Blythe

I wish to thank the Green Party for the recent local news to build 15,000 properties over
15 years in our borough.

I was grateful to receive your news letter to indicate where the eight number sites for retirement and care homes are intended to be built or now built. I am pleased to see the sites are replacing existing premises that are no longer required. The important thing to me is they do not take up additional land.

However, I am concerned with the new proposals to build 15,000 homes which will take up considerable areas in sites (2) and (3) as per the outlined plans. I live in Shirley West, a well established area. Most of these houses have conventional drives, a garage and a garden.

When I travel along Tanhouse Lane I believe I am in the country side. It makes you feel good because of the green fields to the left as you travel towards Beckets Farm. I foresee that coming to an end because the houses to be built will extend from the Dickens Heath complex right up to Tanhouse Lane. It’s a maize and difficult to find your way out. Most of the houses are cramped together. Their front doors face the road, have no drives and have very little space at the back of them providing very little privacy.

No wonder a lot of them have gone up for sale. That’s what you get in a “design and build” contract. The main contractor will dominate the schemes to the point of the no.
of properties. In turn decide on who will work on the schemes starting with an architect and other specialist professions ie do as I say.

I may be wrong but it seems to me the main contractor will benefit the most.

You mention in your report the present doctors are under a lot of pressure. I agree with your comment, Ultimately new surgeries/health care centres will need to be introduced.
The same principal will apply to new schools. A financial matter but necessary.

Our road network is also under pressure. Any new road out of each complex will end up onto existing quite narrow lanes. A fair problem for Highway Engineers

Each area in my opinion besides the usual water and electrify supply infrastructure should have a gas supply. It’s not time yet to say all homes will all be electric. I do know sometimes the gas supply is omitted which of course saves a lot of money.

If Solihull MBC want to be recognised for the build of desirable properties and attract people to the areas I hope they, a team of in-house specialists, address some of my thoughts. It would be a good idea for the planning officers to seek advice from these people beginning with the chief architect.

It should not be a case of total no’s but reasonable no’s to satisfy local people too!

I have looked at your proposed form for Submission of Representations. It is not fit for purpose.

I wish to submit multiple and linked representations.

I find the plan and the consultation process severely flawed such as to make the current plan and timetable for consultation Unsound and not legal.

I outline my reasoning in the attached document which is ordered according yo your plan and where possible references specific paragraphs and Policies.

My high level objections to the consultation process are stated at the start of the attached document.

See attachment

I wish to register my formal objection to the above proposed development. I believe it is not in the interests of the local Shirley community ether from an ecological or sustainability aspect.

Yours sincerely,

John Dodd
41 Amington Road
Shirley
B90 2RF

Site 192 should be considered as an additional allocation being a high performing site adjacent to the proposed allocation (BL1) land west of Dickens Heath.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

I write with reference to the Local Plan Review in respect of Solihull and the proposed housing developments in the Tythe Barn Lane (BL1) Dog Kennel Lane (BL2) Whitlocks End Farm (BL3) allocations.

As a resident of Neville Road I write to register my concerns and objections to the proposed development sites and the number of proposed dwellings to be included on each site.

In total the 3 sites are proposing in the region of 1650 additional homes. Whilst no-one can dispute that additional housing is needed, the area and amenities cannot support the proposed number of proposed dwellings. I note that you are including provision for some additional primary school places, but I cannot see in the review that there is any intention to increase or offer any additional secondary school places. Secondary school places in Solihull are already in demand and many residents do not get their first place choices. I do consider that if you intend to allow an additional 1650 houses to be built in the local area, there will not be enough places for our children and this needs to be considered alongside any proposals for additional housing..

