Q1. Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?

I think there are too many challenges to allow proper focus. In short, it should be to manage all changes (HS2, additional housing etc) without compromising the community, which is something the residents have worked hard to create and have lived with for many years.

Challenge D makes no reference to managing plan impacts on Balsall Common. The proposals to increase the number of houses by over 34% will fundamentally change a village into a town. This will result in overwhelming pressure on already stretched public facilities and infrastructure (schools,medical, roads,car parking) and an outdated and crowded village centre. Neighbourhood planning processes are already dysfunctional and a holistic Balsall Common plan is required to deliver an integrated approach and avoid unacceptable damage to the existing community.

There is no recognition of need to address poorly maintained (potholed) rural road infrastructure to encourage sustainable transport (cycling).

Whilst the broad approach to challenges is acceptable, the challenge of maintaining settlement cohesion and sense of community is not

We feel that the inclusion of the land in the proposed development of our Organic Horticulture/conservation/sports service for Solihull people with mental health problems - see attached description and photos - will negatively impact on Challenges C,F,J,K. Most importantly it delivers part of the Health and Well-being Strategy (J) by contributing to the physical and emotional health of the population; however we also positively contribute to C by providing a healthy space for cycling and walking, plus F and K as our work has sustained/brought back biodiversity through the ponds, meadow,replanting of indigenous apple trees and organic plants/vegetable growing.

You plan is to vastly increase the size of Balsall Common conurbation yet do not address the centre of the village which will be inadequate in terms of shops and car parking, and will lack adequate up to date community facilities. A new school will also be required and its location will be critical to ensure easy access and safety of children

Support challenges identified, but feel that bigger focus should be on congestion reduction, air quality improvement, public transport to Airport and HS2 interchange, energy plan to achieve carbon reduction targets, cycling and pedestrian routes.

Support challenges identified, but feel that higher importance should be given to ensuring that congestion, noise and pollution impacts can be minimised during construction

Right challenges identified, need to ensure required housing whilst retaining green belt.

Mitigation of construction phase impacts is critically important.

Allocation 13. There is less than one kilometre of open green fields between Shirley and Dickens Heath, building on this land will leave a narrow corridor/airfield of green belt land, with no public footpaths.
There is a clear boundary on the northern edge, a very well used public footpath, resurfaced by Solihull council after a local petition, and public amenity land.
As the only green space is extremely important for the health and welfare of the locals. I walk over these fields every morning on well-worn footpaths, along with many other local residents making it a very enjoyable social activity.

Challenge D makes no reference to managing plan impacts on Balsall Common. The proposals to increase the number of houses by over 34% will fundamentally change a village into a town. This will result in overwhelming pressure on already stretched public facilities and infrastructure (schools,medical, roads,car parking) and an outdated and crowded village centre. Neighbourhood planning processes are already dysfunctional and a holistic Balsall Common plan is required to deliver an integrated approach and avoid unacceptable damage to the existing community. There is no recognition of need to address poorly maintained (potholed) rural road infrastructure to encourage sustainable transport (cycling).

A further challenge will be in how these challenges are prioritised. Another challenge will be the threat of sprawl. The ability of the plan to withstand pressures from national government and the developers. The need for Solihull to support the rest of the conurbation by protecting its natural assets and assisting development to take place where development is required not just developing green field / belt sites in close proximity to the Motorway network or the badly located station associated with High Speed Rail.

Development of Balsall Common village centre has not been identified as a challenge in the context of the scale of the proposed housing development. Currently the village centre is far from an conducive area to attract interesting, attractive and desired investment from commercial ventures. Instead it is a collection of convenience outlets for fleeting visits only - not for daily or extended visits. This is because the area sits on the axis of traffic flow, and with parking and feeder roads un-sighting drivers and pedestrians, it is not a nice place to stop and likely will reduce in quality.

