Showing comments and forms 61 to 90 of 248

No

Draft Local Plan Review

Representation ID: 1220

Received: 13/02/2017

Respondent: Mrs Judith Thomas

Representation Summary:

Welcome sequential approach to site selection but note this has not been followed for Balsall Common, as brownfield sites (of which there are many around village) not included and no explanation why excluded. Council should fully follow NPPF and its stated policy or provide reasons why village treated as an exception. Balsall Common not a sustainable transport location as bus services intermittent and daytime only, journey times to Solihull are very slow and indirect, only 2 local train services per hour in each direction and services overcrowded, roads are poorly maintained and dangerous for cycling, and limited employment opportunities.

Full text:

I welcome the sequential approach to site selection set out in paragraph 96 but note that this has not been followed in the case of Balsall Common. Proposals contain no brownfield sites (of which there are many around the village) and do not provide any form of explanation as to why they have been excluded. Either the council should fully follow the NPPF and its stated policy or specifically provide reasons as to why Balsall Common is to be treated as an exception

No

Draft Local Plan Review

Representation ID: 1234

Received: 17/02/2017

Respondent: Friends of the Earth (Cities for People)

Representation Summary:

This plan could result in ever more sprawl and car based development. There is not enough emphasis on increased densities as well as catering for a truly mixed community in terms of age, affordability and abilities.

Full text:

This plan could result in ever more sprawl and car based development. There is not enough emphasis on increased densities as well as catering for a truly mixed community in terms of age, affordability and abilities.

No

Draft Local Plan Review

Representation ID: 1251

Received: 13/02/2017

Respondent: Mrs Alex Woodhall

Representation Summary:

Objects to proportion of new housing proposed in Shirley South at 41% of the total, which should be spread more evenly over the borough. Can Solihull provide a list of brownfield sites in the borough.

Full text:

Allocation 13. Why are we in Shirley South getting 41% of the total housing plan, it should be spread more evenly over the borough. Building Affordable housing is very important to me, but I do not believe that I will be able to afford anything in this area, what you and I class as affordable seem to be a long way apart. Why have Solihull got to take some of Birmingham's allocation, when they have so many brownfield sites, many used as cheap car. parking. Can Solihull provide a list of brownfield sites in the borough.

No

Draft Local Plan Review

Representation ID: 1253

Received: 13/02/2017

Respondent: Mr Dan Salt

Representation Summary:

Solihull's plan for Balsall Common, whilst in adherence with its own simple site selection criteria, seems at odds with the stance of the current Government, insofar as the development of green belt land should be absolutely sacrosanct until all other alternatives have been exhausted. Mindless spatial infilling which begins with the surrender of green belt surely just begets further green belt surrender. There is no published evidence Solihull has adequately appraised numerous brownfield sites in and around the village and has instead opted for the simplest and most economical option for large scale yet disproportionate development. This appears plainly unlawful.

Full text:

The spatial strategy and site selection criteria appears overly simplified. there are numerous multifaceted concerns that arise as a consequence of the proposed large scale development of Balsall Common. Public transport is not fit to withstand a further 1000+ dwellings. There is currently an irregular train service with two trains per hour in one direction. A wait of up to 40 minutes can occur which does not look like Good public transport links to me. Furthermore, residents are acutely aware and know that people travel in from Tile Hill and Kenilworth for example to cram onto trains at Berkswell Village. increasing the capacity of the car park and even encouraging London Midland to increase train sizes will not serve the local community - it will only serve out of area users. Train and Bus services are currently sporadic and largely unsafe for younger and female users due to long wait times. Additionally i would estimate that cramming more users on at Berkswell will just create a problem at the next station stop - so rail users at Hampton in Arden or Marston Green for example, cannot board trains. All because of disproportionate increases in dwellings in Balsall Common at the expense of the Green Belt. The general consensus view of residents is that housing development needs to occur and everyone should share in that, but it should be done in the first instance by the sensible recycling of brownfield sites to infill the settlement, concurrently avoiding focussed point strain on roads and infrastructure and having a hugely negative impact on the ecologically rich environment (Bats, Newts, Owls, Dormice, Frogs, to name but a few species, but all clearly present on the proposed Barratts Farm Site).

No

Draft Local Plan Review

Representation ID: 1255

Received: 13/02/2017

Respondent: Mr Stuart Woodhall

Representation Summary:

Allocation 13 ( south Shirley )does not support the HS2 vision as this likely to located to North east of the borough
With journey times by car to access HS2 to be greater than 1hr at peak times

Full text:

Allocation 13 ( south Shirley )does not support the HS2 vision as this likely to located to North east of the borough
With journey times by car to access HS2 to be greater than 1hr at peak times

No

Draft Local Plan Review

Representation ID: 1263

Received: 13/02/2017

Respondent: Mrs Olga Cawdell

Representation Summary:

Object to proportion of new housing proposed for South Shirley, as believes building 41% of the Borough's housing allocation in one small area would be a major error by the council, and building on such a large scale will change the whole character of the area, turning it into just another part of the urban sprawl.

Full text:

Allocation 13. I believe building 41% of the housing allocation in one small area in south Shirley would be a major error by the council, building on such a large scale will change the whole character of the area, turning it into just another part of the urban sprawl.

