Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10793

Received: 12/12/2020

Respondent: Mr John Outhwaite

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Proposed relocation of the tip is not legally compliant because the proposal hasn't been consulted upon in accordance with the Statement of Community Involvement.
The proposal is not positively prepared or justified because insufficient evidence ( options to improve current facility, alternative site information, traffic assessment) provided or consulted upon.
The "need" for a relocated waste/recycling site has been artificially generated by lumping together improved waste/recycling facilities plus the Moat Lane Depot operation on a single site for ulterior and unstated motives.

Change suggested by respondent:

Due to the inadequate information provided and the failure to consult on this proposal then the Plan should be confined to stating /justifying the need for improved waste/recycling facilities and then state what the identified options are, i.e. 1) alter existing site, 2) relocate to Damson Parkway (and identify exactly where) and 3) relocate to the other site the Council have referred to (the not preferred option) and identify where that site is. The plan should state what consultation will be undertaken in order to inform a decision as well as state what evidence base will be published prior to such consultation. No preference as to the solution should be expressed in the plan.

Full text:

The proposed relocation of the Bickenhill tip is not legally compliant because this has not been consulted upon, this is the first time this proposal has been put into the public domain, so it does not comply with the statement of community involvement. No information about the alternative (but not preferred) site that it turns out has been considered and rejected have been provided, no details about the possibility of expansion of the current site have been provided. It is stated that there is sufficient space for queuing vehicles, but no evidence has been provided. Relocation of the site to land adjacent to Damson Parkway would significantly increase traffic/congestion on Damson Parkway, Damson Lane and Rowood Drive and at shift change times at JLR plus traffic from the new logistics facility would likely result in traffic gridlock. No traffic assessment/sustainability assessment appears to have been undertaken. Thus there is inadequate information provided/available to support the "exceptional circumstances to justify the the potential use of the site" as referred to in para 354.
The need for improved facilities for waste/recycling can probably be met by changes at the existing site, in this plan the Council is joining this need togehter with a desire to develop a new site which includes both the waste/recycling centre and the operations currently at the Moat Lane Depot, for which there is no actual requirement. I consider that these two items have been lumped together in this way so that it would be shown that the existing waste/recycling site cannot be expanded to also accomodate the Moat Lane operation as well, thus generating a "false" requirement for a relocated waste/recycling site. The real, but unstated, reason for this is so that the Council can release the Moat Lane Depot site for housing development and make money from that. Thus the plan for this is not sound and is not legal.
Other options to co-operate with other local authorities, in particular Birmingham Council, have not been explored thus the duty to co-operate has not been met.