrome safeguarding process. This
process should be referenced within the Local Plan with a separate planning policy included to
ensure that any development (not just waste as is currently the case) with the potential to impact on
the aerodrome and airspace should be referred to BAL prior to the planning application being
submitted.
SMBC do consult with the BAL on planning applications close to the Airport boundary. However, the
process is often time consuming and the applicant often has very little knowledge of the safeguarding
process, what it might entail and crucially, how it might impact on timescales for determination of
planning applications.
Therefore, it is recommended that a new policy is added to the Local Plan, which deals specifically
with Aerodrome Safeguarding and encourages pre consultation with Birmingham Airport. Prior
consultation will benefit SMBC in meeting it’s statutory determination periods for planning
applications.
A brief explanation of the safeguarding process is provided below:

Aerodrome safeguarding covers several factors:
• Protecting the integrity of radar and other electronic aids to navigation by preventing
reflections and diffractions of the radio signals.
• Protecting aeronautical lighting, such as approach and runway lighting, by ensuring that they
are not obscured by any proposed development and that any proposed lighting could not be
confused for aeronautical ground lighting.
• Protecting the aerodrome from any increased wildlife strike risk. In particular bird strikes,
which pose a hazard to flight safety.
• Preventing any construction processes from interfering with aerodrome operations through
the production of dust/smoke, temporary lighting or construction equipment impacting on
radar and other navigational aids.
When BAL is consulted on a planning application, a safeguarding assessment is undertaken to
identify potential hazards to the Airport operation, as follows;
Obstacle Limitation Surfaces (OLS)
The OLS is an area of specified dimensions provided around the airport, an example is the areas at
the end of the runways where aircraft take-off and land. These protected surfaces extend as far as
a radius around the airport of 15km. The dimensions create invisible protected surfaces and areas
of airspace with height restrictions by which no development should infringe into.
The OLS assessment needs to determine that the airspace is free from buildings or structures that
have the potential to cause danger to aircraft. The objective is to protect the surfaces and
communicate back to developers or Local Planning Authorities what the findings are.

Construction
Construction equipment and cranes have the potential to infringe the protected surfaces around the
aerodrome and can impact on radar and other navigational aids by their height and moving parts.
All crane applications will be assessed and may need a permit to operate.
Several potential hazards can be created from construction activities. These include, temporary
lighting which can cause glare or confusion to pilots and air traffic control, and earthworks and soil
disturbance provides a food source for birds.
Communications, Navigation and Surveillance (CNS)

Technical Safeguarding
Air Traffic Control uses a range of equipment to undertake communications, navigation and
surveillance of multiple aircraft and vehicles. The primary task of air traffic control is to maintain safe
separation of aircraft on the ground and in the air.
Protecting the integrity of signals emitting from radar and electronic aids is critical, such as reflections
and diffractions (bending) of the radio waves (signals). Signals must conform to very high standards
of accuracy and interrupting them can cause degradation. An aircraft flying at night or in the fog must
be confident the signals provided are accurate. The process of assessment is known as “Technical
Safeguarding”.

Wildlife Hazards
Wildlife includes animals and birds on and near the aerodrome. This might include foxes, badgers
or even muntjac deer. The primary concerns are for birds and the risk of an aircraft striking a bird or
flock of birds. The flight paths, roosting and feeding sites are of interest and the airport is responsible
for continuous monitoring out to 13 kilometres.
Developments can easily influence bird behaviours. An example of this is a water park or landfill site,
which birds will be attracted to, they can fly up to 30 kilometres in a day to feed and back again,
twice. The generation and storage of putrescible waste will attract birds. These may cause the flight
paths of the birds to change and this could bring them across the runway or near to the airport.
Developments and contract works could also act as nesting or feeding areas for birds, such as large
pitched roofs, large landscaping schemes, earthworks which expose food for birds, buildings and
structures with perching opportunities.
Instrument Flight Procedures (IFP’s)
IFPs are rules established by aviation governing bodies allow aircraft to fly by reference to the
instruments in the aircraft. Navigation is accomplished by provided by electronic signals and aircraft
fly using these as a reference in defined areas of airspace. The Airport has Standard Arrival Routes
(STAR’s) and Standard Instrument Departures (SID’s) which are protected to allow a safe traverse
by aircraft.
IFP’s must always be clear of obstacles. The IFP surfaces must not be infringed and if they are it
may cause flights to be diverted or cancelled. Long term, this may impact on future airspace
development.

Lighting
Lights from local car parks, or construction sites, buildings or even street lighting can create dazzle
to pilots or air traffic controllers.
Ground lights on and approach lights to the runway provide a light pattern which pilots can
distinguish. The lighting pattern provides assurance to pilots for the critical task of landing the aircraft.
Unwanted lighting may cause confusion at the critical stage of landing or prevent an air traffic
controller from seeing important information.

Drones
Restricting drone operations to prevent impacts to aircraft safety is very important. This growing
phenomenon offers several challenges, but we have a permit system in place which allows drones
to be flown safely on or near the airport. Drone pilots must only do this if they meet specific criteria
and with express permission of Air Traffic Control.

Public Safety Zones (PSZs)
At the ends of our runway are areas provided to protect people. A PSZ is an area of land where
development is restricted in order to prevent people living and working within it. This minimises the
risk to people in the event of an accident. Certain amenities are permitted such as parks and golf
courses, but not permanent dwellings.

5G Technology
Whilst BAL supports technological advancements, the Airport does have a responsibility to ensure
that the aerodrome communication, navigation and surveillance equipment used for the safe
operation and navigation of aircraft are protected from any harmful interference.
Ofcom have identified an issue with the spectrum used by 5G when in the vicinity of aerodrome
radar bands, as well as the specification surrounding the permitted out of band emissions of the
mobile infrastructure, which could cause interference within the radar band.
Ofcom Guidance: https://www.ofcom.org.uk/__data/assets/pdf_file/0018/114264/3.4-Radar-Coordination.
pdf

Considering the above, BAL are requesting that planning applications (including pre-application
submissions) should include an assessment to demonstrate how there would be no harmful impact
on Birmingham Airport’s protected Radar system, as a result of any proposed development involving
5G technology.
In order to protect the Airport aerodrome and airspace, Birmingham Airport recommend that a new
safeguarding policy in included within the Local Plan, which can be informed by the text provided
above.
BAL are mindful of the positive impact the airport has and the potential the airport has to continue to
make a significant contribution to the regional and national economy and will continue to work
proactively with SMBC and our surrounding neighbours, residents, stakeholders, landowners,
businesses and visitors in the development of the next stage of the Local Plan.

Additional housing allocations at small to medium sites, such as ‘Land off Old Station Road’, would provide a ‘buffer’ and mitigate against the risk of stalled delivery at larger sites.

Dear Sir / Madam,

Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').

I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.

Kind regards

None suggested reiterates earlier points and commitment to bringing forward development. Highlights current developments including work being undertaken to bring forward alternative parking associated with the interchange station and to enhance Birmingham International Station.

See attached form

Policy P1 UK Central Solihull Hub Area UK and P1A Blythe Valley Business Park should demonstrate the importance of transport master plans, with opportunities being demonstrated which can reduce car dependence and fully promote sustainable transport.

See Attached Letter and Representation Form.

RECOMMENDATION:
- Add reference to WMCA’s HS2 Connectivity Package under Policy P1 UK Central Solihull Hub Area.

See Attached Letter and Representation Form.

The following site specific elements in P1 relating to Arden Cross should be addressed: Passenger facilities no longer feature in the Birmingham Airport Masterplan 2018 and should be deleted. The phasing set out in the Hub Growth and Infrastructure Plan (January 2018) is now superceded and does not align with the current LPR plan period (2036).



