Q12. Do you agree with the level of affordable housing being sought in Policy P4? If not why not, and what alternative would you suggest?

In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Land.

SOLIHULL COUNCIL'S DRAFT HOUSING PLAN
Dear Sir
We wish to make the following comments concerning the above for you to consider.
GREEN BELT
At a time when government are announcing through many avenues of media that GREEN BELT land must be preserved at all costs it seems that SMBC have totally ignored this announcement and in doing so will close the ever decreasing gap between Balsall Common and Coventry and given the continuation of this policy along with the proposals Coventry have suggested, it appears that the GREEN BELT gap will be obliterated completely, which is totally unacceptable.
BALSALL COMMON CENTRE
While your plan intends to increase the dwellings in Balsall Common by well in excess of 30% there is absolutely no mention of your intention of increasing the facilities of the centre of Balsall Common. It is a fact that while the number of dwellings in Balsall Common has drastically increased over the last twenty years there has been no attempt by SMBC to increase the facilities. In fact most recently yet another bank has announced it intends to close its branch. The parking situation even with the increased parking facility behind the shops is still not enough and there are times now when it is very dangerous to try and get out of a parking position onto Station Road.
There are nowhere near enough variety of shops to service the existing residents of Balsall Common let alone an increase of the magnitude you intend and there are no public toilets, which one would think is a necessity with the increase of people your plan will attract.
TYPE OF HOUSING
We understand that you aim to make 50% of the new homes "affordable" even though one of the new sites under construction in Balsall Common has already found great difficulty in selling the "affordable" housing on the site because of the price. Surely it is common sense to position "affordable housing" in an area with in the borough where the surrounding properties and therefore the new properties fall into a price range that make the price affordable, rather in an area like Balsall Common where the prices are not conducive the "affordable" market
TRAFFIC
The largest site for Balsall Common is obviously the Barretts Lane Farm development but at this time no mention of how the site would be accessed is available. We would ask you to consider that Meeting House Lane must not be used in any form either directly or via Oxhayes Close or Sunnyside Lane or Barretts Lane, because it is already used as a bypass to the A452 even though you have had a number of speed bumps installed. Meeting House lane does not have pavements on either side of it other than a very small section of approximately 100metres and in fact it only has one pavement on one side of the Road from Station Road down to Sunnyside Lane which makes it a very dangerous road on which to encourage a very large percentage increase in foot traffic, a very large amount of which would be school children, if your if your plan comes to fruition.
If permission for the Barretts Lane site is given please consider the access to the new site to be a feeder Road off the current island positioned at the junction of Station Road and Hall Meadow Drive and taking it through to at least Kelsey Lane. This would not only eradicate any further problems along Meeting House Lane but also complete the extension to Hall Meadow Drive which would provide a complete bypass to Balsall Common Centre if it were extended to the island at the junction with the A452 and A4177.

In respect of the Draft Solihull Local Plan Review consultation please find attached representations which are submitted by Turley on behalf of IM Properties and IM Land.

Thank you for your letter of 8 December 2016 informing me of the consultation process.
Please find attached my response to the Solihull Draft Local Plan Consultation.
Solihull Local Plan Review - Draft Local Plan Consultation

