Solihull Local Plan (Draft Submission) 2020
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Solihull Local Plan (Draft Submission) 2020
Policy BC1 - Barratt's Farm, Balsall Common
Representation ID: 11113
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Allocation of BC1 Barratt's Farm is contrary to the vision in the Plan to protect the Meriden Gap and evidence in the Strategic Growth Study (SGS) highlighting it's Principle Contribution to Green Belt Purposes. Justifying it's release on the basis of the Green Belt Assessment and SHELAA is inappropriate. The former is not fit for purpose, requires more detailed assessment and does not determine whether land should be released. The latter assessment is suspect, partly due to changes since 2016, as proposal requires a relief road, land is in use for agriculture, a high pressure oil pipeline is present, and adjoining rail and relief road constitute bad neighbour uses. Alternative options not involving land making a Principle Contribution have not been investigated including SGS South of Birmingham. Contrary to the spatial strategy focusing development where needs arise and reliance on private car is low. Contrary to national guidance emphasising the use of brownfield land and protection of Green Belt. No obvious suggestion of required Green Belt compensation. Fails to take account of development proposed in Meriden Gap within Coventry
Policy BC1 and its associated Concept Masterplan should be removed. Alternatively, timing of the delivery period in paragraph 226 should be delayed to phase iii, and the land safeguarded as per NPPF paragraph 139c and d, to allow the full impact on the Green Belt land in the Meriden Gap to be understood before it is destroyed forever. If future events reduce the housing demand the site will be returned to full Green Belt protection.
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Policy BC4 - Pheasant Oak Farm, Balsall Common
Representation ID: 11116
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
There is a serious discrepancy in the definition of the Green Belt boundary south of Waste Lane. Specifically, paragraph 537 says “The boundary will be drawn close to the eastern edge of site BC4 before following the line of Windmill Lane to the southern point of site BC3 where it then cuts across to Kenilworth Road”.
Concept Masterplan BC4 states “The alignment of the bypass will provide the new green belt boundary to the east of the site” which could then release significant areas of land south of Hob Lane down to the A452 at Mere End. The Concept Master Plan BC4 should be corrected.
Concept Master Plan BC4 2nd paragraph to be amended to read “The boundary will be drawn from the eastern edge of site BC1 along Old Waste Lane to the junction with Waste Lane and then close to the eastern edge of site BC4 before following the line of Windmill Lane to the southern point of site BC3 where it then cuts across to Kenilworth Road”.
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Balsall Common
Representation ID: 11119
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The Statement of Common Ground should be published to allow public scrutiny before the plan goes to the Secretary of State. Changing the Green Belt boundaries is contrary to NPPF in the absence of a SOCG showing that SMBC has discussed the potential for some of its need to be accommodated outside the Green Belt elsewhere. The Plan fails to take account of housing and industrial land proposals in Coventry close to the boundary with Solihull. The need for the Balsall Common Relief Road should be reassessed in context of the A46 A45 link road in Coventry.
Reference Solihull MBC Local Plan – publication stage. Guidance Note to Accompany Model Representation Form – Legal Compliance and Duty to Cooperate – paragraph 2.3.
“Non-compliance with the duty to cooperate cannot be rectified after the submission of the plan”.
The plan should not be submitted to the Secretary of State until the SoCG has been negotiated, published and the public have had an opportunity to scrutinize it with a 6 week consultation period.
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Balsall Common
Representation ID: 11123
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Balsall Common suffers a severe lack of public open space equating to 2.5ha/1000 compared to a Borough average of 5ha/1000. The Plan presents an opportunity to address this deficiency, but the additional 13ha for 4,000 population will worsen it contrary to Policy P20. Despite a commitment to acquire land for sports hubs across the Borough, there is no specific allocation for Balsall Common. The Plan fails to comply with the Berkswell NDP Policy B1 requiring pos between existing and new housing for allocation BC1. The BFNAG proposal for a Central Park is not incorporated at the southern end.
Policy BC1 2 ix to read:
Provision of sufficient public open space around water courses, heritage assets and ecologically sensitive areas to bring the average POS ha/1000 head of population for the site up to the average for the rest of Solihull Borough.
Policy BC1 3 ix to read:
Provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and SMBC Cabinet meeting 13/08/2020 agenda item 3.5 and 3.6; and resolution 5. Land acquisition on Site BC1 to be funded according to Cabinet meeting 13/08/2020 resolution 5 i, ii, iii.
Concept Master Plan Principles for BC1 to include the sentence:
POS to provide a buffer to the south of the development between the new and existing properties providing an opportunity for a public park and for the integration of the future and existing residents.
The Concept Master Plan for site BC1 should be amended so that the 4 areas designated as low density housing between the footpath running SE from Barratt’s Lane and the houses on Meeting House Lane/Kelsey Lane are designated as POS.
The medium density housing area immediately to the NE of Old Waste Lane should be shortened so that there is POS to the rear of the existing properties (see attachment).