Amend or remove paragraphs 85 to 87 as the development trajectories are now out-of-date and do not align with the current LPR plan period. For example, paragraph 85 makes reference to new homes being delivered by 2033 when the plan period is to 2036.
• Remove paragraph 92 as it refers to the Garden City principles explored six years ago, which do not align with the current mixed use urban neighbourhood place-making principles in the Arden Cross Masterplan.
• The mix of land uses set out at paragraph 93 are accurate and accord with the Arden Cross Masterplan and should be reflected in Policy P1 and Policy UK1.

see attached document

Further information is requested from the Council in relation to the planned trajectory and stages of delivery of these housing numbers. We understand that such details are not currently available. It is not clear how much residential development will be delivered around the area safeguarded for HS2 and the Interchange station and whether delivery will be effected by the safeguarding and or construction priorities. To confirm deliverability of the 500 dwellings, we consider that further information in relation the planned delivery of the site is provided to confirm that the delivery of the HS2 station does not prejudice the delivery of the 2,740 homes to be delivered up to 2036. We request further evidence from the Council to ensure that conclusions regarding housing delivery are effective to deliver a sound plan.
The proposals for circa 20% of the housing target in a single location should be reviewed as they are not considered to be sound, deliverable or provide an effective or justified strategy.

See attached documents.

Our client is the landowner of the Gables Hotel, located at Old Damson Lane, Solihull B92 9ED. The Hotel is immediately to the south of, and with access to, the A45 Coventry Road, opposite Birmingham Airport. The Hotel is located within the UK Central Hub as identified within the SLDP Proposed Policies Map and subject to an allocation within the SLPD Policy P1 (UK Central Solihull Hub Area) and UK2 (Land at Damson Parkway), and thereby its removal from the Green Belt.
The Gables Hotel presently has 18 bedrooms, running at 90% occupancy. Approximately 50% of our client’s trade is related to the NEC and Birmingham Airport. The next largest customer is Jaguar Land Rover (JLR), for whom the Hotel accommodates contract shift staff, usually up to 4 nights a week.
Our client would like to modernise and expand their hotel operations to meet the existing and growing demand arising from their existing customer base and to attract new customers, the demand of which they cannot currently accommodate. Expansion would not only achieve a more economically sustainable operation but would also provide an opportunity to modernise the accommodation and conference offer to better meet the changing needs of customers.
Despite the Hotel’s location towards the centre of the UK Central Hub, with the Birmingham Airport and NEC to the north and JLR to the south, and good access via the A45 Coventry Road, a strategic arterial road from Birmingham city centre to the M40, expansion has previously been stifled by the Green Belt designation.
In 2017, our client sought to make a significant investment in the Hotel with a major rebuilding works but was refused planning permission (PL/2017/00371/PPFL, refused 15/06/2017) for which a key reason was ‘inappropriate development within the Green Belt’. As a consequence, the Hotel been at a disadvantage to the more recent hotel development further along the A45 Coventry Road in terms of its marketability.
Accordingly, our client welcomes the opportunities arising from the UK Central Hub allocations and its removal from the Green Belt and considers that the opportunities this provides would in return provide valuable support to the key objectives of both SLPD Policy P1 and UK2 in return.
Policy P1 UK Central Solihull Hub Area
Sub paragraph 1. States “…the Hub Area offers the greatest potential for growth in the Borough …; and will make a significant contribution to the wider West Midlands economy…”
Sub paragraph 2. States “The Hub Area, indicated on the Policies Map, embraces Birmingham Airport, the National Exhibition Centre (NEC), Birmingham Business Park and Jaguar Land Rover, each of which are key economic assets in their own right. This Plan seeks to support the future aspirations of the key economic assets in a holistic, well connected way, and to bring forward development of the area surrounding the HS2 Interchange Station at Arden Cross.”
and
Sub paragraph 3. States “…Development proposals within the Hub will be expected to demonstrate how they achieve the following key objectives…” and
i. Contribute towards sustainable and inclusive economic growth, the continued success of the key economic assets and …
iv. Encourages the use of modes of travel other than the private car;
vi. Create distinctive and unique places with a strong sense of identity … whilst maximising the efficient use of land;
vii. Support inclusive economic growth by supporting employment and supply chain opportunities …
The Hotel is possibly the closest small hotel to the JLR plant and within walking or cycling distance. The Hotel does offer some travel and shared lift options. With a larger facility these more sustainable modes of travel would be more economic and affective. The Hotel supports the key economic assets by providing accommodation in close proximity, specifically in respect of JLR and their workforce, but also in providing accommodation for operational workers during the build phase and customers during the running of conferences, exhibitions and concerts, and for travellers arriving/departing from Birmingham Airport and in the future the HS2 railway interchange. The opportunity to undertake major works to the Hotel would enable a modernised design both internally and externally, creating a new sense of identity for the site and improving the overall impression along this key approach to Birmingham city centre.
Notably, Policy P1 provides specific support to the key assets for which it is highlighted that Sub paragraph 4 states:
In respect of Arden Cross:
ii. The Council will support proposals that include passenger facilities, offices, and residential, together with associated ancillary uses (including retail, leisure and hotel developments of an appropriate scale).
In respect of the NEC:
v. To enable the NEC to meet its future aspirations and to drive economic and employment growth, the Council will enable a broad range of developments to enhance the visitor offer, diversity facilities and increase international competitiveness.
vii. The Council will also support a broad range of ancillary and complementary facilities needed to enhance visitor experience and support operational needs. These will include hotels ….providing it is justified in terms of scale, its support for the NEC as a whole and is appropriately located within the NEC.
In respect of Birmingham Airport:
x. The Council will also support a broad range of ancillary and complementary facilities including hotels, …. Proposals should be justified in terms of scale and in terms of supporting the Airport function and be appropriately located so as not to detract from Airport function.
xi. Where justified, development for Airport related uses beyond the Airport boundary will be permitted, providing that it accords with other policies in the Plan, including Green Belt policy. This will include opportunities within the allocated employment site (UK2).
In respect of JLR:
xiii. The Council will support and encourage the development of JLR within its boundary defined in this Local Plan. This will include a broad range of development needed to maintain or enhance the function of JLR as a major manufacturer of vehicles.
xiv. Site UK2 on the Policies Map, will be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant
In respect of Birmingham Business Park:
xvii. The Council will also support a broad range of ancillary or complementary uses needed to enhance the attraction of the business park to occupiers. These could include hotels and commercial/business/service uses of a scale that does not compete with existing or planned facilities outside of Birmingham Business Park.
It is clear that our client’s Hotel is ideally placed to support these key economic assets and as an existing hotel on a key strategic approach road to the city centre. Accordingly, our client supports Policy P1 and in return would provide support to meeting its objectives.
Policy UK2 Land at Damson Parkway
Sub paragraph 2 identifies that the allocated site is to be developed in accordance with Concept Masterplan, that is yet to be developed and thereby not included within the Solihull Local Plan Concept Masterplans (October 2020) that forms part of the plan-making process.
Our client welcomes the future development of the Concept Masterplan as an opportunity to provide certainty to their future investment plans and as a landowner within the allocation area requests the opportunity to actively contribute to its formation.

It is recommended that the policy is amended to specify the quantum of growth which the hub will deliver over the plan period.

It is recommended that the policy is linked to clear plans showing where the residential growth will be delivered within the hub boundaries in order to show deliverability.

Representations to the Local Plan Review Regulation 19 consultation: Land at Bickenhill Road, Marston Green
Please find attached representations and their appendices plus the relevant form on behalf of our client L&Q Estates.
I would be grateful if you could acknowledge receipt

It is recommended that the policy is amended to specify the quantum of growth which the hub will deliver over the plan period.
It is recommended that the policy is linked to clear plans showing where the residential growth will be delivered within the hub boundaries in order to show deliverability.

See attachments.

