Question 39 - Red Sites

I wish to Appeal this decision and ask that the Council re-examine our Submission for inclusion as an AHS, as I believe there are grave errors in the Council's failure to select the Site 88 as an AHS, as follows : -

- in the Council's Summary for this Site, when reaching its decision, it says -

1. - " Site lies well beyond existing Green Belt boundary in a lower performing parcel ".

This is manifestly incorrect, as the existing Built Up Area in the nearest position to the Site, is at the corner Widney Road and Four Ashes Road, which is only some 50 yards away -

2. - " An indefensible boundary would be established, thereby opening up the surrounding land for development".

Again this is disputed. Of all the Sites offered to the Council for designation as an AHS, this is probably one of, if not the most, easily defensible Sites that could be designated as an AHS, which would have clearly well defined, and substantial permanent and immoveable physical boundaries which would stop it being used as a precedent for other Green Belt Sites to be designated as an AHS.

a) - the Site fronts to and adjoins Widney Manor Road to the East, which is a long established made up road, being one of the three main access roads into the Town Centre over the M42 Motorway from the south of the Borough, as evidenced by its heavy private and commercial vehicular use to and from the Town Centre at all times of the day and night --

b) - It also contains several Bus services which regularly use Widney Manor Road, again at all times, people to and from the Town Centre, to and from the adjoining Widney Manor Cemetery. Also, the considerable numbers of parents and school children to the many schools in this part of the Borough, and also to and from Solihull 6 th Form Centre, further down Widney Manor Road. Plus commuters going to work in the many shops and offices in the Town Centre, as well as those passing through the Town Centre to get to other destinations, Widney Manor Station, Solihull Station, Birmingham City Centre, NEC, and elsewhere.

c) - to the South of the Site is the Council's own Widney Manor Cemetery, which obviously is now completely established and therefore a permanent and immoveable physical boundary -

d) - to the West is the Chiltern Railways Railway Line from Birmingham Snow Hill to Marylebone, London, again
a permanent and immoveable physical boundary -

e) - to the North less than 100 yard away, is the M42 Motorway, again a permanent and immoveable physical boundary -

f) - the existing immoveable and permanent and physical boundaries on all 4 sides of the Site are quite clearly and obviously capable of forming defensive boundaries as opposed to other proposed AHS's. If this Site is allocated as an AHS, no other Green Belt Site applying to be designated an AHS could possibly use as a precedent, that the Site was taken out of the Green Belt, and designated an AHS, as they would not have the necessary permanent and immoveable physical boundaries to all the sides of any other proposed Site, contrasted as currently already exists at Site 88, that would make it clearly defensible by the Council -

3. - " It would erode the gap between Solihull and KDBH and result in isolated encroachment into the countryside ".

This is also disputed.

a. - As shown in 2) above, this would not be the case -

b. - the Site is not " isolated" as claimed. It is part of a long established settlement of existing properties built many years ago, and would be no more than infilling in an existing ribbon development of houses either side of Site 88 that has existed for many decades -

c. - the Site sits on the South West side of Widney Manor Road, in between the four established houses that adjoin Site 88, and Widney Manor Cemetery Offices and Caretaker's house to the South of the Site, and to Blythe House and the Columban Fathers Blythe Hall and separate Blythe Hall Lodge to the North of the Site -

d. - as the above shows, the Site clearly cannot be claimed to be " isolated " when it is between existing housing on both sides of the Site, all of which with those other houses similarly front to Widney Manor Road itself, which cannot be by definition classed as - " isolated" -

e. - the existing housing settlement continues along the same side of Widney Manor Road to the traffic island outside of the entrance to Widney Manor Cemetery, where the settlement and existing housing continues further along the same side of the roadway up to the railway bridge, but after the Cemetery, the roadway then becomes and is called Four Ashes Road -

4. - "Site has medium/high accessibility in overall terms and is in an area with medium landscape character sensitivity, medium landscape value and a low landscape capacity to accommodate change " -

