Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13966

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Climate Change Agenda
- Welcome that Solihull MBC has declared a climate emergency on 8th October 2019, and committed its support for UK’s 100 Net Zero Local Leadership Club.
- Since Climate Change declaration, how many planning applications have been passed which do not show enough ambition? Conditions should be used to enable more progress across Borough on climate change action.
- Numerous statements in plan on reducing and minimising carbon emissions, however huge growth planned will increase emissions significantly.
- Many of the infrastructure projects will use huge amount of concrete. How are these emissions assigned within Borough’s plans and climate objectives?
- What are climate implications of airport operations?
- How does local plan fit with Climate Emergency Statement of Intent of 19th October 2019?
- NPPF could and should go further in addressing climate change.
- Has SMBC considered adopting the UN Sustainable Development goals as part of its local plan?

Object

Representation ID: 13967

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Pattern and locations of development:
- Danger the plan is out of date before it is examined, due to impact of Covid-19 on planning.
- Primary aim should be urban regeneration and conversion of shopping centres for housing. Many car-dependent shopping venues in Borough should be surplus to requirement. Could make way for high quality housing, which is low/positive carbon.
- Standard methodology algorithm may change to encourage town centre development, see Robert Jenrick announcement on 16th November 2020.
- Para. 63 – challenge statement that there are extremely limited options for land in urban area.
- Options E-G – Not homogeneous options. Need to travel and car reliance are likely to be higher, even taking account of rail provision. Seems significant reliance on housing development at edge of settlements. Additional capacity could be identified in urban area and mitigate the need for these sites. Could increase density, especially at UK Central.
- Also need to consider location of UK2, access and impact on traffic growth and CO2 emissions.

Object

Representation ID: 13968

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Need additional work to test justification level of housing. - - Potential town centre regeneration in Solihull, given Covid-19 impacts on retail patterns, could provide additional housing capacity, as well as windfalls, densification and other supply sources.

Support

Representation ID: 13969

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Plan includes positive policies in relation to sustainable transport, as well as emphasis on Rapid Transit & Metro in P8A.

Object

Representation ID: 13970

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

- Despite positive policies in relation to sustainable transport, it is likely that development will result in huge increases in car usage and undermine positive transport policies.
- Para. 282 - Challenge need for bypasses and likely traffic impacts of proposed housing sites.

Object

Representation ID: 13971

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concept Masterplans:
- Concept Masterplans appear largely to have been provided by developers. Some, particularly those in less accessible location, designed on traditional cul-de-sac, car orientated basis.
- Design features should embed sustainable travel and favour reduction in CO2 emissions. Needs to be in individual [site] policies, especially if Planning White Paper proposals are carried forward, which will reduce opportunities for input post Plan adoption.
- Limited services on edge of settlements. Will new services be provided on sites?

Object

Representation ID: 13972

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P9
- P9 is largely about how things are built. Development patterns need to also be addressed as they have significant impacts on climate change, especially if not covered by other policies in the Plan or in the SA.
- Energy policies should show real ambition. Large number of roof spaces across the borough could be used for solar power electricity and hot water generation. These should be considered in policy.
- Green Belt may limit opportunities for certain forms of renewable energy production, yet many places being sacrificed to meet growth.
- Risk that housing developments not benefit from district heating policy.
- Policy should introduce stronger monitoring measures, i.e. reduce emissions from a level at a certain time, monitor and then reduce again.
- UK Government committed to reduce greenhouse gas emissions by at least 68% compared to 1990 levels by 2030. Will plan achieve Solihull’s contribution to UK target?
- As such plan is unsound.

Object

Representation ID: 13973

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy has some commitment to move up the waste hierarchy.
Should include policies on biogenic waste, use of anaerobic digestion and new sources of energy generation. Will biogenic resources arising in Borough be treated by composting or AD? Modular treatment should be used to reduce capacity over time. Use of waste energy facility in Coventry conflicts with proximity principle in Para. 350. Plan not mention separate food waste collection from 2023 – this will require local treatment facilities within the Borough.

Object

Representation ID: 13974

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Could principles be applied to alterations and redevelopment?

Support

Representation ID: 15170

Received: 12/12/2020

Respondent: Friends of the Earth (Cities for People)

Plan includes positive policies in relation to sustainable transport, as well as emphasis on Rapid Transit & Metro in P8A.