No

Draft Local Plan Review

Representation ID: 1276

Received: 15/02/2017

Respondent: Mrs Denise Delahunty

Representation Summary:

I agree with principle of concentrated development so that infrastructure can be built in BUT to have MORE concentrated development in the Shirley/Dickens Heath would put too much pressure on existing infrastructure. Due to Dickens Heath, local 2ndary schools are already at capacity (all schools have porta-cabins already), roads are full to capacity & parking space is at a premium.There are other suburbs of Solihull on the edge of the urban area that have not had this amount of development imposed.

Full text:

I agree with principle of concentrated development so that infrastructure can be built in BUT to have MORE concentrated development in the Shirley/Dickens Heath would put too much pressure on existing infrastructure. Due to Dickens Heath, local 2ndary schools are already at capacity (all schools have porta-cabins already), roads are full to capacity & parking space is at a premium.There are other suburbs of Solihull on the edge of the urban area that have not had this amount of development imposed.

No

Draft Local Plan Review

Representation ID: 1314

Received: 14/02/2017

Respondent: Mr Roger Monkman

Representation Summary:

More thought should be given to brownfield sites rather than eating into the Green Belt again. Can the council justify this approach? Not according to the draft local plan. And more thought needs to be put into public transport links. With more than 1,000 houses proposed for Balsall Common there has to be an improvement but the local plan seems to disregard the fact that the area has an aging population as well as great many schoolchildren.

Full text:

More thought should be given to brownfield sites rather than eating into the Green Belt again. Can the council justify this approach? Not according to the draft local plan. And more thought needs to be put into public transport links. With more than 1,000 houses proposed for Balsall Common there has to be an improvement but the local plan seems to disregard the fact that the area has an aging population as well as great many schoolchildren.

No

Draft Local Plan Review

Representation ID: 1344

Received: 14/02/2017

Respondent: Mrs Sylvia Gardiner

Representation Summary:

This is a difficult form to understand and fill in. However, the green belt I do understand. If all 'allocation 13' is used for building it will box South Shirley in, giving residence no open area for recreation. This will be a major health problem. Who benefits the residents or the builders? It does make one wonder who is benefiting financially from this project. To take all our environment is scandalous! It makes one question who is working for us the residence.

Full text:

This is a difficult form to understand and fill in. However, the green belt I do understand. If all 'allocation 13' is used for building it will box South Shirley in, giving residence no open area for recreation. This will be a major health problem. Who benefits the residents or the builders? It does make one wonder who is benefiting financially from this project. To take all our environment is scandalous! It makes one question who is working for us the residence.

Yes

Draft Local Plan Review

Representation ID: 1349

Received: 14/02/2017

Respondent: mrs jacqui gardner

Representation Summary:

It is preferable to build on existing developed land over green belt, however I believe that public transport links will need improvement.

Full text:

It is preferable to build on existing developed land over green belt, however I believe public transport links need improvement.

No

Draft Local Plan Review

Representation ID: 1357

Received: 15/02/2017

Respondent: Mr Michael Fairbrother

Representation Summary:

The high % of use of greenfield vs developed land not in line with policy. "..balance should be struck between concentrating development in a relatively small number of locations and dispersing development over a greater number of locations" - with regard to the disproportionate allocation to Balsall Common this is NOT achieved. Rather than destroy a whole village both for the present and the future there should be a cap on the allocation to any single community based on the planned % increase in population. This would ensure some objective fairness

Full text:

The high % of use of greenfield vs developed land not in line with policy. "..balance should be struck between concentrating development in a relatively small number of locations and dispersing development over a greater number of locations" - with regard to the disproportionate allocation to Balsall Common this is NOT achieved. Rather than destroy a whole village both for the present and the future there should be a cap on the allocation to any single community based on the planned % increase in population. This would ensure some objective fairness

No

Draft Local Plan Review

Representation ID: 1363

Received: 14/02/2017

Respondent: David Holtom

Representation Summary:

In growth option F, why suggest constructing increased housing in a wedge between the SE of Balsall Common and the proposed HS2 line,with an expected exposure to high noise volumes. The SW or West of Balsall Common would be a much more satisfactory choice of location.

Full text:

In growth option F, why suggest constructing increased housing in a wedge between the SE of Balsall Common and the proposed HS2 line,with an expected exposure to high noise volumes. The SW or West of Balsall Common would be a much more satisfactory choice of location.

No

Draft Local Plan Review

Representation ID: 1409

Received: 15/02/2017

Respondent: Dr Christine West

Representation Summary:

Selection criteria have not been correctly applied in Balsall Common because available brownfield sites not used, all sites are green field/Green Belt, and the scoring for the different sites lacks clear criteria.

Full text:

The Borough's Spatial Strategy is being contravened by the use of Green Fields instead of first using every available brown field area. In Balsall Common, the use of Barratts Farm, destroys a huge area of the Green Belt which was accessible to the community and reached the Kenilworth Greenway. Much of this area is criss-crossed with regularly used footpaths, and fields where wheat is grown and cows pastured. There would be no other near footpaths for people on this side of the village so the deprivation is huge. A park would never replace this amenity.

No

Draft Local Plan Review

Representation ID: 1419

Received: 15/02/2017

Respondent: Mr Andrew Burrow

Representation Summary:

The spatial strategy ignores SMBC policies with respect to sustainable development particularly public transport policy. Balsall Common is an unsustainable location but SMBC plan large amounts of housing there creating further road traffic.

