Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 10739

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

The Parish Council has submitted a detailed objection to the release of site BL2 from the Green Belt
for residential development and a school/nursery.
It is clear from the publication draft of the Local Plan that the objections have been dismissed by the
Council and, there is no new evidence that has been presented to justify the removal of land from
the Green Belt that the Council’s Green Belt Assessment 2016 rates as highly performing.
The land is rated as performing highly for the purpose of preventing towns and settlements from
merging into one another.
The Council rate the land for the purposes of its release from the Green Belt as moderately
performing despite the findings of the Green Belt Assessment 2016.
There is an existing and permanent Green Belt formed by Dog Kennel Lane. The Council propose to
bypass this existing feature and create a new boundary. It is suggested that an estate road would
fulfil this purpose.
Paragraph 139 indent F of the NPPF confirms that Green Belt boundaries should be defined by
recognisable features that are likely to be permanent.
The policy does not specifically state that a feature must be existing but, we are extremely
concerned that the creation of a boundary as proposed by the Council does not have the
permanence of the existing boundary and could be open to amendment and movement as time goes
by.
The release of the site from the Green Belt is not in accordance with national planning policy and 13
cannot therefore be justified.
The Council has not addressed the issues that have been previously raised concerning flood risk and
flood mitigation measures.
The evidence used by the Council acknowledges that there is a flood risk in the area but provides no
clarification of what type of mitigation will be used.
Policy BL2 uses the phrase that flood alleviation will be a likely requirement of development
proposals rather than it being essential.
There is a complete reliance on the planning application process to determine the type and extent of
any flood alleviation measures.
The land will have been released from the Green Belt by that point placing a presumption in favour
of development with no surety that appropriate flood mitigation will be provided.
The Parish Council has previously raised concerns over the traffic levels and congestion within the
area at the present time. The original objection includes details of the existing situation including
photographs of traffic congestion in the area.
Policy BL2 proposes up to 1000 homes and a school/nursery that will add to the existing traffic levels
in the area.
Yet, the Council has not produced a Transport Study for the site as has been done for development
in Knowle and Balsall Common.
The Council has not therefore provided justification that the development of the site will be
acceptable in traffic and infrastructure terms.
The site is also some distance from existing and emerging employment areas placing more emphasis
on the use of unsustainable transport options in conflict with policies P7 and P8 of the publication
draft Local Plan.
This also brings into question the distribution of development in the area which has been unfairly
stacked towards the Blythe area.
Policy BL2 and the 2020 Concept Master Plan for the site do not provide the required level of surety
that local heritage assets will be properly protected.
We have fully considered policy BL2 of the plan and the evidence used to support it.
The release of the land from the Green Belt for development is not justified and does not comply
with NPPF policy.
Policy BL2 is therefore not sound and we request that it is removed from the emerging Local Plan.

Object

Representation ID: 14888

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to Site BL2 on number of grounds (see reps):
Green Belt:
- GB boundary not comply with NPPF (Para. 139 f)
- Disagree that land in moderately performing area of Green Belt – 2016 GBA states in Appendix G that area in higher performing Green Belt land, especially in preventing settlements merging into one another.
- No justification in text for demotion
- Dog Kennel Lane is an established & permanent boundary feature providing distinct separation between built-up area and Green Belt.
- Updated evidence too vague.
- BL2 lacks permanent features required to define a Green Belt boundary, contrary to Para. 600 in Plan.
- Introduction of estate road as boundary feature (Para. 609) risks further development south of the road, and GB encroachment Proposed.
- Rest of landholdings could become target for further development.
- Gap to east of BL2 and Creynolds Lane at risk of infill in future.

Object

Representation ID: 14889

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to Site BL2 on number of grounds (see reps):
Flood Risk:
- Policy BL2 and updated evidence give no assurance that development will not worsen the current flooding situation for existing residents in Cheswick Green.
- Policy BL2 3 (ii) only refers to flood alleviation as ‘likely’ infrastructure requirement, and not properly considered flood risk evidence, which acknowledges flood risk exists and identifies there is a need to address flooding issues. - Should include solutions or recommendations in policy now to ensure that flooding issues will be addressed, beyond simply SUDs.
- Not satisfactory to rely on planning application process as principle of development will have been established then.

Object

Representation ID: 14890

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Please refer to attached statement. Policy is not in accordance with NPPF policy and is not based on clear and robust evidence.

Object

Representation ID: 14891

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to Site BL2 on number of grounds (see reps):
Traffic:
- CGPC previously raised concerns, and Reg 19 Plan not addressed concerns.
- CGPC have carried out their own survey and provided photos of local traffic congestion.
- 2020 Transportation evidence includes Transport Studies for Knowle and Balsall Common, but not for Site BL2.
- Insufficient evidence on transport issues to make informed decisions at this stage.

Object

Representation ID: 14892

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to Site BL2 on number of grounds (see reps):
Heritage and Landscape:
- Issue previously raised and not addressed.
- Updated evidence does not provide necessary clarity to assess how development could affect heritage assets and landscape within the area.
- Policy and Concept Masterplan both have a fall-back position that could allow development harmful to the heritage asset.
- Should be more certainty in the Plan.
- Site also includes an underground Nuclear Monitoring Station. Not listed as a heritage asset, but is an important relic from the cold war period. Structure is in poor condition and at risk of being lost (see photo).

Object

Representation ID: 14893

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Objection to distribution of development:
- Issue raised previously and not addressed.
- Disproportionate development in Blythe.
- BL2 is some distance from national infrastructure projects such as HS2, and regional employers such as JLR. Site relatively close to J4 of M42, but proximity to motorway and displacement from major employment areas are concerning.
- Will increase car journeys, traffic and congestion and be contrary to Policies P7 and P8.

Support

Representation ID: 14894

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Object to Site BL2 on number of grounds (see reps):
Location of School:
- Question justification of school within Site BL2 as traffic & congestion will be worsened by comings and goings associated with a primary school and nursery.
- Location at edge of site will also have a harmful impact on Green Belt purposes.
- No consideration has been given to possibility of locating school in non-Green Belt area, e.g. Blythe Valley Park.

Object

Representation ID: 14895

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Timing of Consultation:
Council should have held back plan til more certainty in planning system, as Bromsgrove have done.

Object

Representation ID: 14896

Received: 10/12/2020

Respondent: Cheswick Green Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Accessibility of consultation:
- Not accessible to residents unaccustomed to online services or without internet access.