Yes

Draft Local Plan Review

Representation ID: 2986

Received: 14/02/2017

Respondent: Lionel Johnson

Representation Summary:

I agree with a strategy and approach where areas of previously developed land (Brownfield) are selected ahead of non-developed land (Greenfield) and areas with good public transport links are considered ahead of those with poorer public transport links.

Full text:


I am responding to the Council's Draft Local Plan (DLP).

In response to Q1:

"Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?"

I believe that improving the centre of Balsall Common has failed to be recognised as an additional key challenge that Solihull Council needs to address. The current facilities within Balsall Common centre struggle to support the existing populace so could not support up to an additional 1350 houses.

In response to Q2:

"Do you agree with the Borough Vision we have set out? If not why not, and what alternative would you suggest?"

I do not agree with the vision set out. It neither provides for improving the centre of Balsall Common nor outlines how it will need to change in order to cater for the needs of a growing local community. There is already insufficient parking for the current populace. The vision for Balsall Common fails to note the need for improvements to local facilities, services and public transport which would encourage more sustainable travel patterns and improved connectivity to surrounding communities.

The inclusion of a generic statement that 'Schools will have continued to thrive and grow' appears naive. The primary school is already at capacity and the required growth will not be possible at its current location. Relocation of this facility should be considered alongside the other significant developments which have been proposed.

I also do not agree with part of the vision which describes that 'an alternative route will have been provided to relieve traffic from the Kenilworth Road'. Any such alternative route will result in a further loss of greenbelt, an increase in traffic and act as a catalyst for additional development.

In response to Q3:

"Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?"

I agree with a strategy and approach where areas of previously developed land (Brownfield) are selected ahead of non-developed land (Greenfield) and areas with good public transport links are considered ahead of those with poorer public transport links.

However, I do not agree that the appropriate growth opportunities have been correctly identified within DLP paragraph 108. I do not understand why Green Belt and Greenfield sites are identified as locations where growth should be focused when there are a number of Brownfield sites (e.g. part- PDL site 240 - Land north of Balsall Common) which do not feature within LPR proposed sites. This is contrary to the guidance as set out within:

a. The strategic objectives of this document (DLP paragraph 96), and
b. "Step 1: Planning for the right homes in the right places" of the Government's "Fixing our broken housing market" white paper by "maximising the contribution from brownfield and surplus public land" (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/590043/Fixing_our_broken_housing_market_-_housing_white_paper.pdf)

In response to Q7:

"Do you agree with Policy P2? If not why not, and what alternative would you suggest?"

I do not agree with Policy P2 as I believe the challenges facing the centre of Balsall Common in light of the proposed housing growth have failed to be recognised and its own master plan is needed. Specifically there is a need to ensure that the provision of parking in the village centre meets the needs of retailers and residents, whilst not acting as a constraint to development.

In response to Q15:

"Do you believe we are planning to build homes in the right locations? If not why not, and which locations do you believe shouldn't be included? Are there any other locations that you think should be included?"

I wish to object to the development of site 3 (Kenilworth Road, Balsall Common) and would propose that serious consideration be given to the development of site 240 (Wootton Green Lane, Balsall Common), as an alternative.

The reasons for my objection are below, based on the outcome of the investigations undertaken by the BARRAGE action group and as such the evidence and supporting information can be found in their report.

1) Balsall Common fails to meet the Council's own specified criteria for high frequency public transport and therefore is not a settlement with good accessibility. As such, the allocation of circa 20% of new housing in the Borough to Balsall Common, is in breach of SMBC's policy that "all new development should be focused in the most accessible locations".

2) Moreover it is a settlement with limited employment opportunities and therefore most people have to commute to work by car. A significant expansion will add unnecessary pressure to the road network as well adding to the carbon footprint. There are no proposed Sprint Runs to mitigate for this.

3) The proposed allocation of 3 greenfield sites in Balsall Common, when there are 14 PDL (Previously Developed Land) sites available, would strongly suggest that due consideration has not been given to these sites. As such, the "very special circumstances" to justify inappropriate development in the greenbelt have NOT been demonstrated.

