Draft Local Plan - Supplementary Consultation

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Object

Draft Local Plan - Supplementary Consultation

Local Housing Need

Representation ID: 9149

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

The objectively assessed need identified through the standard methodology cannot be met in Solihull without undermining the green belt. Knowle conservation area is the most important conservation area in the Borough. Proposals to surround Knowle to the north and south east would undermine the Conservation areas character and setting. Knowle would become a town in terms of population and urban context. Conservation areas like green belt as one of the grounds in NPPF footnote 6 for restricting development below the objectively assessed need. A further exceptional circumstance which justifies a different approach is the degree to which the Borough is the location for a large number of jobs taken by people who do not live there. The extent of commuting in and out of Solihull makes estimating local housing need difficult. The conclusion to draw is that Solihull's housing provision should not include provision for more than 50% of those who work in the Borough but should include some provision for the needs of Birmingham, whilst this may appear paradoxical it reflects the reality of the employment. The alternative to the standard methodology is capacity led. The level of housing should in principle be limited to urban capacity on land which is not green belt or which would not undermine specific village character. There is scope for changes to green belt boundaries in locations which do not affect the openness and rural character of the Meriden Gap and Knowle village. There is no justification for the commitment to take 2,000 dwellings from the wider HMA, not aware that the Council has reached any agreement with adjoining Councils. Rate of housing delivery suggested in the consultation document is far above any completions except in 2005. it is double the rate of housing completions over the past ten years and above the cap that would apply if the standard method were to be used to calculate Solihull's own local housing need. The proposed housing policy is not sound as it is not deliverable or achievable from past evidence. Should use 2016 ONS household projections to indicate the most likely household growth in the Borough. This is 550 households or 9350 over 17 years 2018 - 2035 and would be achievable within the constraints of the green belt and Knowle conservation area. On this basis there is capacity for 13 years up until 2031 without needing new allocated sites which are Green Belt

Full text:

1. Do you believe that there are exceptional circumstances that would justify the Council using an alternative approach, if so what are the exceptional circumstances and what should the alternative approach be?

The method used by the Council to determine the housing requirement for the Plan is not suitable. It uses a national methodology and outdated household projections. It is based on the assumption that there is no constraint to meeting the full projected requirement (now called 'Local Housing Need' in NPPF 2018).
The NPPF 2018 sets out at para 11 the principle for Plan-making:
Plans and decisions should apply a presumption in favour of sustainable development.
For Plan-making this means that:
a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas (footnote 5), unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area (footnote 6); or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.
Footnote 5 As established through statements of common ground (see paragraph 27).
Footnote 6 The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.

Solihull Borough, outside its built-up areas, is all land designated as Green Belt. The Green Belt is of greater than usual strategic (geographic) significance because it separates two cities, Birmingham and Coventry, by the area known as the Meriden Gap, which is only 6 miles wide and risks becoming narrower. It has been established policy in successive development plans and in regional strategies to retain the Green Belt between the two cities and to maintain very strong planning policies to prevent urbanisation of the land between them. This policy dates from the 1950s and has been supported by successive Solihull development plans - the UDPs adopted in 2000 and 2006, and the Solihull Local Plan adopted 2013. The Green Belt in Solihull provides a very strong reason for restricting the overall scale of development in the Plan area. The 'objectively assessed need' or 'local housing need' identified by the standard method cannot be met without undermining the Green Belt, listed as a policy in Footnote 6 of the NPPF..
A second policy to protect an area and asset of particular importance is that for the Knowle Village Conservation Area. Knowle is the most important Conservation Area is the Borough, and the designation aims to preserve its village character. Proposals to surround Knowle village with extensive housing to its north and southeast would undermine the Conservation Area's character and setting because Knowle would become a town in terms of population size and urban extent. Conservation Areas are listed in the NPPF's Glossary as Designated Heritage Assets. Designated Heritage Assets, like land designated as Green Belt, are included in NPPF Footnote 6 as one of the grounds for restricting development below the 'objectively assessed need'.
A further exceptional circumstance which makes Solihull unusual and justifies an alternative approach is the degree to which the Borough is the location for a large number of jobs taken by people who do not live there, and who commute in.
Solihull has a population of 210,400 (2015). The Draft Local Plan states at para 30 that the number of jobs in the Borough is 100,000, and that 50% of them are taken by people who do not live there. Thus 50,000 people commute into the Borough daily. There is also substantial commuting out of the Borough to Birmingham. The extent of commuting in and out of Solihull makes estimating 'local housing need' under the NPPF 2018 and PPG difficult and contentious. Solihull's employment growth has never been dependent on provision of housing and has not been held back by limitations on housing or on its price. The long-standing policy of the Council to encourage employment growth has been in the full knowledge that many of the jobs are filled by people living outside the Borough.
The conclusion to draw from para 30-31 of the Plan is that Solihull's housing requirement should not include provision for more than 50% of those who work in the Borough, perhaps less; but should include some provision for the needs of Birmingham. While this may appear paradoxical, it reflects the reality of the employment pattern and the interrelationship of Solihull and Birmingham.

