Solihull Local Plan (Draft Submission) 2020

A robust reassessment of the housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within the Housing Market Area over the plan period.

See attached document. Land at Knowle

The allocation should be extended to include Land at east of Warwick Road and north of Wyndley Garden Centre (site 552 in the Site Assessment October 2020).

See attached document. Land at Knowle

The allocation should be extended to include Land at east of Warwick Road and north of Wyndley Garden Centre (site 552 in the Site Assessment October 2020).

See attached document. Land at Knowle

In order to make this policy sound, the allocation should be extended to include Land at Meeting House Lane (part of site 102 in the Site Assessment October 2020).

Policy BC1 Barratt’s Farm, Balsall Common
This policy is not considered to be sound for the following reasons.
It is noted that the proposed allocation at Barratt’s Farm, Balsall Common has been reduced from 900 dwellings at the Draft Local Plan Supplementary Consultation to 875 dwellings (albeit a further 300 could come forward followingthe completion of HS2), and yet still does not look to include the Spitfire site which borders the southern boundary of the proposed allocation. As has been set out previously Spitfire do not object to the principle of an allocation in this location, however questions have been raised over the number of dwellings that can actually be accommodated on the site having regard to the site constraints including designated heritage assets, ecology and potential areas of floor risk. There also appears to be a significant number of landowners which raises further questions over the deliverability of the scheme. This matter is raised at paragraph 541 of the Draft Submission Plan.
As is set out in paragraph 536 of the Draft Submission Plan, Balsall Common is identified for significant housing growth and as part of this significant infrastructure improvements are also proposed for the settlement. these are detailed in paragraphs 527-535 of the Draft Submission Plan and include a relief road, enhanced centre, station parking, improved public transport, new primary school, and improvements to the existing secondary school. As such the settlement is going to change significantly over the plan period and is able to take additional growth over and above that already proposed in the Local Plan.
Land at Meeting House Lane (part of site 102 in the Site Assessment October 2020) has previously been put forward as being suitable for development. This site provides a very logical rounding off of the proposed Barretts Farm development utilising an existing agricultural field bounded by roads to the east and south together with residential development to the west. The Site Assessment carried out by the Council suggests that this site could be considered as part of a larger site subject to constraints. This site is not affected by other known constraints, for example, listed buildings. With the questions being raised as to the deliverability of the Barratt’s Farm site, it would be sensible to include this additional land to ensure that the housing numbers being proposed within this allocation can actually be met. Equally with the sites removal from the Green Belt, there is nothing to prevent this site coming forward for development in the short term.
This site is available immediately and is being actively promoted by Spitfire Homes. There are no known constraints which would prevent delivery. The site is adjacent to existing development and the proposed allocation at Barratts Farm. Development of this site would represent a logical rounding off of the Barratts Farm allocation. As there are questions over the land holdings at Barratt’s Farm, this site can easily be delivered within the next five years providing much needed housing in Balsall Common in the short term.

Modifications required to make the plan sound
In order to make this policy sound, the allocation should be extended to include Land at Meeting House Lane (part of site 102 in the Site Assessment October 2020).

In order to make this policy sound and legally compliant the Land between Old Waste Lane and Waste Lane, Balsall
Common should not be designated as Local Green Space

