Policy BL1 - West of Dickens Heath

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Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10628

Received: 23/11/2020

Respondent: Mrs Deborah Williams

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The area cannot cope now with the volume of traffic. Also this area is a flood zone

Change suggested by respondent:

Consider the people who already live in the area. It needs to be disbanded. Find another location!!!!!!!!.

Full text:

I have lived in this area for the last 32 years. I also own a property in the Dickens Heath Village. My main concern with the proposed development is the huge increase in road traffic. Majors Green comes under Bromsgrove District Council. There is no consideration for the residens of this small hamlet. We have seen immense increase of traffic along Haslucks Green Road and Peterbrook Road. There is no regard to tge speed. The road on which Whitlocks End Station is located has no white lines the pavement is the same level as the road . You take your life in your one hands trying to walk along this stretch of road with speeding cars. Have had very many frightening near misses. The infrastructure in this area cannot cope.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10636

Received: 19/11/2020

Respondent: Matthew Wood

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The site includes sports fields, which will affect children and adults who use the fields.
The land is high grade Green Belt - should protect greenbelt and build on brownfield first
Development will be surrounded by LWS & Ancient woodland - so will impact wildlife
Road network cannot take further development
Site is in Flood zone 1
Mitigation measures in plan are not achievable, so the site is not sustainable. Other sites are more suitable
Character and setting of village will be adversely affected. Community feel and identity will be compromised. Village already had strong definable boundaries.

Full text:

Please find my objections listed to Site 4 Dickens Heath.

- There are numerous sports fields included so this will affect our children (and adults) who play rugby and football on these fields, including Old Yardleians Rugby Club, Highgate Football Club and Wychall Wanderers Football Club, as well as Fitbox boot camp on the rugby field.
- The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.
- Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland.
- The narrow rural road network cannot take further development and is already overloaded.
- Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability.
- Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.
- The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10637

Received: 20/11/2020

Respondent: Ms Sally Hill

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to building of 350 houses in Dickens Heath. Land is high grade Green Belt. Government policy is to protect Green Belt and develop Brownfield first.

Full text:

I write to express my opposition to the proposed building of 350 houses in Dickens Heath due to the fact that the land is high grade green belt and the Government policy is to protect Green belt and develop brownfield land first.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10655

Received: 01/12/2020

Respondent: Mr Edward Tan

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objects to the allocation of Site 4/BL1 for residential development
Dickens Heath should be protected and conserved as a new village, together with its character and setting in the countryside.
The proposed large-scale housing allocations would reduce or remove key gaps between settlements such as Majors Green and Tidbury Green.
Proposed Housing Allocation Site 4/BL1 is not in a sustainable location and would create substantial car traffic.
There would be a major loss of sports grounds and playing fields.
Loss of the Akamba Heritage Centre on Tythe Barn Lane.
There is no prospect of any community benefit from the Site 4/BL1 proposal which could outweigh the loss of it as an existing leisure, cultural and recreation facility.
The majority of the Housing Allocation Site 4/BL1 location would exceed the accepted walking distance of 800 metres to the centre of the Village. Increased traffic would place an unacceptable burden on the road system and the existing Village centre car parking shortage.
The proposals are unsustainable on highway safety grounds, adding to current pressures and the increased through traffic from Tidbury Green and Tythe Barn Lane. Major road improvements cannot be carried out without removal of established hedgerows and mature trees. The internal Village road network cannot be upgraded.
There will 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/BL1, there would need to be extensive piling. The cost of developing this site would be unsustainable.

Change suggested by respondent:

Removal of Policy BL1

Full text:

Ed Tan of 34 Tythe Barn Lane, Dickens Heath, Solihull, B90 1RW’s
response to the Emerging Concept Masterplan
As one of the first residents in Dickens Heath having moved to Tythe Barn Lane in 1998 and lived at the current address for over twenty years, I object to the allocation of Site 4 for residential development of 350 dwellings in the strongest terms.
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. Dickens Heath should be identified in the Emerging Concept Masterplan 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 Emerging Concept Masterplan do not comply with the stated Policies as set out in both the existing adopted Local Plan and this Emerging Concept Masterplan. It would be unsustainable and would no longer make Dickens Heath a “special place”.
“… 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 and does not align with Government policy to protect Green Belt from development.
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 and Tidbury 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.
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. No service is provided between said station and 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 Emerging Concept Masterplan, 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. 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.
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. Site 4 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.
The original concept design for Dickens Heath 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 four wheeled motor vehicles 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 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 both Lowbrook Farm and Tidbury Green Farm developments are completed, never mind an additional 350 dwellings plus the cut-through traffic that also use Tythe Barn Lane. 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 350 additional dwellings would have a cumulative severe impact on the area.
“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.
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. Evidence from neighbouring sites show that piling had to go to depths of 8m 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.
For the reasons given above, I call on Solihull Council to remove the proposed allocation of Site 4 west of Dickens Heath from the Emerging Concept Masterplan.
Yours sincerely,
Edward Tan

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10656

Received: 20/11/2020

Respondent: Hilary Hargrave

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- Loss of sports facilities that are fundamental for local communities.
- The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.
- The site is surrounded by LWS and Ancient Woodland - proposals will affect different species
- Highway infrastructure in the area is already overloaded. High levels of upgrading and potential destruction of more green belt would be needed to create anything like a sustainable access route into any proposed development.
- Site is in Flood zone 1
- Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.
- The character and setting of Dickens Heath and Tidbury Green has already been decimated by developments in nearby areas.
- The facilities for the village are already way below what is needed for the number of residents - i.e. shops, hospitality, public transport, car park.
- Local schools would not be able to accommodate additional housing

Full text:

I am writing to object to the above proposals on the following grounds:


• The area affected by the proposals includes a large number of sports facilities which are fundamental to the local and surrounding communities in providing recreational and competitive activities. These facilities not only provide well-being (physically and mentally) to young and older people, but they provide opportunities for volunteering working, and bringing communities together.
• The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.
• Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – these proposals will affect many different species including ( deer, badgers, bats, birds and other wildlife that exist and live in the affected areas)
• The road and highways infrastructure in this area is already overloaded due to development in teh surrounding areas, high levels of upgrading and potential destruction of more green belt would be needed to create anything like a sustainable access route into any proposed development. Walking around these areas is virtually impossible on a safe basis already with cars, vans and occasionally lorries passing through narrow country roads.
• Site 4 is mostly in flood Zone 1. This area is already subject to flooding, a situation that deteriorates as each year goes by.
• Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.
• The character and setting of Dickens Heath and Tidbury Green has already been decimated by developments in nearby areas, the effect of this on the environment and the status of the area as a village is hard to describe.
• The facilities for the village are already way below what is needed for the number of residents - whether this be shops, hospitality, public transport links, car parking - the list is endless.
• The effect on the environment of additional traffic
• Local Schools would not be able to accommodate additional housing in this area.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10657

Received: 23/11/2020

Respondent: Elizabeth Donaghy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Below are the reasons I object to planning 350 more houses in dickens heath:
• Flooding - the site is flood zone. The area cannot facilitate houses and by building more you put the houses in the surrounding area at risk of flooding also.
• Green Belt - the land is high protected green belt land. It is a habitat for natural wildlife. We should not be allowed to build 350 houses only a few yards from where these protected animals live. Objection were ignored when the new plot on Dickens Heath Road was proposed, which impacted wildlife in the area.
• Facilities - Whitlocks End car park was only extended a few years ago and it already can not facilitate the growing population in the local area.
• Traffic - every morning Dickens’s heath road is overflowing with traffic during rush hour
Sports - there are two football clubs, a rugby club and a fitbox club on the area proposed to build these new houses. Local sport, leisure and physical activity can help people to live longer, healthier lives.

Full text:

Below are the reasons I object to planning 350 more houses in dickens heath:

• Flooding - the site is flood zone 1, the area floods every single year and the drains in the area cannot cope. Every time there is heavy rainfall on Tilehouse Lane and Tythe Barn Lane the drains are overflowing with water into the roads. The last time flooding warnings were ignored, the plot on Dickens Heath road (0.25 miles away) ended up flooding the newly built houses and families had to vacate from their homes within the first year of living there. The area cannot facilitate houses and by building more you put the houses in the surrounding area at risk of flooding also.

• Green Belt - the land is high protected green belt land. The area is a habitat for natural wildlife. I have seen foxes, deer and bats on numerous occasions on my walks on Tythe Barn lane and building on these plots will disturb wildlife and take away their homes. These objections were ignored by the council when the new plot on dickens heath road was proposed however it did seriously disturb and confuse the wildlife in the area. Two times bats flew into my aunty’s home on dickens heath road when the building works began, which proves the bats were disturbed and couldn’t find their roots. The area on Tythe Barn Lane is high grade green belt for a reason, it is there to protect natural wildlife. The barn on Tythe Barn Lane has never been able to be redeveloped due to it becoming a habitat for the bats. We should not be allowed to build 350 houses only a few yards from where these protected animals live. It will lead to more street lights and lighting from houses which will effect their feeding and foraging and will lead to the needless deaths of a species that has a already declining population.

• Facilities - Whitlocks End car park was only extended a few years ago and it already can not facilitate the growing population in the local area. There are new housing plots on Tilehouse lane and Low brook lane which are less than a mile from the proposed plot. Locals in the area should not suffer from being unable to use facilities due to the council accepting ill thought out plots.

• Traffic - every morning Dickens’s heath road is overflowing with traffic during rush hour. This traffic flows up Tythe Barn Lane. The roads and village were never built for level of traffic it currently has and there are no plans to facilitate the growing population in the area. Adding another 350 houses when there are unfinished new build plots less than a mile away will make the area an incredibly inconvenient place to live.

• Sports - there are two football clubs, a rugby club and a fitbox club on the area proposed to build these new houses. Local sport, leisure and physical activity can help people to live longer, healthier lives. This makes them fundamental to achieving councils’ aspirations for their communities. In the current economic climate and in the face of national challenges such as obesity and mental health, it is vital for these sports clubs to stay in the local area.

I hope you take the objections I have raised into serious consideration.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10674

Received: 23/11/2020

Respondent: Miss Leigh Cole

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- Schools in the area are oversubscribed (both primary and secondary). there has been talk of further primary schools, but not secondary
- site is located on sports fields that will affect our children who use the fields
- land is high grade Green Belt - Government policy is to protect Green Belt and develop Brownfield land first.
- site is surrounded by LWS & Ancient Woodland
- road network cannot cope with further development
- area around dickens heath and the site is prone to flooding.
- character & setting of the Village will be adversely affected and sense of community and identity compromised.

Full text:

To whom it may concern,

I’m writing to outline my objectionS to further development of a further 350 homes at site 4, Dickens Heath.

A large majority of residents purchased property in the area to be in a small safe community, within a certain secondary school zone. Secondary schools are over subscribed. There has been talk of further primary schools but nothing addresses the lack of secondary school options.

The sports fields included in site 4 will affect our children who play rugby and football on these fields.

The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.

Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland. There are barn owls nesting in this area. There have been migrating Egrits in some of these fields.

The road network in Dickens Heath cannot take further development and is already overloaded and problematic.

The whole area of Dickens Heath and surrounding land is prone to flooding. Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability. If anything we should be planting more trees to build up a root system to help with the existing issues.