Further, i note that you state you intend to improve access on Bills Lane. This is already an extremely busy road and there is always a backlog of cars during peak periods. There are limited ways in which you could improve this area and with the additional proposed number of homes that would increase the number of traffic travelling on Bills Lane and surrounding roads to dangerous levels. Currently the pathways on the side of Bills Lane which joins Neville Road is too narrow and there is no foothpath at all on the opposite side which runs along Bills Wood. Also Bills Lane itself is a fairly narrow road which cannot support the current traffic levels without the proposed expansions on housing.

I have concerns also regarding the provision for Doctors surgeries, which are struggling now without additional patients. Further the proposed closure of Solihull Police Station would leave a highly populated area with no provision for Police support. With the closure of Solihull Hospital for accident and emergency and maternity services, there is also limited provision for hospital support in the area and does not reflect the population and any additional proposals for housing.

I note from having reviewed the draft local plan, that Shirley has the largest number of proposed additional homes that the area simply cannot support and which will put pressure on all services within the community.

The majority of current proposals in the Shirley area are retirement properties. Whiist there is no doubt a need for these types of properties, not every pensioner wishes to live in this type of property nor wishes to pay the extortionate service charges that are applied as a resident of one of these developments. Surely these would be better placed as having a smaller development of houses to accord with the need of the area. Particularly the proposed developments at the former Office World site and former Morrisons site.

I look forward to hearing from you further in due course.

I wish to object to the proposal to build a huge number of homes in Shirley. A disproportionate amount of the development is being pushed onto Shirley. Indeed 800 units or dwellings have already been built or proposed before taking into consideration the further numbers proposed.

Your proposals mean tens of thousands of acres of greenbelt will be lost forever. Greenbelt land around us is of the utmost importance; green belt that we can walk to and through mean we do not increase already high pollution levels and makes a huge difference to the physical health and well being of the residents of Shirley.

The development in the area has already put pressure on the service that can be provided by doctors. Pressure particularly acute because the number of retirement homes built has increased the numbers of older people who naturally have greater medical needs. Trying to contact a doctor is very difficult; being told that you are 77th in a queue is appalling! This is not an isolated incident. Consultation with doctors in the area and a consideration of care services provided is of the utmost importance.

The development that has already taken place has already put infrastructure under unbearable pressure. It cannot cope with the types of vehicles now using it. Buses and other large vehicles are already causing significant damage to roads not constructed to withstand such use. The increased volume of traffic also means frequent traffic jams. Your proposals will put further strain on an already overloaded infrastructure.

I strongly believe that you need to look at:
1. Regeneration in Chelmsley Wood
2. Making better use of the HS2interchange site for housing
3. Bring the Solihull Town Centre Masterplan forward.
Indeed many such suggestions were first made several years ago and are recorded by the council.

If you look at these suggestions you would be able to protect the majority of the sites on the greenbelt. You could also build the kinds of home most needed, in locations that promote sustainable travel.

I wish to have it known that I am disappointed that the Council did not do more to publicise the ‘Draft Local Plan Consultation Response’ and only permitted the legal minimum requirement for consultation, resisting efforts by other parties to get an extension.

New homes are needed but your plans are not fair; you have not considered the environment or the communities that will be impacted.

High Street will have a significant number of empty units as a result of many companies going into administration- these must be potential housing development opportunities.

