Dear sirs

Please find a statement in connection with the local plan review.
I strongly object to any additional development in Dickens Heath.
We have suffered too much fringe development and over development in recent years together with an appalling lack of infrastructure improvements and highway maintenance works, to such an extent the surrounding road networks are verging on third world standard!
Dickens Heath is a new village, it was designed as a contemporary village and should remain so, Local plan proposals seek to eradicate the village and extend the boundaries into surrounding rural/semi-rural settlements whereby Dickens Heath village actually becomes part of Shirley conurbation!

As a resident of Dickens Heath for over 13 years, I wish to strongly object to the allocation of Site 4 for residential development of 700 dwellings.
Dickens Heath is a planned new village with clearly defined limits. It is unique in Solihull as having emerged through the Unitary Development Plan process as an entirely new community. It has an architectural character of its own. It is not an urban extension. It differs therefore from previous urban development in the Borough of Solihull, planned and carried out in previous decades as large-scale urban extensions: Chelmsley Wood (1960s/70s) and Cranmore-Widney (1970s-80s).
Dickens Heath should be identified in the Local Plan as having a particular character and design and that there should be limits to its continued growth in terms of numbers and direction; the Village should be protected and conserved as a new village, together with its character and setting in the countryside.
The housing proposals for Dickens Heath in the Plan Review do not comply with the stated Policies as set out in both the existing adopted Local Plan and this Local Plan Review. It would be unsustainable and would no longer make Dickens Heath a "special place". In the Vision for the Borough, Dickens Heath is addressed at paragraph 87:

"... whilst retaining its intrinsic character of distinctive villages separated by open countryside". The proposed major development of Site 4 would not be in accordance with this stated policy.

The Government has consistently committed to protecting the Green Belt and stated that the single issue of unmet housing demand is unlikely to outweigh harm to the Green Belt. It is my opinion as a Developer professional that there are a substantial number of other sites in the Borough more suitable for development. No robust and detailed appraisal of alternative sites has been carried out in a sequential test. The Council has not fully examined the infrastructure requirements that would justify and mitigate altering the Green Belt. Permanence is a feature of Green Belt and any decision to change its status should be considered carefully. Areas of land which are assessed in the Atkins Green Belt Assessment as having a score of 7 or higher - presumably because they perform best against the criteria for being in the Green Belt - should not therefore be removed from the Green Belt. Instead some of those higher performing sites have been proposed for removal from the Green Belt for no logical reason.

The proposed large-scale housing allocations on Green Belt land in Dickens Heath Parish would be a major expansion of the urban area and would reduce or remove key gaps between settlements such as Majors Green. The attractive rural setting of Dickens Heath will be partly lost to development. In Dickens Heath Parish, access to the countryside and recreational opportunities will be reduced, not improved.

There is also a disproportionate amount of the additional housing proposed in the Plan Review proposed to be located in the Blythe Ward - Parishes of Dickens Heath and Cheswick Green. 45% of all the proposed additional housing would be sited in these two Parishes. I consider that this is an excessive burden placed on such a small area. It notes that there are no housing proposals at all in the Dorridge & Hockley Heath Ward, although this comprises a significant part of the Borough and has a number of locations suggested for development in the 'call for sites' and identified in the SHELAA (Housing Land Availability Assessment). None of these have been properly assessed in the analysis conducted to arrive at the final suggested allocations. There should be a preference for smaller sized housing allocations rather than the almost entirely proposed large scale mass housing locations controlled by a few national house builders. Indeed, the Government promote the use of SME builders in developing small scale housing for local needs as suggested in the recent Housing White Paper. There appears to be little cognizance of this vital tool for local employment and economic benefit within the proposals.
The Plan should be revised to reduce the number and scale of large allocations, and to replace some of these with a wider range of small/medium housing sites which would be delivered faster and can be absorbed more easily into their communities.

The proposed allocation of Site 4 does not accord with Government policy to protect Green Belt from development. An example is the Secretary of State's statement in the Commons on 18 July 2016:

"The Green Belt is absolutely sacrosanct. We have made that clear: it was in the Conservative party manifesto and that will not change. The Green Belt remains special. Unless there are very exceptional circumstances, we should not be carrying out any development on it."

