Balsall Common

Delete Site BC2

I am writing to you regarding my concerns over the local Plans for Balsall Common and in particular my objections to the concept master plans for BC2 Frog Lane.

The local plan is a cacophony of housing developments of which 31% has been allocated to Balsall Common eroding the rural fringe of Solihull and encroaching on the Meriden Gap. 1100 of the 1600 houses in Balsall Common are being developed on green fields site, ignoring the governments recommendation to protect greenbelt and favour Brownfield sites.
Brownfield land is a renewable source, green belt is not.
In particular, BC2 Concept Master Plan should be removed from the Local Plan. This is a small development on vital greenbelt land that would have an insignificant contribution to the overall housings needs in Solihull at the cost of the environment.

The SMBC’s plan to change the greenbelt boundary of BC2 site is contradictory to the NPPF. The NPPF makes it clear that the fundamental aim of the Green Belt Policy is to prevent urban sprawl by keeping land permanently open. It also explicity states that established boundaries should only be altered in exceptional circumstances. There are no exceptional circumstances to justify removing this land from greenbelt. It is a small housing development that provides little impact to the overall housing shortage in Solihull. In addition, altering greenbelt boundaries would set a precedent for other landowners in the area to change their greenbelt boundaries and encourage further urban sprawl.

The BC2 site in on an elevated position (as shown on your landscape assessment) and slopes towards a rural country lane and farmland. This is a critical flood risk and will erode natural flood planes causing nearby farming fields to be waterlogged and to potentially ruin crop growth.

The proposed entrance to the site is unsuitable. Balsall Street East is a heavily congested road and with a large primary school and large secondary school adjacent it. Additional traffic to the area would cause further congestion on a hazardous main road especially at peak school times where cars already obstruct the pavement of Balsall Street East.

Finally the BC2 site is poorly positioned from local public transport connections and is located at the furthest point in Balsall Common train station and village centre which is in contravention with planning best practise and would require all residents to drive any local amenities or work. The impact of the carbon footprint would be substantial in comparison to the small gain to housing requirements in the borough.

Based on the above, I hope Solihull council will review the decision to develop on BC2 greenbelt land and remove this site from the planning process. Local plans should reflect the future needs of the borough and not the demands of local landowners and development companies profiteering from the BC2 site.

Berkswell Church of England (VA) Primary School should be identified by name in Paragraph 516

Berkswell Church of England (VA) Primary School is located in Berkswell village. It is currently the only school in Berkswell Parish. The school admits children from 3 to 11 years of age. Its admission number is 30 in each academic year, making the school 1 form entry. Berkswell School has a total of 210 places for statutory school age children plus a nursery class.
The school is very successful, a popular choice with families, and seldom has any surplus places.
The Governors would like the Local Plan to identify the school by name in the local plan.
New Housing
The governors accept that additional housing is required in Solihull Borough and Balsall Common has been selected as an area of growth. The governors recognise that additional families moving into the area will increase the demand for school places. Berkswell Primary School is currently at capacity, as are the other primary schools serving Balsall Common.
The total number of houses proposed in Balsall Common in the local plan is between1,654 - 1,819 dwellings.
The governors have independent advice that the total of all the houses proposed, in due course, is likely to generate sufficient demand for a 420 place (two form entry) primary school with a 30 place nursery.

The new primary school.
The plan clearly states that the provision of the new 2 form entry primary school with nursery is to be funded through developer contributions.
A site on part of the Barratts Farm development is identified in the local plan. The national government guidance for new primary schools would provide the template for standard provision. The Borough also has a shortfall of provision for children with Special Education Needs and Disability (SEND).
Special Education Needs and Disability (SEND) provision.
Department for Education statistics (4th July 2019) show that 14.9% of all pupils have special education needs (January 2019) with 3.1% of all pupils having an Education Health and Care Plan. In a school population of 420 this equates to 62 pupils with SEND and of those potentially 13 with an education health and care plan.
The new primary school should include enhanced provision for specialist facilities for pupils with special education needs and disabilities. This need meets the planning obligations tests and therefore should also be funded by the housing developments.

The timing of developments.
The plan period is 2020 to 2036 and makes clear that the completion of HS2 will have an impact on future land availability and housing programmes in Balsall Common. The Barratts Farm development, because of its proximity to HS2 and the relief road, is identified as the housing site which will take place later than the other housing sites. This is potentially problematic given that this site will also accommodate the proposed new school. Should the formation of the school occur after the completion of many new houses, it will place pressure on existing provision that is already at capacity. Interim arrangements will need to be made for the new pupils requiring places.
The Governors request participation in pupil forecast modelling exercises to ensure the new school is introduced at the optimum time.

Paragraph 531 should be expanded to reflect to need for the nursery, SEND provision and to indicate interim arrangements before the new school is provided

Berkswell Church of England (VA) Primary School is located in Berkswell village. It is currently the only school in Berkswell Parish. The school admits children from 3 to 11 years of age. Its admission number is 30 in each academic year, making the school 1 form entry. Berkswell School has a total of 210 places for statutory school age children plus a nursery class.
The school is very successful, a popular choice with families, and seldom has any surplus places.
The Governors would like the Local Plan to identify the school by name in the local plan.
New Housing
The governors accept that additional housing is required in Solihull Borough and Balsall Common has been selected as an area of growth. The governors recognise that additional families moving into the area will increase the demand for school places. Berkswell Primary School is currently at capacity, as are the other primary schools serving Balsall Common.
The total number of houses proposed in Balsall Common in the local plan is between1,654 - 1,819 dwellings.
The governors have independent advice that the total of all the houses proposed, in due course, is likely to generate sufficient demand for a 420 place (two form entry) primary school with a 30 place nursery.

The new primary school.
The plan clearly states that the provision of the new 2 form entry primary school with nursery is to be funded through developer contributions.
A site on part of the Barratts Farm development is identified in the local plan. The national government guidance for new primary schools would provide the template for standard provision. The Borough also has a shortfall of provision for children with Special Education Needs and Disability (SEND).
Special Education Needs and Disability (SEND) provision.
Department for Education statistics (4th July 2019) show that 14.9% of all pupils have special education needs (January 2019) with 3.1% of all pupils having an Education Health and Care Plan. In a school population of 420 this equates to 62 pupils with SEND and of those potentially 13 with an education health and care plan.
The new primary school should include enhanced provision for specialist facilities for pupils with special education needs and disabilities. This need meets the planning obligations tests and therefore should also be funded by the housing developments.

The timing of developments.
The plan period is 2020 to 2036 and makes clear that the completion of HS2 will have an impact on future land availability and housing programmes in Balsall Common. The Barratts Farm development, because of its proximity to HS2 and the relief road, is identified as the housing site which will take place later than the other housing sites. This is potentially problematic given that this site will also accommodate the proposed new school. Should the formation of the school occur after the completion of many new houses, it will place pressure on existing provision that is already at capacity. Interim arrangements will need to be made for the new pupils requiring places.
The Governors request participation in pupil forecast modelling exercises to ensure the new school is introduced at the optimum time.

The Arden Cross Development (site UK1) has only got plans for 500 dwellings in the plan period. The total planned for this new town is 3,000 homes. Building all 3,000 during the plan period would take a lot of pressure to build in semi-rural areas like Balsall Common.

I moved into Balsall Common with my family in 1984. The plans for housing are unfair. I understand we should take our fair share of future housing but we have been allocated over 30% of the dwellings even though our village has only around 3% of the population of the Borough.
These proposals will mean that Balsall, a large village or small town with inadequate infrastructure, will balloon into an even bigger town with village-standard facilities way below what one would expect in such a densely-populated urban area.

Utilise as much brownfield as possible - should be revisited as with Covid there will be more permanently available for development.
Balance the share of building across the borough or phase differently. Balsall Common is being devastated by HS2. There has been excessive building in recent years. This should now pause until HS2 is complete.

Not content with the devastation of the semi rural landscape of Balsall Common for white elephant HS2, our so called Conservative council ( who traditionally protected greenbelt) is planning to put more than 31% of planned new homes In the borough in Balsall Common. This equates to more devastation and destruction of our green belt. Brownfield sites should urgently be identified - there are empty retail units in the borough which could be converted.
In para 521, the village is not well placed for future growth. It cannot cope with current levels of demand for GP, schooling or parking.

Include strategy for expansion of Secondary School in paragraph 532.

I am concerned that there will be an unbalanced development in Balsall Common, if the current Draft Plan comes to fruition.
During the process of the Village Plan which reported in 2009, we undertook much research. One of the key questions we asked of senior officers was the calculation of children of school age as part of new development. We were advised that 1000 dwellings would produce 800 children of school age.
One of the issues of critical importance was the co-efficient relating to school numbers/pupils. This was very valuable at the time. During submissions from 2012, I have continued to ask whether the equation in 2008 had changed. I am assured that the equation of 1000 dwellings would produce 800 children / students of school age.
There is a statement in the document covering Balsall Common that a two-form entry Primary school would be built as part of the Barratt’s Lane development. There is also a statement that Heart of England School could cope with the construction of 1680 dwellings. However if the numbers proved beyond this capacity, expansion of the school would come from developer contributions. This is currently an unknown situation. Perhaps a strategy to cover this potential would be advisable. Para 526 is clear that requirements from other locations may mean that Balsall Common is destined for more development.
May I submit that this inference could prove to be unnecessarily costly to SMBC, unless additional accommodation could be provided?
My thinking is along the following lines: -
1. The current Primary School is over subscribed to the extent that the Head Teacher has relocation in mind; over-sized classes at Primary level are best avoided. [I am given to understand that he has Frog Lane in mind.]
2. The calculation of school places needed from 1680 dwellings is 1344 new arrivals. Taking this figure over 12 teaching years, this amounts to the addition of 112 per year group. If the calculation were taken over 15 school years, there would be 90 in each year group.
3. On the basis of these figures, it is difficult to see how the existing Primary school will be able to cope. [ 3 form entry is perceived to be too large]
4. Using the same formula, the 875 dwellings in Barratt’s Lane would produce 700 pupils. Clearly some “relocation” of pupils from the current Primary school would be required.
5. This may not be popular or convenient for some parents as well as causing additional traffic.
6. The point is made that HoE school takes pupils from outside Solihull. Presumably officers have been in contact with Coventry City and other boroughs whose pupils attend Solihull schools? This would necessitate removing some pupils from outside.
This Draft Plan seeks to cover a decade or so, before further review is necessary. In these circumstances, perhaps dealing with the relocation of the Primary school initially could open the possibility of HoE expanding into the plot occupied by the Primary school. Clearly some internal reorganisation of infrastructure would be necessary – toilets and desks/tables with chairs. Overall a modest expenditure to enable the longer-term view to be achievable.
The removal of the Frog Lane site could become a subject of some argument with the current owners, unless a site for the Primary school could be found close by.
There are two obvious possibilities which could meet this need:-
1. Oakes Farm, or
2. Grange Farm.
Planning implications
Balsall Parish Council over many years has always hoped that Balsall Street (B4101) would be the western boundary and kept clear of development. The officers reviewing the options on this settlement are in effect sanctioning development beyond B4101. The only previous development on the west side was approved in the early 90s, of which I had some involvement – Saracen’s Drive.
Oakes Farm is a large site which could accommodate a newly relocated Primary school. The land is extensive but is not level. [The owners have submitted their site for development. This has not found favour with officers.]
Grange Farm is a much larger site and included in the proposals for development a new Primary school was included. It is large enough for some form of open space / parkland to be included, thus keeping current uses in place.

Include strategy to address possible additional development needs in Balsall Common.

