Policy UK2 - Land at Damson Parkway

Because of the lack of information provided and the failure to consult the local community and trying to approve this behind residents backs, the plan should justify the need for an improved tip and then provide the reasons why this is the preferred site. We still need to be exactly clear on where the site is including, entrance, exit and queuing points. We need to fully understand any alternative site identified and why this was rejected as the preferred site. And we need to fully understand why the existing site can not be improved/expanded. The plan should provide clear and concise information and provide unbiased reasoning behind there findings.

The proposed relocation of the tip is not legally compliant because the local community have been kept largely in the dark until very recently and have had nowhere near enough time to digest the enormity of the proposal.
Insufficient evidence has been provided regarding the necessity to move the tip against improving the current facility which should surely be the more sensible solution. A full traffic assesment which should take into account the JLR traffic has not been provided and there has been no co-operation with other local authorities to examine alternative solutions.

Development of remaining green belt between Damson Parkway & A45 should be stopped due already high levels of noise and air pollution. HWRC needs to be relocated to site away from residential areas, not nearer! Look at developments made by Leics (Ashby) and Oxon (Ardley).

Relocation HWRC contradicts Council’s own declared objectives, para 38 (c), (d), (g), (j) and (k), the defined Challenges and associated Objectives, specifically Challenges A, C, E, F, J, M & N.
Paras 293 & 299, Solihull MBC charges itself with development and growth of clean air; improving the health and well-being of residents; creating sense of space, reducing noise impacts. Proposals contained in Para 831 are irreconcilable with these goals.
Para 831 development contains two serious inaccuracies: road infrastructure and new HWRC site being “relatively isolated”.

1) Proper consultation should have taken place, which it has not and items 104 to 107 should be taken out of the plan.
2) The area should be left in Green Belt
3) An alternative site should be found for the refuse facility

I refer to section 104 to 107 and my objection is as follows:-
1) My home over looks this area and no one from Planning dept has attempted to contect me to consult.
2) section 105 suggests this site is taken out of Green belt because "it may be attractive to businesses and investments that support the automotive and motorsport industries" May be is not a strong enough justification to take out a vital part of Green belt and Meriden Gap
3) Section 105 suggests moving the Refuse Facility to this site. JLR traffic involves surges in traffic at shift end, which in reality is a high volume of very fast moving impatiently driven cars that will be mixing with JLR feed lorries between the main plant and the new distribution depot. The road system is inadiquate to handle this traffic, and certainly inadiquate to add refuse trafic on top of this.
4) Section 105 suggests moving the Refuse Facility closer to residental areas and Elmdon park. It should be moved further away not closer to

That the household waste facility, if it needs to be relocated, should move to a more suitable brownfield site on the edge of Solihull, not in a central part of it near to houses.

This site is not fit to house a relocated Household Waste and Recycling facility as the area has already been heavily built on. It will add more traffic to an area already busy from existing houses and JLR traffic and which will only get busier if the plan for 700 new homes is approved. The site is a residential area and not suitable for waste facility.

Leave the waste disposal site where it is situated now.
Stop ruining the countryside.

The council have never explained what the benefits are, if any to local residents.
No consultation with residents.
Possible traffic jams, which we suffer now with the Land Rover development.
It appears that all we are going to get is more pollution and traffic jams.
It is apparent that Solihull Council believe this move to be a benefit to the residents.
The council have shown no consideration to the residents who live in the immediate area and who could possibly see their properties depreciate in value. Every where in the vicinity will become an even greater bottleneck .

There seems to be very little transparency here on why Site UK2 Land at Damson Parkway is considered a suitable location for a relocated Household and Waste Facility. This combined with a complete lack of publicly available documents noting the details of its specific location within the overall UK2 site, means that residents are unable to effectively scrutinise the proposals for the relocation.

I object to the plan as the Cushman and Wakefield report, the supporting document, says that this land shouldn’t be declassified as green belt as it would not meet the criteria for re-zoning. Also, the potential relocation of a Household Waste and Recycling Facility to site UK2 will only further increase pollution in an area that already has unacceptably high pollution levels. I disagree with the refusal to extend the consultation period on the Local Plan as a whole, as well as, the lack of consultation with Elmdon residents and councillors, who will be most affected by the potential relocation.

Develop the existing site at Bickenhill which is away from residential areas and serviced by an A road. Improve road access to the site and manage user traffic with a workable booking system.

This is a flood risk area and development here will increase the severity and occurrence of these events. There will be increased traffic around the area especially Damson Lane which is already a rat run for people trying to avoid the traffic on Damson Parkway during peak times.
The development is near residential areas with more housing developments planned which will also lead to increased traffic parking and local unrest. I disagree that there will be improvements to the Green Belt because developments such as this only reduce the amount of Green Belt land.

The plan to locate the waste facility at this location should be abandoned and an alternative location chosen. The chosen location should be in an existing industrial setting and not one that is near to a residential area.

The construction and operation of a waste disposal and recycling facility in the proposed location of Damson Parkway would bring severe levels of noise, pollution and disruption to the residents of the Damson Parkway estate. The siting of such a facility so close to a residential area will have a great impact on the levels of harmful emissions, both from the plant itself and the vehicles accessing it. This facility will have a detrimental impact on the quality of life and on the mental health of those living nearby and bring dangerous levels of vehicle traffic.

Tip shoul dremain where it is and be extennded at it's current site.

Damson Parkway is a residential area and not a suitable place for a tip

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 across those parts of the site that have not been previously archaeologically examined. 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.

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.

*WCC Archaeological Information and Advice, 2018. 'Archaeological Assessment to Inform the Solihull Metropolitan Borough Council Local Plan'. Warwick: WCC Archaeological Information and Advice

The HWRC etc should be situated further away from houses and businesses.

This is already a congested area, and becoming more so due to the JLR logistics centre. This facility should be situated elsewhere.

An area away from an already busy road but still available from across the borough, with controllable access not impacting on local traffic in a negative manner.

