Parish Council PO Box 6379, , CV6 9LP

Berkswell Parish Council response to draft Plan

This report is divided into two sections. Part 1 covers the Parish Council’s response to the housing numbers and site selection issues. Part 2 covers response to all other issues and SMBC questions.

Contents Part 1 - Response to the draft Solihull Plan covering issues related to housing numbers and site selection ...... 2 1. Summary ...... 2 2. Introduction ...... 2 3. Response to questions in relation to site selection and housing numbers ...... 3 4. The Greenbelt Scoring System ...... 12 Criteria 1- To check the unrestricted sprawl of large built-up areas...... 12 Criteria 2 - To prevent neighbouring towns merging into one another...... 12 Criteria 3 - To assist in safeguarding the countryside from encroachment...... 13 Amended Greenbelt scoring ...... 14 5. Conclusion ...... 17 Part 2 - Response to the Solihull draft plan covering issues other than site selection ...... 18 1. What needs to happen in to accommodate the growth...... 18 2. Recommendation 1 – Balsall Common centre (questions 1, 7, 2 and 16)...... 18 3. Recommendation 2 - Spatial Strategy (question 3) ...... 19 4. Recommendation 3 – Berkswell Station Car Parking (question 16) ...... 19 5. Recommendation 4 - Bus and Train Services (Question 18) ...... 19 6. Recommendation 5 – Other infrastructure/facilities/Health & Supporting Local Communities (Questions 16 and 21) ...... 20 7. Recommendation 6 – Inset Study (questions 1, 2, 16) ...... 22 8. Recommendation 7 - Sustainable Economic Growth – Question 4 & 6 ...... 22 9. Recommendation 8 - Providing Homes for all – Question 11 ...... 22 10. Recommendation 9 - Delivery and Monitoring – Question 22 ...... 22 11. Phasing of House building ...... 23 12. Balsall Common bypass ...... 23 Appendix 1- Photographs showing overflow Station Parking on Hallmeadow Road ...... 25 Appendix 2 - Results of 2015 Car Parking Survey ...... 26 Appendix 3 – Greenbelt analysis by land parcel ...... 28

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Part 1 - Response to the draft Solihull Plan covering issues related to housing numbers and site selection

This section of the Berkswell Parish Council response to the draft plan covers issues relating to housing numbers and site selection. Part 2 of the PC’s response covers all other issues and the questions posed by Solihull Council

1. Summary 1.1. The prime objectives of Berkswell Parish Council in connection with town and country planning are to protect the character and appearance of the local landscape, the heritage assets within it, and the amenities of local residents; and to secure and maintain the vital strategic Meriden Gap, which at this point is very narrow and subject to increasing development pressures from within Solihull Metropolitan Borough and from proposals on the south western edge of the Coventry urban area. The area will also be severely adversely affected by the line of HS2. 1.2. The narrow gap between Balsall Common and the western edge of Coventry contains a number of small settlements and scattered developments but it performs a number of very important Green Belt functions in checking the unrestricted sprawl of large built-up areas, preventing neighbouring towns merging into one another; and assisting in safeguarding the countryside from encroachment. The importance of the Green Belt in this area is such that the Parish Council is of the strong opinion that no major development should take place in the gap between the existing defined built-up area boundary on the eastern side of Balsall Common and the western edge of the Coventry urban area. Furthermore, the importance of this particular part of the Green Belt should be given precedence over accessibility consideration and all other matters. 1.3. To this end the Parish Council strongly objects to proposed housing allocation 1 for the erection of 800 dwellings at Barratt’s Farm, Balsall Common and 200 dwellings at Windmill Lane allocation 3.

2. Introduction

2.1. Berkswell Parish Council welcomes the opportunity of commenting on the Draft Local Plan (November 2016) and recognises that the Borough Council has a major task in finding locations to meet the full objectively assessed housing need. The Parish Council further recognises the need for local communities to work with the Borough Council in helping find suitable sustainable locations for new housing development. This, however, must not be at the cost of valued landscapes and accessible areas of countryside, nor, moreover, by removing land from the Green Belt in vital parts of the strategic Meriden Gap. 2.2. The narrow area of land between Balsall Common and the western side of Coventry performs a number of important Green Belt functions within the strategic Meriden Gap, and it must be protected from major developments. The existence of existing settlements and scattered development within the gap between Balsall Common and Coventry does not diminish the need to protect the remaining open areas of countryside, indeed it reinforces the imperative to prevent further major development taking place for, at this point, the gap is very narrow and vulnerable. Further the future construction of HS2, which in itself will have a severe adverse impact on the character and appearance of the area, should not be seen as a justification for new housing or other forms of development. Quite the reverse as the cumulative effects would be immensely damaging. The impacts would be further exacerbated