I am concerned that there will be an unbalanced development in Balsall Common, if the current Draft Plan comes to fruition.
During the process of the Village Plan which reported in 2009, we undertook much research. One of the key questions we asked of senior officers was the calculation of children of school age as part of new development. We were advised that 1000 dwellings would produce 800 children of school age.
One of the issues of critical importance was the co-efficient relating to school numbers/pupils. This was very valuable at the time. During submissions from 2012, I have continued to ask whether the equation in 2008 had changed. I am assured that the equation of 1000 dwellings would produce 800 children / students of school age.
There is a statement in the document covering Balsall Common that a two-form entry Primary school would be built as part of the Barratt’s Lane development. There is also a statement that Heart of England School could cope with the construction of 1680 dwellings. However if the numbers proved beyond this capacity, expansion of the school would come from developer contributions. This is currently an unknown situation. Perhaps a strategy to cover this potential would be advisable. Para 526 is clear that requirements from other locations may mean that Balsall Common is destined for more development.
May I submit that this inference could prove to be unnecessarily costly to SMBC, unless additional accommodation could be provided?
My thinking is along the following lines: -
1. The current Primary School is over subscribed to the extent that the Head Teacher has relocation in mind; over-sized classes at Primary level are best avoided. [I am given to understand that he has Frog Lane in mind.]
2. The calculation of school places needed from 1680 dwellings is 1344 new arrivals. Taking this figure over 12 teaching years, this amounts to the addition of 112 per year group. If the calculation were taken over 15 school years, there would be 90 in each year group.
3. On the basis of these figures, it is difficult to see how the existing Primary school will be able to cope. [ 3 form entry is perceived to be too large]
4. Using the same formula, the 875 dwellings in Barratt’s Lane would produce 700 pupils. Clearly some “relocation” of pupils from the current Primary school would be required.
5. This may not be popular or convenient for some parents as well as causing additional traffic.
6. The point is made that HoE school takes pupils from outside Solihull. Presumably officers have been in contact with Coventry City and other boroughs whose pupils attend Solihull schools? This would necessitate removing some pupils from outside.
This Draft Plan seeks to cover a decade or so, before further review is necessary. In these circumstances, perhaps dealing with the relocation of the Primary school initially could open the possibility of HoE expanding into the plot occupied by the Primary school. Clearly some internal reorganisation of infrastructure would be necessary – toilets and desks/tables with chairs. Overall a modest expenditure to enable the longer-term view to be achievable.
The removal of the Frog Lane site could become a subject of some argument with the current owners, unless a site for the Primary school could be found close by.
There are two obvious possibilities which could meet this need:-
1. Oakes Farm, or
2. Grange Farm.
Planning implications
Balsall Parish Council over many years has always hoped that Balsall Street (B4101) would be the western boundary and kept clear of development. The officers reviewing the options on this settlement are in effect sanctioning development beyond B4101. The only previous development on the west side was approved in the early 90s, of which I had some involvement – Saracen’s Drive.
Oakes Farm is a large site which could accommodate a newly relocated Primary school. The land is extensive but is not level. [The owners have submitted their site for development. This has not found favour with officers.]
Grange Farm is a much larger site and included in the proposals for development a new Primary school was included. It is large enough for some form of open space / parkland to be included, thus keeping current uses in place.

Include proposals for a relocated and expanded Primary School.

I am concerned that there will be an unbalanced development in Balsall Common, if the current Draft Plan comes to fruition.
During the process of the Village Plan which reported in 2009, we undertook much research. One of the key questions we asked of senior officers was the calculation of children of school age as part of new development. We were advised that 1000 dwellings would produce 800 children of school age.
One of the issues of critical importance was the co-efficient relating to school numbers/pupils. This was very valuable at the time. During submissions from 2012, I have continued to ask whether the equation in 2008 had changed. I am assured that the equation of 1000 dwellings would produce 800 children / students of school age.
There is a statement in the document covering Balsall Common that a two-form entry Primary school would be built as part of the Barratt’s Lane development. There is also a statement that Heart of England School could cope with the construction of 1680 dwellings. However if the numbers proved beyond this capacity, expansion of the school would come from developer contributions. This is currently an unknown situation. Perhaps a strategy to cover this potential would be advisable. Para 526 is clear that requirements from other locations may mean that Balsall Common is destined for more development.
May I submit that this inference could prove to be unnecessarily costly to SMBC, unless additional accommodation could be provided?
My thinking is along the following lines: -
1. The current Primary School is over subscribed to the extent that the Head Teacher has relocation in mind; over-sized classes at Primary level are best avoided. [I am given to understand that he has Frog Lane in mind.]
2. The calculation of school places needed from 1680 dwellings is 1344 new arrivals. Taking this figure over 12 teaching years, this amounts to the addition of 112 per year group. If the calculation were taken over 15 school years, there would be 90 in each year group.
3. On the basis of these figures, it is difficult to see how the existing Primary school will be able to cope. [ 3 form entry is perceived to be too large]
4. Using the same formula, the 875 dwellings in Barratt’s Lane would produce 700 pupils. Clearly some “relocation” of pupils from the current Primary school would be required.
5. This may not be popular or convenient for some parents as well as causing additional traffic.
6. The point is made that HoE school takes pupils from outside Solihull. Presumably officers have been in contact with Coventry City and other boroughs whose pupils attend Solihull schools? This would necessitate removing some pupils from outside.
This Draft Plan seeks to cover a decade or so, before further review is necessary. In these circumstances, perhaps dealing with the relocation of the Primary school initially could open the possibility of HoE expanding into the plot occupied by the Primary school. Clearly some internal reorganisation of infrastructure would be necessary – toilets and desks/tables with chairs. Overall a modest expenditure to enable the longer-term view to be achievable.
The removal of the Frog Lane site could become a subject of some argument with the current owners, unless a site for the Primary school could be found close by.
There are two obvious possibilities which could meet this need:-
1. Oakes Farm, or
2. Grange Farm.
Planning implications
Balsall Parish Council over many years has always hoped that Balsall Street (B4101) would be the western boundary and kept clear of development. The officers reviewing the options on this settlement are in effect sanctioning development beyond B4101. The only previous development on the west side was approved in the early 90s, of which I had some involvement – Saracen’s Drive.
Oakes Farm is a large site which could accommodate a newly relocated Primary school. The land is extensive but is not level. [The owners have submitted their site for development. This has not found favour with officers.]
Grange Farm is a much larger site and included in the proposals for development a new Primary school was included. It is large enough for some form of open space / parkland to be included, thus keeping current uses in place.

Include Site 82 Kenilworth Road as housing allocation, possible as alternative to Site BC3.

Along with Matthew Nightingale, we own over 2 hectares of land at Kenilworth Road, Balsall Common which has been put forward for consideration for residential development several times over the last 17 years, including in the latest invitation for Call for Sites in 2016/17 in relation to this current review of the Local Plan.
Our land, known as Site 82 in your evidence base, and shown on the attached site plan, has been assessed and considered to be a moderately performing parcel in the Green Belt similar to many other sites which have been put into allocations in the emerging Local Plan. The site does have defensible boundaries with the open space ransom strip on the north side of Dengate Drive, the woodland to the west and a green way to the north. The only significant negative in the assessment was distance to jobs but that is common to most if not all sites proposed to be allocated in Balsall Common.
As one of the owners of Site 82 I am of the view that the above site specifically should be included as a site for housing allocation as it accords with and addresses many of the challenges facing Solihull as it sets out how and where Solihull will develop in the future. Given the considerable local concern about the allocation of housing land at Windmill Lane, Balsall Common our Site 82 could offer at least a partial alternative to the proposed housing land in your current site BC3.
Our alternative site on the west side of Kenilworth Road is just adjacent to the existing Dengate Drive housing estate, and far closer to the village centre and services than both Trevallion Stud which you propose to designate to the north, and the Windmill Lane site further to the south which is far further from the village centre and is far less sustainable.
We note that Site 82 has been joined with Grange Farm and adjoining land in the Sustainability Assessment under reference AECOM76. We consider that to be unfair. This site should be separately considered. The Peter Brett assessment in the SHELAA notes that the site performs well against suitability and availability criteria, although it indicates that in their view the site faces some achievability problems. This may relate to the need to obtain an access to Kenilworth Road and we have indicated an access via No 166 Kenilworth Road – which we have recent confirmation that it remains available to us – and has been verified with the Council’s Highway Engineer as being acceptable.
Site 82 is a small to medium scale site in line with the NPPF requirements to consider such sites in Local Plans and provides an excellent opportunity for small to medium sized builders to make a significant contribution towards the overall future need for housing in Balsall Common. Moreover, it is in close proximity walking distance to all services including shops, medical centre, train services, and importantly all local schools without the need to use a car to use these services. There is a bus service stop within a few metres from the Site, which ensures a level of sustainability that the other locations would have difficulty in matching.
The land is flat and available, sustainable, suitable and deliverable now.
The release of Site 82 is favoured by many in lieu of development at BC3 Windmill Lane and has far better advantages, especially with its proximity to the village centre. No doubt due in part to the fact that the size and scale of the necessary development of this flat site would have minimal impact on the day to day life of the village. Whilst seamlessly fulfilling an urgent housing need that still has countryside surrounding it and within the current settlement boundary and existing residential properties without extending the village.

At the end of para 528 add the following " Within the settlement there is a particular deficiency of foodstores capable of meeting the weekly /fortnightly shopping needs of the local population. There is evidence of substantial leakage of expenditure on convenience goods by Balsall Common residents, mostly to large foodstores in Coventry, resulting in unsustainable travel patterns. This deficiency will be exacerbated in future years as a result of planned population growth. There is therefore, a need to attract a new foodstore to Balsall Common capable of meeting bulk food shopping needs. In recognition of the constraints to the location of such a store in the village centre, that new provision may have to be located out of centre, subject to the requirements of Policy P2 in terms of retail impact and the sequential test."

The policies for Balsall Common fail to identify a need for new convenience retail floorspace in the form of a new supermarket in the settlement to meet weekly/fortnightly bulk food shopping needs to reduce expenditure leakage and unnecessary travel.

In Balsall Common sites one or more of the fiollowing sites should be allocated for employment purposes. s
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

While it is clearly important in the Local Plan to address the issue of providing sufficient land for housing over the plan period, it is apparent that less serious attention has been given to the provision of new land for employment purposes.
The allocation of Site UK2 on land at Damson Parkway in the Policies Map, is to 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. That land has also been earmarked for the relocation of the existing public Civic Amenity Recycling site presently sited at Arden Eco Park
Arden Cross is being promoted as providing for housing as well as other uses including such as research and development and advanced manufacturing as part of an innovation district for employment and higher education.
The Council has readily diluted the original business allocation of Blythe Valley Park and other business parks with significant residential development.
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.
In Balsall Common sites such as
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

The plan shows a new school located at what would be a junction with the proposed relief road. As the relief road is designed for traffic to bypass Balsall Common, it defeats the object of it going directly to the school, where it will congest with the local traffic trying to get into school from within Balsall Common.

The location of a primary school in the field centered on SP2442777314 will increase traffic on the already busy Station Road.

The plan needs to recognise that green belt land should only be used when absolutely necessary, and only after all brown field alternatives have been developed

The plan for Balsall Common is an invasion of our green belt environment. Earlier consultations and discussions with the local population made it clear that the residents were in favour of some development, and a number of brown field alternatives were suggested . As a result of this Solihull plan now includes those brown field sites with NO reduction in Green Belt development, a clear disregard of local democracy.
Residents have also made it clear that the infrastructure of the village centre is unsuited to an additional 1000+ homes

Not to put a primary school next to the station

Not appropriate to put a Primary School next to a station. Will also cause issues with parking, safety and congestion.

Reduce the amount of development taking into account case law on Listed Buildings and the impact on the openness of the Green Belt. Land at 114 - 118 Widney Manor Road to be allocated as a residential site in part compensation for a reduction at Balsall Common.

All sites in Balsall Common are poorly related to employment, and BC1 to BC5 have adverse impacts on the Green Belt compounded by their location in the sensitive Meridien Gap. BC1 will adversely affect the setting of several Listed Buildings contrary to case law.

This site must be removed from the plan in favour of alternatives where delivery can be within the plan period.
Barratt's Farm overlooks the Greenway which has taken 50 years to mature and 5 days to destroy for HS2. The Barratt's Farm site is due for new build in the second and third phase of the plan after HS2 has been completed allowing for an access road/by pass to be built. This site must not be taken out of green belt until the site has funding arranged for the By-pass.

