Alternative Site Suggested (Call for Sites)

The emerging draft Local Plan Review has found it necessary to release land from the Green Belt in order to meet the Council's housing targets. Given the shortfall within the wider Housing Market Area and the potential requirement for Solihull to accommodate further dwellings within the plan period, particularly to address Birmingham's significant shortfall, it will be necessary to identify further sites for development within the Borough and further Green Belt land release is likely to be necessary.

These representations therefore promote land to the west of 227 Lugtrout Lane as suitable for residential development and it is requested that the Council consider its release from the Green Belt. The site was considered a suitable site for development which was available and achievable, scoring highly on all matters considered in the Council's SHELAA (site ref 28) and in accordance with the recent White Paper on housing, local planning authorities should be looking to allocate sites for smaller developments to meet up to 10% of their housing targets. This site would suit that purpose.

The site is currently located in Green Belt and the Local Plan Review is an appropriate place to review Green Belt boundaries to identify land to meet need, which, as discussed above, this would do. The Council's own Green Belt Study identifies the land as lower performing when considered against the objectives of including land within the Green Belt for all purposes except one, where it is considered to perform 'moderately' in preventing neighbouring towns from merging. The release of this land from the Green Belt would not result in the merging of any settlements. It is a well contained piece of land which has development surrounding it and its release would not adversely affect the role or objectives of the Green Belt.

In summary, it is evident that further land will need to be identified for housing to meet the full need, once fully identified through the Local Plan Review process and joint working, particularly with Birmingham City Council. The site promoted in these representations would assist in meeting the Solihull housing need and also the Government's direction in the White Paper stating that local planning authorities will need to provide 10% of housing targets as smaller size allocations.

Please find attached the Response of The Knowle Society to your Consultation of the draft Local Plan 2017 Review.

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.

As a resident of Shirley South I am getting increasingly concerned about flooding that is affecting gardens in the area and also the effect of development on the land at Site 13. Site 13 has a number of eco systems that range from grass land to marsh and heath land, evergreen forest and mature deciduous trees and hedgerows. There is a network of drainage ditches and well-established farm ponds and also a sink area which is effectively bog land. The area is very wet and for the most part of the winter is very boggy due to the very high water table and the constituent soil composition. This results in heavy flooding across most of this low lying area. Many of the houses that back onto the fields in Langcomb Road experience flooding in their back gardens on a regular basis. A phenomenon that has reduced to an extent following the intensive planting of Christmas trees in the field adjacent to the gardens.
If the proposed development of Site 13 was to go ahead then there would be significant effects on the water table in the area, both in terms of run-off and drainage. The Local Flood Risk Management Strategy from April 2015 doesn't factor in surface water meaning that the flood risk at site 13 is significantly underestimated. The long term predictions are for wetter weather throughout parts of the year. I am concerned that the constraints map used to detail the flood risk across the borough doesn't fully capture all the areas of concern, especially Site 13.

Any significant expansion of rural villages/settlements should be directed away from other conurbations and not reduce the green belt between Coventry, Burton Green and Coventry.
No mention is made of using Brown field or previously developed Green field sites although this is said to be a guiding principle.
The LPR evidence base is flawed. Although it purports to use a pseudo-scientific method to identify sites the actual scoring is subjective and in some cases incorrect.
There are sites in Dorridge and Barston which may be more suitable and are further from the boundary with Coventry thus protecting the Meriden Gap.

The proposal to build 1215 new houses in Balsall Common (1350 with current permissions) represents a strategic change which will both fundamentally change the balance and nature of the existing community and will overwhelm already precarious village infrastructure.

Expanding the existing settlement by over a third is disproportionate when measured against the impact on other areas such as Dorridge which have equally good transport links and better infrastructure provision.

The plan provides no convincing reason as to why similarly rated sites in these areas have been disregarded in favour of Balsall Common options.

A failure to spread development more evenly loses the opportunity to deliver housing needs without major disruption to infrastructure and with sensitivity to existing residents.

