Foreword

Support

Representation ID: 14508

Received: 11/12/2020

Respondent: Mrs Beryl Hukin

Is happy with the details.

Object

Representation ID: 14549

Received: 11/12/2020

Respondent: St Philips - Land at Stratford Road, Hockley Heath

Agent: Lichfields

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HMA/DtC:
It is understood the Council intends to contribute 2,105 dwellings to meet unmet housing from the Greater Birmingham and Black Country Housing Market Area; however, this is not set out in a Statement of Common Ground (SoCG). In the absence of SoCG, St Philips considers that an increase to the proposed housing requirement is necessary to ensure additional flexibility in the event that constituent HMA authorities suggest a need for an increased contribution to the shortfall.

Object

Representation ID: 14610

Received: 12/12/2020

Respondent: Kimberley Orme

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

• Unfair timing of this consultation, taking place during COVID19 when the district is in Tier 3 local down, resulting in issues attending meetings to discuss such matters

Object

Representation ID: 14625

Received: 14/12/2020

Respondent: Sheila Cooper

Legally compliant? No

Sound? No

Duty to co-operate? No

I believe the decision not to extend was unsound.
Flawed methodology and inaccurate data.

Object

Representation ID: 14649

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Sustainability Appraisal:
The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year, and has therefore not been informed by the SA in accordance with the Framework.

Option 2 (15,000 dwellings) is the Plan’s preferred approach in light of the SA, and yet higher levels of growth perform equally as well. The only tangible difference between Option 3 (16,000 dwellings) and Option 2 is that Option 3 has a negative effect in relation to resource efficiency (resulting from greater generation of waste) whereas Option 2 is regarded as neutral
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options. Only considering two spatial options for this higher level of growth clearly has the potential to skew the conclusions of the SA.

It is acknowledged that the SA has to be manageable, and cannot consider endless alternatives and permutations. However, given the importance of testing higher levels of housing growth in light of the scale of unmet need arising from the neighbouring authority, the SA should have undertaken a finer grain analysis of options at levels of growth above 16,000 dwellings utilising its own evidence base of available and suitable sites.

The SA does therefore not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement

In relation to the specific assessment of Site 417 (AECOM59a West of Stratford Road, Hockley Heath), there are a number of effects identified that can easily be mitigated and avoided. The SA has indicated a number of significant negative effects for some of the proposed allocations (not least UK Central), but that on-site mitigation has been taken into consideration in the selection of the allocations.

Object

Representation ID: 14666

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Some sites have not been considered within the SA as reasonable alternatives without explanation. In the Supplementary Consultation (2019) ‘amber site’ A1 was consulted upon as part of the consideration for further site options (identified in step 1 of the site selection process as ‘likely allocation’). However, the Site Assessment document (site reference 345) states that the SA does not assess the site. Therefore, the SA could not have informed the overall conclusions of the Site Assessment process (which for this site concludes it is ‘red’ – no allocation).
At Section 7.2 the SA provides ‘outline reasons’ for the selection of proposed housing sites at the plan level, however the SA does not provide any outline reasons for individual sites in terms of why they have or have not been selected for allocation. This is not fully in accordance with the Strategic Environmental Assessment Regulation h) which requires an ‘outline of the reasons for selecting the alternatives dealt with’.

Object

Representation ID: 14667

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Five new Sports Hubs are required across the Borough to deal with replacement / new provision. The Plan is unclear on the precise location and deliverability of this mitigation, and it is unclear whether the land is available to deliver these hubs, or the cost and timing of when they will be delivered. It is implied that in some instances very special circumstances will be required at the application stage. We object to this approach. The draft SLP should clearly state what mitigation is required and how it can be delivered, with support from the evidence base – for instance transport, Green Belt, landscape, viability. It cannot be considered an afterthought.

