Protecting and Enhancing our Environment

The policy should remove any reference to the Household Waste and Recycling Centre and Depot being moved from its present Bickenhill Site to Damson Parkway, and instead the plan should concentrate on how the Bickenhill site could be improved (better parking, access booking systems etc.).

Policy P12-para7 - Reference to moving the Household Waste and Recycling Centre and Depot from its present Bickenhill site to Damson Parkway is not legally compliant, or sound. A move is not justified on environmental grounds, and does not properly take account of the negative climate change / environmental impacts of an unnecessary move (Planning and Compulsory Purchase Act 2004, s. 19 (1A), nor the requirement for community involvement given the strong objections from the residents nearest to the proposed Damson Parkway site (s. 19 (3)). No evidence of co-operation with other agencies regarding this site move is provided.

This development should not take place for the above reasons, and the housing should be re-allocated to areas where the environmental impact would be much less, for example, around the outskirts of Solihull.

Barretts Farm development

This will materially affect the quality of the environment:
1) 900 homes x average of 3 residents per home = additional 2700 (approx) people added to the existing population, just from this one development. This is massive, and will forever distort its environment, and the nature of the village
2) THIS IS GREEN BELT LAND - why do we keep forgetting this, why do we keep finding reasons to justify its erosion, and why do we not find every reason to successfully find alternative solutions?

See Attached Letter.

See Attached Letter.

See Attached Letter.

‘The Environment Agency have set out a framework for our regulation and management of groundwater resource in the ‘The Environment Agency’s approach to groundwater protection’ document In this they describe their aims and objectives for groundwater, their technical approach to its management and protection, the tools they use and the policies and approach to the application of legislation. Land Contamination Risk Management (LCRM) guidance also provides guidance on how to manage these risks.

See Attached Letter.

REPLACEMENT TEXT (JUSTIFICATION)

Delete 2nd clause of 3rd sentence of paragraph 350 and replace with 'treating it locally wherever practical'.

Delete paragraphs 351-352 and replace with:
'The circumstance with regard to capacity needs within the Borough are detailed in the Council’s Waste Needs Assessment for Solihull, November 2018. In particular, future requirements are set out in Tables 49 to 51 of the Assessment. These relate to local authority collected waste; commercial and industrial waste; and construction, demolition and excavation waste. The Council will support the sustainable provision of waste management facilities to meet these forecasts at the dates and intervals set out in the tables (2020, 2025, 2030 and 2035).

Much of the required capacity is already in place. Appropriate additional provision will be made in accordance with Policy P12. In this regard, there are a couple of specific additional needs. These are considered below.'

Delete the 2nd clause of the 4th sentence and the 5th and 6th sentences of paragraph 353 and replace with:
', and further consideration of the recommendations has concluded that a site within the proposed employment land allocation at Site 20 Land at Damson Parkway offers the most suitable option.'

Add new paragraphs after paragraph 355:
'In addition to the above, the policy is supportive of the provision facilities for the management of secondary and recycled materials and minerals waste. This is in recognition of the emphasis given, in national policy, to the contribution that can be made from the sources in the supply of minerals.

Policy P12 also offers support, in principal, to the provision of facilities for the management of hazardous waste. This is because of a general lack of such capacity within the Borough.

Sustainable provision will thus be made in a variety of ways. The provision identified above will address shortfalls in capacity within the Borough in a move to help satisfy local needs. Developments will complement on-going provision at the Coventry EfW facility, the Birmingham MRF and the Packington composting facility and such additional sustainable capacity as may be commissioned through the Borough’s Municipal Waste Management Strategy.'

Delete 1st sentence and 1st clause of 2nd sentence of paragraph 356.

Delete 1st and 2nd sentences of paragraph 357.

Split paragraph 358 into 2 after 2nd sentence.

Add new paragraph after paragraph 358:
'On-site management shall be preferred unless the activities would result in unacceptable harm through impacts on the environment, on transport or on neighbouring uses or it is demonstrated that management elsewhere would have wider sustainability benefits. Particular opportunities include the on-site recovery of construction and demolition waste as well as provision of recycling infrastructure in housing, retail and employment developments.'

See attached

Delete 'within a defined area of search' from the 2nd sentence and replace 'significant' with 'major' in the last sentence of paragraph 360.
Redraft paragraphs 361-363 once production requirement has been revisited, adding the following policy commitment:
'At all times, the Council will aim to maintain a landbank of permitted reserves of sand and gravel of a least seven years.'
Amend Policies Map to identify Specific Sites, clarify MIN1 to MIN5 and show minerals Area of Search.

See attached

The Local Geological Site designation should be removed from the emerging policies map.

