Full text:
I write to you as a Solihull resident for 66 years, a qualified architect for 47 years, who's first residential commission was a 5 bedroom detached house in Hampton in Arden designed in 1967. I have been a principal in private practice specializing in residential projects from 1 to 520 houses for 45 years, and having operated from offices in Balsall Common for over 12 years, feel that I understand the village and have added to it's variety of housing stock over the years, and continue to do so.
I do appreciate that the decisions that need to be made when preparing Local Plans are not easy, and that you have prepared robust arguments for the cases that I have looked at, however, I do feel strongly that the emphasis on spreading Balsall Common still further to the South East has too many issues to be suitable. I also feel that the easy option of involving the fewest sites to make up the numbers does not meet with the NPPF guidance on the expected mix and variety of sites is not met in your latest proposals, so draw your attention to three smaller sites with which I have been involved, and know that they are currently still available, suitable, likely to be viable and be brought forward for development within the first 5 years of your Plan without unnecessary delay. This is despite the original owner of Rose Bank, giving it's name to Site Reference 422, having sold and the new Owner, Mr Goodfellow, agreeing to join with the Owners of the other properties to put the land forward for consideration.
In the Supplementary Consideration documents this appears to be the only site considered in the Commentary as 'may be suitable for consideration as a windfall site' that was not classified as Amber in the Site Selection Step 2.
Policy BC3 – Kenilworth Road/Windmill Lane, Balsall Common.
1. The latest version of the Council's Local Plan appears to cover most topics sufficiently well, with
the exception of allocating so much of the housing land proposed in Balsall Common to site BC3
2. In his foreword Councillor Courts referred in item 3 to the need to release Green Belt land, albeit
reluctantly, due to a shortage of suitable brown field sites.“However, we have looked to minimise
this and in doing so ensured the continued integrity of the significant Green Belt that remains”.
3. The centre of the village, already well to the North of the area within the development boundary,
would be further from this proposed site which extends down down to the Windmill Lane,
Kenilworth Road junction to the South East.
4. The suggestion that the southern portion of BC3 should accommodate some open space for
development is insufficient, and the dwellings intended here should be provided elsewhere.
5. There are better locations to the South West, West, and North West, balancing the sites proposed
to the East, and within similar distances from the centre of the village.
6. Although Coventry City Council have approved around 2,400 new homes at Eastern Green, and
infilling open space directly between the centres of Solihull and Coventry, affecting the heart of
the Meriden Gap, this is not a good example to follow.
Justification for Promotion of Policy BC3
7. Despite the reduction in numbers following the Draft Local Plan and Supplementary Consultation
indicating that the 200 dwellings originally intended would have a significant adverse impact on
the ecological quality of the site and the setting of the adjacent very important Heritage Asset (in
the form of Grade 2* Listed Berkswell Windmill) the reduced number at 120 dwellings is still
too many in a poor location (see Para 555).
8. Believed to be the oldest Georgian Windmill in existence, it's relatively remote setting has
already been eroded too far by the expansion of Balsall Common towards the Windmill.
9. The SLP Inspector may well have concluded that “the area was not so remote that it would
justify the omission of the two sites in this parcel....” as it now extends no further South than the
existing housing (Para 556), but that housing is also too far from the “key economic assets” .
10. The argument in Para 557 that the area is a poorer portion of the Green Belt partly due to “the
development and encroachment that has already taken place in the parcel” is no reason to make
a poor situation even worse. The remaining land is clearly of significant ecological value and
this provides a further reason why it should therefore remain undeveloped.
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11. The admission is then made that “the site does not perform well in the Sustainability Appraisal,
with twice as many negative effects as positive, including one significant negative effect due to
the distance to the key economic assets...” (Para 558).
12. Since the sustainability and Green Belt issues do not appear to comply with the NPPF, the
question of the setting of the extremely rare Grade 2* Listed Building adjacent to the site and
the extent of any mitigation for this and the local ecology need not have been further researched.
It is difficult to understand the reasons why the site has been retained in the Local Plan at all.
Alternative Sites
13. With the Government's intention of increasing both housing numbers and speed of delivery,
there are several other sites that have been put forward that between them could more than
satisfy both of these objectives. The better mix of parcel size and locations, to the North West
and West of the village centre, coming forward where it is needed and capable of development
without unnecessary delay would comply with Para 59 of the NPPF.
14. If the Council did reconsider the following sites which would offer an alternative location to
retain a sufficient supply and mix, taking into account their availability, suitability, and likely
viability NPPF Para 67, they should also prove more capable of early delivery than the larger
sites which often take far longer to complete. This would inevitably help with the 5 year supply
of deliverable sites, a major issue set out in Para 74 of the NPPF and one which trips up many
Local Authorities when their Local Plans are tested in practice.
Site 82 Land at the rear of 152 to 172 Kenilworth Road, (including 166 and 170).
This site is capable of taking up to 70 dwellings.
Site 421 Silver Tees Farm, Balsall Street.
This site could take up to 16 dwellings.
Site 422 Rose Bank Balsall Street.
This site could take up to 25 dwellings.
There are several other similar sites that may be similarly available to make up the shortfall.