Object

Representation ID: 14688

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year and has therefore not been informed by the SA in accordance with the Framework.
Option 2 (15,000 dwellings) is the Plan’s preferred approach in light of the SA, and yet higher levels of growth perform equally as well. The only tangible difference between Option 3 (16,000 dwellings) and Option 2 is that Option 3 has a negative effect in relation to resource efficiency (resulting from greater generation of waste) whereas Option 2 is regarded as neutral
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options. Only considering two spatial options for this higher level of growth clearly has the potential to skew the conclusions of the SA.
It is acknowledged that the SA has to be manageable, and cannot consider endless alternatives and permutations. However, given the importance of testing higher levels of housing growth in light of the scale of unmet need arising from the neighbouring authority, the SA should have undertaken a finer grain analysis of options at levels of growth above 16,000 dwellings utilising its own evidence base of available and suitable sites.
The SA does therefore not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement
It is noted that Site 416 (Land north of School Road, Hockley Heath) has not been assessed within the SA even though the site was submitted to the Council in 2018. However, the Site Assessment makes reference to the SA of AECOM 59 (the adjoining site), there are a number of effects identified that can easily be mitigated and avoided

Object

Representation ID: 14694

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Unmet needs: The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. The Plan does not fully address unmet housing needs and the housing requirement should be increased accordingly. Paragraph 227 of the Plan advises that Birmingham has unmet needs (37,900 homes), and paragraph 228 advises that the Plan is proposing a contribution of 2,105 homes towards unmet needs. However, there is no evidence that this level of contribution is agreed with Birmingham or other neighbouring authorities, or that the unmet needs that remain are to be addressed elsewhere. There is no evidence as to why the contribution is only 2,105 homes.
In addition to Birmingham’s needs, it is also noted the Black County Authorities estimate unmet housing needs of 29,260 homes and up to 570ha of employment land to 2038, and have written to the Council notifying them. The Council has suggested their unmet needs can be dealt with as part of the next review of the Local Plan. However, that is not evidence of effective joint working, but rather deferring its consideration which is evidence of an unsound Plan in being contrary to paragraph 35 c) of the Framework.

Object

Representation ID: 14714

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Community Involvement - The process of community involvement is not in general accordance with the SCI. Despite requests, Site 127 has not been reassessed, if so it would demonstrate that errors were made in the first assessment and that the site is suitable.
Consultation on the submission plan was not long enough, particularly given the introduction of new evidence and the impact of covid restrictions.
Paragraph 52 SCI – In respect of the responses to the 2019 Consultation, Cabinet Member only received a summary of all the comments received during the consultation.
Paragraph 53 SCI – This was not complied with in relation to the publication of the submission version of the plan. In particular, prior to submission, there is no opportunity to explain how the consultation had been used to shape the final submission plan.
The FTA does not address the disadvantageous impact of a minimum 6 week consultation period on protected characteristics during a global pandemic with severe restrictions.

Object

Representation ID: 14769

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year, and has therefore not been informed by the SA in accordance with the Framework.
Very little difference between Options 2 and 3 and the SA conclusions are inconsistent.
The SA demonstrates that a higher level of housing growth than 15,000 dwellings can be
accommodated sustainably.
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options.
The SA does not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement.

Object

Representation ID: 14802

Received: 13/12/2020

Respondent: South Solihull Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Objects to the response time: 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 - Plan unsustainable due to the disproportionate amount of greenbelt land used - built up areas not prioritised enough - Lack drop in/ face to face sessions.

Support

Representation ID: 14862

Received: 12/12/2020

Respondent: Solihull Ratepayers Association

Feel the Solihull Planning Process by way of providing public community information in considerable detail over the extended Review Period together with the informal non-statutory and statutory consultations has been to a high standard - welcomes amendments made at different stages of the plan -

Support

Representation ID: 14885

Received: 11/12/2020

Respondent: Canal & River Trust

I can confirm that the Trust does not have any further comments to make on the Plan.

Object

Representation ID: 14895

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Timing of Consultation:
Council should have held back plan til more certainty in planning system, as Bromsgrove have done.

Object

Representation ID: 14896

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Accessibility of consultation:
- Not accessible to residents unaccustomed to online services or without internet access.

