Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 15051

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Given none of the emerging masterplans show any compensatory improvements within the Green Belt, it would appear that the Policy is relying on there being additional land being available within the control of applicants (which may not be the case), or the payment of contributions.
- SMBC’s viability evidence does not take this requirement into account, and no detail is provided as to how these contributions will be spent or what level of contribution is required. This therefore brings uncertainty, and the Policy should be reconsidered to ensure what is required is clear, and that it will not impact upon the viability of schemes.

Object

Representation ID: 15052

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Council’s viability testing does not take into account digital infrastructure within the testing and, as such, it should be evidenced that this will not render development unviable.

Object

Representation ID: 15053

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Note that sole justification of proposing 1,756 homes in Balsall Common is based on settlement including a primary and secondary school, and full range of retail and associated facilities.
- However no significant areas of employment, as supported by SA which states people travel outside of settlement to work.
- Expansion of settlement therefore contrary to sustainability objectives of reducing need to travel to employment areas.
- 1,756 dwellings to single rural village is not a proportional distribution strategy, but completely disproportionate.
- No discussion on how bypass, station car park, improved public transport or primary school will be funded/delivered.
- Reference to scope to enhance existing local centre and provision of a village centre masterplan, but no proposals on what these enhancements would entail or function, especially as a bypass would draw trade away from existing centre.
- No assessment of Balsall Common’s ability to deliver this level of growth, for market to absorb and deliver multiple sites/outlets in such a small area.
- Furthermore, Balsall Common will be acutely affected by HS2, both in terms of physical construction of the line and disruption and uncertainty this will bring, as well as market desirability.

Object

Representation ID: 15054

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Barratts Farm multiple ownership is described as ‘complex’ in Para. 541.
- Is single largest site and one proposed to delivery by-pass.
- Previous draft of Local Plan stated site will only be brought forward if landowners/promoters could demonstrate collaborative and comprehensive approach. Seems from text this is not the case.
- Serious doubt Barratts Farm can be delivered within anticipated timeframe, which affects Plan’s housing land supply.
Relief road issues:
- Policy advises relief road required early in the plan period.
- Road will be provisionally funded by CIL payments and grant funding that may come from WMCA.
- CIL funding can only be secured through future sites, which can only be delivered until Local Plan Review is adopted (as they are in the Green Belt) and subsequent CIL schedule is adopted.
- No grant funding proposal in place to fund the road.
- Therefore, road is not deliverable.

Object

Representation ID: 15055

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Consider sports re-provision should be considered now, otherwise pitches will be lost with no alternative in place, and no guarantee of re-provision. Any proposals within Green Belt need to considered against Green Belt tests, inc. floodlighting.
- Note unable to re-provide on site because of LWS.
- Significant local concern, particularly with no proposals for replacement.
- Council have had ample time to secure alternative sports provision. Lack thereof suggest no alternatives are currently available, and questions delivery of site.
- Therefore, consider Site BL1 should be deleted from Plan.

Object

Representation ID: 15056

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Text pre-judges a planning application by stating that very special circumstances will likely exist to support re-provision of sports pitches with the Green Belt to the north of the allocation, for which no detail is known, and therefore cannot be relied upon.
- Therefore, housing that would be included on the existing sports pitches should not counted until the reprovision of the sports pitches is secured.

Object

Representation ID: 15057

Received: 14/12/2020

Respondent: Barratt David Wilson - Arden Green

Agent: Barton Willmore Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Proposed Alternative Site, CFS 545:
o Should qualify as Priority 5 in Step 1 (yellow) as in accessible location (see Atkins 2016 Accessibility score) within a lower performing Green Belt area (4).
o Should therefore advance past Step 1
o N.B. Accessibility of Site 545 is same as Sites 126, 176, 122 and 130 (components of Site 4/BL1), which have been taken forward to Step 2.
o Site selection process is therefore flawed.
o Factors in favour of Step 2:
 Site would be part of Growth Option G; given Council are proposing developments in the Tidbury Green/Whitlocks End area.
 Hard constraints do not prevent development, as TPO trees will be unaffected.
 Site has existing defensible Green Belt boundaries to the north, west and east, and would be defined by strong boundaries; a railway and flood zone to the west, buildings to the north, and road to the east.
 Site can deliver a significant area of amenity open space to the south (over and above that required by policy), which can be retained in perpetuity to ensure a long-term maintenance of a gap between Whitlocks End and Tidbury Green.
 Site also close to amenities in Wythall (Bromsgrove DC)
 Can be demonstrated that historic landfill can be dealt with and does not adversely affect site’s suitability – would increase SHELAA score
 No development proposed within Flood Zone 3 of wider site boundary – would increase SHELAA score
 Site within Landscape Character Area ‘2’, but other sites are already proposed within this landscape area. LCA (p.25) confirms it is not possible to establish a baseline sensitivity to change without details of proposed development (see Appendix 2 – Landscape and Visual Appraisal for Site).
 SA does not identify any significant harmful impacts.
 Accessibility overall score is medium/high, with lower scores for GP and food store. These are within 1.8km along a formal route, and is considered a reasonable distance to walk or cycle. See enclosed DTA assessment, which demonstrates accessibility to site.