The strategy for developing PDL land before greenfield is correct but that it not what this plan does.

The strategy makes sweeping claims about developing urban areas then puts large numbers of houses in rural areas without transport and other infrastructure
For both reasons the plan is unsound.

Full text:

The spatial strategy ignores SMBC policies with respect to sustainable development particularly public transport policy. Balsall Common is an unsustainable location but SMBC plan large amounts of housing there creating further road traffic.

The strategy for developing PDL land before greenfield is correct but that it not what this plan does.

The strategy makes sweeping claims about developing urban areas then puts large numbers of houses in rural areas without transport and other infrastructure
For both reasons the plan is unsound.

No

Draft Local Plan Review

Representation ID: 1424

Received: 15/02/2017

Respondent: Dominic Griffin

Representation Summary:

Balsall Common and Berkswell are rural areas in the Green Belt. If the borough's plan is increase housing for employment, these need to be where the jobs will be, near the UK Central Hub Growth Area, not a remote location in the /southeast of the borough.

Full text:

Balsall Common and Berkswell are rural areas in the Green Belt. If the borough's plan is increase housing for employment, these need to be where the jobs will be, near the UK Central Hub Growth Area, not a remote location in the /southeast of the borough.

No

Draft Local Plan Review

Representation ID: 1454

Received: 15/02/2017

Respondent: Yasmine Griffin

Representation Summary:

Should use brownfield land ahead of green belt land, as extensive brownfield, industrial or abandoned land throughout the Borough, crying out for development. New housing should be closer to employment eg HS2, Airport, NEC, Resorts World and JLR, with improved transport links between communities, such as Kenilworth and Balsall Common, universities and employment areas, as would reduce congestion and carbon emissions. If development to be proposed in Balsall Common needs to be a settlement masterplan to cover use of brownfield land, transport and accessibility and infrastructure requirements.

Full text:

Solihull Council should use brownfield land ahead of Greenbelt land. There is extensive brownfield land throughout the borough. Industrial or abandoned land which is crying out for development. Such sites would reduce congestion in Balsall Common. Few residents of Balsall Common work in the area. The majority of residents drive. Very few use the poor train service which runs only twice an hour in each direction or the 87 bus service which runs on the hour for a few hours during the day. It is not appropriate to advocate these services as a reason to place housing in the village.

No

Draft Local Plan Review

Representation ID: 1476

Received: 16/02/2017

Respondent: Mr Mark Bruckshaw

Representation Summary:

I believe that the building so many properties in such a small area will be devastating to the area and cause more problems than it solves. ASB, crime, will rise and health and wellbeing will plummet. The roads will not cope, regardless of what improvements are made. Businesses will suffer and move out of the area. FORWARD THINKING PLEASE!

Full text:

I object because I believe that the building so many properties in such a small area will be devastating to the area and cause more problems than it solves. I have worked to help homeless people for over 25 years and so my view point does not come from 'not in my back yard'. I have managed estates on residential properties for 30 years and from experience, ASB, crime, will rise and health and well being will plummet. The roads will not cope, regardless of what improvements are made. Businesses will suffer and move out of the area. FORWARD THINKING PLEASE!

No

Draft Local Plan Review

Representation ID: 1489

Received: 16/02/2017

Respondent: Mr Keith Tindall

Representation Summary:

The spatial strategy should start with development of brown field sites.

Full text:

The spatial strategy should start with development of brown field sites.

Yes

Draft Local Plan Review

Representation ID: 1527

Received: 16/02/2017

Respondent: Star Planning and Development

Representation Summary:

Richborough Estates Limited support the principles of the spatial strategy and the broad locations for growth. Based upon the range of technical and environmental assessments undertaken by the Council and Richborough Estate, the Proposed Housing Allocation 2: Frog Lane, Balsall Common and Proposed Housing Allocation 4: West of Dickens Heath accord with the spatial strategy and national planning policy about the sustainable locations for growth.

Full text:

Strategic Objectives paras 96 and 102.

Richborough Estates Limited support the approach of the Local Plan Review to promote patterns of development that focus significant growth in locations that are, or can be made, sustainable. Richborough Estates recognise that previously developed land within urban areas should be exploited which is referred to in the White Paper Fixing our broken housing market.

However, given the nature of Solihull Borough, the recognition that opportunities for non-Green Belt development outside the main urban area and the larger settlements are limited is welcomed. Further, even where such opportunities might be claimed to exist then careful consideration is needed as to whether development could proceed without harming the character of existing areas (e.g. 'town cramming', poor quality backland development, loss of open area, reductions in employment opportunities/land, etc.). There are also questions whether such opportunities are deliverable because of constraints associated with, amongst other matters, ownership, legal restrictions, access, trees, ground conditions, viability implications etc.

Using the available evidence base, the Borough Council can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirement and that there are exceptional circumstances associated with delivering the objectively assessed housing need which fully justify amending the Green Belt boundary at appropriate locations. Such an approach is consistent with the National Planning Policy Framework and the White Paper.