The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows. The way things are going Dickens Heath will be an extension of Shirley. The infrastructure doesn’t cope as it is.
Thank you for your consideration.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10679

Received: 04/12/2020

Respondent: Birchy Close Residents Association

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Site BL1 Dickens Heath

I would like to register my objections to the inclusion of part of the above site in the Local Plan, the larger of the two which proposes up to 350 dwellings
My reasons are;
- Increase traffic problems.
The population of Dickens Heath has grown from the original award-winning design of 850 dwellings to 1,757 units today. The proposed new housing would increase this to around 2,100 dwellings. However, the roads and infrastructure have not been designed or improved to accommodate this increase. The vast number of dwellings proposed in the Local Plan Review for the Blythe area, together with the large housing estates given planning permission in the general area in the last few years has caused considerable congestion at peak times. Given the parking problems in the Village centre, the narrow rural roads and historic hedgerows, it will be difficult if not impossible to make all the required road improvements to take any more traffic.

- Accessibility
One of the main design concepts of Dickens Heath was to limit the need for private car use. This meant that all housing was to be within easy walking distance (800 metres) of the centre. The majority of the proposed Site BL1 exceeds this walking distance. The new residents would therefore generally use their own vehicles to reach the retail, educational and social facilities of the existing village where car parking is already a major problem. New footpath links would be necessary to make the development sustainable in terms of walking distances to the Village Centre. Earlier drafts of the plan showed a new footpath through Birchy Close. This will not be deliverable as it is a private road owned by approximately 50 separate freeholders. Also, the plans do not show the junction of Birchy Leasowes/ Dickens Heath Road which lies within the shortest alternative route from the proposed development to the Village. This cannot be improved as ancient woodland and LWS adjoin the narrow highway where there are no footpaths. In addition, as the distance from the proposed site is not within an accepted walking distance, a bus route is proposed by the Council along Birchy Leasowes Lane but buses cannot turn on to Dickens Heath Road safely. Neither can a bus travel to the Village Centre along Tythe Barn Lane, as the access on to Dickens Heath Road is also restricted.
Furthermore, this site is not “highly accessible” as stated in the Sustainability Appraisal. While it would be close to Whitlocks End railway station, the overloaded 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 or employment locations which are further than 15 minutes distance, for which here is only a slow and indirect bus service, and there would be no public transport to the ‘UK Central’ location east of the M42 Junction 6. There would be no direct access from Site BL1 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.
- Impact on natural environment
This is a high performing Green Belt site. There are more Local Wildlife Sites surrounding it than any other of the proposed allocations with protected species, ancient woodlands and hedgerows. Also, the land is liable to flooding as the sub-soil is deep boulder clay that does not allow adequate percolation.

- Local ‘overload’

The Plan proposes to locate approximately 39% of all proposed new housing in the Borough to South Shirley/Blythe Ward. This is an inordinate amount compared with other communities so does not contribute to geographical distribution. I think that this will place an excessive burden on such a small area given the nature of the roads, traffic levels, the flood risks and the rural environment

Change suggested by respondent:

Site BL1 Dickens Heath

I would like to register my objections to the inclusion of part of the above site in the Local Plan, the larger of the two which proposes up to 350 dwellings
My reasons are;
- Increase traffic problems.
The population of Dickens Heath has grown from the original award-winning design of 850 dwellings to 1,757 units today. The proposed new housing would increase this to around 2,100 dwellings. However, the roads and infrastructure have not been designed or improved to accommodate this increase. The vast number of dwellings proposed in the Local Plan Review for the Blythe area, together with the large housing estates given planning permission in the general area in the last few years has caused considerable congestion at peak times. Given the parking problems in the Village centre, the narrow rural roads and historic hedgerows, it will be difficult if not impossible to make all the required road improvements to take any more traffic.

- Accessibility
One of the main design concepts of Dickens Heath was to limit the need for private car use. This meant that all housing was to be within easy walking distance (800 metres) of the centre. The majority of the proposed Site BL1 exceeds this walking distance. The new residents would therefore generally use their own vehicles to reach the retail, educational and social facilities of the existing village where car parking is already a major problem. New footpath links would be necessary to make the development sustainable in terms of walking distances to the Village Centre. Earlier drafts of the plan showed a new footpath through Birchy Close. This will not be deliverable as it is a private road owned by approximately 50 separate freeholders. Also, the plans do not show the junction of Birchy Leasowes/ Dickens Heath Road which lies within the shortest alternative route from the proposed development to the Village. This cannot be improved as ancient woodland and LWS adjoin the narrow highway where there are no footpaths. In addition, as the distance from the proposed site is not within an accepted walking distance, a bus route is proposed by the Council along Birchy Leasowes Lane but buses cannot turn on to Dickens Heath Road safely. Neither can a bus travel to the Village Centre along Tythe Barn Lane, as the access on to Dickens Heath Road is also restricted.
Furthermore, this site is not “highly accessible” as stated in the Sustainability Appraisal. While it would be close to Whitlocks End railway station, the overloaded 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 or employment locations which are further than 15 minutes distance, for which here is only a slow and indirect bus service, and there would be no public transport to the ‘UK Central’ location east of the M42 Junction 6. There would be no direct access from Site BL1 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.
- Impact on natural environment
This is a high performing Green Belt site. There are more Local Wildlife Sites surrounding it than any other of the proposed allocations with protected species, ancient woodlands and hedgerows. Also, the land is liable to flooding as the sub-soil is deep boulder clay that does not allow adequate percolation.

- Local ‘overload’

The Plan proposes to locate approximately 39% of all proposed new housing in the Borough to South Shirley/Blythe Ward. This is an inordinate amount compared with other communities so does not contribute to geographical distribution. I think that this will place an excessive burden on such a small area given the nature of the roads, traffic levels, the flood risks and the rural environment


P Brandum
17 Birchy Close
B90 1QL

Full text:

See below

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10680

Received: 23/11/2020

Respondent: Daniel Barber

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- site contains numerous sports fields, which will impact children and adults who use the fields
- land is high grade Green Belt. Government policy is to protect Green Belt and develop Brownfield land first.
- the site is surrounded by LWS and Ancient woodland. development will be detrimental to wildlife
- Narrow rural road network cannot take further development and is already overloaded.
- site is mostly in flood zone 1. the fields flood every winter
- Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.
- access to local services is being impacted (its harder to get a doctors appointment). its also difficult to leave the village by car since other housing developments have been completed. it will impact our standard of living.

Full text:

Hi there

I would like to object to your local plan review on the following grounds-

* There are numerous sports fields included so this will affect our children (and adults) who play rugby and football on these fields, including Old Yardleians Rugby Club, Highgate Football Club and Wychall Wanderers Football Club, as well as Fitbox boot camp on the rugby field.

* The land is high grade GREEN BELT – Government policy is to protect Green Belt and develop Brownfield land first.

* Site 4 is surrounded by Local Wildlife Sites and Ancient Woodland – this will be so detrimental to the deer, badgers, bats and other wildlife that roam in these fields and adjoining woodland.

* The narrow rural road network cannot take further development and is already overloaded.

* Site 4 is mostly in flood Zone 1, these fields flood every winter and whenever there is a particularly heavy rainfall as the area is of bolder clay that restricts permeability.

* Sustainability – Some of the mitigation measures included in the Plan are not achievable, therefore it isn’t sustainable. Other sites are more sustainable.

* The character and setting of the Village will be adversely affected and sense of community and identity compromised. There are strong, definable boundaries to the existing Village being the canal and the woodlands and ancient hedgerows.

Personally, we have noticed how much harder it is to get a doctors appointment in Dickens Heath or even leave the village by car since the other local housing developments were completed. This plan will make it a lot worse and negatively impact our standard of living in Dickens Heath

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10697

Received: 07/12/2020

Respondent: Mrs Helen Bruckshaw

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

I can't get on the train now at Whitlocks end station, how will so many extra homes help this problem. The surrounding roads are already congested, how will extra homes help this problem.

Change suggested by respondent:

Spread the load on new homes over the borough not allowing Shirley to have the lions share on top of the new developments already completed.

Full text:

I can't get on the train now at Whitlocks end station, how will so many extra homes help this problem. The surrounding roads are already congested, how will extra homes help this problem.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10727

Received: 10/12/2020

Respondent: Mrs Cherie Foxall

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Consider the existing residents

Change suggested by respondent:

The plan needs to be scrapped

Full text:

The infastructure for the area has not been considered. Tilehouse Lane B90 1PW has become busy enough with large volumes of traffic and the impact of more housing sites will add to what has become a dangerous road. When we try to leave our driveway onto Tilehouse Lane you have to wait for a break in the traffic which could take several minutes. What will happen when all the proposed houses are built? Once a country lane, as we have lived at the property for 31 years, has become a nightmare. Dickens Heather add's to the constant traffic up and down this road. How on earth will it be made safer and better for all existing house owners and new residents to the area?

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10730

Received: 10/12/2020

Respondent: Wythall Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Wythall Parish Council Planning Committee have grave concerns over the effect to the surrounding area, particularly Majors Green, of policy BL1. Traffic will increase enormously on already busy and historically dangerous rural roads including Haslucks Green Road which has a hump back bridge, blind bend and adverse camber within a stretch of a few hundred metres. The Plan contains no measures to mitigate this detrimental effect on neighbouring parishes.
Also, there will be an increase in passenger numbers using Whitlocks End Train Station, yet there is no mention within the plan of how the already full car park will cope.

Change suggested by respondent:

As this development is right on the border with the parish of Wythall, some evidence of consideration and collaboration should be included with plans of how the local road network will be improved to cope with the additional traffic.
Ideally a reduced number of houses would be preferable.

Full text:

Wythall Parish Council Planning Committee have grave concerns over the effect to the surrounding area, particularly Majors Green, of policy BL1. Traffic will increase enormously on already busy and historically dangerous rural roads including Haslucks Green Road which has a hump back bridge, blind bend and adverse camber within a stretch of a few hundred metres. The Plan contains no measures to mitigate this detrimental effect on neighbouring parishes.
Also, there will be an increase in passenger numbers using Whitlocks End Train Station, yet there is no mention within the plan of how the already full car park will cope.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10757

Received: 11/12/2020

Respondent: Mrs Jean Walters

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BL1 is in a high performing Green Belt area (7 &8).

The Sustainability Appraisal is inaccurate.

The sports fields should be retained.

There are other more sustainable sites in a sequential test.

The character and setting of the Village will be adversely affected.

Many Local Wildlife Sites and Ancient Woodland and their connectivity compromised.

Traffic congestion exacerbated. Narrow, rural roads.

Village Centre parking problem cannot be solved just by controlling some on-street parking.

Site not within a recognised walking distance (800m) from the Village Centre facilities.

Flooding

A more detailed report is contained in Appendix 1

Change suggested by respondent:

Part of site BL1, land west of Dickens Heath and south of Tythe Barn Lane should be deleted from the Plan.

The land for approx. 100 dwellings north of Tythe Barn Lane has fewer constraints so could be allocated but only at the end of the Plan period when other lesser grade Green Belt land has been developed.

Full text:

BL1 is in a high performing Green Belt area (7 &8).

The Sustainability Appraisal is inaccurate.

The sports fields should be retained.

There are other more sustainable sites in a sequential test.

The character and setting of the Village will be adversely affected.

Many Local Wildlife Sites and Ancient Woodland and their connectivity compromised.

Traffic congestion exacerbated. Narrow, rural roads.