Ref. BC1 Barratt's Farm Green Belt is not just in the Meriden Gap, it is at the narrowest part of the Gap protecting the merger of Solihull with Coventry. The plan talks about protecting the Meriden gap so why would you choose to build the largest number of homes on one site reducing the gap so significantly at the narrowest point when alternative sites were available.
The site was chosen based on site selection criteria that appeared to need more clarification. Alternative sites in the Borough could have been chosen which would not have reduced the existing Gap.

Para 527. In order to be a meaningful by-pass the Balsall Common Relief Road will be planned and constructed as a single entity not in phases.

Para 528. Delivery of the enhanced centre will be from grant funding opportunities that may be available from such as the West Midlands Combined Authority and/or from a combination of SMBC and Parish Council CIL monies.

Para 531. The building of the new 2 form entry primary school will be at the earliest stage of the Barratt's Lane development to cope with the expected population growth from the large scale housing development across Balsall Common.

527. Balsall Common Relief Road. While supporting the proposal for a by-pass there is great concern that it will be built in such a piece meal way that it becomes merely a feeder road/rat run for the large Barratt's Farm development and cause greater congestion in the centre of Balsall Common.

528. Enhanced Centre. Aspirational but without sufficient information on its funding.

531. New Primary School. The present school cannot cope now so this is welcomed, but it must be built at the earliest stage of the Barratt's Farm development not after the houses are built.

527: Proposal for the relief road to be made a bypass should be halted. This road should provide access to the new development only.

528: Proposal that further retail shopping areas should not be built in the Balsall Common area. This is a village which will loose it's heart and soul if a retail development proceeds. There is access to Coventry, Resort World, Kenilworth, Birmingham for wider retail needs of the village.

530: There is no evidence to suggest local transport will improve with HS2. Commuters would prefer to continue to use Berkswell service for Birmingham, Coventry and London than drive to the NEC, park at considerable cost and then use HS2 services at considerable cost.

Proposal for a regular bus route linking Kenilworth to balsall common and onto the NEC and airport.

531: The proposal for a Primary School and Nursery at the northern end of Station Road is unacceptable and illegal. This area is designated a site of ecological significance. and must not be developed on under any circumstances.

The fields and ponds between the railway and existing homes are full of diverse wildlife. the area is home to:
Bats Newts Frogs Toads Butterflies Bees Dragonflies Muntjack deer Shrews Voles Owls King fishers Heron Moorhens Mallard ducks Pheasants Polecats Hedgehogss jays Robins Sparrows Blackbirds Swifts

These animals will not be able to use the green space along HS2. Instead, these animals need corridors and connected spaces between the existing village and development to enable their survival and free access to roam across the countryside as they do at present. If these corridors are removed the wildlife and beauty of Balsall Common will be destroyed.

PROPOSAL 1: FOR A GREEN BELT FROM THE HORSE FIELD AND PRESERVED WILDLIFE AREAS AROUND ALL PONDS IN THE ECOLOGICAL AREA OF SIGNIFICANCE AT THE WESTERN END OF THE SITE AT STATION ROAD THROUGH TO WASTE LANE AND OPEN COUNTRYSIDE. This should be two fields deep behind all existing homes to ensure these areas are preserved. See Landscape assessment which states" those areas highlighted on the southern and western boundaries should be enhanced as grassland creation and enhancement zones."

PROPOSAL 2: FOR THE PRIMARY SCHOOL TO BE SITUATED IN THE CENTRE OF THE PROPOSED DEVELOPMENT. The proposed site on Station Road is an area of ecological significance and should not be developed. Instead the school should be in walking distances from all new homes in the centre of the development. Thus averting congestion and a a bottle neck at Station Road with the round about, relief road, low bridge under the existing train line and HS2.

535: Proposal for green belt enhancement to be positioned between the existing village and the new development. This not only preserves valuable wildlife but enables natural woodland and grasslands for recreational use for the health and well being of all village resident. It also links communities to the heart of the village centre and amenities rather than simply providing access to the station.

527. OBJECTION: Relief Road: further divides Berkswell Parish which already has an existing railway & HS2.
528: OBJECTION: The village centre is adequate for the village & proposed development with 4 supermarkets.
530: OBJECTION: There is no evidence to suggest transport links will be improved or that more transport links are necessary as this is a commuter village with 2 cars per household.
531: OBJECTION: location of proposed Primary School is on the site of an area significant ecological value. This is a wildlife haven that should be enhanced.
535: NOTE: green belt enhancement should be around the existing village.

It is proposed that the similar wording is used as that for the relief road funding and the following words should be added to the end of paragraph 528.
“Delivery of the enhanced centre will be from grant funding opportunities that may be available through for instance, the WMCA and/or from a combination of SMBC and Parish Council CIL funds.”

See attachment

Balsall Parish Council supports the re-phasing of housing allocations proposed by Berkswell Parish Council in its submission to ensure that primary school provision keeps pace with housing development and that the plan is sustainable and sound.

See attachment

Reference Solihull MBC Local Plan – publication stage. Guidance Note to Accompany Model Representation Form – Legal Compliance and Duty to Cooperate – paragraph 2.3.
“Non-compliance with the duty to cooperate cannot be rectified after the submission of the plan”.
The plan should not be submitted to the Secretary of State until the SoCG has been negotiated, published and the public have had an opportunity to scrutinize it with a 6 week consultation period.

See Attachment

Policy BC1 2 ix to read:
Provision of sufficient public open space around water courses, heritage assets and ecologically sensitive areas to bring the average POS ha/1000 head of population for the site up to the average for the rest of Solihull Borough.
Policy BC1 3 ix to read:
Provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and SMBC Cabinet meeting 13/08/2020 agenda item 3.5 and 3.6; and resolution 5. Land acquisition on Site BC1 to be funded according to Cabinet meeting 13/08/2020 resolution 5 i, ii, iii.
Concept Master Plan Principles for BC1 to include the sentence:
POS to provide a buffer to the south of the development between the new and existing properties providing an opportunity for a public park and for the integration of the future and existing residents.
The Concept Master Plan for site BC1 should be amended so that the 4 areas designated as low density housing between the footpath running SE from Barratt’s Lane and the houses on Meeting House Lane/Kelsey Lane are designated as POS.
The medium density housing area immediately to the NE of Old Waste Lane should be shortened so that there is POS to the rear of the existing properties (see attachment).

See Attachment

Policy BC1 3 to read
“Infrastructure requirements will include:” (Ie remove “Likely”)
i. Provision of a new 2 form primary school and nursery before any major house building takes place.
iii. A thorough evaluation of the impact and sustainability of the development on all health care services carried out by SMBC and the CCG. Developer and Solihull MBC contributions to…..CCG.
x. A detailed master plan for the enhanced village centre, published and funded, and agreed by the Borough Council, Balsall and Berkswell Parish Councils, Village resident’s association and local action groups; before any development is begun.

See Attachment

If the transport survey proves that the full bypass from Mere End to the Hall Meadow Road junction with the A452 will not cause serious congestion, pollution and safety problems, then:
Policy BC1 3 vi to read
“Provision of the Balsall Common bypass between Station Road and Mere End as the first phase of the development.”

If the transport survey raises congestion, pollution and safety issues, then Policy BC1 3 vi to read
“The Site BC1 estate feeder Road between Station Road and Waste Lane to be designed to ensure it is not possible to use it as a “rat run” to bypass the village centre.

See Attachment

Paragraph 525 to read “…..with the main works due for completion during the period 2029-2033 ready for the line to open at some later date still to be confirmed.”
Policy BC1 2 vi changed from “Housing shall be phased to avoid coinciding with construction of the HS2 rail line in this vicinity” to “No housing development to be started in site BC1 until all construction work on the HS2 rail line affecting this location is completed”.
Policies BC4, BC5, and BC6 should have similar amendments

See Attachment

The Sustainability Appraisal should be exploring alternative options, including elsewhere in Balsall Common and/or other highly accessible settlements such as Hampton-in-Arden.

The allocations in Balsall Common should be revised to refer to updated, robust evidence around the infrastructure requirements and deliverability; otherwise they should be deleted.

Hello,

Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.

Regards,

Please accept below my response to the Local Plan Review Consultation.

My initial comment is that distribution of new housing in the Borough is biased towards two geographic areas resulting in 31% of the total being proposed in the Balsall Common area within the Meriden ward and 39% within the Shirley South and Blythe ward areas that are geographically adjacent. The majority of the land involved is within the Green Belt. The Shirley South site is site 11 within the previous iteration of the Local Plan document, which is in the process of being built.
There are proposals included in other wards which are not particularly significant in terms of housing numbers and consequent impact on those local areas.
The document refers to proposed housing provision within Solihull town centre and the Arden Cross and National Exhibition areas adjacent to the proposed HS2 railway station. No numbers are provided within the current iteration of the Local Plan document for either of these locations. This is a significant omission from this version of the document as it means that inclusion of the detail for these sites could take a significant amount of pressure off the areas detailed above and reduce the amount of Green Belt that is currently committed within the document.
A further significant impact of the proposals is the situation regarding local school places at the primary level. This is a particular issue within the Blythe ward area. Primary schools exist at Cheswick Green, Dickens Heath and Tidbury Green. All are currently single form entry with nursery units. The sites in the Local Plan document within the catchment areas of these schools are BL1 in Dickens Heath, BL2 at Dog Kennel Lane and BL3 also in Dickens Heath. Two sites currently being built which have an impact are site 11 from the previous iteration of the Local Plan and a further development at the Blythe Valley Business Park site.
Dickens Heath school is single form entry with no scope for expansion. Both Cheswick Green and Tidbury Green primary schools are in the process of being extended to two form entry. A further two form entry primary school is proposed as part of site BL2.
My main concern regarding primary level schooling in the area is that the increased number of houses will generate significant traffic level increases in the surrounding area on what are already busy roads with some effectively being country lanes. This will also significantly increase already high traffic pollution during school drop off and pick up periods. This will have an impact on the Council’s developing Net Zero Carbon plan.
Congestion is already a problem around both Dickens Heath and Cheswick Green schools as there is no off road parking provision at those two locations.
Another concern is that the Local Plan proposals in its current form will add to the existing significant pressures on the local health service provision. There are no documented proposals to enhance the existing local health service provisions to support the increased number of residents.
The proposals also cause merging of the existing settlements within Blythe ward.
Potential flooding in the area is also a concern. Rainfall run off from the sites discussed feed into the river Cole to the north and the river Blythe to the south. The river Cole impacts on roads within Shirley West ward, particularly Nethercote Gardens. The area has suffered from two one in a hundred years flooding incidents within the last 15 years. The river Blythe impacts on Cheswick Green village In Blythe ward and the lower part of the village has also been impacted by two one in a hundred years flooding incidents within the last 15 years.
The proposed local plan does not conform totally with the sentiments of the National Planning Policy Framework which contends that brown field sites should be considered ahead of Green Belt land for housing. The Arden Cross area and Solihull town centre fall into this category and their use to support housing should be considered ahead of use of Green Belt land.
The climate change agenda suggests that locations for housing should be sustainable and not car dependant. Within Blythe ward all roads are very busy and not conducive the cycling and walking. Local bus services are infrequent and follow circuitous routes which are not conducive to encouraging large numbers of users. Consequently there is a high dependency on the use of private cars in all of the settlements within the area. The proposed developments will only make the current situation worse with consequential increase in local pollution.
There is no defensible boundary identified between site BL2 and Cheswick Green village.
My final concern is that there are mainly inaccuracies within the issued Local Plan.