Policy P20 Provision for Open Space, Childrens Play, Sport, Recreation and Leisure
This policy is not considered to be legally compliant or sound for the following reasons.
It is acknowledged and appreciated that a general requirement of the Local Plan will be a policy relating to open
space. My client does not have any significant concerns with the majority of the policy, apart from part 6 which
states:
6. In this plan the following sites (as shown on the policies plan) are designated as Local Green Spaces:
I. Land between Old Waste lane and Waste Lane, Balsall Common
II. Land south of Shirley
The supporting text to this draft policy states at paragraph 474 that “The importance of these sites has been
highlighted through their proximity to sites being allocated for development, or previously considered for such. This
list will be kept open and there is opportunity for future plan reviews to include other sites (including those areas of
open space being provided within site allocations), or for Neighbourhood Plans to identify such sites. Any proposals
for development of these sites will be judged by the Green Belt policies of the NPPF and Policy P20 of this plan in
accordance with paragraph 101 of the NPPF”.
The site my client is interested in is Land between Old Waste Lane and Waste Lane, Balsall Common.
As you will be aware, paragraph 100 of the NPPF states that “The Local Green Space designation should only be
used where the green space is:
a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of
its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its
wildlife; and
c) local in character and is not an extensive tract of land.”
There is little justification for the designation of these Local Green Spaces, other than that set out in paragraph 474
of the Draft Submission Plan and paragraph 91 of the Open Space Topic Paper which simply states two sites are
designated as Local Green Space. In light of this, further clarification has been sought from the Council and a
response from the Planning Policy Team Leader (dated 27th November) stated the following in relation to land at Old
Waste Lane this site “is in the proximity of proposed Site BC1, Barretts Farm. The openness of the land contributes
to the rural, tranquil character at this entrance to Balsall Common, which is of benefit in ensuring an attractive
gateway to the settlement as well as being of benefit as a recreational green space to existing surrounding residents
and future residents. It is proposed in the Plan that the land will be removed from the Green Belt as a consequence
of the proposed housing allocation at Site BC1 Barrett’s Farm & BC4 Pheasant Oak Farm. Designation will ensure
continuation of protection for this green area, if and when the Green Belt boundary is amended.”
In light of this, the justification provided by the Council must be considered against the requirements for designation
set out in paragraph 100 of the NPPF:
a) in reasonably close proximity to the community it serves;
It is not entirely clear what community, this designation serves, presently the site is surrounded by existing fields
with a handful of properties located along the norther boundary. The land is detached and some distance from the
main settlement of Balsall Common. There has been no indication in the supporting documentation from the Council
as to what community this land is seen to serve. The proposal therefore fails to meet criteria 1 of the requirements
for Local Green Space Designation.
b) demonstrably special to a local community and holds a particular local significance, for example because of
its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its
wildlife; and
The Council within the draft submission plan and in their further email response provide no further justification or
reasoning as to why it meets any of the above criteria. They appear to suggest that the land is important as the
gateway to Balsall Common, and as recreational value. The site is in private ownership and whilst there is a public
footpath which runs through the site (which would be retained as part of any future development of the site), it
provides no further recreational value. The proposal therefore fails to meet criteria 2 of the requirements for Local
Green Space Designation.
c) local in character and is not an extensive tract of land.
It is agreed that the site is not an extensive tract of land, however no justification has been provided as to why the
land is local in character. The proposal therefore fails to meet criteria 3 of the requirements for Local Green Space Designation.
It is clear from the supporting text in the draft submission plan and the Councils response that this land is being
designated as Local Green Space simply because it is proposed to be removed from the Green Belt and it is close
to sites being allocated for development. The Council is well aware that this site has been promoted for development
and that should it be removed from the Green Belt; it is likely to come forward subject to compliance with all other
planning policies. Whilst it is acknowledged that the site is not an extensive tract of land, the NPPG is clear that
“blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation
should not be proposed as a ‘back door’ way to try to achieve what would amount to a new area of Green Belt by
another name.” (ID ref: 37-015-20140306). This designation is clearly a way to prevent development on the site.
Furthermore, it must be noted that the site is located in Berkswell Parish and was not allocated as Local Green
Space as part of their Neighbourhood Plan. The Parish would have been aware of the forthcoming allocations in the
Draft Submission Plan and the removal of the Old Waste Lane site from the Green Belt yet felt no need to allocate this land as Local Green Space. The PPG is clear that Local Green Space can be allocated on Green Belt land if there
is considered to be any additional local benefit to its designation as Local Green Space (ref ID: 37-010-20140306).
There is clearly no local significance of this land to the local community.
Finally it must be acknowledged that the PPG is clear that the Local Planning Authority should make contact with
landowners at an early stage about proposals to designate any part of their land as Local Green Space (ref ID: 37-
019-20140306). To date, and despite this site being actively promoted through the Local Plan process the Council
have failed to notify the promotor or landowner of the proposed designation.

Modifications required to make the plan legally compliant and sound
In order to make this policy sound and legally compliant the Land between Old Waste Lane and Waste Lane, Balsall
Common should not be designated as Local Green Space for the reasons set out in detail above.