Land at four ashes road dorridge

The heading for and the text of paragraphs xii-xv of Policy P1 that relates to JLR and Site UK2 should be amended as follows:
“Jaguar Land Rover (JLR)/and Site UK2
xii. The Council will support JLR to compete and further its success in the global vehicles industry. To achieve this, the JLR site will need to continue to evolve and where necessary expand, with the only realistic opportunity for significant expansion being to the north east.
xiii. The Council will support and encourage the development of JLR within its boundary defined in this Local Plan. This will include a broad range of development needed to maintain or enhance the function of JLR as a major manufacturer of vehicles.
xiv. Site UK2 on the Policies Map, will be released from the Green Belt to accommodate employment development as set out in Policy UK2. This will include employment development to meet wider identified needs, together with that required to meet the additional needs of JLR and JLR related activities and ancillary development to Birmingham Airport. . The exceptional circumstances justifying the removal of the land from the Green Belt are set out in the justification to this policy.
xv. It will be expected that proposals for the development of Site UK2 will be promoted in a comprehensive and coordinated manner that can make provision for a phased approach, if required”.
2. Paragraphs 104 and 105 and the associated heading should be amended as follows:

“Jaguar Land Rover (JLR)/and Site UK2
104. The Council will continue to support the further development and modernisation of the vehicles plant in order to enable its continued success in the competitive global vehicles market. JLR is constrained in terms of its ability to expand by its location within the main urban area. To reflect this and having regard to the vital importance of JLR to the region’s economy and to job creation, Policy P1 includes proposals to remove land at Damson Parkway from the Green Belt to support this aim. As set out under Policy UK2, in addition to meeting JLR needs, Site UK2 will also provide for wider employment opportunities to meet the needs identified in Policy P3, as well as for potential ancillary requirements for Birmingham Airport.
105. Part of Site UK2 has also been identified as a potential location for a relocated Household Waste and Recycling Centre and Council Depot subject to ongoing options assessment by the Council. Further justification for this proposal is included in Policy P12.”
3. The fifth bullet point of Paragraph 106 should be expanded as follows:

“A significant part of the site already has planning permission and has been constructed for use as a despatch facility and logistics operations centre for Jaguar Land Rover, as well as the associated primary road infrastructure works for the site. These proposals were which was justified with very special circumstances”.
4. The 8th bullet point of Paragraph 106 relating to the Household Waste and Recycling Centre should be removed entirely.

See attachments

Policy P1 should be amended to specify the quantum of growth which the hub will deliver over the plan period,
and be linked to clear plans showing where the residential growth will be delivered within the hub boundaries in order to show deliverability.

Land at Damson Parkway - see attachments for full details

Further information on the planned delivery of the housing and infrastructure related to the site is required to ensure that delivery of the HS2 station does not prejudice the delivery of the 2,740 homes to be delivered up to 2036.
The proposals for circa 20% of the housing target in a single location should be reviewed.

Policy BL1
References contained at point 5 of the policy clearly indicate that there is a significant question
mark over its deliverability. The policy states “Until such time as these facilities [existing sports
facilities south of Tythe Barn Lane] are appropriately relocated or robust plans have been
confirmed to secure a timely relocation that would prevent the closure of any associated
clubs….development of the site will not be supported”. Until the relocation of the sports
pitches that enable the deliverability to take place on site BL1 (land West of Dickens Heath) it
cannot be justified in policy terms. There are significant delays associated with resolving this
issue; firstly suitable alternative locations have to be found for the pitches to be relocated to;
and secondly, those sports pitches have to be laid out and often that takes a 2 to 3 year time
span to set them up because of the need for specialist grass and proper drainage and sub soil
preparation for that grass to be laid.
Paragraph 16 of the National Planning Policy Framework (‘NPPF’), requires plans to “be
prepared positively, in a way that is aspirational but deliverable”. Savills emphasis
This reference provides a very real risk to the deliverability of this allocation and something we
consider the Council should not be leaving to aspiration or fortune. The proposed allocation of
the 350 homes is being put at jeopardy where alternative locations cannot be found for the
existing sports pitches and on this basis the site should only be safeguarded at this stage and
an alternative site such as site 192 (land east of Tilehouse Lane, Tidbury Green) be included
in the plan as this site is not the subject of these deliverability concerns and performs lower in
Green Belt terms than BL1.

We consider that there are several options the Council have to make this allocation sound.
Firstly they should confirm the latest position on the progress made on the relocation of the
sports pitches required to make BL1 deliverable. As written BL1 is not justified or effective as
the text (bullet 5) is clear that until these facilities are relocated or robust plans the relocation
has not been confirmed “development of this site will not be supported”. This is not positive
planning and puts much needed housing delivery at risk. Secondly the Council could consider
whether a larger area of land around Tidbury Green such as land east of Tilehouse Green
land could be considered as part of the comprehensive strategy to deliver the housing as it
does not require the relocation of sports pitches. This could mean that some or all of the
sports pitches remain in situ. Until the position regarding the sports pitches is made clear then
either the allocation should be downgraded to safeguarded land or an alternative allocation is
provided that is deliverable site such as the site to the south (site 192 ) - land east of
Tilehouse Lane, Tidbury Green.
In Green Belt terms site 192 scores 6 which is less (i.e. lower performing in Green Belt terms)
than the proposed allocation BL1 (score of 7). In landscape sensitivity terms site 192 scores
the same (as they are in the same sub area - LCA2) as BL1.
In allocating site 192 and safeguarding site BL1, we consider the plan would be more effective
and sound. This representation should be read in conjunction with representations made to
policies P1 and P5 which are fundamental to the Borough’s housing strategy.

Policy P1
Officially, the Government state that the HS2 Interchange station will be completed by 2026. Given delays that often happen on large infrastructure project, we consider that this timescale is likely to be pushed back. Paragraph 280 of the draft plan states that the HS2 line is ex-pected to open between 2029 – 33. Paragraph 89 of the plan refers to 2,740 homes being delivered up to 2036. If the plan is adopted in early 2022, with two years lead in for planning and a year for site works, development may not begin until 2025. This allows for eleven years to develop out the 2,740 units. If this was spread out over eleven years equally, this would equate to 249 dwellings per annum. This is a very high level of delivery, that we do not con-sider has been adequately demonstrated as being deliverable, considering delays in delivery of the HS2 Station.
It should be noted that in 2018, the Hub Framework stated that delivery of 2,240 homes during the plan period would include up to 550 homes being delivered at the NEC up to 2022. We have reviewed Solihull’s online application register and cannot see reference to an application for residential development at the NEC. We therefore consider that the levels of delivery en-visaged, even in the early stages of the plan period are overambitious. We therefore consider that this policy is not effective in the way that it is currently drafted. Furthermore, we under-stand that UK Hub requires a new connector road from the Coventry Road to a new motorway junction on the M42, being a “just in time” for JLR and its Damson Parkway units. Whilst it has received in-principle go-ahead, the land has to be purchased and the road has to be built which could involve a significant delay.
We have requested further information form the Council in relation to the planned trajectory and stages of delivery of these housing numbers. We understand that such details are not available. We are therefore also not aware of how much of this housing delivery the Council considers will be required to be delivered before the HS2 station is completed.

We therefore request further information in relation the planned delivery of the site and reas-surance that the delivery of the HS2 station does not prejudice the delivery of the 2,740 homes to be delivered up to 2036. Notwithstanding we challenge the assumed delivery rate proposed by the Council in this location and the provision of circa 20% of the overall dwelling provision in a single location in a high density format which does not accord with the Bor-ough’s housing requirement for predominantly family housing.
We request confirmation from the Council of the amount of housing and related infrastructure that will be coming forward for completion before this date. A whole community is needed to be formed from scratch. Although this is not beyond the realms of possibility, we request further evidence from the Council to ensure that conclusions regarding housing delivery are effective to deliver a sound plan.
The proposals for circa 20% of the housing target in a single location should be reviewed as they are not considered to be sound, deliverable or provide an effective or justified strategy.