We dispute -

a. - " medium/high accessibility in overall terms " -

i) - It has very high accessibility, being immediately adjacent and fronting to Widney Manor Road itself, which as stated earlier, is a very busy and well used roadway by all manner of traffic types of vehicles and users, to and from Town Centre -

ii) - different bus services serving the various districts this side of the M42 use Widney Manor Road, and in fact stop outside the Site some 50 yards away -

iii) - there is also the extremely and usefully convenient and very well used Widney Manor Rail Station on the Chiltern Railways Line mentioned in 2 (d) above, which is no more than 750 metres from the Site -

b. - " and is an area of with medium landscape sensitivity, medium landscape value and low landscape capacity to accommodate change " -

i)- the Site has no redeeming or worthwhile landscape features that should be retained or protected, as it comprises old and unused agricultural land which has not been farmed or cultivated since approx. 1988 and for all intents and purposes is now just overgrown, and contains no landscape features of merit at all. It should therefore in fact be re-classified - very low landscape sensitivity -

ii) - there are only 12 other living trees on the whole of the Site, none of which are in very good condition and would need severe tree surgery if not complete removal. The same 12 trees being for the most part on the various boundaries of the Site. It should therefore be re-classified as - very low landscape value -

iii) - for the above reasons, it is also considered that the Site has a very high landscape capacity, which would be quite capable of handling and accommodating change as an AHS, as the Site slopes gently away from its frontage to Widney Manor Road and runs gently down the Site to the railway line. This would make a use of the Site as an AHS virtually hidden from and noticeable or visible at all from Widney Manor Road -

5) - " The SA identifies 6 positive and 4 negative effects and the site does not fit neatly with the spatial strategy as it appears visually detached from the nearest settlement " -

a. - for the above and other reasons, I would dispute that there are 4 negatives to the Site being designated as an AHS. For the reasons contained herein as well as the earlier Submissions in January 2017, I believe that the Site should now be re-assessed by the Council and its previous conclusions changed and
re-designated as a a Green Site, as it contains 8 out of 10 of the most important elements for consideration as an AHS are already present and identifiable in this Site -

b. - reference to - " it appears visually detached from the nearest settlement " - for the above reasons this comment is disputed. A Site inspection or even just a limited view of the Site from just Widney Manor Road, would show this is wrong as the Site is between old established housing on either side of the Site and on the same side of Widney Manor Road, being a part of an existing ribbon development of houses forming a long established sub-settlement of Bentley Heath itself -

By way of other general comment, I would also raise the following points : -

6) -

a) - Proposed Approach - paragraph 234, page 44 -

says - " Sites that are close to the existing settlement or are/ can be well-served by public transport will be preferable, " -

as previously stated, the current and existing bus services already travel along Widney Manor Road to which the Site adjoins and fronts to, and Widney Manor Station is only 750 yards from the Site. It is suggested, no other comparable Site is as well served by public transport than Site 88, that is already currently existing and not a proposed future or later date expectation -

b) - Site 8 - Hampton Road - paragraph 237, page 44 -

i) - says, - "The southern part of the allocation lies beyond Green Belt boundary, although it is immediately adjacent to the built up area of the settlement and would represent a continuation of the existing development along Hampton Road " -

ii) - Site 88 is also adjacent in distance terms to the built up area of the settlement, the same as Site 8 -

iii) - similarly, Site 88, would represent a continuation of the existing ribbon development along the same side of Widney Manor Road, (which is itself a continuation of Four Ashes Road), from the Offices and Caretaker's House at Widney Manor Cemetery. Past the existing and established 4 houses on that side of Widney Manor Road, all the way along past Blythe House, the Columban Fathers at Blythe Hall and Blythe Hall Lodge, up to the M42 Motorway bridge -

iv) - designating Site 88 as an AHS, would be no more than making it a logical infilling of the existing ribbon development of long established houses that runs along that side of Widney Manor Road -

v) - same paragraph says - " Whilst it is recognised that the site [8] lies within a parcel of highly performing Green Belt [ as opposed to Site 88 being classified as - " in a lower performing parcel"] it is acknowledged that it comprises a small part of a wider parcel [ Site 88 is an already well defined and completely self contained parcel of land, not being part of a wider parcel of land] -

vi) - it also says - " The site [8] is relatively well contained [Site 88 is completely well-contained as opposed to relatively well-contained] and a defensible Green Belt boundary could be provided " -

this comment is highly debatable and disputed, whereas Site 88, with the existing permanent and immoveable physical boundaries that surrounds the Site, the Green Belt boundary would always be clearly defensible and could easily be protected and defended by the Council if it were an AHS -

c. - Site 9 - Arden Triangle -

i) - paragraph 242, page 45, says - " These strong physical features would establish a logical boundary to define the extent of the land to be removed from the Green Belt " -

ii) - paragraph 243 says - " The site is an area with medium landscape character sensibility and low visual sensitivity. The landscape value of the area is medium with a low landscape capacity to accommodate new development " -