This policy is not considered to be sound for the following reasons.
It is noted that the proposed allocation at Barratt’s Farm, Balsall Common has been reduced from 900 dwellings at
the Draft Local Plan Supplementary Consultation to 875 dwellings (albeit a further 300 could come forward following
the completion of HS2), and yet still does not look to include land at Old Waste Lane (site 101 in the Site Assessment
October 2020) which borders the southern boundaries of the proposed allocation. As has been set out previously
Spitfire do not object to the principle of an allocation in this location, however questions have been raised over the
number of dwellings that can actually be accommodated on the site having regard to the site constraints including
designated heritage assets, ecology and potential areas of floor risk. There also appears to be a significant number
of landowners which raises further questions over the deliverability of the scheme. This matter is raised at paragraph
541 of the Draft Submission Plan.
Since the time of the original representations, further work has been undertaken to produce a Vision Document and
Environmental Appraisal relating to the site identified as Land at Old Waste Lane/ Waste Lane (site 101 in the Site
Assessment October 2020)
As is set out in paragraph 536 of the Draft Submission Plan, Balsall Common is identified for significant housing
growth and as part of this significant infrastructure improvements are also proposed for the settlement. these are
detailed in paragraphs 527-535 of the Draft Submission Plan and include a relief road, enhanced centre, station
parking, improved public transport, new primary school, and improvements to the existing secondary school. As
such the settlement is going to change significantly over the plan period and is able to take additional growth over
and above that already proposed in the Local Plan.
It is acknowledged that Land at Old Waste Lane/ Waste Lane (Site 101) is proposed to be designated as Local Green
Space. As has been set out in detail above within this representation, this designation does not accord with the
requirements for Local Green Space and should therefore the site should be considered as a logical extension/
rounding off of the Barratt’s Farm proposal. As part of this submission, an Environmental Appraisal has been
prepared by EDP and accompanies this submission. As is proposed within the Draft Submission Plan, the site is to
be removed from the Green Belt. The assessment carried out by EDP agrees with this conclusion with their review
concluding that the site as it currently stands makes a limited assessment to the Green Belt. Given this is a relatively
small parcel of land, its removal from the Green Belt would not have an impact on the purposes of the Green Belt.
Furthermore, the conclusions reached by EDP are that the site can be development in accordance with sound master
planning principles without harm to the integrity of the Green Belt overall.
Accompanying this submission is a vision document which demonstrates how development can be accommodated
on the site having regard to the identified site constraints. The vision document identifies the site as strategic infill,
which forms part of the wider strategic proposals for Balsall Common. In addition, the proposal looks to prove
sustainable connections. The masterplan presents an opportunity for an improved footpath link through the site
which forms part of the Millennium Way and provides wider connections to the centre of Baslall Common. The site
as it currently stands is bounded by mature hedgerows and trees. The masterplan allows the scheme to integrate
within its existing landscape setting. Equally the proposals allow for ecological enhancements, and the opportunity
to provide an area of play for residents.
Land at Old Waste Lane is available immediately and is being actively promoted by Spitfire Homes. There are no
known constraints for which would prevent delivery. The site is adjacent to existing development and the proposed
allocation at Barratts Farm. Development of this site already surrounded by existing residential dwellings would
represent a logical rounding off of the Barratts Farm allocation. As there are questions over the land holdings at
Barratt’s Farm, this site can easily be delivered within the next five years providing much needed housing in Balsall
Common in the short term.

Modifications required to make the plan sound
In order to make this policy sound, the allocation should be extended to include sites identified as Land at Old Waste
Lane/ Waste Lane (site 101 in the Site Assessment October 2020).

In order to make this policy sound, the allocation should be extended to include sites identified as Land at Old Waste
Lane/ Waste Lane (site 101 in the Site Assessment October 2020).