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

should proposals for a by-pass around the eastern side of Balsall Common be progressed by the Borough Council. 2.3. The Parish Council has studied the evidence base to the Draft Local Plan, and makes comments subsequently in this document, but fails to find the exceptional circumstances necessary, as set down in paragraph 83 of the National Planning Policy Framework, to justify altering the established Green Belt boundary on the eastern side of Balsall Common to allow for the scale of new development advanced in proposed housing allocation 1: Barratt’s Farm, Balsall Common. 2.4. The Parish Council recognises the potential accessibility of the proposed site to Berkswell Station, but contends that the vital importance and function of this particularly part of the Green Belt should be given precedence over this consideration and all other matters. We also note that Berkswell Station not only failed to meet the service frequency of the old Policy but also does not meet the requirements of new Policy and is therefore provides non sustainable public transport. The Green Belt boundary should not be altered and no major developments should be permitted in the area. The Borough Council needs to find suitable and sustainable land elsewhere, and in this respect the Parish Council, once again, urges the Borough Council to look more closely at the potential of increasing housing densities within the main urban areas of the Borough especially in and around the town centre and Shirley. 2.5. With regard to the land to the east of Balsall Common the Parish Council finds that the Draft Local Plan fails to be based on the findings of various documents forming the evidence base, and that in some respects that evidence base is flawed and too general to enable the Borough Council to claim that the proposed housing allocations, in particular proposed housing allocation 1, is sound and in accordance with the National Planning Policy Framework. Furthermore, the Draft Local Plan is internally inconsistent in that the allocation does not meet the vision and objectives of the Plan. 2.6. Allocation 3 (Windmill Lane) is a small enough to be reallocated to a more appropriate site towards the north of Balsall Common (including PD land) as suggested in the submission made by Wendy Wilson, Jeanette Mcgarry and John Wilson dated 9th February 2017

3. Response to questions in relation to site selection and housing numbers

Within this context the remainder of this document addresses the questions raised in the Draft Local Plan in so far as they are relevant to the Parish Council’s prime concerns.

1. Do you agree that we’ve identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?

3.1. In general, the Parish Council considers the Draft Local Plan to identify the right challenges facing the Borough but feels that the Plan fails to address these challenges in an appropriate manner in terms of the location and quantum of new housing development against the vital need to protect critical and highly vulnerable parts of the strategic Meriden Gap, i.e. the land to the east of Balsall Common.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Further detailed comments on the “Challenges” are shown in Part 2 of our response with respect to Balsall Common centre. 3.2. It is noted that one of challenges faced by the Borough Council is the protection of key gaps between urban areas and settlements, and maintaining the integrity of the Green Belt and the Borough’s attractive rural setting, in the context of the significant pressures on agriculture and for development to meet housing requirements. The objective of the Local Plan therefore is stated to be:

“Maintain the Green Belt and improve the network of green infrastructure in Solihull, to prevent unrestricted expansion of the major urban areas, to safeguard key gaps between settlements such as the Meriden Gap and the countryside. Ensure that the countryside is managed so as to deliver a range of benefits including the growing of food and energy products, create an attractive rural setting and improved public access and recreational opportunities.”

3.3. Further, the Draft Local Plan notes that the Rural Area generally has a high quality built and natural environment, characterised by its Arden landscape setting, attractive countryside, important green corridors such as its canals and rivers and its rich biodiversity. The predominant land use is agriculture, which contrasts with the urban character of the remainder of the Borough and most of the Rural Area is protected by the Green Belt. 3.4. Despite the recognition of the strategic importance of key gaps and the resultant objective the Draft Local Plan goes ahead and allocates an extensive area of land to the east of Balsall Common which evidently runs contrary to the objective, and other parts of the Draft Plan. 3.5. Further the allocation fails to have regard to the findings of various studies constituting the evidence base for the Plan. This is addressed later in this document.

2. Do you agree with the Borough Vision we have set out? If not why not, and what alternative would you suggest?

3.6. The Parish Council strongly disagrees with the Borough Vision as it affects Balsall Common. Clearly a mix of market and affordable housing needs to be provided but the vision of a significant new development on the edge of Balsall Common is not the appropriate means of meeting those needs. Balsall Common is not a sustainable location for large amounts of new market and affordable housing, which in the Parish Council’s view should be focussed in the main urban cores and areas. Further one of the prime objectives in terms of Balsall Common, as noted in the above section, should be the protection of the key gaps and in the Parish Council’s opinion there is no more important key gap than the one to the east of the existing built-up area of the settlement. The protection of this key gap should be given great weight and a very high planning priority. 3.7. It is important to ensure that the centre of the village continues to thrive and cater for the needs of the local community. The overall scale of development planned however is not required to secure this objective and taking into account other factors the Parish Council submits that the overall amount of housing should and could be reduced to 300 to 400 new homes within Berkswell Parish plus an appropriate allocation for Balsall Parish. That would provide a total of around 750 homes. A sizeable contribution to the Borough’s needs in addition to the circa 200 already included within the 2012 plan/approved but not yet completed.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

3.8. The Parish Council has had a long held objection to the principle of a bypass running on the eastern side of Balsall Common and therefore need to disagree with this part of the Vision for Balsall Common. The bypass was removed from the local plan in 2012 because there was no objective need for it. Current traffic surveys show no significant change and HS2 Ltd Environmental Statement states that that the traffic generated by HS2 does not warrant any infrastructure changes. The need for the bypass cannot be justified, in whole or in part, on the requirements of the major allocation at Barratt’s Farm which in itself is unacceptable. 3.9. It is noted that the provision of the bypass is to be pursued through the local plan review but that no route is proposed at this stage. It is clear however from the extent of proposed housing allocation 1 that the Borough Council envisages the same line as that shown in the 2006 UDP. That alignment, individually and cumulatively with the proposed housing development itself and HS2, would have a severe adverse impact on the openness of the Green Belt, and “the local distinctiveness of the area, the open countryside setting, sense of remoteness, distinctive fieldscapes, woodland and assets such as the , Grand Union canal and the network of scattered historic hamlets and farmsteads”. All of these are due to be protected and enhanced by the Draft Local Plan.

3. Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?

3.10. The purpose of the strategic objectives is to ensure that a strategy is arrived at that makes the effective use of land and creates a pattern of development that focusses significant development in locations that are, or can be made, sustainable. Balsall Common however, does not meet the high frequency criteria and the Parish Council questions whether a satisfactory service, which will meet existing and future residents’ travel needs over the long term can be delivered, even with the scale of new development planned in the Draft Local Plan. 3.11. Presently there is no high frequency bus service in the Parish or in Balsall Common, and neither it nor the train service meets the requirements of Policy 7 even though these requirements have been reduced. It only caters for a small proportion of journey to work and other trips. The SMBC data shows that 70% of residents use their car for travel to work and other trips. Parking at the station is limited, as manifestly shown by the number of cars parking along Hallmeadow Road. 3.12. The Parish Council applaud the Borough Council’s vision of securing a modal shift but in reality even a significantly enhanced bus (and rail) service will not be able to carry or otherwise cope with the level of existing and future residents’ varied travel needs. The better solution therefore is to place significant new housing in areas of existing high accessibility to employment growth using public transport and therefore sustainable, and where there is a realistic ability to enhance existing service provision. The chosen option of significant development in Balsall Common is ill-founded and not supported by the Parish Council. 3.13. The Parish Council considers that greater emphasis should be given to increasing densities in existing urban areas, including allocating more development in Solihull town centre, in and close to the centre of Shirley and at UK Central. The Parish Council further believes that SMBC have failed to adequately investigate the option proposed by the PC for a garden village close to the A45 and the employment opportunities just north of the A45. New settlements have been a national planning policy objective since 1947 and remains an objective for the government. The Parish Council is not

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

convinced that these options have been fully explored and urge the Borough Council to reconsider its approach, particularly the major allocation in Balsall Common. 3.14. With regard to the major allocation at Balsall Common, the Parish Council notes that the strategic objectives set out a sequential approach to directing growth, and in addition, some guiding principles have been identified. The guiding principles include those which generally are not in support of development: 3.14.1. Protecting the strategic purposes of the Green Belt; 3.14.2. Areas of the Green Belt that perform well against the purposes of including land in the Green Belt; 3.14.3. Preserving, conserving, enhancing and restoring environmental assets.

3.15. Application of these guiding principles must exclude the major allocation of land at Barratt’s Farm. 3.16. The spatial strategy does not consider the benefits that a new Garden Village would bring in terms of meeting housing objectives at locations that are sustainable in transport terms for employment and where purpose designed facilities/infrastructure can be included rather than trying to adapt existing facilities. This approach has been a key element of an approach to maintain gaps between settlements and the prevention of urban sprawl since the Town and Country Planning Act 1947. With its recent announcements of 14 garden villages from Cornwall to Cumbria the Government clearly still supports this concept

3.17. In summary, the Parish Council considers that the strategy should be based on: • Minimising the impact of development on the Green Belt and recognising that within the Green Belt there are vital strategically significant gaps that should be given precedence when assessing the location of future development; • Focussing development into the urban cores and increasing housing densities elsewhere within the existing urban areas; • Maximising the use of previously developed land as required by the NPPF; • Minimising dependency on car usage, by locating new homes in areas where job growth will be the highest and where high frequency transport is best or can be secured; and • The PC notes that the growth has been unequally distributed without justification. All parts of the Borough should take some new housing development. • At least one garden village

14. Do you agree that we are planning to build the right number of new homes? If not why not, and how many do you think we should be planning to build?

3.18. The Parish Council is not in position to comment on the total amount of new housing to be provided within the Borough during the Plan period. The Parish Council however strongly feels that the spatial distribution of the housing to be provided is inappropriate, in particular the concentration of so much of the new housing provision at Balsall Common. Notwithstanding the work undertaken by, and on behalf of the Borough Council, Balsall Common is not a sustainable location for the amount of new housing planned, in addition to that already built in recent years and committed. 3.19. The Draft Local Plan allocates 18 sites for housing development which in total will provide for 6,150 new homes. Of the 18 sites, 12 are within the Green Belt and three of these are at Balsall Common. The 12 Green Belt sites are planned to provide for 5,250 new homes, or around 85% of the 6 | P a g e

Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

total Borough allocation. The three sites in Balsall Common are to provide 1,150 new homes, that is just under 19% of the total allocation. The site at Barratt’s Farm is allocated for 800 new homes, or 13% of the total allocation. 3.20. This level of provision for Balsall Common is inappropriate and unsustainable, particularly having regard to the settlement’s location in the strategic Meriden Gap, the lack of any meaningful employment opportunities in and immediately around the settlement, and poor public transport systems linking with key employment, commercial, and retail areas, and social and community facilities. The rail services offered via Berkswell Station do not and cannot meet the travel needs of existing and future residents, and undoubtedly many will have to use, or choose to use the private car in the absence of any reliable, safe, convenient, regular and frequent bus services. 3.21. The Parish Council recognises that some new housing development could take place at Balsall Common but submit the overall number should be reduced to 300 to 400 new homes by the deletion of proposed housing allocation 1: land at Barratt’s Farm.

