Policy P5 – Provision of Land for Housing

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Evidence is required to:
• demonstrate which of the SHLAA sites identified as contributing towards the 5 and 16 year housing land supply in the 2013 SLP have been delivered.
• extrapolate the windfall, Brownfield Land Register and SHLAA site completions.
• robustly demonstrate the deliverability and developability of all Brownfield Land Register sites, SHELAA sites, and proposed housing allocations.

If justification cannot be provided, those site allocations, SHELAA sites, Brownfield Land Register sites and planning permissions should be deleted from the Plan and housing land supply information.

Dear Sir/Madam,

Please find attached representations submitted on behalf of our Clients Messrs Benton & Neary to the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Representation recommends that this part of Policy P5 is removed

See attached letter

'3. New housing will be supported on windfall sites in accessible locations where they contribute towards meeting borough-wide housing needs particularly where proposals involve the redevelopment of suitable brownfield sites. Unless there are exceptional circumstances, new housing will not be permitted in locations where accessibility to employment, centres
and a range of services and facilities is poor'.

'Density
6. The Council will seek to make most effective use of land, by seeking to ensure an appropriate density of new housing that will be based on a number of factors,
and measured on the developable area of a site'.

See attachment

See attached documents.

See attachment

A robust reassessment of the housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within the Housing Market Area over the plan period.

See attached document. Land at Knowle

see attached document

Summary Table of Residential Allocations (para 226) should be amended to include sites in which housing can be provided such as the Barns at Eastcote on Barston Lane which is a brownfield site suitable for housing.

See attachment with representations on P4B & P5

Align housing densities in concepts document to approved KDBH NP.

See attachments

Include Site 43 in table of allocated sites in paragraph 226

See attached

The Council should commit to the inclusion of a series of reserve sites within the Local Plan Review identified to meet housing requirements in the event that the Government’s standard methodology continues to indicate that housing need is significantly higher than that set out within the submission draft plan.

The alternative would be to include a policy within the Local Plan Review requiring the commencement of a separate Site Allocations document, such work to be commenced no later than six months after the adoption of the Local Plan Review, to include a series of reserve sites and to be read in conjunction with the Local Plan Review including adherence to the development strategy.

One of the advantages is that the site allocations could deal with any deficiency in five year housing land supply, and where it was felt that Green Belt release was required, land could continue to be safeguarded and Green Belt policies apply until such time as any given site was required.

Dear Sir / Madam,

Please see attached Representations in relation to Regulation 19.

Please don’t hesitate to get in touch if you have any queries.

Many thanks,

Clare Garrad

Criterion 5 should be amended to remove the requirement to comply with Nationally Described Space Standards. Rather this should be something that “should” be complied with, as it is not always possible.
Rather than relying on windfall provision, the Council should consider maximizing the potential opportunities associated with draft allocations in the plan. For example, the Hampton Road site was originally allocated for 300 dwelling, but reduced to 180. As demonstrated in our representations, the Green Belt boundaries proposed are not robust and should both be extended further north. This would enable the delivery of an additional dwellings and could provide positively planned development, as opposed to relying on more windfall.

See attached documents.

See other proposed modifications to Plan to achieve the above aims.

See Attached Letter and Representation Form.

• Increase in Housing figures of between 1,036 and 1,248 dpa
• Reduction in windfall allocations from 200 dpa to 150 dpa
• Reduction in BFLR allocations by 29 - from 77 to 48.

See attached

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

Policy P5 to be redrafted to explicitly commit the Council to deliver a contribution to the unmet needs of the wider HMA.

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

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

Remove this element of the Policy P5.

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

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

Section 1 – The tables should be provided with Figure numbers so that the allocation table can be linked with Policy P5.

Section 6 - Density criteria (iii) be revised to read ‘…and, heritage assets and their setting’.

Wording in Policy BC3 requires alteration as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2*’ etc and should be altered to the Roman numerals used in the listing process i.e. 2* would read II* etc.