Sequentially, within the Green Belt it is correct to direct growth towards locations that are highly or moderately accessible whether they are greenfield or previously developed sites. Sustainable and accessible locations are those related to public transport corridors (or transport hubs as now referred to in the White Paper) or on the edge of accessible settlements which possess a range of local facilities. The proposed allocations at Frog Lane, Balsall Common (Potential Housing Allocation 2) and West of Dickens Heath (Potential Housing Allocation 4) fully accord with the sequential approach adopted in the Local Plan Review towards directing growth to sustainable locations.

Although superficially attractive, growth on previously developed land in the Green Belt located away from existing public transport corridors or accessible settlements should be resisted because it would fail to deliver sustainable forms of development.

Broad Options for Growth and Development - paras 108 and 109.

Richborough Estates Limited support the broad options for growth and development focusing significant growth in locations that are, or can be made, sustainable as advocated in the Local Plan Review's Strategic Objectives and Guiding Principles.

Using the available evidence base, the Borough Council can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirement and that there are exceptional circumstances associated with delivering the objectively assessed housing need which fully justify amending the Green Belt boundary at the chosen broad locations. Such an approach is consistent with the National Planning Policy Framework and the White Paper Fixing our broken housing market.

The chosen broad option for growth and development provide a balanced approach to accommodate development by dispersing growth to accessible locations across the Borough rather than placing undue reliance upon one or two strategic locations (e.g. The UK Central Hub Area/HS2). A balanced approach to the distribution of housing growth across the Borough enables the identification of a range of different sizes and types of sites in the emerging Local Plan, including those within both the urban area and the Green Belt.

The broad option also enables the Local Plan Review to identify a wide choice of allocations in different locations across the Borough which can be delivered at the same time thereby both fostering competition which will assist with curbing house price inflation and enhancing the prospects of delivering the required dwellings within the plan period to meet the identified housing needs. These identified needs are related to both the local Solihull housing market and addressing part of the shortfall of suitable and available residential land within the wider Housing Market Area.

The White Paper is also clear that 'Policies in plans should allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector' (paragraph 1.29). The ability to identify a wide range choice of housing allocations increases the potential delivery of a mix of high quality homes, provides the opportunity to widen opportunities for home ownership and promotes the ability to create sustainable, inclusive and mixed communities of the type sought by the National Planning Policy Framework.

Larger scale housing allocations on the periphery of Solihull, Shirley and other accessible settlements could incorporate the principles of Garden Cities as advocated in the Framework. Such an opportunity also exists through the allocation of land to the West of Dickens Heath (Potential Housing Allocation 4 (PHA4)) which is a large site at adjacent to an accessible settlement and located along a public transport corridor, specifically adjacent to a transport hub.

As recorded in the Interim Sustainability Appraisal Report (January 2017) there are sites available under this approach capable of contributing towards the meeting housing supply within the next 5-years, including land under the control of Richborough Estates at Frog Lane, Balsall Common (Potential Housing Allocation 2 (PHA2)) and to the West of Dickens Heath (PHA4). The Frog Lane site could be fully delivered within 5-years from when the site is taken out of the Green Belt. There would be new homes delivered during a 5-year period at Dickens Heath but it would be reasonable to assume that the whole scheme would take between 8-10 years to deliver from the date of the first dwelling being occupied.

At both locations, new homes can readily be delivered utilising existing local services and public transport. The opportunity also exists for investment in new or improved facilities and services for the benefit of both existing and future residents, including a Community Sports Hub at Dickens Heath. Further, and as indicated in the White Paper, there are potential
opportunities for compensatory improvements to the environmental quality or accessibility of remaining Green Belt land or land within the vicinity of these broad locations.

No

Draft Local Plan Review

Representation ID: 1545

Received: 16/02/2017

Respondent: Mr Paul Southall

Representation Summary:

Housing should accommodate people that work in the Midlands rather than providing housing for the needs of people in London, and community will suffer because we will simply be a commuter town. Council should be working to encourage business in Solihull, but building houses in Blythe Valley Park shows that the council have failed the community. People working in London will shop there, go out there, Solihull will not benefit, house prices will rise to the detriment of local people. It will however benefit builders!

Full text:

Whilst it is important that public transport is provided, the majority of people in rural areas use cars. The road network in the lanes and roads south of the A34 are generally narrow. Access in and out of Dickens Heath is very poor. Whilst plans allow for 2 cars per household, with many households having grown children at home many houses will need more than provision for 2 cars.
If people use railway stations increased car parking will be required.

No

Draft Local Plan Review

Representation ID: 1570

Received: 17/02/2017

Respondent: Mrs Julie Cooper

Representation Summary:

Given the significant use of green belt for proposed development, concerned that council has not sufficiently explored non green belt sites available, of which there are many in the Balsall Common area, nor has this been sufficiently evidenced throughout the plan.

Full text:

Given the significant use of green belt proposed for this local plan it feels like the council has not sufficiently explored non green belt sites available, of which there are many and this has not been sufficiently evidenced throughout the plan as to why so many of the sites are green belt rather than non green belt. Due to further disruption to borough from the delivery of HS2 and related UKC developments it compounds the impact in certain areas of the borough and is going Impact on residents quality of challenging over the coming 5 to 15 years.