Policy P20 Provision for Open Space, Childrens Play, Sport, Recreation and Leisure
This policy is not considered to be legally compliant or sound for the following reasons.
It is acknowledged and appreciated that a general requirement of the Local Plan will be a policy relating to open
space. My client does not have any significant concerns with the majority of the policy, apart from part 6 which
states:
6. In this plan the following sites (as shown on the policies plan) are designated as Local Green Spaces:
I. Land between Old Waste lane and Waste Lane, Balsall Common
II. Land south of Shirley
The supporting text to this draft policy states at paragraph 474 that “The importance of these sites has been
highlighted through their proximity to sites being allocated for development, or previously considered for such. This
list will be kept open and there is opportunity for future plan reviews to include other sites (including those areas of
open space being provided within site allocations), or for Neighbourhood Plans to identify such sites. Any proposals
for development of these sites will be judged by the Green Belt policies of the NPPF and Policy P20 of this plan in
accordance with paragraph 101 of the NPPF”.
The site my client is interested in is Land between Old Waste Lane and Waste Lane, Balsall Common.
As you will be aware, paragraph 100 of the NPPF states that “The Local Green Space designation should only be
used where the green space is:
a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of
its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its
wildlife; and
c) local in character and is not an extensive tract of land.”
There is little justification for the designation of these Local Green Spaces, other than that set out in paragraph 474
of the Draft Submission Plan and paragraph 91 of the Open Space Topic Paper which simply states two sites are
designated as Local Green Space. In light of this, further clarification has been sought from the Council and a
response from the Planning Policy Team Leader (dated 27th November) stated the following in relation to land at Old
Waste Lane this site “is in the proximity of proposed Site BC1, Barretts Farm. The openness of the land contributes
to the rural, tranquil character at this entrance to Balsall Common, which is of benefit in ensuring an attractive
gateway to the settlement as well as being of benefit as a recreational green space to existing surrounding residents
and future residents. It is proposed in the Plan that the land will be removed from the Green Belt as a consequence
of the proposed housing allocation at Site BC1 Barrett’s Farm & BC4 Pheasant Oak Farm. Designation will ensure
continuation of protection for this green area, if and when the Green Belt boundary is amended.”
In light of this, the justification provided by the Council must be considered against the requirements for designation
set out in paragraph 100 of the NPPF:
a) in reasonably close proximity to the community it serves;
It is not entirely clear what community, this designation serves, presently the site is surrounded by existing fields
with a handful of properties located along the norther boundary. The land is detached and some distance from the
main settlement of Balsall Common. There has been no indication in the supporting documentation from the Council
as to what community this land is seen to serve. The proposal therefore fails to meet criteria 1 of the requirements
for Local Green Space Designation.
b) demonstrably special to a local community and holds a particular local significance, for example because of
its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its
wildlife; and
The Council within the draft submission plan and in their further email response provide no further justification or
reasoning as to why it meets any of the above criteria. They appear to suggest that the land is important as the
gateway to Balsall Common, and as recreational value. The site is in private ownership and whilst there is a public
footpath which runs through the site (which would be retained as part of any future development of the site), it
provides no further recreational value. The proposal therefore fails to meet criteria 2 of the requirements for Local
Green Space Designation.
c) local in character and is not an extensive tract of land.
It is agreed that the site is not an extensive tract of land, however no justification has been provided as to why the
land is local in character. The proposal therefore fails to meet criteria 3 of the requirements for Local Green Space Designation.
It is clear from the supporting text in the draft submission plan and the Councils response that this land is being
designated as Local Green Space simply because it is proposed to be removed from the Green Belt and it is close
to sites being allocated for development. The Council is well aware that this site has been promoted for development
and that should it be removed from the Green Belt; it is likely to come forward subject to compliance with all other
planning policies. Whilst it is acknowledged that the site is not an extensive tract of land, the NPPG is clear that
“blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation
should not be proposed as a ‘back door’ way to try to achieve what would amount to a new area of Green Belt by
another name.” (ID ref: 37-015-20140306). This designation is clearly a way to prevent development on the site.
Furthermore, it must be noted that the site is located in Berkswell Parish and was not allocated as Local Green
Space as part of their Neighbourhood Plan. The Parish would have been aware of the forthcoming allocations in the
Draft Submission Plan and the removal of the Old Waste Lane site from the Green Belt yet felt no need to allocate this land as Local Green Space. The PPG is clear that Local Green Space can be allocated on Green Belt land if there
is considered to be any additional local benefit to its designation as Local Green Space (ref ID: 37-010-20140306).
There is clearly no local significance of this land to the local community.
Finally it must be acknowledged that the PPG is clear that the Local Planning Authority should make contact with
landowners at an early stage about proposals to designate any part of their land as Local Green Space (ref ID: 37-
019-20140306). To date, and despite this site being actively promoted through the Local Plan process the Council
have failed to notify the promotor or landowner of the proposed designation.