With regard to the 2019 Heritage Impact Assessment for this site the analysis refers to ‘significant’ harm – it is not clear whether this means substantial harm or not. We note that the area to the south has not been taken forward.
2 i - Protection Conservation or enhancement of heritage assets and their setting;the setting of heritage assets adjacent the site;

2 ii - Provision of low density housing, and where relevant single storey housing to protect the setting and functionality of GII* Berkswell Windmill.

With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy BC3 could be tightened up further in respect of impact on the GII* Berkswell Windmill and its setting. The LPA will need to be satisfied that the functionality of this heritage asset would not be affected through the proposed development.

Wording in Policy KN1 requires alteration in line with NPPF requirements for harm (this may be duplication however if text for Policy P16 is revised) and as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘1’ etc and should be altered to the Roman numerals used in the listing process i.e. 1 would read I etc.
With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy KN1 criteria could be tightened up further in respect of impact on the setting of GI Grimshaw Hall.

Policy P5: Provision of Land for Housing.

Section 1 - The Policy refers to a table setting out allocations which is one table of a number of unnumbered tables which follows the policy.

Section 6 - The setting of heritage assets is not referred to within the policy at present.
Section 1 – It is recommended the tables be provided with Figure numbers so that the allocation table can be linked with Policy P5 for the avoidance of doubt.

Section 6 - In line with NPPF requirements it is recommended that Section 6: Density criteria (iii) be revised to read ‘…and, heritage assets and their setting’.

Historic England would refer you to comments made at an earlier consultation stage where we encouraged SBC to take the opportunity to refine the early post NPPF heritage policy in the extant Plan.

Whilst our earlier comments are predominantly recommendations, the proposed policy wording does not differentiate between harm and substantial harm as set out in the NPPF and we are of the view that this should be addressed within the policy.
The policy should include the following text, or a similar alternative:

Great weight will be given to the conservation of all designated assets and their settings (and non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments). Such assets should be conserved in a manner appropriate to their significance, irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance. Development which leads to less than substantial harm to a designated heritage asset will be weighed against the public benefits of the proposal.

Development which leads to substantial harm to, or total loss of, the significance of a designated heritage asset will only be acceptable where it can be demonstrated that it is necessary to achieve substantial public benefits that outweigh that harm or loss, or where all of the following apply:

the nature of the heritage asset prevents all reasonable uses of the site;

no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation;

conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible;

and the harm or loss is outweighed by the benefit of bringing the site back into use.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.

Clarify use of 'zone of significance on the setting of the listed building’ in terms of assessing impact on heritage assets or setting.
Use alternative logo.
Use roman numerals for listed building gradings.

Wording in Policy BC3 requires alteration as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2*’ etc and should be altered to the Roman numerals used in the listing process i.e. 2* would read II* etc.


With regard to the 2019 Heritage Impact Assessment for this site the analysis refers to ‘significant’ harm – it is not clear whether this means substantial harm or not. We note that the area to the south has not been taken forward.
2 i - Protection Conservation or enhancement of heritage assets and their setting;the setting of heritage assets adjacent the site;

2 ii - Provision of low density housing, and where relevant single storey housing to protect the setting and functionality of GII* Berkswell Windmill.

With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy BC3 could be tightened up further in respect of impact on the GII* Berkswell Windmill and its setting. The LPA will need to be satisfied that the functionality of this heritage asset would not be affected through the proposed development.

Wording in Policy KN1 requires alteration in line with NPPF requirements for harm (this may be duplication however if text for Policy P16 is revised) and as suggested below.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting since the wording does not tie up with the 2019 Heritage Impact Assessment analysis;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘1’ etc and should be altered to the Roman numerals used in the listing process i.e. 1 would read I etc.
With regard to the 2019 HIA work and the Concept Masterplans information, we would welcome opportunity to discuss this site with you ahead of the EIP to establish whether the concept plan and Policy KN1 criteria could be tightened up further in respect of impact on the setting of GI Grimshaw Hall.

Policy P5: Provision of Land for Housing.

Section 1 - The Policy refers to a table setting out allocations which is one table of a number of unnumbered tables which follows the policy.

Section 6 - The setting of heritage assets is not referred to within the policy at present.
Section 1 – It is recommended the tables be provided with Figure numbers so that the allocation table can be linked with Policy P5 for the avoidance of doubt.