No

Draft Local Plan Review

Representation ID: 1587

Received: 17/02/2017

Respondent: Portland Planning Consultants

Representation Summary:

Having regard to law, policy and case law (IM Properties v Lichfield DC [2014] EWHC and Gallagher Homes v Solihull Metropolitan Borough Council [2014] EWHC 1283) it is considered that the approach to testing of Green Belt sites for release is misplaced, as should involve consideration of impact on openness and accessibility to facilities, including reference to travel to work patterns, as part of overall sustainability assessment.

Full text:

Whilst the first priority being given to non Green Belt land is considered to be appropriate nad now in line with the recent White paper it is felt the Green Belt hierarchy is in appropriate. For Green Belt sites a testing involving impact on openness and accessibility to facilities, including reference to travel to work patterns should be employed in order to secure an appropriate ordering for release. The current approach set out the spatial strategy choices at paragraph 96 (b) has an arbitrariness not well related to the purposes of the Green Belt. An analysis which omits on a site by site basis and assessement on the openness regime and overall sustainability assessement would seem to be flawed.

IM Properties v Lichfield DC [2014] EWHC addresses the approach thus:-

' 90.
The case of Gallagher Homes v Solihull Metropolitan Borough Council [2014] EWHC 1283 deals with the test for redefining a green belt boundary since the publication of the NPPF. Paragraphs 124 and 125 of Gallagher read:


"124. There is a considerable amount of case law on the meaning of "exceptional circumstances" in this context. I was particularly referred to Carpets of Worth Limited v Wyre Forest District Council (1991) 62 P & CR 334 ("Carpets of Worth"), Laing Homes Limited v Avon County Council (1993) 67 P & CR 34 ("Laing Homes"), COPAS v Royal Borough of Windsor and Maidenhead [2001] EWCA Civ 180; [2002] P & CR 16 ("COPAS"), and R (Hague) v Warwick District Council [2008] EWHC 3252 (Admin) ("Hague"). "
125. From these authorities, a number of propositions are clear and uncontroversial.
i) Planning guidance is a material consideration for planning plan-making and decision-taking. However, it does not have statutory force: the only statutory obligation is to have regard to relevant policies.
ii) The test for redefining a Green Belt boundary has not been changed by the NPPF (nor did Mr Dove suggest otherwise).
a) In Hunston, Sir David Keene said (at [6]) that the NPPF "seems to envisage some review in detail of Green Belt boundaries through the new Local Plan process, but states that 'the general extent of Green Belts across the country is already established'". That appears to be a reference to paragraphs 83 and 84 of the NPPF. Paragraph 83 is quoted above (paragraph 109). Paragraph 84 provides:
"When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development...".
However, it is not arguable that the mere process of preparing a new local plan could itself be regarded as an exceptional circumstance justifying an alteration to a Green Belt boundary. National guidance has always dealt with revisions of the Green Belt in the context of reviews of local plans (e.g. paragraph 2.7 of PPG2: paragraph 83 above), and has always required "exceptional circumstances" to justify a revision. The NPPF makes no change to this.
b) For redefinition of a Green Belt, paragraph 2.7 of PPG2 required exceptional circumstances which "necessitated" a revision of the existing boundary. However, this is a single composite test; because, for these purposes, circumstances are not exceptional unless they do necessitate a revision of the boundary (COPAS at [23] per Simon Brown LJ). Therefore, although the words requiring necessity for a boundary revision have been omitted from paragraph 83 of the NPPF, the test remains the same. Mr Dove expressly accepted that interpretation. He was right to do so.
iii) Exceptional circumstances are required for any revision of the boundary, whether the proposal is to extend or diminish the Green Belt. That is the ratio of Carpets of Worth.
iv) Whilst each case is fact-sensitive and the question of whether circumstances are exceptional for these purposes requires an exercise of planning judgment, what is capable of amounting to exceptional circumstances is a matter of law, and a plan-maker may err in law if he fails to adopt a lawful approach to exceptional circumstances. Once a Green Belt has been established and approved, it requires more
than general planning concepts to justify an alteration."
91.
From that review it can be seen that there is no test that green belt land is to be released as a last resort. It is an exercise of planning judgment as to whether exceptional circumstances necessitating revision have been demonstrated.

92.
The interested parties emphasise the importance of section 39 of the Planning and Compulsory Purchase Act 2004 which imposes a duty upon the defendant and the

inspector when exercising their functions under part 2 of the Act in relation to local development documents. The section demonstrates that the achievement of sustainable development is an ongoing duty upon any body exercising its function under part 2 of the Act. Sustainable development is a concept which is an archetypal example of planning judgment.

93.
The duty to contribute to sustainable development imports a concept which embraces strategic consideration about how best to shape development in a district to ensure that proper provision is made for the needs of the 21st century in terms of housing and economic growth and for mitigating the effects of climate change. Inevitably, travel patterns are important. Both the SEA and the sustainability appraisal are important components in forming a judgment to be made under Section 39(2).

94.
As a result it is submitted that the green belt designation is a servant of sustainable development.

Discussion and conclusions

95.
In my judgement to refer to a falsification doctrine is to take the words of Simon Brown LJ out of context. To elevate the words that he used into a doctrine is to overstate their significance.

96.
What is clear from the principles distilled in the case of Gallagher is that for revisions to the green belt to be made exceptional circumstances have to be demonstrated. Whether they have been is a matter of planning judgment in a local plan exercise ultimately for the inspector. It is of note that in setting out the principles in Gallagher there is no reference to a falsification doctrine or that any release of green belt land has to be seen as a last resort.