15. Do you believe we are planning to build new homes in the right locations? If not why not, and which locations do you believe shouldn’t be included? Are there any other locations that you think should be included?

3.22. Question 15 General

The Parish Council strongly disagrees that the Borough Council is planning to build new homes in the right locations. As already expressed Balsall Common is the wrong location for such significant new housing development. The quantum of proposed new housing being directed to the village (19% of the total Borough- wide provision) is wholly disproportionate, unsuitable and unsustainable. The Parish Council accepts that the village can accommodate some new provision but the proposed housing allocation 1 makes it too much and it is unacceptable to build on the site for other valid planning reasons, not least the prejudicial effect it would have on the purposes of including land in the Green Belt, and the adverse effect it would have on the character of the countryside and the rural setting of Balsall Common and other settlements in the area.

3.23. Question 15 Allocation 1 – Barratt’s Farm

Should SMBC consider that it is essential that a large development is provided within the Balsall Common area then an objective greenbelt analysis would place it elsewhere and not in the narrowest part of the Meriden Gap. We note that Barratt’s Farm is in multiple ownership/control whereas other available sites are under single control and it is logical to presume that delivery would be easier where single control exists. Furthermore the construction of HS2 is likely to interfere with deliverability at Barratt’s Farm but have little or no impact on the alternatives. We also note that alternative sites do not have listed buildings. It is National & SMBC policy to protect the setting of such historical assets.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

3.24. The Parish Council disagrees with the justification given in the Draft Local Plan for proposed housing allocation 1: Barratt’s Farm, and moreover feels that the allocation is not supported by the evidence base. 3.25. Consideration has been given to the findings of the Landscape Character Assessment, in particular area LCA 5 – Balsall Common Eastern Fringe, and LCA6 – Eastern Fringe. The study notes that the area is heavily influenced by the settlement of Balsall Common bringing in strong elements of suburbia. This is particularly noticeable around Catchems Corner and Carol Green. The strong influence of Balsall Common on the rural character of the area has led to the loss of the definitive edge between the urban area and the countryside beyond. However, strong tree cover creates a strong sense of place that adds to the distinctiveness of the area. Even in the area of built development, the tree structure has been retained and remains a dominant influence. 3.26. The landform along with the strong hedgerow structure creates short-distance views that are contained within the LCA. The area is easily accessible via a network of roads, footpaths and long distance trails including the Millennium Way, and Kenilworth Greenway linear park, which form key recreational routes through the area. Being in close proximity to the built edge, the area is well used for recreation and is an important access point to the countryside. 3.27. The study goes on to give some guidelines, including the need to preserve openness between dwellings and resist further development. It comments that this is a landscape with a strong sense of place, defining landscape features and a characteristic field pattern. The historic field pattern around the settlement is an important feature along with the associated tree structure, which contributes to the setting of the settlements in the wider landscape. 3.28. In terms of visual sensitivity, the study states that the prevention of coalescence is important particularly where the urban edge has a strong relationship with existing built form. 3.29. On landscape value, the study states this is a locally distinctive landscape containing valued characteristics. The historic field pattern is irreplaceable and considered fundamental to the distinctiveness of the character of the area. The value of the area is increased by the presence of the long distance trails. 3.30. Further LCA5 has a low landscape capacity to accommodate new development. The LCA is an attractive largely rural landscape with urban influences, being in close proximity to Balsall Common. It is characterised by its historic field pattern and pastoral fields. The study concludes that, overall, the area would be able to accommodate only small areas of new development, which would need to be of an appropriate type, scale and form in keeping with the existing character and features of the landscape. Any new development should not result in the loss of the historical field patterns or facilitate the further expansion of Balsall Common into the countryside. The landscape contains many scattered buildings and has limited capacity to accept additional built development without causing detrimental coalescence. 3.31. The findings of the study in respect of LCA6 (Eastern Fringe) are also relevant. The Parish Council takes the view that there is little distinction between the two LCAs and notes the important statement that the southern half of the area (LCA6) plays an important role in separating Balsall Common from Coventry, and is sensitive to development which would result in coalescence. There is pressure for new housing in the attractive countryside due to easy access to Coventry, with increasing pressure on the arterial roads. The LCA has limited capacity to accept development without impact upon the character of the area.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