Village Centre parking problem cannot be solved just by controlling some on-street parking.

Site not within a recognised walking distance (800m) from the Village Centre facilities.

Flooding

A more detailed report is contained in Appendix 1

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10843

Received: 13/12/2020

Respondent: Mrs Jennifer Fearn

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

BL1 - West of Dickens Heath, BL2 South of of Kennel Lane - Both funnel traffic towards Stratford Road adding to congestion. It currently create further serious congestion around the traffic islands at the junction of Tanworth Lane, Dickens Heath Road, Blackford Road and Dog Kennel Lane. Queues extend from this point to DH Village clock, Town end Tanworth Lane, queues extend into Woodlands Road and Stretton Road. No evidence of plans with traffic impact.

Change suggested by respondent:

Delay development in these areas until congestion on Stratford Road has been improved.

Full text:

BL1 - West of Dickens Heath, BL2 South of of Kennel Lane - Both funnel traffic towards Stratford Road adding to congestion. It currently create further serious congestion around the traffic islands at the junction of Tanworth Lane, Dickens Heath Road, Blackford Road and Dog Kennel Lane. Queues extend from this point to DH Village clock, Town end Tanworth Lane, queues extend into Woodlands Road and Stretton Road. No evidence of plans with traffic impact.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10876

Received: 14/12/2020

Respondent: Rob Grinnell

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Essential green belt land, especially during these times. Plans will merge Dickens Heath with Shirley, lose distinct boundaries between areas making it one large conurbation.

Change suggested by respondent:

Maintain distinct separation between Dickens Heath and Shirley. Keep essential green belt land for animals, plants/trees, people.

Full text:

Essential green belt land, especially during these times. Plans will merge Dickens Heath with Shirley, lose distinct boundaries between areas making it one large conurbation.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10902

Received: 14/12/2020

Respondent: Richborough Estates

Agent: Star Planning and Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Richborough Estates supports the principle of the housing allocation at land west of Dickens Heath (Policy BL1) and the timing of its delivery. It is an available, suitable and deliverable site for housing at one of the larger settlements within Solihull Brough which sits on a public transport corridor and has a range of facilities.

Objections are made to Policy BL1 related to the detailed requirements for the proposal. Alternative wording is proposed to provide some flexibility to ensure the policy is positively prepared, effective and justified.

The Akamba site should be excluded from the Green Belt

Change suggested by respondent:

Criterion 1 should be amended to be a “approximately” 610 dwellings.
Criterion 2(ii) should refer to “An enhancement to pedestrian connectivity along Tythe Barn Lane is proposed in order to provide a safer route to Whitlocks End Station.” Reference to the link across the canal can be retained.
Criterion 2(ii) should be deleted
Criterion 2(iii) increased to around 3.57 hectares based on 610 dwellings
Criterion 2(iv) should refer to “The potential for sports pitches to be provided on land to the north of Tythe Barn Lane.”
Criterion 2(v) should be amended to “Subject to other masterplanning considerations, the retention of Local Wildlife Sites, with potential for enhancement and an appropriate buffer to Tythe Barn Coppice ancient woodland provided.”
Criterion 2(vi) should be amended to state “As far as reasonably possible the retention of trees and hedgerows within the site and along Tythe Barn Lane to conserve the character of this approach into Dickens Heath”
Criterion 2(viiI) a 2½% target for self and custom build plots.
Criterion 3(v) should be deleted. If a criterion is required then it should state “As part of any application a SuDS scheme shall be submitted”.
Under Criterion 6, the Concept Masterplan is objected to by Richborough Estates because it fails to identify the full housing capacity of the land proposed to be excluded from the Green Belt, including because the floodplain is incorrectly identified on the Council’s Concept Master Plan Document. The capacity is approximately 610 dwellings with 470 dwellings on land south of Tyhe Barn Lane and some 40 dwellings on the Akamba site.
The Akamba should be removed form the Green Belt to recognise its future potential to be redeveloped for housing. There would be clear Green Belt boundaries, similar to those proposed for the land to the east, utilising the strong hedgerow which defines the western boundary of Akamba and the Stratford upon Avon Canal to the north.

Full text:

1. Richborough Estates Limited supports the principle of allocating land to the west of Dickens Heath (Policy BL1) and the timing of its delivery. It is an available, suitable and deliverable site for housing and is well located relative to the public transport corridor between Birmingham and Stratford upon Avon and the existing settlement of Dickens Heath.

2. For clarity, Richborough Estates controls the land bounded by Tythe Barn Lane, Tilehouse Lane and Birch Leasowes Lane which, themselves, would provide robust and readily recognisable Green Belt boundaries.

3. Although Richborough Estates has worked with the Solihull Metropolitan Borough Council to assist the framing of the potential housing scheme indicated on the Concept Masterplan, objections are made to Policy BL1 related to the detailed requirements for the proposal. Alternative wording is proposed to provide some flexibility to ensure the policy is positively prepared, effective and justified and a revised Concept Masterplan presented, including to identify another potential access location.

Objection to Policy BL1

4. The idea of Concept Masterplan for the proposed Dickens Heath housing allocation is supported. However, the production of Concept Masterplan does create a strong expectation about how an allocation might come forward for development, especially with the local community.

5. It is recognised that Concept Masterplans are acknowledged by the Council to be the subject of change as further infrastructure survey work is carried out at the application stage. However, Policy BL1 is clear that any significant departure from the principles outlined in the Concept Masterplan will need to be justified and it will be necessary to demonstrate that the overall objectives for the site and its wider context are not compromised. The overall objectives associated for any of the Concept Masterplans are not specifically identified in either the relevant policy or the supporting document. Further, there is a lack of clarity about how a significant departure is defined.

6. Accordingly, although not seeking to materially dilute the drafting of the policy and the Concept Masterplan document to such a degree that it has limited content, there is a need to ensure some flexibility in how an allocation might come forward for development.

7. At Dickens Heath the specific requirement of Policy BL1 needs to be amended to ensure the Local Plan is positively prepared, effective and justified:

a) For the reasons explained in more detail below, the capacity of the proposed allocation as a whole should be increased to about 610 dwellings. As such, Criterion 1 should be amended to be a “approximately” 610 dwellings. Notwithstanding the upwards capacity adjustment, an absolute figure of the type drafted is too prescriptive, especially where the final capacity should emerge through a more detailed design process at application stage.

b) Criterion 2(ii) should have greater flexibility concerning the potential improvement to the footway connectivity along Tythe Barn Lane. There are different approaches available. The criterion should refer to “An enhancement to pedestrian connectivity along Tythe Barn Lane is proposed in order to provide a safer route to Whitlocks End Station.” Reference to the link across the canal can be retained.

c) The principle of facilitating the connection of Dickens Heath to Solihull town centre via a cycle route is supported but it is unclear what this actually means for the purposes of masterplanning the allocation. Criterion 2(ii) should be deleted because it is part of the infrastructure requirement associated with criterion 3(vi).

d) Subject to the acceptance of the increased capacity, the public open space provision should be increased to around 3.57 hectares in Criterion 2(iii).

e) As drafted, the relocation of the sports pitches is addressed in Criteria 5 and 3(iii) and is not required in Criterion 2(iv). However, as a masterplanning matter, there should be the ability to consider the potential for relocation of the sports clubs to the land north of Tythe Barn Lane. This is within land also controlled by Richborough Estates and was originally proposed as a Sports Hub. Accordingly, Criterion 2(iv) should refer to “The potential for sports pitches to be provided on land to the north of Tythe Barn Lane.”

f) There should be flexibility to enable to possible justified partial loss of the Local Wildlife Sites and this being off-set elsewhere. This is not intended to suggest that any or all of the Local Wildlife Sites should or would be lost but to enable some flexibility to improve the masterplanning process. For example, there might be a need for an item of infrastructure, or even a sports pitch, to be located on a Local Wildlife Site. Criterion 2(v) should be amended to “Subject to other masterplanning considerations, the retention of Local Wildlife Sites, with potential for enhancement and an appropriate buffer to Tythe Barn Coppice ancient woodland provided.”

g) A similar point applies to the trees and hedgerows along Tythe Barn Lane under Criterion 2(vi) because there may be examples where some vegetation removal might be required for accesses of whatever type, highway improvements (see Criterion 3(iv)) or the improved pedestrian link along Tythe Barn Lane. The criterion should be amended to state “As far as reasonably possible the retention of trees and hedgerows within the site and along Tythe Barn Lane to conserve the character of this approach into Dickens Heath”

h) Richborough Estates have submitted an objection to Policy 4D. In respect of Dickens Heath, Richborough Estates question is whether it is appropriate to provide 5% of the market dwellings as self and custom build plots on this site. Some 1,650 new homes are proposed within the Local Plan to be constructed in the Blythe Ward with the policies for each allocation seeking 5% self and custom build plots. Is there sufficient evidence of demand for these plots? Richborough Estates propose that a 2½% target is included in Policy BL1 for self and custom build plots.

i) The detailed design of a SuDS system is a matter for a planning application taking into account the ground conditions and topography of the site. It is also worthy of note that there are underground features, such as soakaways or subbases, which are part of a typical SuDS scheme. To seek to restrict a potential optimum design of a SuDS system should not be included in a policy but flexibility should be retained. Accordingly, criterion 3(v) should be deleted. If a criterion is required then it should state “As part of any application a SuDS scheme shall be submitted”.

j) Alongside Policy P20, the principle of Criterion 5 is recognised by Richborough Estates as being appropriate to ensure the future of the relocated sports clubs. Richborough Estates is actively engaged with the Council in the identification of suitable land within Blythe Ward for the relocation of the Sports Clubs. For commercial reasons, it is not possible as part of these representations to provide details of these discussions at this stage. However, it is worthy to record that on 13 August 2020 the Council confirmed the potential use of compulsory purchase powers to acquire land for sports hubs within Solihull.

k) It is noted that the land north of Birchy Leasows Lane is not used for sports pitches and, as such, it would be possible to bring this part of the allocation forward for housing development at an early stage. Such an approach would enable appropriate financial contributions to be generated from land sales to facilitate the relocation of the sports clubs as sought by Criterion 5 and Policy P20.

8. Under Criterion 6, the Concept Masterplan is objected to by Richborough Estates because it fails to identify the full housing capacity of the land proposed to be excluded from the Green Belt.

9. The first matter is that the extent of the floodplain is incorrectly identified on the Council’s Concept Master Plan Document. The floodplain is not as extensive as is suggested and does not preclude the potential development of 2 fields as currently indicated. The Strategic Flood Risk Assessment plans which had then been used to inform the Concept Master Plan for Dickens Heath have now been reviewed in further detail by BWB and it is common ground with the Council (and its consultants) that they do not accurately depict the extent of flooding constraints. A Preliminary Flood Risk Technical Note prepared by BWB and agreed with the Council and its consultants concerning the correct floodplain is included as part of these representations. The consequence of this is that the area of land within the allocation area affected by flood constraints has been reduced and the developable area significantly increased. Accordingly, this results in more land being with Flood Zone 1 and, as such, there is greater dwelling capacity across the site which is more in line with the development quantum suggested by the Council at the earlier (Regulation 18) plan making stage.