In addition, the opening paragraph of the Solihull Local Plan Review states:-

"At the heart of planning is the need to plan positively for sustainable development. One of the principal ways this is achieved is by having a local plan to guide the development of an area. Having a local plan is key to delivering sustainable development that reflects the vision and aspirations of local communities."
"Sustainability will be a key focus of the Review including sustainable transport accessibility."
"The vision recognises the importance of the Borough's distinctive rural settlements and wider rural area."
"Growth in rural settlements will be considered in the context of emerging Neighbourhood Plans and the capacity of local infrastructure or the potential for new capacity."

The new Housing White Paper includes further strengthening of policy on Green Belt as well as asking for smaller sites to be made available for development by local builders and those wanting to self-build. Build more homes on public sector land; Local Authority to be allowed to sell land with the benefit of planning permission; encourage estate regeneration.

Green belt to be used as a last resort (once LA have demonstrated that they have examined fully all reasonable options for meeting their identified development requirements) and the impact is to be off-set by compensatory measures.
"Green Belt land will continue to be protected in order to meet its strategic purposes, including countryside protection, in accordance with established principles and the NPPF."
I do not agree that exceptional circumstances can be demonstrated to release, in particular, the Housing Allocation Site 4 from the Green Belt. There has not been a sequential test carried out to identify which sites are the most sustainable. There are other small and medium sized sites now within the Green Belt which have a lower score in the Atkins Assessment than Site 4, and would be more sustainable with less adverse effects.

Proposed Housing Allocation Site 4 would not be in a sustainable location and would create substantial car traffic. While it would be close to Whitlock's End railway station, the rail service at that station gives access to Central Birmingham and to Stratford-upon-Avon. It does not provide a service to Solihull Town Centre, for which there is only a slow and indirect bus service or across the Borough to UK Central. There would no direct access from Site 4 to the services and facilities in Dickens Heath village itself, as there would be no direct road or cycleway to the village centre. Cycle and pedestrian access to the village centre was a core principle of the design for Dickens Heath.

If Site 4 is included in the Local Plan, there would be a major loss of sports grounds and playing fields. Sport England as a Statutory consultee would object to any loss of sports grounds especially those which are regularly used. Taking a sustainable approach would consider replacement elsewhere a waste of money and resources, it is doubtful any new facilities will be used by the greater community in higher volumes. If the current facilities are in need of renovation, there are grants and charitable donations available to support such schemes negating the need to sell to developers for a fast buck.

The Green Belt which would be lost to Site 4 contains a variety of different types of sports facilities. The proposed replacement sports facility on Site 4 between Tythe Barn Lane and the Stratford Canal would not adequately replace the many sports clubs' requirements. There are already many objections to the loss of the several current sports fields and facilities; these are used by people from a large area of the Conurbation and surrounding towns.

The suggested replacement new sports facilities - which appear to be included as part of the housing allocation - are more urban and would include significant built development and car parking. They would be too large and intensive to be capable of being appropriate development in Green Belt. The openness of the Green Belt, which the current sports fields preserve effectively, would be lost. There would be no guarantee that that new sports area would not be the subject of further housing development proposals later. It should be entirely removed from the Housing Allocation site if that allocation remains despite the Parish Council's deep concerns about it in principle. We have actually fallen victim to this very trick in Dickens Heath less than two years ago. The current Bellway development had a MUGA pitch designed within the site proposals only to be removed at the 11th hour without any public consultation, due - we are told - to Solihull MBC's refusal to take on the ownership and future maintenance! A fantastic result for the developer who managed to increase the number of oversized multi million pound executive houses realizing substantial windfall profits and reduced community benefit contribution costs.

Additionally, and significantly, the valuable and popular Akamba Heritage Centre on Tythe Barn Lane would be lost, which is also a good local employer. This is because the land on which it stands would be redeveloped for car parking and new more intensive set of sports facilities. Akamba offers an unusual leisure and recreation experience and its character contributes to the quality of the environment. It merits protection under Policy P10. There is no prospect of any community benefit from the Site 4 proposal which could outweigh the loss of it as an existing leisure, cultural and recreation facility. The Housing Allocation Site 4 proposals would force its closure.