Allocation 13 in local plan fails to maintain the green belt between urban areas under challenge C
The green belt is vital to martian the feel of borough and for the wellbeing of the people that live here

The housing minster Gavin Barwell stated in a paper recently building on green belt is not needed to solve the UK housing problem

The centre of Balsall Common is a key challenge if there is to be an above 1,000 housing increase. It will have to expanded to take in more shops as well as an appropriate increase in car parking.

see representation on behalf of Ellandi LLP

I disapprove of so many houses being built in this area 41%. While appreciating the need for more houses. South Shirley green belt is heavily used and enjoy by dog walkers, children, runners, ramblers and cyclists. If the council take all the fields, so much enjoyed by the residence. Activities will be forced onto already busy streets: it will be to the detriment of health. I ask you to consider how much open space there is in Shirley. Already Shirley Park has been eroded for shops and flats. Green lane Park is really hardly fit for purpose.

The significant omission is about people who have lived in the rural setting for several years - who specifically moved to quiet villages e.g. Balsall Common and who have progressively seen the erosion of their way of life by the incursion of ever more housing into their village. Why is there no challenge to satisfy this significant group of people?
In all scenarios the improvement of the centre of BC should be recognised as a key challenge.

In Balsall Common further housing development is impossible without:-
1. Consideration of traffic congestion in the village centre
2. Adequate central parking
3. Much increased parking at the railway station to avoid dangerous parking on surrounding roads.
The above key challenges are omitted from the Borough plan.

Challenge E - Protecting key gaps between urban areas and settlements:
Challenge K - Protecting and enhancing our natural assets. Degrading of the historic Arden landscape character in parts of the Borough.

The proposed housing count for Balsall Common and Berkswell is only possible by infringing upon the Green Belt land of the Meriden Gap.

Challenge D

This fails to mention Balsall Common centre whilst mentioning 3 other centres. Given that Balsall Common will become a town under the draft plan this is an omission. I suggest that Balsall Common Centre is added to this section with the following comments
* Dated appearance and in need of environmental improvements
* High impact of traffic and a lack of parking to support growth
* Maintain its local importance

Challenge E
I totally support the policy objective of improved public access.However, the wording does not accurately reflect NPPF para 81 and should be modified

I do not believe Solihull Council's challenges have been met in the draft plan. If 1350 new homes are placed in Balsall Common, inequalities in housing, health and well being, and education will not be addressed; the attractiveness of the village, green belt and borough will not be sustained instead the village will no longer be a semi rural village but a soulless commuter town, our natural assets and green belt lost forever; accessibility to motorways and HS2 hub will not be sustained instead congestion will worsen dramatically. Measures should be put in place to avoid building in this area.

As an established provider of new affordable Homes within Solihull we strive to overcome the major risk of land availability and the limited supply of sites that can be redeveloped for future residential use.

Housing and population growth is a major challenge for our infrustructure and has not been fully addressed.
The existing infrustructure in Balsall Common is already under extreem pressure and will not be able to cope with the proposed massive increase in housing and the community being severed by HS2.

