Other

ID sylw: 106815

Derbyniwyd: 06/03/2025

Ymatebydd: Solihull MBC

Reasons to Oppose Hockley Heath Group (SG24) as a Strategic Growth Location in the South Warwickshire Local Plan.

1. Surface Water Drainage Issues
Current drainage problems in Hockley Heath highlight the unsuitability of large-scale development without substantial infrastructure improvements.

2. Lack of Secondary School Provision
Hockley Heath lacks a secondary school, and neighbouring schools are already at capacity, making it unsustainable to meet the educational needs of an additional 2,000 households.

3. Poor Public Transport Links
Hockley Heath is not close to a train station and has limited public transport, increasing reliance on cars and contravening the aim to promote sustainable travel.

4. Character of the Village
A large-scale development would fundamentally alter the character of Hockley Heath, a small village, undermining its distinctiveness and rural identity.

5. Maintaining a Green Buffer
Keeping a green buffer between Dorridge and Hockley Heath prevents urban sprawl and protects the individual identities of these settlements.

6. Contradiction with SMBC's Local Plan
Solihull Metropolitan Borough Council (SMBC) determined that only small-scale development is appropriate for Hockley Heath. Overriding this decision undermines local planning authority evidence and contradicts NPPF Paragraph 15, which encourages plans to be shaped by local needs.

7. Traffic Congestion and Road Safety
A development of this size will significantly increase traffic on the A3400 and surrounding roads, worsening congestion and raising safety concerns in a village already experiencing issues with speeding and heavy vehicles.

8. Biodiversity and Environmental Impact
The proposed site risks harming wildlife habitats in and around the village, failing to meet this requirement.

Other

ID sylw: 107241

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Solihull welcomes the opportunity to respond to this stage of the Local Plan which sets out the Preferred Options for achieving sustainable growth in South Warwickshire until 2050. This response builds on the comments provided to earlier consultations and focuses on the delivery of housing and economic growth together with our comments on the identification of sites at Hockley Heath (SG24) as a strategic growth location. These comments are also made in light of recent national policy changes set out in the revised NPPF (December 2024).
SMBC has engaged in ongoing dialogue with Warwick and Stratford District Councils and will continue to engage in discussions to ensure duty to cooperate obligations are met as part of the plan making process. The cross-boundary delivery of housing and employment across the housing market area together with the provision of necessary infrastructure is a key element of these duty to cooperate discussions.

Other

ID sylw: 107242

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Meeting Housing Need
The housing need figure for South Warwickshire over the plan period is set out in Draft Policy Direction 1 and is presented as a range reflecting the findings of the Coventry and Warwickshire HEDNA as a minimum and the standard methodology as the top of the range. It proposes the delivery of at least 1,679 dwellings per annum across the area with flexibility to provide up to 2,188 per annum. This equates to 41,975 between 2025 and 2050 with flexibility to provide up to 54,700 dwellings.
A revised National Planning Policy Framework (NPPF) was published on the12th December 2024. This sets out the approach for determining local housing need which expects local authorities to follow the standard methodology for assessing local housing need. It identifies that the minimum annual housing need figure should be based on this approach (Paragraph 62). National Planning guidance sets out that where ‘Local housing need assessments may cover more than one area in particular where strategic policies are being produced jointly. In such cases the housing need for the defined area should at least be the sum of the local housing need for each local planning authority within the area (para 013 Housing and Economic Needs Assessment guidance).
Paragraph 69 of the NPPF sets out that strategic policy making authorities should establish a housing requirement figure for their whole area which shows the extent to which their identified housing need (and any needs which cannot be met within neighbouring areas) can be met over the plan period.
The plan sets out a sustainable spatial strategy for meeting the areas growth needs over the plan period with flexibility to meet the upper end of the identified housing need as evidenced through the standard methodology. This focuses development in priority areas 1 to 3 identifying potential new settlements and 24 potential strategic growth locations. It is clear from the range of potential locations for growth identified in the plan that there is capacity and sufficient flexibility to meet the overall higher need based on the standard methodology as set out in the NPPF. SMBC would support in principle a strategy which seeks to meet the identified housing need within the Local Plan boundary and does not seek to redistribute growth outside of the Local Plan area. Given the capacity to plan for the higher housing need figure it is unclear why the housing need is presented as a range and the higher figure derived from the standard methodology is not identified as the minimum housing need. This would reflect the latest government position for delivering national objectives for housing growth and would ensure the housing needs for South Warwickshire are met.
SMBC welcomes the commitment within the Preferred Options Plan to address the issue of unmet cross boundary housing needs. It is acknowledged within the Plan that there is a shortfall relating to the Greater Birmingham and Black Country HMA but the level beyond 2031 has yet to be established. It is considered that a study refresh is needed to take account of updated evidence and latest guidance. On this basis it is proposed that the Regulation 19 version of the plan will consider unmet housing need reviewing latest evidence and duty to cooperate discussions. SMBC would reiterate the importance of engaging in duty to cooperate discussions to ensure wider housing needs are met. The South Warwickshire Plan may need to address needs arising from both housing market areas. It is acknowledged that further evidence will be necessary to consider the wider housing market area through an update of the West Midlands Strategic Growth study which is currently underway.