Introduction
Paragraph 18 sets out that the site allocations from the Solihull Local Plan (December 2013) will be brought forward. We consider that the automatic allocation of these sites which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach. We address this in more detail under our comments in respect of Policy 4.
Finally, Paragraph 21 refers to neighbourhood plans and the importance SMBC places on these. Paragraph 30 of the National Planning Policy Framework (NPPF) sets the most recently adopted policies will take precedence. SMBC may wish to set this out within this section, to make it clear that the LPR will take precedence upon adoption over any currently adopted Neighbourhood Plans.
Soundness – The Plan is not:
- Justified
Change Sought:
- Existing allocations should be tested for deliverability prior to re-allocation
- The hierarchy of neighbourhood plans should be made clear
Vision
Given that paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positively worded.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- The vision should be more positively worded in order to significantly boost the supply of housing
- The need to release lower performing green belt to meet identified needs, and preserve higher performing parcels, should be set out
Providing Homes for All
Policy P4C Meeting Housing Needs – Market Housing
We object to the inflexible market housing mix which is prescribed within this policy. The NPPF encourages provision of balanced and mixed communities catering for a wide range of the population.
Individual sites should cater for a wide range of housing types and sizes. Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long term sustainable communities. Instead it will result in a transient community where people will not be able to form long term neighbourhoods as they will need to move on as their circumstances change if there are insufficient homes of the right size on a site to accommodate them. We do not consider that this represents good planning and consider that the focus should be on building strong healthy communities which can cater for all, rather than simply planning for short term ownership.
The inclusion of a prescribed housing mix runs counter to the criterion elsewhere within the policy which allow a number of factors to be taken into consideration. This plan has a significant lifespan and to prescribe a housing market mix which is to remain in place for the whole of plan period does not provide sufficient flexibility for adaptation to current housing need and demand. We have seen with the current pandemic the way external factors can influence people’s choice of lifestyle.
Soundness – The Plan is not:
• Justified
• Effective
Change Sought:
• Amendment of policy to allow for housing mix based on up to date market evidence
Policy P4D Meeting Housing Needs – Self and Custom Housebuilding
The latest Annual Monitoring Report (March 2020), covering the period 2018/19, sets out that for the period November 2018 – October 2019 there were 374 entries on the Self-build register.
As such, requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision is being made for 7,605 houses through allocations above 100 houses and the UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations.
The Planning Practice Guidance (PPG) advises that the Council should engage with landowners who own sites that are suitable for housing and ‘encourage’ them to consider self-build and custom housing and who are interested in provision. Imposition of mandatory requirement goes beyond encouragement.
Following the example of Stratford District for example, the Council have specifically identified custom build sites which are discreet standalone small sites.
We also include extracts from the Bedford Local Plan Inspector’s Report (Appendix 4) where the Inspector recommended deletion the policy akin to that being proposed here as the policy was not justified with reference to the self-build register. The same principle applies here in that the amount being sought is over double that on the register.
Soundness – The Plan is not:
• Justified
• Consistent with national policy
Change Sought:
• Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites
Policy P5 Provision of Land for Housing
Policy P5 sets out the Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing supply to deliver 15,017 additional homes in the plan period. This would result in an average annual housing land provision target of 938 net additional homes per year. This annualised target is made up of a stepped requirement with 851 homes per year delivered between 2020-2026 and 991 dwellings delivered between 2026-2036.
Demand
A Housing Need Technical Report has been provided (December 2020) (Appendix 5) and should be read in conjunction with our commentary on Policy P5. In summary, this Note makes the following key points:
• Planning Practice Guidance (PPG) states the Standard Method (SM) figure represents the minimum housing need, and there may be circumstances whereby need is higher;
• The Draft Plan identifies the clear economic growth aspirations for the Borough, including the nationally significant growth planned for the UK Central Hub. This is a circumstance where housing need may exceed the minimum need. If it does, housing delivery must be of a quantum to support these aspirations;
• The Council’s 2020 HEDNA confirms that the calculation of housing need is underpinned by the growth at the UK Central Hub. The Hub is projected to generate an additional 13,000 jobs to the baseline Experian job growth forecast (10,000 jobs) included in the HEDNA;
• The HEDNA tests several economic-led housing need scenarios. However, the UK Hub Scenario assumes only 25% of the additional 13,000 jobs created by the Hub are to be taken up by Solihull residents. This results in the housing need (816 dpa) underpinning the Plan;
• However, this ignores the ‘Growth A’ scenario which concludes that 908 dpa would be required based on the ‘Adjusted Local Growth’ scenario. This scenario assumes that strong industries in Solihull will outperform the baseline Experian forecast, resulting in an additional 5,680 jobs to the baseline (10,000 jobs) over the Plan period, with Solihull residents taking up these jobs;
• However, no scenario is presented to show what the housing need would be based on the UK Central Hub scenario being fulfilled in full by Solihull residents. It is important to understand this so that the duty to cooperate discussions referred to in the HEDNA are well informed;
Barton Willmore provide these sensitivity scenarios based on two approaches to commuting, and two approaches to underlying demographic rates (mortality, fertility, and migration);
• The results of our testing are summarised in Table 7.1:
Table 7.1: Solihull Borough – Barton Willmore Demographic Forecasting 2020-2036 Scenario Demographic rates Jobs per annum 2020-2036 Dwellings per annum 2020-2036
Dwelling-constrained:
Standard Method
2016 ONS rates
7721 – 8132
807
2018 ONS rates
1,0141 – 1,0682
Employment-constrained:
UK Central Hub
2016 ONS rates
1,437
1,1991 – 1,2482
2018 ONS rates
1,0361 – 1,0852
Source: Barton Willmore Development Economics
1 Commuting Ratio 0.98
2 Commuting Ratio 0.93
• Growth of between 1,036 and 1,248 dpa would be required to support the UK Central Hub scenario (between 16,576 and 19,968 dwellings in total);
• This represents an increase of between 220 dpa and 432 dpa on the housing need calculated by the HEDNA (816 dpa), or an additional 3,520 to 6,912 dwellings over the Plan period;
• Our analysis of historic levels of job growth in Solihull 1991-2019 shows a range of 1,225 and 1,650 jobs per annum (jpa). This highlights that the UK Central Hub scenario (1,437 jpa) is a realistic assumption;
• The HEDNA identifies an ‘acute’ situation in respect of affordable housing need. Our analysis suggests that the HEDNA’s conclusion on overall need (816 dpa) should be increased to meet as much affordable need as possible.
• Furthermore, our analysis of unmet need in the wider GBBCHMA suggests that the 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031, and for Birmingham alone the deficit in unmet need is between 11,294 and 13,101 dwellings up to 2031;
• In addition, there is significant unmet need up to 2031 based on the existing Standard Method coming from Birmingham City and the Black Country. This amounts to unmet need of between 25,543 and 27,350 dwellings up to 2031. If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031. This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect once Birmingham’s Local Plan becomes older than 5 years in 14 months’ time;
Adoption of the proposed changes to Standard Method consulted on by Government in summer 2020 would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
• Furthermore, the unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.
• In summary, the analysis in this report results in the following broad conclusions:
1. The SM’s minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub and the ‘acute’ need for affordable housing in the Borough;
2. Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario;
3. 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 such, in order to ensure the LPR is positively prepared, SMBC should seek to plan for more housing, and should allocate further sites.
SUPPLY
Further to the above, and as set out above, we also consider that some elements of the supply should be reviewed:
Dealing with the supply side of the equation, we make the following objections to the various components of supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’. Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.
Solihull Local Plan sites
We question the automatic inclusion of Solihull Local Plan sites which have yet to be granted planning permission. The current Plan was adopted in 2013 and the Council cannot currently demonstrate a 5-year supply of housing. In this situation, the Council should be encouraging every suitable site to come forward. The fact that these sites have not come forward despite the housing shortfall, suggests that these should not be considered ‘deliverable’ housing sites without significant justification as to why they will now come forward when they have not to date.
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply. We consider that any sites to be delivered in this way should be considered as windfall developments.
Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.
UK Central Hub
We consider that given the scale of the UK Central Hub proposals, the rate of delivery assumed by the Council is overly optimistic. The Council have not provided any trajectory for the Site, and we note that the August 2020 consultation did not contain any firm commitments to delivery timescales or set out any delivery partners.
This assertion is supposed by the findings of the Lichfields’ Report1 that sets out the average time from outline planning application to the first delivery of homes is 8.4 years. The average build out rate is 160dpa.
As such, taking this into account, and based on a LPR adoption date of 20222, we consider the first completions will likely be C.2030. With an average build out rate of 160dpa, this means that approximately 960 dwellings will be delivered during the Plan Period, assuming that the housing is within the first delivery phases (the August 2020 consultation referenced a mix of uses coming forward). While more outlets may increase the speed of delivery, the amount of infrastructure required also needs to be taken into account. The type of supply also needs to be considered, with UK Central Hub likely to be geared towards apartments.
As such, we consider that 1,780 houses should be removed to take into account the likely delivery timescales.
Trajectory
We also note that SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase. The Inspector assessing the Guildford Local Plan set out:
39. In the submitted plan, the combined effect of the stepped trajectory in Policy S2 together with the “Liverpool” methodology (in which the delivery shortfall accumulated over the first 4 years of the plan (2015/16 to 2018/19) is spread over the whole plan period), would have deferred a significant proportion of the housing requirement to the later years of the plan. Set against the (then higher) housing requirement, this would not have met the Government’s objective to boost the supply of housing in the shorter term. (our emphasis)
We consider that SMBC should take the same approach as Guildford and allocate further sites to meet need early in the Plan Period. The existence of the UK Central Hub is not of a sufficient size to warrant a different approach (i.e. it is not akin to a new settlement).
Further, as with the withdrawn Uttlesford Local Plan, this stepped trajectory may create a fragile 5 year housing land supply position, taking into account the ambitious delivery targets of the UK Central Hub and the delivery concerns relating to the draft allocations set out below. The Inspectors’ letter relating to the withdrawn plan states:
29. This calculation relies on the use of a reduced annual requirement of 568 dpa for most of the years, as it is based on the stepped trajectory set out in Policy SP3. It is also based on what we consider to be unrealistic commencement/housing delivery dates for two of the Garden Communities (North Uttlesford and Easton Park, as set out above). So, whilst the Council can, in theory, demonstrate a 5.65 year HLS, we are concerned that if the housing delivery at North Uttlesford and Easton Park slips by just one year, as seems very likely, this would result in 100 less dwellings in this 5 year period. This would result in a very fragile 5 year HLS position.
There are comparisons that can be drawn here based on the stepped trajectory and the anticipated 5.37 year supply upon adoption.
The Inspectors for the withdrawn Uttlesford Local Plan also referenced the need to meet the full objectively assessed need for market and affordable housing in the housing market area (NPPF Paragraph 47). The HEDNA states there is a ‘clearly acute’ shortage of affordable housing. The proposed stepped trajectory therefore may worsen the affordability problem as it would delay the provision of housing until late years of the plan period.
Taking the above into account, we consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
This is a reduction of 3,521 and, as such, to meet the increased demand set out above, and take into account the concerns relating to a stepped trajectory, a review of the supply is required and additional sites allocated.
The Council should also ensure that a large number of these sites can be delivered early on in the Plan Period in order to take account of the likely later delivery of some other sites.
Soundness – The Plan is not:
• Positively prepared
• Justified
• Effective
• Consistent with national policy
Change Sought:
• Review of demand and amendment to the strategy
• Review of supply and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible
Improving Accessibility and Encouraging Sustainable Travel
Policy P7 Accessibility and Ease of Access
We consider that the requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- Policy should be clarified that there are other ways of ensuring sustainable transport options are available
Policy P8 Managing Travel Demand and Reducing Congestion
Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.
Soundness – The Plan is not:
• Consistent with national policy
Change Sought:
• Point 2(ii) should be deleted
Protecting and Enhancing our Environment
Policy P11 Water and Flood Risk Management
With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Deletion of point relating to confirmation from relevant infrastructure owner
• Clarification as to obligation requirements and the necessary tests
Promoting Quality of Place
Policy P17 Countryside and Green Belt
Within Point 1 of the policy, SMBC is seeking to safeguard best and most versatile agricultural land (BMVAL) unless there is an overriding need for development that outweighs the loss. BMVAL is referenced within the NPPF at Paragraph 170 which states that planning policies should contribute to and enhance the natural and local environment by taking into account a number of criteria. One of these is:
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.
Firstly, we consider that including reference to BMVAL within a policy relating to Green Belt seeks to conflate two separate issues. Further, as can be seen above, the test set out by the NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL. As such, we consider this point should be deleted.
SMBC have set out, within Point 4, a number of different factors that may be taken into account when considering very special circumstances.
Further to this, point 5 sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given Green Belt is a spatial designation, designed to prevent sprawl, we consider that this requirement goes beyond the scope of the Green Belt, as set out in the NPPF. The LPR contains policies relating to protecting landscape, where necessary, and as such, this point should be deleted.
Soundness – The Plan is not:
• Positively prepared
• Consistent with National Policy
Change Sought:
• Deletion of point 1
• Inclusion of further factors which may create very special circumstances
• Deletion of point 5
Policy P17A Green Belt Compensation
Paragraph 138 of the NPPF sets out that ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.
Policy P17 is seeking to require this by requiring development on sites removed from the Green Belt to provide appropriate compensatory improvements to environmental quality and accessibility of remaining Green Belt in the form of a Section 106 Agreement utilising the below hierarchy:
1. Compensatory requirements as set out as part of the Local Plan masterplans
2. Where no compensation has been set out within the Local Plan masterplan, improvements are provided as:
i. Improvements within the Green Belt adjacent to, or in close proximity to, the development site;
ii. Improvements within the Green Belt adjacent to, or in close proximity to, the settlement or area accommodating the development;
iii. Improvements within the Green Belt in an area identified for environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.
3. In the event it is robustly demonstrated that none of the above options can be satisfied then the Council will accept a commuted sum.
Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.
Soundness – The Plan is not:
• Consistent with National Policy
Change Sought:
• Reconsideration of the policy to ensure that it is evidenced based, does not impact upon viability of schemes, and is in accordance with national policy
Delivery and Monitoring
Policy P21 Developer Contributions and Infrastructure Provision
Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Confirmation that digital infrastructure provision allows for viable development
Settlement Chapters
Policy BC1 Barratt’s Farm, Balsall Common
We note that 1,756 new homes are proposed for Balsall Common across the plan period with the sole justification seemingly being that it contains both a primary and secondary school and has a full range of retail and associated facilities. However, it is still described as a rural settlement with no significant areas of employment and the distribution strategy remains one of “proportional distribution”. 1,756 dwellings to a single rural village would be completely disproportionate. There is discussion in the document regarding delivery of a by-pass; provision a station car park; improved public transport and a new primary school. However, there is no discussion as to how these are to be funded / delivered relative to the level of growth identified. In addition, there is discussion regarding the scope to enhance the existing local centre and the provision of a village centre masterplan. However, this land is in multiple ownerships and there are no proposals for what these enhancements could entail or how they could function – particularly with a by-pass in place which could actually draw trade away from the existing centre.