See attachment

As a resident of Cheswick Green, I would like to raise serious concerns about the soundness of the Solihull Local Plan for the following key reasons:
 The spread of housing is not distributed fairly across the borough, with 39% in Shirley/Blythe (B90 postcode), including the site at The Green Shirley (site 11) currently being built.
 Many areas of the borough, such as Dorridge, are having no homes at all and will not meet their housing needs in the plan, while the Shirley/Blythe area is disproportionately over-contributing to the local housing need. This is unfair and is an imbalance that needs to be addressed through modification to the plan.
 The loss of Green Belt is too high considering that brownfield sites at Solihull Town Centre and the HS2 Interchange site are being under-utilised for housing and masterplans for both locations are not included in the plan.
 There is a lack of supporting evidence to demonstrate that sites BL1, BL2 and BL3 do not pose a significant flood risk, particularly in view of the fact that they feed into the River Blythe and Cole catchments which have flooded more than once in excess of 1 in 100 year levels in the past 15 years. These events are happening more frequently as a result of Climate Change, and the risk of building 1,600 more homes in the area cannot be underestimated.
 The cumulative effect of the quantity of housing being allocated to the Shirley/Blythe area will result in the gap between Shirley and Dickens Heath/Cheswick Green being narrowed too much, putting in jeopardy the remaining Green Belt buffer. The prospect of a new road forming a new Green Belt boundary at site BL2 is of considerable concern. Dog Kennel Lane provides a well-established and distinct separation between the built-up area of Shirley and the Green Belt, and this should be maintained. There is significant community concern that over time, the narrow gap in Green Belt that is left behind will be filled in and will result in a continuous urban sprawl.
 There is a lack of any detail in the plan on how it will cater for the increased demand for primary healthcare services, like GP surgeries in the Shirley area. With the housing numbers we already have, and proliferation of care homes and housing for older people, current facilities are struggling to cope and the system has fallen over during the Covid-19 pandemic. This is not sustainable and whilst the plan identifies sites for new primary schools, there are no sites identified for primary care.
 The plan has been rushed through with an inadequate timescale for public consultation, especially in view of the Covid-19 pandemic, with traditional outreach methods, like public meetings, not being possible. Requests to extend the consultation period have been denied by the Council.
 Documents in support of the plan were uploaded by the Council after the consultation opened on 30 October 2020, with some alterations made as late as the final week of the consultation. Despite this, no extensions were granted to allow people the chance to review their representations in view of the amendments made.
 A disproportionate amount of supporting evidence was uploaded in October (around a third of the total in page numbers) when the consultation went live. This gave a very limited window of opportunity for respondents to go through all the documents.
The plan should not be submitted for public examination until it is modified, as it would result in thousands of acres of Solihull Green Belt being lost unnecessarily, while the housing needs of many parts of the borough will not be met.
The vast majority of the land allocated in this plan is currently in the Green Belt, and contributes greatly to openness and recreation, improving mental health and wellbeing for our communities. Using Green Belt to the extent the plan does is flawed because it is the least sustainable from a transport perspective, resulting in high car dependency due to poor public transport and active travel links. Traffic congestion and air pollution are already major problems in the Shirley/Blythe area, and with the quantity of new development proposed in the plan, this will only worsen and the Council has not provided sufficient evidence to justify the inclusion of these sites.
Green Belt land is also essential for CO2 sequestration. Priority in the plan should have been given to verticalisation in urban areas rather than urban extension to maximise land efficiency for housing.
The National Planning Policy Framework (NPPF) is clear in section 11 that “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.”
Further to this, section 8 of the Council’s Draft Submission Plan FAQs states that “Developments will be located in accessible locations for sustainable transport, or improve the existing provision as well as being well-connected for cyclists and pedestrians.” The plan relying so heavily on Green Belt sites, which have poor access to sustainable transport options, does not achieve this. Additionally, policies P7 and P8 of the plan advocate ease of travel, reducing the need to travel and easing congestion. Relying on allocating so many Green Belt sites will not accord with those policies.
In conclusion, the plan does not meet the needs of the whole borough, sacrificing our Green Belt when this could be avoided with a sound and fair plan. The Shirley/Blythe area in particular is targeted with too high a number of new homes without the infrastructure to sustain this, whereas other parts of the borough are not taking a fair share of Solihull's housing need. Objections raised by residents, Opposition Councillors, Parish Councils and other third parties have been ignored and dismissed by the Council and the consultation has not been sufficiently inclusive.

We have read the Draft LDP.
We note that the map of Solihull, showing proposed sites, displays as an extensive green space with future developments again focused around the periphery of areas with substantial populations.