The idea of relocating the Council public waste site to some point on Damson Parkway seems unreasonable given that the road is a busy link road from Solihull to the A45 and the JLR plant, already carrying a steady amount of traffic which could easily be gridlocked with a high demand for the waste disposal site.

Dear Solihull Council,
Email re-sent with name and specific address to comply with requirements.

As a resident, I am writing to register my objection to the relocation of the Household and Recycling Centre to land within site UK2 at Damson Parkway.

This is clearly an inappropriate development, at this proposed site, and seems to me; to directly oppose many of the criteria set out in the local plan.

Solihull Local Plan - Draft Submission has a sub heading ‘ A plan for people and places where wellbeing and the environment matter’. The people of Damson Parkway will see any further development, particularly the Recycling Centre, as being in contradiction of these fine words.

The recycling centre proposal comes in addition to the significant expansion of the JLR facility, with development of their Logistics Centre. As a former JLR employee, I understand the need for this facility, but nonetheless it is unsightly and will significantly add to traffic density in the local area (despite the improved roadways). Let’s not forget JLR have expanded to the other side of Damson Lane with the Vehicle Dispatch facility.

We also have had major development of the Airport with greater engine noise when planes take off and land, plus the consequential added pollution. Solihull Moors football club car park is not sufficient for their needs, with supporters using Damson Lane for parking overspill.

The very nature of a Household Recycling Centre is that it can be accessed by the public. The public will visit the centre to suit their specific needs and that flow of traffic cannot be planned. Add to this the JLR increased traffic, Solihull Moors, Elmdon Park visitors and you will have guaranteed traffic disruption.

Please recognise these issues and do not proceed with the relocation of the Recycling Centre.

See Attached Word doc.

Dear Sir/Madam,
Please see attached representation in support of Policy SO2 Moat Lane Depot submitted on behalf of SMBC Strategic Land and Property (as landowner).
Submitted are the following:
• Representation Form
• Representation – Site SO2 Moat Lane Depot
• Site SO2 Moat Lane Depot - Preferred Concept Masterplan (attached)
I would be grateful if you could confirm receipt.
Please let me know if you have any questions.
We are happy to combine this submission into a single document if helpful for publication.
Thank you.
Kind regards, Clare

See Attached Letter.

It is recommended that the following clauses should be added to Policy UK2:

“6. The concept Masterplan document should be submitted alongside evidence of meaningful
engagement with key stakeholders, landowners and interested parties.

7. The concept Masterplan should not prejudice Birmingham Airport’s ability to achieve it’s
sustainable growth aspirations and serve the region as a key economic asset.”

Further justification should be included in the policy to provide more clarity on how the Masterplan will be developed. This includes guidance on significant stakeholder and landowner engagement and how such engagement will be recorded and addressed.

Thank you for consulting Birmingham Airport Limited (hereafter referred to as ‘BAL’) in respect of the Solihull Metropolitan Borough Council (hereafter referred to as ‘SMBC’) Local Plan – Draft Submission Plan (hereafter referred to as the ‘Local Plan’).
Birmingham Airport: Key Economic Asset

As stated within the Local Plan, Birmingham Airport is a key economic asset and therefore its ability to grow sustainably and support both the national and local economy should be supported. The Birmingham Airport Master Plan 2018 remains relevant despite the short-term impact COVID 19 has had on the aviation sector. The Airport Master Plan included three growth scenarios (Government, balanced and high). Under the balanced growth scenario, the Airport is expected to grow to 18 million passengers by 2033. In the longer term, BAL expects to recover from the impact of COVID 19 and continue to have a positive impact on the regional economy increasing both the density and frequency of route networks to provide more choice for passengers in core catchment area and beyond.
Birmingham Airport’s regional significance is reinforced by the excellent connectivity to surface access it enjoys. This will be further enhanced with HS2, Metro and Sprint providing an opportunity for Birmingham Airport to increase the positive impact it can have on the region and the wider UK economy.
Pre COVID 19 estimates suggest that the economic activity associated with intra-UK connectivity at Birmingham Airport is worth approximately 4,500 jobs and £225m of GVA per year. In terms of extra
UK connectivity, Birmingham Airport is associated with approximately 47,700 jobs and £2.4bn of GVA each year (source: Oxera 2019).
BAL will continue to capitalise on its strong position within UK Central, as a regional airport providing
aviation services to the local community. This reduces the need for surface access travel to other airports which may be further away and has a range of benefits including reduced congestion on the road network, and lower CO2 emissions, air pollution and road traffic accidents.
BAL is committed to achieving a net zero carbon target by 2033 and will work collaboratively with SMBC to help achieve this.
Comments on the SMBC Local Plan – Submission Draft

This representation is informed by the Birmingham Airport Master Plan 2018 and the tests of soundness which are set out in the National Planning Policy Framework (hereafter referred to as ‘NPPF’) (para 35): “Local Plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound.”

Plans are ‘sound’ if they are:
1. Positively Prepared: providing a strategy which, as a minimum, seeks to meet the area’s
objectively assessed needs; and is informed by agreements with other authorities, so that unmet
need from neighbouring areas is accommodated where it is practical to do so and is consistent with
achieving sustainable development.

2. Justified: an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence This means that the Local Plan should be based on a robust and credible
evidence base involving:
• Research/fact finding: the choices made in the plan are backed up by facts.
• Evidence of participation of the local community and others having a stake in the area; and
• The Local Plan should also provide an appropriate strategy when considered against reasonable
alternatives. These alternatives should be realistic and subject to sustainability appraisal.
• The Local Plan should show how the policies and proposals help to ensure that the social,
environmental, economic and resource use objectives of sustainability will be achieved.
3. Effective: deliverable over the plan period and based on effective joint working on cross-boundary
strategic matters.
4. Consistent with national policy: enabling the delivery of sustainable development in accordance
with the policies in the NPPF. The NPPF is considered to be the government’s explanation of what
sustainable development means for planning policy therefore compliance with the NPPF is key
unless a locally justified departure is clearly evidenced.

