Policy BC3 - Kenilworth Road/Windmill Lane, Balsall Common

Removing either all or sensitive parts of BC3 need not mean that the overall proposed allocation of housing in Balsall Common cannot be fulfilled. In the submissions made in response to the Council’s Call for sites many landowners responded and many of those sites are far better placed in relation to the village centre and closer to services than site BC3, so far more sustainable. The site assessment for many of these sites is better or equivalent to the assessment for BC3, The council have not properly considered those sites in terms of sustainability and/or impact on the Green Belt
Amongst those sites are
Site 82 – Land at Kenilworth Road capable to taking around 70 dwellings
Site 422 – Land at Rose Bank Balsall Street capable of taking 20 dwellings
Sile 421 – Land at Silver Tree Farm Balsall Street capable of taking 20 dwellings
Site 1 – Land at Springhill 433 Station Road, Balsall Common - 20 dwellings
Site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road – 40 dwellings

The proposed allocation of land at Kenilworth Road/Windmill Lane is not sound, positively prepared or sustainable and fails to accord with NPPF policies. The allocation appears to be based solely on the fact that the site is being promoted by a large volume house builder rather than any spatial logic. The allocation adds further unjustified pressure on the vital strategically important Meriden Gap.
While there a case could be made for the northern part of the site for around half the number of units to be released proposals for the extension of that for further housing into the southern part of the rest of the site into more open countryside is totally unjustified. While some parts of that southern section are suggested for public open space that is insufficient as a buffer of open land around the windmill which should become a much-needed country park.
The master plan proposals fundamentally disregard the impact on the proper setting of historic Berkswell Windmill and moreover it would extend housing development around the village of Balsall Common much further south away from village services and facilities, when there are better and more sustainable sites closer to the village centre which could and should be released. A number of those omission sites have been discounted on questionable grounds
The northern part of the proposed allocation site could be justified as integrating into existing recent residential development fronting Kenilworth Road and backing onto property in Kelsey Lane as well as linking through to the proposed allocation site BC4 at Pheasant Oak Farm which is also proposed to take 200 homes.
Green Belt
Balsall Common is destined to take a significant amount of new housing on 6 identified new sites all within the Green Belt which taken together would add more than 1600 dwellings in addition to land at Riddings Hill. There is already a narrow gap between the village and Coventry within the Meriden Gap and recently Coventry City Council have approved some 2400 new houses at Eastern Green so narrowing the gap even further.
Sustainability
The location of BC3 is remote from the main facilities in the village, and while anew primary school is proposed on BC1 Barretts Farm, access to other services in the village would require use of a car from much of BC3, adding to congestion in and around the village centre. As an unsustainable location the allocation of all of BC3 for housing cannot be justified under the NPPF.


Setting of Berkswell Windmill
The Concept masterplan has removed some originally proposed housing development at the southern end of the BC3 site but still leaves a southern tongue of land between existing housing development on Kenilworth Road frontage and some identified ecologically important area fronting Windmill Lane.
Leaving that tongue of potential development without strengthening the protection of ecological site would mean that further development pressures would arise in the future. The southern tongue of development land should be deleted from BC3. That way the full visual protection of the setting of the windmill will be properly protected and a country park developed as part of a proper comprehensive plan including closure of Windmill Lane at its southern end. The latter action will greatly mitigate the current noise and disturbance impact on the setting of the windmill from volumes of traffic using Windmill Lane as a short cut.
Ecological Assessment
Much of BC3 has been shown by a recent study by Warwickshire Wildlife to be an area of ecological value and as such it is questionable that the site be used for development. The area is characteristic of Arden Landscape and there is little information as to how biodiversity offset provision is going to be made. Significantly reducing the extent of proposed development would allow proper provision to be made on the site.

There needs to be a full re-appraisal of the site with regards to the environmental and ecological damage to ensure that sufficiently large areas of wildlife habitation and corridors are maintained and not over encroached by housing development.

There needs to be greater focus on protecting the Berkswell Windmill as a very important heritage asset, not just in functionality but in its rural aspect and appeal as a tourist attraction.

The proposed development fails to fully protect habitats and species of conservation importance.

The proposal does not adequately protect the heritage assets adjacent to the site.

Active travel includes equestrians as vulnerable road users (Jesse Norman MP, 2018). Improvements to the connectivity of cycle and pedestrian routes should include equestrians where it could avoid horse riders being sandwiched between fast moving motorised traffic and fast moving cyclists, to improve safety.

2v, 3iv and 4ii do not include equestrian access in the policy.

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

This will help to ensure that any 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.

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

The Parish Council requests that the housing area within the area of development constraint is marginally reduced to respect the constraint area shown in the Ecological Assessment. This will implement the recommendations in the Assessment and Policy P10 in the submission plan, particularly paragraphs 2, 5, 8, 9 and 11 of the policy.

See attachment

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Dear Sir/Madam,
Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

I would also ask you to consider the overall impact of increased housing on our village . The infrastructure is not there to support more people/ houses/ children/ traffic.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:
The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council's own criteria.

2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it isremoved from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Please find below my further objection to the proposed development of site BC3. I am disappointed to see that this continues to be presented as a viable option despite local opposition, alternative sites in Brownfield and National Pledges from the Conservatives to not build on Greenbelt. Having listened to the Solihull Council meeting online where this was discussed, I feel extremely let down by local MPs who were unhappy with suggesting this site but appeared to vote in favour of a substandard Local Plan as they needed to meet a deadline. I believe that the proposed site fails to meet the requirements needed for it to be viable as outlined below.
We are extremely concerned by the loss of natural habitat, the influx of traffic onto Windmill Lane which is already a notorious rat run and the lack of facilities that we already suffer from. At present, the doctors fails to provide appointments for the current population, the roads are congested and the infrastructure cannot cope. The amount of housing proposed generally in Balsall Common will make it impossible for our village to function properly.
Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Dear Sir/Madam,

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.



3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.


With the current schedule of development within the village of Balsall Common, the critical question surrounding infrastructure to support residential development at this scale has simply not been addressed in an effective or timely manor. One wonders how specialists in planning appear to repeatedly make the same errors.
A more sympathetic reflection on local residential development, which focuses on the needs of a community first, and money second, would encounter less resistance and help establish a relationship of trust between sides.
Is it not our responsibility to leave a legacy for future generations that our time can be proud of?

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:
1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.

2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.
3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness

I wish to formerly object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.

The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainable using the Council’s own criteria.


2) Justified:

The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:

There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.

I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.