Policy P4A
We do not consider that this policy is effective (NPPF paragraph 35) as it does not provide
developers with flexibility and the mix of housing should be considered at the application stage
in accordance with the Housing and Economic Development Needs Assessment 2020 (‘HEDNA’).
For example, as stated under point 9 of Policy P4A, it may be appropriate for sites that
are within the town centre to provide a higher percentage of 1 and 2 bedroom dwellings compared
to a site on the edge of a rural settlement. The HEDNA sets out a range for of mixes for
each dwelling size. We support the Council providing some guidance on housing mix but this
should accord with the mix proposed in the HEDNA.
The NPPF (Annex 2) sets out a definition of affordable housing and identifies affordable housing
tenures which includes: affordable housing for rent, starter homes, discounted market
sales and affordable routes to home ownership. Policy P4A sets out a proposed tenure requirement
for 65% social rent and 35% shared ownership within the Borough. The HEDNA
has been used as the evidence base to support this policy. The HEDNA has identified that
there is a need for affordable rent within the Borough (paragraph 7.101). The HEDNA also
states that there is a clear requirement for both social and affordable rent but has recommended
to the Council that they do not propose a rigid mix on the split between social and
affordable rented housing. Furthermore, shared ownership is a narrow offer of affordable
housing that is not social rented. Intermediate housing is considered to be a more appropriate
definition to use.
Affordable Rent is also encouraged by Homes England and should be included in the Council’s
list of tenures. Nevertheless, Policy P4A makes no provision for affordable rent. Therefore we request that the Policy P4A is amended to refer to both affordable rent and social rent.

The HEDNA sets out range for the proposed affordable housing mix which provides flexibility,
it is not clear how or why the Council has chosen to apply fixed percentage requirements for
social rented and shared ownership homes. Each application for residential development
should be considered on its merits and the type and mix of affordable housing should be discussed
with the Council’s housing and planning departments at the pre-application stage. We
consider that this will make the policy more effective than simply applying a fixed blanket approach
across all residential sites in the borough.
Policy P4A (bullet 6) should be amended to include reference to a requirement for social and
affordable rent rather than purely social rent. The policy should also be amended to replace
“shared ownership” with “intermediate housing” which includes Shared Ownership, Shared
Equity, Discounted Market Housing for Sale etc

Policy P4C
Point 1 of Policy P4C lists a range of criteria that the Council will have regard to when negotiating housing mix on allocated and windfall major development sites. Within the list it notes that the “current indicative Borough-wide needs assessment” and “the existing mix of market housing and local housing demand” will be taken into account. Point 3 of Policy P4C goes on to set out specific requirements for housing mix. We do not consider that this policy is effective (NPPF paragraph 35) as it does not provide developers with flexibility and the mix of housing should be considered at application stage in accordance with the Housing and Economic Development Needs Assessment 2020 (‘HEDNA’).
Paragraph 122 of the National Planning Policy Framework (NPPF) sets out the importance of planning policies to make efficient use of land taking into account: the identified need for different types of housing, local market conditions and viability, the availability and capacity of infrastructure, the desirability of maintaining an area’s character and setting and the importance of securing well-designed and attractive places. The housing mix proposed in the HEDNA provides a range for each dwelling type which reflects the ‘latest’ evidence in 2020. However, many sites are different in character and surroundings and therefore a blanket approach to the unit mix is not considered appropriate or sound. Furthermore, market demand can change and so this ‘latest’ evidence may not be representative of need when planning applications are submitted in the future. As developers and national housebuilders have a focus on building and products that are deliverable and meet market needs, the policy should not provide a fixed dwelling mix and a blanket approach to the size and mix should be avoided as not all residential sites will be appropriate for this mix. A rigid approach to mix and house type could have a negative effect on development viability, leading to inflexibility and result in unnecessary delays to developments coming forward.
In addition to the above, the policy does not make any reference to the approach that may be required where there is an existing proposed housing mix set out in ‘made’ Neighbourhood Plans (‘NP’).

We request that the Council removes reference to mix (point 3) from Policy P4C and instead refer indicative housing mix ranges in accordance with the HEDNA within the explanatory text. Developers should be ‘encouraged’ and not ‘required’ to accord with the mixes set out in the explanatory text. This is the approach the LPA has taken to density requirements (Policy P5) in the Submission Draft and we consider this flexible approach should be used for market housing mix. Market demand at the time of the application should play an important role in determining the mix of dwellings delivered on a site.

Policy P4D
Policy P4D requires allocated sites of 100 dwellings or more to contribute 5% of open market
dwellings in the form of self and custom build plots on each of the development sites. We
object to this requirement and do not consider that the Council has provided sufficient
evidence to justify a threshold of 100 dwellings or for these sites to contribute 5% self and
custom build homes. The PPG (Reference ID: 57-025-201760728) sets out ways in which the
Council should consider supporting self and custom build homes which includes: developing
policies in their Local Plan for self-build and custom housebuilding and “engaging with
landowners who own sites that are suitable for housing and encouraging them to consider
self-build and custom housebuilding” [Savills emphasis]. There is no requirement in the PPG
for self or custom build plots to be provided as part of new housing allocations and landowners
should only be ‘encouraged to consider’ promoting their land for self and custom build
housing. The policy has been prepared without any regard to the potential for unintended
consequences arising from this approach which could have a negative impact on the policy
delivering the 5% self or custom built homes. We consider the policy to be ineffective.
Paragraph 195 of the Submission Draft states that there are 370 individual entries on the
Council’s ‘Self Build and Custom Housebuilding Register’. The register may provide an
indication of the level of interest, but this needs to be analysed in further detail to uncover the
specific requirements of respondents. Furthermore, this register does not test whether people
have the means to acquire the land and privately construct their own property or whether their
requirements align with being located on a large new housing development. Without this
exercise having been undertaken and supporting the Council’s conclusions, we do not
consider that Policy P4d to be justified or effective.
Furthermore, there are also practical issues to consider in providing self and custom building housing plots on an allocated site. For example, the day to day operation of such sites and
consideration of potential health and safety issues of having multiple individual construction
sites within one development. Other considerations that do not appear to be factored in
include where a large housing site is the subject of a design code. What approach in the
Council expecting self-build projects to take in the design of their “bespoke” self or custom
built home?

Policy P4E
Policy P4E requires major residential development sites to be built to Category M4(2) building regulations and at least 5% of dwellings to be wheelchair user friendly. The Planning Practice Guidance (PPG) states that Councils have the option to “set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access” where there is a justified need (Savills emphasis) for this requirement (Reference ID: 56-002-20160519). The PPG does not state what level of provision should be required within Local Plan policies.
Requiring all new dwellings to be built to the Category M4(2) standards will result in larger dwellings and in turn less dwellings being delivered per net developable hectare. The NPPF is clear that planning policies should support development that makes efficient use of land (Paragraph 122). Furthermore, as a Green Belt authority with limited brownfield redevelopment opportunities (Housing Land Supply table on page 69 of the consultation document) and part of a Housing Market Area with a shortfall in housing (NPPF Paragraph 123), Solihull Council should be making the most efficient use of land on the Green Belt sites proposed to be released in order to avoid significant Green Belt release in future Local Plan Reviews. We therefore consider that the requirement to build all dwellings to Category M4(2) standards should be evidenced and balanced against the need to make the most efficient use of land available. Without this approach, the policy will not be consistent with national planning policy or effective, making Policy P4E unsound.
In addition to the above, the PPG is clear that “Local Plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable, neither of the Optional Requirements in Part M should be applied” (Reference ID: 56-008-20160519) [Savills emphasis]. Policy P4E includes 4 criteria (Point 5) for how the policy will be applied flexibly which relate to: viability; the need to achieve a successful development; and whether the standards would prejudice the realisation of other planning objectives. However, none of the criteria make reference to the suitability of a site to accommodate accessible dwellings, for example their topography or local demographic requirements. We consider that the policy should be amended to accord with the PPG guidance or evidence provided which justifies the position being proposed in the policy.
Policy P4E also requires developments of 300+ dwellings to provide specialist housing or care bed spaces. By taking this approach it is appears that there is a disconnect between the Council’s housing strategy and the health and well-being of the various communities with differing specialist and health requirements across the Borough. Although the policy does not state how many dwellings or care bed spaces should be provided as part of the development, the viability appraisal has assumed that 0.5ha of land on each site will be delivered and has concluded that this will improve viability on the site as the land can be sold to a specialist provider. No evidence is provided to justify 0.5ha provision. In our experience a full care village will require sites larger than this and so the requirement put forward in this policy may only cover part of the specialist housing requirement it needs to.
We consider that this requirement is ambiguous and not shaped by effective engagement between the Council, developers and specialist care providers (NPPF paragraph 16) for the following three reasons:
1. There is no clear evidence which demonstrates or justifies how the Council has cho-sen the 300 dwellings threshold;
2. Point 6 of Policy P4E lists criteria where applications for specialist housing will be supported, for example, the site needs to be accessible to shops and services and the specialist housing needs to meet specialist building regulations. It is not clear whether this criteria will also be used to determine whether the 300+dwelling sites are actually suitable locations for specialist housing or care bed spaces; and
3. It is unclear whether all specialist and senior living providers will be interested in sites as small as 0.5ha and whether it is appropriate for specialist sites to be dispersed around the borough rather than provision being met on a few specifically allocated sites in suitable and accessible locations. Providers of open market housing and spe-cialist / senior living accommodation are usually different. Therefore, it is not as sim-ple as seeking these specialist requirements to be provided as part of the larger resi-dential allocations. Careful consideration of the demographic and health needs of each community need to be assessed and understood to enable appropriate sites to be identified that will meet the specialist and elderly care accommodation needs that is required for each community.
We consider that the requirement for 300+ dwellings sites to deliver specialist housing or care bed spaces should be removed from this policy and instead specific and suitable sites which accord with Point 6 of Policy P4E should be allocated within the plan to deliver this provision.