97.
The only statutory duty is that in Section 39 (2) (supra). In that regard the contents of paragraph 84 of the NPPF are relevant. That says,


"84. When drawing up or reviewing Green Belt boundaries
local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt
boundary."
98.
That is clear advice to decision makers to take into account the consequences for sustainable development of any review of green belt boundaries. As part of that patterns of development and additional travel are clearly relevant.

99.
Here, the release from the green belt is proposed in Lichfield which is seen by the defendant as consistent with the town focused spatial strategy. The further releases have been the subject of a revised sustainability appraisal by the defendant. That found that no more suitable alternatives existed for development.

100.
The principal main modifications endorsed by the defendant expressly referred to the green belt review and to the supplementary green belt review as informing the release of green belt sites. They contained advice as to the relevant tests that members needed to apply. Both documents were available to the decision making committees and were public documents. Ultimately, the matter was one of planning judgment where the members had to consider whether release of green belt land was necessary and, in so determining, had to be guided by their statutory duty to achieve sustainable development.


101. The members were aware that they had originally been presented with the Deans Slade and Cricket Lane sites as directions of growth at a much earlier stage of the local plan development. As the sites were to the south of Lichfield members were advised that development there would have little impact on the setting of the city overall and there were few limitations beyond the policy constraint of green belt. However, the extent of concern about loss of green belt at that time meant that the plan was revised to reduce the amount of growth in that direction. The inspector had found that the defendant had failed to produce a sound plan with that approach. An alternative strategy of a new village had been considered by the inspector as a first stage of the examination process and he had found that that failed to outperform the council's preferred strategy. The members were entitled to take all of those factors into account in concluding whether there was a necessity to propose to release sites from the green belt.
102.
In my judgment, the members were aware of the test which they had to apply through the content of the documents before them together with their experience and knowledge as members of a council where a significant amount of its land was within the green belt. They were entitled to take into account the genesis of the plan and the inspector's findings in concluding that in their view there were exceptional circumstances for a green belt revision. The main modifications endorsed show, in my judgment, that the defendant grappled with matters set out in the NPPF, their duty under Section 39 and the request by the Inspector to remedy shortcomings in their Development Plan.

103.
Further, the letter from Deloitte of the 6th January 2014 which was sent to members of the Environment and Development (Overview and Scrutiny) Committee, albeit on the part of the claimants, was absolutely clear as to the correct approach to adopt. It rightly said that exceptional circumstances had to be demonstrated. It is odd, in those circumstances, for the claimant to make the submission that the defendant throughout misunderstood, misinterpreted and/or was misled as to the relevant test to apply. This ground fails. '

In the context of the above it is considered the approach set out in paragraph 96 of the Draft Local Plan Review is flawed and the proposed allocations derived from it need to be re-tested

No

Draft Local Plan Review

Representation ID: 1597

Received: 17/02/2017

Respondent: Hockley Heath Parish Council

Representation Summary:

HHPC does not agree that spatial strategy should be looked at afresh (paragraph 91). "Releasing land from the Green Belt to maximise the growth potential from HS2" has yet to be agreed (Paragraph 104). The cascade model is a reasonable approach and the outcome connects proposed developments to existing urban areas with access to services whilst maintaining the rural area, but needs to say more on transport network design and upgrades and avoidance of overloading rural networks connecting to primary routes. Do not agree with Growth Option G relating to significant expansion of rural villages/settlements.

Full text:

Paragraph 91 states "The two factors outlined above represent a significant shift from the starting point of the 2013 plan and requires the spatial strategy to be looked at afresh. This is in the context that to deliver the level of growth envisaged, will require significant releases of land from the Green Belt". HHPC do not agree with this conclusion.
Paragraph 104 states "Releasing land from the Green Belt to maximise the growth potential from HS2". HHPC view is that this is yet to be agreed.
Paragraph 105 - HHPC do not agree with "Growth Option G - New Settlements, Large Scale Urban Extensions or Significant Expansion of Rural Villages/Settlements".

No

Draft Local Plan Review

Representation ID: 1602

Received: 17/02/2017

Respondent: Heyford Developments Ltd

Agent: Avison Young

Representation Summary:

Welcome approach in Plan. Agree development should be focused in most accessible locations and ensure necessary infrastructure is delivered.
DLP does not define how Council proposes to assess alternative locations for development. Absence of such criteria renders DLP unsound.
Para. 101 should be amended to refer to evidence base.
Para. 107 includes inconsistencies on spatial distribution. Should be reworded to ensure equal consideration of alternative development.
Strongly object to Reviewing the Options paper.
Lack of comparative analysis.
Overestimated site delivery timescales.
Should make more reference to Neighbourhood Plans, e.g. KDBH, and amend Para. 108.




Full text:

Please see to the uploaded attachements

No

Draft Local Plan Review

Representation ID: 1631

Received: 17/02/2017

Respondent: mr Robert Powell

Representation Summary:

The policy seems to be to build more houses regardless of the availablity of suitable land. with the loss of green field sites and farm land. Suppose it is more profitable for the farmer to sell the land for devopment and sit back and live of the proceeds.
Solihull and surrounding Councils are being forced to become overspill areas for Birmingham as a large central ring around the city is now becoming a run down slum area. Let more brown field sites be redeveloped.