Whilst BAL are supportive of the Local Plan and concur with the exceptional circumstances outlined in Policy P1 for releasing land from the Green Belt, BAL consider that minor amendments should be made to the wording of planning policies P1 and UK2 to help deliver a sound Local Plan.

Furthermore, additional policies should be included to ensure that West Car Park (circled in red
below) is safeguarded for future Airport use and any future development near the Airport boundary
does not harm Birmingham Airport’s aerodrome or airspace. These issues will be discussed in turn
below.
The plan below is taken from the Local Plan Proposals Map and shows the Airport, the UK2 site and
West Car Park.
Extract taken from SMBC Local Plan – Draft Submission
Policy P1 states that following in respect of Birmingham Airport:
“Policy P1 – UK Central Solihull Hub Area

ix. The Council will support and encourage further development needed for operational purposes such as passenger and freight facilities, terminals, transport facilities and other development that supports operational needs, or which allows the capacity of the extended runway to be maximised.
x. The Council will also support a broad range of ancillary and complementary facilities including hotels, administrative offices car parks and other appropriate facilities needed to serve the needs of air travellers using the Airport.

Proposals should be justified in terms of scale and in terms of supporting the Airport function and be appropriately located so as not to detract from Airport function.

xi. Where justified, development for Airport related uses beyond the Airport boundary will be permitted, providing that it accords with other policies in the Plan, including Green Belt policy. This will include opportunities within the allocated employment site (UK2).”

BAL Comment
Policy P1 should be amended to include reference to development for Airport related uses proposed
by Birmingham Airport only and the development of urban mobility. This ensures that the future of a
key economic asset is safeguarded.
Furthermore, reference should also be made to West Car Park, which may be required to provide
additional capacity for Airport related development beyond the 15-year horizon outlined within the
Airport Master Plan (see circled site above). The Local Plan is currently silent on its intentions for
this site.

Policy UK2 states the following:
“1. This site is allocated for employment development to meet local employment needs, needs associated with the key economic assets in the UK Central Solihull Hub Area, and for a potential relocated Household Waste and Recycling Centre and Depot.
2. Development of this site should be consistent with the principles of a Concept Masterplan for this site, which is expected to include the following:
i. No development within any area of higher flood risk zones;
ii. Relocation of the existing sports provision off Damson Parkway to a suitable site in the vicinity (see below);
iii. The existing sports provision off Damson Parkway will not be available for development until a suitable alternative site
is provided and ready for use, within the vicinity of the existing sites;
iv. The alternative site must be agreed with the governing bodies and Sport England;
v. The alternative site must be in accordance with the relevant policies of the plan, in particular Policy P20;

3. Likely infrastructure requirements will include:
i. Development of the site should provide flood alleviation to Damson Lane;
ii. The Low Brook corridor shall be significantly improved and turned into a high quality linear attenuation and water quality improvement area for SuDS;
iii. Highway improvements as required and access improvements along Damson Parkway and Damson Lane;
iv. Appropriate measures to promote and enhance sustainable modes of transport including pedestrian and cycle connectivity to surrounding residential areas;
4. Green Belt enhancements will include:
i. Improvements to environmental quality of remaining Green Belt between the main urban area and Damson Parkway;
ii. Improvements to the environmental quality of Green Belt to the east to enhance/extend the important grassland habitats to the east of the site.

5. The Concept Masterplan document should be read alongside this policy. Whilst the concept masterplans may be subject to change in light of further work that may need to be carried out at the planning application stage, any significant departure from the principles outlined for Site UK2 will need to be justified and demonstrate that the overall objectives for the site
and its wider context are not compromised.

BAL Comment
In accordance with intended connotations of the above mentioned policy, it is recommended that the
following clauses should be added to the policy:

“6. The concept Masterplan document should be submitted alongside evidence of meaningful
engagement with key stakeholders, landowners and interested parties.
7. The concept Masterplan should not prejudice Birmingham Airport’s ability to achieve it’s
sustainable growth aspirations and serve the region as a key economic asset.”

Policy UK2 continued:
This is an employment led land release of c94ha which will provide additional employment land to meet local needs, including future expansion for JLR and JLR related activities and ancillary development for Birmingham Airport. It will also provide an option for a relocated Household Waste and Recycling Centre and Depot, which will address needs set out in Policy P12 and enable the delivery of Site SO2 housing allocation. The release of the site from the Green Belt will meet
local employment and waste management needs, and needs associated with the key economic assets within the UK Central Solihull Hub Area.
The area east of Damson Parkway lies in a moderately performing parcel whilst the land to the west is lower performing in the Green Belt Assessment. Both parcels have been affected by development by JLR permitted under very special circumstances, so their contribution to Green Belt purposes is reduced. The site is in an area that has low capacity to accommodate change in the Landscape Character Assessment. The site performs reasonably well in the Sustainability Appraisal with three times as many positive or neutral effects than negative, and the only significant negative effect due to the size of the site.
A Level 2 Strategic Flood Risk Assessment has been undertaken for this site, as a small part adjacent the eastern boundary in the corridor of Low Brook lies within higher flood zones. This area is included within the green infrastructure proposals for the site, and development will be restricted to areas within flood zone 1 and should ensure that flood risk is not increased
to surrounding land uses. The low point on Damson Lane is known to flood significantly during rainfall events, so development at this point will be required to provide flood alleviation benefits to protect existing and proposed infrastructure.
The Low Brook corridor on the south eastern boundary of the site has the potential to be significantly improved and turned into a high quality linear attenuation and water quality improvement area for SuDS.
The exceptional circumstances justifying its release are set out in Policy P1. Compensatory improvements will be required for the loss of Green Belt as set out in the policy.
A concept masterplan will be developed to help guide development of this site.”

BAL Comment
In line with the Local Plan soundness criteria set out above, in order to ensure that the Local Plan is
fully justified, BAL consider that the above mentioned policy should provide more clarity on how the
Masterplan will be developed. This includes guidance on significant stakeholder and landowner
engagement and how such engagement will be recorded and addressed.