The alternative approach to the standard method specified in the NPPF and PPG should therefore be capacity-led. The level of new housing in the Plan period should in principle be limited to the urban capacity on land which is not Green Belt, or whose development would not undermine the specific village character and conservation status of Knowle village and its setting.

There is scope for some changes to the Green Belt boundary in locations which do not affect the openness and rural character of the Meriden Gap, and do not undermine the village character and rural setting on the north, east and southeast of Knowle village. However these should be limited. The Solihull Green Belt Study gives some guidance on which areas of the Green Belt make the most and least contribution to its purposes; its status is however limited by the fact that it is a consultants' report and not a planning document that has been subject to public consultation or involvement in its preparation.

Housing Market Area

In the section 'Housing Market Area' (para 49-52), it is stated (para 49):
The Draft Local Plan included a commitment to accommodate 2,000 dwellings from the shortfall that is occurring in the wider Housing Market Area. Using the same contribution, the overall housing requirement to be addressed in the Local Plan Review would, using the standard methodology outlined above, be 15,039 dwellings over the period 2018 to 2035, or 885 dwellings per year.

There is no justification for this commitment to take 2,000 dwellings from the wider HMA, because that conflicts with the principles set out in NPPF para 11 and the Green Belt and Knowle Conservation Area constraints.

We are not aware that the Council has reached an agreement with adjoining Councils regarding its contribution to the HMA shortfall.

The rate of housing delivery suggested in the Consultation text, 885 dwellings/year for 17 years 2018-2035, is far above the highest number of completions in the Borough in any one year except in one year, 2005. It is double the rate of house completions that have been recorded over the last 10 years (2008-2018). It is also above the 'cap' that would apply if the standard method were to be used to calculate Solihull's own local housing need.

The proposed housing policy and projected housing requirement of 15,000 over 17 years is not sound, because it is not deliverable from past evidence. Such a high rate of delivery over the life of the Local Plan could never be achieved - it is double the past rate, the housebuilding industry does not have the resources to built at such a rate, it takes no account of economic cycles or the projected economic downturn of the next few years.

The Council can instead use the 2016-based household projections, which are independently published by the ONS and indicate the most likely household growth in the Borough given the many constraints. This is an annual growth of 550 households, or 9,350 over 17 years 2018-2035.

That level of housing provision is largely achievable within the constraints of the Green Belt and the Designated Heritage Asset of Knowle Village Conservation Area. The Solihull Housing Land Supply table (page 13) shows that housing supply excluding 'Allocated Sites' (6,310 dwellings) and UK Central Hub (2,500 dw) is 7,355. (The 'minus 400' or 10% reduction applied to sites with planning permission and SLP 2013 allocated sites is not justified. Experience in the Borough in recent decades is that generally the number of houses given planning permission at detailed application stage is above the Local Plan number, not below it.) Therefore there is capacity for 13 years of the Plan period, up to 2031, without needing new allocated sites which are now Green Belt, if the most recent household projections for the Borough are used.