Modifications required to make the plan legally compliant and sound
In order to make this policy sound and legally compliant the Land between Old Waste Lane and Waste Lane, Balsall
Common should not be designated as Local Green Space for the reasons set out in detail above.

This policy is not considered to be sound for the following reasons.
It is noted that the proposed allocation at Barratt’s Farm, Balsall Common has been reduced from 900 dwellings at
the Draft Local Plan Supplementary Consultation to 875 dwellings (albeit a further 300 could come forward following
the completion of HS2), and yet still does not look to include land at Old Waste Lane (site 101 in the Site Assessment
October 2020) which borders the southern boundaries of the proposed allocation. As has been set out previously
Spitfire do not object to the principle of an allocation in this location, however questions have been raised over the
number of dwellings that can actually be accommodated on the site having regard to the site constraints including
designated heritage assets, ecology and potential areas of floor risk. There also appears to be a significant number
of landowners which raises further questions over the deliverability of the scheme. This matter is raised at paragraph
541 of the Draft Submission Plan.
Since the time of the original representations, further work has been undertaken to produce a Vision Document and
Environmental Appraisal relating to the site identified as Land at Old Waste Lane/ Waste Lane (site 101 in the Site
Assessment October 2020)
As is set out in paragraph 536 of the Draft Submission Plan, Balsall Common is identified for significant housing
growth and as part of this significant infrastructure improvements are also proposed for the settlement. these are
detailed in paragraphs 527-535 of the Draft Submission Plan and include a relief road, enhanced centre, station
parking, improved public transport, new primary school, and improvements to the existing secondary school. As
such the settlement is going to change significantly over the plan period and is able to take additional growth over
and above that already proposed in the Local Plan.
It is acknowledged that Land at Old Waste Lane/ Waste Lane (Site 101) is proposed to be designated as Local Green
Space. As has been set out in detail above within this representation, this designation does not accord with the
requirements for Local Green Space and should therefore the site should be considered as a logical extension/
rounding off of the Barratt’s Farm proposal. As part of this submission, an Environmental Appraisal has been
prepared by EDP and accompanies this submission. As is proposed within the Draft Submission Plan, the site is to
be removed from the Green Belt. The assessment carried out by EDP agrees with this conclusion with their review
concluding that the site as it currently stands makes a limited assessment to the Green Belt. Given this is a relatively
small parcel of land, its removal from the Green Belt would not have an impact on the purposes of the Green Belt.
Furthermore, the conclusions reached by EDP are that the site can be development in accordance with sound master
planning principles without harm to the integrity of the Green Belt overall.
Accompanying this submission is a vision document which demonstrates how development can be accommodated
on the site having regard to the identified site constraints. The vision document identifies the site as strategic infill,
which forms part of the wider strategic proposals for Balsall Common. In addition, the proposal looks to prove
sustainable connections. The masterplan presents an opportunity for an improved footpath link through the site
which forms part of the Millennium Way and provides wider connections to the centre of Baslall Common. The site
as it currently stands is bounded by mature hedgerows and trees. The masterplan allows the scheme to integrate
within its existing landscape setting. Equally the proposals allow for ecological enhancements, and the opportunity
to provide an area of play for residents.
Land at Old Waste Lane is available immediately and is being actively promoted by Spitfire Homes. There are no
known constraints for which would prevent delivery. The site is adjacent to existing development and the proposed
allocation at Barratts Farm. Development of this site already surrounded by existing residential dwellings would
represent a logical rounding off of the Barratts Farm allocation. As there are questions over the land holdings at
Barratt’s Farm, this site can easily be delivered within the next five years providing much needed housing in Balsall
Common in the short term.

Modifications required to make the plan sound
In order to make this policy sound, the allocation should be extended to include sites identified as Land at Old Waste
Lane/ Waste Lane (site 101 in the Site Assessment October 2020).

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.