The numbers of intended properties are, allegedly an appropriate strategy.
The distribution is questionable.
It is acknowledged that Stratford Road in Shirley has “High level of through traffic and congestion” yet almost 600 units are currently being built/planned ,for aged /retired people, along this road. This concentration does not include retirement property existing in roads adjoining the Stratford Road.
Every Shirley resident is entitled to equal NHS care. The current Pandemic emphasises the health challenges in Solihull’s most densely populated areas.
It is inappropriate to mass elderly people in Shirley, in particular along a busy road with substantial pollution.

Where is the additional planned public green space?
The existing space between Stretton Road and Dickens Heath is especially invaluable to residents from Shirley and Dickens Heath.
This is one area where wildlife has some chance of existing, with the adjoining canal providing current access to greener space towards Earlswood.

Positively prepared?
“Provide cycleways and wildlife to provide connectivity....”
What wildlife is Solihull proposing to provide?

Sites 17,18 , 20,21
These are likely to add to the congestion on the Stratford Road. Access from Dickens Heath and new Cheswick Green housing creates serious congestion around the traffic islands at the junction of Tanworth Lane, Dickens Heath Road, Blackford Road and Dog kennel Lane. Traffic queues from Dickens Heath extend to the village clock; town end of Tanworth Lane traffic queues extend into Woodlands Road and Stretton Road.

Where are the children from families, in these new homes, going to school?
Currently, parents, of children attending Shirley Heath Junior School and Woodlands Infant School, are challenged by the Stratford Road hazard.

Increasing distance children have to travel increases car travel and nuisance to residents close to schools.
Has Solihull considered organising “Walking Bus” school routes. (Ref. Bournville Primary Schools).

The emphasis on protection of “Meriden Gap” ignores the lack of gaps between Tidbury Green and Wythall/Worcestershire/South Birmingham.

Urbs in Rure /Urbs ad Nauseum?

Dear Sirs,
>
> On behalf of the Cheswick Green Residents Association, I wish to make representation to the above plan. Under the heading of “Justified”, it is argued that the plan is not “An Appropriate Strategy”.
>
> SECTION 575
> This section calls for Cheswick Green School (CGS) to become two-form entry, thus doubling the volume of pupils. It is noted that the additional capacity is designed to accommodate children from the Mount Dairy Farm and Blythe Valley Park developments.
>
> It is accepted that families from Mount Dairy Farm should be entitled for their children to be educated at CGS. However, as Blythe Valley Park is some 2.7 miles away and without footpaths, cycle lanes or easy accessed roads to Cheswick Green, it is not right that these children should be allocated just to CGS.
>
> Furthermore, 2.7 miles is too far for young children to walk and in most cases the return journey would be made by car. Not only would this be bad for the environment, but it would cause traffic chaos in the immediate area outside the school. It should also be noted that a number of vehicle accidents have already occurred outside the school.
>
> In July 2016, the Residents Association surveyed Cheswick Green residents on many local issues. The survey attracted 237 responses and the preferences for primary schools is provided below
> - Expand CGS with a rear drop-off point 9.6%
> - Build a new school on Blythe Valley Park 86.2%
>
> Following publication of the residents survey, the Residents Association recommendation was to accommodate children in all three local primary schools. This still represents the most sensible route.
>
> SECTION 608
> This section calls for the building of 1,000 homes on land south of Dog Kennel Lane.
>
> Residents already living in the Blythe Ward chose their location for the semi rural environment it affords. However, in recent years, Blythe has had more than its fair share of housing development which has contributed to flooding, traffic congestion, accidents and an erosion of the semi rural environment. In contrast the surrounding villages of Dorridge and Hockley Heath have virtually escaped new development.
>
> It is apparent that much of Solihull’s new housing has been dumped on the Blythe Ward and this has to stop. Accordingly, it is requested that this development is cancelled.
>
> Would you please acknowledge receipt of this note and confirm that our recommendations will be taken into account.
>
> Greg Allport
> Acting Chairman - Cheswick Green Residents Association

To whom it may concern,

I’m writing to object to the local plan, particularly with respect to sites BL1, BL2 and BL3 in and around Tidbury Green, Dickens Heath and Cheswick Green. The existing infrastructure (schools, surgeries, roads) is already struggling, even before the completion of residences already underway, e.g. near Stratford road. Much of the traffic from these villages commutes to the M42 J4, and as such creates gridlock during rush hour. Building more houses along these already busy routes is only going to exacerbate the problem, and demand to travel to the M42 is only going to increase with HS2. The narrow, rural road network cannot take further development and is already overloaded.

