Blythe

See Attached Word doc.

The Sustainability Appraisal should be updated to re-consider higher levels of housing growth.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The Sustainability Appraisal of Site 404 should be amended to reflect the updated and correct position.

Dear Sir or Madam,

Please see attached representations on behalf of Rainier Developments Limited in respect of land at Tidbury Green (site 404). We have also submitted these with the corresponding appendices in the email below as a file share. If you have any problems accessing the file share please let me know.

Kind Regards,

Gary Stephens

The Sustainability Appraisal should be updated to re-consider higher levels of housing growth and assess reasonable alternatives in relation to the location of employment growth.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The Sustainability Appraisal of Site 62 should be amended to reflect the updated and correct position.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

The Site Selection should include an allocation of land west of Stratford Road.

Dear Sir or Madam,

Please see attached multiple representations on behalf of IM Properties in respect of land west of Stratford Road (Site 62).

Kind Regards,

Land at Winterton Farm, Blythe Valley (SHELAA reference 173) should be considered for a residential allocation.

Dear Sir / Madam,
On behalf of Mark Horgan, please find attached a response to the Draft Submission version of the Local Plan Review in regards to his land interests at Winterton Farm, Blythe Valley (SHELAA reference 173).
We have submitted the following:
• Covering letter;
• Five Consultation Response Forms;
o Policy P4C
o Policy P4D
o Policy P4E
o Policy P5
o Policy P17
• Promotion Document (January 2016).
Please contact me if you have any queries with the submission.
Kind regards
Jess

The Green Belt proposals should be tested on a regional basis due to the scale of housing need.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

The Fulford Hall Farm site should be categorised as priority 6 – “Greenfield in accessible moderately performing Green Belt Location” and not priority level 9.

A reassessment of the Green Belt options needs to be undertaken. A robust long-term Green Belt boundary around Tidbury Green needs to be identified taking account of the exceptional circumstances arising from the Borough’s development needs. Land at Fulford Hall Farm should be removed from the Green Belt and allocated for development.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990
LAND AT FULFORD HALL FARM, TIDBURY GREEN, SOLIHULL
SOLIHULL LOCAL PLAN REVIEW DRAFT SUBMISSION LOCAL PLAN CONSULTATION
DECEMBER 2020
REPRESENTATIONS ON BEHALF OF SUMMIX FHS DEVELOPMENT LIMITED

I make the following submission to the Solihull Draft Local Plan Review Consultation on behalf of Summix FHS Developments Limited, which comprises:

• Representations to the Solihull Local Plan Publication Version Consultation
• Appendix 1 - Vision Statement
• Appendix 2 - Green Belt, Landscape and Masterplanning Report
• Appendix 3 - Transport Mobility Strategy
• Appendix 4 - West Midland Rail Aspiration Study
• Appendix 5 - Economic Benefits
• Appendix 6 - GB Assessment Appendix F Overall Score Plan
• Appendix 7 – Network Rail email (14.12.20)
• Appendix 8 - Fulford Hall Farm Site Assessment
• Appendix 9 – Location Plan
• Representation Form - Borough Vision Overview
• Representation Form - Spatial Strategy
• Representation Form - Challenge A
• Representation Form - LP Foreword paras 2, 5, 12 and 13
• Representation Form - para 51 and 52
• Representation Form - Policy P9

Please could you confirm receipt of the above stated documents.

If you have any questions, please feel free to contact me.

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.

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.

Alternative site 544 Broad Lane proposed to meet part of need proposed at Balsall Common

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.

Site 544 Broad Lane should be allocated for housing as is appropriate using site assessment criteria and deliverable

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.

See attached letter.

See attached letter.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

A new site allocation at ‘land to the west of Tilehouse Lane’ for residential development.

Or inset a new paragraph below paragraph 601 in the Plan as follows:
‘In addition to the proposed site allocations in the Blythe area, BL1, BL2 and BL3 that would fall within the settlement boundary, if the Green Belt boundary is amended as proposed, there is also land west of Tilehouse Lane (as shown on Enclosure 2), that would then be considered appropriate for development as they would then also be within the settlement boundary. This area has been promoted for development by landowners and if the Green Belt boundary is changed the area would no longer be subject to Green Belt policy. Following the proposed amendments as defined on the Policies Plan Map, proposals in this location will be considered appropriate for residential development subject to development proposals satisfying local and national planning policy requirements.’