Policy P5 Provision of Land for Housing
This policy is not considered sound or legally compliant for the following reasons
Whilst Spitfire Homes welcomes the increase in housing numbers from the previous Supplementary Consultation
Document, it is not felt that this goes far enough. A separate representation has been prepared by Barton Willmore on behalf of Barratt David Wilson Homes, IM Land, Spitfire Bespoke Homes, Heyford Developments, and Generator Strategic Land on the Borough’s Housing Need. The conclusions of this representation are supported.
In summary, this representation makes the following conclusions. The NPPF is clear at paragraph 59 that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward”. Paragraph 60 further states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing needs assessment, conducted using the standard method in national planning guidance……. In addition to the local housing need figure, any need that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing planned for”.
In the case of SMBC, policy P5 proposes the following:
• The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing
land supply to deliver 15,017 additional homes in the period 2020-2036. The allocations will be part of the
overall housing land supply detailed in the table below.
• The average annual housing land provision target is 938 net additional homes per year (2020-2036). A
trajectory showing how this target will be delivered from all sources of housing land supply is shown below.
It will be subject to annual review through the AMR.
This is based on the minimum identified need of 807dpa and a contribution of 2,015 dwellings across the plan period to help meet the unmet need within the Housing Market Area. This gives a total of 938dpa.
However, as is made clear in the NPPF and within the representations from Barton Willmore and the House Builders Federation (HBF) that this housing need over the plan period has been underestimated. Equally the housing need figure in policy H5 should be expressed as a minimum which is currently is not.
The Borough has significant ambitions over this plan period as identified as Challenge D and Challenge M.
Challenge D looks to secure sustainable and inclusive economic growth including:
• Meeting Solihull’s important regional and sub-regional role
• 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.
• Retaining and developing a high skilled workforce.
• Provide a range of housing to attract inward investment
Challenge M looks to maximise the economic and social benefits of the High Speed 2 Rail Link and UKC Hub Area
including:
• Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and
development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills,
environment and infrastructure.
• To provide an appropriate planning framework so as to ensure that the potential economic and social benefits
of growth enabled by the HS2 rail link and interchange station are delivered.
These ambitions are of course welcomed, but equally they have implications on ensuring appropriate housing is
delivered within the Borough.
The representation prepared by Barton Willmore makes the following conclusions:
• As has been set out above, the policy fails to make it clear that the housing numbers proposed are a
minimum figure.
• The Standard Methods minimum need for Solihull (807dpa) will need to be increased to account from
expected job growth within the Borough.
• Modelling carried out by Barton Willmore shows that between 1,036 and 1,248 dpa. are required to support
the UK Central Hub scenario
• Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being
delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031,
a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases
when the unmet need from the Black Country is considered. Additional unmet need will be created post
2031.
As a result, this raises significant concerns on the housing numbers set out within policy P5. Therefore, settlements such as Balsall Common which have been identified as being able to accommodate housing growth beyond its own needs should have further land allocated within it to meet housing needs.
In this case, further consideration needs to be given to Land at Oakes Farm, Balsall Common. The NPPF is clear at paragraph 68 that “small and medium sized sites can make an important contribution to the meeting the housing requirement of the area and are often built out relatively quickly”.
Spitfire Homes has an option on Land at Oakes Farm, Balsall Common (site 304 in the Site Assessment October 2020). This site could help to meet the additional housing need identified within the representations from Barton Willmore. This site is located to the south west of Balsall Common and would sit comfortably within the built form of the settlement having regard to both existing development and proposed allocations. The chapter on Balsall Common within the Draft Submission Plan sets out at paragraph 521 that “Balsall Common is one of two rural settlements in the Borough that has a full range of facilities including both secondary & primary schools, health services and a range of retail and associated facilities. As such it is well placed to accommodate levels of growth in excess of just its own local needs.”
The Site Assessment document in respect of this site sets out that the “Settlement identified as suitable for
significant expansion, although site would have no defensible green belt boundary”. An accompanying vision
document has been prepared which demonstrates how development could be sensitively located on this site having regard to the site constraints. The site as it currently stands has very clear boundaries with Fernhill Lane marking the western boundary, Oakes Farm shop and hedgerows marking the southern boundary, and hedgerows on the eastern boundary with the B4101 running along the northern boundary of the settlement. Whilst in planning terms the site may be regarded as open countryside, its current and surrounding land use and visual character is such that it does not form part of the more functionally intact agricultural landscape to the south.
The Site Assessment document suggests that it “is within moderately performing parcel in the Green Belt
Assessment and would result in indefensible boundaries to the south and west
An Environmental Appraisal of the site has been undertaken by EDP and in respect of Green Belt when the site is considered on its own merits, it scores significantly lower than suggest in the Council site assessment. A summary of the table is attached.
It is acknowledged that land is proposed to be developed as part of this plan at Frog Lane for 110 dwellings (policy
BC2). As part of the assessment prepared by EDP, they have also assessed the Frog Lane site, and this
demonstrates that the Frog Lane site performs a stronger purpose against three of the tests compared to the Oakes
Farm site. With regard to those performances, it was considered that development of the site is likely to have a
particular effect on the rural character and setting of Frog Lane to the south and east.
The Oakes Farm site is in a highly sustainable location with a bus stop within 400 metres of the site, and the centre of Balsall Common within a 10-15 minute walk, and both a primary and secondary school no more than 1.3km from the site. As is set out within the vision document there is currently an abrupt settlement edge to Balsall Common in this location and development at Oakes Farm would allow this to be softened albeit clearly defined and defensible.
The strategy within the masterplan provides a number of key principles including a significant landscape buffer,
which provides a transition from urban to rural as well as ensuring there is a robust and defensible boundary to the
Green Belt. Within the site, it is proposed to integrate existing public rights of way ensuring good connections to
the centre of Balsall Common village centre. In addition, there are opportunities to provide significant ecological
improvements to the site.
This site is available immediately and is being actively promoted by Spitfire Homes. Apart from the site’s location within the Green Belt, there are no known constraints which would prevent development of the site. This site can easily be delivered within the next five years providing much needed additional housing within the Borough. As has been demonstrated within the accompanying appraisal by EDP, the Oakes Farm site could reasonably be removed from the Green Belt and developed in accordance with the sound masterplanning principles without harm to the integrity of the Green Belt overall.