There is no assessment of the ability of Balsall Common to deliver this level of growth in such a small area. Whilst clearly some sites (i.e. Barratts Farm) will be able to have multiple outlets, the ability of the market to absorb and deliver multiple sites at any one time in a rural location should be reviewed; particular when Balsall Common will be acutely affected by HS2 – both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
We also note that Barratts Farm is in multiple ownerships and these are described as “complex” in paragraph 541. This is the single largest site and the one which is proposed to deliver the by-pass. Within the previous draft of the Plan, it was stated that this site would only be taken forward if the landowners / promoters could demonstrate they are working on a collaborate and comprehensive basis. Reading paragraph 541, this collaborate working has clearly not been secured in the way it was envisaged and nothing additional is suggested to demonstrate that joint / collaborative working is possible.
The relief road is identified as being necessary for Barratts Farm in particular with the policy advising that is required early in the plan period. The road is provisionally to be funded via CIL payments; and grant funding which “may” be possible through the WMCA. Firstly, CIL payments can only be secured through those sites which will come forward in the future however these sites are Green Belt sites and cannot therefore be delivered until the Local Plan Review is completed and the subsequent CIL schedule is adopted. Secondly, there is no grant funding proposal in place to fund the road. As it currently stands this road is not deliverable. The road is required to be delivered early in the plan period i.e. before there are significant CIL funds in place and, potentially, at a point where, in order to receive grant funding, applications should be being made now / near future.
There has to be serious doubt over the ability of Barratts Farm to be delivered within the anticipated timeframes and therefore places serous doubt over the plan as a whole given the scale of this allocation.
The Sustainability Appraisal notes that there are limited employment opportunities within Balsall Common and that people travel outside of the settlement to work. As such, it is noted that the expansion of this settlement would fly in the face of sustainability objectives of reducing the need to travel to areas of employment. Whilst such a case could be made for the majority of the rural areas of the Borough, it is heightened especially here when such a large proportion of future growth is identified for one rural settlement.
At this stage, the level of growth attributed to Balsall Common is disproportionate and that inadequate research has been undertaken into the deliverability of this level of growth and the associated aspirations; and the ability of the market to deliver this level of growth in a rural area is considered to be unrealistic.
On the basis that we do not consider the sites identified to be deliverable and the significant shortfall in supply identified by the more realistic timescales we have identified for UK Central, we propose an alternative site – Land at Hawkshurst (Site 544) as an alternative to meeting part of this need. To date this site has been inappropriately assessment by the Council and a more appropriate evaluation of the site is given in the section below.
Policy BL1 – West of Dickens Heath
The policy requires that the proposal for BL1 secures the relocation of the existing sports provision to a suitable site in the local vicinity. Until such time as these facilities are relocated or a plan is in place to secure timely relocation (which should include the grant of planning permission in our view, given that any site will be in the Green Belt), then the site cannot come forward for development. Our key concern here relates to Site 4 (West of Dickens Heath). It is noted that the identification of a Local Wildlife Site within the site hampers re-provision within the site itself and therefore alternative options will need to be pursued outside of the site. We consider that these alternatives should be considered now as clearly, as it currently stands, the pitches will be lost with no alternative in place (and therefore no guarantee of any re-provision). This is all the more important given that the land in the area is all located within the Green Belt and therefore any proposals which may, for example, include floodlighting, will have to be carefully considered against the Green Belt ‘tests’. We understand that the loss of these facilities is causing significant local concern particularly with no proposals for replacement.
The Council have had ample time to identify and secure alternative provision and therefore the fact that this is not identified within the plan, suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Policy KN1 Hampton Road, Knowle
As with the Site West of Dickens Heath, this draft allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable. However, this pre-judges any application, for which the detail is not known, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Site Assessment Criteria
We consider that a more dispersed growth option should be considered and, as set out previously, consider that the land at Broad Lane, Hawkshurst (Site 544) is ideally suited to make an important contribution to the Council’s housing need. Following the Council’s own site selection criteria, we set out why this site is a suitable and deliverable alternative site which can be delivered utilising existing infrastructure:
We object strongly to the manner in which Site 544 has been assessed in the site selection process for the reasons which are set out below – and on that basis, object to the inconsistent application of the methodology.
Firstly, in assessing Site 544, the Council deemed that the site did not pass ‘Step 1’ – which is the initial, high-level sieving process. Sites which are not taken forward at this stage are then not subject to the more refined ‘Step 2’ analysis. We consider the manner in which the process was applied is fundamentally flawed and have carried out our own assessment (using the Council’s own analysis) to demonstrate that the site should not have been discounted at Step 1 and should have been included in Step 2.
STEP 1
The first stage in the sieving process is a high-level look at the following:
(i) Brownfield vs greenfield
(ii) Urban areas vs Green Belt
(iii) Accessibility
Sites can be rated from Priority 1 (brownfield in urban area or settlement) to Priority 10 (greenfield in isolated highly performing Green Belt location). A traffic light rating is then applied – sites which falls within Priority 1 to Priority 4 are green sites; Priority 5 sites are yellow; Priority 6, 6b and 7 sites are blue; and Priority 8, 9 and 10 sites are red. Red sites fail Step 1 and are not taken forward to Step 2 for assessment. Site 544 was incorrectly identified as a Priority 9 red site and was not therefore taken forward to Step 2.
In summary, Site 544 is a greenfield and Green Belt site. However, it is accessible (being on the edge of the Coventry urban area) and also within an area with a low GB score of 5. Therefore, it should be allocated a Priority score of no higher than 5 (yellow). We review below the manner in which this initial sieving assessment was flawed - taking Site 544 step by step through the same assessment process as the Council.
Green Belt
In the Green Belt Assessment 2016, Site 544 is identified as part of Refined Parcel RP83:5 which has a combined score of 5, within a range from the highest performing Green Belt sites (12) to the lowest performing sites, scoring as low as 0. With a score of 5, site 544 is clearly a lower performing site. The starting point for consideration as a Priority 5 site is a score of 5 or lower in the Green Belt––Site 544 falls into that category. The results of this assessment are backed up by our own Green Belt assessment which is included with this submission.
Accessibility
The second part of the criteria relates to accessibility and to achieve a Priority 5 ranking, the site is required to be in an accessible location. This is defined as:
(a) On the edge of the urban area or
(b) On the edge of a settlement which has a wide range of services and facilities including a primary school and a range of retail facilities.
Site 544 adjoins the urban edge of Coventry – indeed in the Council’s Site Assessment, the site is identified as possibly being an extension to Coventry.
It should be noted that in relation to the Publication Draft Plan, the Council have updated the Accessibility Study to take account of retail / surgery provision in adjoining LPA areas, however they have then not used this information to re-visit first principles and determine whether sites have been appropriately assessed from the start. Therefore, whilst this site now scores more positively, its ‘priority 9’ status has not been re-evaluated despite an Addendum to the Site Assessments being produced and the Accessibility Study being revisited. It appears that despite the site being on the urban edge of Coventry this has been discounted due to the sites geographical relationship with Coventry as opposed to Solihull. However, accessibility should be based upon spatial location rather than boundaries. The fact that the retail offer is in Coventry will not prevent residents of Hawkshurst using it.
For the absolute avoidance of doubt therefore, we enclose our own submission produced by Phil Jones Associates which demonstrates that the site is in a suitable and sustainable location.
It is fundamentally incorrect for Site 544 to have been ‘sieved out’ at Step 1. The site should have been correctly assessed as a Priority 5 yellow site as it meets the two necessary criteria. The site, therefore, should have been taken forward for a more detailed analysis in Step 2.
On the basis that the site does pass Step 1 – we have carried out the Step 2 assessment using the same table and criteria as the Council. There are no scorings or weightings attributed to the Step 2 analysis – it assessed on a qualitative basis.
STEP 2 – REFINEMENT CRITERIA
FACTORS IN FAVOUR
In accordance with the spatial strategy
(including only proportional additions to lower order settlements (i.e. those without a secondary school or not located close to the urban edge).
The preferred spatial strategy would be to locate development needs close to where they arise. However the Plan identifies that there is limited land available to achieve this and therefore the Council has had to look at alternative options, which includes land released from the Green Belt in the form of urban extensions and also followed a more dispersed strategy for development. They have sought to focus development in locations that are, or can be made, accessible and sustainable. Such locations are identified as typically being on the edge of urban areas (or within ruralsettlements) that have a greater range of services. Potential locations for development include adjoining the urban edge or a highly accessible settlement. This will have the benefit of focusing on urban areas and sustainable urban extensions to provide the best opportunity for achieving accessibility and delivering public transport improvements.
It is abundantly clear that geographically Site 544 adjoins the urban edge of Coventry – Coventry is the second largest City in the West Midlands, after Birmingham. Site 544, as confirmed in the SHELAA assessment, would be viewed as an urban extension to Coventry and there is, therefore, no doubt that Site 544 is in accordance with the Spatial Strategy, which seeks to locate development in the most accessible locations. Coventry is clearly such a location and there is nothing within the Spatial Strategy which would rule against this.
Therefore, it can only be concluded that the development of Site 544 would be in accordance with the Spatial Strategy.
Any hard constraints only affect a small proportion of the site and/or can be mitigated.
The SHELAA does not identify any hard constraints – we concur with this assessment.
The site would not breach a strong defensible boundary to the Green Belt.
There are no strong existing defensible Green Belt boundaries that would be breached. The existing boundaries to Bannerbrook Park comprise simply hedgerows, some of which were planted in conjunction with the existing development. The same form of boundary treatment can therefore be replicated on this site and indeed is proposed within the masterplan included with this submission.
Any identified wider planning gain over and above that which would normally be expected.
Following discussions with local undertakers regarding the lack of burial space available within the Borough, the landowners are willing to offer land for a multi faith burial space which will provide a much needed facility for the Borough and also secure the long term permanence of the Green Belt boundary in this location.
Sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
See above.
If finer grain accessibility analysis (including output from the Accessibility Study) shows the site (or the part to be included) is accessible.
The Accessibility Study is flawed when it comes to assessment of sites on the Solihull / Coventry boundary. The Study provides a scoring for accessibility for facilities within 1,200m of a site, however when assessing facilities beyond the administrative area of Solihull only facilities within 800m of the boundary are assessed, this is despite an updated assessment being provided in 2020 which proposed to apply some adjustment of standards and yet makes no sensible adjustment to standards for cross boundary provision. Sites in such locations are not therefore being assessed on a comparable basis. Furthermore, the assessment is only being undertaken of walking distances and makes no allowance for accessing facilities by bike. The document references ‘shared cycle’ routes but then makes no consideration of people actually using them for cycling. Clearly were cycling to be factored in, especially for those sites, which adjoin major settlements and therefore have access to a good cycleway network (such as Site 544) then their accessibility criteria would be much improved.
Whilst it is noted that some provision is now taken off cross boundary retail provision and public transport which has moved Site 544 to a higher scoring position; it is still not being assessed on a comparable basis.
There is a shared footway/cycleway through the Bannerbrook Park development which can be extended into Site 544. Furthermore, opportunities will be considered to accommodate a bus route through Site 544 and on through Bannerbrook Park.
It is therefore clear that the proposal can only be defined as being in an ‘accessible location’.
FACTORS AGAINST
Not in accordance with the Spatial Strategy
As set out above, the development of this site is in accordance with the Spatial Strategy
Overriding hard constraints that cannot be mitigated.
There are no hard constraints identified.
SHELAA Category 3 sites unless demonstrated that concerns can be overcome.
The site is not identified as a Category 3 site in the SHELAA. We make comments below in respect of the flaws of SHELAA assessment and carry out our own assessment.
Sites that would not use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
As already confirmed, the site uses existing defensible boundaries and proposes to strengthen the defensible boundary and strengthen existing hedgerow planting.
If finer grain analysis shows the site (or the part to be included) is not accessible.
As previously confirmed, the Council have failed to consider the proximity of services in Coventry on a fair basis and because of this, it is not possible to determine how detailed the assessment has been. However, given that the site adjoins a major urban area is it simply not feasible to draw a conclusion that the site is inaccessible.
If the site is in a landscape character area that has a very low landscape capacity rating.
It is wholly unreasonable if the Council have used this criterion to discount this site. According to the Council’s Landscape Character Study (December 2016) this site falls within Landscape Character Area (LCA) 26 – which covers the eastern fringe of the Borough – yet significant Green Belt release is proposed in other areas of the Borough which are in an identical LCA. With one blanket ‘very low’ landscape capacity conclusion for such wide areas it cannot be used to discount some sites and not others – there must be parity in assessment. Furthermore, the study itself (page 49 – text adjoining Table 24) confirmed that it is not possible to establish a baseline sensitivity to change without having details of a given development proposal and therefore the conclusions should be taken as a guide only. On this basis, we do not consider it appropriate to use this criterion as a basis to discount sites given sites with the same assessment have been given a ‘green’ score’.
We enclose with this submission our own detailed, site specific, landscape and visual appraisal which confirms that the site has the ability to accommodate development of scale which is comparable to the surrounding area without compromising the function of the surrounding Green Belt.
If the SA appraisal identifies significant harmful impacts.
The SA identified 2 harmful impacts:
(i) The site contains over 20ha of Grade 1 – 3 agricultural land.
The site is wholly Grade 3 agricultural land – clearly within Grade 3, the site could in fact be Grade 3b land which would mean it is not BMVL. Furthermore, the Regional ALC mapping, which was last updated in November 2018, shows this to be the prevailing land type across the Borough which is not unsurprising. As a result, a number of proposed allocated sites have the same classification. It is not therefore appropriate to identify this as a harmful impact when a consistent approach has not been applied across the board.
(ii) The distance to jobs is identified as 8km within the SA
This is clearly incorrect as the SA treats the administrative boundary between Coventry and Solihull as a line which people will not cross. This is clearly incorrect. As already stated, there is for example a good bus connection to Warwick University which is a key local employer as well as Coventry city centre which offers multiple employment opportunities. The SA has applied the same approach to all services and facilities – relating its conclusions only to Solihull Borough and thus the distances to shops / schooling / healthcare are distorted. In addition, we highlight that this is a specific issue related to Balsall Common also (which is also further away from Coventry) and yet the Council has seen fit to allocate in excess of 1,700 dwellings in Balsall Common.
In summary:
• The site has medium / high accessibility – at the same level as the other ‘green sites’ identified in the Draft Plan.
• The site is in lower performing Green Belt than other ‘green sites’ in the plan.
• The site has existing defensible Green Belt boundaries which can be strengthened.
• The site has no constraints within the development area which cannot be mitigated in the normal way.
• The site has the same landscape character as other ‘green sites’.
• It is not, therefore, credible for Site 544 to be categorised as a ‘red’ site.
• For this reason, we consider the score for Site 544 should be corrected and the Council should re-visit their assessments from first principles.
As is evidenced from the corrected SHELAA commentary the site is rated as a Category 1 – Deliverable Site. Such sites are deemed to be available now, offer a suitable location for housing now and there is a reasonable prospect that housing will be delivered on site within 5 years from the date of adoption of the plan.