Pegasus Group are instructed to make representations to the Solihull Regulation 19 Local Plan (October 2020) (SLP) on behalf of our clients Kilbride Resources Ltd with regard to emerging draft Policy P12 and land at the former Arden Brickworks site situated to the south of the A45 as shown on the red line plan attached at Appendix 1. Our clients have an interest in the site as the landowner's preferred development partner.
Paragraph 38 of the SLP recognises at bullet point I that providing sufficient waste management facilities is one of challenges the Borough faces during the proposed plan period. This point is expanded on at p.19. which states that objectives of the SLP with regard to waste are;
• To promote the management of waste arising in the Borough further up the waste hierarchy and its treatment as a resource to be used wherever possible.
• To address the identified needs for waste management in the Borough.
Paragraph 53 states that the vision for the Borough with regard to waste is that;
" Solihull will have reduced the amount of waste produced in the Borough through increased recycling and re-use, eliminated the gap between the amount of waste arising and the capacity of its facilities.."
In order to address this matter the SLP identifies at Policy P12 the removal of land from the Green Belt to the south east of Damson Parkway/Old Damson Lane with an option for a relocated Household Waste Recycling Centre and Council Depot as an option on part of this land.
Draft Policy P12 – 'Resource Management' refreshes the existing Policy P12 in the adopted Solihull Local Plan (Dec 2013) and points to the need for focus on moving towards a net zero carbon economy with regard to the transportation of waste from source to processing facility with an associated sequential approach to the identification of the appropriate location for new waste management facilities.
The Cushman Wakefield 'Assessment of land for potential re-location of a Household Waste Recycling Centre and Depot' (June 2019) provides a significant part of the evidence base for the consideration of such facilities in the Borough with the northern and southern parcels of the former Arden Brickworks site being identified sequentially as the first and third most appropriate sites respectively within the Borough, whilst the allocated Damson Parkway site as the fourth most sequentially preferable site.
The Arden Brickworks site is identified on the existing adopted Policies Map and the emerging Policies Map as a Strategic Waste Management Facility, therefore the consolidation and expansion of waste management activities at the site would be held to be appropriate under emerging Policy SP12 criteria 3.ii.
Moreover, draft policy SP 12 criteria 5 states;
"Strategically important waste management sites within the Borough, where waste management activities will be supported in principle, are identified on the Policies Map. These sites include the site of the former Arden Brickworks in Bickenhill, which contains the household waste recycling centre, and a range of other waste management operations…" (emphasis added)
Draft Policy SP12 criteria 6 states;
"When investigating the suitability of sites for waste management operations in the Borough, the potential for consolidating or expanding waste management facilities at the former Arden Brickworks site …. shall be considered."
Draft Policy SP12 criteria 8 provides a list of 15 sub-criteria to be used in the consideration of waste management criteria proposals and include at criteria vi. and vii.
"vi. The potential for the co-location of complementary activities where there are no adverse cumulative impacts
vii. The contribution towards the restoration of former mineral workings in the Borough."
Our client's site is situated within the Green Belt. However, the southern part of the site includes a former quarry area, and given its identification in the emerging SLP as an existing Strategic Waste Management Facility, the location of the site with regard to the strategic highway network, its location in very close proximity to the NEC, Birmingham Airport and the strategic Arden Cross site, the potential for the co-location of waste recycling and energy generation facilities in an eco-park campus style development merits further consideration for inclusion as part of an allocation in the emerging SLP.
Our client's site would comply with criteria already contained within emerging Policy SP12 and has been identified in the Council's own evidence base as comprising the first and third most sequentially preferable sites for the relocation of a household waste management facility within the Borough.
The plan attached at Appendix 1 comprises only the brownfield and mineral extraction areas of the southern parcel of Arden Brickworks considered in the Cushman Wakefield report (and omits the area of green field agricultural land to the east of this area which is included in the parcel in the evidence base and contributes towards its lower scoring).
Attention is also drawn to the identification by the authority of a 'Local Geological Site' (LGS) designation at the Arden brickworks site. The site is not identified as a Local Geological Site on the adopted Solihull Local Plan Proposals Map nor it is it listed as a Regional Important Geological Site (RIG) or Local Geological Site in the adopted Solihull Local Plan. As an emerging LGS, the site would be subject to criteria 5 and 18 of Policy P10 of the emerging Local Plan.
Research into this matter has elucidated that the main geological value of the site is for educational purposes post GCSE, owing to the visible exposure of strata from the Triassic, Mercia Mudstone Group; "The strata consists of irregularly bedded red clay and mudstone, interbedded with green mudstone and green sandstone skerry horizons".
While visits to the site can be arranged for educational purposes, it should be noted that the site is privately owned and not publicly accessible.
It is also noted; as referred to in Chapter 10 of the Environmental Statement presented to the Development Consent Order Inquiry into the widening of Junction 6 of the M42, (prepared by Highways England and dated January 2019); that the mineral extraction permission at the site requires the restoration of the site once extraction is complete, at which point the currently exposed strata would be lost.
Whilst it is appreciated that restoration at the site might occur after the end of the emerging SLP plan period, it is requested that consideration be given to the removal of the LGS designation from the site and the emerging policies map and instead further consideration be given to the allocation of the site as an Eco Park for waste recycling and energy generation purposes. This may of itself present opportunities for the retention of the geological features of interest for educational purposes however this would need to be the subject of detailed further investigations.
Our client's site is suitable, available and deliverable and therefore offers a sequentially preferable potential alternative location to the Damson Parkway site for a new Household Waste Recycling Facility in the Borough, and an opportunity for such a Materials Recycling Facility to be combined with complementary energy storage and generation as part of a comprehensive approach to deliver a Waste and Energy Eco-Park development.
This comprehensive form of allocation would assist the Borough in moving towards net zero carbon emissions, with the Eco-Park attracting inward investment into the Borough comprising of waste management coupled with energy generation technologies to the benefit of the local economy and environment.

It is requested that the emerging SLP allocate our client's site at former Arden Brickworks as a potential Eco-Park for waste management, energy and employment related development in order to provide flexibility in the plan for the delivery of the Council's vision and objectives to provide adequate waste management provision to meet the waste management needs arising in the plan period within the Borough.
It is also requested that the SLP acknowledge in any potential allocation at the former Arden Brickworks site as shown in red on the accompanying site layout plan that these proposals would assist the Borough in moving towards net zero carbon emissions with the Eco-Park attracting inward investment into the Borough for co-locating waste management and energy generation facilities.
It is also requested that the Local Geological Site designation be removed from the emerging policies map.