10. Secondly, reflecting the National Planning Policy Framework (the Framework), Dickens Heath is an allocation which is well related to a public transport corridor and is within easy walking distance of Whitlocks End railway station which provides a direct service to Birmingham (paragraph 137). There is also a bus service which provides a link to Solihull town centre. This is a case where, under paragraphs 106 and 123(a) of the Framework, there is the opportunity to optimise the density of development in a location well served by public transport. Further, an appropriate uplift in the average density of residential development at locations well served by public transport should be sought unless it can be shown that there are strong reasons why this would be inappropriate. No such strong reasons exist.

11. Thirdly, reflecting the Framework, where land is proposed to be released from the Green Belt then it would be appropriate for the optimum use of such sites to minimise the need for further Green Belt land releases.

12. Richborough Estates has undertaken a critique of the Concept Masterplan for the land west of Dickens Heath and have identified that the capacity of the allocation (as a whole including Akamba) at approximately 610 dwellings inclusive of the accommodation for older people, meeting the open space requirements and respecting the Local Wildlife Sites in line with the Council’s existing masterplan.

13. A copy of the updated Concept Masterplan for the land contained by Tythe Barn Lane, Tilehouse Lane and Birchy Leasowes Lane is included with these representations and also reflects the objections of Richborough Estates to the specific criteria of Policy BL1. This part of the allocation has the capacity to accommodate some 470 dwellings.

Green Belt Boundary

14. Tythe Barn Lane, Tilehouse Lane and Birch Leasowes Lane would provide robust and readily recognisable Green Belt boundaries. However, in seeking to redefine the Green Belt it would be appropriate to exclude the Akamba Garden Centre as part of the land proposed to be removed from the Green Belt to the north of Tythe Barn Lane.

15. The Akamba is an existing and extensive area of previously developed land. It is in commercial use at the current time but the Concept Masterplan Document recognises the potential for this site to be redeveloped at a later date. Although it is recognised redevelopment previously developed land in the Green Belt is not inappropriate development, this is a case where the exclusion of the land from the Green Belt would provide greater flexibility concerning how the redevelopment could be undertaken at a later date. The capacity of this parcel of land is circa 40 dwellings and has been included within the approximate 610 dwellings for the allocation as a whole.

16. There would be clear Green Belt boundaries, similar to those proposed for the land to the east, utilising the strong hedgerow which defines the western boundary of Akamba and the Stratford upon Avon Canal to the north.

Principle of the Allocation

17. Once established, the National Planning Policy Framework (the Framework) is clear that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies of plans should establish the need for any changes to Green Belt boundaries having regard to their intended permanence in the long term, so that they can endure beyond the plan period (Paragraph 136).

18. Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, taking in to account whether the strategy makes as much use as possible of previously developed and underutilised land; optimises the density of development to make efficient use of land including higher densities in town centres and other locations well served by public transport; and informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development (Paragraph 137).

19. When reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account and where it has been concluded that it is necessary to release Green Belt land, plans should give first priority towards land which has been previously developed and/or is well served by public transport, and plans should set out ways in which the impact can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land (Paragraph 138).

20. Although there is no definition in policy or guidance of what comprise exceptional circumstances as envisaged in the Framework, Case Law has confirmed that any alteration to the Green Belt must be justified by exceptional circumstances rather than general planning concepts (Carpets of Worth Ltd v Wyre Forest DC (1991) 62 PCR 334). It is a matter for the Council to reach a sound planning judgment on whether exceptionality exists in the circumstances of an individual case (Calverton Parish Council v Nottingham City Council, Broxtowe Borough Council and Gedling Borough Council [2015] EWHC 1078 (Admin)). The application of the exceptional circumstances test was also recently considered in the decision of Ouseley J. in Compton PC & Others v Guildford BC & Others [2019] EWHC 3242 (Admin) (Compton). Although this case related to the 2012 version of the Framework the commentary for this Case concerning exceptional circumstance remains relevant.

21. There is a recognised two-stage approach to which can be followed to provide the necessary evidence and justification to identify that exceptional circumstances exist to alter the Green Belt boundary through the preparation of a Local Plan. The first stage is the evidence gathering and assessment that leads to an in principle decision that alterations of the Green Belt boundary may be justified to help meet development needs in a sustainable way. Such a need may relate to the significant benefits which would be associated with a specific development proposal (e.g. in the Compton case was found to have significant benefits in terms of affordability and delivery of affordable housing notwithstanding the objectively assessed housing need was being materially exceeded).

22. Stage 1 concerns the evidence gathering and assessment that leads to an in principle decision that a review of the Green Belt boundary may be justified to help meet development needs in a sustainable way. It is set out at paragraph 137 of the Framework and requires the Council to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.

23. There is evidence that there have been discussions throughout the preparation of the Local Plan with neighbouring authorities, under the Duty to Co-operate, to consider whether there is the opportunity for these areas to accommodate some of Solihull Borough’s housing need on non-Green Belt land. However, the authorities boarding Solihull Borough have a lack of land within their urban areas, the same Green Belt considerations and issues about accommodating the growth needs of an adjoining large urban area, whether Birmingham or Coventry.

24. The Overall Approach Topic Paper records the issues related to accommodating the unmet housing needs of Birmingham across the Greater Birmingham Housing Market Area (HMA). As at April 2019, there was still a shortfall of some 2,597 dwellings to be accommodated across the HMA even after Solihull agreeing to accommodate some 2,000 dwellings. However, it is also recognised in the Topic Paper that the final details of any contribution must be tested through a Local Plan process in accordance with national guidance. This is primarily associated with the need to release land from the Green Belt to support any contributions it makes. Equally, there is a question whether Solihull Borough might be able to accommodate further unmet housing needs to address the ongoing HMA shortfall.

25. Although Richborough Estates does have concerns about the assessed housing requirement, principally associated with the HMA shortfall, it is clear from the Local Plan’s evidence base that to accommodate the level of housing proposed does require land to be removed from the Green Belt. There have been extensive studies concerning what land might be suitable and available for housing development within the urban areas of Solihull Borough. Indeed, the Local Plan has sought to making as much use as possible of suitable brownfield sites and underutilised land within both the urban area and, in sustainable locations, the Green Belt. A significant number of the potential housing sites in the Site Assessments document are within the urban area.

26. Within the urban areas there is evidence the Council is seeking to optimise density compatible with local character. The justification for Policy P15 refers to “The appropriate density of residential development will be informed by the need to make efficient use of land together with the desirability of maintaining an area’s prevailing character and setting. Where it can be demonstrated that a higher density would improve the character and quality of an area, this will be supported.”

27. As a matter of principle, Richborough Estates concur with the Council that the necessary Stage 1 exceptional circumstances exist for alterations to the Green Belt boundary to accommodate the housing needs during the plan period. There is a separate point whether it is necessary to identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period. (Framework paragraph 139)? Richborough Estates have proposed such a site at Cheswick Green if it is not needed for housing purposes during the Local Plan period.

28. Stage 2 of the exceptional circumstances approach then determines which sites would best meet the identified need having regard to Green Belt harm and other relevant considerations, including whether they are suitably located and developable. Stage 2 considers such as previously developed land or land well served by public transport together with ways in which the impact of removing land from the Green Belt can be off-set through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. In the case of this Local Plan, Policy P17A allows for such enhancements to also be secured through off-setting which is a pragmatic approach to adopt and supported by Richborough Estates.

29. For the land west of Dickens Heath, the allocation as a whole was not formally assessed in the Site Assessments document prepared by the Council. Instead, the eastern (Ref 176) and western (Ref 126) parts of the allocation have been assessed separately. However, Site Ref 176 also included land north of Tythe Barn Lane (not proposed for housing) which skewed the scoring concerning impact on the Green Belt. The Site Assessments recognised for both parts of the allocation that “Dickens Heath is identified as suitable for significant growth, although ensuring key gaps are protected and within walking distance to rail station.” This is what the allocation does by retaining a clear physical and visual gap between any proposed development and Majors Green in a similar manner to the current gap.

30. The Overall Approach Topic Paper states that “The moderate impact on the Green Belt and the medium to high accessibility indicate that this settlement is suitable for consideration for growth, although any development would need to take account of the higher performing Green Belt to the northwest and ensure that key gaps to adjacent settlements and the urban area are protected. Development to the west of the settlement would be within walking distance of the rail station, avoid the key gaps, and maintain separation to the settlement of Major’s Green in Bromsgrove District”. The proposed allocation accords with these principles.

31. An element of caution is required in the interpretation of the Sustainability Appraisal of the proposed allocation prepared by the Council. The reason being is that Sustainability Appraisal includes land north of Tythe Barn Lane (AECOM 87) not proposed for housing. Hence, the assessment about the allocation having a “Landscape with high sensitivity to change” needs to be reads within the context of the wider site and not just the allocation south of Tythe Barn Lane.

32. The area proposed for housing , apart from the boundary trees, only has local biodiversity interest, is located away from the setting of designated heritage assets, can accommodate development outside the confirmed floodplain and is physically separated from the wider agricultural landscape. The site is physically and visually well contained by trees, hedgerows and roads. The technical work undertaken by Richborough Estates demonstrates that access and utilities can be provided and a SuDS strategy implemented to comply with the current requirements for surface water drainage.

33. The west of Dickens Heath allocation is on a public transport corridor and is well placed in terms of access to the facilities at Dickens Heath and Tidbury Green, including the education provision which is one of the highest trip generators at morning peak. Other facilities within Dickens Heath are capable of being accessible on foot or cycle via Tythe Barn Lane or Birchy Leasowes Lane. There are public transport connections available to Birmingham and Solihull and these locations have extensive employment opportunities and higher order facilities.

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10940

Received: 14/12/2020

Respondent: The British Horse Society

Representation Summary:

4i Opportunity for the Public Rights of Way referred to to include equestrian access.

Full text:

4i Opportunity for the Public Rights of Way referred to to include equestrian access.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10962

Received: 14/12/2020

Respondent: Archaeology Warwickshire

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

As highlighted in the 2018 Archaeological Assessment undertaken by the Warwickshire County Council Archaeological Information and Advice team on behalf of SMBC*, this site has significant archaeological potential. This potential, and the need for further archaeological assessment in advance of the submission of any planning application is not referenced in this policy. As the results of the assessment may influence the final form of the development across this area, it should be.

*Warwickshire County Council, 2020. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan'. Warwick: Archaeological Information and Advice

Change suggested by respondent:

The policy should reference the significant archaeological potential of this area and highlight that, prior to the submission of any planning application, a detailed archaeological assessment, including evaluative fieldwork, should be undertaken. It should further advise that results of the assessment should inform the development of a strategy, if appropriate, to mitigate the potential archaeological impact of the proposed development and that this strategy may include designing the development to avoid impacting any archaeological features present which are worthy of conservation.

This will help to ensure that any planning application is submitted with sufficient archaeological information to enable a reasoned and informed planning decision to be made.

Full text:

As highlighted in the 2018 Archaeological Assessment undertaken by the Warwickshire County Council Archaeological Information and Advice team on behalf of SMBC*, this site has significant archaeological potential. This potential, and the need for further archaeological assessment in advance of the submission of any planning application is not referenced in this policy. As the results of the assessment may influence the final form of the development across this area, it should be.