The Policies Plan Map should be amended to either exclude ’land to the west of Tilehouse Lane’ from the Green Belt or exclude the site plus the quadrant, with a SHELAA capacity of 48-51 and a capacity based SHELAA numbers plus indicative layout of 81-84 dwellings.

Dear Sir/Madam,

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

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

We look forward to hearing from you.

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

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


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

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

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

Paula Pountney

f.a.o. Spatial Planning
LOCAL PLAN CONSULTATION RESPONSE
I would like you to understand that the consultation time offered by the council for the local population to acquire, digest, read, comprehend and react to the Local Plan is far too short. The entire plan contains over 10,500 pages with 30% being added on October 30th, the first day of the consultation period. To be given only six weeks to formulate a response is far too short a time.
It is acknowledged that the population of the U.K. is ageing but within Solihull, over 65’s make up 21% of the population and it has been said that they will number more than 50,000 by 2035.
Shirley has a 30% higher level of older people than the national average.
In recent years and indeed to date, Shirley has taken more than its fair share of retirement and care homes in comparison to the rest of Solihull. This has had a marked impact on Shirley as residents in these kinds of properties have particular needs and demands on local services, many of which are unable to cope at today’s levels of demand. Doctors are struggling, indeed at least one new care home is unable to find a local surgery at which to register its residents. Care services are well over subscribed in the area and south Solihull now has no primary care facility. Adding to the housing aimed at older people will only make matters worse. If these agencies are struggling now, what will be the impact of building even more homes in the area?
Of all the new housing proposed for the borough of Solihull more than 39% is planned to be in Shirley. This does not include the homes already completed such as those on what was the Powergen site and other windfall developments. If the proposed plans go ahead then much of the greenbelt land between Shirley, Cheswick Green and Dickens Heath will be lost forever.
Since the pandemic has closed so many shops and offices generally, I would question the need for so many extra new houses on virgin land. The empty / unused buildings could be repurposed for joint domestic / commercial use thus saving the greenbelt and keeping town centres alive.
No matter how much developers advocate that public transport is the way forward, and that narrow roads and little off road parking are a sign of the future, public transport in Shirley, away from the Stratford Road, is generally poor. The railway stations that serve the area are not easily accessed by road, pedestrian footpath or cycleway
Dickens Heath was built on the premise that the residents would be dissuaded by limiting the number of parking areas, garages and spaces not need to use cars and would instead, use public transport. The public transport in the area is so poor that most families in the village own at least two cars and there is a huge parking problem. The existing road system in and around Shirley is already far too congested. Access to the major routes such as the Stratford Road, the Alcester Road, the M42 and M40 are extremely busy now. Many more houses in the area would completely gridlock the road system.
Much of Shirley is built on clay and there is a considerable amount of local flooding, the newer areas of housing to be built have had to have ponds / pools incorporated in order to contain excess water, I understand this to be called SUDS (sustainable drainage system) and seems to be developer’s favoured way of overcoming the problem of flooding. These pools / ponds do not add to the attractiveness of a development being filled with reeds or similar and they are a danger, particularly to young children.
Speaking of children, there is one primary school planned in the development and not a single secondary school. The proposed homes will attract families and families mean children. Where are they meant to travel to for their education given the poor transport system already mentioned and the lack of access to get to bus stops or the stations? Schools, doctors, chemists, shops are more than a convenient walk away and generally will rely on existing narrow twisty country lanes many of which have no pedestrian footpaths. The distances involved are in many cases too far and too dangerous for mums with pushchairs and young children to negotiate. As there is only one primary school and no proposed secondary school many parents will have to transport their children by car. The only other alternative would be to cycle but the roads are too narrow and will have an undisputed inherent extra amount of traffic on them.
I understand that the average selling price of a new home proposed to be built on the various sites in Shirley will be over £340 000 meaning the developers will get a return of over £800 000 per acre, a far larger amount than they would make if they were to made to redevelop brown field or windfall sites which is what they should be encouraged to do as most of the required basic infrastructure is already paid for and in place.
I understand that people need homes but Shirley is being tasked with far more development than is fair or sensible, Chelmsley Wood is being regenerated, more homes could be built there where generally the infrastructure is already designed and existing, the new Arden development at the HS2 interchange can take more development of suitable homes not only the unaffordable ones that the developers are forcing on Shirley.
I feel that the Local Plan is being pushed through under cover of the pandemic with not enough time allowed for the general public to have their say. For the above reasons, I would like to register my objections to it.
Geoffrey Ward

