Solihull Local Plan (Draft Submission) 2020

Provision of employment land should be made in Knowle and Balsall Common, sites should be allocated in the urban area for expanding religious, social and cultural facilities, and Country Park should be allocated on land around the Berkswell Windmill and around the fringe of Solihull Town Centre at the Berry Hall estate or Council and at Widney Manor Road.

The Local Plan has been prepared without consideration of the wider needs of the community in terms of appropriate allocation of land for sustainable employment provision closer to growth communities, provision of adequate land in appropriate locations for religious, cultural and social facilities, adequate positive protection for significant listed buildings and provision of country parks to redress the balance of loss of Green Belt land for housing and employment.

Removing either all or sensitive parts of BC3 need not mean that the overall proposed allocation of housing in Balsall Common cannot be fulfilled. In the submissions made in response to the Council’s Call for sites many landowners responded and many of those sites are far better placed in relation to the village centre and closer to services than site BC3, so far more sustainable. The site assessment for many of these sites is better or equivalent to the assessment for BC3, The council have not properly considered those sites in terms of sustainability and/or impact on the Green Belt
Amongst those sites are
Site 82 – Land at Kenilworth Road capable to taking around 70 dwellings
Site 422 – Land at Rose Bank Balsall Street capable of taking 20 dwellings
Sile 421 – Land at Silver Tree Farm Balsall Street capable of taking 20 dwellings
Site 1 – Land at Springhill 433 Station Road, Balsall Common - 20 dwellings
Site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road – 40 dwellings

The proposed allocation of land at Kenilworth Road/Windmill Lane is not sound, positively prepared or sustainable and fails to accord with NPPF policies. The allocation appears to be based solely on the fact that the site is being promoted by a large volume house builder rather than any spatial logic. The allocation adds further unjustified pressure on the vital strategically important Meriden Gap.
While there a case could be made for the northern part of the site for around half the number of units to be released proposals for the extension of that for further housing into the southern part of the rest of the site into more open countryside is totally unjustified. While some parts of that southern section are suggested for public open space that is insufficient as a buffer of open land around the windmill which should become a much-needed country park.
The master plan proposals fundamentally disregard the impact on the proper setting of historic Berkswell Windmill and moreover it would extend housing development around the village of Balsall Common much further south away from village services and facilities, when there are better and more sustainable sites closer to the village centre which could and should be released. A number of those omission sites have been discounted on questionable grounds
The northern part of the proposed allocation site could be justified as integrating into existing recent residential development fronting Kenilworth Road and backing onto property in Kelsey Lane as well as linking through to the proposed allocation site BC4 at Pheasant Oak Farm which is also proposed to take 200 homes.
Green Belt
Balsall Common is destined to take a significant amount of new housing on 6 identified new sites all within the Green Belt which taken together would add more than 1600 dwellings in addition to land at Riddings Hill. There is already a narrow gap between the village and Coventry within the Meriden Gap and recently Coventry City Council have approved some 2400 new houses at Eastern Green so narrowing the gap even further.
Sustainability
The location of BC3 is remote from the main facilities in the village, and while anew primary school is proposed on BC1 Barretts Farm, access to other services in the village would require use of a car from much of BC3, adding to congestion in and around the village centre. As an unsustainable location the allocation of all of BC3 for housing cannot be justified under the NPPF.


Setting of Berkswell Windmill
The Concept masterplan has removed some originally proposed housing development at the southern end of the BC3 site but still leaves a southern tongue of land between existing housing development on Kenilworth Road frontage and some identified ecologically important area fronting Windmill Lane.
Leaving that tongue of potential development without strengthening the protection of ecological site would mean that further development pressures would arise in the future. The southern tongue of development land should be deleted from BC3. That way the full visual protection of the setting of the windmill will be properly protected and a country park developed as part of a proper comprehensive plan including closure of Windmill Lane at its southern end. The latter action will greatly mitigate the current noise and disturbance impact on the setting of the windmill from volumes of traffic using Windmill Lane as a short cut.
Ecological Assessment
Much of BC3 has been shown by a recent study by Warwickshire Wildlife to be an area of ecological value and as such it is questionable that the site be used for development. The area is characteristic of Arden Landscape and there is little information as to how biodiversity offset provision is going to be made. Significantly reducing the extent of proposed development would allow proper provision to be made on the site.

Greater clarity needs to be given as to how the objectors can secure some reasonable low density residential development of their land along with some open green space.

Mr and Mrs Hughes have owned Stoney Croft since 1986. They are not part of the landowner group who have are pursuing their case for the release of the bulk of the land at Trevallion Stud as a housing allocation in the Local Plan. However I have sought to find out what would be expected of Mr and Mrs Hughes if they were to join the landowner group but we have had no meaningful response.
Stoney Croft was omitted as part of the proposed release in the previous masterplan published in January 2019, but in the latest masterplan published as part of this present Regulation 19 consultation, Stoney Croft has now been included within the red line for a proposed omission from the Green Belt and release for development.
Mr and Mrs Hughes are grateful for this rectification as Wootton Green Lane is a firm and defensible Green Belt boundary and it is right and proper that their land is to be included with the rest of Trevallion Stud.
Mr and Mrs Hughes have no immediate plans to sell their property and move elsewhere, but they are very concerned that without any prior consultation their property has now been proposed for designation by the Council as public open space in the latest concept masterplan.
The concept masterplan notes that based on 230 homes for Trevallion Stud, 1.8 ha of public open space will need to be provided. The POS - which is assumed to be some of that taking in much of Mr and Mrs Hughes land - provides a buffer to the south of the development between the new and existing development providing opportunity for place-making and for the integration of the future and existing residents.
The masterplan notes that “doorstep” space – whatever that means - will need to be provided on site. A local play space and neighbourhood play area will need to be provided in the locality the mechanism for its delivery can be considered at the application stage alongside other development brought forward in Balsall Common in the adopted Local Plan.
As there have been no discussions with them, Mr and Mrs Hughes are not clear as to what the implications are for their property or what arrangements the Council are making to compensate them for the loss of development value of at least part of their property, how the land is likely to be taken over to become POS, and if Mr and Mrs Hughes are likely to be responsible for any work to landscape and maintain the land as POS.
As such in the absence of any approach from the Council, Mr and Mrs Hughes wish to raise concerns about the implication of the concept master plan is for their property.