3.32. In view of the above findings the Parish Council must question how the Borough Council feels able to make such a major allocation as at Barratt’s Farm. The harm to the landscape will be further exacerbated by HS2, and the proposed eastern bypass if constructed. 3.33. In addition, the Parish Council has considered the content of the Solihull Strategic Green Belt Assessment. It notes that it is stated that the assessment forms an essential cornerstone in the provision of a sound and up to date evidence base to support the development of policies relating to growth in the Borough. Regrettably this is not the case and, as a consequence, the proposed allocations, in particular that relating to Barratt’s Farm, Balsall Common, are not soundly based. Furthermore, we are unclear to what extent the Greenbelt Assessment was actually used to inform site allocations because NDP representatives were told in September 2016 that it was not complete at that time yet within one month major site allocations were made allegedly based on the Greenbelt Assessment. 3.34. The assessment lists the five purposes of the Green Belt, as set out in the NPPF, and goes on to consider how various sites perform against them. It is noted, however, that it is a strategic assessment and intended to form the basis for more detailed assessment of Green Belt land within the Borough. The Parish Council is not aware of any more detailed assessment having been carried and being made publicly available. Yet the Borough Council feels able to make a major housing allocation in what undoubtedly is one of the most sensitive and vulnerable key gaps in the strategic Meriden Gap. 3.35. The assessment notes that the character of the Green Belt varies greatly across the Borough “with the eastern portion forming part of the vital strategic Meriden Gap – the area of Green Belt separating and Solihull form Coventry in the east. This area of the Green Belt is predominantly rural in nature and generally characterised by countryside with smaller settlements scattered across the area.” 3.36. The Green Belt Assessment defines two ‘distinct’ categories of area: • Refined Parcels; and • Broad Areas

3.37. Refined Parcels of Green Belt land are stated to be land adjoining or adjacent to built-up areas, including the inset villages. The wider rural areas were divided into Broad Areas which are defined in the assessment as being Green Belt land that is not located on the edge of, or adjacent to, large built up areas within SMBC or those within adjoining authorities. The distinction apparently “reflects the varying character and role of Green Belt land across the Borough. Green Belt land immediately adjoining the urban areas performs a different role to those areas of Green Belt within the more rural areas of the Borough.” The Parish Council fundamentally disagrees with this statement and the distinction drawn between the Refined Parcels and Broad Areas as it affects land within the Parish. 3.38. The assessment asserts that the delineation of the Refined Parcels and Broad Areas follows strong permanent physical features, in line with paragraph 85 of the NPPF in terms of defined Green Belt boundaries, but the Parish Council believes the approach adopted and the particular features used are not appropriate and, as a result have resulted in a flawed study especially as it affects the land to the east of Balsall Common. 3.39. The boundary between Broad Area 4, which is primarily the area to the east of Balsall Common, and Refined Parcel (RP) 54 is simply a public footpath. This is not a durable and strong physical feature and, in reality there is little or no distinction in terms of the contribution made by the land on either side of the boundary to the purposes of the Green Belt. Indeed, in the view of the Parish Council the whole of RP54 should be within Broad Area 4. Similarly, RP55 and RP56 should also be within Broad 9 | P a g e

Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Area 4. As such these refined parcels do not exist on the ground separate from the rest of Broad Area 4. 3.40. The Parish Council notes that the Broad Areas have been defined in the more rural areas of the Borough where Green Belt land is characterised by countryside. These Broad Areas largely form the gaps between large built-up areas. By virtue of their character and location all Broad Areas are considered to make an equal contribution to purpose 3 ‘Assist in safeguarding the countryside from encroachment’ and were therefore all assigned a score of 3 against this purpose. 3.41. Broad Area 4 forms the eastern portion of the borough at its boundary with Coventry to the east and North Borough Council to the north. The area covers a large part of the strategic Meriden Gap between the major urban areas of Birmingham and Solihull to the west and Coventry to the east. The Broad Area also contains Berkswell Conservation Area. The Area performs highly against all 4 purposes and makes an equal contribution to the preservation of the Meriden strategic gap and the setting and character of Berkswell Conservation Area. 3.42. As already indicated the Parish Council feels that RP54, RP55 and RP 56 share the same characteristics and Green Belt functions as Broad Area 4 and should have been included in it. 3.43. The Parish Council is concerned to see proposed housing allocation 1 extends beyond the boundaries of RP54 and RP55 to include a significant area of land in Broad Area 4, which the Borough Council’s assessment states performs highly against all 4 purposes of the Green Belt. The harm caused by the proposed allocation therefore would be severe and fundamentally harmful to this key part of the strategic Meriden Gap. Further adverse cumulative impacts would arise from the encroachment of the proposed eastern bypass, and HS2 into this vulnerable area.

3.44. Question 15 – Allocation 3 Windmill Lane 3.44.1. Berkswell PC supports the arguments made by Wendy Wilson, Jeanette McGarry and John Wilson in their paper dated 11th February 2017 and does not believe that it would be helpful to repeat them here. 3.45. Question 15 – Alternative housing sites

Consultees are requested to give alternative sites to those proposed by SMBC. Our suggestions are as follows

