Q19. Do you agree with the policies for protecting the environment? If not why not, and what alternatives would you suggest?

Showing comments and forms 91 to 108 of 108

Yes

Draft Local Plan Review

Representation ID: 4145

Received: 17/02/2017

Respondent: Burton Green Parish Council

Representation Summary:

We applaud the vision of the Council in its approach to the Green Belt and we fully support the statement in the Local Plan that Solihull will continue to be Urbs in Rure, "without compromising the quality of its environment, protecting the integrity of the Green Belt and retaining the strategic gap between the Birmingham conurbation and Coventry."

Full text:

I am chair of the Burton Green Parish Council and I am sending our response to the Solihull Local Plan. I would appreciate if you confirmed that our response has been delivered. Also when the Inspector's proceedings begin, we would like to be represented there when it looks at the developments in Berkswell and Balsall Common, especially when the transport infrastructure is discussed.

Yes

Draft Local Plan Review

Representation ID: 4162

Received: 21/02/2017

Respondent: Natural England

Representation Summary:

Support policy P9
Object to Policy P10. Amendments are recommended so that the Mitigation Hierarchy heading comes ahead of the Site headings, to show that SSSIs have significantly increased levels of protection than LNRs and sites outside statutory designations.
No evidence that an HRA report has been undertaken.
Policy P11 should refer to the river Blythe SSSI, to reflect its status. The Policy should recognise the need to protect habitats from water related impacts and seek enhancement, especially SSSIs, but also local sites.
Recommends changes to Policy P13 and separate policies on Soils and Agricultural Land Quality and Ancient Woodland.

Full text:

additional letter to supplement reps made online

No

Draft Local Plan Review

Representation ID: 4215

Received: 10/03/2017

Respondent: Environment Agency

Representation Summary:

Policy P9: Support
Policy P11: Suggest additional wording/amendments to various parts of the Policy and to the Policy Justification (see full response). The Policy title should be changed to Water and Flood Risk Management. The Policy is lengthy, so suggest consideration of 2 separate policies.
Policy P13: Suggest changes to 8th bullet point of the policy (see full response)
Policy P14: Text in relation to Contaminated Land appears somewhat out of place. The protection and remediation of Controlled Waters is more of a water quality issue, so suggest that it is included a policy relating to Water Quality.

Full text:

see attached letter

No

Draft Local Plan Review

Representation ID: 4241

Received: 17/02/2017

Respondent: Richard Lloyd

Representation Summary:

There should be a clear policy for requiring solar PV on all new buildings, and prohibiting green-field solar farms. In addition, policies should encourage use of solar PV in paved areas etc. There should be clear architectural/design standards for all solar PV installations.

Full text:

Challenges
1. Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?
Vision

No.
Challenge C - Balsall Common village centre suffers from many of the challenges listed for Solihull, Shirley, and Chelmsley Wood Centres.

2. Do you agree with the Borough Vision we have set out? If not why not, and what alternative would you suggest?

No.
The vision seems to rely on increasing transport dependency. It implies that employment growth will necessitate people travelling from outside the area to work within Solihull, and Solihull residents travelling long distances outside the Borough to go to work. A better strategy would be to focus on creating local employment, with the transport growth aimed at transporting materials and goods. Transport of people for employment purposes could be reduced by improved broadband network infrastructure and tele-working.
the spatial strategy seems to run counter to the wish in para 74 for preserving the environment.
There doesn't seem to be any proposals to meet the aspiration in para 75 to reduce carbon emissions.
In para 86 it's said growth will occur on the edge of settlements which will inevitably increase traffic and transport need, and runs counter to the aspirations in paras 72 and 75. A bypass for Balsall Common is proposed without consideration of the impact on the viability of the village centre, the environment, or existing residents.

Spatial Strategy
3. Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?
Sustainable Economic Growth

No.
The proposed significant expansion of rural settlements is in conflict with the stated preference and national policy of giving preference to brown field sites, and does not recognise the absence of high frequency public transport in most of the Borough.
Given the shortage of housing land to meet the Government's housing targets, it is essential that all new development is to a high density to reduce the land-take.

4. Do you agree with Policy P1? If not why not, and what alternative would you suggest?

No.
There doesn't seem any plan to mitigate the increased traffic, congestion, carbon emissions, air quality degradation, and noise disturbance. The land should not be developed until after the aggregate resources have been extracted. Renaming the area as Arden Cross is simply tacky and tasteless. It already has a name, Middle Bickenhill.

7. Do you agree with Policy P2? If not why not, and what alternative would you suggest?

No.
Balsall Common centre has suffered from the loss of business premises, the loss of the Health Centre to a greenfield site on the edge of the village, inadequate parking, the lack of a bus station, and now a proposal to divert through-traffic. A comprehensive development plan is required to address all these issues.