*Warwickshire County Council, 2020. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan'. Warwick: Archaeological Information and Advice

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11075

Received: 15/12/2020

Respondent: Warwickshire Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Site BL1 is directly adjacent to three designated LWS’s and adjacent to designated Ancient Woodland and in the green belt. We have had a number of concerns from a vast majority of our members regarding this site.
The policy wording is also not considered to be strong enough stating ‘potential for enhancement and appropriate buffer to Tythe Barn Coppice ancient woodland’. The word ‘potential’ should be modified out of the plan text, appropriate buffers should also be included on all of the Local Wildlife Site edges. The Landscape Assessment (2016) states also that the Blythe area has a high overall sensitivity to new development.

Change suggested by respondent:

The word ‘potential’ should be modified out of the plan text, appropriate buffers should also be included on all of the Local Wildlife Site edges.

Full text:

See Attached Word doc.

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11194

Received: 14/12/2020

Respondent: Persimmon Homes Central

Agent: Planning Prospects

Representation Summary:

Allocation BL1 is considered suitable, deliverable and is therefore supported. Persimmon’s site, Land North of Tythe Barn Lane, can be developed as an early phase of the overall allocated site. The proposals have been refined for this part of the allocation to align to the Council’s masterplan.

Full text:

Sirs

Please find attached representations on behalf of Persimmon Homes, comprising Part A and subsequent separate Part B forms relating to each objection/response

We look forward to discussing the attached and suggested amends further with Officers

Regards

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11195

Received: 14/12/2020

Respondent: Persimmon Homes Central

Agent: Planning Prospects

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy BL1 requires the relocation of the existing sports provision south of Tythe Barn Lane. Where the development of any phase of the allocation impacts upon existing sports provision, that phase should provide for its relocation. Each development phase should mitigate its own impacts.

Criterion 3 references Green Belt enhancements in relation to replacement sports provision – this is only relevant to those phases of the development which result in the loss of existing facilities.

Change suggested by respondent:

References within Policy BL1 which require relocation of the existing sports facilities should ensure that these requirements are only for those parts of the development which result in the loss of such existing facilities.

Full text:

Sirs

Please find attached representations on behalf of Persimmon Homes, comprising Part A and subsequent separate Part B forms relating to each objection/response

We look forward to discussing the attached and suggested amends further with Officers

Regards

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11196

Received: 14/12/2020

Respondent: Persimmon Homes Central

Agent: Planning Prospects

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criteria 5 of Policy BL1 restricts development of the site until the existing sports facilities south of Tythe Barn Lane are relocated. Mitigation can only reasonably be imposed upon any phase of development of the site which results in the loss of the existing facility- the Persimmon site does not impact on existing facilities.

The plan should seek opportunities for phased delivery to support early housing delivery in the plan period. The current wording of BL1 is restrictive and could potentially prevent early delivery of the Persimmon parcel.

Change suggested by respondent:

Criterion 5 should be amended to the following:
“To support sustainable development within the area, the site should be promoted on a comprehensive basis and where the proposals result in the loss of the existing sports facilities, supporting the positively planned relocation of the existing sports facilities south of Tythe Barn Lane to alternative locations within the surrounding area. Where a phase of the development results in the loss of the existing sports facilities, until such time as these facilities are appropriately relocated or robust plans have been confirmed to secure a timely relocation that would prevent the closure of any associated clubs (either for a short period of time or permanently), development of that phase of the development site will not be supported.”

Full text:

Sirs

Please find attached representations on behalf of Persimmon Homes, comprising Part A and subsequent separate Part B forms relating to each objection/response

We look forward to discussing the attached and suggested amends further with Officers

Regards

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11197

Received: 14/12/2020

Respondent: Persimmon Homes Central

Agent: Planning Prospects

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criterion 2 Parts Xiii and iX refer to other policy requirements of the plan relating to self build and elderly accommodation and are not necessary to repeat.

Change suggested by respondent:

Criterion 2, Parts Xiii and iX can be deleted as other policies of the plan address such matters.

Full text:

Sirs

Please find attached representations on behalf of Persimmon Homes, comprising Part A and subsequent separate Part B forms relating to each objection/response

We look forward to discussing the attached and suggested amends further with Officers

Regards

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13702

Received: 12/12/2020

Respondent: Environment Agency

Representation Summary:

We are pleased to have been able to review your Level 2 SFRA (October 2020).
Consider that the Level 2 SFRA adequately considers the risk posed to and from these sites, and that the recommendations from this assessment have been carried forward into the plan, namely to provide flood risk reduction wherever possible and not locate any built development within Flood Zone 2 and 3.
We defer any other flood risk comments on the other sites within the Level 2 SFRA to your internal drainage team as the Lead Local Flood Authority with a remit including surface water flooding and that flood risk from Ordinary Watercourses. We are pleased to see that the LLFA has already been engaged in the drafting of this assessment.

Full text:

See Attached Letter.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13861

Received: 14/12/2020

Respondent: Mrs M Joyce

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Insufficient evidence has been provided on the relocation of the existing sports provision south of Tythe Barn Lane, with multiple complex land assembly issues to overcome. This is contrary to the deliverability and developability requirements set out in National Planning Policy Framework.

The ‘Developer Site Proposal’ plan included in the Concept Masterplan Document shows the re-placement playing pitches on a ‘Local Wildlife Site’. This would be contrary to Policy BL1 criteria v and Policy P10.

There are significant time implications for the outstanding work necessary relating to the replacement playing pitches. BL1 is undeliverable and potentially unviable in the short to medium term.

There are suitable alternative options to BL1 including allocating more small and medium sized sites; allocating brownfield land; additional small-scale development to larger village boundaries; and ensuring development densities make efficient use of land.

Change suggested by respondent:

If issues of soundness cannot be overcome- paragraphs 225 and 226 should be amended to remove BL1 from Delivery Phases I and II.

Policy BL1 should be amended in light of the findings of additional evidence gathering, negotiations with landowners, playing field search and masterplan work

Full text:

Dear Sir/Madam,

I submitted these representations yesterday and have just notice that my email gave the wrong client name and so to clarify this particular set of representations are submitted on behalf of our Client Mrs M Joyce (our Ref 10444) in respect of the Draft Submission Solihull Local Plan currently out to consultation.

We should be grateful if you would confirm receipt of these representations and confirm that they will be submitted for consideration by the Local Plan Examination Inspector.

We look forward to hearing from you.

Kind regards,
Glenda

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13863

Received: 22/01/2021

Respondent: Dickens Heath Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Key Infrastructure Issues:
Satisfied with proposed education facilities.
Understand commitment to provide adequate health service provision, but have reservations over CCG’s ability to provide in time effective manner.
Existing traffic and parking congestion issues; particular concern is Dickens Heath Road/Tanworth Lane junction at Miller & Carter, junctions onto Tilehouse Lane from Birchy Leasowes and Tythe Barn Lane, plus flow of traffic through village due to hazardous parking on Dickens Heath Road.
DHPC expect to be consulted on Highways and Traffic Management matters throughout life of Plan.
Village centre parking seen as key priority, as long-standing issues and planning controls been ineffective.
Recognise importance of improved connectivity and public transport links & highway improvements along Tythe Barn lane to Whitlock’s End station, as well as enlarged parking provision.

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13864

Received: 22/01/2021

Respondent: Dickens Heath Parish Council

Representation Summary:

Principle of Development:
Welcome reduction in housing numbers to 350 from 700.
Seek more formal protection of mature trees and adjacent woodlands through TPOs, especially given recent losses on development sites.
DHPC regard proposed Green Belt boundary at Tilehouse Lane and Birchy Leasowes Lane as very important – further development should not be allowed in Tidbury Green Parish to retain a firm peripheral Green Belt boundary and prevent further urban sprawl. This should be considered with regard to deferred Bromsgrove Local Plan, with significant potential development sites along the Solihull boundary.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13866

Received: 22/01/2021

Respondent: Dickens Heath Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Proposed Sports Hub -
Serious concerns about loss of playing pitches and sports facilities on site south of Tythe Barn Lane.
Important to retain links to the village and their contribution to the health and wellbeing of the local community.
DHPC propose an alternative consolidated enhanced sports hub on the site north of Tythe Barn Lane (within the boundary of the 2016 Draft Local Plan proposal), that will incorporate the existing sports pitches.
Proposed alternative sports hub would not alter the proposed housing development in the concept masterplans.
Our indicative scheme has the support of the common landowner.
Can be delivered in a timely manner with seamless transfer of clubs, Highgate United FC and Old Yardleians Rugby FC onto new site.
Would keep the facilities close to the village and be of great benefit to new and existing communities, and not an undetermined remote location further into countryside.
Adequate parking and good access, reduced need to travel.
Potential for additional planting to meet climate change objectives.
DHPC seek to replace part of the proposed wilding area. The sporting use would have a greater community, healthcare and recreational benefits than the designated wilding area.
Sports hub would provide a much more efficient use of land.
DHPC anticipate the sports hub being supported by Sports England as a logical alternative and less disruptive site for longstanding sporting activities.
Large section of existing designated wildlife area on this site includes the Equine Rescue Charity with stables and grazing, which would be relocated by the landowner.
Scheme would retain nationally recognised Akamba Heritage Centre.
Final scheme should be approved through EiP process.

Change suggested by respondent:

Replacement Sport Pitches and Hub to be situated on land north of Tythe Barn Lane, and accord with proposed concept plan as attached.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13885

Received: 14/12/2020

Respondent: Barratt David Wilson Homes - Land south of Broad Lane

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council has had ample time to identify and secure alternative sports provision for the loss of playing pitches at Site BL1 and the fact that this is not identified within the plan suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.

Change suggested by respondent:

Reprovision of the sports pitches should be secured prior to allocation and Policy BL1 should be deleted from the plan.

Full text:

Introduction
Paragraph 18 sets out that the site allocations from the Solihull Local Plan (December 2013) will be brought forward. We consider that the automatic allocation of these sites which have been allocated for a number of years, without any justification as to their deliverability, is an incorrect approach. We address this in more detail under our comments in respect of Policy 4.
Finally, Paragraph 21 refers to neighbourhood plans and the importance SMBC places on these. Paragraph 30 of the National Planning Policy Framework (NPPF) sets the most recently adopted policies will take precedence. SMBC may wish to set this out within this section, to make it clear that the LPR will take precedence upon adoption over any currently adopted Neighbourhood Plans.
Soundness – The Plan is not:
- Justified
Change Sought:
- Existing allocations should be tested for deliverability prior to re-allocation
- The hierarchy of neighbourhood plans should be made clear
Vision
Given that paragraph 59 of the NPPF states that the Government’s objective is to significantly boost the supply of housing, the wording relating to meeting the needs of the housing market area should be more positively worded.
Paragraph 50 sets out that SMBC are seeking to protect the integrity of the Green Belt. Wording should be included setting out that lower performing parcels could be released to protect higher performing parcels while meeting identified and evidenced needs.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- The vision should be more positively worded in order to significantly boost the supply of housing
- The need to release lower performing green belt to meet identified needs, and preserve higher performing parcels, should be set out
Providing Homes for All
Policy P4C Meeting Housing Needs – Market Housing
We object to the inflexible market housing mix which is prescribed within this policy. The NPPF encourages provision of balanced and mixed communities catering for a wide range of the population.
Individual sites should cater for a wide range of housing types and sizes. Provision of such a significant proportion of only smaller (3 bed or fewer) dwellings on sites will not develop long term sustainable communities. Instead it will result in a transient community where people will not be able to form long term neighbourhoods as they will need to move on as their circumstances change if there are insufficient homes of the right size on a site to accommodate them. We do not consider that this represents good planning and consider that the focus should be on building strong healthy communities which can cater for all, rather than simply planning for short term ownership.
The inclusion of a prescribed housing mix runs counter to the criterion elsewhere within the policy which allow a number of factors to be taken into consideration. This plan has a significant lifespan and to prescribe a housing market mix which is to remain in place for the whole of plan period does not provide sufficient flexibility for adaptation to current housing need and demand. We have seen with the current pandemic the way external factors can influence people’s choice of lifestyle.
Soundness – The Plan is not:
• Justified
• Effective
Change Sought:
• Amendment of policy to allow for housing mix based on up to date market evidence
Policy P4D Meeting Housing Needs – Self and Custom Housebuilding
The latest Annual Monitoring Report (March 2020), covering the period 2018/19, sets out that for the period November 2018 – October 2019 there were 374 entries on the Self-build register.
As such, requiring all sites of over 100 houses to provide 5% of open market dwellings in the form of self-build plots is unreasonable and unjustified. Given provision is being made for 7,605 houses through allocations above 100 houses and the UK Central Hub area, this would equate to the 761 self and custom build plots to be provided from the draft allocations.
The Planning Practice Guidance (PPG) advises that the Council should engage with landowners who own sites that are suitable for housing and ‘encourage’ them to consider self-build and custom housing and who are interested in provision. Imposition of mandatory requirement goes beyond encouragement.
Following the example of Stratford District for example, the Council have specifically identified custom build sites which are discreet standalone small sites.
We also include extracts from the Bedford Local Plan Inspector’s Report (Appendix 4) where the Inspector recommended deletion the policy akin to that being proposed here as the policy was not justified with reference to the self-build register. The same principle applies here in that the amount being sought is over double that on the register.
Soundness – The Plan is not:
• Justified
• Consistent with national policy
Change Sought:
• Deletion of specific policy requirement and replacement with specific allocations or general support for self-build sites
Policy P5 Provision of Land for Housing
Policy P5 sets out the Council will allocate sufficient land for at least 5,270 net additional homes to ensure sufficient housing supply to deliver 15,017 additional homes in the plan period. This would result in an average annual housing land provision target of 938 net additional homes per year. This annualised target is made up of a stepped requirement with 851 homes per year delivered between 2020-2026 and 991 dwellings delivered between 2026-2036.
Demand
A Housing Need Technical Report has been provided (December 2020) (Appendix 5) and should be read in conjunction with our commentary on Policy P5. In summary, this Note makes the following key points:
• Planning Practice Guidance (PPG) states the Standard Method (SM) figure represents the minimum housing need, and there may be circumstances whereby need is higher;
• The Draft Plan identifies the clear economic growth aspirations for the Borough, including the nationally significant growth planned for the UK Central Hub. This is a circumstance where housing need may exceed the minimum need. If it does, housing delivery must be of a quantum to support these aspirations;
• The Council’s 2020 HEDNA confirms that the calculation of housing need is underpinned by the growth at the UK Central Hub. The Hub is projected to generate an additional 13,000 jobs to the baseline Experian job growth forecast (10,000 jobs) included in the HEDNA;
• The HEDNA tests several economic-led housing need scenarios. However, the UK Hub Scenario assumes only 25% of the additional 13,000 jobs created by the Hub are to be taken up by Solihull residents. This results in the housing need (816 dpa) underpinning the Plan;
• However, this ignores the ‘Growth A’ scenario which concludes that 908 dpa would be required based on the ‘Adjusted Local Growth’ scenario. This scenario assumes that strong industries in Solihull will outperform the baseline Experian forecast, resulting in an additional 5,680 jobs to the baseline (10,000 jobs) over the Plan period, with Solihull residents taking up these jobs;
• However, no scenario is presented to show what the housing need would be based on the UK Central Hub scenario being fulfilled in full by Solihull residents. It is important to understand this so that the duty to cooperate discussions referred to in the HEDNA are well informed;
Barton Willmore provide these sensitivity scenarios based on two approaches to commuting, and two approaches to underlying demographic rates (mortality, fertility, and migration);
• The results of our testing are summarised in Table 7.1:
Table 7.1: Solihull Borough – Barton Willmore Demographic Forecasting 2020-2036 Scenario Demographic rates Jobs per annum 2020-2036 Dwellings per annum 2020-2036
Dwelling-constrained:
Standard Method
2016 ONS rates
7721 – 8132
807
2018 ONS rates
1,0141 – 1,0682
Employment-constrained:
UK Central Hub
2016 ONS rates
1,437
1,1991 – 1,2482
2018 ONS rates
1,0361 – 1,0852
Source: Barton Willmore Development Economics
1 Commuting Ratio 0.98
2 Commuting Ratio 0.93
• Growth of between 1,036 and 1,248 dpa would be required to support the UK Central Hub scenario (between 16,576 and 19,968 dwellings in total);
• This represents an increase of between 220 dpa and 432 dpa on the housing need calculated by the HEDNA (816 dpa), or an additional 3,520 to 6,912 dwellings over the Plan period;
• Our analysis of historic levels of job growth in Solihull 1991-2019 shows a range of 1,225 and 1,650 jobs per annum (jpa). This highlights that the UK Central Hub scenario (1,437 jpa) is a realistic assumption;
• The HEDNA identifies an ‘acute’ situation in respect of affordable housing need. Our analysis suggests that the HEDNA’s conclusion on overall need (816 dpa) should be increased to meet as much affordable need as possible.
• Furthermore, our analysis of unmet need in the wider GBBCHMA suggests that the 2020 Position Statement’s conclusions under-estimate the remaining unmet housing need from Birmingham up to 2031, and for Birmingham alone the deficit in unmet need is between 11,294 and 13,101 dwellings up to 2031;
• In addition, there is significant unmet need up to 2031 based on the existing Standard Method coming from Birmingham City and the Black Country. This amounts to unmet need of between 25,543 and 27,350 dwellings up to 2031. If we were to assume the increased capacity for Birmingham City (65,400 dwellings 2011-2031) set out in the 2020 Position Statement the unmet need would still be between 11,243 and 13,050 dwellings up to 2031. This increases significantly based on the uncapped Standard Method figure for Birmingham City which would come into effect once Birmingham’s Local Plan becomes older than 5 years in 14 months’ time;
Adoption of the proposed changes to Standard Method consulted on by Government in summer 2020 would lead to there being unmet need against emerging/existing housing requirements in all but one of the GBBCHMA authorities;
• Furthermore, the unmet need post 2031 should be considered, as referenced to in the 2020 Position Statement. Based on data available at the present time and the most recent Local Plan figures, Barton Willmore calculate this to be a minimum 17,700 dwellings 2031-2040.
• In summary, the analysis in this report results in the following broad conclusions:
1. The SM’s minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub and the ‘acute’ need for affordable housing in the Borough;
2. Barton Willmore’s demographic modelling shows that between 1,036 and 1,248 dpa are required to support the UK Central Hub scenario;
3. Barton Willmore’s calculations suggest that the deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded on by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered. Additional unmet need will be created post 2031.
As such, in order to ensure the LPR is positively prepared, SMBC should seek to plan for more housing, and should allocate further sites.
SUPPLY
Further to the above, and as set out above, we also consider that some elements of the supply should be reviewed:
Dealing with the supply side of the equation, we make the following objections to the various components of supply:
‘Sites identified in land availability assessments’
It is unclear what is meant by ‘sites identified in land availability assessments’. Given these are sites which do not benefit from a draft allocation, then they are by definition, windfall sites which means that there is double counting from unknown sources of supply.
Solihull Local Plan sites
We question the automatic inclusion of Solihull Local Plan sites which have yet to be granted planning permission. The current Plan was adopted in 2013 and the Council cannot currently demonstrate a 5-year supply of housing. In this situation, the Council should be encouraging every suitable site to come forward. The fact that these sites have not come forward despite the housing shortfall, suggests that these should not be considered ‘deliverable’ housing sites without significant justification as to why they will now come forward when they have not to date.
Brownfield Land Register (BLR)
We query the separate identification of sites identified in the BLR – this BLR is subject to periodic review and thus will not be fixed as a permanent source of supply. We consider that any sites to be delivered in this way should be considered as windfall developments.
Lapse Rates
Whilst we support the use of a 10% lapse rates, it needs to be applied across the board i.e. it is equally application in relation to what is to come as to what has already gone before. If the Council accept that a 10% lapse rate is application to sites which already benefit from planning permission, then surely it should also accept that it is applicable to future planning consents which have yet to be granted.
Windfall allowance
The windfall allowance is justified by reference to past windfall rates however it fails to recognise that ‘ town centre sites’ (a traditional source of windfall supply) are allocated in the plan through the town centre masterplan and the Council have identified other sources of supply through the brownfield register. In the absence of any assessment / analysis of this component demonstrating the projected level of future windfall provision taking these factors in account, we consider that the level of windfall should be reviewed and adjusted accordingly.
UK Central Hub
We consider that given the scale of the UK Central Hub proposals, the rate of delivery assumed by the Council is overly optimistic. The Council have not provided any trajectory for the Site, and we note that the August 2020 consultation did not contain any firm commitments to delivery timescales or set out any delivery partners.
This assertion is supposed by the findings of the Lichfields’ Report1 that sets out the average time from outline planning application to the first delivery of homes is 8.4 years. The average build out rate is 160dpa.
As such, taking this into account, and based on a LPR adoption date of 20222, we consider the first completions will likely be C.2030. With an average build out rate of 160dpa, this means that approximately 960 dwellings will be delivered during the Plan Period, assuming that the housing is within the first delivery phases (the August 2020 consultation referenced a mix of uses coming forward). While more outlets may increase the speed of delivery, the amount of infrastructure required also needs to be taken into account. The type of supply also needs to be considered, with UK Central Hub likely to be geared towards apartments.
As such, we consider that 1,780 houses should be removed to take into account the likely delivery timescales.
Trajectory
We also note that SMBC are seeking to provide a stepped trajectory as some of the larger sites will not make a significant contribution to completions until the mid-delivery phase. The Inspector assessing the Guildford Local Plan set out:
39. In the submitted plan, the combined effect of the stepped trajectory in Policy S2 together with the “Liverpool” methodology (in which the delivery shortfall accumulated over the first 4 years of the plan (2015/16 to 2018/19) is spread over the whole plan period), would have deferred a significant proportion of the housing requirement to the later years of the plan. Set against the (then higher) housing requirement, this would not have met the Government’s objective to boost the supply of housing in the shorter term. (our emphasis)