Site Capacity Comment

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

New Garden village on site 76 This is 71 hectares and could The concept of garden villages accommodate 1000 to 1500 was an option for the spacial homes, a school and shops. Over strategy. This proposal would put the course of time the Garden new homes close to the jobs by village can be expanded as the airport and close to the Sprint further land is restored after bus service. As such it is a highly quarrying on site 212 is sustainable location. It is not in completed. We note that the the narrowest part of the original commitment was that Meriden Gap and therefore site 212 restoration should have performs better in greenbelt already started. It can also be terms than Barratt’s Farm. As linked to site 216 which is PDL reclaimed land it also has a worse land. landscape value to the small field system and old trees/hedgerows This site is so large that it could of Barratt’s Farm. It also offers not only obviate the need for the no real value to residents development of Barratt’s Farm because it is not accessible in the but can also take pressure off manner of Barratt’s Farm and other areas such as Knowle. performs less well to meet para 81 of the NPPF. It also has no listed buildings Site 216 – Marsh Farm Truck Stop This is PDL land which taken together with 76 adds mass to the new settlement readily connected by the proposed HS2 roundabout. Lavender Hall Farm 69 according to SMBC but over Fully PDL land. An excellent site 100 according to proposer for affordable housing. 200m by foot Station and Doctors. 500m by car and 350m by foot to Sainsbury. New Park Lane will provide easy access to A452. 1 km from Berkswell School. Wooton Green Lane 265 Part PDL site proposed by Wendy Wilson in her submission as alternative to Allocation 3. Easy access to A452. Walking distance to shops, & schools. Springhill 21. Could be expanded to 50-60 Part PDL site. An excellent site for with inclusion of adjacent SMBC affordable housing. 100m to land Station, 150 m to Doctors. Closer to schools and shops than current Riddings Hill development and the same as the proposed Council owned site next to the medical centre allocated in 2012. Site 43 40 A site fully bounded by roads and railways of very low greenbelt value at north of village. Close to Sainsbury and on A452 for access to employment. 11 | P a g e

Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Pheasant Oak Farm 80 Almost all PDL land. As close to facilities as the proposed allocation 3 site. There are lots of other sites across the borough with lower greenbelt value than allocation 1 many with better public transport links hence conforming to the need for sustainable transport. Particulaly those to the west of the M42 which can directly link to Solihull. The M42 acts as the natural barrier the Solihull/Birmingham conurbation

4. The Greenbelt Scoring System

The Parish Council has reviewed the assessment criteria and scoring system adopted in the document and, as a consequence has to question the findings of the study in relation to both Barratt’s Farm (allocation 1) and Windmill Lane (allocation 2)

Criteria 1- To check the unrestricted sprawl of large built-up areas.

4.1. The existence of ribbon or other development detached from the existing built-up area with no clear boundary, within the Refined Parcels or Broad Areas, does not mean that the land is necessarily ‘lower performing’. Indeed, the existence of development can increase the importance of retaining open land and areas of countryside around it. The cumulative impact of existing and proposed development, especially large-scale schemes, can have a marked and seriously prejudicial impact, and contribute to unrestricted sprawl. 4.2. Further, account needs to be taken of other committed and future development and infrastructure schemes within or close to the RP, and the failure to do so in the assessment is a serious omission. 4.3. It is noted that the assessment comments durable permanent boundaries are considered to be motorways and ‘A’ roads, other infrastructure, and permanent natural features such as watercourses. Less durable boundaries are considered to be established field boundaries, hedgerows and treelines. Whilst easily identifiable these features are less durable. This reinforces the Parish Council’s view that the chosen definition between RP54 and Broad Area 4 is misguided. The definition fails to properly reflect the full contribution made by the RP to the purposes of the Green Belt.

Criteria 2 - To prevent neighbouring towns merging into one another.

4.4. The approach and scoring system is seriously flawed in that it would appear no account is taken of existing development which, in combination with proposed development would individually and cumulatively lead to coalescence of towns and settlements. The scoring system for assessment of the 12 | P a g e

Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Refined Parcels needs to be more sensitive, for example the existence of present development within wider gaps between towns and other larger settlements should mean that the remaining open areas perform a higher purpose, and thus should be given a higher score, not lower. 4.5. Furthermore, the graduation in the scoring system is too steep and course. For gaps of between 1 and 5 kilometres to be given the same score (2) and for them to be regarded as ‘more moderately performing’ is inappropriate and inadequate to properly reflect local circumstances. 4.6. As stated existing development can only contribute to potential coalescence, as recognised in the Landscape Character Assessment, and, in addition, account must also be taken of other committed and future development and infrastructure schemes. 4.7. It is noted that strategic gaps are considered to be those areas that separate major urban areas/cities, e.g. Birmingham and Coventry. The RPs on the eastern side of Balsall Common are within a key, vulnerable part of the strategic gap.

Criteria 3 - To assist in safeguarding the countryside from encroachment.

4.8. Again the approach and scoring system is seriously flawed and fails to take into account other important factors such as public accessibility to the area, the topography of the land and setting of historic buildings. Planning Authorities are required by paragraph 81 of the NPPF to seek to provide access to greenbelt land. By failing to include public access as a criteria within the greenbelt analysis, SMBC have failed to accurately measure the relative value of the various parcels/areas of land assessed. Similarly, whilst the setting of conservation areas rates a score of 3 no scoring is given for the setting of historic buildings with listed status. This is contrary to NPPF paragraphs 132 and 133. A combination of these factors has led to an underscoring of allocations 1 & 3. Allocation 1 is highly accessed by residents using the public footpaths. Allocations 1 and 3 both impact the settings of historic listed assets. 4.9. Further it is evident that the scoring of the Refined Parcels can be skewed by the actual definition of the boundaries of the area, and the inclusion of, and weighting given to existing development within the area. In cases it is clear that a small area of existing development within a Refined Parcel can have a fundamental and unjustified effect on the scoring of the area. RP54 is a case in point where a limited amount of existing development (which does not appear to actually exist in the RP) results in the wider area being underscored in terms of its contribution to the purpose of the Green Belt. 4.10. In view of its concern about the findings of the Green Belt Assessment the Parish Council has undertaken its own appraisal of the RPs on the eastern side of Balsall Common (RP52 to RP56) and the findings are set down in the tables in the appendix. 4.11. The reasons for the Parish Council’s scoring is given in the ‘BPC Response’ column of the tables appendix 3 and the scores are summarised below:

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Amended Greenbelt scoring

Refined Parcel GBA Score BPC Score

RP52 1. To check the unrestricted 2 2 sprawl of large built-up areas.

2. To prevent neighbouring 2 3 towns merging into one another. 3. To assist in safeguarding the 2 3 countryside from encroachment. 6 8 RP53 1. To check the unrestricted 1 2 sprawl of large built-up areas.

2. To prevent neighbouring 2 2 towns merging into one another. 3. To assist in safeguarding the 2 2 countryside from encroachment. 5 6 RP54 1. To check the unrestricted 1 3 sprawl of large built-up areas.

2. To prevent neighbouring 2 3 towns merging into one another. 3. To assist in safeguarding the 2 3 countryside from encroachment. 5 9

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RP55 1. To check the unrestricted 2 3 sprawl of large built-up areas.

2. To prevent neighbouring 2 3 towns merging into one another. 3. To assist in safeguarding the 2 3 countryside from encroachment. 6 9 RP56 1. To check the unrestricted 1 3 sprawl of large built-up areas.

2. To prevent neighbouring 2 3 towns merging into one another. 3. To assist in safeguarding the 1 3 countryside from encroachment. 4 9 RP57 1. To check the unrestricted 1 2 sprawl of large built-up areas.

2. To prevent neighbouring 2 2 towns merging into one another. 3. To assist in safeguarding the 1 2 countryside from encroachment. 4 6

4.12. The assessment of the Parish Council therefore is that all of the RPs on the eastern side of Balsall Common are highly performing in terms of the purposes of including land in the Green Belt, and should not be developed. In particular, RP54, RP55 and RP56 perform at the highest level, cannot accommodate development without serious harm, and therefore are inappropriate to be released for development. 4.13. At this point that Parish Council feels it should comment on the Strategic Housing Land Availability Assessment (SHLAA) carried out for the Borough Council. There are a number of inaccuracies in respect of the land at Barratt’s Farm. The SHLAA fails to record the listed buildings that are within site, and records the land classification as grade 5, whereas the area would appear to be grade 3 given the majority of Barratt’s Farm is growing wheat. Other land with much lower agricultural land classifications have b een rejected for development. This is contrary to Para 112 of the NPPF. In addition, whilst it might be presently true that the site has no bad neighbours, the site will be affected by the route of HS2. In combination these factors reduce the suitability of the site for development when compared to other locations.

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4.14. Finally, under this question the Parish Council wishes to express concern about the lack of firm proposals to establish long term and durable Green Belt boundaries. In addition the Parish Council is very concerned about the precedent which would be created for yet more development on the eastern, and south eastern side of Balsall Common, especially if a bypass is constructed on the alignment shown in the 2006 UDP.

16. Do you believe we have identified the infrastructure required to support these developments? If not why not? Are there any additional facilities you believe are required, of so what are they?

4.15. It is noted that the Draft Local Plan comments the “traffic associated with the HS2 Interchange site (and wider Hub area), and growth potential south of Coventry, especially when combined with the traffic generated from new housing in the area, is likely to have an effect on the A452 as it passes through Balsall Common. This is expected to justify the provision of an alternative route that could accommodate through traffic, and provide a basis for new residential developments to access the network in an appropriate manner. This alternative route will be pursued through the local plan review, although at this stage a specific line is not being proposed.” As already stated this statement greatly concerns the Parish Council which sees no need for a bypass, that it would in itself be harmful to the vitality of the village centre, and seriously prejudicial to the openness of the Green Belt, and to the character of the local valued landscape and to the attractive setting of the Balsall Common and other nearby settlements. Once again the Parish Council makes the point that there would be significant adverse cumulative impacts with new development and HS2. 4.16. The Parish Council submits that more limited development at Balsall Common would not require major new infrastructure provision. It therefore objects to the provision of a bypass, which is not required and should not be seen as a justification for unacceptable and inappropriate large scale housing development.

20. Do you agree with the policies for quality of place? If not why not, and what alternatives would you suggest?

4.17. In general, the Parish Council supports the Borough Council’s policies for quality of place, but it is disappointed that the Borough Council is not applying the principles and policies to the development of land to the east of Balsall Common. 4.18. Policy P10 states the Council will seek to protect, enhance and restore the diverse landscape features of the Borough. The proposed housing allocation 1 however does not comply with the policy and the objective behind it. 4.19. Further the Draft Local Plan expects developers to take the Landscape Character Assessment into account in locating and designing development. Yet the Borough Council ignores its findings when allocating the proposed housing at Barratt’s Farm.