The three sites proposed for Balsall Common all utilise green belt in priority to a number of potential PDL sites all of which appear to have been disregarded without a reason being given.

As such I regard the proposals as inconsistent with existing NDDP requirements and Solihull's stated strategy. Why is this being ignored in the case of Balsall Common?

In particular, the size of the proposed Barratts farm development when combined with major developments such as HS2 and planned for west Coventry places unacceptable pressure on existing green belt and in doing so threatens the very essence of the Meriden Gap.

The siting of such a major development is also inconsistent with the Plans stated sustainability objectives. Building housing in the south east when employment opportunities are in the North and West with an absence of reliable sustainable transport options can only serve to further impact existing road congestion.( see further comments on infrastructure requirements below)

I understand that that more housing could be created by resurrecting the Berkswell Parish Council proposals for use of reclaimed land at Cornets End Lane for creation of a new settlement. Has this been considered and if so why was it rejected?

Please find attached an objection to the allocation of Site 4 for 700 dwellings.
As a resident of Dickens Heath for 18 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. Other sites in the Borough are 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 small/medium sized housing allocations rather than the almost entirely proposed large housing locations which would be controlled by a few main house builders as suggested in the recent Housing White Paper.
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. 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.

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.

I am writing to object to Allocation 4 Land West of Dickens Heath set out in Solihull's Draft Local Plan and provide detail of my objection below:
Maintaining greenbelt, such as that between Dickens Heath and neighbouring Majors Green, which allocation 4 encroaches upon, is vital to preventing 'urban sprawl', and stopping towns 'joining up'. In this instance, the urban sprawl of Solihull, and Dickens Heath towards Majors Green and Wythall in Worcestershire.
The development of allocation 4 and/or 2, would both worsen already congested roads and accident 'hot spots' on the west and north of Dickens Heath on junctions of Haslucks Green Road and Tilehouse lane, and Haslucks Green Road and Bills Lane.
Transport and infrastructure serving the area of Dickens Heath and Majors Green, which is already woefully under-serviced, would need to be vastly improved at significant financial cost, to service the proposed development (at allocation 4) and curb the likely environmental impact of increased road usage associated with development in this area. Developments close to HS2, and allocation 11 at TRW would allow for developments of a similar size but are already excellently served by existing transport infrastructure, and where it would be comparatively cost effective to increase capacity. Alternative Brownfield sites should be re-developed, or their use maximised prior to beginning to consider the needless destruction of precious greenbelt on the site of allocation 4. There is plenty of other, more suitable land locally that could be built on, and a similar housing capacity could be achieved significantly more cost effectively. In 2014, a Campaign to Protect Rural England report found that there is enough suitable brownfield land, available now, for at least one million new homes. A number of which are identified in Solihull's Draft Local Plan, including allocation 11 at TRW and Blythe Valley. The Government Planning Policy states that changes to "Green Belt boundaries should only be considered in exceptional circumstances" and development in this area fails to meet the exceptions stated including (i) building for agriculture (ii) extension of existing building (iii) infilling in villages. This particular area of Green belt provides for well established and long standing opportunities for outdoor sport and recreation, which could
be destroyed under the current Draft Plan, or moved at unnecessary great financial cost.




The proposed development in allocation 4, exceeds the capacity of existing public amenities and infrastructure, including schools, a medical centre and shops built specifically for the existing Dickens Heath Development. Additionally, Dickens Heath already provides for some further additional housing within its existing boundaries, which are still in development. Solihull's Draft Local Plan itself recognises Dickens Heath as an "attractive" "multi-award winning village", whose development was guided by an "architect-led master plan". In addition a stated objective of Green Belt allocation is "preserving the character" of areas. Comparatively higher-density development, which is out of character with the existing development, as set out in allocation 4 of the Solihull Draft Local Plan serves to be detrimental to the character of both Dickens Heath and Majors Green. Indeed they will 'merge' together should the plans for allocation 4 go ahead. It is my hope that you will take into consideration the strong views of the majority of residents of Majors Green in the consultation.