Whereas Site 88, was also, medium landscape value and low capacity to accommodate change. Why is there a difference to treatment of both Sites with identical comments regarding landscaping issues, and the fact that Site 9 does not contain existing logical and defensible permanent physical boundaries to all parts of the Site, whereas Site 88 does ? -

There appears to be a different treatment and distinction made between the merits of Site 88 with Sites 8 and 9, and particularly with Site 9, based upon the same criteria being applicable, but where Site 9 is designated Green and Site 88 is designated Red -

7) - Washed Over Sites - (Amber Sites) - land rear of 114 to 118 Widney Manor Road (Site 134) -

Says, - " As such development will take place to the rear of existing frontages [ same as Site 88 which has a relatively small road frontage, and any development would be to the rear of the frontage, and down the sloping Site away from the road, and be behind and to the rear of the existing adjoining houses both sides of the Site, and therefore not physically noticeable or visible from Widney Manor Road] -

8) - again there appears to have been different treatment between Site 134 and this Site 88. Bearing in mind, both Sites are on the same side of Widney Manor Road, both Sides are opposite to existing Green Belt land, and if the argument put forward that Site 134 would not impact on the openness of the undeveloped Green Belt land opposite and being included as Amber Site in the Draft Local Plan, that it must also equally apply to Site 88. I therefore believe Site 88 should also now be re-designated, see 9) below. Not to do so I would suggest might be considered as a harsh and unfair prejudice against Site 88.

9) - the Council have made no reference or even commented upon at all, that the Council in 1965, apparently Granted Outline Planning Permission for Residential Development on Site 88. (Paragraph 42, page 13, our Submission 15 th February 2017).

As the instances of the Council Granting Planning Permission, (albeit Outline Permission), were I would suggest much more restrictive and virtually impossible to obtain in 1965 as compared to the present day. That if the Council could therefore in 1965 override its general presumption against development in the Green Belt as inappropriate, other than for exceptional circumstances, was as a general rule not normally permissible. I would therefore suggest, it must carry very great weight and store upon that fact that in 1965, that the Council overruled its normal and general presumption of rejection of Green Belt Development as being inappropriate, but did so then and Granted such Outline Planning Permission for Residential Development.

Whatever were those exceptional circumstances in 1965 that persuaded the Council to abandon and overrule its normal and general presumption that residential development in the Green Belt was inappropriate, but that for Site 88 was permissible and granted Outline Planning Permission at that time, must still apply even more so today, and if for no other reason whatsoever, as being of itself a valid reason to now include Site 88 as an AHS -

I would suggest, that this is a very important fact that the Council cannot just completely ignore, and is most relevant to the Submission and reason for the same land as Site 88, now being included as an AHS -

10) - as no mention is made by the Council and it has not specifically answered the point, that it appears on the face of the Draft Consultation, that it has not thought about or considered the point I raised in my letter 20 th January 2017 and Submissions of 15 th February 2017, and that no value has been put on the important comment in the otherwise flawed PBA's Assessment of 28 th November 2016.

That is, in the section " Achievability", PBA said under Achievability Details - " Good marketability and/or viability
(likely to come forward within first five years) " -

I therefore find it hard to reconcile that PBA said Site 88 was both viable, and would come forward within first five years, which at the time of their Assessment in November 2016, would have meant they believed it would be forthcoming and available as a housing site by November 2021.

Given that the Local Plan is for the period ending 2033, I suggest that in the light of PBA's comments, it is irreconcilable that it should not be included as a Green Site suitable as an AHS in the current Draft Consultation.

To recap, I therefore feel that the above are more than just minor points but are serious and very important and compelling points for this Site to be re-allocated as a Green Site to be eventually designated as an AHS.

Bentley Heath Church of England School has not been consulted about a plan to develop site 207 with a relocation of the school - despite what the proposer may say. The school does not endorse the proposal which will be submitted by Savills on behalf of St Philip's Land. The school has dual ownership with Birmingham Diocese and as an academy is on land leased from SMBC. It also has St James' Church within the site and a consecrated holy space. If the school were asked to expand this would be achievable on its current site.