Providing Homes for All
11. Do you agree with Policy P4? If not why not, and what alternative would you suggest?

No.
The shortage of land and the need for housing means that there should be a significant increase in density and the provision of smaller homes.

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

No.
The affordable housing provision should be greater than 50% for all sites - which would require development of an individual house to be "affordable".

14. Do you agree that we are planning to build the right number of new homes? If not why not, and how many do you think we should be planning to build?

No.
The housing target should just meet local needs. Excess requirements should be met in the rural expanses in neighbouring counties, who are expected to have a "duty to cooperate". Solihull should not cater for Birmingham overspill. Solihull Borough has essentially reached capacity in terms of housing provision, and a Predict and Provide policy will lead to a continuous decline in the quality of the environment and to the detriment of residents.

15. Do you believe we are planning to build new homes in the right locations? If not why not, and which locations do you believe shouldn't be included? Are there any other locations that you think should be included?

No.
The planning objectives of re-using previously-developed land and creating new settlements have been ignored. Areas such as Balsall Common are being encouraged to sprawl in contravention of accessibility, sustainability, and Green Gelt policies. The Green Belt analysis has not been conducted in line with the NPPF as non-defensible boundaries have been used. The scores attached to preserving the narrowest part of the Meriden Gap are too low and irrational. Balsall Common seems to have been singled out for concentrated and disproportionate expansion, in contrast to areas such as Dorridge, which has far better public transport. In particular, sites 1 and 3 appear to have been chosen for administrative convenience rather than compliance with local and national policies.
Preference should be given to developing brown-field sites and to raising the housing density generally.

16. Do you believe we have identified the infrastructure required to support these developments? If not why not? Are there any additional facilities you believe are required, if so what are they?

No.
With regard to Site 1, the proposed highway access is completely unsuitable and will put traffic onto residential roads. No "bypass" is proposed, but with the lack of funding the proposals are likely to create a rat-run that will cause further environmental harm for residents. There is no strategy to deliver bus service and school provision. With regard to Site 3, it is far too distant from the village centre to benefit from the quoted infrastructure improvements.

18. Do you agree with the policies for improving accessibility and encouraging sustainable travel? If not why not, and what alternatives would you suggest?

No.
Para 267 is incorrect, the HS2 Environmental Impact has been assessed on the basis that no road improvements would be needed south of the A45. It is highly unlikely that people will travel from south of Balsall Common to HS2 at Middle Bickenhill when there are nearer and more convenient alternatives at Warwick. In addition, the current railway is available to feed the new station via the People Mover. The additional housing proposed for Balsall Common is wrongly sited if it creates additional commuting traffic. There are alternative sites to the north of Balsall Common that would have good access to new employment sites and would not require road improvements.
One reason for abandoning the bypass for Balsall Common was the need to maintain the vitality of the village centre retail options. The proposed new housing would be too far from the centre to offset any loss of through-custom. The A452 only becomes congested when there are problems on the motorway network, and there is no identified need for improved capacity. Much of the traffic is generated within the village. Capacity is limited by the traffic lights at the south of the village, and improvements to that junction should be the first to be considered if demand increases.
There doesn't seem to be any justification for expensive projects like Metro and Sprint (Policy 8A). The passenger demand should first be proven by running bus services. The main factors limiting greater use of public transport are: service interval; unreliability; lack of real-time information; primitive or non-existent waiting shelters; absence of evening services; difficult access for the less agile. Berkswell Station has an irregular service with 40 minute waiting times, and has had a marked reduction in the quality of the waiting facilities. It is difficult for the disabled to board the trains due to the platform gap.
The service interval target (Policy P7) has been increased from 15 minutes between busses and 20 minutes between trains. Rail services have been dropped from the policy, and should be specificed with the same targets as for busses. The previous target intervals were too long for many users, but the proposed 30 minute wait is far too long. The rural area generally has only an hourly service, and few dwellings are within 400 metres of a stop, so Policy P7 is hugely optimistic and unrealistic.

Protecting and Enhancing our Environment
19. Do you agree with the policies for protecting the environment? If not why not, and what alternatives would you suggest?

No.
There should be a clear policy for requiring solar PV on all new buildings, and prohibiting green-field solar farms. In addition, policies should encourage use of solar PV in paved areas etc. There should be clear architectural/design standards for all solar PV installations.