Other

ID sylw: 107243

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Meeting Employment Need
SMBC welcomes the inclusion within the Preferred Options plan of land to meet strategic employment needs as identified in the West Midlands Strategic Employment Sites Strategy. SMBC participated in this joint study and acknowledges the outcome. It is noted that the plan includes provision for the upper limit of the requirement identified in the WMSESS (between 75 to 125ha) for the M40 / A46 corridor in South Warwickshire to reflect that the WMSESS only forecasts up until 2045. The figure derived from the WMSESS relates to the whole study area rather than individual authority areas. Two sites capable of meeting the qualitative and quantitative strategic need have been identified. SMBC expect the delivery of strategic employment sites and the relationship to labour patterns and wider housing need within the housing market area to continue to form part of duty to cooperate discussions. Further consideration of these matters following the outcome of this consultation and as part of part 2 of the West Midlands Strategic Growth Study will be needed.
It should also be acknowledged that the provision of strategic employment land, whilst primarily to provide sites of a size and nature to attract large scale regional or national operators will also meet local needs.
The plan also identifies a Core Opportunity Area based on the road opportunity area (ROA 8) and rail opportunity area (ROA 4) identified within the WMSESS and the South Warwickshire Employment Land study 2024. The Core Opportunity area will be the focus for new employment within South Warwickshire. It is noted that this includes the area around Burton Green which adjoins the Solihull local authority boundary. Major investment sites have been identified within the plan area including the University of Warwick to the north of the plan area. Any expansion or significant economic development to the south of Solihull may have implications for the wider transport network and delivery of economic objectives and would need to be considered as part of duty to cooperate discussions.

Other

ID sylw: 107244

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Delivering Infrastructure-
It is noted that the Local Plan will be accompanied by an Infrastructure Delivery Plan to identify key infrastructure necessary to deliver the plan and to set out how this will be funded and delivered. The plan highlights the role of the IDP in helping to coordinate delivery of infrastructure and reflect the outcomes of discussions on infrastructure needs, including any cross-boundary issues under the Duty to Cooperate. It is important that a comprehensive assessment of the potential infrastructure requirements is undertaken at an early stage as this could affect the sustainability and deliverability of different growth options. Establishing any cross-boundary infrastructure requirements relating to potential sites adjoining neighbouring local authority boundaries in particular land identified at Hockley Heath (SG24) is particularly important as this would necessitate a commitment to joint working.
In the case of SG24 there will be a need to have cross boundary agreement regarding infrastructure delivery. At the moment Hockley Heath struggles to be a sustainable community with very limited public transport and no primary care facilities. It has an oversubscribed school. If SG24 is to be progressed, then funding for a Doctors surgery and pharmacy needs to be made. There needs to be a plan to fund better public transport that provides regular linkage to Dorridge station.
Further consideration of the implications of this and transport measures proposed in the future through the Regulation 19 Plan which could have implications on the wider transport network including within Solihull and therefore should be subject to cross boundary discussions. It is clear that the impact of this development will affect Hockley Heath and Solihull, so any infrastructure levy should be given to Solihull MBC who will spend in consultation with Warwickshire. There will need to be S106 payments for primary and secondary schools upgrades.

No

ID sylw: 107246

Derbyniwyd: 07/03/2025

Ymatebydd: Solihull MBC

Strategic Growth Location SG24 Hockley Heath Group of sites:

The Preferred Options Version of the SWLP states that the majority of the strategic growth needs of the area will be met in Priority Areas 1 to 3. Hockley Heath is one of 24 strategic growth areas identified as having the potential to accommodate growth.