Sites 142 and 233 - Grange Farm Balsall Common - are discounted. The combined capacity of these sites is 2698. Although in the Green Belt and therefore should be protected, they are not in the Meriden Gap and therefore should not be considered as performing as highly as Barrett's Farm which is in the Meriden Gap. These sites on average are no further from the station than extreme parts of Barrett's Farm.
Along with the Trevallion Stud site, these could also provide support for a western bypass which would be far preferable to the eastern one proposed.

I would like to register my concerns and objections to the current draft local plan.
Shirley and Blyth Valley has now 38% of the proposed housing which is more than the lions share and will link many areas together i.e. Cheswich Green, Dickens Heath, & Tidbury Green. All will become just another hugh conurbation with no identity.

I believe the council has based it's calculation on the 2014 Office of National Statistics figures and there is a clear case that the 2016 figures could be used which shows a lower calculation.
There has been no consideration of increase of traffic on the current road system and public transport system, the Mott Macdonald plan was not obtained. The council state that public transport will be improved, however if there is no public transport now how can that be improved.
There is already a lack of local GP's and pupils are already travelling far and wide due to lack of schools in the appropriate areas. There are no plans in the current draft for extra GPs and schools.
With the current proposals the council would need to build 885 homes per year, a target that has never been obtained.
Site 4 an extension of Dickens Heath, proposed as it is near a station. Dickens Heath which won best village was based on all houses being within a 10 minute walk to shops, this is something which is already null and void. Site 4 states that improvements will be made to the infrastructure however roads cannot be improved as there are ancient hedgerows, which again the council appeared not to have done their homework. The council has asked for alternative sites, if being near a station is all that is required, have the fields to the east of Widney Manor Station been considered. Widney Manor Station is much better linked.
Site 26 I have no objections providing that the level of housing is kept as per the plan however the increase in traffic on Bills Lanes would need the Mott Macdonald plan being obtained prior to any permissions being granted.
However with this development then site 13 is the mitigation against the loss of green belt and would be beneficial for the community if this was designated a Village Green/ Nature Reserve.
What is quite frightening is that the HSR report into the historic past of Blyth Valley has not been acknowledged by Solihull Council, A report that was widely available and already printed. A Report that could have considerable bearing on future housing.

Nurton Developments considers that the correct site (Site 25) has been chosen for allocation at Hockley Heath and none of the red sites at Hockley Heath should be included for allocation. A summary is provided below of the reasons why each of these red sites should not be viewed favourably for allocation.

Site 13/121 - The development of this site would result in an incursion of built form into open countryside where no permanent physical features are present to establish a strong and defensible Green Belt boundary. The trees along the site boundary do not provide a readily recognisable feature that is likely to be permanent, as required by paragraph 139 of the National Planning Policy Framework. The site also has some constraints including Tree Preservation Orders and habitats of wildlife interest.

Site 14 - Given the presence of further low-density development to the south, it would be difficult to establish a defensible boundary to the Green Belt in this location. The site is affected by Tree Preservation Orders and a locally-listed building and is also within the setting of a listed building.

Site 38 - Development of this site would extend Hockley Heath into open countryside to the north and east where it would be very difficult to establish a logical and defensible Green Belt boundary. Only field boundaries separate this site from the wider countryside and they do not provide a readily recognisable feature that is likely to be permanent, as required by paragraph 139 of the National Planning Policy Framework.

Site 57 - This small site could only accommodate 4 dwellings and would require release from the Green Belt. It does not offer any defensible boundaries to which Green Belt boundaries could be re-drawn.

Site 120 - This site is detached from the main part of the settlement and does not relate well to the form of the settlement. Even if it were considered in conjunction with adjacent land for allocation, which would result in a very large and disproportionate urban extension to Hockley Heath, it would still lack a defensible Green Belt boundary. It would also reduce the gap between the village and
Blythe Valley Park/Cheswick Green, therefore conflicting with one of the main purposes of the Green Belt.

Site 145 - This site is remote from the built-up-area of Hockley Heath and would result in an isolated incursion into the countryside. It would not be possible to re-draw the Green Belt boundary to a logical and defensible boundary in this location.

