Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 11084

Received: 15/12/2020

Respondent: Warwickshire Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy BC3 - Kenilworth Road/Windmill Lane, Balsall Common section of the plan states that
‘558. Whilst 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, much of the adverse effects relating to ecology, landscape, green infrastructure, historic assets and amenity can be mitigated with the more modest capacity now proposed’.

There is no detailed information or assessment of how this impact could be mitigated in the section of the plan. The policy proposes ‘creation of a significant corridor of public open space between the
development and the Relief Road. However public open space would most likely not provide suitable land for ecology and flora and fauna to thrive.

There is concern that the analysis in the Sustainability appraisal has not informed the plan making. As negative results have been discarded and sites seem to have been allocated without exploring alternative sites with less of an environmental assessment in detail.

Object

Representation ID: 11085

Received: 15/12/2020

Respondent: Warwickshire Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Concerns that the Sustainability Appraisal has not been taken into account:
Policy HA1 - Meriden Road, Hampton in Arden justification states Para 643’ Whilst the site performs relatively poorly in the sustainability appraisal’. Again ignoring the results of the detailed SA work.

Object

Representation ID: 11086

Received: 15/12/2020

Respondent: Warwickshire Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Proposals Map -
We would also request that Nature Reserves and Potential Local Wildlife Sites are included on the proposals map.

Object

Representation ID: 11087

Received: 15/12/2020

Respondent: Warwickshire Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Warwickshire Wildlife Trust supports the work that has been into the plan up until this stage but has a number of remaining concerns.
Overall WWT support the identification of LWS’s on the proposals map, however are extremely concerned about number of site allocations which are designated Local Wildlife Sites, near to ancient woodland and in the green belt. It is considered that these site allocations are not in line with the test of soundness. Reference is made to Sites BC1, BL1, BVP, BBP, KN1, KN2, SO1, UK2.
Concerned whether the SA, particularly environmental issues, has fully informed site selection and allocation, in particular Sites BC3 and HA1.
Modifications proposed for Policy P10.
Submission refers to Para. 174 of the NPPF, Section 40 of the NERC Act and Defra's 25-year Environment Plan.