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Balsall Common
Representation ID: 11124
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Development at Balsall Common will have a huge impact and demands a total rethink of the infrastructure of the village. Paragraph 528 of the plan pays lip-service to this for the Balsall Common village centre and does not comply with Policy P21. The LPR has been underway for 4 years and residents have a right to something more substantial.
Balsall Common medical centre services are being reduced and centralised in places difficult to access by public transport, despite the significant increase in population proposed and contrary to Policy P18.
The new primary school proposed for Barratt's Farm needs to be provided earlier in the Plan period.
Policy BC1 3 to read
“Infrastructure requirements will include:” (Ie remove “Likely”)
i. Provision of a new 2 form primary school and nursery before any major house building takes place.
iii. A thorough evaluation of the impact and sustainability of the development on all health care services carried out by SMBC and the CCG. Developer and Solihull MBC contributions to…..CCG.
x. A detailed master plan for the enhanced village centre, published and funded, and agreed by the Borough Council, Balsall and Berkswell Parish Councils, Village resident’s association and local action groups; before any development is begun.
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Balsall Common
Representation ID: 11125
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The Plan proposes a Balsall Common Relief Road although the evidence concentrates on the section from Waste Lane to Meer End, ignoring the effect on Hall Meadow Road and the existing estates and medical centre or through BC1 which is unsound. There is no evidence that pollution, congestion and safety assessments have been undertaken. Whilst phased early to provide for HS2 traffic, Barratt's Farm will be phased later or after HS2 which will invalidate proposal. There is considerable uncertainty over the funding of the waste Lane to Meer End section. Reasonable alternative routes west of Balsall Common have not been investigated.
If the transport survey proves that the full bypass from Mere End to the Hall Meadow Road junction with the A452 will not cause serious congestion, pollution and safety problems, then:
Policy BC1 3 vi to read
“Provision of the Balsall Common bypass between Station Road and Mere End as the first phase of the development.”
If the transport survey raises congestion, pollution and safety issues, then Policy BC1 3 vi to read
“The Site BC1 estate feeder Road between Station Road and Waste Lane to be designed to ensure it is not possible to use it as a “rat run” to bypass the village centre.
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Balsall Common
Representation ID: 11175
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
The timetable for HS2 works in paragraph 525 is inconsistent with paragraph 280 and needs correcting. Given the later opening date of 2020-33, how practical is delivery of Site BC1 within the Plan period? Need assurance that no significant development on Barratt's Farm will take place until all HS2 construction throughout Balsall Common is complete. HS2 construction will also impact sites BC4, BC5, and BC6 and their phasing should allow for this.
Paragraph 525 to read “…..with the main works due for completion during the period 2029-2033 ready for the line to open at some later date still to be confirmed.”
Policy BC1 2 vi changed from “Housing shall be phased to avoid coinciding with construction of the HS2 rail line in this vicinity” to “No housing development to be started in site BC1 until all construction work on the HS2 rail line affecting this location is completed”.
Policies BC4, BC5, and BC6 should have similar amendments
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Policy BC1 - Barratt's Farm, Balsall Common
Representation ID: 11192
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Policy BC1 fails to address the climate emergency or Challenge A, the huge loss of fields is not compensated for and it is not clear how the requirement for biodiversity net gain can be met. The policy should include public open space between new and existing housing and a wildlife corridor along the western edge to link Lavender Hall Park and open countryside to the south-east. It should also address the WMCA requirement to plant one tree per resident, or 11,500 trees for Balsall Common requiring 10ha of land, Barratt's Farm provides the best opportunity and planting could screen HS2.
The following to be added to Policy BC1 4 i:-
after.… woodland copse planting. “This to provide a minimum 10% net gain in biodiversity and habitat creation; and space for tree planting to meet the requirements of paragraph 38 challenge K; and replacement of trees and habitat lost to HS2.”
“A wildlife corridor at least 6.5m wide to be created to run all the way along the western edge of the Barratt’s Farm site to connect and act as a “stepping stone” between Lavender hall Park in the north and what remains of the open countryside to the south and east.”
See Attachment
Object
Solihull Local Plan (Draft Submission) 2020
Policy P15 Securing Design Quality
Representation ID: 14790
Received: 09/12/2020
Respondent: BFNAG
Number of people: 120
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Carefully controlled phasing of the construction on large allocations is essential to ensure that the concepts of the masterplan are not lost and haphazard piecemeal uncoordinated construction is avoided.
Concept Master Plans are for most residents the most important section in the plan. It is vital that once the plan is made, the concept master plans are adhered to and not amended to suit developer convenience or profit opportunity. No change to concept master plans should allowed without specific agreement from the borough council, relevant parish council or neighbourhood forum, and established neighbourhood action groups.
A policy should be inserted in the plan to explicitly enforce this.
Policy P15: New point 10
"Concept Master Plans as included in Local Development Plan must be adhered to in spirit and in detail throughout development unless changes are specifically agreed by the borough council, relevant parish council/neighbourhood forum, residents’ associations and established neighbourhood action groups."
See Attachment