Site should be allocated for employment uses not residential

Land is unconnected from main part of Balsall Common,
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.

In Balsall Common sites one or more of the fiollowing sites should be allocated for employment purposes. s
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

While it is clearly important in the Local Plan to address the issue of providing sufficient land for housing over the plan period, it is apparent that less serious attention has been given to the provision of new land for employment purposes.
The allocation of Site UK2 on land at Damson Parkway in the Policies Map, is to be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant. That land has also been earmarked for the relocation of the existing public Civic Amenity Recycling site presently sited at Arden Eco Park
Arden Cross is being promoted as providing for housing as well as other uses including such as research and development and advanced manufacturing as part of an innovation district for employment and higher education.
The Council has readily diluted the original business allocation of Blythe Valley Park and other business parks with significant residential development.
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.
In Balsall Common sites such as
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Balsall Common allocate sites for employment purposes on one or more af the following sites
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Knowle an area within the Arden Triangle a suitable site should be allocated for employment uses.

While it is clearly important in the Local Plan to address the issue of providing sufficient land for housing over the plan period, it is apparent that less serious attention has been given to the provision of new land for employment purposes.
The allocation of Site UK2 on land at Damson Parkway in the Policies Map, is to be released from the Green Belt to accommodate employment development, including that required for JLR operational needs or to enable JLR component suppliers, needed to directly support JLR operational needs, to be located close to the plant. That land has also been earmarked for the relocation of the existing public Civic Amenity Recycling site presently sited at Arden Eco Park
Arden Cross is being promoted as providing for housing as well as other uses including such as research and development and advanced manufacturing as part of an innovation district for employment and higher education.
The Council has readily diluted the original business allocation of Blythe Valley Park and other business parks with significant residential development.
While much of that is to be welcomed in the two main areas of residential growth – Knowle and Balsall Common – no provision has been made of land for employment purposes to help to create a balanced community rather than commuter villages where the population has to travel usually by car to employment opportunities elsewhere. In both those communities’ provision should be made in the Local Plan for a modest amount of employment land.
In Balsall Common sites such as
• Lavender Hall Farm site BC6
• Call for Sites site 1 – Springhill, 443 Station Road, Balsall Common
• Call for Sites site 43 – Land adjacent to Old Lodge Farm, Kenilworth Road

In Knowle an area within the Arden Triangle a suitable site should be allocated for employment uses.

Each allocation should include a specific requirement for the developer to allocate land for those purposes and to facilitate those that wish to build houses that way.

While there is cleraly a need to make provision for self and custom build most housing allocations will be taken up by volume house builders. There is no mechanism put forward to explain how the Council will definitely ensure that appropriate parts of those sites will be specifically allocated for this purpose. Realistically volume house builders will earnestly resist having to provide sites for self or custom building.

The Council should identify more small sites to cater for small builders who otherside cannot secure sufficient land to carry them forward.

Paragraph 68 of the NPPF sets out that small and medium sized sites can make an important contribution to meeting thehousing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant planpolicies, that there are strong reasons why this 10% target cannot be achieved.

Council should include more small and meduim sites for local house builders many of which were submitted for consideration at Call for Sites stage and have been summarily discounted in favour of large sites for volume housbuilders. Each has their place and more small and medium sites should be allocated.

Paragraph 68 of the NPPF sets out that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant planpolicies, that there are strong reasons why this 10% target cannot be achieved

As you may be aware, I represent Mrs Mavis Ferguson of 147 Lugtrout Lane which is on the north side of Lugtrout Lane. Mrs Ferguson is unwilling to enter into any MOU with landowners on the south side of Lugtrout Lane.
We are in regular contact with representatives of other landowners on the north side of Lugtrout Lane about separate arrangements with those landowners. Mrs Ferguson is a free-standing landowner and supports the allocation of Site SO1 and removal of her property from the Green Belt. She is prepared to develop her land broadly in line with the latest version of the masterplan and will cooperate so long as she is able to do so with other landowners on that side of Lugtrout Lane.
We have already provided a site survey and possible layout of No 147 Lugtrout Lane to accommodate around 5 dwelling units which has been incorporated into the masterplan when last seen, and we will contribute land to the linear open space at the rear of the site if required to do so.
We will also seek to come into line with any overall drainage strategy as long as Mrs Ferguson can achieve a modest development on her land which we believe we have shown that we can. As we have a frontage to Lugtrout Lane and other services are available, we do not consider that there is need for any equalisation at this present time.