Site 180 - The site extends out from Hockley Heath and does not relate well to the built-up-area of the settlement. The development would appear as an intrusion into the countryside and the site and lacks any defensible boundaries to which to re-draw the Green Belt.

Site 208 - This site is remote from the built-up-area of Hockley Heath and would result in an isolated incursion into the countryside. It would not be possible to re-draw the Green Belt boundary to a logical and defensible boundary in this location.

Site 416 - This site is poorly related to the form of the settlement, being located at the end of a ribbon of development, which it would continue into the countryside.

Site 417 - This site is detached from the main part of the settlement and does not relate well to the form of the settlement. It comprises an extensive area of countryside, development of which would be disproportionate to the village, appearing as urban sprawl. It lacks a defensible Green Belt boundary. Only field boundaries separate this site from the wider countryside and they do not provide a readily recognisable feature that is likely to be permanent, as required by paragraph 139 of the National Planning Policy Framework. It would also reduce the gap between the village and Blythe Valley Park/Cheswick Green, therefore conflicting with one of the main purposes of the Green Belt.

For the above reasons, and since Site 25 is free of constraints, well related to the form of the village, would represent a proportionate expansion of the village and is well-contained by strong and defensible boundaries, Site 25 is a justified choice for allocation over these other red sites.

For reasons set out in other representations, I believe that the proposed level of development in the KDBH area is excessive without admitting any Amber or Red sites as Allocated Sites. However, the relative assessment of Site 413 (Amber) against Site 207 (Red) is very difficult to understand on an objective basis.

Site 207 seems to have been rejected largely on the basis of reducing the separation between KDBH and Solihull. That is a very weak argument as:
o The separation would still be much greater than that between KDBH and Solihull close to Junction 5 M42; and
o There would still be significant separation through fields and then the very well defined impermeable barrier of the M42.

Development of Site 207 would be much more in keeping with the density and character of the surrounding area than Site 413. It would also be materially more compliant with key policies within the KDBH Neighbourhood Plan.

Access to Solihull Town Centre, M42, A34 and A41 would be considerably easier by road from Site 207 compared with Site 413. Surrounding roads are designed for greater throughput and pinch points around Station Road and Knowle High Street would be avoided.

The Council should look more closely at other sites listed in the Schedule of Assessed Sites set out in Appendix E of the consultation, in particular parcels such as 72, 107, 135, 207, 210, 244, and 344. Some of these seem to perform reasonably well but have been categorised as red, although it is not clear why. Also, if the Council is prepared to create new Green Belt boundaries as at Hampton Road, then, presumably, some of the concerns over these other sites might be overcome, rendering them preferable to the currently allocated ones. These other sites could contribute to a more dispersed pattern of development which would be more consistent with government guidance and have less impact upon, and be less damaging to the village character. and infrastructure of the KDBH area.

Alternative sites in the "gap" between Knowle & Solihull would be preferable to both the major proposed sites to the north and south of Knowle centre. Access to transport links, the M42 and employment areas would be far superior and have a less damaging, effect upon transport, congestion, parking & the quality of life for existing residents in Knowle & Dorridge. For example the "Red" site ref 207 (land bounded by Browns Lane, Smiths Lane & Widney Manor Road) would be more suitable than the land south of Knowle thus avoiding unnecessary intrusion into the Green belt.

See Letter

See Letter

This version of the plan seems to prioritise development of large scale new / green belt sites rather than more sensitive localised developments in and around existing developed areas. Whilst I'm sure this is the preference for property development companies (they can maximise profit per square metre) I really don't feel this is in the long term interests of the region from an economic, aesthetic nor practical perspective.

Site No. 207 Smiths Lane/Widney Manor Road - this would be more accessible sustainable than the Arden Triangle in terms of access to Solihull and the Motorway. It is not so congested as Knowle & Dorridge which would take away the problem of traffic south of the Motorway getting through Knowle High Street and Warwick Road. Also for consideration more smaller dispersed sites that would not have such huge impact on the heritage and infrastructure of existing residential areas. These could be built a lot quicker and be better for the people that live in these smaller communities.
Use alternative sites in the gap between Knowle & Solihull which would be preferable to both of the major proposed sites to the north and south of Knowle Centre. Access for transport links and the M42 motorway would be far easier and have a less damaging effect on the infrastructure, congestion of Knowle/Dorridge village, car parking, dr's and dentist surgeries, nursery and school places in the Knowle & Dorridge community. Red site 207 would be better option aswell areas north of Knowle around the M42 would give clear access to transport & commuter routes out without affecting Knowle Dorridge.