Aerodrome Safeguarding
As a statutory consultee, BAL is consulted on developments that are likely to impact on aerodrome
safeguarding. BAL is responsible for protecting the airspace around an aerodrome to ensure no
buildings or structures cause danger to aircraft either in the air or on the ground. This is achieved
through the ‘Obstacle Limitation Surfaces’ (OLS).
Whilst BAL support local and regional growth, this must be balanced against the need to safeguard
the Airport aerodrome and airspace. This is done through the aerodrome safeguarding process. This
process should be referenced within the Local Plan with a separate planning policy included to
ensure that any development (not just waste as is currently the case) with the potential to impact on
the aerodrome and airspace should be referred to BAL prior to the planning application being
submitted.
SMBC do consult with the BAL on planning applications close to the Airport boundary. However, the
process is often time consuming and the applicant often has very little knowledge of the safeguarding
process, what it might entail and crucially, how it might impact on timescales for determination of
planning applications.
Therefore, it is recommended that a new policy is added to the Local Plan, which deals specifically
with Aerodrome Safeguarding and encourages pre consultation with Birmingham Airport. Prior
consultation will benefit SMBC in meeting it’s statutory determination periods for planning
applications.
A brief explanation of the safeguarding process is provided below:

Aerodrome safeguarding covers several factors:
• Protecting the integrity of radar and other electronic aids to navigation by preventing
reflections and diffractions of the radio signals.
• Protecting aeronautical lighting, such as approach and runway lighting, by ensuring that they
are not obscured by any proposed development and that any proposed lighting could not be
confused for aeronautical ground lighting.
• Protecting the aerodrome from any increased wildlife strike risk. In particular bird strikes,
which pose a hazard to flight safety.
• Preventing any construction processes from interfering with aerodrome operations through
the production of dust/smoke, temporary lighting or construction equipment impacting on
radar and other navigational aids.
When BAL is consulted on a planning application, a safeguarding assessment is undertaken to
identify potential hazards to the Airport operation, as follows;
Obstacle Limitation Surfaces (OLS)
The OLS is an area of specified dimensions provided around the airport, an example is the areas at
the end of the runways where aircraft take-off and land. These protected surfaces extend as far as
a radius around the airport of 15km. The dimensions create invisible protected surfaces and areas
of airspace with height restrictions by which no development should infringe into.
The OLS assessment needs to determine that the airspace is free from buildings or structures that
have the potential to cause danger to aircraft. The objective is to protect the surfaces and
communicate back to developers or Local Planning Authorities what the findings are.

Construction
Construction equipment and cranes have the potential to infringe the protected surfaces around the
aerodrome and can impact on radar and other navigational aids by their height and moving parts.
All crane applications will be assessed and may need a permit to operate.
Several potential hazards can be created from construction activities. These include, temporary
lighting which can cause glare or confusion to pilots and air traffic control, and earthworks and soil
disturbance provides a food source for birds.
Communications, Navigation and Surveillance (CNS)

Technical Safeguarding
Air Traffic Control uses a range of equipment to undertake communications, navigation and
surveillance of multiple aircraft and vehicles. The primary task of air traffic control is to maintain safe
separation of aircraft on the ground and in the air.
Protecting the integrity of signals emitting from radar and electronic aids is critical, such as reflections
and diffractions (bending) of the radio waves (signals). Signals must conform to very high standards
of accuracy and interrupting them can cause degradation. An aircraft flying at night or in the fog must
be confident the signals provided are accurate. The process of assessment is known as “Technical
Safeguarding”.

Wildlife Hazards
Wildlife includes animals and birds on and near the aerodrome. This might include foxes, badgers
or even muntjac deer. The primary concerns are for birds and the risk of an aircraft striking a bird or
flock of birds. The flight paths, roosting and feeding sites are of interest and the airport is responsible
for continuous monitoring out to 13 kilometres.
Developments can easily influence bird behaviours. An example of this is a water park or landfill site,
which birds will be attracted to, they can fly up to 30 kilometres in a day to feed and back again,
twice. The generation and storage of putrescible waste will attract birds. These may cause the flight
paths of the birds to change and this could bring them across the runway or near to the airport.
Developments and contract works could also act as nesting or feeding areas for birds, such as large
pitched roofs, large landscaping schemes, earthworks which expose food for birds, buildings and
structures with perching opportunities.
Instrument Flight Procedures (IFP’s)
IFPs are rules established by aviation governing bodies allow aircraft to fly by reference to the
instruments in the aircraft. Navigation is accomplished by provided by electronic signals and aircraft
fly using these as a reference in defined areas of airspace. The Airport has Standard Arrival Routes
(STAR’s) and Standard Instrument Departures (SID’s) which are protected to allow a safe traverse
by aircraft.
IFP’s must always be clear of obstacles. The IFP surfaces must not be infringed and if they are it
may cause flights to be diverted or cancelled. Long term, this may impact on future airspace
development.

Lighting
Lights from local car parks, or construction sites, buildings or even street lighting can create dazzle
to pilots or air traffic controllers.
Ground lights on and approach lights to the runway provide a light pattern which pilots can
distinguish. The lighting pattern provides assurance to pilots for the critical task of landing the aircraft.
Unwanted lighting may cause confusion at the critical stage of landing or prevent an air traffic
controller from seeing important information.

Drones
Restricting drone operations to prevent impacts to aircraft safety is very important. This growing
phenomenon offers several challenges, but we have a permit system in place which allows drones
to be flown safely on or near the airport. Drone pilots must only do this if they meet specific criteria
and with express permission of Air Traffic Control.

Public Safety Zones (PSZs)
At the ends of our runway are areas provided to protect people. A PSZ is an area of land where
development is restricted in order to prevent people living and working within it. This minimises the
risk to people in the event of an accident. Certain amenities are permitted such as parks and golf
courses, but not permanent dwellings.