Housing Land Supply: Small Sites

The Consultation document at para 56-57 addresses the issue of 'Small Sites' but there is no consultation question attached. In the previous consultation (Dec 2016-Feb 2017) there was significant comment that the Local Plan is relying on large housing allocations and contains very few small sites, despite national policy to encourage small sites which can be developed with short lead-time and quickly, compared to the slow rate at which large sites reach detailed permission stage and then are built out. NPPF 2018 para 68 says: 'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly'.

Para 56-57 seek to justify the Local Plan's preference for large sites by asserting that national policy is complied with if only 1500 houses are proposed on small sites below 1 ha. It says that since windfall sites (2250 dw) and brownfield-register sites (400 dw) would be small sites, 'these sources will comfortably exceed the 10% requirement for small sites'.

NPPF 2018 para 68(a) in fact states that planning authorities should identify land to accommodate 'at least 10%' on sites no larger than 1 ha. But this does not mean that the remainder can therefore be proposed on large site allocations. There are many sites between 1 ha and 5 ha which are 'small or medium' and would not be large allocated sites. Many were advanced by developer or property interests at the call-for-sites stage but have not been accepted.

There are good reasons to maximise the number of small and medium sites:

* They are usually sustainable locations within the existing urban areas
* They are accessible - served by existing public transport
* They are near existing services - schools, shops, community facilities
* Small and medium sites in the urban areas reduce or remove the need to change Green Belt boundaries and remove land from the Green Belt.
* The large sites proposed in the Local Plan can only be 'greenfield' as there are no more old industrial areas to redevelop; hence cause loss of Green Belt.

The Plan's bias in favour of large, greenfield, housing sites remains. It needs to be changed and the focus changed to (a) sites below 1 ha and (b) sites between 1 ha and 5 ha (small-to-medium).

Object

Draft Local Plan - Supplementary Consultation

Site Selection Methodology

Representation ID: 9150

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

No, because there are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The analysis of sustainability does not meet the standards as set out in the NPPF2 Para. 3.32.
The Council should consider reviewing their Sustainability Appraisal in line with the Government's sustainability scorecard. When applied to Site 4 at Dickens Heath, this site only scored a 30% sustainability rating which puts it in the 'red' not 'green' category. There are other sites that are inconsistent with Option G of the Spatial Strategy.
It is not possible to understand how some of the sites fall into the green category. If an updated sustainability scoring was used the results on site selection would be different. Without this, the credibility and robustness of the process is undermined. It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. The Plan's strategy continues to focus only on large scale Green Belt releases. This is not consistent with government advice in the NPPF that a mix of sites should be encouraged. Many of the small sites which have not been accepted as allocations in the Plan need to be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character, and whether they are more readily deliverable.

Full text:

2. Do you agree with the methodology of the site selection process; if not, why not and what alternative/ amendment would you suggest?

No, because there are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The analysis of sustainability does not meet the standards as set out in the NPPF2 Para. 3.32.
The Council should consider reviewing their Sustainability Appraisal in line with the criteria as set out in the Government's sustainability scorecard, see:- www.thescorecard.org.uk For example, when this analysis was applied to Site 4 at Dickens Heath, this site only scored a 30% sustainability rating which outs that proposed housing site in the 'red' not 'green' category. Just looking beyond that example, there are other sites that are inconsistent with Option G of the Spatial Strategy.
It is not possible to understand how some of the sites fall into the green category. The criteria for 'green'status is that "they have no or relatively low impact on relevant considerations; or that severe impacts can be mitigated". But some clearly have a high impact. Again, if an updated sustainability scoring was produced in line with recent Government Policy, the results on site selection would be different. Without this, the credibility and robustness of the process is undermined.
It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. As noted in the response to Question 1, regarding the 'Small Sites' section of the Consultation document (para 56-57), the Plan's strategy continues to focus only on large scale Green Belt releases. This is not consistent with government advice in the NPPF that a mix of sites should be encouraged. Many of the small sites advanced by owners or prospective developers which have not been accepted as allocations in the Plan need to be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character, and whether they are more readily deliverable.