We submit that Site 81, Land North of Fillongley Road, Meriden, should not be omitted and should be included in the Submission Draft Local Plan.

This site immediately adjoins Meriden to the east and offers a highly sustainable option to bring forward additional housing growth as outlined in the Proposal Site Supporting Statement submitted with this response.

The site could be brought forward either on its own or as part of a larger sustainable northern expansion of the village between the existing settlement and the A45. Such a wider proposal could also facilitate an expansion to the primary school, as land to the rear of the school is also being promoted for development (Site ref 144).

The evidence base documents prepared to inform the Local Plan Review (including the Sustainability Appraisal, Accessibility Mapping Report, SHELAA, Green Belt Assessment, Landscape Character Assessment and Topic Papers) demonstrated that Meriden provides a sustainable development location. The village offers a number of community facilities, can be easily accessed by public transport and, given the village's location off the A45, is within good proximity to major employment centres. It is also very close the HS2 Interchange Station. New development at the edge of the village would have no higher landscape impacts and effects on the function of the Green Belt than other village locations. It is therefore inadequate for the Draft Local Plan Review to only include one housing allocation (Site10) for Meriden. This site was originally for 50 dwellings although is now suggested for 100 dwellings. This is still insufficient and we consider that the village provides far greater scope to accommodate housing needs. It is not clear from the Draft Local Plan Review evidence base or this latest Supplementary Consultation why the decision has been taken to only focus a very modest amount of development at Meriden. For example, a much larger allocation has been identified in the Draft Local Plan Review in Hampton-in-Arden, a similar sized settlement to Meriden with a similar level of accessibility and service provision. We note from the Meriden Housing Needs Survey dated August 2018 that the demand for local housing itself is 45 units. This is before any allowance is given for district or market area needs. Overall, it is clear to us that Meriden should have a far higher housing allocation than 100 units.

As set out in the Supporting Statement, Site 81 is well contained and would have a very moderate impact on the Green Belt. It is well located within easy walking distance of the centre of the village and the primary school. It is highlighted as a highly accessible site in the Council's Accessibility Mapping Report. It would have very limited ecological or landscape impact. The main constraint noted in the SHELAA is the lack of road access, but this can be overcome as the promoter controls a property fronting Fillongley Road where suitable access can be provided. This is set out further in the Supporting Statement. There are no other technical constraints to the development of this site.

Accordingly, it is requested that the Local Plan Review should include Site 81 as an additional allocation, either on its own or in combination with other sites between the settlement and the A45.

Alternative sites in the "gap" between Knowle & Solihull would be preferable to both the major proposed sites to the north and south of Knowle centre. Access to transport links, the M42 and employment areas would be far superior and have a less damaging, effect upon transport, congestion, parking & the quality of life for existing residents in Knowle & Dorridge. For example, the "Red" site ref 207 (land bounded by Browns Lane, Smiths Lane & Widney Manor Road) would be more suitable than the land south of Knowle thus avoiding unnecessary intrusion into the Green belt.

Why have sites 76 and 212 not been assessed for housing? Although they are in Green Belt, they are PDL and are near both Hampton and Berkswell stations. They are within easy reach of the motorway network. These could provide a purpose-built new settlement.
Sites 142, 198 and 233 could provide an alternative to Barratt's Farm and facilitate a by-pass to the west of Balsall Common. The site assessment has very similar attributes to site 1. It would provide a better site for a new primary school and could be developed ahead of the completion of HS2

Alternative sites between Knowle & Solihull would be much preferable to both the major proposed sites to the north and south of Knowle centre. Access to the M42, transport links, and employment areas would be significantly superior and have a much less damaging, effect upon transport, congestion, parking & the quality of life for existing residents in Knowle & Dorridge. An example being, the "Red" site ref 207 (land bounded by Browns Lane, Smiths Lane & Widney Manor Road) being much more suitable than the land south of Knowle - this would avoid unnecessary intrusion into the Green belt.