Promoting Quality of Place
20. Do you agree with the policies for quality of place? If not why not, and what alternatives would you suggest?
Health and Supporting Local Communities

No.
Policy P16 should be expanded to include requirements to identify unrecognised archaeological remains during any development. A more integrated approach should be adopted to finding traces of early settlement in the area. All works in new areas should be preceded by geophysical surveys.
Policy P17 should specify Balsall Common as inset in the Green Belt and protected like the other named settlements.

21. Do you agree with the policies health and supporting communities? If not why not, and what alternatives would you suggest?

No.
Policy P20 does not provide sufficient long-term protection for public open space. All such areas should be designated as Village Greens, and green spaces in new developments should be dedicated as Village Greens by the developers.

Delivery and Monitoring
22. Do you agree with the Policy P21? If not why not, and what alternatives would you suggest?

No.
Policy P21 should be clearer about spending all "planning gain" within the affected communities. In addition, all new developments should only be approved following agreement of a detailed strategic site plan agreed within the community.
**********************************************

No

Draft Local Plan Review

Representation ID: 4261

Received: 16/02/2017

Respondent: Gladman Developments

Representation Summary:

Policy P10 - the landscape part of the policy does not seem to meet criteria in NPPF.

Full text:

Solihull Local Plan Review - Draft Plan Consultation
Please find attached a representation from Gladman into the above referenced consultation

No

Draft Local Plan Review

Representation ID: 4412

Received: 17/02/2017

Respondent: Arden Academy & Mr V Goswami

Representation Summary:

POLICY P11

- Wording in policy P11 relating to water use is too prescriptive. should instead
reference the national standards, which will future-proof the policy against any changes to national standards.
- text in the policy relating to planning obligations in respect of flood risk management schemes is ambiguous and not in compliance with national regs.
-

Full text:

joint submission by Arden Academy & Mr Ved Goswami re: Arden Triangle site 9 Knowle
see attached documents

No

Draft Local Plan Review

Representation ID: 4418

Received: 17/02/2017

Respondent: Arden Academy & Mr V Goswami

Representation Summary:

POLICY P13

- overly prescriptive to require all developments to demo that not resulting in sterilisation of mineral resources. an appropriate threshold for development size for requiring such information should be included for proposals for non-mineral development of that development within defined settlement boundaries should be exempt from this requirement.

Full text:

joint submission by Arden Academy & Mr Ved Goswami re: Arden Triangle site 9 Knowle
see attached documents

No

Draft Local Plan Review

Representation ID: 4810

Received: 17/02/2017

Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green

Agent: Pegasus Group

Representation Summary:

Recognise importance of protecting the environment.
Policy P10:
'Full ecological survey' and 'net gain or enhancement' to each development is overly arduous and not in spirit of NPPF, which states 'provide net gains in biodiversity where possible.'
Policy P11:
Approach in policy alludes to sequential test, but this is not explicit.
Unreasonable to state 'there are no other viable site at lower risk of flooding'. Viability is a much more restrictive test than availability, which is not in accordance with national guidance and should be revised accordingly.

Full text:

I am instructed by my client Gallagher Estates to submit representations to the Draft Local Plan Review consultation (December 2016).

The representations comprise of the following submissions:

* Representations to the Solihull Local Plan Review - Draft Local Plan comprising of Pegasus Group Report with accompanying appendices:
o Site Location Plan (Appendix A); o Review of SHELAA (Appendix B); o Review of SMHA (Appendix C);
o Un-met Housing Need and the Duty to Cooperate (Appendix D)
o Chelmer Model Papers (Appendix E)

* Separate Background Documents relating to :
o Land at Damson Parkway , Solihull;
o Land at Four Ashes Road, Dorridge;
o Land off Bickenhill Road, Marston Green and;
o Land off Berkswell Road, Meriden

Yes

Draft Local Plan Review

Representation ID: 4848

Received: 17/02/2017

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

The policies are consistent with advice within the National Planning Framework and subject to the measures required by each of the proposed policies not having an adverse impact on viability, the policies would appear to be acceptable.

Full text:

see attached documents

No

Draft Local Plan Review

Representation ID: 4868

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Representation Summary:

Recognise importance of protecting the environment.
Policy P10:
'Full ecological survey' and 'net gain or enhancement' to each development is overly arduous and not in spirit of NPPF, which states 'provide net gains in biodiversity where possible.'
Policy P11:
Approach in policy alludes to sequential test, but this is not explicit.
Unreasonable to state 'there are no other viable site at lower risk of flooding'. Viability is a much more restrictive test than availability, which is not in accordance with national guidance and should be revised accordingly.

