Solihull Local Plan (Draft Submission) 2020

Support

Representation ID: 11245

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Allocation SO1 is supported. All landowners and their representatives have agreed a masterplan for the allocation. Technical reports have been undertaken with issues and constraints identified and addressed in the masterplan. There is agreement in principle to have a memorandum of understanding.

The site is available, achievable and could deliver a higher number of dwellings than the proposed allocation (more than 700 dwellings). Land north of Lugtrout can be brought forward at an early stage, with no major infrastructure requirements. The site is in a sustainable location, close to local services and facilities.

Object

Representation ID: 14323

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is no certainty over the provision of either HS2 and the Balsall Common bypass in terms of construction or completion dates. The master plan advises the bypass is a requirement there is no evidence in relation to viability, or that it can be delivered by the quantum of development proposed. This raises doubts over the certainty of a firm eastern Green Belt boundary to the site, without HS2 or the bypass, it would result in an indefensible Green Belt Boundary, which is particularly relevant as the site is highly performing Green Belt.

The Plan does not make clear whether the HS2 or West Coast Mainline will become the Green Belt Boundary.

Object

Representation ID: 14324

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The site is of multiple ownership and has complex land assembly
As noted in the Council’s most recent site assessment document (October 2020), the site: is part of high performing Green Belt, would result in an indefensible Green Belt boundary to the east, has a low level of accessibility, and could be considered subject to provision of clear firm Green Belt boundaries. The DSP states “Development should preferably be on land that is more highly accessible, and/or performs least well in Green Belt terms and/or provides strong defensible boundaries”. These factors weigh heavily against the site as a draft allocation.

BC4 is reliant on the building of the bypass, which appears to have no policy or proposal of this section of the bypass adjacent to BC4. It must be assumed this section would not to be built within the Plan period up to 2036 and there is no certainty over its provision at any stage.
There is no consistency between the DSP and the SLP Concept Masterplans over the precise location of the Revised Green Belt boundary in relation to BC4. The DSP proposes the eastern boundary of the site (paragraph 560) as the defensible boundary, whilst the Masterplan proposes the alignment of the bypass (page 32).

Object

Representation ID: 14325

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The site is of multiple ownership and has complex land assembly
Firm and defensible Green Belt boundaries would only be created when considered in a comprehensive manner, which cannot be assured.
The site is also identified as having high visual sensitivity in the Landscape Character Assessment
The site extends significantly out into open Green Belt, impacting considerably on the openness of the Green Belt. This is contrary to one of the five purposes of the Green Belt, to safeguard from encroachment

Object

Representation ID: 14326

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The site is a later addition to the housing allocations, and it is not clear why the site was considered suitable for allocation.
The site is detached from the settlement, having no contextual link/setting to suggest that the site makes sensible addition to the village, which sets a inappropriate precedent for future development.
The site lies within the highest performing Green Belt Parcel and the Landscape Character Assessment identifies that the site has medium visual sensitivity. The allocation contradicts the Councils own assessment criteria, which states that development should preferably be on highly accessible land/performs well in Green Belt terms/provides defensible boundaries.
The site would be unsuitable for residential development given its position between the West Coast Mainline and possible HS2 line, resulting in an environment with noise, vibration and visual sensitivity.
The site would lie outside the defensible Green Belt boundary (West Coast Mainline), contrary to the principles of Policy BC1 Barrett’s Farm, which notes the need for strong defensible boundaries within Balsall Common.
It makes no logical sense to identify a defensible Green Belt boundary to mark the eastern most boundary of Balsall Common and then breach that boundary in endeavouring to justify allocating a further site (BC6) and create a weaker Green Belt boundary around that site.

Object

Representation ID: 14333

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SLP Site19 Riddings Hill/Hallmeadow Road:

The site was allocated in the adopted Local Plan 2013 and as far as it can be ascertained, there has been no movement on bringing the site forward for development and as such raises doubts over its future delivery and within the proposed Plan period. It has not been demonstrated that this site is available, achievable and deliverable. Its continued inclusion as an allocation in the DSP is unsound.

Object

Representation ID: 14335

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Development here would result in the coalescence of Dickens Heath with Whitlocks End and Majors Green.
The intrinsic character of the village would be lost through an illthought out addition to the west of the village, having no relationship with the original concept or masterplan. This is an insensitive treatment for an award winning settlement.

BL1 has previously been dismissed as an allocation at a number of Public Local Inquiries over many years since the Solihull Local Plan has been reviewed. Former site 13 (Solihull Draft Local Plan 2016, which included Three Maypoles Farm) was deallocated as it was deemed too important to keep a gap between any urban extension and Dickens Heath. The impact of BL1 would be considerably more devastating and the perceived coalescence with Dickens Heath, Whitlocks End and Majors Green would be the result.
To attempt to overcome issues of coalescence, master planning has continually reduced the development areas but the latest reduction in developable area has not reduced the site capacity. Irrespective of what the Site Assessment commentary suggests, the perception of coalescence remains.
Relocation of sports pitches on the site have not been identified, local or otherwise. The 3 football pitches on the site have not been relocated due to impact on LWS. This situation has not been addressed at any point in the Local Plan Review process and should have been resolved before the site was allocated within the DSP. This calls the delivery of the site into question either at all or within the plan period.
There is a concern for the impact of development on the highway system.

Object

Representation ID: 14348

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst accepting the Councils Strategy of urban expansion. this site raises concerns over compliance with government policy and the Council’s own methodology and site selection process, which includes using planning judgement to refine selection. Concern is raised about the proposed allocation on Green Belt grounds and Landscape Character assessment concerns.
Government policy states that the land to the south of Shirley, opposite Dog Kennel Lane clearly exhibits openness. The Landscape Character Assessment identifies the site as lying within a landscape character area of high sensitivity. Development here would extend built development out into open countryside.

Paragraphs 600 and 609 provide conflicting statements and constructing a new road to form the Green Belt boundary does not conform to Government policy. The existing field structure between Dog Kennel Lane and Cheswick Green does not provide a clear contiguous defensible Green Belt boundary for new development, it cannot be demonstrated how coalescence with Cheswick Green would be avoided. In developing out into open countryside there would be a substantial and detrimental impact on landscape character.

Object

Representation ID: 14351

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Coalescence and potential coalescence with both Dickens Heath and Majors Green and the resulting gaps between settlements have been a major concern since the late introduction of this site as a potential allocation and the deletion of Site 13 in the Draft Local Plan Supplementary Consultation document 2019.

Master planning, quite reasonably, has been used in endeavouring to overcome these concerns, together with carefully worded text to promote the site, a luxury which was seemingly not afforded Site13 and which master planning could have overcome issues raised by the Council. Rosconn submitted a master plan which did just that. A copy of the master plan is attached as Appendix 1.

Site BL3 is no further away from Dickens Heath than the parts of site 13 and Site 340 which are intended to be built development.
Whitlocks End Farm (BL3) lies within the highly performing Green Belt parcel, whereas former allocation Site 13 lies within the moderately performing Green Belt in the Council’s Green Belt Assessment document.

Object

Representation ID: 14370

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Land to the west of this site was allocated for housing in the adopted Local Plan on condition that the former ammunition depot was reclaimed for open space or if not available, an alternative development solution delivering open space was forthcoming. This situation still exists and so calls into question the allocation of HA1.
The combination of both allocations appears to have resulted in an overall reduction in POS. POS for the previously allocated site has now been pushed into the Green Belt outside either allocation boundary, causing further encroachment and urbanisation. There is no evidence in relation to viability of the site and how this may be affected by any potential contamination issues as a consequence of the former use of the site.