The requirement for all dwellings to be built to Category M4(2) standards should be removed unless evidence can be provided to justify this blanket approach or a percentage requirement that is evidenced based on an appropriate assessment of need to ensure that developments can still make the most efficient use of land in accordance with the NPPF (paragraphs 122 and 123).
The criteria listed under Point 5 of Policy P4E should be amended to state “Site specific factors which may make step-free access unsuitable or unviable”. For example not every site identified is flat and able to accommodate level access in a uniform matter.
The requirement for 300+ dwellings to deliver specialist housing or care beds paces should be removed from this policy and specific sites for specialist and senior living should be allocated to deliver this specialist provision. This will ensure that the requirements of Point 6 are met.

Policy P5
Policy P5 states that the Council will allocate at least 5,270 dwellings to meet their housing
requirement of 15,017 dwellings between 2020 – 2036. This equates to 938 dwellings per
annum. The proposed number of allocated dwellings has decreased by 1,040 dwellings
between the Draft version of the Local Plan Review document (January 2019) (6,310
dwellings) and the Submission Draft (5,270 dwellings). From our understanding, three
allocations have been removed since the Draft version (Sharmans Cross Road, Jensen House
and TRW/The Green) for 790 dwellings, four allocations have increased their capacity (East of
Solihull, Lavender Hall Farm, Oak Farm and Pheasant Oak Farm) by 235 dwellings and seven
of the remaining allocations have seen a reduction in their capacity by 485 dwellings.
Furthermore, 600 dwellings have been added to the windfall category. Given that this is
meant to be a plan-led process we do not consider this approach to meet the test of the plan
being positively prepared.
We do not support the proposed reduction in the number of allocated sites and the reduction
in site capacity for seven of the proposed allocations. As we have stated in our separate
response to Policy P4E, the NPPF is clear that planning policies should support development
that makes efficient use of land (Paragraph 122). Furthermore, as a Green Belt authority with
limited brownfield redevelopment opportunities (Housing Land Supply table on page 69 of the
consultation document) and part of a Housing Market Area with a shortfall in housing (NPPF
Paragraph 123), the Council should be making the most efficient use of land on the Green Belt
sites proposed to be released in order to avoid significant Green Belt release in future Local
Plan Reviews.
The Housing Land Supply in the table of page 69 of the Submission Draft document states
that across the plan period the UK Central Hub area is expected to deliver 2,740 dwellings;
2,240 dwellings at the NEC and 500 dwellings at Arden Cross. This equates to around 18% of
the proposed housing requirement for the Borough (15,017 dwellings). Due to the amount of
development proposed in this area, we consider that the majority of dwellings delivered will be
apartments. The Council should be seeking to deliver a balanced housing portfolio across the
Borough. By relying on 18% of the provision in one location and all potentially high density
living which doesn’t meet the needs of most families, we do not consider the Council to be
presenting a positively prepared plan nor is this strategy considered to be justified or effective.
Furthermore, having reviewed the evidence base for the UK Central Hub area, we do not
consider that 2,740 dwellings will be delivered at the NEC and Arden Cross between now and
2036. Firstly, the evidence documents seem to show different housing figures for the sites For
example, the NEC masterplan (2018) states that 2,500 dwellings could potentially be
accommodated on the site (page 34) whereas the Hub Framework Plan (2018) states that
1,780 dwellings could be delivered at the NEC. The Hub Framework Plan also sets out
potential timescales for development coming forward. Table 1 sets out a land use trajectory
which states that between 2018 – 2033 only 1,675 dwellings are expected to be delivered on
the Arden Cross and NEC sites. Between 2018 – 2022, circa 130 - 550 dwellings were
expected to be delivered at the NEC. With no planning application submitted at the NEC, we
consider it unlikely that any dwellings will be delivered by 2022. In light of this, we do not
consider that the expected housing delivery for UK Central of 2,740 dwellings up to 2036 to be
justified or supported by any of the Council’s evidence base and is therefore considered
unsound. We consider that the target for the anticipated number of houses to be delivered at
UK Central should be reduced to a more realistic level and additional housing sites added to
the portfolio rather than being overly focussed around UK Central or simply added to the
windfall provision. If almost 20% of the Council’s housing target is to be met by high density
accommodation in a single location, then this needs to be evidenced and justified as it
represents a departure from the Borough’s previous housing strategy and prevailing demand
for family housing. The constraints associated with the timing in the delivery of HS2 are also
not clear or explained.
Windfall provision has increased by 600 dwellings between the Draft version of the Local Plan
Review document and the Submission Draft and is 50 dwellings per annum more than the
adopted Local Plan. The NPPF states that there must be “compelling evidence” that windfall
sites will provide a reliable and realistic source of supply having regard to the strategic
housing land availability assessment, historic windfall delivery rates and expected future
trends (paragraph 70). As Solihull is constrained by Green Belt and there are only limited
deliverable brownfield land opportunities (77 dwellings identified on page 69 of the Submission
Draft document), we do not consider that 200 dwellings per annum of windfall dwellings is
realistic or an effective way to plan for the future. Rather than relying on windfall provision, the
Council should have additional sites identified and allocated and/or safeguarded for residential
development.
In relation to the contribution towards the HMA’s housing need, Solihull is currently proposing
to contribute 2,105 dwellings towards the Housing Market Area shortfall (paragraph 2.28 of the
Submission Draft document). We do not consider that this is a sufficient contribution from
Solihull Council towards the contributions (North Warwickshire is contributing an additional
3790 dwellings to support the Greater Birmingham HMA shortfall) and there is no evidence to
justify how the 2,105 dwelling “offer” was calculated. The most recent HMA Position Statement
states that the remaining shortfall up to 2031 is now estimated to be 2,597 dwellings.
However, it is now apparent that there will be a shortfall post-2031 (minimum 29,260
dwellings). As the plan period for the Submission Draft will cover up to 2036, we consider that
this should be addressed within the Local Plan Review. Once an agreement is in place
between the HMA authorities as to the distribution of the shortfall, a Statement of Common
Ground should be prepared to demonstrate to the Inspector that Solihull has complied with the
duty to cooperate (PPG Reference ID: 61-010-20190315) and that Solihull has addressed key
strategic matters through effective joint working and not deferred them to a subsequent Local Plan Review (PPG Reference ID: 61-022-20190315).
The housing need figure should be calculated at the start of the plan-making process and kept
under review until the Local Plan Review document is submitted for Examination (PPG
reference 2a-008-20190220). This is important for Solihull as at the same time as consulting
on the ‘White Paper – Planning for the Future’ document (August 2020), the Government has
also confirmed its intention to review the standard methodology. Using the Government’s
revised standard methodology that was published for consultation, the minimum housing need
figure for Solihull could increase by 25% to 1,011 dwellings per annum (16,176 dwellings
between 2020-2036). This could equate to a total minimum housing requirement of 3,264
more dwellings than the proposed housing requirement figure between now and 2036.
We consider that the Council could plan for this additional growth by considering the two
scenarios that may emerge from the Standard Method calculations. The first option could be
what the Council is currently planning for which is using the current Standard Method figure of
807 dwellings. The second option that the Council should also consider is the revised
Standard Method which could see the annual housing need increasing to 1,011 dwellings. In
order to demonstrate a robust approach at Examination and to be able to present a positively
prepared Local Plan (NPPF paragraph 35), we consider that the Council should plan for
additional growth than currently proposed and identify additional sites which could be
allocated if the Inspector requires the Council to plan for growth in accordance with the revised
standard methodology figure or if they agree with our findings set out above, that the UK
Central Hub area is unlikely to deliver 2,740 dwellings by 2036. The Council should recognise
and test a range of housing growth options that may be derived from changes to the standard
method and wider HMA growth requirements and plan for these options.
Point 6 of Policy P5 sets out that appropriate density of new housing will be based on a variety
of factors which are listed in the policy. We support the flexibility provided within this policy,
however, in order to comply with national policy, we consider that the criteria listed under Point
6 should be the same criteria that are listed under paragraph 122 of the NPPF. Paragraph 122
states that in order to make efficient use of land, planning policies should consider: the
identified need for different types of housing, local market conditions and viability, the
availability and capacity of infrastructure, the desirability of maintaining an area’s character
and setting and the importance of securing well-designed and attractive places. Currently,
Point 6 makes no reference to local market conditions and viability which we consider is an
important consideration that should be taken into account when identifying the appropriate
density and mix for each site.
In addition to the above, the indicative densities set out under paragraph 240 of the
Submission Draft state that the Council will seek to achieve indicative densities of 40dph for
houses, 90dph – 150dph for apartments and 50-70dph mixed areas at the UK Central Hub
area. The Arden Cross Masterplan shows 13.04ha of land designated for residential use
(Page 47). 500 dwellings are expected to be delivered during this plan period once HS2 is
completed. Although they are not expected to all be delivered in this plan period, if 3,000
dwellings are expected on the Arden Cross site, densities will need to be circa 250dph –
300dph in order to achieve the Council’s target. This is a significant increase on the densities
of development currently achieved in Solihull and the Council will need to ensure that the
impact of these densities is reflected and considered in the Local Plan Review document.
In summary, we consider that the Council should seek to allocate additional sites for
residential development within the plan because we consider that:
1. the UK Central Hub site will be unlikely to deliver 2,740 dwellings up to 2036 which
could leave a shortfall of circa 700 – 1,000 dwellings;
2. the revised Standard Methodology could increase the Council’s minimum housing
need by 25%; and,
3. the proposed contribution towards the HMA shortfall is not a sufficient or justified contribution
in light of the identified shortfall post-2031 which should be addressed in the Local Plan Review as the plan period runs until 2036.
In light of the above, the Council will need to identify additional sites to meet their increased
housing need requirements. Our client’s site at land east of Tilehouse Lane, Tidbury Green
(Site reference 192) is being promoted for circa 300 dwellings and public open space. The site
is located immediately adjacent to Dickens Heath and Tidbury Green in area which has been
expanded and is identified for further expansion in the Submission Draft given its accessibility
and sustainability.
In the Council’s evidence base site 192:
 is located within a lower performing Green Belt parcel;
 is located within a Medium / Low landscape parcel;
 has ‘Medium / High’ accessibility;
 is a Category 1 site in the Site Assessment Paper as it performs well against the suitability,
availability and achievability assessments.
In summary, our client’s site is strongly performing potential development site in the Council’s
evidence base and should be considered for a residential allocation to assist the Council in
meeting their housing needs. It would provide a logical extension to the proposed allocation
(BL1) land West of Dickens Heath.