We consider that SMBC should take the same approach as Guildford and allocate further sites to meet need early in the Plan Period. The existence of the UK Central Hub is not of a sufficient size to warrant a different approach (i.e. it is not akin to a new settlement).
Further, as with the withdrawn Uttlesford Local Plan, this stepped trajectory may create a fragile 5 year housing land supply position, taking into account the ambitious delivery targets of the UK Central Hub and the delivery concerns relating to the draft allocations set out below. The Inspectors’ letter relating to the withdrawn plan states:
29. This calculation relies on the use of a reduced annual requirement of 568 dpa for most of the years, as it is based on the stepped trajectory set out in Policy SP3. It is also based on what we consider to be unrealistic commencement/housing delivery dates for two of the Garden Communities (North Uttlesford and Easton Park, as set out above). So, whilst the Council can, in theory, demonstrate a 5.65 year HLS, we are concerned that if the housing delivery at North Uttlesford and Easton Park slips by just one year, as seems very likely, this would result in 100 less dwellings in this 5 year period. This would result in a very fragile 5 year HLS position.
There are comparisons that can be drawn here based on the stepped trajectory and the anticipated 5.37 year supply upon adoption.
The Inspectors for the withdrawn Uttlesford Local Plan also referenced the need to meet the full objectively assessed need for market and affordable housing in the housing market area (NPPF Paragraph 47). The HEDNA states there is a ‘clearly acute’ shortage of affordable housing. The proposed stepped trajectory therefore may worsen the affordability problem as it would delay the provision of housing until late years of the plan period.
Taking the above into account, we consider that the SMBC’s supply is actually 11,496 (rounded) before any reduction in windfall or the deletion of draft allocations which are unlikely to be delivered is taken into account.
This is a reduction of 3,521 and, as such, to meet the increased demand set out above, and take into account the concerns relating to a stepped trajectory, a review of the supply is required and additional sites allocated.
The Council should also ensure that a large number of these sites can be delivered early on in the Plan Period in order to take account of the likely later delivery of some other sites.
Soundness – The Plan is not:
• Positively prepared
• Justified
• Effective
• Consistent with national policy
Change Sought:
• Review of demand and amendment to the strategy
• Review of supply and amendment to the strategy
• Allocation of additional sites to ensure housing need is met (including suitable provision for wider HMA needs) and an annualised trajectory is possible
Improving Accessibility and Encouraging Sustainable Travel
Policy P7 Accessibility and Ease of Access
We consider that the requirement for major residential development should be clarified to set out that there may be other ways in which sustainable access options can be implemented. The distance to a bus stop/train station should not be seen as the only measure of sustainable access.
Soundness – The Plan is not:
- Positively prepared
Change Sought:
- Policy should be clarified that there are other ways of ensuring sustainable transport options are available
Policy P8 Managing Travel Demand and Reducing Congestion
Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. Within point 2(ii), SMBC are seeking to bring in a further test which would not be in accordance with the NPPF. This should therefore be deleted.
Soundness – The Plan is not:
• Consistent with national policy
Change Sought:
• Point 2(ii) should be deleted
Protecting and Enhancing our Environment
Policy P11 Water and Flood Risk Management
With regards to point 6, the confirmation of discharge into a public sewer falls under Section 106 of the Water Industry Act 1991. As such, it should be made clear that planning permission can be granted prior to this being confirmed, as it falls within a different regulatory regime.
With regards to point 14, it should be clarified that contribution through a Section 106 Agreement is only required where it meets the tests set out in NPPF Paragraph 56.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Deletion of point relating to confirmation from relevant infrastructure owner
• Clarification as to obligation requirements and the necessary tests
Promoting Quality of Place
Policy P17 Countryside and Green Belt
Within Point 1 of the policy, SMBC is seeking to safeguard best and most versatile agricultural land (BMVAL) unless there is an overriding need for development that outweighs the loss. BMVAL is referenced within the NPPF at Paragraph 170 which states that planning policies should contribute to and enhance the natural and local environment by taking into account a number of criteria. One of these is:
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.
Firstly, we consider that including reference to BMVAL within a policy relating to Green Belt seeks to conflate two separate issues. Further, as can be seen above, the test set out by the NPPF does not require the safeguarding of BMVAL. Planning policies are required to contribute to and enhance natural and local environment by recognising economic and other benefits from BMVAL. As such, we consider this point should be deleted.
SMBC have set out, within Point 4, a number of different factors that may be taken into account when considering very special circumstances.
Further to this, point 5 sets out that development that is ‘conspicuous’ from the Green Belt must not harm the visual amenity of the Green Belt by reason of siting, materials or design. Given Green Belt is a spatial designation, designed to prevent sprawl, we consider that this requirement goes beyond the scope of the Green Belt, as set out in the NPPF. The LPR contains policies relating to protecting landscape, where necessary, and as such, this point should be deleted.
Soundness – The Plan is not:
• Positively prepared
• Consistent with National Policy
Change Sought:
• Deletion of point 1
• Inclusion of further factors which may create very special circumstances
• Deletion of point 5
Policy P17A Green Belt Compensation
Paragraph 138 of the NPPF sets out that ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.
Policy P17 is seeking to require this by requiring development on sites removed from the Green Belt to provide appropriate compensatory improvements to environmental quality and accessibility of remaining Green Belt in the form of a Section 106 Agreement utilising the below hierarchy:
1. Compensatory requirements as set out as part of the Local Plan masterplans
2. Where no compensation has been set out within the Local Plan masterplan, improvements are provided as:
i. Improvements within the Green Belt adjacent to, or in close proximity to, the development site;
ii. Improvements within the Green Belt adjacent to, or in close proximity to, the settlement or area accommodating the development;
iii. Improvements within the Green Belt in an area identified for environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.
3. In the event it is robustly demonstrated that none of the above options can be satisfied then the Council will accept a commuted sum.
Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.
Soundness – The Plan is not:
• Consistent with National Policy
Change Sought:
• Reconsideration of the policy to ensure that it is evidenced based, does not impact upon viability of schemes, and is in accordance with national policy
Delivery and Monitoring
Policy P21 Developer Contributions and Infrastructure Provision
Policy P21 expected major development to provide or contribute towards the provision of measures to directly mitigate its impact and physical, social, green and digital infrastructure.
SMBC’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.
Soundness – The Plan is not:
• Justified
• Consistent with National Policy
Change Sought:
• Confirmation that digital infrastructure provision allows for viable development
Settlement Chapters
Policy BC1 Barratt’s Farm, Balsall Common
We note that 1,756 new homes are proposed for Balsall Common across the plan period with the sole justification seemingly being that it contains both a primary and secondary school and has a full range of retail and associated facilities. However, it is still described as a rural settlement with no significant areas of employment and the distribution strategy remains one of “proportional distribution”. 1,756 dwellings to a single rural village would be completely disproportionate. There is discussion in the document regarding delivery of a by-pass; provision a station car park; improved public transport and a new primary school. However, there is no discussion as to how these are to be funded / delivered relative to the level of growth identified. In addition, there is discussion regarding the scope to enhance the existing local centre and the provision of a village centre masterplan. However, this land is in multiple ownerships and there are no proposals for what these enhancements could entail or how they could function – particularly with a by-pass in place which could actually draw trade away from the existing centre.
There is no assessment of the ability of Balsall Common to deliver this level of growth in such a small area. Whilst clearly some sites (i.e. Barratts Farm) will be able to have multiple outlets, the ability of the market to absorb and deliver multiple sites at any one time in a rural location should be reviewed; particular when Balsall Common will be acutely affected by HS2 – both in terms of the physical construction of the line and the disruption and uncertainty that this will bring; but also in terms of market desirability until such time as the line is constructed.
We also note that Barratts Farm is in multiple ownerships and these are described as “complex” in paragraph 541. This is the single largest site and the one which is proposed to deliver the by-pass. Within the previous draft of the Plan, it was stated that this site would only be taken forward if the landowners / promoters could demonstrate they are working on a collaborate and comprehensive basis. Reading paragraph 541, this collaborate working has clearly not been secured in the way it was envisaged and nothing additional is suggested to demonstrate that joint / collaborative working is possible.
The relief road is identified as being necessary for Barratts Farm in particular with the policy advising that is required early in the plan period. The road is provisionally to be funded via CIL payments; and grant funding which “may” be possible through the WMCA. Firstly, CIL payments can only be secured through those sites which will come forward in the future however these sites are Green Belt sites and cannot therefore be delivered until the Local Plan Review is completed and the subsequent CIL schedule is adopted. Secondly, there is no grant funding proposal in place to fund the road. As it currently stands this road is not deliverable. The road is required to be delivered early in the plan period i.e. before there are significant CIL funds in place and, potentially, at a point where, in order to receive grant funding, applications should be being made now / near future.
There has to be serious doubt over the ability of Barratts Farm to be delivered within the anticipated timeframes and therefore places serous doubt over the plan as a whole given the scale of this allocation.
The Sustainability Appraisal notes that there are limited employment opportunities within Balsall Common and that people travel outside of the settlement to work. As such, it is noted that the expansion of this settlement would fly in the face of sustainability objectives of reducing the need to travel to areas of employment. Whilst such a case could be made for the majority of the rural areas of the Borough, it is heightened especially here when such a large proportion of future growth is identified for one rural settlement.
At this stage, the level of growth attributed to Balsall Common is disproportionate and that inadequate research has been undertaken into the deliverability of this level of growth and the associated aspirations; and the ability of the market to deliver this level of growth in a rural area is considered to be unrealistic.
On the basis that we do not consider the sites identified to be deliverable and the significant shortfall in supply identified by the more realistic timescales we have identified for UK Central, we propose an alternative site – Land at Hawkshurst (Site 544) as an alternative to meeting part of this need. To date this site has been inappropriately assessment by the Council and a more appropriate evaluation of the site is given in the section below.
Policy BL1 – West of Dickens Heath
The policy requires that the proposal for BL1 secures the relocation of the existing sports provision to a suitable site in the local vicinity. Until such time as these facilities are relocated or a plan is in place to secure timely relocation (which should include the grant of planning permission in our view, given that any site will be in the Green Belt), then the site cannot come forward for development. Our key concern here relates to Site 4 (West of Dickens Heath). It is noted that the identification of a Local Wildlife Site within the site hampers re-provision within the site itself and therefore alternative options will need to be pursued outside of the site. We consider that these alternatives should be considered now as clearly, as it currently stands, the pitches will be lost with no alternative in place (and therefore no guarantee of any re-provision). This is all the more important given that the land in the area is all located within the Green Belt and therefore any proposals which may, for example, include floodlighting, will have to be carefully considered against the Green Belt ‘tests’. We understand that the loss of these facilities is causing significant local concern particularly with no proposals for replacement.
The Council have had ample time to identify and secure alternative provision and therefore the fact that this is not identified within the plan, suggests that there are currently no alternative sites. This calls into question the delivery of this site and with no evidence and no proposals in place, we consider that proposal BL1 should be deleted from the plan.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Policy KN1 Hampton Road, Knowle
As with the Site West of Dickens Heath, this draft allocation requires the reprovision of sports pitches. In this instance, the re-provided pitches are currently shown within the Green Belt to the north of the allocation.
The Council, within Paragraphs 713-715 state that it’s likely that very special circumstances will exist to support development in this location and, as such, the reprovision will likely be acceptable. However, this pre-judges any application, for which the detail is not known, and as such cannot be relied upon. Therefore the housing that would be provided on the sports pitches should not be included until the reprovision of the sports pitches is secured.
Soundness – The Plan is not:
• Justified
• Effective
• Consistent with National Policy
Change Sought:
• Reprovision of the sports pitches should be secured prior to allocation
Site Assessment Criteria
We consider that a more dispersed growth option should be considered and, as set out previously, consider that the land at Broad Lane, Hawkshurst (Site 544) is ideally suited to make an important contribution to the Council’s housing need. Following the Council’s own site selection criteria, we set out why this site is a suitable and deliverable alternative site which can be delivered utilising existing infrastructure:
We object strongly to the manner in which Site 544 has been assessed in the site selection process for the reasons which are set out below – and on that basis, object to the inconsistent application of the methodology.
Firstly, in assessing Site 544, the Council deemed that the site did not pass ‘Step 1’ – which is the initial, high-level sieving process. Sites which are not taken forward at this stage are then not subject to the more refined ‘Step 2’ analysis. We consider the manner in which the process was applied is fundamentally flawed and have carried out our own assessment (using the Council’s own analysis) to demonstrate that the site should not have been discounted at Step 1 and should have been included in Step 2.
STEP 1
The first stage in the sieving process is a high-level look at the following:
(i) Brownfield vs greenfield
(ii) Urban areas vs Green Belt
(iii) Accessibility
Sites can be rated from Priority 1 (brownfield in urban area or settlement) to Priority 10 (greenfield in isolated highly performing Green Belt location). A traffic light rating is then applied – sites which falls within Priority 1 to Priority 4 are green sites; Priority 5 sites are yellow; Priority 6, 6b and 7 sites are blue; and Priority 8, 9 and 10 sites are red. Red sites fail Step 1 and are not taken forward to Step 2 for assessment. Site 544 was incorrectly identified as a Priority 9 red site and was not therefore taken forward to Step 2.
In summary, Site 544 is a greenfield and Green Belt site. However, it is accessible (being on the edge of the Coventry urban area) and also within an area with a low GB score of 5. Therefore, it should be allocated a Priority score of no higher than 5 (yellow). We review below the manner in which this initial sieving assessment was flawed - taking Site 544 step by step through the same assessment process as the Council.
Green Belt
In the Green Belt Assessment 2016, Site 544 is identified as part of Refined Parcel RP83:5 which has a combined score of 5, within a range from the highest performing Green Belt sites (12) to the lowest performing sites, scoring as low as 0. With a score of 5, site 544 is clearly a lower performing site. The starting point for consideration as a Priority 5 site is a score of 5 or lower in the Green Belt––Site 544 falls into that category. The results of this assessment are backed up by our own Green Belt assessment which is included with this submission.
Accessibility
The second part of the criteria relates to accessibility and to achieve a Priority 5 ranking, the site is required to be in an accessible location. This is defined as:
(a) On the edge of the urban area or
(b) On the edge of a settlement which has a wide range of services and facilities including a primary school and a range of retail facilities.
Site 544 adjoins the urban edge of Coventry – indeed in the Council’s Site Assessment, the site is identified as possibly being an extension to Coventry.
It should be noted that in relation to the Publication Draft Plan, the Council have updated the Accessibility Study to take account of retail / surgery provision in adjoining LPA areas, however they have then not used this information to re-visit first principles and determine whether sites have been appropriately assessed from the start. Therefore, whilst this site now scores more positively, its ‘priority 9’ status has not been re-evaluated despite an Addendum to the Site Assessments being produced and the Accessibility Study being revisited. It appears that despite the site being on the urban edge of Coventry this has been discounted due to the sites geographical relationship with Coventry as opposed to Solihull. However, accessibility should be based upon spatial location rather than boundaries. The fact that the retail offer is in Coventry will not prevent residents of Hawkshurst using it.
For the absolute avoidance of doubt therefore, we enclose our own submission produced by Phil Jones Associates which demonstrates that the site is in a suitable and sustainable location.
It is fundamentally incorrect for Site 544 to have been ‘sieved out’ at Step 1. The site should have been correctly assessed as a Priority 5 yellow site as it meets the two necessary criteria. The site, therefore, should have been taken forward for a more detailed analysis in Step 2.
On the basis that the site does pass Step 1 – we have carried out the Step 2 assessment using the same table and criteria as the Council. There are no scorings or weightings attributed to the Step 2 analysis – it assessed on a qualitative basis.
STEP 2 – REFINEMENT CRITERIA
FACTORS IN FAVOUR
In accordance with the spatial strategy
(including only proportional additions to lower order settlements (i.e. those without a secondary school or not located close to the urban edge).
The preferred spatial strategy would be to locate development needs close to where they arise. However the Plan identifies that there is limited land available to achieve this and therefore the Council has had to look at alternative options, which includes land released from the Green Belt in the form of urban extensions and also followed a more dispersed strategy for development. They have sought to focus development in locations that are, or can be made, accessible and sustainable. Such locations are identified as typically being on the edge of urban areas (or within ruralsettlements) that have a greater range of services. Potential locations for development include adjoining the urban edge or a highly accessible settlement. This will have the benefit of focusing on urban areas and sustainable urban extensions to provide the best opportunity for achieving accessibility and delivering public transport improvements.
It is abundantly clear that geographically Site 544 adjoins the urban edge of Coventry – Coventry is the second largest City in the West Midlands, after Birmingham. Site 544, as confirmed in the SHELAA assessment, would be viewed as an urban extension to Coventry and there is, therefore, no doubt that Site 544 is in accordance with the Spatial Strategy, which seeks to locate development in the most accessible locations. Coventry is clearly such a location and there is nothing within the Spatial Strategy which would rule against this.
Therefore, it can only be concluded that the development of Site 544 would be in accordance with the Spatial Strategy.
Any hard constraints only affect a small proportion of the site and/or can be mitigated.
The SHELAA does not identify any hard constraints – we concur with this assessment.
The site would not breach a strong defensible boundary to the Green Belt.
There are no strong existing defensible Green Belt boundaries that would be breached. The existing boundaries to Bannerbrook Park comprise simply hedgerows, some of which were planted in conjunction with the existing development. The same form of boundary treatment can therefore be replicated on this site and indeed is proposed within the masterplan included with this submission.
Any identified wider planning gain over and above that which would normally be expected.
Following discussions with local undertakers regarding the lack of burial space available within the Borough, the landowners are willing to offer land for a multi faith burial space which will provide a much needed facility for the Borough and also secure the long term permanence of the Green Belt boundary in this location.
Sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
See above.
If finer grain accessibility analysis (including output from the Accessibility Study) shows the site (or the part to be included) is accessible.
The Accessibility Study is flawed when it comes to assessment of sites on the Solihull / Coventry boundary. The Study provides a scoring for accessibility for facilities within 1,200m of a site, however when assessing facilities beyond the administrative area of Solihull only facilities within 800m of the boundary are assessed, this is despite an updated assessment being provided in 2020 which proposed to apply some adjustment of standards and yet makes no sensible adjustment to standards for cross boundary provision. Sites in such locations are not therefore being assessed on a comparable basis. Furthermore, the assessment is only being undertaken of walking distances and makes no allowance for accessing facilities by bike. The document references ‘shared cycle’ routes but then makes no consideration of people actually using them for cycling. Clearly were cycling to be factored in, especially for those sites, which adjoin major settlements and therefore have access to a good cycleway network (such as Site 544) then their accessibility criteria would be much improved.
Whilst it is noted that some provision is now taken off cross boundary retail provision and public transport which has moved Site 544 to a higher scoring position; it is still not being assessed on a comparable basis.
There is a shared footway/cycleway through the Bannerbrook Park development which can be extended into Site 544. Furthermore, opportunities will be considered to accommodate a bus route through Site 544 and on through Bannerbrook Park.
It is therefore clear that the proposal can only be defined as being in an ‘accessible location’.
FACTORS AGAINST
Not in accordance with the Spatial Strategy
As set out above, the development of this site is in accordance with the Spatial Strategy
Overriding hard constraints that cannot be mitigated.
There are no hard constraints identified.
SHELAA Category 3 sites unless demonstrated that concerns can be overcome.
The site is not identified as a Category 3 site in the SHELAA. We make comments below in respect of the flaws of SHELAA assessment and carry out our own assessment.
Sites that would not use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt.
As already confirmed, the site uses existing defensible boundaries and proposes to strengthen the defensible boundary and strengthen existing hedgerow planting.
If finer grain analysis shows the site (or the part to be included) is not accessible.
As previously confirmed, the Council have failed to consider the proximity of services in Coventry on a fair basis and because of this, it is not possible to determine how detailed the assessment has been. However, given that the site adjoins a major urban area is it simply not feasible to draw a conclusion that the site is inaccessible.
If the site is in a landscape character area that has a very low landscape capacity rating.
It is wholly unreasonable if the Council have used this criterion to discount this site. According to the Council’s Landscape Character Study (December 2016) this site falls within Landscape Character Area (LCA) 26 – which covers the eastern fringe of the Borough – yet significant Green Belt release is proposed in other areas of the Borough which are in an identical LCA. With one blanket ‘very low’ landscape capacity conclusion for such wide areas it cannot be used to discount some sites and not others – there must be parity in assessment. Furthermore, the study itself (page 49 – text adjoining Table 24) confirmed that it is not possible to establish a baseline sensitivity to change without having details of a given development proposal and therefore the conclusions should be taken as a guide only. On this basis, we do not consider it appropriate to use this criterion as a basis to discount sites given sites with the same assessment have been given a ‘green’ score’.
We enclose with this submission our own detailed, site specific, landscape and visual appraisal which confirms that the site has the ability to accommodate development of scale which is comparable to the surrounding area without compromising the function of the surrounding Green Belt.
If the SA appraisal identifies significant harmful impacts.
The SA identified 2 harmful impacts:
(i) The site contains over 20ha of Grade 1 – 3 agricultural land.
The site is wholly Grade 3 agricultural land – clearly within Grade 3, the site could in fact be Grade 3b land which would mean it is not BMVL. Furthermore, the Regional ALC mapping, which was last updated in November 2018, shows this to be the prevailing land type across the Borough which is not unsurprising. As a result, a number of proposed allocated sites have the same classification. It is not therefore appropriate to identify this as a harmful impact when a consistent approach has not been applied across the board.
(ii) The distance to jobs is identified as 8km within the SA
This is clearly incorrect as the SA treats the administrative boundary between Coventry and Solihull as a line which people will not cross. This is clearly incorrect. As already stated, there is for example a good bus connection to Warwick University which is a key local employer as well as Coventry city centre which offers multiple employment opportunities. The SA has applied the same approach to all services and facilities – relating its conclusions only to Solihull Borough and thus the distances to shops / schooling / healthcare are distorted. In addition, we highlight that this is a specific issue related to Balsall Common also (which is also further away from Coventry) and yet the Council has seen fit to allocate in excess of 1,700 dwellings in Balsall Common.
In summary:
• The site has medium / high accessibility – at the same level as the other ‘green sites’ identified in the Draft Plan.
• The site is in lower performing Green Belt than other ‘green sites’ in the plan.
• The site has existing defensible Green Belt boundaries which can be strengthened.
• The site has no constraints within the development area which cannot be mitigated in the normal way.
• The site has the same landscape character as other ‘green sites’.
• It is not, therefore, credible for Site 544 to be categorised as a ‘red’ site.
• For this reason, we consider the score for Site 544 should be corrected and the Council should re-visit their assessments from first principles.
As is evidenced from the corrected SHELAA commentary the site is rated as a Category 1 – Deliverable Site. Such sites are deemed to be available now, offer a suitable location for housing now and there is a reasonable prospect that housing will be delivered on site within 5 years from the date of adoption of the plan.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13891

Received: 13/12/2020

Respondent: Councillor T Hodgson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to proposals on grounds of:
- Flood Risk
- Disproportionate level of housing in Blythe ward
- Lack of detail in plan on how it will cater for increased demand on primary care services
- Erosion of Green Belt
- Coalescence between settlements
- Increase to existing traffic congestion
- Increase to pollution

Full text:

See attached letter.

Attachments: