No

Draft Local Plan Review

Representation ID: 4241

Received: 17/02/2017

Respondent: Richard Lloyd

Representation Summary:

There should be a clear policy for requiring solar PV on all new buildings, and prohibiting green-field solar farms. In addition, policies should encourage use of solar PV in paved areas etc. There should be clear architectural/design standards for all solar PV installations.

Full text:

Challenges
1. 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?
Vision

No.
Challenge C - Balsall Common village centre suffers from many of the challenges listed for Solihull, Shirley, and Chelmsley Wood Centres.

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

No.
The vision seems to rely on increasing transport dependency. It implies that employment growth will necessitate people travelling from outside the area to work within Solihull, and Solihull residents travelling long distances outside the Borough to go to work. A better strategy would be to focus on creating local employment, with the transport growth aimed at transporting materials and goods. Transport of people for employment purposes could be reduced by improved broadband network infrastructure and tele-working.
the spatial strategy seems to run counter to the wish in para 74 for preserving the environment.
There doesn't seem to be any proposals to meet the aspiration in para 75 to reduce carbon emissions.
In para 86 it's said growth will occur on the edge of settlements which will inevitably increase traffic and transport need, and runs counter to the aspirations in paras 72 and 75. A bypass for Balsall Common is proposed without consideration of the impact on the viability of the village centre, the environment, or existing residents.

Spatial Strategy
3. Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?
Sustainable Economic Growth

No.
The proposed significant expansion of rural settlements is in conflict with the stated preference and national policy of giving preference to brown field sites, and does not recognise the absence of high frequency public transport in most of the Borough.
Given the shortage of housing land to meet the Government's housing targets, it is essential that all new development is to a high density to reduce the land-take.

4. Do you agree with Policy P1? If not why not, and what alternative would you suggest?

No.
There doesn't seem any plan to mitigate the increased traffic, congestion, carbon emissions, air quality degradation, and noise disturbance. The land should not be developed until after the aggregate resources have been extracted. Renaming the area as Arden Cross is simply tacky and tasteless. It already has a name, Middle Bickenhill.

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

No.
Balsall Common centre has suffered from the loss of business premises, the loss of the Health Centre to a greenfield site on the edge of the village, inadequate parking, the lack of a bus station, and now a proposal to divert through-traffic. A comprehensive development plan is required to address all these issues.

Providing Homes for All
11. Do you agree with Policy P4? If not why not, and what alternative would you suggest?

No.
The shortage of land and the need for housing means that there should be a significant increase in density and the provision of smaller homes.

12. Do you agree with the level of affordable housing being sought in Policy P4? If not why not, and what alternative would you suggest?

No.
The affordable housing provision should be greater than 50% for all sites - which would require development of an individual house to be "affordable".

14. Do you agree that we are planning to build the right number of new homes? If not why not, and how many do you think we should be planning to build?

No.
The housing target should just meet local needs. Excess requirements should be met in the rural expanses in neighbouring counties, who are expected to have a "duty to cooperate". Solihull should not cater for Birmingham overspill. Solihull Borough has essentially reached capacity in terms of housing provision, and a Predict and Provide policy will lead to a continuous decline in the quality of the environment and to the detriment of residents.

15. Do you believe we are planning to build new 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?

No.
The planning objectives of re-using previously-developed land and creating new settlements have been ignored. Areas such as Balsall Common are being encouraged to sprawl in contravention of accessibility, sustainability, and Green Gelt policies. The Green Belt analysis has not been conducted in line with the NPPF as non-defensible boundaries have been used. The scores attached to preserving the narrowest part of the Meriden Gap are too low and irrational. Balsall Common seems to have been singled out for concentrated and disproportionate expansion, in contrast to areas such as Dorridge, which has far better public transport. In particular, sites 1 and 3 appear to have been chosen for administrative convenience rather than compliance with local and national policies.
Preference should be given to developing brown-field sites and to raising the housing density generally.

16. 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.
With regard to Site 1, the proposed highway access is completely unsuitable and will put traffic onto residential roads. No "bypass" is proposed, but with the lack of funding the proposals are likely to create a rat-run that will cause further environmental harm for residents. There is no strategy to deliver bus service and school provision. With regard to Site 3, it is far too distant from the village centre to benefit from the quoted infrastructure improvements.

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

No.
Para 267 is incorrect, the HS2 Environmental Impact has been assessed on the basis that no road improvements would be needed south of the A45. It is highly unlikely that people will travel from south of Balsall Common to HS2 at Middle Bickenhill when there are nearer and more convenient alternatives at Warwick. In addition, the current railway is available to feed the new station via the People Mover. The additional housing proposed for Balsall Common is wrongly sited if it creates additional commuting traffic. There are alternative sites to the north of Balsall Common that would have good access to new employment sites and would not require road improvements.
One reason for abandoning the bypass for Balsall Common was the need to maintain the vitality of the village centre retail options. The proposed new housing would be too far from the centre to offset any loss of through-custom. The A452 only becomes congested when there are problems on the motorway network, and there is no identified need for improved capacity. Much of the traffic is generated within the village. Capacity is limited by the traffic lights at the south of the village, and improvements to that junction should be the first to be considered if demand increases.
There doesn't seem to be any justification for expensive projects like Metro and Sprint (Policy 8A). The passenger demand should first be proven by running bus services. The main factors limiting greater use of public transport are: service interval; unreliability; lack of real-time information; primitive or non-existent waiting shelters; absence of evening services; difficult access for the less agile. Berkswell Station has an irregular service with 40 minute waiting times, and has had a marked reduction in the quality of the waiting facilities. It is difficult for the disabled to board the trains due to the platform gap.
The service interval target (Policy P7) has been increased from 15 minutes between busses and 20 minutes between trains. Rail services have been dropped from the policy, and should be specificed with the same targets as for busses. The previous target intervals were too long for many users, but the proposed 30 minute wait is far too long. The rural area generally has only an hourly service, and few dwellings are within 400 metres of a stop, so Policy P7 is hugely optimistic and unrealistic.

Protecting and Enhancing our Environment
19. Do you agree with the policies for protecting the environment? If not why not, and what alternatives would you suggest?

No.
There should be a clear policy for requiring solar PV on all new buildings, and prohibiting green-field solar farms. In addition, policies should encourage use of solar PV in paved areas etc. There should be clear architectural/design standards for all solar PV installations.

Promoting Quality of Place
20. Do you agree with the policies for quality of place? If not why not, and what alternatives would you suggest?
Health and Supporting Local Communities

No.
Policy P16 should be expanded to include requirements to identify unrecognised archaeological remains during any development. A more integrated approach should be adopted to finding traces of early settlement in the area. All works in new areas should be preceded by geophysical surveys.
Policy P17 should specify Balsall Common as inset in the Green Belt and protected like the other named settlements.

21. Do you agree with the policies health and supporting communities? If not why not, and what alternatives would you suggest?

No.
Policy P20 does not provide sufficient long-term protection for public open space. All such areas should be designated as Village Greens, and green spaces in new developments should be dedicated as Village Greens by the developers.

Delivery and Monitoring
22. Do you agree with the Policy P21? If not why not, and what alternatives would you suggest?

No.
Policy P21 should be clearer about spending all "planning gain" within the affected communities. In addition, all new developments should only be approved following agreement of a detailed strategic site plan agreed within the community.
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