SMBC does not support the identification of sites at Hockley Heath as a strategic growth location, and strongly objects to its inclusion.
Hockley Heath is a small settlement located within Solihull, but closely bounded on three sides by the boundary with Stratford upon Avon and Warwick District Council. As a consequence, any proposals which focused significant growth within or adjacent to this settlement would have cross boundary implications. The existing settlement is small scale therefore significant development could affect the character and amenity of the existing settlement; and it does not have the scale of infrastructure needed to support the proposed development.
In response to the Issues and Options consultation in March 2023 SMBC identified the issue of potential growth related to a number of ‘call for sites’ submissions around Hockley Heath. At that time the dispersed growth option did not indicate the Hockley Heath area as an indicative location that may feature in this option. Nor was the village listed in the settlements considered under this option. The Council supported this position.
It was pointed out that to identify the settlement as a location for growth to take place in South Warwickshire would be considered to run contrary to the spatial strategy in Solihull’s plan. It would have a detrimental impact on the character of the village and would not be supported by the necessary infrastructure, a factor complicated by not being within the same local planning authority.
In the Solihull Local Plan Review the settlement had been identified in the spatial strategy as a rural settlement identified for just limited expansion. In accordance with the spatial strategy an allocation (in Solihull’s plan) to accommodate some 100 dwellings has been made for the settlement and it is considered that this fulfils the ability of the settlement to accommodate limited expansion. The Inspectors carrying out the examination of Solihull’s plan indicated that the plan’s spatial strategy was appropriate in principle.
The Local Plan Review was withdrawn in October 2024 and the Council has committed in the Local Development Scheme to the preparation of a new Local Plan Review. This review will be prepared in accordance with the Revised NPPF.
SMBC acknowledges that the strategic growth areas have been put forward for consultation purposes and that not all of these areas will be needed and taken forward to provide for the area’s growth needs over the plan period. At this stage these have been included in the preferred options document to explore the range of reasonable alternatives and further work will be undertaken prior to the publication of the Regulation 19 consultation to set out which will be allocated.
Some of the identified strategic growth locations including SG24 are located within the Green Belt. It is acknowledged that further evidence is being prepared to further consider the sustainability of the options. Stage 2 of the green belt assessment will provide more detailed consideration of areas considered for development including the contribution an area makes to green belt purposes and the impact on the wider green belt if this area was released. This evidence will enable a wider assessment of the most sustainable options for accommodating South Warwickshire’s housing and employment land needs. This will include whether there are sufficient non-Green Belt locations or whether there are clear sustainability to utilising green belt locations. This will form the basis of exceptional circumstances arguments to justify green belt release.
SMBC would reiterate the need to ensure that careful assessment of the sustainability of different options is undertaken and in the case of Green Belt locations to justify exceptional circumstances. The plan should ensure that the site selection process to finalise sites taken forward in the regulation 19 version of the plan reflects the up-to-date approach set out in the NPPF in relation to Green Belt. SMBC would welcome sufficient opportunity to review and comment on the evidence presented in the stage 2 Green Belt assessment particularly in relation to sites in the vicinity of Hockley Heath (SG24)
The plan states that within the strategic growth areas development will only be accommodated where it is of sufficient scale for significant infrastructure upgrades to be provided on site. We wish to reiterate earlier consultation responses that Hockley Heath is a small settlement with limited facilities and services; and SMBC does not consider there is sufficient evidence to demonstrate that this is the right location to focus development. SMBC consider that any proposals which focus growth on sites adjacent to Hockley Heath would have significant cross boundary implications for infrastructure delivery. Proposals would be likely to require Section 106 and CIL contributions for infrastructure and services that would be needed within the SMBC area. Such development would therefore need to align with the strategic growth vision for Solihull being progressed through the new Local Plan Review process.
If the South Warwickshire Plan is adopted with Hockley Heath identified as a strategic growth location, then the plan will need to acknowledge that the infrastructure supporting the development is likely to be within Solihull and mechanisms must be in place to ensure SMBC is the recipient of appropriate S106 monies and CIL receipts to enable appropriate infrastructure to be delivered. It is paramount that infrastructure needs are agreed with SMBC as they are materially affected. The Warwickshire IDP should recognise the Infrastructure need for the village and SMBC.