Thank you for your letter of 8 December 2016 informing me of the consultation process.
Please find attached my response to the Solihull Draft Local Plan Consultation.
Solihull Local Plan Review - Draft Local Plan Consultation

RESPONSE

This is to raise objections and concerns about the proposal to build 1050 new houses in Knowle, this being on two sites, namely the 'Arden Triangle' with 750 houses and Hampton Road with 300 houses.
My wife and I have lived in Knowle for over 37 years. I have been active, since its inception, in the work of the Knowle, Dorridge and Bentley Heath Neighbourhood Forum (KDBH-NF) and am consequently familiar with relevant background evidence including the Residents' Survey and data related to infrastructure, transport and services.
The proposed excessive housing allocation for Knowle is in complete conflict with the evidence base.
This document supports points made in the response from the KDBH-NF, which presents a convincing argument to significantly reduce the proposed allocation of housing in Knowle.
The points made below are often inter-related and represent only a sample of the arguments for opposing the proposals for Knowle in the Draft Local Plan
1050 extra houses for Knowle is far too many.
* This increases the housing stock in Knowle by over 25%, this is not counting the recent and current developments taking place. There has been zero allocation to Dorridge and Bentley Heath. This seems abundantly unreasonable.
* Where there is to be a mix of large and small-scale developments across the Borough, it would seem logical that any large development (over 400, for instance) should be adjoining urban areas to minimise detrimental impact and the 'smaller' developments (100-400) equitably sited around the villages to avoid overload of services and infra-structure. To put two large developments in the village is a sure way to secure maximum harm to services and infra-structure.
* There will be extremely detrimental impact on the identity, character and appearance of Knowle. Outcomes such as increased traffic density, reduced provision of personalised service, diminished sense of community and lack of locally specific services will erode the 'village character' currently valued by residents.
* The residents' survey has identified that there are already problems with parking, traffic congestion at peak times and access to primary medical care. Development of such magnitude will undoubtedly take this infrastructure beyond breaking point. Recent roadworks in Knowle have shown that any further stress on the road system will bring about gridlock.
* There would be a need for just under 2 additional forms of entry at primary school level. Even with this, primary school admission arrangements will be severely disrupted by the increased numbers of primary age children in two large blocks of new housing.
* With regard to retail facilities, it seems inappropriate to build all the houses in Knowle, where the provision of a Waitrose is problematic, and no houses in Dorridge where there is a new Sainsbury's with additional parking.
* The area, by nature of its village context, is not well connected or adjacent to the main transport links. There are much better sites.
* The proposal will ensure that Knowle effectively becomes a building site for 15 years with all that recent developments have brought to the village - mud on the roads, large lorries on small roads, noise, danger and inconvenience.


The rationale for choosing the two sites is unclear and there is a lack of strategic planning.
* It is unclear how the choice of sites arises from the policies, criteria and spatial strategy. The methodology to arrive at the proposal seems unsound.
* Access and transport criteria appear to have been evaluated from the nearest point to the village of each site, giving a falsely favourable reading to the site suitability overall.
* The methodology of basing choices around the 'call for sites' model seems to contradict the government current and intended policy of only using greenbelt in 'exceptional circumstances'. The two sites chosen perform highly on SMBC's own assessment of quality of green belt and therefore should have been safe from major development.
* The decision to choose the two sites seems to be swayed by the promise of community facilities. However, much of this is problematic at best.
* It seems absurd to base the future of Knowle around the aspirations of two independent organisations. It is particularly incomprehensible that the Solihull Draft Plan assumes that these two organisations are in a position to judge community need, particularly when on a parochial basis. In contrast, KDBH-NF has spent the last year collecting data, much of it from SMBC, and feedback, such as the residents' survey carried out by an independent organisation across every household in the area, that gives, without bias, as clear a picture as possible of community need and aspiration in the KDBH area.
* There is no account of the cost in terms of lost estate, revenue, recent investment and resource. A rough estimate is at least £50m - this at a time of increasing demands on public finances. There is no attempt to match income from developers to assessed need in order to make best use of finance.
Arden Triangle
The 'Arden Triangle' scheme was made known approximately 4 years ago. Proposals dated January 2013 were for a small-scale land swap scheme to provide new buildings for Arden Academy, a figure of 250 new homes in keeping with existing properties being mentioned. Since then, the vision has magnified considerably, there currently being a number of issues that are not clear, including any guarantee of accessibility and availability of community resources and the extent, type and density of new housing within the scheme in order to deliver the full package with appropriate facilities, playing fields and access. Assertions previously made, such as the nature of housing, have changed and cannot be kept once the project is in the hands of developers. The prospect of new buildings for Arden, promoted over the past 4 years, is seen by some as attractive. However, the cost, need and impact aspects have not been made public and many of these implications would not impact on those many parents and pupils favouring a new school who live outside Knowle. The proposed new school is reported to cost approximately £30m, a further cost being poor return on past and recent investment in existing buildings, some relatively new, to be demolished. This total cost is presumably at a loss to SMBC and could be spent on the basis of well researched priorities. This need analysis would certainly entail a condition and capacity assessment of all schools in KDBH. Overall, what evidence is there to justify the need for a new school at a cost of £30m+ and the detrimental impact on Knowle of 750 houses? This needs far deeper public scrutiny with consideration of alternatives.
Existing projects, such as the MIND garden area, had not been considered. There must be clear arrangements to avoid distress to vulnerable people.
There is mention of moving St George and St Teresa school to the new site. However, the logical priority for school places arising from current trends and the proposed housing would appear to be an additional two forms of entry at primary, these being sited with regard to reducing travel distance from any new houses and at a school that has a priority for local children.
In general, there must be maximum protection for public investment in new school buildings, whether primary or secondary, as this presents an extreme financial risk, particularly in the light of the autonomy of academies in relation to access to resources and in their admission policies which, even currently, cater for the admission of a high proportion of students from outside the area.
The proposed site for the 750 houses would present difficulties of access and considerable increases in traffic through the village as it is the 'wrong' side for access to Birmingham, the NEC, airport, railway stations and motorways, these being centres for employment and onward journeys.
This site, if extending to the full 750 houses, would have a significantly detrimental effect on the street scene in Station Road and approach through Stripes Hill and Grove Road.
The proposal has arisen from the stated aim of providing new premises for Arden Academy, it is not put forward as a planned scheme for new housing. The need and cost implications have not been made public. Whilst there may be some aspects of merit, the lack of independent assessment of need, the vagueness of outcome and no public awareness at this point of any concept masterplan, means SMBC is proposing a scheme that will undoubtedly have a devastating impact on Knowle and with little idea of what the plan will cost and what it will deliver.
Hampton Road
The proposals from the football club are at a more moderate scale. However, there are still questions about the cost to SMBC and the ownership and availability of resources. It is clear that the football club have a large number of teams that cannot be accommodated easily with the current number of pitches. However, provision of new resources would be of greater benefit if extending to more sports beyond football in order to cater for a wide range of skills and consequently attract more people to sport.