Having reviewed the evidence base, we consider that the UK Central Hub area will not deliver
2,740 dwellings in this plan period, an additional contribution should be made towards the
HMA shortfall and the revised standard methodology requirement should be taken into
consideration by the Council before submitting the Local Plan for Examination. Furthermore,
the most recent reduction in some allocations and an the revised plan strategy of adding
another 600 homes to the windfall provision should be reviewed. We consider that the
Council should allocate additional housing sites and select those which have performed well
against the Council’s evidence base criteria and are in sustainable locations.
The land being promoted by Bloor Homes (site 192) should be considered as an additional
allocation being a high performing site adjacent to the proposed allocation (BL1) land west of
Dickens Heath.
Amend Point 6 of Policy P5 to accord with the criteria listed in NPPF Paragraph 122 and
amend the indicative densities table on page 76 to set out more realistic densities for the UK
Central Hub area if 5,000 dwellings are going to be delivered on the UK Central Site
(paragraph 830 of the Submission Draft document).

Policy P9
Policy P9 proposes to set additional requirements on development sites in order to reduce energy demand and minimise carbon dioxide emissions. The requirements include all new dwellings having to:
 achieve a 30% reduction in energy demand over and above the requirements of Build-ing Regulations Part L;
 be net zero carbon from 2025;
 provide at least 15% of energy from renewables; and,
 provide at least 1 charging point for electric vehicles.
To justify the proposed 30% uplift, the Council’s ‘Protecting the Environment’ Topic Paper (October 2020) refers to paragraph 148 of the NPPF which states that “the planning system should support the transition to a low carbon future in a changing climate… It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions…and support renewable and low carbon energy and associated infrastructure”. These requirements are considered to be over and above the requirements of the PPG which states that Local Plans “can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes” (Reference ID: 6-012-20190315).
The PPG also states that if a Council is “considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development” (Reference ID: 6-009-20150327). Viability has been tested on the Governments preferred interim standard which shows that 30% uplift is “generally viable at 2020 land and sales values” (paragraph 113 of the Protecting the Environment Topic Paper). The Protecting the Environment Topic Paper refers to precedents set elsewhere in the UK. Having reviewed the examples given, London seeks 35% uplift but Milton Keynes and Reading only seek a 19% uplift. We do not consider that Solihull has sufficiently justified why it is proposing an uplift of 30%.
In relation to developments providing at least 15% of energy from renewables, consideration should be given to the capital cost and land take involved to achieve this requirement which we do not consider has been undertaken in the Council’s evidence base. Furthermore, it should be noted that it is now the case that sourcing energy from the National Grid can actually, in some cases be more sustainable than small scale renewable energy production as each year they are sourcing more of their energy from renewable sources.
The Council’s viability appraisal sets out that circa £6,000 per dwelling has been allowed for in order to meet the future homes standard and provide electric vehicle charging required by Policy P9. We consider that this is a significant amount of money per dwelling just to meet energy requirements without any of the other requirements being sought in the plan to be taken into account e.g. affordable housing, specialist housing, accessible dwellings, Green – Belt compensation and other S106 contributions and CIL monies that will be sought by the Council and statutory consultees.

Amend Policy P9 to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimise carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage. The requirement to reduce energy demand to over and above Building Regulations Part L should be removed as this does not comply with the PPG.

Policy P10
We note that reference is made to the requirement for a “net gain” in biodiversity of at least
10% compared with the pre-development baseline. It is not clear whether the Council intend to
bring a 10% requirement in ahead of the Environment Bill being passed, which is potentially
before the Plan’s scheduled adoption. We do not consider that the Council is justified in
bringing this requirement forward ahead of the Bill being progressed through parliament, and
secondary legislation has been passed and brought into effect.
We support reference to Natural England standing advice in relation to ancient woodland and
veteran trees. This is the most appropriate guidance to take note of in respect of these trees.
16 i makes reference to development proposals being required to demonstrate that they have
considered impact on tranquility. We request that the Council clarify what is meant the
reference to “tranquility”, and how the impact on tranquility can be effectively measured. We
are unsure how this will be assessed as part of a planning application. Without this evidence
we do not consider the policy as written to be justified or effective.