5G Technology
Whilst BAL supports technological advancements, the Airport does have a responsibility to ensure
that the aerodrome communication, navigation and surveillance equipment used for the safe
operation and navigation of aircraft are protected from any harmful interference.
Ofcom have identified an issue with the spectrum used by 5G when in the vicinity of aerodrome
radar bands, as well as the specification surrounding the permitted out of band emissions of the
mobile infrastructure, which could cause interference within the radar band.
Ofcom Guidance: https://www.ofcom.org.uk/__data/assets/pdf_file/0018/114264/3.4-Radar-Coordination.
pdf

Considering the above, BAL are requesting that planning applications (including pre-application
submissions) should include an assessment to demonstrate how there would be no harmful impact
on Birmingham Airport’s protected Radar system, as a result of any proposed development involving
5G technology.
In order to protect the Airport aerodrome and airspace, Birmingham Airport recommend that a new
safeguarding policy in included within the Local Plan, which can be informed by the text provided
above.
BAL are mindful of the positive impact the airport has and the potential the airport has to continue to
make a significant contribution to the regional and national economy and will continue to work
proactively with SMBC and our surrounding neighbours, residents, stakeholders, landowners,
businesses and visitors in the development of the next stage of the Local Plan.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

Removal of potential proposal for the Household waste and recycling plant to be relocated within the allocation.

Flexibility within the policy to accommodate the new dual carriageway proposal to improve accessibility and congestion at junction 6 and future plans to join to the allocation. Allow flexibility for future rail freight capability.

We write on behalf of our client, Jaguar Land Rover, to submit a response to the publication of the
Solihull Local Plan (Draft Submission) 2020 (Reg 19) consultation (the ‘Draft Submission Plan’).
Jaguar Land Rover’s Lode Lane manufacturing site (the ‘site’) employs approximately 7,000
people, operating 24 hours a day to meet the global demand for Range Rovers and the Jaguar FPACE.
It forms one of the largest employment sites in the West Midlands and is Jaguar Land
Rover’s largest manufacturing facility in the UK.
This site bounds the draft employment land allocation UK2 at Damson Parkway, Solihull (formerly
known as Proposed Employment Site 20 in earlier versions of the draft Plan), with specific
reference made to the site providing expansion opportunities for Jaguar Land Rover.
Jaguar Land Rover support the principle of allocating employment land at draft allocation UK2.
Jaguar Land Rover does however have serious and grave concerns with some of the detail of draft
allocation UK2 as submitted for Regulation 19 consultation, and requests Solihull MBC takes into
account the detail of this letter and makes the requested changes to this policy.
Concerns with draft Policy UK2
The recently published Draft Submission Plan October 2020 (Reg 19) amends the previous
wording of draft Policies UK2 – Land at Damson Parkway and P12 – Resource Management to
include an option for the provision of a relocated Household Waste and Recycling Centre and
Council Depot within the land allocation. Jaguar Land Rover has serious and grave concerns
regarding this addition within the allocation and does not support this amendment, due to following
potential implications:
▪ The potential impact on the future site expansion of Jaguar Land Rover’s Solihull
manufacturing facility;
▪ The potential impact on the future aspirations of creating direct access to the new M42
Junction 6 road link; and
▪ The non-compliance with adopted Policy P3 Provision of Land for General Business
and Premises.
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Future expansion
The continued expansion and growth of the largest of Jaguar Land Rover’s UK manufacturing sites
and one of the West Midlands’ largest employers, is largely constrained on the north, south and
west by the neighbouring urban form and protected Elmdon Park. Land to the east of the facility is
the only area that could accommodate growth. It is therefore essential that this land is protected for
the future expansion needs of Jaguar Land Rover.
As a recognised Key Economic Asset contributing to Solihull and creating a substantial number of
local skilled employment opportunities, the Solihull Local Plan Review reinforces the Council’s
objective to support Jaguar Land Rover’s continued economic success, understanding their need
to stay competitive and the requirement for growth through the proposed allocation of employment
land site Ref: UK2 (adopted and draft Policy P1). Site UK2 identifies the only area available for the
Lode Lane facility’s expansion, to the north/east of the existing site.
The land to the immediate north of the existing facility, to the west of Damson Parkway, was
granted consent for development in conjunction with the continued operation of Jaguar Land
Rover. The location of this development infills the remaining available land to the west of Damson
Parkway and south of the A45.
The proposed amendment to the justification text of Policy UK2 notes that part of the draft
allocation, to the south east of Damson Parkway, has been identified as an option for the relocation
of the Household Waste and Recycling Centre and Council depot. This area of land bounds Jaguar
Land Rover’s existing dispatch lot to the east.
The development of a Household Waste and Recycling Centre and Council depot in this location
would result in the total enclosure of Jaguar Land Rover’s Lode Lane facility, developing the last
area of land available as a natural extension to the existing facility’s footprint.
Further details would also be needed to understand the security provisions of any facility which
bounds our site. There is a potential to weaken defensible boundaries and pose additional security
risks.
Prior to the recent amendments to the wording of Policy UK2, the proposed allocation supported
Paragraphs 80 and 82 of the NPPF, seeking to create an identified area of employment land for
the continued growth and expansion of Jaguar Land Rover and/or for the addition of alternative,
complementary automotive use, creating a cluster of industry.
The proposed provision of a waste treatment facility and depot would result in the inability for the