Object

Draft Local Plan - Supplementary Consultation

Question 4 - Site 1 - Barratts Farm

Representation ID: 9154

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

Barratt's Farm should NOT be included as an allocated site. The land is an extensive area of farmed countryside which performs a key role in the Meriden Gap. Development of Barratt's Farm would reduce the separation between Balsall Common and the edge of the Coventry built-up area, which is Burton Green, from 2 km to just over 1km. The remaining open land is degraded to an extent by the National Grid switching station, and the row of houses on Waste Lane, whilst nominally within Green Belt, bridges a significant proportion of the Green Gap not occupied by the National Grid site. HS2 if built will then effectively remove the remaining open landscape between Balsall Common and Burton Green.

It is likely that Barratt's Farm on average performs better than site RP51. This is a large tract of land having a Green Belt score of 7.

Draft Concept Plan:
Detailed comments on the Concept Plan for Site 1 have been submitted by local people and Parish Councils. We support the general points that they are making

Full text:

Question 4:
Do you believe that Site 1 Barratt's Farm should be included as an allocated site, if not why not? Do you have any comments on the draft concept masterplan for the site?

Barratt's Farm should NOT be included as an allocated site. The land is an extensive area of farmed countryside which performs a key role in the Meriden Gap. Development of Barratt's Farm would reduce the separation between Balsall Common and the edge of the Coventry built-up area, which is Burton Green, from 2 km to just over 1km. The remaining open land is degraded to an extent by the National Grid switching station, and the row of houses on Waste Lane, whilst nominally within Green Belt, bridges a significant proportion of the Green Gap not occupied by the National Grid site. HS2 if built will then effectively remove the remaining open landscape between Balsall Common and Burton Green.

It is likely that Barratt's Farm on average performs better than site RP51. This is a large tract of land having a Green Belt score of 7.

Draft Concept Plan:
Detailed comments on the Concept Plan for Site 1 have been submitted by local people and Parish Councils. We support the general points that they are making.

Object

Draft Local Plan - Supplementary Consultation

Question 6 - Site 3 - Windmill Lane

Representation ID: 9155

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

No. We wish to object to the Council's proposal to allocate Site 3, in Balsall Common, as part of the Local Plan. Although there are many reasons why the site is unsustainable, we are particularly concerned about the ecological impact the development of this site would have. The Green Infrastructure map Habitat Distinctiveness 2016 shows that this is an area of High Habitat distinctiveness, where development should be avoided (see p4 of the Ecological Assessment). However, these have not been fully respected when cross referenced to p23 of the master plans, particularly with regards to the 30m buffer around woodland.

Although there is no doubt as to the high impact the site would have on biodiversity (Draft Concept Plans, p24), Solihull Council's proposed solution would appear to be focussed around offsetting rather than preserving these precious habitats. There are other smaller sites that have a higher sustainability scoring and a lesser ecological value than Site 3.

Full text:

6. Do you believe that Site 3 Windmill Lane, Balsall Common, should be included as allocated site, if not why not? Do you have any comments on the draft concept masterplan for the site?

No. We wish to object to the Council's proposal to allocate Site 3, in Balsall Common, as part of the Local Plan. Although there are many reasons why the site is unsustainable, we are particularly concerned about the ecological impact the development of this site would have. The Green Infrastructure map Habitat Distinctiveness 2016 shows that this is an area of High Habitat distinctiveness, where development should be avoided (see p4 of the Ecological Assessment). However, these have not been fully respected when cross referenced to p23 of the master plans, particularly with regards to the 30m buffer around woodland.

Although there is no doubt as to the high impact the site would have on biodiversity (Draft Concept Plans, p24), Solihull Council's proposed solution would appear to be focussed around offsetting rather than preserving these precious habitats. There are other smaller sites that have a higher sustainability scoring and a lesser ecological value than Site 3.

Object

Draft Local Plan - Supplementary Consultation

Question 10 - Green Belt Changes

Representation ID: 9156

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

We oppose removal of 'washed over' designation because it is useful in restricting the scale and density of redevelopment in Green Belt areas surrounding large towns and cities. near large populations. . In low-density settlement areas, or dispersed settlement, the 'washed-over' designation ensure that Green Belt policy is maintained. This provides for limited infilling in a developed frontage, where new houses are permitted of a size and height of the existing development. But elsewhere new houses should not be significantly larger than those they replace.

In the area east of Balsall Common, removal of Green Belt status proposed for land south of Old Waste Lane and Waste Lane will remove the current level of control over development. This would result in unstructured, random development as individual sites are promoted for development.

The majority of the land in this parcel is broad area 4 and is scored at 12 in the Atkins Strategic Green Belt Area Assessment (2016). Only a very small area RP56 is found to make a limited contribution to the Green Belt. Therefore proposing to remove this land from the Green Belt goes against the AGBR that broad area 4 which states " The area covers a large part of Birmingham and Solihull to the West and Coventry to the East......The area performs highly against all 4 purposes and makes an equal contribution to the preservation of the Meriden Strategic Gap and the setting and character of the Berkswell Conservation Area".

Full text:

Other Green Belt Changes

10. Do you have any comments to make on potential changes to the Green Belt boundary east of the settlement (Balsall Common) that would result in the removal of the 'washed over' Green Belt from those areas not covered by a formal allocation?

We oppose removal of 'washed over' designation because it is useful in restricting the scale and density of redevelopment in Green Belt areas surrounding large towns and cities. near large populations. . In low-density settlement areas, or dispersed settlement, the 'washed-over' designation ensure that Green Belt policy is maintained. This provides for limited infilling in a developed frontage, where new houses are permitted of a size and height of the existing development. But elsewhere new houses should not be significantly larger than those they replace.

In the area east of Balsall Common, removal of Green Belt status proposed for land south of Old Waste Lane and Waste Lane will remove the current level of control over development. This would result in unstructured, random development as individual sites are promoted for development.

The majority of the land in this parcel is broad area 4 and is scored at 12 in the Atkins Strategic Green Belt Area Assessment (2016). Only a very small area RP56 is found to make a limited contribution to the Green Belt. Therefore proposing to remove this land from the Green Belt goes against the AGBR that broad area 4 which states " The area covers a large part of Birmingham and Solihull to the West and Coventry to the East......The area performs highly against all 4 purposes and makes an equal contribution to the preservation of the Meriden Strategic Gap and the setting and character of the Berkswell Conservation Area".

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Question 11 - Infrastructure Requirements at Blythe

Representation ID: 9383

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

Disagree that new development at Dickens Heath will "add to the vibrancy and vitality of the settlement, whilst retaining the intrinsic character of distinctive villages separated by open countryside."
Do not agree with statement regarding public transport use. There is high car ownership in the area and there will be low uptake of public transport
Car Park at Whitlocks End station is full at 8am and expansion would not assist much. There are no employment opportunities and none proposed which will increase commuting.
Walking and cycling will be reduced as cannot access Birchy Close.
Highways improvements will not be feasible on 20mph roads.
More off-street parking in Dickens Heath will be difficult to achieve.
Lack of firm proposals to replace sports pitches.
Agree with provision of country park.

Full text:

see attached letter of response

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Question 23 - Site 8 - Hampton Road

Representation ID: 9384

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

Site 8 should not be allocated in the Local Plan Review.
Proposals to surround Knowle village with extensive housing to its north (Site 8) and south (Site 9) would undermine the Conservation Area's character and setting because Knowle would become a town in terms of population size and urban extent.
Impact on Knowle Conservation Area, most important in the Borough and other heritage assets. Would have the effect of developing open land to the north of the historic village and removing the countryside setting that remains to that side of Knowle. Turning settlement from village to more like a town.
Loss of Green Belt

Full text:

see attached letter of response

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Question 24 - Site 9 - Land South of Knowle

Representation ID: 9385

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

Site 9 should not be allocated in the Local Plan Review.
Proposals to surround Knowle village with extensive housing to its north (Site 8) and south (Site 9) would undermine the Conservation Area's character and setting because Knowle would become a town in terms of population size and urban extent.
Impact on Knowle Conservation Area, most important in the Borough and other heritage assets. Would have the effect of developing open land to the north of the historic village and removing the countryside setting that remains to that side of Knowle. Turning settlement from village to more like a town.
Loss of Green Belt