The requirement for a biodiversity net gain of 10% should be removed from this
policy and any requirements left to SPD once the Environment Bill is passed and
secondary legislation has been brought in.

Policy P15
Bloor Homes consider that climate change considerations should be a ‘fabric first’ approach to build i.e. building in such efficiencies to new homes that reduce the call on energy demand in the first place and avoids ‘retro fits’.
We generally support the approach to this draft policy but suggest that amendments are required to 2iv and 7 to make the policy more effective.

We request that the following amendments are made to the wording of this policy:
Point 2 iv of this policy should be amended as follows: “Where possible, make appropriate provision for water management within development, without causing unacceptable harm to retained features, utilising innovative design solutions.” The reason for adding “where possible” is to ensure that allowance can be made for site specific constraints such as ground conditions that may be present preventing delivery of SuDS.

Policy P17
When defining Green Belt boundaries, the NPPF states that Local Plans should “be able to
demonstrate that Green Belt boundaries will not need to be altered at the end of the plan
period” (Paragraph 139e). The Council’s evidence base acknowledges that there are limited
brownfield opportunities left in Solihull and so to meet their housing needs Green Belt release
is needed for this Local Plan Review and may therefore will be needed again in future reviews.
The NPPF encourages Councils to identify areas of safeguarded land in order to meet longerterm
development needs beyond the plan period (paragraph 139c). However, the Council has
not sought to safeguard any land for development as part of the Local Plan Review. This is
particularly surprising where the housing requirement for the Borough has been the subject of
several key influences, including proposed changes to the standard method and the HMA
shortfall (Birmingham and Black Country).
In order to be consistent with national policy, we consider that the Council should identify
areas of land that could be released from the Green Belt in this Local Plan Review and
safeguarded for future development should the Council not be able to meet their housing
needs or the housing needs of the HMA during the next plan period.
As stated in our separate response to Policy P5, a significant HMA housing shortfall is
expected from 2031 so it is likely that Solihull will need to contribute additional dwellings to
assist in addressing this shortfall. Therefore, safeguarding land for the future is needed in
order to meet the longer term development needs of the HMA.
When identifying potential sites to release from the Green Belt and safeguard, the Council
should choose sites in lower performing Green Belt parcels, which are adjacent to sustainable
settlements, accessible and considered suitable, achievable and deliverable in the Council’s SHELAA (Category 1). Our client’s land at Our client’s site at land east of Tilehouse Lane,
Tidbury Green (Site reference 192) is being promoted for circa 300 dwellings and public open
space. The site is located immediately adjacent to Dickens Heath and Tidbury Green in area
which has been expanded and is identified for further expansion (BL1 – Land west of Dickens
Heath) in the Submission Draft given its accessibility and sustainability.
In the Council’s evidence base site 192:
 is located within a lower performing Green Belt parcel;
 is located within a Medium / Low landscape parcel;
 has ‘Medium / High’ accessibility;
 is a Category 1 site in the Site Assessment Paper as it performs well against the suitability,
availability and achievability assessments.

To provide a plan which is more effective and responsive to these variables we consider that
the Council should have tested a number of scenarios and provided appropriate allocations
and safeguarded areas to enable them to flexibly respond to the ever changing
circumstances. We request that the Council consider identifying areas of land that could be
released from the Green Belt in this Local Plan Review and safeguarded for future
development should the Council not be able to meet their housing needs or the housing needs
of the HMA during the next plan period.
We consider that additional allocations and/or safeguarded ;and should be identified and in
that regard we consider that site 192 (land east of Tilehouse Lane, Tidbury Green) is a
suitable and sustainable opportunity that is deliverable.

Policy P17A
The planning practice guidance states that compensatory improvements to environmental quality and accessibility of remaining Green Belt will be incorporated into a Section 106 agreement. The NPPF (paragraph 138) does not specifically state that Green Belt compensation has to be sought through S106 contributions. The PPG states that compensation can be secured through CIL or conditions and the S106 can be used to set out the long-term maintenance of sites (Reference ID: 64-002-20190722). As Solihull is a CIL charging authority, we consider that the Council should also set out Green Belt compensation projects which can be paid for through CIL. The PPG states that when setting out policies for compensatory improvements, they may be “informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies, and could for instance include: new or enhanced green infrastructure; woodland planting; landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal); improvements to biodiversity, habitat connectivity and natural capital; new or enhanced walking and cycle routes; and improved access to new, enhanced or existing recreational and playing field provision” (Reference ID: 64-002-20190722). As local communities receive a percentage of the CIL contribution this could enable the local communities to identify the projects that they would like compensation to fund.
In terms of Green Belt compensation, there may be circumstances where the Green Belt compensation cannot be provided effectively on site or it could significantly reduce the net developable area of the proposed allocation. Where these circumstance exist, the Council should have an effective strategy in place that enables off site contributions to be made to Green Belt mitigation in other locations e.g. through the identification of donor sites.
Additionally, the Council has not provided any indication of how the level of compensation will be determined. We request that a formula or calculation be provided in order to determine the level of contribution that may be provided to allow developers to plan for this requirement on top of the other contributions / requirements being sought in the Local Plan Review.

We request that the Council amend Policy P17A to refer to the use of CIL as well as S106 agreements to set out the Green Belt compensation projects. We also seek confirmation from the Council as to the level of compensation that will be requested for sites removed from the Green Belt.

Policy P18
We object to the requirement at 2 vii for all new development to deliver new and improved health services. This is not justified and therefore not effective due to requirement being placed on all development sites without site specific consideration. Delivering new and improved health facilities as part of all new developments. New health facilities should not be a blanket requirement no all new developments and should be considered on a site by site basis. Where improvements are needed in health services or facilities, but a new building or facility is not required, then financial contributions could be sought to improve existing facilities.

We propose that the policy is amended to allow for financial contributions where improvements are identified as the necessary mitigation to make development acceptable in planning terms.

Policy P20
We object to the requirement in point 10 that new development should look to accommodate the needs of existing population. Although it is likely that the existing population will use any open space provided, it should be recognised that any contribution or enhancement to be agreed through a section 106 agreement should be directly related to the development and take account of the tests of Regulation 122 of The Community Infrastructure Levy Regulations (2010) and NPPF paragraph 54 and 56. In essence new development should only seek to mitigate the impacts arising from tat development and not resolve existing deficiencies.

Point 10 of the policy should be amended to remove the reference to providing for the open space needs of the existing population as this would be contrary to Reg122.

See Attached Document

The plan should be modified reducing the number of completions expected in the plan period.
Instead the plan should allocate additional smaller sites such as land north of Main Road, Meriden to bring flexibility to ensure the housing need for the Borough is met in the plan period.

See attached Land North of Main Road, Meriden

See Attached document

See Attached document

See Attached Document

It is recommended that the policy is amended to specify the quantum of growth which the hub will deliver over the plan period.
It is recommended that the policy is linked to clear plans showing where the residential growth will be delivered within the hub boundaries in order to show deliverability

LAND AT BERKSWELL ROAD, MERIDEN see attached documents

1. Add further analysis to seek to quantify extraneous in migration generated by UK Central hub.
2. Add land at rear of 114 - 118 Widney Manor Road to the table of residential allocations.