Section 6 - In line with NPPF requirements it is recommended that Section 6: Density criteria (iii) be revised to read ‘…and, heritage assets and their setting’.

Historic England would refer you to comments made at an earlier consultation stage where we encouraged SBC to take the opportunity to refine the early post NPPF heritage policy in the extant Plan.

Whilst our earlier comments are predominantly recommendations, the proposed policy wording does not differentiate between harm and substantial harm as set out in the NPPF and we are of the view that this should be addressed within the policy.
The policy should include the following text, or a similar alternative:

Great weight will be given to the conservation of all designated assets and their settings (and non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments). Such assets should be conserved in a manner appropriate to their significance, irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance. Development which leads to less than substantial harm to a designated heritage asset will be weighed against the public benefits of the proposal.

Development which leads to substantial harm to, or total loss of, the significance of a designated heritage asset will only be acceptable where it can be demonstrated that it is necessary to achieve substantial public benefits that outweigh that harm or loss, or where all of the following apply:

the nature of the heritage asset prevents all reasonable uses of the site;

no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation;

conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible;

and the harm or loss is outweighed by the benefit of bringing the site back into use.

In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.
In respect of the Concept Masterplan document there are a number of concerns as follows:

 In terms of the historic environment, a ‘zone of significance on the setting of the listed building’ is indicated within concept masterplans where relevant. It is not clear what this means in terms of assessing the impact of a development proposal on the significance of a heritage asset or its setting;

 It appears that listed buildings are indicated by the use of the English Heritage logo which has the potential to raise copyright issues and should be altered. It would not be appropriate to use the Historic England logo as alternative. A different identifying symbol should be used instead; and,

 Grades of listed buildings are set out in number format ‘2’ etc and should be altered to the Roman numerals used in the listing process i.e. 2would read II etc.

The housing target should be expressed as a
minimum, the contribution to meeting HMA needs increased and land safeguarded for future development needs.

See attached

Table at paragraph 225 should be re-assessed and additional allocations provided to meet local housing need, contribution to Housing Market Area shortfall and 5 year housing land supply

See attached

See attachments.

Land at four ashes road dorridge

Re-include the site at Sharmans Cross Road (Site 246) as a formal allocation to meet housing needs.

See attachments

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.