Full text:

The policy seems we need to build more houses regardless of the availablity of suitable land just build on another green field site but this is being done all over the country. with the loss of farm land. Suppose it is more profitable for the farmer to sell the land for devopment and sit back and live of the proceeds.
.Solihull and surrounding Councils are been forced to become overspill areas for Birmingham as a large central ring around the city is now becoming a run down slum area. Let more brown field sites be redeveloped.

Yes

Draft Local Plan Review

Representation ID: 1649

Received: 17/02/2017

Respondent: M7 Real Estate Ltd

Representation Summary:

The spatial strategy is supported. The larger greenfield allocated sites will require the provision of extensive infrastructure and services. It would be advantageous to encourage the development of sustainably located brownfield sites in the early part of the Local Plan period so as to provide a more even supply of new homes throughout the Plan period.

Full text:

The spatial strategy is supported. The larger greenfield allocated sites will require the provision of extensive infrastructure and services. It would be advantageous to encourage the development of sustainably located brownfield sites in the early part of the Local Plan period so as to provide a more even supply of new homes throughout the Plan period.

No

Draft Local Plan Review

Representation ID: 1662

Received: 17/02/2017

Respondent: Mr Eric Homer

Representation Summary:

Disproportionate amount of building in Shirley South. Inadequate infrastructure which cannot be mitigated. Loss of valuable amenity space. impact on health and wellbeing of residents. Impact on valuable eco systems and wildlife. In crease in urban sprawl. Merging of communities losing identity. Increase in pollution. Full utilisation of brownfield sites has not been made. Should be building close to employment growth areas in the east and centre of the borough not in south Shirley.

Full text:

Developing residential buildings in the town centre makes good sense especially in terms of offering good transport connections and supporting the local economy in the town centre. However, the concentration of settlements to the south of Shirley does not make any sense. The Shirley area is already subject to a huge amount of congestion which affects the whole of the Stratford Road from the M42 junction and all arterial routes, including Dog Kennel Lane, Tanworth Lane, Shakespeare Drive, Blackford Lane, Haslucks Green Road and Bills Lane. In addition, the main route out of Dickens Heath to the Miller and Carter is like a racetrack. Some of the local rat runs such as Stretton Road constantly has drivers coming along the road at ridiculous speeds, in an area with two schools and a large elderly community. The addition of thousands of new homes will compound congestion and traffic flow to a catastrophic level and also increase rat run traffic.
In terms of benefitting from HS2, I can understand the logic of building residential
properties in the vicinity of UK Central, but if properties were built around Shirley, residents would need to access both the A34 and the M42, worsening what are already congested roads.

There is also the question of fairness to take into account in terms of opting for a model which focuses on concentrated development. There are 18 sites allocated sites in the plan, totalling 6,150 dwellings. 2,550 of these (4, 11, 12, and 13), or 41% will directly impact Shirley. We in Shirley will lose space which provides an important buffer between Shirley and Dickens Heath, will lose a significant amount of space which plays an important role in maintaining the health and wellbeing of the community and its residents. The Shirley Mature Suburb will not retain the suburbs leafy character as the draft plan shows building houses on our network of high quality open spaces and not preserving them which is in direct conflict with the Borough Vision.

Site 13 is used extensively by local residents for much valued healthy walking exercise and enjoying the huge variety of wildlife and there is an atmosphere of friendliness and community spirit when out walking.
The impact of losing this is unimaginable and could not be replaced, not only in respect of the wildlife but also the health of people using and living by this area. The presence of the large numbers of Christmas trees, other mature deciduous trees and mature hedgerows within site 13 enhances the air quality absorbing greenhouse gases such as Carbon Dioxide and Methane. Losing this would significantly increase pollution, increase the Carbon footprint and have a considerably detrimental impact on air quality affecting local residents.
Site 13 provides a valuable green, healthy area separating the two areas of Shirley and the ever expanding Dickens Heath Village. To virtually adjoin these areas with more developments would turn a well balanced Mature Suburb into a vast urban sprawl and would destroy the semi rural feeling of the area and be detrimental to the identity and community of the two areas.
Site 13 plays a particularly important role in the community. Very many walkers go across that land every day. It's one of the few places where you can guarantee that people will talk and interact with one another, even those who they have never met before. This is pivotal for maintaining relationships, mental health and an identification with the place you live for a great many people.

The loss of green belt around the existing estates of Shirley, increased traffic volumes and decreasing air quality will have to be borne by residents of Shirley South. The development of these sites would bring about an increase in urban sprawl. I do not consider that full utilisation of brownfield sites across the West Midlands Combined Authority has been made. Sites to the east of Solihull should be looked at with greater intensity. There is greater opportunity to develop infrastructure around the edge of the smaller conurbations, offering the opportunity to provide better public transport links and connect more readily and conveniently with HS2. There is less risk of merging of settlements with distinctive identities, as the gap between settlements is far larger. These sites are also closer to the growth areas of JLR, the airport the NEC and HS2. Put the houses where the employment areas are not miles away in Shirley.

Also, the town centre offers an opportunity for higher density housing than anywhere
else in the borough. The benefit to the community should be put before property developers.