2. Question 1: Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?
2.1 The following responses are made in respect of Section 3: Challenges;
Challenge B- Meeting housing needs across the Borough, including the Borough's own needs and where possible assisting with accommodation the Housing Market Area (HMA) wide shortfall
2.2 Challenge B identifies the need for the Council to meet the Full Objectively Assessed Housing Need (FOAN) and accommodating some of the needs of the HMA shortfall.
2.3 The Council sets its objective of ensuring that provision for an "appropriate proportion" of the HMA shortfall is made within the Borough, whilst maintaining the other objectives of the plan with regard to achieving sustainable development.
2.4 Fulfilling the Duty to Cooperate will require the Borough Council to reach agreement with the other authorities throughout the HMA on how it can assist, in accommodating an appropriate portion of the unmet housing needs from across the HMA (as identified in the SHNS).
2.5 It is understood that the Spatial Plan for Growth (SPG) will comprise the vehicle to deliver this agreement, but it is unclear how this will be achieved in practice, bearing in mind that the SPG is in the hands of the GBSLEP and that it will be the responsibility of the relevant authorities to reach formal agreement on distribution of the unmet needs.
2.6 Whilst the Council has proposed to accommodate a further 2000 dwellings of the HMA shortfall beyond its own FOAN, there is no agreement between the other HMA authorities to demonstrate cooperation or any agreement to a distribution of the shortfall. The lack of such agreement if highlighted by the emerging response of North Warwickshire Borough Council included at Appendix II and which expresses concern that the Borough should accommodate a greater proportion of wider HMA growth.
2.7 In the absence of such effective collaboration, the Draft Local Plan is unsound and would potentially fail to ensure that the wider HMA housing requirement is met. The Plan would not satisfy the Duty to Co-operate under paragraph 178 of the NPPF and would therefore not be "positively prepared" in accordance with the requirements of paragraph 182 .
Objectives
2.8 We are also concerned about the lack of clarity over the mechanism to agree how the unmet HMA housing needs are going to be distributed and delivered. Any such agreement should be open to public scrutiny and should be based upon a clear evidential basis.
2.9 Within the GBSLEP Strategic Housing Needs Study Stage 3 (SHNS) report it is concluded (para 2.45) that "Of these 'missing dwellings', most should be within easy reach of Birmingham and to a lesser extent Solihull. This is where the largest imbalances between need and supply are found".
2.10 As such, the SHNS provides a clear steer towards Solihull accommodating a significant portion of the HMA Shortfall, bearing in mind that Birmingham itself is unable to meets its own needs (as tested through Examination).
2.11 There are a number of compelling reasons why Solihull is well placed to accommodate a significant part of the HMA shortfall:
* Economic Growth - the SHNS identifies the Borough as having the greatest rate of projected job growth of all the authorities within the HMA (25%) (Table 7.1 from Stage 3 Report). Furthermore, HS2 would provide a spur to economic growth which is recognised in the SHNS as "supergrowth" in respect of the UK Central initiative (see paras. 7.16 - 7.19 of Stage 3 Report).
* Public Transport Links - Solihull has strong public transport linkages with Birmingham which accounts for the greatest part of the HMA deficit and is where the SHNS suggests most of the missing dwellings should be within easy reach. The SHNS indicates that 8,345ha of land is available within the Borough within 3.75km of railway stations which is not affected by "absolute" constraints, which indicates that significant sustainable land is available if the Green Belt is reviewed.
* Lack of "Absolute Constraints" - Although the Borough is heavily constrained by Green Belt, this is a policy constraint which can be reviewed.
* An attractive and aspirational housing market - the Borough is one of the most attractive and aspirational places to live in the HMA. This is reflected in average house prices (third highest authority in HMA), affordability ratios (third worst in HMA) and low vacancy rates (1%- lowest in HMA).
2.12 As set out throughout our responses, there are strong grounds to suggest that Solihull Borough is well placed to deliver a significant portion of the unmet needs and this should be provided for through the Local Plan Review. It is critically important to the social and economic interest of the GBSLEP area that the HMA authorities provide a clear strategy and programme for joint working to effectively agree ("resulting in a final position", para. 181 of the NPPF) the distribution of unmet housing needs across the HMA.
2.13 Unless this is achieved it is highly likely that the Draft Local Plan will be found unsound and the Duty to Cooperate will not be met. Procrastination on this issue will delay the preparation of other Local Plans resulting in housing needs being unmet which will have significant adverse impacts across the HMA and risks stifling economic growth.
Action required to ensure "soundness"
2.14 The Council should amend the text under Challenge B second bullet to give greater certainty of approach with regard to the need to satisfy the "duty to co-operate" test with the other HMA authorities to;
"To satisfy the Duty to Cooperate test set out in the NPPF which will be achieved through accommodating an appropriate proportion of the HMA wide housing shortfall, in a manner which satisfies the principles of sustainable development."
2.15 The second bullet point under Objectives should be amended to;
"To ensure that provision is made for an appropriate provision of HMA shortfall in new housing land. This will be delivered based upon achieving formal agreement with the HMA authorities and based upon unique position of the Borough to assist in delivering new homes and economic growth as recommended in the GBSLEP SHNS."
Challenge D- Securing sustainable economic growth
2.16 Challenge D identifies under Key Economic Assets (fourth bullet) the potential impact of congestion arising from additional growth/housing upon Solihull's important regional and sub-regional role.
2.17 We are concerned that the Council's stated objectives do not reflect the important role that Solihull can deliver in terms of managing the threat of congestion on the road/ rail networks that would be caused through its failure to accommodate an appropriate level of housing growth upon the wider HMA as a result of unnecessary inward commuting to the Borough.
2.18 As a result, the text under challenge D would fail to result in a Draft Local Plan that is "positively prepared" or consistent with achieving sustainable development.
Action required to ensure "soundness"
2.19 The objectives under Challenge D should be amended with a new bullet to state;
"Maximise the opportunity for reducing congestion on motorways, the strategic rail network and rail through delivery of an appropriate level of new housing to meet the shortfall across the HMA within the Borough, where this can be achieved to deliver sustainable development."
Challenge E- Protecting key gaps between urban areas and settlement
2.20 Challenge E seeks to ensure that in meeting housing needs for Solihull and the wider HMA, that the integrity of the Green Belt and rural setting of the Borough is maintained.
2.21 The objectives underpinning the challenge fail to reflect the nature of technical assessments undertaken to provide justification for site release to ensure that environmental protection is achieved.
2.22 As a result, Challenge E of the Draft Local Plan does not set out to ensure that it is "justified" in accordance with the NPPF and that it is therefore, based upon the most appropriate strategy and a proportionate evidence base.
Action required to ensure "soundness"
2.23 The objective should be amended to state;
"Justification for the release of land from the Green Belt to meet the need to new development should be focused on those sites which perform least well against the functions of Green Belt and outcomes from the Borough's Green Belt Assessment."