With particular reference to site BL1, this site will be unassociated, both visually and physically, with the surrounding villages which have clearly defined boundaries. This site will start to fill in the gaps between villages, removing the unique character of the area and destroying the connectivity between local wildlife sites and ancient woodland, as highlighted by Natural England. The BL1 site is in a high performing green belt area, which has not been taken into consideration in the Sustainability Appraisal. Central Government Policy is to protect the green belt and develop on brownfield land first.

I believe a full sustainability appraisal should have been carried out prior to site allocation, rather than trying to make the preselected site allocations fit the plan.

In response to the aforementioned topic highlighted in the subject, I would like to express my objections.

There are far too many local developments of this kind, local roads and amenities are already struggle. Doctors appointments, schooling, parking. All of these everyday luxuries and continuing to be pressed.

I hope these points are taken into consideration

Explore local options for brownfield in Solihull or other authorities that do not encroach on green belt

See attachment

See attachment

I am very concerned about the amount of housing planned for the Shirley area at 39% of the total of the borough, this is not sustainable from an infrastructure or local services point of view Why is it not more evenly spread over the entire Solihull area, with more concentration by the HS2 interchange.

Shirley already has a large proportion of older residents and many retirement flats and care-homes to numerous to mention by name, which have been built everywhere on the Stratford road.

Our doctors surgery’s are already over capacity and are struggling to recruit new doctors.
Solihull Hospital has been down graded three times in as many years , it has put unsustainable pressure on our local surgeries, the whole infrastructure is ready to collapse.

With every new housing development in the area suffers from more flooding.
Flood defences are no where near adequate now, which is clear from Dickens Heath which has flooded despite been a relative new development with the climate getting wetter we will soon be unable to get house insurance.

Dickens Heath roads are already grid locked every morning, without the additional housing planned. New relief roads are needed, but sending the traffic onto already grid locked roads like Bills lane, should not be an option.

To whom it may concern,

As a current resident of Shirley I wanted to express my view of the situation around availability of key services. Currently in Shirley it is extremely difficult to get a GP appointment (I've had to wait on phone for 1:45hr to speak to a receptionist and then wait 2 days for an urgent appointment), we are having to rely on using the national 111 service more and more as the local GPs cannot service us adequately any longer, and we are also unable to find ANY NHS dentists in the surrounding area (my wife is not registered at any dentist).

Further housing developments must consider this situation and plan to add further GP surgeries, NHS dentists and schools. We will consider moving out of the area to another borough if the situation deteriorates.

Thanks and regards,
Benjamin Williams

52 Langcomb Road
Shirley
Solihull
B90 2PR

I wish to strongly oppose this development on the grounds:

Shirley has taken more development than any other area within Solihull.
Numerous care homes, retirement homes, supermarkets and car sales rooms and also a large number of apartments and houses.

Road congestion is getting to an impossibly dangerous level which in turn is increasing air pollution beyond a safe level and impacting on our children's health.

We have precious little green belt which should be protected for our future generations and also help with flooding which is a serious problem.

Doctors and schools cannot accommodate the population as it is.