Introduction
Paragraph 18 sets out that the site allocations from the Solihull Local Plan (December 2013) will be brought forward. We consider that the automatic allocation of these sites which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach. We address this in more detail under our comments in respect of Policy 4.
Finally, Paragraph 21 refers to neighbourhood plans and the importance SMBC places on these. Paragraph 30 of the National Planning Policy Framework (NPPF) sets the most recently adopted policies will take precedence. SMBC may wish to set this out within this section, to make it clear that the LPR will take precedence upon adoption over any currently adopted Neighbourhood Plans.
Soundness – The Plan is not:
- Justified
Change Sought:
- Existing allocations should be tested for deliverability prior to re-allocation
- The hierarchy of neighbourhood plans should be made clear
Vision
Given that paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positively worded.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- The vision should be more positively worded in order to significantly boost the supply of housing
- The need to release lower performing green belt to meet identified needs, and preserve higher performing parcels, should be set out
Providing Homes for All
Policy P4C Meeting Housing Needs – Market Housing
We object to the inflexible market housing mix which is prescribed within this policy. The NPPF encourages provision of balanced and mixed communities catering for a wide range of the population.
Individual sites should cater for a wide range of housing types and sizes. Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long term sustainable communities. Instead it will result in a transient community where people will not be able to form long term neighbourhoods as they will need to move on as their circumstances change if there are insufficient homes of the right size on a site to accommodate them. We do not consider that this represents good planning and consider that the focus should be on building strong healthy communities which can cater for all, rather than simply planning for short term ownership.
The inclusion of a prescribed housing mix runs counter to the criterion elsewhere within the policy which allow a number of factors to be taken into consideration. This plan has a significant lifespan and to prescribe a housing market mix which is to remain in place for the whole of plan period does not provide sufficient flexibility for adaptation to current housing need and demand. We have seen with the current pandemic the way external factors can influence people’s choice of lifestyle.
Soundness – The Plan is not:
• Justified
• Effective
Change Sought:
• Amendment of policy to allow for housing mix based on up to date market evidence
Policy P4D Meeting Housing Needs – Self and Custom Housebuilding
The latest Annual Monitoring Report (March 2020), covering the period 2018/19, sets out that for the period November 2018 – October 2019 there were 374 entries on the Self-build register.
As such, requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision is being made for 7,605 houses through allocations above 100 houses and the UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations.
The Planning Practice Guidance (PPG) advises that the Council should engage with landowners who own sites that are suitable for housing and ‘encourage’ them to consider self-build and custom housing and who are interested in provision. Imposition of mandatory requirement goes beyond encouragement.
Following the example of Stratford District for example, the Council have specifically identified custom build sites which are discreet standalone small sites.
We also include extracts from the Bedford Local Plan Inspector’s Report (Appendix 4) where the Inspector recommended deletion the policy akin to that being proposed here as the policy was not justified with reference to the self-build register. The same principle applies here in that the amount being sought is over double that on the register.
Soundness – The Plan is not:
• Justified
• Consistent with national policy
Change Sought:
• Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites
Policy P5 Provision of Land for Housing
Policy P5 sets out the Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing supply to deliver 15,017 additional homes in the plan period. This would result in an average annual housing land provision target of 938 net additional homes per year. This annualised target is made up of a stepped requirement with 851 homes per year delivered between 2020-2026 and 991 dwellings delivered between 2026-2036.
Demand
A Housing Need Technical Report has been provided (December 2020) (Appendix 5) and should be read in conjunction with our commentary on Policy P5. In summary, this Note makes the following key points:
• Planning Practice Guidance (PPG) states the Standard Method (SM) figure represents the minimum housing need, and there may be circumstances whereby need is higher;
• The Draft Plan identifies the clear economic growth aspirations for the Borough, including the nationally significant growth planned for the UK Central Hub. This is a circumstance where housing need may exceed the minimum need. If it does, housing delivery must be of a quantum to support these aspirations;
• The Council’s 2020 HEDNA confirms that the calculation of housing need is underpinned by the growth at the UK Central Hub. The Hub is projected to generate an additional 13,000 jobs to the baseline Experian job growth forecast (10,000 jobs) included in the HEDNA;
• The HEDNA tests several economic-led housing need scenarios. However, the UK Hub Scenario assumes only 25% of the additional 13,000 jobs created by the Hub are to be taken up by Solihull residents. This results in the housing need (816 dpa) underpinning the Plan;
• However, this ignores the ‘Growth A’ scenario which concludes that 908 dpa would be required based on the ‘Adjusted Local Growth’ scenario. This scenario assumes that strong industries in Solihull will outperform the baseline Experian forecast, resulting in an additional 5,680 jobs to the baseline (10,000 jobs) over the Plan period, with Solihull residents taking up these jobs;
• However, no scenario is presented to show what the housing need would be based on the UK Central Hub scenario being fulfilled in full by Solihull residents. It is important to understand this so that the duty to cooperate discussions referred to in the HEDNA are well informed;
Barton Willmore provide these sensitivity scenarios based on two approaches to commuting, and two approaches to underlying demographic rates (mortality, fertility, and migration);
• The results of our testing are summarised in Table 7.1:
Table 7.1: Solihull Borough – Barton Willmore Demographic Forecasting 2020-2036 Scenario Demographic rates Jobs per annum 2020-2036 Dwellings per annum 2020-2036
Dwelling-constrained:
Standard Method
2016 ONS rates
7721 – 8132
807
2018 ONS rates
1,0141 – 1,0682
Employment-constrained:
UK Central Hub
2016 ONS rates
1,437
1,1991 – 1,2482
2018 ONS rates
1,0361 – 1,0852
Source: Barton Willmore Development Economics
1 Commuting Ratio 0.98
2 Commuting Ratio 0.93
• Growth of between 1,036 and 1,248 dpa would be required to support the UK Central Hub scenario (between 16,576 and 19,968 dwellings in total);
• This represents an increase of between 220 dpa and 432 dpa on the housing need calculated by the HEDNA (816 dpa), or an additional 3,520 to 6,912 dwellings over the Plan period;
• Our analysis of historic levels of job growth in Solihull 1991-2019 shows a range of 1,225 and 1,650 jobs per annum (jpa). This highlights that the UK Central Hub scenario (1,437 jpa) is a realistic assumption;
• The HEDNA identifies an ‘acute’ situation in respect of affordable housing need. Our analysis suggests that the HEDNA’s conclusion on overall need (816 dpa) should be increased to meet as much affordable need as possible.
• Furthermore, our analysis of unmet need in the wider GBBCHMA suggests that the 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031, and for Birmingham alone the deficit in unmet need is between 11,294 and 13,101 dwellings up to 2031;
• In addition, there is significant unmet need up to 2031 based on the existing Standard Method coming from Birmingham City and the Black Country. This amounts to unmet need of between 25,543 and 27,350 dwellings up to 2031. If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031. This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect once Birmingham’s Local Plan becomes older than 5 years in 14 months’ time;
Adoption of the proposed changes to Standard Method consulted on by Government in summer 2020 would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
• Furthermore, the unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.
• In summary, the analysis in this report results in the following broad conclusions:
1. The SM’s minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub and the ‘acute’ need for affordable housing in the Borough;
2. Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario;
3. 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 such, in order to ensure the LPR is positively prepared, SMBC should seek to plan for more housing, and should allocate further sites.
SUPPLY
Further to the above, and as set out above, we also consider that some elements of the supply should be reviewed:
Dealing with the supply side of the equation, we make the following objections to the various components of supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’. Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.
Solihull Local Plan sites
We question the automatic inclusion of Solihull Local Plan sites which have yet to be granted planning permission. The current Plan was adopted in 2013 and the Council cannot currently demonstrate a 5-year supply of housing. In this situation, the Council should be encouraging every suitable site to come forward. The fact that these sites have not come forward despite the housing shortfall, suggests that these should not be considered ‘deliverable’ housing sites without significant justification as to why they will now come forward when they have not to date.
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply. We consider that any sites to be delivered in this way should be considered as windfall developments.
Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.
UK Central Hub
We consider that given the scale of the UK Central Hub proposals, the rate of delivery assumed by the Council is overly optimistic. The Council have not provided any trajectory for the Site, and we note that the August 2020 consultation did not contain any firm commitments to delivery timescales or set out any delivery partners.
This assertion is supposed by the findings of the Lichfields’ Report1 that sets out the average time from outline planning application to the first delivery of homes is 8.4 years. The average build out rate is 160dpa.
As such, taking this into account, and based on a LPR adoption date of 20222, we consider the first completions will likely be C.2030. With an average build out rate of 160dpa, this means that approximately 960 dwellings will be delivered during the Plan Period, assuming that the housing is within the first delivery phases (the August 2020 consultation referenced a mix of uses coming forward). While more outlets may increase the speed of delivery, the amount of infrastructure required also needs to be taken into account. The type of supply also needs to be considered, with UK Central Hub likely to be geared towards apartments.
As such, we consider that 1,780 houses should be removed to take into account the likely delivery timescales.
Trajectory
We also note that SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase. The Inspector assessing the Guildford Local Plan set out:
39. In the submitted plan, the combined effect of the stepped trajectory in Policy S2 together with the “Liverpool” methodology (in which the delivery shortfall accumulated over the first 4 years of the plan (2015/16 to 2018/19) is spread over the whole plan period), would have deferred a significant proportion of the housing requirement to the later years of the plan. Set against the (then higher) housing requirement, this would not have met the Government’s objective to boost the supply of housing in the shorter term. (our emphasis)
We consider that SMBC should take the same approach as Guildford and allocate further sites to meet need early in the Plan Period. The existence of the UK Central Hub is not of a sufficient size to warrant a different approach (i.e. it is not akin to a new settlement).
Further, as with the withdrawn Uttlesford Local Plan, this stepped trajectory may create a fragile 5 year housing land supply position, taking into account the ambitious delivery targets of the UK Central Hub and the delivery concerns relating to the draft allocations set out below. The Inspectors’ letter relating to the withdrawn plan states:
29. This calculation relies on the use of a reduced annual requirement of 568 dpa for most of the years, as it is based on the stepped trajectory set out in Policy SP3. It is also based on what we consider to be unrealistic commencement/housing delivery dates for two of the Garden Communities (North Uttlesford and Easton Park, as set out above). So, whilst the Council can, in theory, demonstrate a 5.65 year HLS, we are concerned that if the housing delivery at North Uttlesford and Easton Park slips by just one year, as seems very likely, this would result in 100 less dwellings in this 5 year period. This would result in a very fragile 5 year HLS position.