Alternative sites in the "gap" between Knowle & Solihull would be preferable to both the major proposed sites to the north and south of Knowle centre. Access to transport links, the M42 and employment areas would be far superior and have a less damaging, effect upon transport, congestion, parking & the quality of life for existing residents in Knowle & Dorridge. For example, the "Red" site ref 207 (land bounded by Browns Lane, Smiths Lane & Widney Manor Road) would be more suitable than the land south of Knowle thus avoiding unnecessary intrusion into the Green belt

I believe that Red site 207 ie the area bounded by Browns Lane , Smiths Lane and Widney Manor Road should be considered for development.I think it would be preferable to build on land near to the M42 than take large quantities of Green Belt Land adjacent to Knowle and Dorridge although i accept the benefits of developing Arden School and providing some additional housing on the northern part of the Arden triangle

I believe that when considering red site 207 against amber site 413 it is difficult to understand objectively. Site 207 has an indicative capacity of 300 dwellings. It appears to have been rejected because it reduces the separation of KDBH and Solihull. This does not correspond with the much smaller separation go the two areas by the M42 junction 5 in Knowle. If site 207 were admitted there would still be a significant area of agricultural land between Browns Lane and the M42 which itself is an impermeable barrier. The housing adjacent to site 207 is much closer to the density and character of a proposed development at site 207. Access to Solihull, and national transport links would be easier than from site 413 and would not additionally load Station Road and other pinch points indicated in the KDNH Neighbourhood Plan. Site 207 should be ranked ahead of site 413 for development.

Sites in the "gap" between Knowle & Solihull would be preferable to the proposed sites north and south of Knowle centre. Access to transport links, the M42 and employment would be far better and have significantly less impact on parking, congestion, and quality of life for residents in Knowle & Dorridge. The "Red" site ref 207 (land bounded by Browns Lane, Smiths Lane & Widney Manor Road) would be more suitable than the land south of Knowle and avoid destruction of Green belt.

Red site 207 would involve no destruction of green belt; would create housing nearer to the sources of employment and thus save travel time; emissions and the traffic chaos that will entail if the arden triange or amber site Re A5 and 413 are developed.

The Council should consider the allocation of further sites away from Knowle village where accessibility to Widney Manor Station, Solihull and Stratford Road and the M-ways would be easier. For instance, Smiths Lane/Widney Manor Rd. Bentley Heath, Earlswood Road Dorridge and Kixley Lane Knowle.

Red sites 42, 49, 81, 97, 107, 128, 195, 197, 211 and 226 should be considered for inclusion to allow for reduction in proposed allocations in other areas which are significantly overweight, inequitable and in direct contradiction to the core principles within the Local Plan. Development of these red sites would not inhibit the Council's desire to retain the Meriden Gap, do not pose threat to the demarcation of exiting settlements and, in conjunction with the development of amber sites proposed above, would provide a more even spread across regions to limit unjustified focus on certain areas (primarily Blythe).

Please see attached document

see attached letter

see attached letter

see attached letter

Yes I believe that development should be concentrated to the north of Knowle/Dorridge particularly no. 207 Smiths Lane/Widney Manor Road. Other sites in the 'gap' between Knowle & Solihull would give easier access to transport links, M42 and would be far less damaging in the way of transport congestion, parking and the infrastructure and quality of life for existing residents in Knowle & Dorridge and would preserve the Green Belt on the proposed Site 9 and the amber site Ref A5 & Ref 413. The Green Belt should not be down graded for development as it destroys the historic settlement.

Land between 39 and 79 Earlswood Road

Question 39: Are there any red sites omitted which you believe should be included; if so which one(s) and why?

These representations are submitted by Knight Frank on behalf of the landowner, in response to the above consultation document and in relation to land between 39 and 79 Earlswood Road.
The Solihull Local Plan Review Draft Local Plan Consultation identifies the site Ref: 210 as being red. We set out bellow the reasons why we believe this site should be considered appropriate for development.

Site Context
The site comprises of paddock land located within the Green Belt, on the southern side of Earlswood Road, Dorridge, just to the east of its junction with Hansell Drive. On the opposite side of Earlswood Road is residential development, comprising relatively modern mostly two-storey detached houses of varying design and appearance, which are part of the built up area of the village. The site is an infill plot between existing properties to either side: to the west lies no.79, a very substantial dwelling; to the east is a ribbon of development comprising mainly of substantial houses.