Full text:

see submission and supporting documents from agent - Pegasus

Yes

Draft Local Plan Review

Representation ID: 4899

Received: 17/03/2017

Respondent: Persons with an interest Site 9

Agent: Cerda Planning Ltd

Representation Summary:

The policies are consistent with advice within the National Planning Framework and subject to the measures required by each of the proposed policies not having an adverse impact on viability, the policies would appear to be acceptable.

Full text:

see attached documents

Yes

Draft Local Plan Review

Representation ID: 5319

Received: 17/02/2017

Respondent: Jaguar Land Rover

Agent: Mr Neil Tiley

Representation Summary:

Support Policy P14 seeking to protect amenity for all, including businesses.

Full text:

see JLR letter via agent

Yes

Draft Local Plan Review

Representation ID: 5591

Received: 17/02/2017

Respondent: Arden Cross Consortium

Agent: Turley

Representation Summary:

Support the principles of Policy P9 and state that the Arden Cross proposals will make a significant contribution to this policy. However, concerns over the expectation that new development and specifically the UKC Hub area should develop and contribute to the development of heat networks within the Borough. This statement appears to have been generated in the absence of any Local Plan evidence to confirm the viability of such networks. The Heat Network delivery Unit Report is not specific to Solihull. Policy P9 should be amended to include a viability element.

Full text:

On behalf of our client, the Arden Cross Consortium, please find attached a copy of representations submitted to the public consultation on the Solihull Draft Local Plan Review (November 2016) and Interim Sustainability Appraisal Report (January 2017).

Yes

Draft Local Plan Review

Representation ID: 6244

Received: 17/02/2017

Respondent: Packington Estate Enterprises Ltd

Representation Summary:

Policy P10 -
Natural Environment:
Welcome importance being placed on maintaining a healthy, natural environment, which is consistent with Packington Estate's longer stewardship objectives.
Suggest including contribution development (in rural areas and Green Belt) makes to the viability of maintaining landscape biodiversity. Conservation and enhancement cannot take place without income and capital.
Arden Landscape section could be linked to Policy P3.
Arden Landscape, Biodiversity/Geodiversity:
Packington Estate, in particular the Deer Park contribute to the original Forest of Arden landscape. Any expansion east of A452 would negatively impact landscape character, River Blythe SSSI and result in 1000s of mature trees.

Full text:

see attached letter

Yes

Draft Local Plan Review

Representation ID: 6245

Received: 17/02/2017

Respondent: Packington Estate Enterprises Ltd

Representation Summary:

Policy P11 -
Flood Risk Reduction:
Welcome policy that ensures developers must promote developments that reduce flood risk and look to reinstate the natural floodplain where feasible, to include de-culverting and improvements of on-site watercourses.

Full text:

see attached letter

Yes

Draft Local Plan Review

Representation ID: 6246

Received: 17/02/2017

Respondent: Packington Estate Enterprises Ltd

Representation Summary:

Policy P13:
Welcome policy effectively encouraging developers to ensure minerals have been extracted before development occurs.
Packington Estate has planning consent to extract mineral at the Arden Cross Interchange Station site and is in the process of extraction.
Recognise the important contribution the mineral reserve to the east of NEC/M42 could play in contributing towards the Borough's mineral requirement.
Recognise the most sustainable mineral is that which could be excavated and used on site again and again.
Urge the Council to aid with implementing a mineral extraction plan to ensure balance of extraction and development are forthcoming.

Full text:

see attached letter

No

Draft Local Plan Review

Representation ID: 6283

Received: 17/02/2017

Respondent: The Home Builders Federation Midland Region

Representation Summary:

Policy P11 -
Should delete higher optional water efficiency standard of 110 litres per day per person.
NPPG is explicit that higher water efficiency standards should only be proposed in identified areas of water stress.
It is noted that the Water Cycle Study by the EA and STW has not identified Solihull as a water stress area (see Para.'s 303 and 304).

Full text:

Please find attached the HBF response to the above mentioned consultation for your consideration

No

Draft Local Plan Review

Representation ID: 6387

Received: 17/02/2017

Respondent: Dr P Johnson

Representation Summary:

Planning approval process is flawed and does not consider health and environment of existing council tax payers as shown by the bad example at Middlefield Spring development where lorries allowed to operate 6 days per week from 7am on roads that are too narrow.

Full text:

The Middlefield spring development illustrates how the Council does not fulfilling obligations to the health and human rights of the existing home owners. The developer has been allowed to run over 400 truck runs within a few weeks Mainly treating the site like a quarry selling the farms top soil. In comparison to the Sainsbury build workers arrive from 7am for a "start" at 8am ( Sainsbury 9am ) 6 days a week. Input that the roads are too narrow for trucks and the need for a new road through Lansdowne farm was ignored now very dangerous/ noisy