There are comparisons that can be drawn here based on the stepped trajectory and the anticipated 5.37 year supply upon adoption.
The Inspectors for the withdrawn Uttlesford Local Plan also referenced the need to meet the full objectively assessed need for market and affordable housing in the housing market area (NPPF Paragraph 47). The HEDNA states there is a ‘clearly acute’ shortage of affordable housing. The proposed stepped trajectory therefore may worsen the affordability problem as it would delay the provision of housing until late years of the plan period.
Taking the above into account, we consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
This is a reduction of 3,521 and, as such, to meet the increased demand set out above, and take into account the concerns relating to a stepped trajectory, a review of the supply is required and additional sites allocated.
The Council should also ensure that a large number of these sites can be delivered early on in the Plan Period in order to take account of the likely later delivery of some other sites.
Soundness – The Plan is not:
• Positively prepared
• Justified
• Effective
• Consistent with national policy
Change Sought:
• Review of demand and amendment to the strategy
• Review of supply and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible
Improving Accessibility and Encouraging Sustainable Travel
Policy P7 Accessibility and Ease of Access
We consider that the requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- Policy should be clarified that there are other ways of ensuring sustainable transport options are available
Policy P8 Managing Travel Demand and Reducing Congestion
Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.
Soundness – The Plan is not:
• Consistent with national policy
Change Sought:
• Point 2(ii) should be deleted
Protecting and Enhancing our Environment
Policy P11 Water and Flood Risk Management
With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Deletion of point relating to confirmation from relevant infrastructure owner
• Clarification as to obligation requirements and the necessary tests
Promoting Quality of Place
Policy P17 Countryside and Green Belt
Within Point 1 of the policy, SMBC is seeking to safeguard best and most versatile agricultural land (BMVAL) unless there is an overriding need for development that outweighs the loss. BMVAL is referenced within the NPPF at Paragraph 170 which states that planning policies should contribute to and enhance the natural and local environment by taking into account a number of criteria. One of these is:
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.
Firstly, we consider that including reference to BMVAL within a policy relating to Green Belt seeks to conflate two separate issues. Further, as can be seen above, the test set out by the NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL. As such, we consider this point should be deleted.
SMBC have set out, within Point 4, a number of different factors that may be taken into account when considering very special circumstances.
Further to this, point 5 sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given Green Belt is a spatial designation, designed to prevent sprawl, we consider that this requirement goes beyond the scope of the Green Belt, as set out in the NPPF. The LPR contains policies relating to protecting landscape, where necessary, and as such, this point should be deleted.
Soundness – The Plan is not:
• Positively prepared
• Consistent with National Policy
Change Sought:
• Deletion of point 1
• Inclusion of further factors which may create very special circumstances
• Deletion of point 5
Policy P17A Green Belt Compensation
Paragraph 138 of the NPPF sets out that ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.
Policy P17 is seeking to require this by requiring development on sites removed from the Green Belt to provide appropriate compensatory improvements to environmental quality and accessibility of remaining Green Belt in the form of a Section 106 Agreement utilising the below hierarchy:
1. Compensatory requirements as set out as part of the Local Plan masterplans
2. Where no compensation has been set out within the Local Plan masterplan, improvements are provided as:
i. Improvements within the Green Belt adjacent to, or in close proximity to, the development site;
ii. Improvements within the Green Belt adjacent to, or in close proximity to, the settlement or area accommodating the development;
iii. Improvements within the Green Belt in an area identified for environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.
3. In the event it is robustly demonstrated that none of the above options can be satisfied then the Council will accept a commuted sum.
Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.
Soundness – The Plan is not:
• Consistent with National Policy
Change Sought:
• Reconsideration of the policy to ensure that it is evidenced based, does not impact upon viability of schemes, and is in accordance with national policy
Delivery and Monitoring
Policy P21 Developer Contributions and Infrastructure Provision
Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Confirmation that digital infrastructure provision allows for viable development
Settlement Chapters
Policy BC1 Barratt’s Farm, Balsall Common
We note that 1,756 new homes are proposed for Balsall Common across the plan period with the sole justification seemingly being that it contains both a primary and secondary school and has a full range of retail and associated facilities. However, it is still described as a rural settlement with no significant areas of employment and the distribution strategy remains one of “proportional distribution”. 1,756 dwellings to a single rural village would be completely disproportionate. There is discussion in the document regarding delivery of a by-pass; provision a station car park; improved public transport and a new primary school. However, there is no discussion as to how these are to be funded / delivered relative to the level of growth identified. In addition, there is discussion regarding the scope to enhance the existing local centre and the provision of a village centre masterplan. However, this land is in multiple ownerships and there are no proposals for what these enhancements could entail or how they could function – particularly with a by-pass in place which could actually draw trade away from the existing centre.
There is no assessment of the ability of Balsall Common to deliver this level of growth in such a small area. Whilst clearly some sites (i.e. Barratts Farm) will be able to have multiple outlets, the ability of the market to absorb and deliver multiple sites at any one time in a rural location should be reviewed; particular when Balsall Common will be acutely affected by HS2 – both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
We also note that Barratts Farm is in multiple ownerships and these are described as “complex” in paragraph 541. This is the single largest site and the one which is proposed to deliver the by-pass. Within the previous draft of the Plan, it was stated that this site would only be taken forward if the landowners / promoters could demonstrate they are working on a collaborate and comprehensive basis. Reading paragraph 541, this collaborate working has clearly not been secured in the way it was envisaged and nothing additional is suggested to demonstrate that joint / collaborative working is possible.
The relief road is identified as being necessary for Barratts Farm in particular with the policy advising that is required early in the plan period. The road is provisionally to be funded via CIL payments; and grant funding which “may” be possible through the WMCA. Firstly, CIL payments can only be secured through those sites which will come forward in the future however these sites are Green Belt sites and cannot therefore be delivered until the Local Plan Review is completed and the subsequent CIL schedule is adopted. Secondly, there is no grant funding proposal in place to fund the road. As it currently stands this road is not deliverable. The road is required to be delivered early in the plan period i.e. before there are significant CIL funds in place and, potentially, at a point where, in order to receive grant funding, applications should be being made now / near future.
There has to be serious doubt over the ability of Barratts Farm to be delivered within the anticipated timeframes and therefore places serous doubt over the plan as a whole given the scale of this allocation.
The Sustainability Appraisal notes that there are limited employment opportunities within Balsall Common and that people travel outside of the settlement to work. As such, it is noted that the expansion of this settlement would fly in the face of sustainability objectives of reducing the need to travel to areas of employment. Whilst such a case could be made for the majority of the rural areas of the Borough, it is heightened especially here when such a large proportion of future growth is identified for one rural settlement.
At this stage, the level of growth attributed to Balsall Common is disproportionate and that inadequate research has been undertaken into the deliverability of this level of growth and the associated aspirations; and the ability of the market to deliver this level of growth in a rural area is considered to be unrealistic.
On the basis that we do not consider the sites identified to be deliverable and the significant shortfall in supply identified by the more realistic timescales we have identified for UK Central, we propose an alternative site – Land at Hawkshurst (Site 544) as an alternative to meeting part of this need. To date this site has been inappropriately assessment by the Council and a more appropriate evaluation of the site is given in the section below.
Policy BL1 – West of Dickens Heath
The policy requires that the proposal for BL1 secures the relocation of the existing sports provision to a suitable site in the local vicinity. Until such time as these facilities are relocated or a plan is in place to secure timely relocation (which should include the grant of planning permission in our view, given that any site will be in the Green Belt), then the site cannot come forward for development. Our key concern here relates to Site 4 (West of Dickens Heath). It is noted that the identification of a Local Wildlife Site within the site hampers re-provision within the site itself and therefore alternative options will need to be pursued outside of the site. We consider that these alternatives should be considered now as clearly, as it currently stands, the pitches will be lost with no alternative in place (and therefore no guarantee of any re-provision). This is all the more important given that the land in the area is all located within the Green Belt and therefore any proposals which may, for example, include floodlighting, will have to be carefully considered against the Green Belt ‘tests’. We understand that the loss of these facilities is causing significant local concern particularly with no proposals for replacement.
The Council have had ample time to identify and secure alternative provision and therefore the fact that this is not identified within the plan, suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Policy KN1 Hampton Road, Knowle
As with the Site West of Dickens Heath, this draft allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable. However, this pre-judges any application, for which the detail is not known, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Site Assessment Criteria
We consider that a more dispersed growth option should be considered and, as set out previously, consider that the land at Broad Lane, Hawkshurst (Site 544) is ideally suited to make an important contribution to the Council’s housing need. Following the Council’s own site selection criteria, we set out why this site is a suitable and deliverable alternative site which can be delivered utilising existing infrastructure:
We object strongly to the manner in which Site 544 has been assessed in the site selection process for the reasons which are set out below – and on that basis, object to the inconsistent application of the methodology.
Firstly, in assessing Site 544, the Council deemed that the site did not pass ‘Step 1’ – which is the initial, high-level sieving process. Sites which are not taken forward at this stage are then not subject to the more refined ‘Step 2’ analysis. We consider the manner in which the process was applied is fundamentally flawed and have carried out our own assessment (using the Council’s own analysis) to demonstrate that the site should not have been discounted at Step 1 and should have been included in Step 2.
STEP 1
The first stage in the sieving process is a high-level look at the following:
(i) Brownfield vs greenfield
(ii) Urban areas vs Green Belt
(iii) Accessibility
Sites can be rated from Priority 1 (brownfield in urban area or settlement) to Priority 10 (greenfield in isolated highly performing Green Belt location). A traffic light rating is then applied – sites which falls within Priority 1 to Priority 4 are green sites; Priority 5 sites are yellow; Priority 6, 6b and 7 sites are blue; and Priority 8, 9 and 10 sites are red. Red sites fail Step 1 and are not taken forward to Step 2 for assessment. Site 544 was incorrectly identified as a Priority 9 red site and was not therefore taken forward to Step 2.
