Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

UK Central Hub

Representation ID: 10918

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Arden Eco Park site has not been properly considered in the Local Plan process but its direct relationship with HS2 and Arden Cross should afford it as both a site for employment uses and for an Energy from Waste facility to serve the needs of Arden Cross and the rest of the UK Central strategic site in which the lies.

Change suggested by respondent:

Allocate the Arden Eco Park site for employment uses and an Energy from Waste site.

Full text:

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west.

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

Object

Solihull Local Plan (Draft Submission) 2020

Policy P3 Provision of Land for General Business and Premises

Representation ID: 10919

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Plan does not properly address the need for provision of land for Local employment uses in Balsall Common and Knowle.

Change suggested by respondent:

Allocate land for employment uses on Balsall Common and Knowle

Full text:

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.

Object

Solihull Local Plan (Draft Submission) 2020

Sustainable Economic Growth

Representation ID: 10921

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do. This would include employment uses as well as an Energy from Waste facility.

Change suggested by respondent:

The Arden Eco Park site should be allocated as a site for energy from waste and other related development as well as employment uses.

Full text:

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west. It lies in the UK Central Corridor.

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

The Arden Eco Park site should be allocated as a site for energy from waste and other related development.

Object

Solihull Local Plan (Draft Submission) 2020

Policy SO1 - East of Solihull

Representation ID: 10922

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site of !47 Lugtrout Lane is a free standing site with the broad allocation of SO1. The landowner is prepared to contribute her site to the larger housing site as long as she can develop the land with a few houses and can contribute to some open space provision. versions of the masterplan show her site included as a small development site but others do not show it. the matter needs clarification.

Change suggested by respondent:

Clearly indicate the site of 147 Lugtrout Lane as small housing site within the overall eventual masterplan

Full text:

The submitted master plans both with the Local Plan and from the Council on behalf of the landowners show conflicting designation of land at 147 Lugtrout Lane. Clarification is required .
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 and its inclusion as a site for some modest housing development. She is prepared to develop her land broadly in line with the masterplan subject to that being clarified 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.

Object

Solihull Local Plan (Draft Submission) 2020

UK Central Hub

Representation ID: 10924

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

No opportunity is given in the consultation for making comments about Arden Eco Park which is located within the UK Hub Central corridor

Arden Eco Park is a major land use site which was submitted as an employment site under the call for sites but that request was not properly dealt with by the Council.

The EcoPark is well related to the HS2 Interchange and well placed to serve the Arden Cross Development and the area as whole in terms of employment uses and for an Energy from Waste facility to supply power to Arden Cross.

Change suggested by respondent:

Designated the Arden Eco Park for employment uses and an Energy from Waste Facility.

Full text:

No provision on made for representations in respect of mineral or recycling sites. The site is most related tp UK Hub Central

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west. The site is located in the UK Central;Hub Corridor

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

The Arden Eco Park site should be allocated as a site for energy from waste and other related development.

RIGS Designation

The Local Plan refers to a Regionally Important Geological Site within the minerals working area. As we understand it RIGS are now called ‘Local Geological Sites’ and have a similar status to Local Wildlife Sites, i.e. non-statutory but protected through policy in Local Plans and as a material planning consideration in applications.

The designation for the Brickworks site still exists in the Submission version of the Local Plan and we believe that the citation for the former brickworks describes important exposures of the Triassic, Mercia Mudstone Group which are important for educational purposes. 'The strata consists of irregularly bedded red clay and mudstone, interbedded with green mudstone and green sandstone skerry horizons'.

While the quarry owners are prepared for students to observe the exposure subject to proper prior and safe arrangements, that exposure is not static and mineral working and subsequent landfill n that such exposure is continually on the move. While extraction is ongoing then presumably there will new exposures of these strata created periodically but the requirements of the minerals planning permission require the land to be back filled and returned to agriculture. As such that designation on the site should be removed from the Local Plan.


Object

Solihull Local Plan (Draft Submission) 2020

Policy BC3 - Kenilworth Road/Windmill Lane, Balsall Common

Representation ID: 13786

Received: 14/12/2020

Respondent: Richard Cobb Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection (Wants site BC3 removed from Solihull Draft Submission Local Plan and Final Local Plan): Fails 3/4 tests of soundness.
> Not positively prepared as it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units (Greenfield) and 1195 units (Meridian Gap) is not required to comply with planning policy. Furthermore, site BC3 specifically is not sustainable using the council’s own criteria.
> Allocation of site BC3 has not been justified. Omission of sites within Balsall common and in the wider Borough which should have been chosen based on merit or for which the omission has not been justified. Final findings from Solihull Town Centre Masterplan are not incorporated and cannot be reconciled with the Draft Local Plan.
>Inconsistencies with the NPPF, specifically para 1; 94; 108; 109; 122; 138; 185 and 194 are not complied with. Sustainable development will not be complied with if site BC3 remains in the Draft Local Plan.
>Wishes to preserve the biodiverse rich habitat that is Site BC3 and protect the character of the Grade II Listed Berkswell Windmill.

Full text:

Objection to Site BC3 - Fails 3 out 4 Tests of Soundness
I wish to formally object to Site BC3 Windmill Lane/Kenilworth Road and ask that it is removed from the Solihull Draft Submission Local Plan and Final Local Plan.
The Draft Submission Local Plan is not sound, in proposing the allocation of Site BC3 for housing, as it fails to comply with 3 of the 4 tests of Soundness:

1) Positively Prepared:

The plan has not been positively prepared in that it is not practical to deliver the unmet need of the HMA (2105 units). NPPF para. 11 has not been given due consideration. To build 4410 units on Green Belt Land (greenfield) and 1195 in the Meriden Gap is not required in order to comply with planning policy. Moreover, it is demonstrated that Site BC3 specifically is not sustainablusing the Council’s own criteria and could in whole or part be replaced with better sites around Balsall Common such as Site 82.
2) Justified:
The allocation of site BC3 has not been justified. There are omission sites both within Balsall Common and in the wider borough which either should have been allocated, based on merit, or for which the omission has not been justified. Moreover, the findings from the final version of the masterplan for Solihull Town Centre are not incorporated and cannot be reconciled with the Draft Local Plan.

3) Consistent with National Policy:
There are inconsistencies with the NPPF. Specifically paragraphs 11; 94; 108; 109; 122; 138; 185 and 194 are not complied with. As such, the enabling of sustainable development will not be delivered should Site BC3 remain in the Draft Local Plan.
I wish to protect the biodiverse rich habitat that is Site BC3 and I also wish to protect the setting and character of the Grade II * Listed Berkswell Windmill.

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