This has not been the case in proposing Site 4 against the evidence provided in the Green Belt Review with the Green Belt in this location scoring 7 & 8 due to the coalescence with neighbouring settlements. Site 13 has a lower Green Belt score of 6. Another main issue of the SLPR is the challenge of protecting the environment, particularly the Green Belt/rural character and building into the Review an emphasis on sustainability/climate change. Site 4 is would significantly adversely affect the Village character and rural setting and would be unsustainable as the proposed development is more than accepted walking distance of 800 metres to the centre of the Village. As this increased traffic would place an unacceptable burden on the already inadequate, congested road system and the existing Village centre car parking shortage, the proposals would not be in accordance with the stated policy or with the policies also stated below.

"Sustainable development will be a central focus for the Review and will take into consideration effects on communities, HS2 and flood risk."
In the Scope, Issues and Options Consultation - Summary of Representations and the Council's Response, it is stated on Page 25:-
"The Council will seek through a managed growth approach to ensure that growth does not result in deterioration in the quality of life of residents and visitors."
"Enhancing Solihull as a place where people aspire to live, learn, work and play, whilst recognising and protecting character and local distinctiveness."

The original concept design for Dickens Heath by John Simpson stated that "A village works as one cohesive entity because the perception is that everything is within easy walking distance". The emphasis for the scheme as a whole is on accessibility where the majority of the residents will be no more than 5 minutes walking time from the centre. The majority of the Housing Allocation Site 4 location would exceed this walking distance, so the new residents would favour the use of cars to the village amenities (where car parking is already a major problem). In transport terms Site 4 would be entirely unsustainable.

The highway network for the original John Simpson design of the Village was for only 700 dwellings. This figure was subsequently increased to a long term maximum of 1,500 dwellings with some highway improvements, but the current highway network is unsuitable for the current 2,200 dwellings plus the increased through traffic from Tidbury Green when the Lowbrook Farm and Tidbury Green Farm developments are completed, never mind an additional 700 dwellings plus the cut-through traffic that also now use the road network. Again, on highway safety grounds the proposals are unsustainable. If major further development was to take place, major road improvements would have to be carried out. However, this would mean the removal of established hedgerows and mature trees which greatly add to and enhance the character and setting of the Village and the central Village road network was not designed for such usage. In addition it is not possible to upgrade the internal Village road network through which additional traffic would have to travel. Paragraph 32 of the NPPF states that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe. Development of 700 additional dwellings would have a cumulative severe impact on the area.
In John Simpson's 1991 Proof of Evidence in Para. 2.04.1, he states:-
"In general Dickens Heath has strong boundaries defined by the Stratford-upon-Avon Canal on two sides and a site of interest to Nature Conservation (SINC)". The SINC comprises of an ancient woodland which forms a natural boundary to the north-west.
John Simpson's Report goes on to analyse the McAlpine proposals where the site for the new village would be moved north-west. In Para. 3.01.3 states that,
"The combination of the woodland SINC, the woodland with tree preservation orders (TPO) and the existing housing provide a further barrier to development running north-south and splitting the site in two." This proposed extension to the Village would have the effect of elongating the settlement pattern to the north-west which cannot be linked by footpaths to the existing built areas, would have the effect of denying Dickens Heath of its village character and so the Village would lose its identity and become a town. The UDPs stated that for the Village to work in the sense of being "a recognisable community with a distinctive character", the inhabitants of the village would need to feel close to the centre of activity and identify with it. This will not be possible for the new residents of the proposed site.
One of the main reasons put forward by McAlpines was the close proximity of Whitlock's End station; the same reason Solihull Council has for including site 4 in the Local Plan Review. This reason alone does not outweigh the substantial unsustainable elements of this proposal.
There would also be a loss of ecological value as there are two badger setts on the sports fields. Bats, sparrow hawks, greater spotted wood peckers also fly over the site for foraging.
To build houses on Site 4, there would need to be extensive piling. There is evidence from neighbouring sites that piling had to go to depths of 8 metres owing to the presence of boulder clay. The cost of developing this site would therefore also be unsustainable and a considerable amount of fill material would have to be brought in as the site is liable to flooding during sustained wet periods.
The Solihull LPR states, "Development will be expected to preserve or enhance heritage assets as appropriate to their significance, conserve local character and distinctiveness and create or sustain a sense of place."
The proposed major extension to Dickens Heath would seriously undermine the Village status as a unique, nationally important model for a new village.
For the reasons given above, I strongly urge Solihull Council to remove the proposed allocation of Site 4 west of Dickens Heath from the Plan.