The views of residents have been ignored.
* The Draft Local Plan is as far away as possible from the views of residents, as reflected in the Neighbourhood Forum survey. Whilst it may have been impossible to accommodate the view about total numbers, there is serious conflict with regard to the size and location of sites, the appropriateness of the housing mix and the need to address the impact on local services and infrastructure. As one example, 98% of residents wanted sites on green belt to be less than 500 houses and 96% wanted them to be less than 100 houses. The current proposal is clearly way out of line with this and other views of residents.

The type and density of housing is inappropriate.
* The stipulation of 50% affordable housing and, in particular, the requirement for rented accommodation, is out of keeping with the area and will have a detrimental effect on the profile and character of Knowle.
* The densities quoted for the two sites are too high, particularly as this presumably average figure takes into account the school and club playing fields.
Recent housing development in Knowle has shown what high-density mixed housing looks like and the difficulties created, particularly with regard to parking and street scene. These recent developments are an indication of how developers can have little regard for providing building that is in keeping with existing housing.

Suggestions
The present proposal is a potential disaster for Knowle and needs a radical rethink along the following lines:
* Significantly reduce the number of houses that are proposed for Knowle by considering:
A new freestanding small-scale garden city that can have its own purpose-built community facilities;
Allocation of large sites to existing conurbations rather than villages;
Other sites outside the area such as those suggested by the Neighbourhood Forum and Knowle Society;
Smaller sites of around 200 to 300 around Dorridge and Bentley Heath to spread the load. Sites 207 (retains adequate separation from Solihull), 104, 135, 241, 199, 029, 210, 127 would take some pressure off Knowle and 059 in Knowle, as a last resort, would ease some aspects of impact in Knowle.
* Assess the costs and benefits of the two existing proposals and, if favourable, set this within a wider planning perspective as below.
* SMBC, in partnership with KDBH-NF and its extensive database, takes an overall strategic view of the Knowle, Dorridge and Bentley Heath area, not accepting without question what is being offered by the two organisations and developers currently favoured. Such proactive planning to take account of:
Making the sites no larger than that needed to secure outcomes that meet proven need;
The need for additional primary school places and planning that take regard of travel plans and maximum preservation of primary school catchment areas;
The need for additional and enhanced primary medical care provision;
Additional resources for a wide range of sport and leisure activities and that have full and long term availability to the community;
Accessibility of community resources, including retail;
Accessibility of sites;
Reducing the use and impact of the car;
Transport links to employment, railway stations, airport and major centres;
Minimal impact on the character of the three villages.

It is difficult to see the current Draft Solihull Plan as anything but a long term disaster for Knowle. It is essential that there is an objective, evidence based re-assessment of the plan for Knowle that evaluates priorities, responds to need, examines cost implications to the public purse and delivers housing in a way that has minimum detrimental impact on services, infrastructure, environmental issues, landscape and village identity.