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Draft Local Plan - Supplementary Consultation

Representation ID: 8848

Received: 15/03/2019

Respondent: Councillor Max McLoughlin

Representation Summary:

CIL payments/boundary issues between settlements.
Significant peak loading put on Dog Kennel Lane/Tanworth Lane/Blackford Road/ Haslucks Green Road/Bills Lane/Shakespeare Drive/Hurdis Road/Burman Road/ School Road and A34, with consequential air quality issues, especially near schools.
Rewording required of paragraph on integration, as problematic as many will not agree, and concern about merging settlements with distinctive identities. What does adequate separating function mean in practice?
Challenges over incorporating public transport, doctors, and secondary schools.
Proper delivery of cycling provisions.
Structural issues on Blackford Road.
Access to new school from Site 26.
Support replacement of Sportsfields, play space and green belt enhancements.

Full text:

It is of significance not only for the purposes of accuracy, but also to acknowledge that allocations on borders can have disproportionate effects beyond them, as opposed to within them. As the parishes are mentioned, they benefit from an opportunity to develop future Neighbourhood Plans and allocate resources through CIL. Many of the affected parts of Shirley will not have this benefit, though in the spirit of the law, they arguably should.
We have had good relations between the neighbouring settlements and hope this to continue. The Planning process plays a role in how it seeks to balance these potentially competing priorities. This is of most pressing concern in this region of the plan, due to the concentration of housing it is expected to take. In light of this we would hope that the Local Authority recognise this fact and see to reduce the proportion of development in this area.
There are significant peak loading issues on the road infrastructure.
The A34, Dog Kennel Lane, Tanworth Lane, Haslucks Green Road, Shakespeare Drive and Bills Lane are all experiencing peak demand issues. There are air quality issues that are borderline legal in the area. The fact that locations that are of greater concern to residents are near to schools and that potential developments would likely exacerbate vehicle movements and air pollution, means that there is considerable resistance to the scale of development in this area.

"New and existing communities will be integrated". This wording is problematic.
Whilst I recognise that the intention of stating "new and existing communities will be integrated" is to stress that new developments brought forward through the Local Plan process will be with a vision of integrating them into adjoining developments, there will be many who may not construe this as such. There is considerable concern that separate settlements, with distinctive identities may be merged. The fact that the plan acknowledges the different timelines of the many settlements exacerbates this potential confusion.
I am confident that this is not the intention of Planning officers at Solihull Council, as stated in later paragraphs, though would hope the wording can be revised in future versions so as to avoid any misunderstandings.