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the
housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within
the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.

Land at Oakes Farm should be allocated within the plan

Policy P5 Provision of Land for Housing
This policy is not considered sound or legally compliant for the following reasons
Whilst Spitfire Homes welcomes the increase in housing numbers from the previous Supplementary Consultation
Document, it is not felt that this goes far enough. A separate representation has been prepared by Barton Willmore on behalf of Barratt David Wilson Homes, IM Land, Spitfire Bespoke Homes, Heyford Developments, and Generator Strategic Land on the Borough’s Housing Need. The conclusions of this representation are supported.
In summary, this representation makes the following conclusions. The NPPF is clear at paragraph 59 that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward”. Paragraph 60 further states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing needs assessment, conducted using the standard method in national planning guidance……. In addition to the local housing need figure, any need that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing planned for”.
In the case of SMBC, policy P5 proposes the following:
• The Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing
land supply to deliver 15,017 additional homes in the period 2020-2036. The allocations will be part of the
overall housing land supply detailed in the table below.
• The average annual housing land provision target is 938 net additional homes per year (2020-2036). A
trajectory showing how this target will be delivered from all sources of housing land supply is shown below.
It will be subject to annual review through the AMR.
This is based on the minimum identified need of 807dpa and a contribution of 2,015 dwellings across the plan period to help meet the unmet need within the Housing Market Area. This gives a total of 938dpa.
However, as is made clear in the NPPF and within the representations from Barton Willmore and the House Builders Federation (HBF) that this housing need over the plan period has been underestimated. Equally the housing need figure in policy H5 should be expressed as a minimum which is currently is not.
The Borough has significant ambitions over this plan period as identified as Challenge D and Challenge M.
Challenge D looks to secure sustainable and inclusive economic growth including:
• Meeting Solihull’s important regional and sub-regional role
• 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.
• Retaining and developing a high skilled workforce.
• Provide a range of housing to attract inward investment
Challenge M looks to maximise the economic and social benefits of the High Speed 2 Rail Link and UKC Hub Area
including:
• Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and
development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills,
environment and infrastructure.
• To provide an appropriate planning framework so as to ensure that the potential economic and social benefits
of growth enabled by the HS2 rail link and interchange station are delivered.
These ambitions are of course welcomed, but equally they have implications on ensuring appropriate housing is
delivered within the Borough.
The representation prepared by Barton Willmore makes the following conclusions:
• As has been set out above, the policy fails to make it clear that the housing numbers proposed are a
minimum figure.
• The Standard Methods minimum need for Solihull (807dpa) will need to be increased to account from
expected job growth within the Borough.
• Modelling carried out by Barton Willmore shows that between 1,036 and 1,248 dpa. are required to support
the UK Central Hub scenario
• Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being
delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031,
a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases
when the unmet need from the Black Country is considered. Additional unmet need will be created post
2031.
As a result, this raises significant concerns on the housing numbers set out within policy P5. Therefore, settlements such as Balsall Common which have been identified as being able to accommodate housing growth beyond its own needs should have further land allocated within it to meet housing needs.
In this case, further consideration needs to be given to Land at Oakes Farm, Balsall Common. The NPPF is clear at paragraph 68 that “small and medium sized sites can make an important contribution to the meeting the housing requirement of the area and are often built out relatively quickly”.