Signed
Pauline Daniels
58 Binley Close
Shirley
Solihull
B90 2RB

See Attached Document

My suggested modifications, by looking at the map from my office, is to build multi-storey social housing at the NW end of Brueton Park, with access from New Road and in the NE end of Tudor Grange Park with access from Monkspath Hall Road. This will not only provide much needed social housing in the borough but it will be close to the transport hubs of Solihull railway and bus stations and the retail employment prospects in central Solihull

See rep form attached

SSCG Local Plan Review Response



We are clearly pleased with the removal of site 13 from the local plan after a long campaign by local residents and SSCG



On the point of the current plan for SMBC to give only six weeks for local residents to respond seems unfair given the fact that you're asking for responses to be put against individual items within the plan.



Coupled with fact that there are ten thousand pages plus with support documents, a large percentage of the documents were uploaded after the consultation went live, with some changes in supporting evidence happening as late as in the final week of the consultation.

None of these were publicised



A disproportionate amount of supporting evidence was uploaded in October (around

30-40% in terms of page numbers), when the consultation went live so it’s less than the six weeks in real terms to submit responses.



We would question the plans soundness and legality to whether the plan has been positively prepared and justified (being an appropriate strategy based on

proportionate evidence),

Is effective (deliverable over the plan period), and is consistent with national policy.



Distribution



The spread of housing is disproportionate, 31% in Balsall Common and 39% in the Shirley Blythe area. This is 70% of the total plan in two small areas.





Sustainability



The environmental impacts are not sustainable



Green Belt land is essential for sustainability, both in terms of maintaining land

availability for future generations, but also for CO2 sequestration (absorbing carbon

from the atmosphere)

Whilst some Green Belt use for housing is unavoidable, the disproportionate amount

is unsustainable



Alternatives



Rather than “urban extension”, which the plan is focussed on, “verticalisation” in

built up areas should have been prioritised to maximise land efficiency for housing.



This is essential for preserving Green Belt, but also to ensure the necessary densities

that make sustainable travel alternatives viable.





Process



No drop-in sessions were arranged due to Covid

instead YouTube briefings were put online but some people reported that their questions were not answered here as they were not interactive in the same way that either a live Zoom/webinar would have been, or a

face-to-face drop-in would have been

I am very concerned about the amount of housing planned for the Shirley area. more than 39% this is not sustainable. Why is it not more evenly spread over the entire Solihull area, with more concentration by the HS2 interchange.

Shirley already has a large proportion of older residents, retirement flats to numerous to mention by name, have been built everywhere in Shirley with large complexes on the Stratford road.

Our doctors surgery’s are already over capacity and are struggling to recruit new doctors. With the continual downgrading of Solihull Hospitalpsp, it has put unsustainable pressure on our local surgeries, the whole infrastructure is ready to collapse.

Shirley is part of the Blythe valley villages. Yes this is a valley. With every new housing development the area suffers from more flooding. Flood defences are no where near adequate now, with the climate getting wetter we will soon be unable to get house insurance.

Dickens Heath roads are already grid locked every morning, without the additional housing planned. New relief roads are needed, but sending the traffic onto already grid locked roads, should not be an option.

Site 13 as modified (which includes part of site 340) should be included as proposed allocation within the DSP. The site could be considered on its own merits or in association with BL3.

See attached form and written representations

Review large scale allocations in rural area.

See attached letter

Remove part of Site BL1, south of Tythe Barn Lane, from the plan

See attached letter.

Remove part of Site BL1, south of Tythe Barn Lane, and include CFS Ref. 545, land at Tidbury Green Golf Club, instead as an allocation.

See attached letter.

Allocate CFS 554 in Local Plan for residential development.

Land at Rumbush Lane, Earlswood

Allocate CFS 554 in Local Plan Review

Land at Rumbush Lane, Earlswood

Given the identified significant shortfall in supply, and on basis that we consider certain sites (BC1, BL1, KN1) are not deliverable, we propose an alternative site, Land at Arden Green (Site 545)
Site should be re-assessed as 'green' in accordance with Site Selection Methodology and should be consulted upon to meet part of housing need.

See attachments.ARDEN GREEN – BARRATT DAVID WILSON