Solihull Council can offer reassurances to residents by expressing what "adequate separating function' means in practice.
The recent removal of Site 13, which has been warmly received in the community, is now replaced with a new site that presents as narrow a gap between Dickens Heath and Shirley as Site 13 would have.
Higher populations are necessary but not sufficient in delivering Public Transport improvements.
Improved Public Transport - A higher population gives greater potential for improved public transport services to be viable, e.g. better frequency of bus services
There are several factors that are needed to deliver Public Transport Improvements as development alone will not do so.
1. Developments have to accommodate access for buses where possible. Creating developments that have through connection, as was originally planned for Blythe Valley Business Park, prevent public transport access. This is not possible, nor appropriate at all sites, which I will make further reference to later. Similarly, the development of Dickens Heath has prevented the possibility of bus routes to the centre of the settlement. This is where the concentrations of people live, which are needed for viable services.
2. Developments have to provide concentrations of people with reasonable walking access to transport corridors. This means that densities of housing should be spatially arranged accordingly. There has been a failure of this with Site 11, which has already been given partial approval. The most viable locations for higher densities of housing will instead be occupied by car dealerships. This has been in the hands of the applicant in that specific instance, though developing masterplans accordingly can help to facilitate better plans in the future and hopefully prevent future missed opportunities. As the developments in the Blythe area are primarily lower density urban extensions they are unlikely to yield the concentrations for viable routes.
3. Public Transport improvements need to be coordinated at a regional level. Currently, the provision of services is wholly inadequate to deliver modal shift. Nowhere is this more evident than in the locale of 'Blythe' as this report defines the area and Shirley's environs. Urban extensions to an area with already worryingly poor bus services are unlikely to yield great improvements. Especially if the reasons why the services are poor is not addressed by the development.
4. All transport operates on nodes. Travel takes place between points. Journeys are between two or more nodes. Bus routes go between 2 nodes (1 with circular routes), with stops at others. If there is no route onwards from a location, then it is unlikely to benefit from good bus services. Those travelling from the urban extension around Shirley tend to want to go to either Solihull, Shirley or Birmingham. There is limited access to Whitlocks End and Widney Manor train stations, and Solihull Town Centre, but only subsidised bus routes operate within the majority of this area. The development is not on a corridor between two settlements that can carry enough demand to operate as a node. It will mean that public resources are deployed to address a problem built in from design.
5. Even if all the stars can be aligned, people do not switch to sustainable travel unless it outperforms private cars on either:
i. Price
ii. Convenience
iii. Reliability
iv. Safety
v. Cleanliness
These factors are, again, outside the remit of the Council's Local Plan. If setting out to achieve these objectives, thorough work needs to be conducted in conjunction with the Combined Authority to ensure successful delivery and uptake is achieved.
Whilst I want to see this improved, there is reluctance to shift for a number of reasons.
Pedestrian and Cycling Connectivity - Cycling and walking links to Whitlock's End station, village centres, local services and Shirley town centre will be improved to facilitate active travel and reduce car dependency, especially for short journeys
Firstly, the demographic composition of the area means that there is reluctance for some to cycle. It has to be understood that there will be many who will not, or cannot use active travel.
Those who are able to, but not there yet communicate significant barriers. The most notable is the safety of cyclists. Where possible bikes need to be separated from vehicles. This is most important on rural roads, where road verges may be in particularly poor condition, vehicle speeds high and visibility low.
The worst possible outcome is that white lines are painted on the edge of roads, as has happened previously in the borough. This in many instances worsens cyclist safety. It creates a defined area that many motorists will believe cyclists should not stray out of. Not only is to legal for cyclists to use the same extent of carriageway as motorists, there are times when surface conditions necessitate it.
Any work on cycling and walking infrastructure requires considered working out with residents beforehand. This should be with residents who do not yet use active transport to ensure any connectivity improvements actually yield modal shift.
There are limitations with what can be done as far as highways improvements go.
Highway improvements - It is likely that highway improvements will be required at various locations in the settlement, as well as capitalising on highway improvement initiatives along the Stratford Road. These could include speed reduction measures, access and junction improvements around development sites, highway capacity improvements or adjustments to traffic priority arrangements.
Whilst developments that result in increasing volumes of vehicles on roads requires attention, there are significant limitations. They include, but are not limited to:

1. Blackford Road will experience a significant amount of traffic from the planned developments as set out in the supplementary update. Blackford Road did have a weight limitation on it for many years, though it has gone unenforced, with neither police nor council having resources to adequately police it to change behaviour. Moreover, changes to bus routes mean that the weight restrictions will roundly be ignored. Those weight restrictions were put in place due to the structural damage that has been recurring both on the road surface and neighbouring properties. There have been numerous investigations between Solihull Council and utilities companies that have not yielded a comprehensive explanation, nor solution. Many plausible explanations have been made, from soil composition, subterranean water erosion, desiccation, and thermal expansion. Sadly, the only certainty is that increasing volumes and weight along this stretch of road will have detrimental impact on the damage to the road subsurface and the nearby properties.
2. Increasing volumes of traffic in the area adjoining the A34 and along it will have a detrimental impact on air quality. Whilst we are hoping that Electric Vehicles (EVs) will yield improvements in some of the airborne pollutants, evidence suggests that some of the most problematic particulate matter (PM 2.5) is distributed at increased rates. Not only are PM2.5 problematic in and of themselves, the kind produced by EVs are the most problematic. Magnetite can cross the blood brain barrier and cause dementia and are produced in the braking systems of EVs. Before we see significant numbers of EVs on our roads, concentrations of traffic on the choke points of the A34 we will have increased Nitrogen Dioxide (NO2), Sulphur Dioxide (SO2), Ozone (O3) and PM2.5 from combustion engines. Moving vehicles through faster is not the solution.
A new school would be welcomed.
New Primary School - Pupils arising from Site 4 will be accommodated at the recently expanded Tidbury Green Primary school. A new two-form entry primary school, however, will be required to serve Sites 11, 12 and 25. The draft concept masterplans show the school situated on Site 12. Funding for the school will be expected via section 106 agreements associated with the development of the allocated sites.
However, the idea that a school can service Sites 11, 12 and 25 seems unrealistic. Walking from Site 25 to Friar's Gate (a closer but approximate point for the school, which the masterplan shows located at the back of the site) would take close to 1 hour 30 minutes. Whilst I am in favour of children getting familiar with active travel, 3 hours of walking around the school day is an impossibility and would create car dependence.
Working on the assumption that point 136 was intending to refer to Site 26, the new development off Bills Lane, instead is not significantly better. Whilst there is a walking route that could realistically be done in around 40-45 minutes, it is through fields, so again fails to appear realistic. Rather than walking, the more likely outcome would be to push cars down Bills Lane, Shakespeare Drive, Hathaway/Stretton Road, Tanworth Lane, Dog Kennel Lane and onto Site 12. These are all roads that are experiencing significant congestion at school opening/closing times, so would be unrealistic.
What is of concern is that we are accounting for 2 new primary schools across the borough, but no secondary schools. The Department for Education has projected a 20% increase in secondary school places over the next decade, which our plans would be wholly unprepared to meet. Not only have schools been expected to fit more students into the same buildings, some have also addressed financial concerns by selling land, reducing their ability to expand further. There are concentrations of Secondary Schools around Tudor Grange, but only 1 in the area in question (Light Hall). Would it not be necessary to consider at least one new Secondary School within the Local Plan's period and wouldn't this area make for a viable location?
GP surgeries in the area are already stretched well beyond capacity.
Health provision - The Council will work with the Clinical Commissioning Group to establish the impact of new development on local GPs and other services, and how this can be addressed.
There is no surgery that I haven't either had direct experience of problems with or heard extremely concerning stories from patients trying to make appointments at, in the area. The fact that there is an intensity of extra care developments coming online within the area shouldn't go unnoticed. All residents deserve to be able to get an appointment with a GP in a timely manner. The increases in vulnerable residents with acute or complex needs will have bearing on services for all residents. To date, the measures to address this through the CIL and Section 106 payments have been wholly insufficient and should be factored into Planners' considerations.
Glad to see Sports fields given a greater degree of protection, considering the number that were to be lost under the last iteration of the Plan.
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard, including access and use by the wider community where appropriate.
Play and Open Space - This is welcomed, but not to a reassuring extent. Provision of play and areas of open space within potential development sites will be required. There is also a need to ensure that best use is made of existing green and blue infrastructure assets within development sites, together with provision for linkages to the surrounding area
There are examples of plans with play and open space on early drafts, that get eroded over the application process. There should be measures in place to ensure delivery is achieved, as play and open space provisions that are never delivered offer only salt in the wounds for those close to new developments.
With reference to the earlier point.
It is important that Site 26, if developed, directs any CIL proportion to Shirley South, rather than Dickens Heath. This is not to suggest that the Parish Council would utilise the funds poorly, as I'm sure there are ample needs for it in Dickens Heath, but more that the adverse impacts of Site 26 would almost wholly be experienced by residents in the Bills Lane area.
Green Belt Enhancements are to be welcomed, particularly if Site 13 can be offered additional protection.

One factor in favour of Site 4 is sustainable transport provision.
As I stated in my response to the Draft Local Plan Consultation, that whilst I do not support Site 4, it does offer the possibility of connecting Dickens Heath up to Whitlocks End Station. At present there is no safe active transport link between the village centre and the station.
However, there are concerns over whether a viable means of delivering this are demonstrated in the masterplan. There appear to be issues over how the site is integrated into the settlement, without disrupting the ancient woodland at Tyburn Coppice.