Draft Black Country Plan

Comment

Representation ID: 17453

Received: 11/10/2021

Respondent: Solihull MBC

Black Country Plan R18 - Response by Solihull MBC

I would be grateful if you would treat the contents of this email as Solihull MBC’s comments on the
consultation.
Solihull MBC welcomes the opportunity to comment on this important next stage in bringing forward
a new plan for the Black Country.
This response will focus on the strategic matters relating to land supply for housing and employment
uses. The Council wishes to repeat its position of seeking collaborative working alongside the BCA,
and other authorities in the HMA, to seek to address solutions to accommodate the unmet needs of
Birmingham and the Black Country.
Solihull Council recognises the difficult decisions that have to be made when considering potential
Green Belt land release. You will be aware that through our current Local Plan Review (currently at
examination stage) that SMBC have sought to take a brownfield land/urban location first approach,
but that it’s been supported be the need to make significant releases of land from the Green Belt
(amounting to some 574ha to fully accommodate its own development needs, and in order to make a
meaningful contribution to the HMA shortfall. This includes land for both housing and employment
delivery as well as supporting the regional gateway to HS2. It also includes positive planning for
substantial mineral extraction within the Boroughs Green Belt to support regional requirements.
It is in this context that Solihull Council does not believe that the Black Country Plan has made enough
of a contribution towards meeting its own needs before asking neighbouring authorities for
assistance. In particular:
Failing to take account of the PPG which at paragraph 035 Reference ID: 2a-035-20201216
(Where should the cities and urban centres uplift be met?) advises: “This increase in the
number of homes to be delivered in urban areas is expected to be met by the cities and urban
centres themselves, rather than the surrounding areas, unless it would conflict with national
policy and legal obligations.”
Question marks remain regarding the maximisation of brownfield land opportunities as
indicated by the mayor and to be tested through an independent study commissioned as such.
Failing to maximise the opportunities presented in the Green Belt in the Black Country to a
sufficient extent before asking neighbouring authorities to sacrifice their own Green Belt.
In relation to the latter point, the commentary at paragraph 3.49 of the plan is particularly noteworthy
as the importance of the Green Belt to Solihull is held in a similar high regard, added to which is the
strategic function that the Green Belt in the Meriden Gap makes in Solihull by separating the
Birmingham & wider conurbation from Coventry. We accept that such a view will undoubtedly be held
in all areas where Green Belt is present and as such do not want to get drawn into a ‘green belt beauty
contest’. Our point is simply that national guidance requires local needs to be met where they arise (in
order to promote sustainable development) and as such local opportunities within a respective area
should be maximised before they are sought to be met elsewhere.
I would be grateful if the above points can be taken into account.