Policy P5 Provision of Land for Housing
This policy is not considered sound or legally compliant for the following reasons
Whilst Spitfire Homes welcomes the increase in housing numbers from the previous Supplementary Consultation
Document, it is not felt that this goes far enough. A separate representation has been prepared by Barton Willmore on behalf of Barratt David Wilson Homes, IM Land, Spitfire Bespoke Homes, Heyford Developments, and Generator Strategic Land on the Borough’s Housing Need. The conclusions of this representation are supported.
In summary, this representation makes the following conclusions. The NPPF is clear at paragraph 59 that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward”. Paragraph 60 further states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing needs assessment, conducted using the standard method in national planning guidance……. In addition to the local housing need figure, any need that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing planned for”.
In the case of SMBC, policy P5 proposes the following:
• The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing
land supply to deliver 15,017 additional homes in the period 2020-2036. The allocations will be part of the
overall housing land supply detailed in the table below.
• The average annual housing land provision target is 938 net additional homes per year (2020-2036). A
trajectory showing how this target will be delivered from all sources of housing land supply is shown below.
It will be subject to annual review through the AMR.
This is based on the minimum identified need of 807dpa and a contribution of 2,015 dwellings across the plan period to help meet the unmet need within the Housing Market Area. This gives a total of 938dpa.
However, as is made clear in the NPPF and within the representations from Barton Willmore and the House Builders Federation (HBF) that this housing need over the plan period has been underestimated. Equally the housing need figure in policy H5 should be expressed as a minimum which is currently is not.
The Borough has significant ambitions over this plan period as identified as Challenge D and Challenge M.
Challenge D looks to secure sustainable and inclusive economic growth including:
• Meeting Solihull’s important regional and sub-regional role
• Meeting aspirations of key businesses to enable them to maintain competitiveness (Birmingham Airport,
National Exhibition Centre, Birmingham Business Park, Blythe Valley Park, Jaguar Land Rover) whilst
contributing to sustainable development.
• Retaining and developing a high skilled workforce.
• Provide a range of housing to attract inward investment
Challenge M looks to maximise the economic and social benefits of the High Speed 2 Rail Link and UKC Hub Area
including:
• Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and
development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills,
environment and infrastructure.
• To provide an appropriate planning framework so as to ensure that the potential economic and social benefits
of growth enabled by the HS2 rail link and interchange station are delivered.
These ambitions are of course welcomed, but equally they have implications on ensuring appropriate housing is
delivered within the Borough.
The representation prepared by Barton Willmore makes the following conclusions:
• As has been set out above, the policy fails to make it clear that the housing numbers proposed are a
minimum figure.
• The Standard Methods minimum need for Solihull (807dpa) will need to be increased to account from
expected job growth within the Borough.
• Modelling carried out by Barton Willmore shows that between 1,036 and 1,248 dpa. are required to support
the UK Central Hub scenario
• Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being
delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031,
a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases
when the unmet need from the Black Country is considered. Additional unmet need will be created post
2031.
As a result, this raises significant concerns on the housing numbers set out within policy P5. Therefore, settlements such as Balsall Common which have been identified as being able to accommodate housing growth beyond its own needs should have further land allocated within it to meet housing needs.
In this case, further consideration needs to be given to Land at Oakes Farm, Balsall Common. The NPPF is clear at paragraph 68 that “small and medium sized sites can make an important contribution to the meeting the housing requirement of the area and are often built out relatively quickly”.
Spitfire Homes has an option on Land at Oakes Farm, Balsall Common (site 304 in the Site Assessment October 2020). This site could help to meet the additional housing need identified within the representations from Barton Willmore. This site is located to the south west of Balsall Common and would sit comfortably within the built form of the settlement having regard to both existing development and proposed allocations. The chapter on Balsall Common within the Draft Submission Plan sets out at paragraph 521 that “Balsall Common is one of two rural settlements in the Borough that has a full range of facilities including both secondary & primary schools, health services and a range of retail and associated facilities. As such it is well placed to accommodate levels of growth in excess of just its own local needs.”
The Site Assessment document in respect of this site sets out that the “Settlement identified as suitable for
significant expansion, although site would have no defensible green belt boundary”. An accompanying vision
document has been prepared which demonstrates how development could be sensitively located on this site having regard to the site constraints. The site as it currently stands has very clear boundaries with Fernhill Lane marking the western boundary, Oakes Farm shop and hedgerows marking the southern boundary, and hedgerows on the eastern boundary with the B4101 running along the northern boundary of the settlement. Whilst in planning terms the site may be regarded as open countryside, its current and surrounding land use and visual character is such that it does not form part of the more functionally intact agricultural landscape to the south.
The Site Assessment document suggests that it “is within moderately performing parcel in the Green Belt
Assessment and would result in indefensible boundaries to the south and west
An Environmental Appraisal of the site has been undertaken by EDP and in respect of Green Belt when the site is considered on its own merits, it scores significantly lower than suggest in the Council site assessment. A summary of the table is attached.
It is acknowledged that land is proposed to be developed as part of this plan at Frog Lane for 110 dwellings (policy
BC2). As part of the assessment prepared by EDP, they have also assessed the Frog Lane site, and this
demonstrates that the Frog Lane site performs a stronger purpose against three of the tests compared to the Oakes
Farm site. With regard to those performances, it was considered that development of the site is likely to have a
particular effect on the rural character and setting of Frog Lane to the south and east.
The Oakes Farm site is in a highly sustainable location with a bus stop within 400 metres of the site, and the centre of Balsall Common within a 10-15 minute walk, and both a primary and secondary school no more than 1.3km from the site. As is set out within the vision document there is currently an abrupt settlement edge to Balsall Common in this location and development at Oakes Farm would allow this to be softened albeit clearly defined and defensible.
The strategy within the masterplan provides a number of key principles including a significant landscape buffer,
which provides a transition from urban to rural as well as ensuring there is a robust and defensible boundary to the
Green Belt. Within the site, it is proposed to integrate existing public rights of way ensuring good connections to
the centre of Balsall Common village centre. In addition, there are opportunities to provide significant ecological
improvements to the site.
This site is available immediately and is being actively promoted by Spitfire Homes. Apart from the site’s location within the Green Belt, there are no known constraints which would prevent development of the site. This site can easily be delivered within the next five years providing much needed additional housing within the Borough. As has been demonstrated within the accompanying appraisal by EDP, the Oakes Farm site could reasonably be removed from the Green Belt and developed in accordance with the sound masterplanning principles without harm to the integrity of the Green Belt overall.