Please find attached my comments in response to the invitation to comment upon the Draft Local plan.

COMMENTS ON SOLIHULL DRAFT LOCAL PLAN
February 2017

Thank you for the opportunity to contribute to the current consultation on the Solihull Draft Plan. My comments are specifically regarding the proposals for Balsall Common and focus upon:

1) The issue of the disproportionate allocation of new housing to Balsall Common, compared with both Knowle and Dorridge, both of which have well established town centres, unlike Balsall Common.

2) The need to develop a comprehensive Plan for Balsall Common which considers improvements to the infrastructure necessary to support any proposed increase in population.

3) The clear logic and evidence for accommodating all proposed housing on the Barrett's Lane site and not developing any of the other suggested sites.

It appears that the number of houses allocated to Balsall Common is disproportionately large given the size of allocations to other locations within the Borough, which have a greater capacity to accommodate sizable developments and which also have better infrastructure to support growth than Balsall Common. Both Knowle and Dorridge have sizeable and well established "town centres" which are cap.able of supporting additional demands, unlike Balsall Common which has a small, restricted and inadequate centre. Parking at Balsall Common centre is also significantly limited and the opportunity to utilize the former Partco site at the rear of the existing shops has been lost with the development of housing, which is currently under construction.

Similarly the transportation and public transport links to are vastly superior to Balsall Common, with the former being much better served and more frequently served by trains and both have more frequent bus services. Also proximity to the M42 is better at both Dorridge and Knowle.

The exercise currently in hand is clearly focused on housing allocations and there appears to be very little evidence of any rigorous or conclusive thought having been given to the broader planning issues and consequences of potentially increasing the housing stock by, up to 1150 new homes, in terms of the impact on existing services and infrastructure within Balsall Common. There needs to be a more comprehensive approach to the future planning and development of Balsall Common alongside the current single focus upon housing allocations. It is essential that the current process include, simultaneous to the consideration of optional housing sites, appropriate discussion and a comprehensive examination of the improvements to infrastructure necessary to support any growth in the housing stock and population, as well as securing improvements for current residents.

I am aware that there has been consideration within some of the developers early schematic plans of location of "open space' and "additional schools" and the like, but again, a much more strategic and comprehensive contextual approach needs to be adopted. There is a danger in the presumption that the impact of additional housing can be met within the finally designated housing areas as many of the impacts will be felt well beyond the boundaries of the new housing sites. Developers will obviously offer planning gains within their proposals, possibly to minimize expectations placed upon them by Section 106 agreements and planning approval conditions, but again such altruistic offerings are likely only to benefit their own proposal and we need to return to the consequences of additional housing upon the whole and entire settlement both existing and proposed.

Unless the issue of the impact of the proposed developments upon the existing and projected infrastructure is properly analysed and solutions identified and detailed, enlargement of the settlement, at the scale envisaged, will be rather like building an inverted pyramid, the base of which is ever increased whilst the grounded apex becomes ever more unstable, with inevitable and predictable consequences.

Thirdly, regarding the sites preferred by the LPA, I'd offer the following comments:

The Barrett's Lane site (Reference 33 /244 Barrett's Lane Farm, BC Meriden 50.65 Forms part of amalgamated site 1002) is easily the most appropriate and feasible site to accommodate the entire allocation. It scores well in terms of its development potential in the Green Belt Assessment: Appendix F : Overall Score Map. Similarly, it is supported by development potential in terms of proximity to transport links, (particularly if the Balsall Common by-pass is completed) as well as access to other existing facilities. The location close to the railway station is consistent with the views expressed in the current 2017 White Paper on Housing and rational regarding the current thinking and policy on sustainable housing, which Balsall Common desperately needs.

Reinforcing the appropriateness of development at the Barrett's Lane site, the Landscape Assessment of Sub-Area 5 (The Balsall Common Eastern Fringe) (on page 42) and the locus of the Barrett's Lane proposals, identifies the area as being lower in landscape quality, with an overall assessment of only "medium".