RESPONSE

This is to raise objections and concerns about the proposal to build 1050 new houses in Knowle, this being on two sites, namely the 'Arden Triangle' with 750 houses and Hampton Road with 300 houses.
My wife and I have lived in Knowle for over 37 years. I have been active, since its inception, in the work of the Knowle, Dorridge and Bentley Heath Neighbourhood Forum (KDBH-NF) and am consequently familiar with relevant background evidence including the Residents' Survey and data related to infrastructure, transport and services.
The proposed excessive housing allocation for Knowle is in complete conflict with the evidence base.
This document supports points made in the response from the KDBH-NF, which presents a convincing argument to significantly reduce the proposed allocation of housing in Knowle.
The points made below are often inter-related and represent only a sample of the arguments for opposing the proposals for Knowle in the Draft Local Plan
1050 extra houses for Knowle is far too many.
* This increases the housing stock in Knowle by over 25%, this is not counting the recent and current developments taking place. There has been zero allocation to Dorridge and Bentley Heath. This seems abundantly unreasonable.
* Where there is to be a mix of large and small-scale developments across the Borough, it would seem logical that any large development (over 400, for instance) should be adjoining urban areas to minimise detrimental impact and the 'smaller' developments (100-400) equitably sited around the villages to avoid overload of services and infra-structure. To put two large developments in the village is a sure way to secure maximum harm to services and infra-structure.
* There will be extremely detrimental impact on the identity, character and appearance of Knowle. Outcomes such as increased traffic density, reduced provision of personalised service, diminished sense of community and lack of locally specific services will erode the 'village character' currently valued by residents.
* The residents' survey has identified that there are already problems with parking, traffic congestion at peak times and access to primary medical care. Development of such magnitude will undoubtedly take this infrastructure beyond breaking point. Recent roadworks in Knowle have shown that any further stress on the road system will bring about gridlock.
* There would be a need for just under 2 additional forms of entry at primary school level. Even with this, primary school admission arrangements will be severely disrupted by the increased numbers of primary age children in two large blocks of new housing.
* With regard to retail facilities, it seems inappropriate to build all the houses in Knowle, where the provision of a Waitrose is problematic, and no houses in Dorridge where there is a new Sainsbury's with additional parking.
* The area, by nature of its village context, is not well connected or adjacent to the main transport links. There are much better sites.
* The proposal will ensure that Knowle effectively becomes a building site for 15 years with all that recent developments have brought to the village - mud on the roads, large lorries on small roads, noise, danger and inconvenience.


The rationale for choosing the two sites is unclear and there is a lack of strategic planning.
* It is unclear how the choice of sites arises from the policies, criteria and spatial strategy. The methodology to arrive at the proposal seems unsound.
* Access and transport criteria appear to have been evaluated from the nearest point to the village of each site, giving a falsely favourable reading to the site suitability overall.
* The methodology of basing choices around the 'call for sites' model seems to contradict the government current and intended policy of only using greenbelt in 'exceptional circumstances'. The two sites chosen perform highly on SMBC's own assessment of quality of green belt and therefore should have been safe from major development.
* The decision to choose the two sites seems to be swayed by the promise of community facilities. However, much of this is problematic at best.
* It seems absurd to base the future of Knowle around the aspirations of two independent organisations. It is particularly incomprehensible that the Solihull Draft Plan assumes that these two organisations are in a position to judge community need, particularly when on a parochial basis. In contrast, KDBH-NF has spent the last year collecting data, much of it from SMBC, and feedback, such as the residents' survey carried out by an independent organisation across every household in the area, that gives, without bias, as clear a picture as possible of community need and aspiration in the KDBH area.
* There is no account of the cost in terms of lost estate, revenue, recent investment and resource. A rough estimate is at least £50m - this at a time of increasing demands on public finances. There is no attempt to match income from developers to assessed need in order to make best use of finance.
Arden Triangle
The 'Arden Triangle' scheme was made known approximately 4 years ago. Proposals dated January 2013 were for a small-scale land swap scheme to provide new buildings for Arden Academy, a figure of 250 new homes in keeping with existing properties being mentioned. Since then, the vision has magnified considerably, there currently being a number of issues that are not clear, including any guarantee of accessibility and availability of community resources and the extent, type and density of new housing within the scheme in order to deliver the full package with appropriate facilities, playing fields and access. Assertions previously made, such as the nature of housing, have changed and cannot be kept once the project is in the hands of developers. The prospect of new buildings for Arden, promoted over the past 4 years, is seen by some as attractive. However, the cost, need and impact aspects have not been made public and many of these implications would not impact on those many parents and pupils favouring a new school who live outside Knowle. The proposed new school is reported to cost approximately £30m, a further cost being poor return on past and recent investment in existing buildings, some relatively new, to be demolished. This total cost is presumably at a loss to SMBC and could be spent on the basis of well researched priorities. This need analysis would certainly entail a condition and capacity assessment of all schools in KDBH. Overall, what evidence is there to justify the need for a new school at a cost of £30m+ and the detrimental impact on Knowle of 750 houses? This needs far deeper public scrutiny with consideration of alternatives.
Existing projects, such as the MIND garden area, had not been considered. There must be clear arrangements to avoid distress to vulnerable people.
There is mention of moving St George and St Teresa school to the new site. However, the logical priority for school places arising from current trends and the proposed housing would appear to be an additional two forms of entry at primary, these being sited with regard to reducing travel distance from any new houses and at a school that has a priority for local children.
In general, there must be maximum protection for public investment in new school buildings, whether primary or secondary, as this presents an extreme financial risk, particularly in the light of the autonomy of academies in relation to access to resources and in their admission policies which, even currently, cater for the admission of a high proportion of students from outside the area.
The proposed site for the 750 houses would present difficulties of access and considerable increases in traffic through the village as it is the 'wrong' side for access to Birmingham, the NEC, airport, railway stations and motorways, these being centres for employment and onward journeys.
This site, if extending to the full 750 houses, would have a significantly detrimental effect on the street scene in Station Road and approach through Stripes Hill and Grove Road.
The proposal has arisen from the stated aim of providing new premises for Arden Academy, it is not put forward as a planned scheme for new housing. The need and cost implications have not been made public. Whilst there may be some aspects of merit, the lack of independent assessment of need, the vagueness of outcome and no public awareness at this point of any concept masterplan, means SMBC is proposing a scheme that will undoubtedly have a devastating impact on Knowle and with little idea of what the plan will cost and what it will deliver.
Hampton Road
The proposals from the football club are at a more moderate scale. However, there are still questions about the cost to SMBC and the ownership and availability of resources. It is clear that the football club have a large number of teams that cannot be accommodated easily with the current number of pitches. However, provision of new resources would be of greater benefit if extending to more sports beyond football in order to cater for a wide range of skills and consequently attract more people to sport.