In summary, Site 544 is a greenfield and Green Belt site. However, it is accessible (being on the edge of the Coventry urban area) and also within an area with a low GB score of 5. Therefore, it should be allocated a Priority score of no higher than 5 (yellow). We review below the manner in which this initial sieving assessment was flawed - taking Site 544 step by step through the same assessment process as the Council.
Green Belt
In the Green Belt Assessment 2016, Site 544 is identified as part of Refined Parcel RP83:5 which has a combined score of 5, within a range from the highest performing Green Belt sites (12) to the lowest performing sites, scoring as low as 0. With a score of 5, site 544 is clearly a lower performing site. The starting point for consideration as a Priority 5 site is a score of 5 or lower in the Green Belt––Site 544 falls into that category. The results of this assessment are backed up by our own Green Belt assessment which is included with this submission.
Accessibility
The second part of the criteria relates to accessibility and to achieve a Priority 5 ranking, the site is required to be in an accessible location. This is defined as:
(a) On the edge of the urban area or
(b) On the edge of a settlement which has a wide range of services and facilities including a primary school and a range of retail facilities.
Site 544 adjoins the urban edge of Coventry – indeed in the Council’s Site Assessment, the site is identified as possibly being an extension to Coventry.
It should be noted that in relation to the Publication Draft Plan, the Council have updated the Accessibility Study to take account of retail / surgery provision in adjoining LPA areas, however they have then not used this information to re-visit first principles and determine whether sites have been appropriately assessed from the start. Therefore, whilst this site now scores more positively, its ‘priority 9’ status has not been re-evaluated despite an Addendum to the Site Assessments being produced and the Accessibility Study being revisited. It appears that despite the site being on the urban edge of Coventry this has been discounted due to the sites geographical relationship with Coventry as opposed to Solihull. However, accessibility should be based upon spatial location rather than boundaries. The fact that the retail offer is in Coventry will not prevent residents of Hawkshurst using it.
For the absolute avoidance of doubt therefore, we enclose our own submission produced by Phil Jones Associates which demonstrates that the site is in a suitable and sustainable location.
It is fundamentally incorrect for Site 544 to have been ‘sieved out’ at Step 1. The site should have been correctly assessed as a Priority 5 yellow site as it meets the two necessary criteria. The site, therefore, should have been taken forward for a more detailed analysis in Step 2.
On the basis that the site does pass Step 1 – we have carried out the Step 2 assessment using the same table and criteria as the Council. There are no scorings or weightings attributed to the Step 2 analysis – it assessed on a qualitative basis.
STEP 2 – REFINEMENT CRITERIA
FACTORS IN FAVOUR
In accordance with the spatial strategy
(including only proportional additions to lower order settlements (i.e. those without a secondary school or not located close to the urban edge).
The preferred spatial strategy would be to locate development needs close to where they arise. However the Plan identifies that there is limited land available to achieve this and therefore the Council has had to look at alternative options, which includes land released from the Green Belt in the form of urban extensions and also followed a more dispersed strategy for development. They have sought to focus development in locations that are, or can be made, accessible and sustainable. Such locations are identified as typically being on the edge of urban areas (or within ruralsettlements) that have a greater range of services. Potential locations for development include adjoining the urban edge or a highly accessible settlement. This will have the benefit of focusing on urban areas and sustainable urban extensions to provide the best opportunity for achieving accessibility and delivering public transport improvements.
It is abundantly clear that geographically Site 544 adjoins the urban edge of Coventry – Coventry is the second largest City in the West Midlands, after Birmingham. Site 544, as confirmed in the SHELAA assessment, would be viewed as an urban extension to Coventry and there is, therefore, no doubt that Site 544 is in accordance with the Spatial Strategy, which seeks to locate development in the most accessible locations. Coventry is clearly such a location and there is nothing within the Spatial Strategy which would rule against this.
Therefore, it can only be concluded that the development of Site 544 would be in accordance with the Spatial Strategy.
Any hard constraints only affect a small proportion of the site and/or can be mitigated.
The SHELAA does not identify any hard constraints – we concur with this assessment.
The site would not breach a strong defensible boundary to the Green Belt.
There are no strong existing defensible Green Belt boundaries that would be breached. The existing boundaries to Bannerbrook Park comprise simply hedgerows, some of which were planted in conjunction with the existing development. The same form of boundary treatment can therefore be replicated on this site and indeed is proposed within the masterplan included with this submission.
Any identified wider planning gain over and above that which would normally be expected.
Following discussions with local undertakers regarding the lack of burial space available within the Borough, the landowners are willing to offer land for a multi faith burial space which will provide a much needed facility for the Borough and also secure the long term permanence of the Green Belt boundary in this location.
Sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
See above.
If finer grain accessibility analysis (including output from the Accessibility Study) shows the site (or the part to be included) is accessible.
The Accessibility Study is flawed when it comes to assessment of sites on the Solihull / Coventry boundary. The Study provides a scoring for accessibility for facilities within 1,200m of a site, however when assessing facilities beyond the administrative area of Solihull only facilities within 800m of the boundary are assessed, this is despite an updated assessment being provided in 2020 which proposed to apply some adjustment of standards and yet makes no sensible adjustment to standards for cross boundary provision. Sites in such locations are not therefore being assessed on a comparable basis. Furthermore, the assessment is only being undertaken of walking distances and makes no allowance for accessing facilities by bike. The document references ‘shared cycle’ routes but then makes no consideration of people actually using them for cycling. Clearly were cycling to be factored in, especially for those sites, which adjoin major settlements and therefore have access to a good cycleway network (such as Site 544) then their accessibility criteria would be much improved.
Whilst it is noted that some provision is now taken off cross boundary retail provision and public transport which has moved Site 544 to a higher scoring position; it is still not being assessed on a comparable basis.
There is a shared footway/cycleway through the Bannerbrook Park development which can be extended into Site 544. Furthermore, opportunities will be considered to accommodate a bus route through Site 544 and on through Bannerbrook Park.
It is therefore clear that the proposal can only be defined as being in an ‘accessible location’.
FACTORS AGAINST
Not in accordance with the Spatial Strategy
As set out above, the development of this site is in accordance with the Spatial Strategy
Overriding hard constraints that cannot be mitigated.
There are no hard constraints identified.
SHELAA Category 3 sites unless demonstrated that concerns can be overcome.
The site is not identified as a Category 3 site in the SHELAA. We make comments below in respect of the flaws of SHELAA assessment and carry out our own assessment.
Sites that would not use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
As already confirmed, the site uses existing defensible boundaries and proposes to strengthen the defensible boundary and strengthen existing hedgerow planting.
If finer grain analysis shows the site (or the part to be included) is not accessible.
As previously confirmed, the Council have failed to consider the proximity of services in Coventry on a fair basis and because of this, it is not possible to determine how detailed the assessment has been. However, given that the site adjoins a major urban area is it simply not feasible to draw a conclusion that the site is inaccessible.
If the site is in a landscape character area that has a very low landscape capacity rating.
It is wholly unreasonable if the Council have used this criterion to discount this site. According to the Council’s Landscape Character Study (December 2016) this site falls within Landscape Character Area (LCA) 26 – which covers the eastern fringe of the Borough – yet significant Green Belt release is proposed in other areas of the Borough which are in an identical LCA. With one blanket ‘very low’ landscape capacity conclusion for such wide areas it cannot be used to discount some sites and not others – there must be parity in assessment. Furthermore, the study itself (page 49 – text adjoining Table 24) confirmed that it is not possible to establish a baseline sensitivity to change without having details of a given development proposal and therefore the conclusions should be taken as a guide only. On this basis, we do not consider it appropriate to use this criterion as a basis to discount sites given sites with the same assessment have been given a ‘green’ score’.
We enclose with this submission our own detailed, site specific, landscape and visual appraisal which confirms that the site has the ability to accommodate development of scale which is comparable to the surrounding area without compromising the function of the surrounding Green Belt.
If the SA appraisal identifies significant harmful impacts.
The SA identified 2 harmful impacts:
(i) The site contains over 20ha of Grade 1 – 3 agricultural land.
The site is wholly Grade 3 agricultural land – clearly within Grade 3, the site could in fact be Grade 3b land which would mean it is not BMVL. Furthermore, the Regional ALC mapping, which was last updated in November 2018, shows this to be the prevailing land type across the Borough which is not unsurprising. As a result, a number of proposed allocated sites have the same classification. It is not therefore appropriate to identify this as a harmful impact when a consistent approach has not been applied across the board.
(ii) The distance to jobs is identified as 8km within the SA
This is clearly incorrect as the SA treats the administrative boundary between Coventry and Solihull as a line which people will not cross. This is clearly incorrect. As already stated, there is for example a good bus connection to Warwick University which is a key local employer as well as Coventry city centre which offers multiple employment opportunities. The SA has applied the same approach to all services and facilities – relating its conclusions only to Solihull Borough and thus the distances to shops / schooling / healthcare are distorted. In addition, we highlight that this is a specific issue related to Balsall Common also (which is also further away from Coventry) and yet the Council has seen fit to allocate in excess of 1,700 dwellings in Balsall Common.
In summary:
• The site has medium / high accessibility – at the same level as the other ‘green sites’ identified in the Draft Plan.
• The site is in lower performing Green Belt than other ‘green sites’ in the plan.
• The site has existing defensible Green Belt boundaries which can be strengthened.
• The site has no constraints within the development area which cannot be mitigated in the normal way.
• The site has the same landscape character as other ‘green sites’.
• It is not, therefore, credible for Site 544 to be categorised as a ‘red’ site.
• For this reason, we consider the score for Site 544 should be corrected and the Council should re-visit their assessments from first principles.
As is evidenced from the corrected SHELAA commentary the site is rated as a Category 1 – Deliverable Site. Such sites are deemed to be available now, offer a suitable location for housing now and there is a reasonable prospect that housing will be delivered on site within 5 years from the date of adoption of the plan.

Property appears blighted due to the unknown route of this By Pass

Balsall Common 1615 homes across 6 sites-- includes By Pass, primary school etc etc.
Whist we believe these proposals are appropriate we need clarity on the positioning of the road as this is crucial in ensuring these homes are built.
We are in our mid seventies and have our home on the market in order to fund our future care home costs.
Unfortunately our property appears blighted due to the unknown route of this By Pass.
We would welcome your help and comments with regard to this situation as it is affecting our health and wellbeing.