The proposed challenge lists are quite comprehensive and in the main appropriate. With regard to the spatial plan the cascade model is a reasonable approach and the outcome places the proposed developments connected to existing urban areas with access to services. It is mindful of maintaining the rural area but needs to say more on transport network design and upgrades and avoidance of overloading rural networks connecting to primary routes.
The current proposed growth opportunities are in my view appropriate and will only have a potential indirect impact on Hockley Heath arising from the attendant local traffic growth adding to the impact of the Blythe Valle development. If the proposed additional local mass transit services in the region are of a significant scale and penetration across the borough then the local traffic growth may well be mitigated.
Agreed with specific additional comments on paragraph 66 as follows:
Reducing inequalities in the Borough (Agreed - ensure that the transport network is properly designed and upgraded to cope with anticipated volumes arising from growth and that high volume rat runs on rural networks is avoided)
Meeting housing needs across the Borough, including the Borough's own needs and, where possible, assisting with accommodating the HMA wide shortfall. (Agreed but Birmingham needs to do more)
Challenge A
Other Areas of the Borough - sentence "Problems of access to housing and local services, particularly in some rural areas" should read "Problems of access to housing and local bus and health services, particularly in some rural areas"
Additional consideration "Increasing investment in rural areas to upgrade and maintain village infrastructure".
Challenge B
"Accommodating some of the HMA wide housing shortfall without adversely affecting the quality of its environment and its attractiveness for businesses and residents (Agreed but Birmingham should be doing a lot more)"
"A need for a range of affordable housing for older people and for people with learning, physical and sensory disabilities and mental health needs. (Agreed subject to detailed assessment)"
Challenge C
"Ensuring there is sufficient amenity space and opportunities for secure children's play in Rural villages as well"
"Ensuring that residential and other amenities are protected in particular Superfast Broadband"
Challenge D
Additional suggested "Identify the new growth industries that Solihull wishes to attract to the Borough e.g. Digital technology, Bio-Technology, Data Hubs Amazon, Google, Apple et al), Energy Hubs (Tesla), Life Sciences (Urgent)"
amend "Meeting aspirations of key businesses to enable them to maintain competitiveness (Birmingham Airport, National Exhibition Centre, Birmingham Business Park, Blythe Valley Park, Jaguar Land Rover) whilst contributing to sustainable development and providing a well-designed SMART road transportation network that can provide safe and secure access sensitive to the rural communities road infrastructure"
"Managing by design the impact of congestion on motorways, the strategic highway network and rail from additional growth/housing"
"Managing by design the impact of pressure for development on the quality of the environment"
"Need for high speed digital connectivity to enhance competitiveness" is critical!
Challenge E
"Maintain the Green Belt and improve the network of green infrastructure in Solihull, to prevent unrestricted expansion of the major urban area, to safeguard the key gaps between settlements such as the Meriden Gap and the countryside. Ensure that the countryside is managed so as to deliver a range of benefits including the growing of food and energy products, create an attractive rural setting and improved public access and recreational opportunities." This is absolutely critical to maintain the Borough's differentiation from any other urban sprawl
Challenge F
"Impact on biodiversity conservation and landscape character establish growth of natural meadows to encourage natural flora and fauna"
Challenge G
Robust enforcement of the use of traveller site with zero tolerance of unauthorised pitches
Challenge N
To minimise the impacts of HS2 and the associated growth during both the construction and operational phases and to monitor and ensure that any unacceptable impacts are satisfactorily mitigated

