Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13854
Received: 09/12/2020
Respondent: John Boucher
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Objection (Wants site BC3 removed from Solihull Draft Submission Local Plan and Final Local Plan): Fails 3/4 tests of soundness.
> Not positively prepared as it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units (Greenfield) and 1195 units (Meridian Gap) is not required to comply with planning policy. Furthermore, site BC3 specifically is not sustainable using the council’s own criteria.
> Allocation of site BC3 has not been justified. Omission of sites within Balsall common and in the wider Borough which should have been chosen based on merit or for which the omission has not been justified. Final findings from Solihull Town Centre Masterplan are not incorporated and cannot be reconciled with the Draft Local Plan.
>Inconsistencies with the NPPF, specifically para 1; 94; 108; 109; 122; 138; 185 and 194 are not complied with. Sustainable development will not be complied with if site BC3 remains in the Draft Local Plan.
>Wishes to preserve the biodiverse rich habitat that is Site BC3 and protect the character of the Grade II Listed Berkswell Windmill. Concerns required net biodiversity gain of 10% can be achieved.
I wish to formally OBJECT to Site BC3 Windmill Lane/Kenilworth Road and ask that it is
removed from the Solihull Draft Submission Local Plan and Final Local Plan.
In proposing the allocation of Site BC3 for housing, the Draft Submission Local Plan is not . sound, as it fails to comply with 3 of the 4 necessary tests:
1 It should be Positively Prepared:
The plan has not been positively prepared as NPPF para. 11bii has not been given due consideration and it will not be practical to deliver the 2105 units comprising the unmet need of the HMA. To build 1195 units on Green Belt Land in the Meriden Gap is not necessary in order to comply with planning policy. Moreover, it fails to demonstrate specifically that Site BC3 is sustainable using the Council’s own criteria.
2 It must be Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which should have been allocated, based on merit. Also, the findings from the final version of the masterplan for Solihull Town Centre have not been incorporated and cannot be reconciled with the Draft Local Plan.
3 Consistent with National Policy:
There are inconsistencies with the NPPF, particularly paragraphs 11; 94; 108c; 122; 138; 185 and 194b are not adequately complied with. As a result the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the rich habitat of Site BC3 and it is difficult to see how under the proposals the required net biodiversity gain of 10% can be achieved without planting large numbers of trees which would adversely affect the setting and operation of the Grade II* Listed Berkswell Windmill, which is a valuable asset of high national importance.