The Frog Lane proposal (Reference 75 /12 Land at Frog Lane) scores similarly in Appendix F : Overall Score Map. However some aspects of the Green Belt Assessment: Appendix G : Highest Score Plan identifying site RP59 with a score of 3 (the highest category) for certain categories of assessment.

However, the location of the site, which is some significant way from the current village centre and even further from the railway station and other key facilities, raises additional questions about its suitability. Presumably the existing road (Frog Lane) would need to be upgraded and given the relatively small number of houses (the site is only 5.44 hectares) this may not justify the investment? It is also presumably, because of its isolated location, not an ideal location for affordable housing and would generate extra and vehicular movements on inappropriate roads.

Also any development in this direction opens the probability of further incursions into the Green Belt in a direction which is counter-intuitive to development around rail stations.

The proposal to develop 800+ houses at Grange Farm is fundamentally flawed in a number of respects. In the Green Belt Assessment Appendix F: Overall Score Map the Grange Farm site scores 7, which is higher than the Barrett's Lane, Meeting House Lane and Windmill Lane Sites. Together with fact that the Grange Farm site is further from current facilities makes it difficult to understand why it would be considered. At the exhibition by potential developers (held at St Peters Church Hall) much was made of the intentions to offer "infrastructure" alongside the development. The attraction of "infrastructure" at Grange Farm needs to be very closely examined and rigorously tested within the context of the entire village (as discussed above), in so much as a sub-centre at a location which is isolated from current infrastructure, could create additional problems for both the existing facilities and the transport network. It would simply be providing facilities in the wrong place.

In addition, the commentary contained in the Landscape Assessment (page 38) on Sub-Area 4c (which is the area to the west of Balsall Common) describes the Landscape Character Sensitivity of this sub-area as High. It goes on to state: "The sub-area has clear legibility and is an attractive rural landscape with distinctive landscape features including the several historic areas that are intimate along with the well treed River Blythe corridor. The landscape is generally in good condition".

The Report goes on to note: "This sub-area would typically have an overall very low landscape capacity to accommodate change. Overall, this character area would be able to accommodate only very restricted areas of new development, which would need to be of an appropriate type, scale and form, and in keeping with the existing character and local distinctiveness of the area. Any new development should not result in the loss of the inherently rural character and should maintain the dispersed settlement pattern of the area".

As an aside, it's interesting and understandable that "busy roads" are identified as a landscape detractor, but it serves to reinforce that fact that additional development in this area would aggravate the traffic issues to the west of the village, which would not benefit from the by-pass.

Clearly the Landscape Assessment rates the quality of the western fringe (including the Grange Farm site) as higher than the eastern fringe (and the Barrett's Lane site). Also, the Assessment rates the western fringe as being more sensitive to change than the eastern fringe. Consequently the conclusion must be that of the two sites, the eastern fringe (including the Barrett's Lane) site would be preferred for development.

Beyond the Landscape Assessment and back to the issues discussed above regarding infrastructure and the need for a comprehensive planning approach to the development of Balsall Common, I would strongly reiterate the need to debate the capacity of the existing village in terms of infrastructure, alongside the consideration of the housing locations, which needs to be expressed in a village masterplan as (part of) the context for the new housing proposals! I've not found any debate about the fundamental questions, for example, about what sort of village / settlement Balsall Common wants to be in the future? The danger exists that we are deciding significant detail before we have determined the overall context or product! It's interesting to note that included in the Evidence Base is the masterplan for the central area of Solihull, which is clearly being used as both the context for future developments as well as providing instructions to the detail decisions that will be made.

Please find attached the detailed report compiled by the BARRAGE action group in response to the Draft Local Plan.

I believe you will have received many letters of objection already which make reference to this report.

Please note that the focus of the report responds to Q15 in the DLP in that we do not believe that sites 2 and 3 should be included in the plan and would propose that serious consideration should be given to the inclusion of site 240 instead.

see attached letter and report from BC BARRAGE action group

6. Please refer to full representation