Policy P17 Countryside and Green Belt

The Strategic Green Belt Assessment should be updated to include an Assessment of Site 534 (land south of Park Lane, Balsall Common)

See attached

Consider whether retaining mineral sites in the Green Belt is appropriate.

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.

The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. 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, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

Consider whether retaining mineral sites in the Green Belt is appropriate.

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.
The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. 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, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

See attachment

The Plan should be amended to include safeguarded land to accommodate longerterm development needs

see attached representation form

I identified an additional similar area of 200 dwellings which I put forward at the time, and described as the Oldway Drive Area. (see Appendix A)
Deletion of P17 3 i
Revision of para 423 to read: ‘ Limited infilling identified as appropriate development in the Green Belt in the NPPF, will be permitted in Chadwick End.
In the other Green Belt villages and hamlets in the Borough, new building, other than that required for agriculture and forestry, outdoor sport, outdoor recreation and cemeteries, or for extensions and alterations will be considered to be inappropriate development, in order to protect the Green Belt and the character and quality of the settlements.’
Revision of para 420 to read: ‘A small number of changes will be made to address anomalies in Green Belt boundaries across the Borough, including the
removal of settlements and areas of existing development which no longer perform any Green Belt function, taking into account an assessment of submissions made during the preparation of this Plan.’
Alteration to the Policies Map to exclude Cheswick Green, Tidbury Green, Millison’s Wood, Whitlock’s End, Widney Manor Road, and the Oldway Drive area (as defined in my Appendix A) from the Green Belt.

See attachments

The Plan should be amended to include safeguarded land to accommodate longerterm development needs

see attached representation form

See modifications in the representations which include:
3 i) and ii) – delete and replace with "Limited infilling or redevelopment will be permitted in accordance with NPPF paras 145 and 146.
3 iii) should be amended to, "Disproportionate additions shall be interpreted as additions that are more than 40% of the original floorspace of the building. However:
a) Additions in the third floor loftspace shall not count towards the additional 40% as they do not impact on the openness of the Green Belt; and
b) Any development under national permitted development rights will not be i) included in the calculation of the original floorspace; ii) counted towards the 40% addition; or iii) otherwise affected or restricted by this Policy."
4 – The list after "In considering proposals for inappropriate development in the Green Belt, the following factors may be taken into account as very special circumstances": Add all circumstances listed in [para 145 and para 146 NPPF].
Para 417 - The pressure on the Green Belt in Solihull has been intensified by the requirement for development emerging from housing needs (both for the Borough and wider housing market area); the lack of vacant and derelict land in the Borough, that Solihull has significant Green Belt @67% with the boundary being set in 1997 when Solihull Metropolitan Borough Council adopted its Unitary Development Plan (UDP) which formally delineated the Borough’s Green Belt boundaries including those areas designated as interim Green Belt.
Set out the minor modifications to the Green Belt under Para 420 and include Site 127 as a minor modification on the Green Belt boundary as it is an anomaly given the location, surrounding land uses and the self-contained nature of the site and/ the inability to of the Site to expand further into the Green Belt or be used as a precedent for other expansion
Para 422 – delete.
Para 242 –Deletions and additions as suggested in the representations.

See attachments.

To provide a plan which is more effective and responsive to these variables we consider that the Council should have tested a number of scenarios and provided appropriate allocations and safeguarded areas to enable them to flexibly respond to the ever changing circumstances. We request that the Council consider identifying areas of land that could be released from the Green Belt in this Local Plan Review and safeguarded for future development should the Council not be able to meet their housing needs or the housing needs of the HMA during the next plan period. Our client’s site (Site Reference 207) should be considered for a residential and community facility allocation or be safeguarded for future development.

See attached documents

The Plan should be amended to include safeguarded land to accommodate longer term development needs.

Please see attached representations on behalf of Rainier Developments Limited for land at Widney Manor Road (Site 407)

The Strategic Green Belt Assessment should be updated and corrected in relation to its Assessment of RP32 (land west of M42 at Brueton Park).

Please see attached representations on behalf of Rainier Developments Limited for land at Widney Manor Road (Site 407)

(i)Additional land should be taken out of the Green Belt to support residential development in this plan period (with a specific proposal for the removal of land at Widney Manor Road (Site 111)); and
(ii) areas of safeguarded land be identified to meet needs beyond the plan period, or sooner if required as part of a review of the Local Plan.

See attached documents

To make the plan sound a proper study needs to be carried out to model the surplus office, retail and manufacturing spaces that will potentially become available over the next 10-15 years as a consequence of retail moving online, Covid-19 and Brexit, particularly if no deal occurs. In fact, you could argue that Brexit is so fundamental to the West Midlands that no plan of this nature should be signed off until the picture becomes clearer.

See attachment

LAND AT BERKSWELL ROAD, MERIDEN see attached documents

Policy P17 (Bullet Point 1):
Deletion of point 1

See attachments.ARDEN GREEN – BARRATT DAVID WILSON

Policy P17 (Bullet Point 4):
Inclusion of further factors which may create very special circumstances

See attachments.ARDEN GREEN – BARRATT DAVID WILSON

Policy P17 (Bullet Point 5):
- Delete Bullet Point 5 of Policy P17.

See attachments.ARDEN GREEN – BARRATT DAVID WILSON

Redraw Green Belt boundary for Site BL3 so that land adjoining site BL3 at Whitlocks End Farm should be excluded from the Green Belt in the same manner and in accordance with the submitted Vision Document (attached).

See attachments.

Policy P17 Criteria 1 should either be deleted or amended to properly reflect national policy and available evidence

Dear Sir / Madam

Please find attached a copy of representations submitted by RPS on behalf of Redrow Homes to the Solihull Local Plan Draft Submission Plan (Regulation 19) consultation in respect to Land off Main Road, Meriden.

Please can we request a delivery receipt once received, for our records.

Many thanks