Spatial Planning
Solihull Metropolitan Borough Council
Manir Swuare
Solihull
B91 3QB
From:
Jon Sellars
26 Langcomb Road
Shirley
Solihull
B90 2PR

Consultation Response to Draft Local Plan Shirley South Green Belt residential Development

I strongly OBJECT to this proposed residential development for the reasons I will refer to below:

The maintenance of sustainability of the development lack any consideration for the destruction of local habitat and ecological balance of this area. This is a time when greater consideration should be given to the environment.

The Shirley South area has the main burden of residential development in Solihull. I must highlight that Shirley and Blyth Valley area has already sustained significant redevelopment over the past 5 years.
Minor road improvements are the Councils only response and does not address the significant increased levels of traffic.
Why is Shirley taking the extra housing burden? Why is the additional housing not being absorbed within the Greater Birmingham's initiative to utilise the Brown Field First site strategy promoted by Andy Street.
Why is the council intent on devouring large swathes of ecological sensitive Green Belt?
This makes a complete mockery of the boroughs motto Urbs et Rure

The site is adjacent to Whitlock End/ Dickens Heath and is close to four local wildlife sites.
It is also only one kilometre from a further 6 significant ecological natural sites.
This development is too close to these sensitive sites and will have a catastrophic effect on the areas; flora, fauna and wildlife, not to mention the quality of life for human inhabitants.
These ecological sensitive high grade greenbelt sites perpetually flood and are therefore natural soak ways that mitigate local flood risk. Thoughtless development like this creates flood problems and removes the flood protection from the surrounding area it currently protects.
The Shirley area is a based on an ancient rural district, with lanes, bridle paths and narrow roads without pavement in many places. It has poor public transport, thereby making it a pedestrian and car dependant area. By increasing residential development this will exponentially increase car usage for each new household; the increase will be a 200% in car usage with a further potential increase of 200% because of natural family development. This development does not consider employment in rurally established areas; they are by their very nature further away from employment, creating further stress on a low-key rural infrastructure, over time this grows further as families develop with the school runs and further education.
Problems concerning utility infrastructure such as gas, water electricity and sewage and water pressure of existing utilities infrastructure is near to breaking point. 3 years ago the entire estate had a blackout over night which was a result of very old infrastructure which has not been improved and will have to support additional homes.
There is constant bolting on of new developments to existing services, which is, essentially on to the original rural setup. This is short sighted and piece meal, leading to an eventual collapse due to inadequate planning. This is highlights the council’s agenda to purely expand the council tax revenue base and has no consideration of the utility infrastructure for the current residents.
Solihull Council must bear in mind the recent changes to the High Street brought about by the pandemic and changes in people shopping habits, which have created a significant change to the retail structure in this area. Many units are falling empty all over the borough; Shirley is a prime example, with the loss of Morrisons and closure of shops on the High street (even charity organisations have vacated) and stores Parkgate closing down. In addition, many units in Solihull town centre are empty, with a huge hole being created with the planned relocation of M&S. This calls for a completely new look at utilising the vacant units that will be left by the devastating impact of the aforementioned shopping and the reuse of brown field sites.

Another consequence of this development is the disproportionate effect that it will have on doctors and the wider health care provision. The existing GP surgeries and dentists are already full to breaking point and additional residents will only increase the problem. The existing system is stretched to breaking point with COVID as well as more residential developments already under construction. This will exponentially increase demand due to pressure of later life care, which is more complex and demanding. The health provision is exacerbated by the down grading of Solihull hospital surely this significant health resource should be upgraded rather than downgraded now to secure the existing population.
The Shirley South community is 100% against and OBJECTING this proposal. The Shirley South residents will not allow this Borough council to destroy the ecological balance, quality of life of existing residents any further with short-term revenue generation schemes.
The community of Solihull, South Shirley and the Blythe want to set trends with good sustainable development not shoddy cash grabs with disastrous environmental consequences.

Jon Sellars
26 Langcomb Road
Solihull
B90 2PR