Object

Representation ID: 14917

Received: 14/12/2020

Respondent: Department for Education

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Evidence Base: Draft Infrastructure Delivery Plan:
- Welcome reference (p.77) to DfE’s Education Contributions Guidance.
- Need to ensure close working with neighbouring local authorities as high number of primary and secondary aged pupils outside of Borough attend Solihull schools.
- Would be useful to produce a Planning for Schools topic/background paper, expanding on evidence in Council’s IDP and School Organisation Plan, setting out clearly how forecast housing growth at allocated sites has been translated (via an evidence-based pupil yield calculation) into an identified need for specific numbers of school places and new schools over the plan period.
- DfE recommends SoCG with neighbouring authorities on cross-boundary movement of school pupils between Solihull borough and adjoining areas.

Object

Representation ID: 14948

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SPDs:
- Number of policies refer to SPDs and other guidance (see separate representations):
o P4A (2), P4E (4), P9 (1), P15 (5), P18 (10).
o Such references are inappropriate and non-compliant with the Regulations.
o Regulations are clear that development management policies should be set out in Local Plan policies. Council’s approach of requiring compliance with adopted SPDs is giving Development Management Plan Document (DPD) status to documents which are not part of the Local Plan, and have not been subject to the same process of preparation, consultation and examination.
o For policy to be effective should be clearly written and unambiguous, set out in sufficient detail, so it is evident how a decisionmaker should react to development proposals and not reliant on other criteria or guidance set out in a separate SPD.
o NPPF and PPG confirm scope and nature of SPDs and that they should not introduce new planning policies nor add unnecessary financial burdens on development.

Object

Representation ID: 14962

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Sustainability Appraisal
- November 2015 Interim SA found that large scale expansion of rural settlements was one of worst performing options.
- Major adverse impacts in terms of resource efficiency, and moderate adverse effects with regard to reducing need to travel and impact on landscape.
- Initial findings were ignored by Council, which opted for large housing allocations in rural villages over sustainable urban extensions.

Object

Representation ID: 14965

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

PRISM Transport modelling:
- Report acknowledges that PRISM transport assessment is a strategic network tool, focuses on 11 key strategic network routes, with limited validity on minor roads. This brings into question validity of site assessments, as these could be considered to be served by inadequate minor road network.

Object

Representation ID: 14976

Received: 11/12/2020

Respondent: Mrs Jean Walters

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Sustainability Appraisal:
Sustainability Appraisal excludes a number of smaller sites, Strategy continues to focus on large scale Green Belt release. Smaller sites could contribute to housing growth in a more sensitive way with less overall impact on Green Belt, local character, and are more deliverable.

Object

Representation ID: 15081

Received: 11/12/2020

Respondent: Highways England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Transport Evidence comments from Highways England:
Strategic Road Network (SRN) within Solihull comprises M42 and M6 motorways, and the A45, A452 and A446 trunk road.
Regard to Para. 16 of DfT Circular 02/2013, NPPF and other relevant policies.
Identified following areas where clarity and further information is required to continue our appraisal of the DSP:
Meeting Housing Need
- Reviewed GBBCHMA Housing Need and Supply Statement published in September 2020, note that greater deficit in delivery of housing than expected in HMA after 2031.
- If housing numbers should increase as a result of consultation process or Examination, then need to fully assessed and modelled, to identify impact on SRN and whether any more additional mitigation will be required.
Transport Evidence base:
- Identified prioritised list of items where we require further information or clarification to help complete our review of Local Plan documents:
o Clarity on development quantum proposed/assumed at UK1 and UK2
o Flow information from PRISM assessments for base, 2026 and 2036 scenarios; can be used for LinSig models
o Base turning counts for SRN junctions if available
o Clarity on whether modelling work includes proposed improvements at M42 J6, and any improvements associated with HS2 (M6 J4)
o Table of flows with associated plots to show amount of development traffic plus overall traffic expected on M42 and A45 (SLP and DLP scenarios). In addition, V/C plots requested.
o Further analysis required to understand whether DSP traffic rat-runs away or displaces any non-development SRN traffic along the M42 and M6.
- Discussed matters at meeting on 7th December – we will continue to work proactively with SMBC on these matters.