The proposals within the Local Plan Review include substantial provision of housing at the UK Central Hub comprising an estimated 2500 dwellings to be delivered within the Plan period. The Council have advised that their housing figures are based on the standard methodology. The standard methodology comprises two elements. The first is the 2014 based estimates of numbers of households projected by the Department of Housing, Communities and Local Government which are essentially and extrapolation of household formation based on the existing and forecast demographic structure taken together with past known trends of inter regional, intra regional and international migration. The second is an adjustment to take account of affordability deficiencies.
The UK Central Hub is an initiative aimed at exploiting the advantages of the new HS2 infrastructure in the interest of furthering the economic well being of the West Midlands Conurbation.
The Overview download from the promotional web site states the hub area is :-
The economic powerhouse of UK Central, The Hub offers inward investors a central and globally connected location to grow their business. Realising the development potential of the High Speed Rail Interchange, a 140 hectare site within The Hub is planned to become a sustainable garden city for the 21st century.
Other promotional material is delivered in Mandarin confirming the global targeting of the project’s economic advantages.
Given this global linkage it can be reasonably supposed that a material proportion of new residents will be migrating in a manner that is materially different from the patterns used in the standard methodology. The circumstances of the development of UK Central Hub are therefore not covered by the trend material which underlies the standard methodology and as an exception to the trend the development of UK Central Hub represents an exceptional circumstance. It is necessary therefore for the additional population arising from this to be taken into account as failure to do so will result in under provision of housing and a corresponding exacerbation of affordability problems which the standard methodology was designed to do.
When measured against Government policy which seeks to meet all strategic development needs (See NPPF 2019 paragraph 23) this would therefore represent a breach of the NPPF. Any breach of the NPPF represents a failure to secure sustainable development. The breach of the NPPF amounts to a situation where the plan would be unsound but more importantly would amount to a breach of the statutory duty on Local Planning Authorities under Section 39 of the Planning and Compulsory Purchase Act the 2004.
The nearest example of the efforts to exploit the High Speed hub in the UK is Ebbsfleet International near Dartford in Kent. Like the ambitions for UK Central Hub the authorities there have sought to exploit the new economic opportunities afforded by a high speed rail link. Their advantages do not include ready access to international air transport as is the case of UK Central.
In order to consider the weight that should be attached to this objection I have checked the figures for housing need in Dartford Borough (where most of the Ebbsfleet development will be located).
The Core Strategy for Dartford proposes (at table 2 on Page 58) that during the period 2016-2026 some 9900 dwellings will be delivered – an annualised rate of 990. The base level 2014 table indicates a housing need of 778 dwellings per annum. This last figure includes the trend based migration evident before the Ebbsfleet initiative started to deliver additional houses. Thus the non trend migration which appears to flow from the Ebbsfleet initiative totals, over the period 2016-2026, some 2120 dwellings [(990-778) x 10].
If a similar pattern were to be repeated in the case of UK Central Hub then this would indicate that the majority of the UK Central development in the plan period would be attributable to non trend migration not hitherto absorbed into the 2014 base household forecasts.
In this context, and to avoid potential unsoundness and breach of statutory duty, the Council is invited to examine closely the impact of UK Central Hub on deviation from the migration trends evident from the 2014 forecasts.
Consideration of the overall housing need in the conurbation, and potential delivery within the conurbation of the conurbation needs has been assessed in the context of the 2014 based household projections. These point to the overall conurbation needs being about the same as when Solihull earmarked the figure of 2000 dwellings to meet conurbation needs. Thus the move to a figure derived from the 2014 based household projections is not materially different from the figures derived from the former housing need calculations. There is no overall change from the underly sub regional figures which will allow the UK Central Hub generated addition migration flows to be offset against changes arising from a move to the standard methodology.
In the context of the foregoing it is submitted that the overall housing requirement needs to take into account this exceptional circumstance presented by the advent of UK Central Hub. The pre submission plan takes into account deficits in supply in the Birmingham HMA but does not take into account growth over and above this from attraction to the UK Central Hub from outside the region. The evidence from Ebbsfleet is that it could be very substantial. A failure to take this into account points to a breach of statute and unsoundness through being inconsistent with national policy for delivery of the housing needs of an area having regard to all sources of need. Land at 114 – 118 Widney Manor Road is well placed to contribute to the likely underestimate of need given that the SA found the site to be classified as ‘reasonable alternative. The site should be added to the table of residential allocations.

See attached - employment Land Reps

The heading for and the text of paragraphs xii-xv of Policy P1 that relates to JLR and Site UK2 should be amended as follows:
“Jaguar Land Rover (JLR)/and Site UK2
xii. The Council will support JLR to compete and further its success in the global vehicles industry. To achieve this, the JLR site will need to continue to evolve and where necessary expand, with the only realistic opportunity for significant expansion being to the north east.
xiii. The Council will support and encourage the development of JLR within its boundary defined in this Local Plan. This will include a broad range of development needed to maintain or enhance the function of JLR as a major manufacturer of vehicles.
xiv. Site UK2 on the Policies Map, will be released from the Green Belt to accommodate employment development as set out in Policy UK2. This will include employment development to meet wider identified needs, together with that required to meet the additional needs of JLR and JLR related activities and ancillary development to Birmingham Airport. . The exceptional circumstances justifying the removal of the land from the Green Belt are set out in the justification to this policy.
xv. It will be expected that proposals for the development of Site UK2 will be promoted in a comprehensive and coordinated manner that can make provision for a phased approach, if required”.
2. Paragraphs 104 and 105 and the associated heading should be amended as follows:

“Jaguar Land Rover (JLR)/and Site UK2
104. The Council will continue to support the further development and modernisation of the vehicles plant in order to enable its continued success in the competitive global vehicles market. JLR is constrained in terms of its ability to expand by its location within the main urban area. To reflect this and having regard to the vital importance of JLR to the region’s economy and to job creation, Policy P1 includes proposals to remove land at Damson Parkway from the Green Belt to support this aim. As set out under Policy UK2, in addition to meeting JLR needs, Site UK2 will also provide for wider employment opportunities to meet the needs identified in Policy P3, as well as for potential ancillary requirements for Birmingham Airport.
105. Part of Site UK2 has also been identified as a potential location for a relocated Household Waste and Recycling Centre and Council Depot subject to ongoing options assessment by the Council. Further justification for this proposal is included in Policy P12.”
3. The fifth bullet point of Paragraph 106 should be expanded as follows:

“A significant part of the site already has planning permission and has been constructed for use as a despatch facility and logistics operations centre for Jaguar Land Rover, as well as the associated primary road infrastructure works for the site. These proposals were which was justified with very special circumstances”.
4. The 8th bullet point of Paragraph 106 relating to the Household Waste and Recycling Centre should be removed entirely.

See attachments

On behalf of the CCWMP the following modifications are proposed to Policy P1 paragraph 3 and the supporting text (additions in “ “): ‘Policy P1 UK Central Solihull Hub Area

Policy wording insert:
3.
vi. Create distinct and unique places ”that are safe with a strong sense of identity, incorporating high quality design which meets ‘Secured by Design’ standards to reduce crime and the fear of crime”, innovation for development and the public realm, whilst maximising the efficient use of land;

vx. "Provide for contributions towards measures to mitigate the impact of development and make it acceptable in planning terms by providing for physical, social, green and digital infrastructure as identified in Policy P21, the Infrastructure Delivery Plan and the hub Framework Plan;"

x. "Maximise partnership working with infrastructure providers, including those identified in the Infrastructure Delivery Plan in particular, in relation to issues of security and safety;"

xi. "Support the evening economy by providing facilities in such a way as to ensure safe, secure, accessible and inclusive environments so that crime, the fear of crime and anti-social behaviour are minimised."

In terms of the supporting text, the following modifications are sought (additions in " "):
Paragraph 82:
The Policy sets out the key objectives that development will be expected to contribute towards, including sustainable and economic growth "and the need for development to achieve ‘Secured by Design’ standards to promote safe and secure environments, the provision of necessary infrastructure, including social infrastructure and ensuring that in terms of the evening economy, facilities are secure, inclusive and accessible." Growth that is inclusive should demonstrate that the benefits will accrue to all by building on the strengths of communities, ensuring that wealth is more evenly spread and enabling everyone to contribute and participate.’

See attached representations forms