The views of residents have been ignored.
* The Draft Local Plan is as far away as possible from the views of residents, as reflected in the Neighbourhood Forum survey. Whilst it may have been impossible to accommodate the view about total numbers, there is serious conflict with regard to the size and location of sites, the appropriateness of the housing mix and the need to address the impact on local services and infrastructure. As one example, 98% of residents wanted sites on green belt to be less than 500 houses and 96% wanted them to be less than 100 houses. The current proposal is clearly way out of line with this and other views of residents.

The type and density of housing is inappropriate.
* The stipulation of 50% affordable housing and, in particular, the requirement for rented accommodation, is out of keeping with the area and will have a detrimental effect on the profile and character of Knowle.
* The densities quoted for the two sites are too high, particularly as this presumably average figure takes into account the school and club playing fields.
Recent housing development in Knowle has shown what high-density mixed housing looks like and the difficulties created, particularly with regard to parking and street scene. These recent developments are an indication of how developers can have little regard for providing building that is in keeping with existing housing.

Suggestions
The present proposal is a potential disaster for Knowle and needs a radical rethink along the following lines:
* Significantly reduce the number of houses that are proposed for Knowle by considering:
A new freestanding small-scale garden city that can have its own purpose-built community facilities;
Allocation of large sites to existing conurbations rather than villages;
Other sites outside the area such as those suggested by the Neighbourhood Forum and Knowle Society;
Smaller sites of around 200 to 300 around Dorridge and Bentley Heath to spread the load. Sites 207 (retains adequate separation from Solihull), 104, 135, 241, 199, 029, 210, 127 would take some pressure off Knowle and 059 in Knowle, as a last resort, would ease some aspects of impact in Knowle.
* Assess the costs and benefits of the two existing proposals and, if favourable, set this within a wider planning perspective as below.
* SMBC, in partnership with KDBH-NF and its extensive database, takes an overall strategic view of the Knowle, Dorridge and Bentley Heath area, not accepting without question what is being offered by the two organisations and developers currently favoured. Such proactive planning to take account of:
Making the sites no larger than that needed to secure outcomes that meet proven need;
The need for additional primary school places and planning that take regard of travel plans and maximum preservation of primary school catchment areas;
The need for additional and enhanced primary medical care provision;
Additional resources for a wide range of sport and leisure activities and that have full and long term availability to the community;
Accessibility of community resources, including retail;
Accessibility of sites;
Reducing the use and impact of the car;
Transport links to employment, railway stations, airport and major centres;
Minimal impact on the character of the three villages.

It is difficult to see the current Draft Solihull Plan as anything but a long term disaster for Knowle. It is essential that there is an objective, evidence based re-assessment of the plan for Knowle that evaluates priorities, responds to need, examines cost implications to the public purse and delivers housing in a way that has minimum detrimental impact on services, infrastructure, environmental issues, landscape and village identity.

Please find attached my comments in response to the invitation to comment upon the Draft Local plan.

COMMENTS ON SOLIHULL DRAFT LOCAL PLAN
February 2017

Thank you for the opportunity to contribute to the current consultation on the Solihull Draft Plan. My comments are specifically regarding the proposals for Balsall Common and focus upon:

1) The issue of the disproportionate allocation of new housing to Balsall Common, compared with both Knowle and Dorridge, both of which have well established town centres, unlike Balsall Common.

2) The need to develop a comprehensive Plan for Balsall Common which considers improvements to the infrastructure necessary to support any proposed increase in population.

3) The clear logic and evidence for accommodating all proposed housing on the Barrett's Lane site and not developing any of the other suggested sites.

It appears that the number of houses allocated to Balsall Common is disproportionately large given the size of allocations to other locations within the Borough, which have a greater capacity to accommodate sizable developments and which also have better infrastructure to support growth than Balsall Common. Both Knowle and Dorridge have sizeable and well established "town centres" which are cap.able of supporting additional demands, unlike Balsall Common which has a small, restricted and inadequate centre. Parking at Balsall Common centre is also significantly limited and the opportunity to utilize the former Partco site at the rear of the existing shops has been lost with the development of housing, which is currently under construction.

Similarly the transportation and public transport links to are vastly superior to Balsall Common, with the former being much better served and more frequently served by trains and both have more frequent bus services. Also proximity to the M42 is better at both Dorridge and Knowle.

The exercise currently in hand is clearly focused on housing allocations and there appears to be very little evidence of any rigorous or conclusive thought having been given to the broader planning issues and consequences of potentially increasing the housing stock by, up to 1150 new homes, in terms of the impact on existing services and infrastructure within Balsall Common. There needs to be a more comprehensive approach to the future planning and development of Balsall Common alongside the current single focus upon housing allocations. It is essential that the current process include, simultaneous to the consideration of optional housing sites, appropriate discussion and a comprehensive examination of the improvements to infrastructure necessary to support any growth in the housing stock and population, as well as securing improvements for current residents.

I am aware that there has been consideration within some of the developers early schematic plans of location of "open space' and "additional schools" and the like, but again, a much more strategic and comprehensive contextual approach needs to be adopted. There is a danger in the presumption that the impact of additional housing can be met within the finally designated housing areas as many of the impacts will be felt well beyond the boundaries of the new housing sites. Developers will obviously offer planning gains within their proposals, possibly to minimize expectations placed upon them by Section 106 agreements and planning approval conditions, but again such altruistic offerings are likely only to benefit their own proposal and we need to return to the consequences of additional housing upon the whole and entire settlement both existing and proposed.

Unless the issue of the impact of the proposed developments upon the existing and projected infrastructure is properly analysed and solutions identified and detailed, enlargement of the settlement, at the scale envisaged, will be rather like building an inverted pyramid, the base of which is ever increased whilst the grounded apex becomes ever more unstable, with inevitable and predictable consequences.

Thirdly, regarding the sites preferred by the LPA, I'd offer the following comments:

The Barrett's Lane site (Reference 33 /244 Barrett's Lane Farm, BC Meriden 50.65 Forms part of amalgamated site 1002) is easily the most appropriate and feasible site to accommodate the entire allocation. It scores well in terms of its development potential in the Green Belt Assessment: Appendix F : Overall Score Map. Similarly, it is supported by development potential in terms of proximity to transport links, (particularly if the Balsall Common by-pass is completed) as well as access to other existing facilities. The location close to the railway station is consistent with the views expressed in the current 2017 White Paper on Housing and rational regarding the current thinking and policy on sustainable housing, which Balsall Common desperately needs.

Reinforcing the appropriateness of development at the Barrett's Lane site, the Landscape Assessment of Sub-Area 5 (The Balsall Common Eastern Fringe) (on page 42) and the locus of the Barrett's Lane proposals, identifies the area as being lower in landscape quality, with an overall assessment of only "medium".


The Frog Lane proposal (Reference 75 /12 Land at Frog Lane) scores similarly in Appendix F : Overall Score Map. However some aspects of the Green Belt Assessment: Appendix G : Highest Score Plan identifying site RP59 with a score of 3 (the highest category) for certain categories of assessment.

However, the location of the site, which is some significant way from the current village centre and even further from the railway station and other key facilities, raises additional questions about its suitability. Presumably the existing road (Frog Lane) would need to be upgraded and given the relatively small number of houses (the site is only 5.44 hectares) this may not justify the investment? It is also presumably, because of its isolated location, not an ideal location for affordable housing and would generate extra and vehicular movements on inappropriate roads.

Also any development in this direction opens the probability of further incursions into the Green Belt in a direction which is counter-intuitive to development around rail stations.

The proposal to develop 800+ houses at Grange Farm is fundamentally flawed in a number of respects. In the Green Belt Assessment Appendix F: Overall Score Map the Grange Farm site scores 7, which is higher than the Barrett's Lane, Meeting House Lane and Windmill Lane Sites. Together with fact that the Grange Farm site is further from current facilities makes it difficult to understand why it would be considered. At the exhibition by potential developers (held at St Peters Church Hall) much was made of the intentions to offer "infrastructure" alongside the development. The attraction of "infrastructure" at Grange Farm needs to be very closely examined and rigorously tested within the context of the entire village (as discussed above), in so much as a sub-centre at a location which is isolated from current infrastructure, could create additional problems for both the existing facilities and the transport network. It would simply be providing facilities in the wrong place.

In addition, the commentary contained in the Landscape Assessment (page 38) on Sub-Area 4c (which is the area to the west of Balsall Common) describes the Landscape Character Sensitivity of this sub-area as High. It goes on to state: "The sub-area has clear legibility and is an attractive rural landscape with distinctive landscape features including the several historic areas that are intimate along with the well treed River Blythe corridor. The landscape is generally in good condition".

The Report goes on to note: "This sub-area would typically have an overall very low landscape capacity to accommodate change. Overall, this character area would be able to accommodate only very restricted areas of new development, which would need to be of an appropriate type, scale and form, and in keeping with the existing character and local distinctiveness of the area. Any new development should not result in the loss of the inherently rural character and should maintain the dispersed settlement pattern of the area".

As an aside, it's interesting and understandable that "busy roads" are identified as a landscape detractor, but it serves to reinforce that fact that additional development in this area would aggravate the traffic issues to the west of the village, which would not benefit from the by-pass.

Clearly the Landscape Assessment rates the quality of the western fringe (including the Grange Farm site) as higher than the eastern fringe (and the Barrett's Lane site). Also, the Assessment rates the western fringe as being more sensitive to change than the eastern fringe. Consequently the conclusion must be that of the two sites, the eastern fringe (including the Barrett's Lane) site would be preferred for development.

Beyond the Landscape Assessment and back to the issues discussed above regarding infrastructure and the need for a comprehensive planning approach to the development of Balsall Common, I would strongly reiterate the need to debate the capacity of the existing village in terms of infrastructure, alongside the consideration of the housing locations, which needs to be expressed in a village masterplan as (part of) the context for the new housing proposals! I've not found any debate about the fundamental questions, for example, about what sort of village / settlement Balsall Common wants to be in the future? The danger exists that we are deciding significant detail before we have determined the overall context or product! It's interesting to note that included in the Evidence Base is the masterplan for the central area of Solihull, which is clearly being used as both the context for future developments as well as providing instructions to the detail decisions that will be made.

Please find attached the detailed report compiled by the BARRAGE action group in response to the Draft Local Plan.

I believe you will have received many letters of objection already which make reference to this report.

Please note that the focus of the report responds to Q15 in the DLP in that we do not believe that sites 2 and 3 should be included in the plan and would propose that serious consideration should be given to the inclusion of site 240 instead.