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the
housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within
the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.

Draft Solihull Local Plan Response - objections and points to be considered

From Mark Taft Dec 2020
44 Langocmb road
Shirley , Solihull
West Midlands B90 2PR


• 5 % of green belt to be built on when there are other options
• Only 3000 housed planed for development on Hs2 Site - Could be treble this number.
• Not only helping to mitigate the road traffic congestion, but also saving valuable green belt, providing breathing space in the Blyth valley areas
• Little housing allowance has been considered in Solihull town Centre, where unwanted office accommodation could be repurposed.
• Little housing allowance has been considered in Chemsley wood area, which is classed as an urban renewal area and has better transport links.
• Site BL3 is designated as green belt of the highest value – why is it being built on?
• Doctors Services in Shirley are already not coping due to the high number of retirement home projects; indirectly causing doctors surgery’s to become unviable business units.
• Roads are already to capacity, making too difficult to get to the M42 for work travel.
• Houses are being built close to the Windmill in Balsall Common, a national monument. The outlook and site should be cherished not trashed by excessive building development.
• Blyth valley area is a known flood plain on mainly clay soil, while little of no recognition of this is given in the plan.
• Solihull should not have extra houses from Birmingham – this has not properly been addressed.
• National government guidelines state that Natural wildlife sites should have interconnecting routes, so why is site BL3, Bl2 allowed to be included.
• Alternate locations such as the Tisbury green golf course should be considered as its nearer the Station, and would allow preservation of the gaps between Shirley , Dickens heath and Cheswick green.
• There seems to be no sustainable assessments contained in the plan.
• On page 180 of the plan, it states it is expecting addition traffic to be feed through Haslucks green road and Bills lane. This is already highly congested already it is difficult to leave the local estates to get to work in the morning.

Draft Solihull Local Plan Consultation Response – Objections and points to be considered.
From Paula Pountney -
44 Langcomb Road,
Shirley,
Solihull,
West Midlands, B90 2PR 10.12.2020