There are no physical constraints on the site. The site is relatively flat with no topography issues. The Environmental Agency (EA) identifies the site as being located within Flood Zone 1, with the least probability of flooding. No statutory or locally listed buildings and/or monuments are located on, or in close proximity to the site. There are a number of locations for potential access along Earlswood Road including an existing agricultural access point from the sites north-east corner. Except for the southern boundary, the site is largely contained by mature, native hedgerow interspersed with mature trees which restricts views in and out of the site from Earlswood Road.

Potential Use
An outline planning application has been submitted for the erection of a care home (use class C2) comprising up to 81 bedrooms. The development would help to meet the urgent identified need to secure additional care home capacity within the Borough.

Site Deliverability
National Planning Policy Guidance (NPPG) sets out that when judging the deliverability of a site for plan-making purposes an assessment should be made regarding the suitability, availability and achievability of a development occurring. These factors are addressed in turn bellow.
The site was identified within the Solihull Strategic Housing and Employment Land Availability Assessment (SHLAA 2016 ref. 210) as being appropriate for a 31 unit residential scheme. The site assessment demonstrated that the site has no physical constraints and performs well against the suitability, availability and achievability criteria.

Suitability
Whilst the site is in the Green Belt, the Draft Local Plan Supplementary Consultation: Site Assessments Green Belt Assessment found that the land was a lower performing parcel (RP47) overall with a combined score of 5. This suggests that the site is not essential to the significance of the Green Belt.

The Site Assessment identifies the site as having low/medium accessibility. We consider the site to be in a sustainable location. The site is well served by existing roads. Dorridge primary school is located 1.1 miles from the site. The nearest surgery is located 0.9 miles from the site. The nearest bus stop is situated on the corner of Hansell Drive and Grange Road within walking distance (330m) of the site. This provides high frequency connections to Solihull, Hockley Heath, and Wythall. To add to this, Dorridge Train Station is just 0.8 miles from the site and provides local trains to Warwick, Leamington Spa, the Black Country and Birmingham, and inter city services to London Marylebone.

The Site Assessment states that the development of the site would create an unacceptable incursion into the countryside, create an indefensible Green Belt boundary and set a precedent for the development of surrounding land. The site is essentially an infill plot between existing properties on the southern boundary of Dorridge. Rather than lead to unrestricted sprawl, the development would simply continue the existing line of development along Earlswood Road. As such, the site would be viewed and perceived as part of the linear development along Earlswood Road, and more broadly as part of the outer residential development at the southern edge of Dorridge. The development of the site would not lead to encroachment into countryside. The site is constrained by existing development on three sides which have set permanent and defensible boundaries, whilst new landscaping and planting along the southern site boundary would restrict encroachment and provide an improved buffer.

The Landscape character assessment found that the landscape character sensitivity of the site was medium. The site is largely contained by mature vegetation which restricts views in and out of the site. Existing trees and hedges could be retained and enhanced to create an attractive new landscape setting which would mature and compliment the area in landscape and visual terms. An effective landscaping strategy would keep the views out from the gable ends, as Broadacre Gardens are located to the east. To add to this, groups of trees and a new native hedge could be planted along the southern boundary. This would help to mitigate the visual impact and in turn the openness impact of the development when viewed from the south.

Availability
An outline planning application has been submitted for the erection of a care (use class C2) comprising up to 81 bedrooms. The landowner owns the freehold of the full extent of the site outlined in the attached plan. The landowner fully supports these representations that are submitted on their behalf. There are no legal issues, the site is in single ownership, and is therefore able to come forward for development without delay.

Achievability
The landowner has already engaged in a formal planning process to achieve a desired consent. There is a strong prospect that the site will become available for development within 0-5 years of the plan period.

Conclusion
In summary, the Solihull Local Plan Review Draft Local Plan Consultation should consider the site as appropriate for development. The site is suitable, available and achievable within the Plan period. The site has no physical constraints; is in a sustainable location; and is essentially an infill plot which would continue the existing line of development along Earlswood Road, and the southern boundary of Dorridge more broadly.

Yours sincerely,
Tom Stanley

Q39 - Red Sites

There are no red sites in Knowle, Dorridge and Bentley Heath that should be included as housing allocations.