Support

Representation ID: 15087

Received: 11/12/2020

Respondent: Highways England

Highways England is committed to continue to work with the Council in a collaborative and constructive manner to support the progression of the Local Plan. As part of this approach we will work with you to develop a Statement of Common Ground between ourselves.

Object

Representation ID: 15111

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans - General comment:
Fair and reasonable that concept masterplans provided to give Council confidence on capacity and delivery of sites.
Status of CMPs in Plan, and weight to be accorded to them, is uncertain.
Text in Concept Masterplans introduction 'indicative broad level masterplans' vary with text in DSP Para. 404. 'Council will require developers to generally accord with principles in CMP.'
Imperative that weight of CMP is clear at development management stage to make Plan sound.

Object

Representation ID: 15132

Received: 13/12/2020

Respondent: Woods Farm (Christmas Trees)

Agent: Twelve Twenty One Planning Services

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policies Map:
This policy is not supported and objected to in very strong terms in the context of the proposed boundary to the Green Belt around site BL3.

Green Belt boundaries should endure for more than one plan period and should provide sufficient flexibility to enable the Council to meet its housing requirements in the short term should sites be delayed or not brought forward for some reason. In this regard, the Council hasn’t attempted to identify “reserve sites” that serve no long term Green Belt function and which could be brought forward for development should that be necessary to meet housing or other needs.

It is proposed that land adjoining site BL3 at Whitlocks End Farm should be excluded from the Green Belt in the same manner and in accordance with the submitted Vision Document (attached).

This Vision Document demonstrates the development that accords with the Council’s objectives of maintaining a 300 metre separation between South Shirley and Dickens Heath and also follows existing hedgerows which form strong and natural boundaries. It also maintains the separation to Majors Green to the west established by the existing railway embankment.

The Vision Document also demonstrates how the proposed allocation BL3 can be implemented yet allows for a natural extension to accommodate further development, particularly to the east, as a natural rounding off of development up to the proposed new public open space.

Redrawing the Green Belt boundary to comply with this Vision Document will not only facilitate further development, if required, of up to 750 dwellings in total but it will also provide a natural edge to Shirley which accords with the five purposes of Green Belts as set out in Paragraph 134 of the NPPF.

Object

Representation ID: 15137

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

No statements of common ground have been prepared at the publication stage. It is unclear if effective and joint working has been undertaken, particularly in respect of unmet housing needs from the HMA. There is a significant gap in the Council’s evidence base on meeting its legal obligations under the Duty.

The housing need across the HMA beyond 2031 has been overlooked. There could be an emerging unmet need for some 39,605 dwellings for the period 2031 to 2036.

Solihull must engage on how to address the significant shortfall in housing needs of the Black Country. Delaying further consideration does not meet the legal test under the 2011 Act.

Object

Representation ID: 15221

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policies Map (in relation to Green Belt boundary for Site BL2)
Considered proposed boundary does not accord with NPPF Para. 35 & 139.
1) Appointed consultants to site promoters, EDP, have carried out an assessment (see attached) and conclude that the site does have well-defined and defensible boundaries for a new Green Belt boundary, contrary to statement Para. 609 in the DSP.
Considered that a well-vegetated field boundary, which could be enhanced with additional planting, would provide a much more appropriate and definable physical
boundary on the ground than a proposed new internal road and in doing so would maintain the existing field structure within the landscape.
To re-align to only a newly built man-made feature is unsuitable, and affords less opportunity to integrate the proposed development into the landscape setting, which may potentially impact the character of the
countryside beyond and the perception of openness in the countryside and would make for an inefficient road layout and less permeable masterplan.
2) Parcel east of BL2 (south of Stratford Rd up to boundary with buildings west of Creynolds Lane) should be re-instated as part of Site BL2, as per the 2019 consultation.
Unclear why land has been removed between 2019 and 2020 consultations; is within a lower performing Green Belt parcel, no flood risk, unconstrained by ecological features and does not contain any heritage assets.
Release of land would have added benefit of additional land available for residential development.