With reference to the above, I understand that one of the main objectives and directives of the plan is to distribute development throughout the borough which is clearly not the case in this plan, as 39% is disproportionately designated to Shirley, with at least 5% being on the green belt.
• There has been a huge amount of development in the Blythe area already in the last 5 – 8 years and a significant amount more than elsewhere, is being planned additionally and this fact seems to have been disregarded.
• Site BL3 is designated as highest value green belt so why build there, when there are clear alternative options?
• Site BL1 is not sustainable, with the only advantage being it is near to Whitlocks End Railway Station. It is wholly inappropriate because it is very high grade green belt land around Dickens Heath rated 7 and 8 status and should have been a red site on the very first round of sustainability appraisals. I understand that The Campaign for the Protection of Rural England has stated that in paragraph 11B of the National Policy Framework because the site has very high areas of ecological value, including at least 4 nature reserves very nearby and a high flood risk, the constraints are proven to be so bad, it’s justified that this land should not be included for development.
• National government guidelines state that Natural Wildlife sites should have interconnecting routes, so why is site BL3 and BL2 included in the plan?
• Why have only such a small number of dwellings - in the region of 3000, been designated for the HS2 site, when it could easily accommodate three times that number? It would be a much superior option with great transport links, job opportunities and much less environmental damage.
• Regeneration in Chelmsley Wood - which appears to have little housing allowance being considered for the town, which is classed as an urban renewal area. This would be a much more appropriate area for extra development environmentally and for future sustainability.
• As previously recorded at the Council, the Solihull Town Centre Masterplan should be brought forward including many suggestions made several years ago. Following the very sad demise of Shops such as those in the Arcadia Group and also soon to be closed - House of Fraser, much of the redundant shop and office space could be re-developed for housing accommodation. It’s a stark fact that since the pandemic, many more people work from home and much of the structure of people’s lives have completely changed and this alone should be a critical reason for the overhaul of the whole plan.
• Alternative locations – such as the Tidbury Green Golf Course Site should be strongly considered as it’s nearer the Railway Station, and would allow preservation of the gaps between Shirley, Dickens Heath and Cheswick Green, preventing coalescence of areas.
• Why have the Council not agreed to these suggestions, in order to protect the majority of the sites on the greenbelt? More importantly, the kind of homes that are most needed, in locations that promote sustainable travel.
• Loss of vast amounts of sports grounds/playing fields with no mention of where all this valuable resource could be re-located? This would result in a loss of health and well-being to the community, which would be a total disgrace!
• The pandemic has had a drastic effect on Doctors Services already completely stretched and failing to keep pace with current demand. This is due partly to the existing retirement and extra care facilities, with more to follow. We know that there is an ageing population and the demographic is 30% higher in this area than the national average. This presents a massive challenge to existing services and should be acknowledged and mitigated by the plan. This has not been addressed, as far as I understand.
• I believe that there has been no extra provision for Hospitals, Dentists and other services featured in the plan. Infrastructure investment has not been clarified and the mechanisms designed to ensure Developers pay fair costs have not been outlined. The consequences of this could be disastrous, as future health and wellbeing have not been addressed. It should be mandatory, in my opinion that Developers are held to scrutiny regarding the protection and enhancement of high quality health and social care Services.
• Roads will be totally gridlocked in Shirley. The traffic is already to utmost capacity, resulting in even more air pollution and noise. This will really exacerbate problems to access the M42. It is also a really terrible idea for additional traffic to be fed through Bills Lane and Haslucks Green Road, which is already highly congested at peak times.
• The Blythe Valley is a well-known flood plain on mainly clay soil, while little or no recognition of this is mentioned in the plan. We are worried about the risk of flooding at the bottom of Bills Lane and Haslucks Green Road, as it is already prone to flood round this area. Will the Council and Developers compensate for any future damage done, as it’s a big risk?
• Solihull should not have to take an extra 2000 houses from the Greater Birmingham area. Andy Street has overseen a lot of development in the centre of Birmingham on derelict and brown field sites and they have brought in an extra £434million to clean up these sites for homes and businesses, easing pressure on Green Belt sites.
• I have been directly advised by Andy Street’s office that Solihull Council are working hard to get a Local Plan in place to provide a safeguard to communities across the borough against a barrage of speculative and unwelcome planning applications. The email stated that the Council have been determined to maximise the use of sites like UK Central and Solihull Town Centre to ease the pressure on the Green Belt Sites. The email states that there is a genuine and serious attempt to meet the challenge and he will continue to work with the Council to do whatever he can to help them in their ambition to defend the Green Belt.
• Is this truthfully the case? As I mentioned earlier in the point about building more development in Solihull town centre, Chelmsley Wood and UK central, why can this not be undertaken before the undesirable outcome of building on the precious Green Belt?
• This plan should be considered unsound as due diligence does not appear to have been carried out on analysing sustainability of the individual sites.
• I do not consider 6 weeks consultation to have been enough time for the public to have had time to adequately study the plan and it has very unfairly been pushed through under the cover of the pandemic. It’s almost like a smokescreen and other Councils have given people much longer to state their opinions and this can only be detrimental to Shirley!
• It’s really difficult to comprehend why the Developers have so much power over Councils to force development on the Green Belt? Shirley has 3 Green Party Councillors acting on our behalf that are opposed to so much development, particularly on the Green Belt in Shirley. Surely, in a democracy they should have a great deal of influence, after being voted for by the people of Shirley? How can Solihull Council impose this plan and believe it is fair and equitable to the already wonderful town of Shirley?
• Finally, please re-consider this contentious, unfair, unfinished plan adversely affecting Shirley. If continued, it will be a drastic legacy for the Council which will ruin the character and identity of Shirley.
Thank you
Regards

Paula Pountney