No

Draft Local Plan Review

Representation ID: 1671

Received: 17/02/2017

Respondent: Mrs Linda Homer

Representation Summary:

Object to disproportionate amount of building in Shirley South as full utilisation of brownfield sites has not been made and should be building close to employment growth areas in the east and centre of the Borough not in south Shirley.

Full text:

Developing residential buildings in the town centre makes good sense especially in terms of offering good transport connections and supporting the local economy in the town centre. However, the concentration of settlements to the south of Shirley does not make any sense. The Shirley area is already subject to a huge amount of congestion which affects the whole of the Stratford Road from the M42 junction and all arterial routes, including Dog Kennel Lane, Tanworth Lane, Shakespeare Drive, Blackford Lane, Haslucks Green Road and Bills Lane. In addition, the main route out of Dickens Heath to the Miller and Carter is like a racetrack. Some of the local rat runs such as Stretton Road constantly has drivers coming along the road at ridiculous speeds, in an area with two schools and a large elderly community. The addition of thousands of new homes will compound congestion and traffic flow to a catastrophic level and also increase rat run traffic.
In terms of benefitting from HS2, I can understand the logic of building residential properties in the vicinity of UK Central, but if properties were built around Shirley, residents would need to access both the A34 and the M42, worsening what are already congested roads.

There is also the question of fairness to take into account in terms of opting for a model which focuses on concentrated development. There are 18 sites allocated sites in the plan, totalling 6,150 dwellings. 2,550 of these (4, 11, 12, and 13), or 41% will directly impact Shirley. We in Shirley will lose space which provides an important buffer between Shirley and Dickens Heath, will lose a significant amount of space which plays an important role in maintaining the health and wellbeing of the community and its residents. The Shirley Mature Suburb will not retain the suburbs leafy character as the draft plan shows building houses on our network of high quality open spaces and not preserving them which is in direct conflict with the Borough Vision.

Site 13 is used extensively by local residents for much valued healthy walking exercise and enjoying the huge variety of wildlife and there is an atmosphere of friendliness and community spirit when out walking.
The impact of losing this is unimaginable and could not be replaced, not only in respect of the wildlife but also the health of people using and living by this area. The presence of the large numbers of Christmas trees, other mature deciduous trees and mature hedgerows within site 13 enhances the air quality absorbing greenhouse gases such as Carbon Dioxide and Methane. Losing this would significantly increase pollution, increase the Carbon footprint and have a considerably detrimental impact on air quality affecting local residents.
Site 13 provides a valuable green, healthy area separating the two areas of Shirley and the ever expanding Dickens Heath Village. To virtually adjoin these areas with more developments would turn a well balanced Mature Suburb into a vast urban sprawl and would destroy the semi rural feeling of the area and be detrimental to the identity and community of the two areas.
Site 13 plays a particularly important role in the community. Very many walkers go across that land every day. It's one of the few places where you can guarantee that people will talk and interact with one another, even those who they have never met before. This is pivotal for maintaining relationships, mental health and an identification with the place you live for a great many people.

The loss of green belt around the existing estates of Shirley, increased traffic volumes and decreasing air quality will have to be borne by residents of Shirley South. The development of these sites would bring about an increase in urban sprawl. I do not consider that full utilisation of brownfield sites across the West Midlands Combined Authority has been made. Sites to the east of Solihull should be looked at with greater intensity. There is greater opportunity to develop infrastructure around the edge of the smaller conurbations, offering the opportunity to provide better public transport links and connect more readily and conveniently with HS2. There is less risk of merging of settlements with distinctive identities, as the gap between settlements is far larger. These sites are also closer to the growth areas of JLR, the airport the NEC and HS2. Put the houses where the employment areas are not miles away in Shirley.

Also, the town centre offers an opportunity for higher density housing than anywhere else in the borough. The benefit to the community should be put before property developers.

No

Draft Local Plan Review

Representation ID: 1677

Received: 17/02/2017

Respondent: Judith Parry-Evans

Representation Summary:

Support the sequential approach, PDL/brownfield, greenfield outside greenbelt, greenfield and green belt but why hasn't this hasn't been applied in Balsall Common? How can Balsall Common contribute to both 'Limited Expansion of Rural Villages/Settlements' and 'Significant Expansion of Rural Villages/Settlements' as the total means significant expansion.
The selection of sites to the east, south east and south of Balsall Common may well preserve the green belt space between Balsall Common and Knowle, but certainly reduces the gap between the village and Coventry - a far smaller separation.

Full text:

Support the sequential approach, PDL/brownfield, greenfield outside greenbelt, greenfield and green belt. Why hasn't this hasn't been applied in Balsall Common?
I fail to see how Balsall Common can be both 'Limited Expansion of Rural Villages/Settlements' and 'Significant Expansion of Rural Villages/Settlements'. the total means significant expansion.
The selection of sites to the east, south east and south of Balsall Common may well preserve the green belt space between Balsall Common and Knowle, but certainly reduce the gap between the village and Coventry - a far smaller separation.

No

Draft Local Plan Review

Representation ID: 1678

Received: 17/02/2017

Respondent: Dr Linda Parsons

Representation Summary:

There seems to be unequal loading on Knowle with clear intention of intrusion into Green Belt which is unacceptable.

Full text:

There seems to be unequal loading on Knowle with clear intention of intrusion into Green Belt which is unacceptable.