Full text:

see attached letter of response

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Question 12 - Site 4 - Land West of Dickens Heath

Representation ID: 9386

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

Site 4 should be reduced to the land between Tithe Barn Lane and the Stratford Canal west of the Whitchurch Lane area of Dickens Heath (c.100 dwellings). The rest of Site 4 should be omitted from the Local Plan.
Objection based on:
Residents objections in Dickens Heath PC survey
Disproportionate housing allocation in Blythe ward
Impact on Green Belt
Conflict with urban form of Dickens Heath new village
Unsustainable location (low accessibility to services)
Increased traffic will worsen peak-hour congestion
Limited scale of replacement of sports pitches
Impact on Local Wildlife Sites
Impact on historic landscape and important hedgerows

Allocation chosen due to is its location close to Whitlocks End railway station. The allocation does not accord, or can be made to accord with the spatial strategy and sequential approach adopted in the Local Plan Review. Analysis of the sustainability and constraints of this Site are flawed and inaccurate. not consistent with the paragraph on how settlements have green belt separating them, because this proposal will reduce the gap to one field only which is not green belt. Other sites in the Borough with a lower Green Belt scoring are more suitable for development.
results of Dickens Heath residents survey found (over 90%) that the residents of Dickens Heath are strongly opposed to the proposed allocation of Site 4. Excessive housing proposed compared with elsewhere in the Borough, so does not contribute to geographical distribution. This is an excessive burden placed on such a small area without the ability to improve the road network accordingly. Allocation does not accord with government policy on green belt. The Council has not fully examined the infrastructure requirements that would justify and mitigate altering the Green Belt in this location. There would be an adverse impact on the function of the Green Belt, as there would be coalescence between Dickens Heath, Whitlock End and Majors Green. Development of Site 4, not within recognised walking distance (800m) of the Village Centre and outside the strong natural boundaries of the Village would be contrary to the original objectives of the settlement. Former farmsteads will be affected by the proposal. Dickens Heath should therefore be identified in the Local Plan as having a particular character and design and that there should be limits to its continued growth in terms of numbers and direction; the Village should be protected and conserved as a "new village," together with its character and setting in the countryside. Original concept of village was based on accessibility to reduce use of private car this proposal is not sustainable and is not accessible. Cost of developing land may be unsustainable. Flood risk has not been properly established. Proposal would not meet the objective of reducing the need to travel. Site 4 would depend on the use of narrow rural roads which still currently retain the character of countryside, major road improvements would be necessary. This will require the removal of established and important hedgerows and mature trees which greatly add to and enhance the character and setting of the Village on its western side. Road network was not intended for more traffic. development would conflict with ecological objectives. This Site 4 is within a landscape character area of high sensitivity to development.

Full text:

see attached letter of response

Attachments:

Object

Draft Local Plan - Supplementary Consultation

Local Housing Need

Representation ID: 10502

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

Representation Summary:

SM is not suitable basis for assessing housing need in Solihull, as it is based on assumption that there is no constraint to meeting full requirement.
NPPF is clear that Green Belt is a reason to restrict development in the plan area (FN5 to Para. 11). Most of undeveloped land in Solihull is Green Belt.
Meriden Gap performs important function in separating cities of Birmingham and Coventry, and has been protected in successive local plans and regional strategies.
Furthermore, there is a lot of commuting in and out of the Borough which makes it difficult to assess local housing need.
Alternative method would be a capacity-led local plan strategy.
No justification for 2000 contribution to HMA shortfall.
No formal agreement on HMA contribution.
Proposed housing growth far exceeds household projections. Borough has not achieved that level of growth in the past.
Capacity in the Plan to meet need up to 2031 without releasing further Green Belt if meet household projections only.
Plan should allocate more small sites of 1-5ha rather than focusing on fewer, larger sites.

Full text:

see attached letter of response

Attachments:

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