Spitfire Homes has an option on Land at Oakes Farm, Balsall Common (site 304 in the Site Assessment October 2020). This site could help to meet the additional housing need identified within the representations from Barton Willmore. This site is located to the south west of Balsall Common and would sit comfortably within the built form of the settlement having regard to both existing development and proposed allocations. The chapter on Balsall Common within the Draft Submission Plan sets out at paragraph 521 that “Balsall Common is one of two rural settlements in the Borough that has a full range of facilities including both secondary & primary schools, health services and a range of retail and associated facilities. As such it is well placed to accommodate levels of growth in excess of just its own local needs.”
The Site Assessment document in respect of this site sets out that the “Settlement identified as suitable for
significant expansion, although site would have no defensible green belt boundary”. An accompanying vision
document has been prepared which demonstrates how development could be sensitively located on this site having regard to the site constraints. The site as it currently stands has very clear boundaries with Fernhill Lane marking the western boundary, Oakes Farm shop and hedgerows marking the southern boundary, and hedgerows on the eastern boundary with the B4101 running along the northern boundary of the settlement. Whilst in planning terms the site may be regarded as open countryside, its current and surrounding land use and visual character is such that it does not form part of the more functionally intact agricultural landscape to the south.
The Site Assessment document suggests that it “is within moderately performing parcel in the Green Belt
Assessment and would result in indefensible boundaries to the south and west
An Environmental Appraisal of the site has been undertaken by EDP and in respect of Green Belt when the site is considered on its own merits, it scores significantly lower than suggest in the Council site assessment. A summary of the table is attached.
It is acknowledged that land is proposed to be developed as part of this plan at Frog Lane for 110 dwellings (policy
BC2). As part of the assessment prepared by EDP, they have also assessed the Frog Lane site, and this
demonstrates that the Frog Lane site performs a stronger purpose against three of the tests compared to the Oakes
Farm site. With regard to those performances, it was considered that development of the site is likely to have a
particular effect on the rural character and setting of Frog Lane to the south and east.
The Oakes Farm site is in a highly sustainable location with a bus stop within 400 metres of the site, and the centre of Balsall Common within a 10-15 minute walk, and both a primary and secondary school no more than 1.3km from the site. As is set out within the vision document there is currently an abrupt settlement edge to Balsall Common in this location and development at Oakes Farm would allow this to be softened albeit clearly defined and defensible.
The strategy within the masterplan provides a number of key principles including a significant landscape buffer,
which provides a transition from urban to rural as well as ensuring there is a robust and defensible boundary to the
Green Belt. Within the site, it is proposed to integrate existing public rights of way ensuring good connections to
the centre of Balsall Common village centre. In addition, there are opportunities to provide significant ecological
improvements to the site.
This site is available immediately and is being actively promoted by Spitfire Homes. Apart from the site’s location within the Green Belt, there are no known constraints which would prevent development of the site. This site can easily be delivered within the next five years providing much needed additional housing within the Borough. As has been demonstrated within the accompanying appraisal by EDP, the Oakes Farm site could reasonably be removed from the Green Belt and developed in accordance with the sound masterplanning principles without harm to the integrity of the Green Belt overall.

Modifications required to make the plan sound
In order to make this policy sound and legally requirement a robust reassessment of the housing numbers of the
housing numbers are required to ensure that the Borough can meet its own needs and those unmet needs within
the Housing Market Area over the plan period.
Consideration also needs to be given to the inclusion of Land at Oakes Farm as an allocation within the plan.