continued growth of the existing large-scale local employer, one of the largest in the West
Midlands, contrary to their adopted and draft Local Plan and the National Planning Policy
Framework (2019) (‘NPPF’).
As such, Jaguar Land Rover request that the Household Waste and Recycling Centre and Council
depot are not located within draft allocation UK2.
Future connectivity to the highway network
Highways England has recently obtained consent for a series of works between Junction 5 and
Junction 6 of the M42, resulting in the creation of a 2.4km dual carriageway link road aligned to the
A45 and access via Junction 5A. This area of the M42 currently supports road access to
Birmingham Airport and significant business locations, such as the UK Central Solihull Hub Area.
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The justification for these works is supported by the current, significant congestion issues that form
a constraint to any future investment and economic growth in this area. The benefits of the scheme
once complete will be an increase in capacity at Junction 6, reduced congestion, improved access
to key business areas in the region, and improved local cycle and pedestrian routes.
There is a future aspiration to connect Damson Parkway directly with this new dual carriageway.
Such a link road would create a more direct route between the UK2 allocation and the M42,
directing traffic away from the existing routes and improving capacity on the local and strategic
road network. This could also allow for further economic development opportunities in the local
area in the future.
The route for such a link road is not yet known, nor has a case been made for it. As such, Jaguar
Land Rover is not asking Solihull MBC to protect the potential route but merely ensure the Local
Plan and allocation UK2 is sufficiently flexible to incorporate this road should it be needed during
the plan period between (2020-2036).
There is an aspiration to have rail freight connectivity serving the allocation to ensure future logistic
capability for all parties. Any plan policy should protect this aspiration.
Policy P3 assessment
Adopted Policy P3 protects allocated employment land for their allocated purposes and
employment uses defined as offices, industrial and warehousing, and where appropriate, waste
management. The amendment to the wording of Policy UK2 seeks to include waste management
as an appropriate land use at Damson Parkway.
Considering site UK2, it is located on both sides of Damson Parkway. The surrounding land
comprises the Jaguar Land Rover Lode Lane facility and its phased extension to the south of the
A45, whilst within the wider site there are several residential dwellings, a gypsy traveller site and
other small, home-based businesses.
Policy UK2 states that the waste treatment centre and depot would be located within the allocation,
understood to comprise the two land parcels to the east and north of Jaguar Land Rover’s dispatch
lot.
Based on the existing site uses and in the interest of enabling the continued growth of Jaguar Land
Rover, a waste management facility is not deemed appropriate in this location.
Policy P3a sets out five criteria for the assessment of alternative uses:
▪ Site is relatively isolated from other business premises or neighbouring uses;
▪ Demonstrated that there is no longer a need to retain the site for their intended
business class purpose; or
▪ There is no reasonable prospect of attracting business development in market terms;
▪ The alternative use will support sustainable development principles and directly deliver
employment locally; and
▪ There is no conflict with policies of the Local Plan or National Planning Policy.
Against the aforementioned criteria, a waste management site and Council depot in this location
would not be deemed appropriate. The proposed location is in proximity to a 24-hour operating
business, which is continuing to expand into the wider area. Furthermore, its neighbours include
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residential dwellings to the north and south, which are not directly compatible with a waste
treatment facility.
The site in its current form does not lack prospects for its future development, nor does it require
extensive marketing to identify potential interest, as this exists in the form of Jaguar Land Rover,
as identified in Policies P1, P3, UK2 and the Council’s objectives to support its continued growth.
The continued growth of one of the West Midland’s largest employers, in proximity to the existing
facility ensuring a concentrated operation, provides a clear rationale for supporting sustainable
development and the delivery of local employment. A concentrated approach reduces the travel
and movement of goods and people across Solihull, supporting the best use of space with their
dense development footprint maximising employment opportunities for skilled workers within the
local community.
Finally, the provision of a waste management facility that would severely constrain the continued
growth of an existing, prosperous and beneficial employer does not constitute the best use of land,
contrary to the NPPF. Jaguar Land Rover currently employ approximately 7,000 people at the
Solihull facility, with any expansion allowing for increasing figures and generating employment
rates in keeping with business use class densities. A waste management facility and depot,
however, would not provide employment densities of the same level based on the site’s function
and use of space, nor does it support the continued large-scale growth of an existing large
employer.
CONCLUSION
Jaguar Land Rover support the principle of employment land at draft allocation UK2 within the
Draft Submission Plan, supporting the continued growth and operation of employment uses within
the area.
Notwithstanding, the amended wording of draft policy UK2 identifies the allocation as a potential,
appropriate option for the relocation of a Household Waste and Recycling Centre and Council
Depot. Jaguar Land Rover do not consider the provision of this option within site UK2 is an
appropriate location for this operation, based on its existing local context. Such a facility, located in
the south east of the allocation, would prejudice the future expansion and continued growth of
Jaguar Land Rover’s Solihull facility. It would potentially prejudice future connectivity with
Highways England’s M42 Junction 6 relief road and does not constitute an appropriate location as
per the adopted Policy P3a assessment.

None

Our client is the landowner of the Gables Hotel, located at Old Damson Lane, Solihull B92 9ED. The Hotel is immediately to the south of, and with access to, the A45 Coventry Road, opposite Birmingham Airport. The Hotel is located within the UK Central Hub as identified within the SLDP Proposed Policies Map and subject to an allocation within the SLPD Policy P1 (UK Central Solihull Hub Area) and UK2 (Land at Damson Parkway), and thereby its removal from the Green Belt.
The Gables Hotel presently has 18 bedrooms, running at 90% occupancy. Approximately 50% of our client’s trade is related to the NEC and Birmingham Airport. The next largest customer is Jaguar Land Rover (JLR), for whom the Hotel accommodates contract shift staff, usually up to 4 nights a week.
Our client would like to modernise and expand their hotel operations to meet the existing and growing demand arising from their existing customer base and to attract new customers, the demand of which they cannot currently accommodate. Expansion would not only achieve a more economically sustainable operation but would also provide an opportunity to modernise the accommodation and conference offer to better meet the changing needs of customers.
Despite the Hotel’s location towards the centre of the UK Central Hub, with the Birmingham Airport and NEC to the north and JLR to the south, and good access via the A45 Coventry Road, a strategic arterial road from Birmingham city centre to the M40, expansion has previously been stifled by the Green Belt designation.
In 2017, our client sought to make a significant investment in the Hotel with a major rebuilding works but was refused planning permission (PL/2017/00371/PPFL, refused 15/06/2017) for which a key reason was ‘inappropriate development within the Green Belt’. As a consequence, the Hotel been at a disadvantage to the more recent hotel development further along the A45 Coventry Road in terms of its marketability.
Accordingly, our client welcomes the opportunities arising from the UK Central Hub allocations and its removal from the Green Belt and considers that the opportunities this provides would in return provide valuable support to the key objectives of both SLPD Policy P1 and UK2 in return.
Policy P1 UK Central Solihull Hub Area
Sub paragraph 1. States “…the Hub Area offers the greatest potential for growth in the Borough …; and will make a significant contribution to the wider West Midlands economy…”
Sub paragraph 2. States “The Hub Area, indicated on the Policies Map, embraces Birmingham Airport, the National Exhibition Centre (NEC), Birmingham Business Park and Jaguar Land Rover, each of which are key economic assets in their own right. This Plan seeks to support the future aspirations of the key economic assets in a holistic, well connected way, and to bring forward development of the area surrounding the HS2 Interchange Station at Arden Cross.”
and
Sub paragraph 3. States “…Development proposals within the Hub will be expected to demonstrate how they achieve the following key objectives…” and
i. Contribute towards sustainable and inclusive economic growth, the continued success of the key economic assets and …
iv. Encourages the use of modes of travel other than the private car;
vi. Create distinctive and unique places with a strong sense of identity … whilst maximising the efficient use of land;
vii. Support inclusive economic growth by supporting employment and supply chain opportunities …
The Hotel is possibly the closest small hotel to the JLR plant and within walking or cycling distance. The Hotel does offer some travel and shared lift options. With a larger facility these more sustainable modes of travel would be more economic and affective. The Hotel supports the key economic assets by providing accommodation in close proximity, specifically in respect of JLR and their workforce, but also in providing accommodation for operational workers during the build phase and customers during the running of conferences, exhibitions and concerts, and for travellers arriving/departing from Birmingham Airport and in the future the HS2 railway interchange. The opportunity to undertake major works to the Hotel would enable a modernised design both internally and externally, creating a new sense of identity for the site and improving the overall impression along this key approach to Birmingham city centre.
Notably, Policy P1 provides specific support to the key assets for which it is highlighted that Sub paragraph 4 states:
In respect of Arden Cross:
ii. The Council will support proposals that include passenger facilities, offices, and residential, together with associated ancillary uses (including retail, leisure and hotel developments of an appropriate scale).
In respect of the NEC:
v. To enable the NEC to meet its future aspirations and to drive economic and employment growth, the Council will enable a broad range of developments to enhance the visitor offer, diversity facilities and increase international competitiveness.
vii. The Council will also support a broad range of ancillary and complementary facilities needed to enhance visitor experience and support operational needs. These will include hotels ….providing it is justified in terms of scale, its support for the NEC as a whole and is appropriately located within the NEC.
In respect of Birmingham Airport:
x. The Council will also support a broad range of ancillary and complementary facilities including hotels, …. Proposals should be justified in terms of scale and in terms of supporting the Airport function and be appropriately located so as not to detract from Airport function.
xi. Where justified, development for Airport related uses beyond the Airport boundary will be permitted, providing that it accords with other policies in the Plan, including Green Belt policy. This will include opportunities within the allocated employment site (UK2).
In respect of JLR:
xiii. The Council will support and encourage the development of JLR within its boundary defined in this Local Plan. This will include a broad range of development needed to maintain or enhance the function of JLR as a major manufacturer of vehicles.
xiv. Site UK2 on the Policies Map, will be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant
In respect of Birmingham Business Park:
xvii. The Council will also support a broad range of ancillary or complementary uses needed to enhance the attraction of the business park to occupiers. These could include hotels and commercial/business/service uses of a scale that does not compete with existing or planned facilities outside of Birmingham Business Park.
It is clear that our client’s Hotel is ideally placed to support these key economic assets and as an existing hotel on a key strategic approach road to the city centre. Accordingly, our client supports Policy P1 and in return would provide support to meeting its objectives.
Policy UK2 Land at Damson Parkway
Sub paragraph 2 identifies that the allocated site is to be developed in accordance with Concept Masterplan, that is yet to be developed and thereby not included within the Solihull Local Plan Concept Masterplans (October 2020) that forms part of the plan-making process.
Our client welcomes the future development of the Concept Masterplan as an opportunity to provide certainty to their future investment plans and as a landowner within the allocation area requests the opportunity to actively contribute to its formation.

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I am making my views known via email because I have spent 2 hours trying to do this on line via the Consultation. I found this a most difficult and unfriendly site to use.



Section 105 of the Solihull Draft Local Plan. Land off Damson Parkway which states: ...part of the land has also been identified as an option for a relocated Household Waste and Recycling Centre and the Council Depot.

As a local Solihull Metropolitan Borough Councillor and also a local resident to this area I know there was no community engagement or councillor engagement about the proposal to relocate the HWRC and the depot to land off Damson Parkway. We were told that land was for light industrial use. The first we knew about it was after the plan was published. Therefore this goes against the statutory requirement.

I can also see no justification for relocating the HWRC and Council Depot in this area for the following reasons:

Policy P12. Protecting and enhancing our environment, Resource Management.

It is my opinion that this is contrary to Policy P12 as far as the local community is concerned.
This area is already over used by JLR. It has become a no go area for many local people. JLR monopolise the area with hundreds of cars going in and out of the factory at all times of the day with their many different shift times. Every vehicle that is made in the factory has the parts brought into the plant in huge HGVs. Every completed vehicle is sent out of the factory on transporters carrying 7 or 8 vehicles at a time. This takes place hundreds of times a day.
To even contemplate having more vehicles in this same area using the same roads will put an even greater strain on the area.
The fumes from the vehicles already in the area cause high carbon emissions. While Policy P12, Resource Management may be beneficial to the council, but to local community this with be contrary to P12 as it will cause smells, more carbon emission and more time to get to their destination due to the increase in traffic as well as the social cost and devaluation of properties.


Glenis Slater

Dear Solihull PSP

I would like to put forward my comments and concerns regarding the wide ranging proposals outlined in your ''2020 Vision for Solihull’’ document.

Whilst i fully understand and accept the need for the council to have to meet a variety of challenges and demands around housing, support for businesses and of course the environmental impacts. The sheer size and scope of the proposals is very concerning and if implemented I suggest will completely destroy the ‘’Town in the Country’’ image that Solihull is so well known for and so greatly treasured by its residents (and I would expect, by Solihull council).