4) The development of site 3, being in the south of Balsall Common, will add to the congestion hotspots on the A452 caused by northbound traffic heading to the main employment centres.

5) The development of site 3 (200 units), in addition to the two sites currently under construction on the Kenilworth Road (115 units), will inevitably cause delays to drivers trying to access the A452. As a consequence, the risk of accidents will increase as drivers attempt to exit these sites in a situation even more difficult than it is today. Windmill Lane will become even more of a "rat run".

6) Site 3 scores poorly in relation to all accessibility criteria, as defined by SMBC, apart from the Primary School. As such most journeys to the shops, medical centre and railway station will have to be by car, adding to the existing congestion and parking difficulties

7) To alter the boundaries surrounding the Crest Nicholson developments on the Kenilworth Road (sites 22 and 23), in order to develop site 3, would directly contravene National policy, as these boundaries were regarded as permanent.

8) The existence of the Berkswell Windmill (Grade II* listed building), as well as Great Crested Newts, a European protected species, has been overlooked in the Council's assessment. As the setting of this iconic landmark will be harmed, the proposal is in breach of National policy.

9) Using the same criteria as the Council to assess sites, part- PDL site 240 outperforms site 3. Given that the area is larger than site 3, this site should be re-assessed by the Council with a view to allocation instead of site 3.

10) The phasing of all 3 proposed allocations for development to take place in years 1 - 5, at the same time as HS2 and the site at Riddings Hill, will place intolerable strain on the settlement. There will be insufficient time to effectively plan for and deliver the necessary improvements to both infrastructure and facilities, which are already overstretched. In particular, the current Primary School provision is wholly inadequate. This directly contravenes SMBC's stated intent to "manage the growth."

In response to Q16

"Do you believe we have identified the infrastructure required to support these developments? If not why not? Are there any additional facilities you believe are required, if so what are they?"

No - parking facilities at Berkswell Station are already insufficient to support the current need. This results in vehicles needing to park elsewhere e.g. along Hallmeadow Road. An increase in the population would put further strain on this facility and as such I believe additional parking facilities are required.

In response to Q18

"Do you agree with the policies for improving accessibility and encouraging sustainable travel? If not why not, and what alternatives would you suggest?"

Policy 7 is only concerned with the proximity to and the frequency of bus services. A defining factor for commuters' transport mode choice is the destination or the appropriateness of the service. e.g. Whether a dwelling is within 400m of a bus stop is irrelevant if the service cannot deliver you to your destination in a timely manner.

In response to Q22

"Do you agree with the Policy P21? If not why not, and what alternatives would you suggest?"

Policy 21 does not specifically state that all CIL payments, new homes bonus or the profit on the sale of Council land for housing should be spent in the areas where the housing is built. I strongly believe that such payments received for a development should be allocated to the directly affected community.

In response to Q23

"Are there any other comments you wish to make on the Draft Local Plan?"

The proposed addition of up to 1350 houses to Balsall Common, representing a sizeable increase in population (>25%), will have a significant impact on the character of the village. It will remove the local distinctiveness of the area, characterised by its open countryside setting, sense of remoteness, distinctive fieldscapes and woodland assets. All of this is in direct conflict with the statement (DLP paragraph 86) that "the local distinctiveness of the area... ...will have been protected".

Furthermore, I support the recommendations from BARRAGE that:

1) A re-assessment is made of the appropriateness of significantly expanding Balsall Common, given its poor accessibility using public transport

2) If there is justification for significantly expanding Balsall Common, then an holistic view is taken as to where housing is best located, with due consideration to be given to the re-use of PDL sites in preference to "greenfield" as well as congestion hot spots

3) The phasing of any development must recognise the impact and disruption of HS2

4) The necessary infrastructure to support any significant expansion must be identified and planned for alongside any development

5) SMBC consults on ALL PDL SITES, which fall within or are adjacent to Balsall Common, with a view to potential allocation with immediate effect to ensure the community is fully engaged

6) Site 3 is removed from the Draft Local Plan as it is not compliant with both National and Borough planning policies and, as such, is not sustainable.