Please refer to our uploaded attachments

This is not agreed in relation to Challenge B as it establishes a subjective test which implicitly secures a brake on housing provision for extraneous needs. By having a test which says more housing except if there is an adverse effect artificially limits provision to meet demand arising outside the Borough. That external demand will find its way into the borough whether housing land is provided or not. If it is not catered for it will simply contribute to a combination of house price rises and ripple effect migration, both of which run counter to Government sustainability policies.

The Challenges and Objectives set out in the emerging Local Plan are supported, but changes are recommended. However, the objectives relating to housing delivery 'Challenge B' should be broadened to include a specific objective that seeks to promote the redevelopment of brownfield sites in sustainable locations. This will help to deliver much needed housing on sites that are often already well served by infrastructure and so can be delivered in the short term. The early redevelopment of brownfield sites would be encouraged by applying a lower affordable housing threshold to these sites in the first five years of the Local Plan. This would assist those developers who have bought brownfield sites under the existing affordable housing threshold of 40% to bring those sites forward in the context of the policy requirement that was in place when the sites were acquired. This incentive, along with the application of the Vacant Building Credit, as set out in Policy P4, will help and encourage the delivery of brownfield sites in the early stages of the Local Plan. This will provide the additional time required to deliver infrastructure to the larger greenfield sites that are proposed to be allocated by the Emerging Local Plan and ensure a more even housing delivery rate throughout the plan period. Such an approach would meet the overall objectives of the National Planning Policy Framework along with the other challenges outlined in the emerging Local Plan.

In respect of 'Challenge D', the objectives that seek to secure sustainable economic growth are in general supported. However, the second objective to 'Challenge D' offers support for the 'key economic assets' of the Borough. These assets thrive in Solihull because of the associated and related industries and services that feed into and support the key economic assets. Therefore, the smaller businesses and services sectors that support the key assets should also be offered support and encouraged to grow. It would, therefore, be preferable to see this objective reworded to include reference to 'supporting businesses and services'. This ties in much better with the Borough Vision as it encourages wider investment in the Borough from smaller companies related to, involved with, or supportive of the key economic assets.

Under "Challenge K - Protecting and enhancing our natural assets" I was disappointed to see that there isn't equal weighting given to the natural environment that borders Shirley. Allocation 13 is an area of biodiversity and habitat of value, an important area for local wildlife in Shirley. We have lost too many of these areas already.
Challenge E - Protecting key gaps between urban areas and settlements. Building houses on Allocation 13 is contrary to the objectives of this challenge. I live in Shirley South adjacent to the Green Belt and can testify to the biodiversity that still exists in this area and the benefits it brings to the local residents and the area.