The proposals if they go ahead will surely just turn the borough into a huge urban sprawl that will be indistinguishable from the neighbouring city of Birmingham?

The two particularly areas of concern for me and I suspect most of the Damson Parkway and Catherine De Barnes residents, are as follows:

1, The number and size of the proposed housing developments, particularly those proposed for sites in Catherine De Barnes and Lug-Trout Lane. Some 795 new homes in what have always been quiet rural or semi-rural locations and will completely dominate those locations.
POLICY HA2 and POLICY S01

2, The proposed relocation of the Bickenhill Waste disposal site to the corner of Damson Parkway and the A45 Coventry Rd. POLICY UK2

This proposal is problematic for the following reasons:

- the environmental impact, noise and disruption in the construction of such a site. No doubt this will be a signifiant development with many months of major construction works.
- the destruction of yet more valuable green belt land, which is in short supply and which the council claims to hold so sacred!
- the noise and pollution that this site will bring when it becomes operational, particularly from heavy vehicles entering and leaving the site
- the traffic chaos that will be caused by traffic using the site having to compete for limited road space with JLR factory traffic and that from the soon to be opened JLR logistics centre. Traffic chaos already exists at JLR shift changeover times and on match days for the Solihull Moors Football Club.

Bringing the waste site to Damson Parkway will be a complete disaster for the local residents who have already had to endure 18 months of pollution and disruption from the construction of the JLR Logistics centre. Which is yet to open and will no doubt cause severe traffic problems of its own.

It will also completely destroy the semi-rural nature of the area by effectively turning what was a residential housing estate near the Land Rover Factory, into a major industrial area.

It seems that Residents of the Damson Parkway estate will be under fire from 2 major developments to the North and West.

There must be other more viable options than to bring a major industrial facility to an already congested Residential area?

I strongly urge the planning and delivery directorate decision makers to reconsider their proposals, particularly with regard to the relocation of the Bickenhill Waste site and Moat Lane Depot to Damson Parkway.
Such sites should surely be located away from residential areas and be contained within or adjacent to an already established industrial estate?

I therefore wish to register my objections to Policies HA2, S01 and UK2, in the strongest possible terms.

Regards


Gerald Hudson

A different location for the waste and recycling centre needs to found

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HWRC relocation can be done within the local area PC-01-049 of HS2 development. The best suitable place is a plot to the east of HS2 route, restricted by HS2 line, A45, and A452.

See representation form attached.

As a resident I am writing to register my objection to the relocation of the Household and Recycling Centre to land within site UK2 at Damson Parkway.

This is clearly an inappropriate development, at this proposed site, and seems to me; to directly oppose many of the criteria set out in the local plan.

Solihull Local Plan - Draft Submission has a sub heading ‘ A plan for people and places where wellbeing and the environment matter’. The people of Damson Parkway will see any further development, particularly the Recycling Centre, as being in contradiction of these fine words.

The recycling centre proposal comes in addition to the significant expansion of the JLR facility, with development of their Logistics Centre. As a former JLR employee, I understand the need for this facility, but nonetheless it is unsightly and will significantly add to traffic density in the local area (despite the improved roadways). Let’s not forget JLR have expanded to the other side of Damson Lane with the Vehicle Dispatch facility.

We also have had major development of the Airport with greater engine noise when planes take off and land, plus the consequential added pollution. Solihull Moors football club car park is not sufficient for their needs, with supporters using Damson Lane for parking overspill.

The very nature of a Household Recycling Centre is that it can be accessed by the public. The public will visit the centre to suit their specific needs and that flow of traffic cannot be planned. Add to this the JLR increased traffic, Solihull Moors, Elmdon Park visitors and you will have guaranteed traffic disruption.

Please recognise these issues and do not proceed with the relocation of the Recycling Centre.

I would like to object to the proposed plans for Uk2 Solihull local planning proposal. Number 831 and 103

We are already having increased noise traffic and lorries etc with JLR with them expanding and taking huge parts of our green belt is bad enough, but I object to further use of our green belt for the recycling tip and refuse tip to put them here would be a disaster for our area increase pollution noise traffic etc. I already feel we as a community tolerate a lot of disruption with JLR please don’t take more green belt affecting our natural habitat animals and people

I object to the proposal to move the HWRC TO Damson Parkway. I have lived on Damson lane for over 40 years and I have seen an absolute transformation in this area and not for the better. My lane is used like a race track constantly day and night the increase in traffic is to be expected with more cars but we also have the other monstrosity of JLR who also add to how busy the roads now are in the area. As you are aware they are building a huge logistic centre which will also add to the already constant stream of lorries up and down the parkway. We do not want the HWRC moved into our community to add pollution and excessive extra traffic on our already busy roads. I think as an area we already have to give way to the constant demands of JLR encroaching on our green belt with the permission of Solihull Council so please do not inflict more pollution with extra lorries vans cars etc on to us. Enough is enough

I object to the Solihull Local Plan specifically to the relocaton of the Bickenhill Household Waste and RecyclingCentre (HWRC) and Moat Lane Works Depot both located on brown sites to a new green site located on Damson Parkway.
Chapter " Protecting and Enhancing our Environment " P89 and UK2 under the chapter UK Central Hub P107/8 should be read in support of the objection.
It is noted that SMBC has not acknowledged the need of prior consultation with ward councillors and residents before submission to the Government Inspector.
Relocating the HWRC and Works Depot will only increase pollution, noise and impact on health of those living in close proximity to the proposal.
The new JLR Logistics Site on Damson Parkway will considerably increase traffic from employment of 2600 new employees and associated increase of cars into work and HG Lorries making deliveries as will the vehicles and lorries to the proposed site for the HWRC and Works Depot. Damson Parkway will not sustain such traffic and will become congested and lead to traffic using normal domestic roads and lanes about the area.
The Human Rights Act notes that a person has rights to peaceful enjoyment of all their possessions which includes the home and other land. Immediate neighbours to the site proposed could view it as having a serious negative impact on their stand of living.

I am forwarding this e mail because of problems of IT at this time and would expect it to be included in the comments section of representation

See attachment