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4.20. The Draft Local Plan notes that most of the undeveloped area of the Borough is designated Green Belt, including the strategically important open land between the urban areas of Birmingham and Solihull and the city of Coventry, known as the Meriden gap, and key gaps between urban areas and rural settlements. The Draft Local Plan states that protecting the Green Belt in Solihull will contribute to the purposes set out in the national policy, and that it is also vital for maintaining the attractive rural setting and environment. 4.21. In explanation to Policy P17, the Draft Local Plan comments that the Solihull Strategic Green Belt Assessment (GBA) demonstrates that the Green Belt in the Meriden Gap between Solihull and Coventry makes the most significant contribution towards the purposes of including land in the Green Belt. 4.22. The Borough Council however disregards the importance of the key part of the Meriden Gap between Balsall Common and Coventry but the allocation of housing at Barratt’s Farm. This allocation fails to meet national Green Belt policy and contrary to the assertions in the Draft Local Plan there are no exceptional circumstances to justify the release of the site from the Green Belt.

5. Conclusion

The Draft Local Plan is unsound and should be amended.

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Part 2 - Response to the Solihull draft plan covering issues other than site selection

This section of the Berkswell Parish Council response to the draft plan covers all issues relating to the Solihull Council consultation questions, based on the assumption that significant development is forced upon the Balsall Common area. This part of the Berkswell Parish Council response to the consultation is organised by recommendation/suggestion on necessary actions if development takes place. These actions are cross referenced to the 23 questions asked in the Solihull Council consultation document.

1. What needs to happen in Balsall Common to accommodate the growth. The proposed level of additional planned housing taken from today as a starting point is an additional 1350 (approx). This includes the 200 or so homes from the existing Kenilworth Road development and in Balsall Common centre which are under construction and the Hallmeadow Road site included within the 2012 plan. In addition there will be windfall homes built. Since the 2012 plan these have averaged about 10 per annum across the Berkswell and Balsall Parishes which if continued will take the total additional housing to around 1500 homes. This represents approximately 55% growth in Balsall Common over 16 years. This will place significant pressure on infrastructure including schools, highways, parking, community facilities and the capacity of Balsall Common centre to cope. It is recognised that additional housing might well help retain the vibrancy of the village centre but that benefit will not be realised without significant facilitating change.

2. Recommendation 1 – Balsall Common centre (questions 1, 7, 2 and 16) 2.1. We note that Balsall Common centre is omitted from the Challenges D – securing sustainable economic growth, (question 1), the Borough vision (question 2,), Sustainable Economic growth (question 7) and Providing homes for all supporting infrastructure (question 16) 2.2. Berkswell PC recommends that the improvement of Balsall Common centre should become a strategic objective for Solihull Council to 2.2.1. improve its dated centre, 2.2.2. increase its current parking capacity, 2.2.3. maintain its local importance. 2.2.4. Make it an attractive place to visit and thereby maintain its vibrancy into the future. 2.3. Balsall Centre must be added to the list of town centres that require a “Master Plan” (question 7) to define the nature, scope and timing of the improvements in 2.2 above. 2.4. The strategic nature of the increased housing being proposed for Balsall Common is not proposed to meet local growth needs but for Solihull Borough and the wider Housing Market Area. Therefore it is not appropriate to require that the improvement of the Balsall Common centre is an issue for a Neighbourhood Development Plan managed by the Parish Council’s when improvements to Chelmsley Wood, Solihull and Shirley town centres are regarded as strategic Solihull Borough issues. We also note that Solihull Council accept the responsibility for the development of other centres such as Solihull town, Shirley and Chelmsley Wood not expecting local Parish Council’s to pay for this through double taxation of the Parish precept. Given the scale of housing that the Solihull Plan is imposing on Balsall Common it is appropriate that Solihull Council takes action itself to ready the centre of Balsall Common for the additional people in the settlement. 2.5. The results of car parking capacity survey undertaken by the NDP Committee shows that the Balsall Common car parking capacity is close to its limit. (appendix 2)

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3. Recommendation 2 - Spatial Strategy (question 3) 3.1. Berkswell Parish Council supports the sequential approach to the use of land requiring the development of PDL/brown field land before Greenfield sites and Greenfield sites outside the greenbelt before greenbelt. 3.2. This is in accordance with the NPPF. 3.3. However, we note that this is not the approach adopted in the Balsall Common area for the draft plan where no PDL land has been included within the proposed sites. We note that no explanation has been given for this breach of policy and one should be provided with specific relation to the Balsall Common area. 3.4. We also note that the plan fails to meet several areas of the NPPF with respect to the greenbelt changes 3.4.1. Paragraph 82 3.4.2. Paragraph 83 3.4.3. Paragraph 84 3.4.4. Paragraph 85 3.5. Berkswell PC strongly urges that Solihull Council conforms to all aspects of the NPPF when developing its Plan or provide a detailed explanation for the divergence from the NPPF. 3.6. We note that Solihull Council have not provided the criteria by which sites have been selected and the weight given to those criteria. We note various tables of numbers against criteria but there is a disconnect between those numerical ratings and the sites chosen. 3.7. There is no evidence that Solihull Council have used the site selection criteria proposed by the NDP Steering Committee which were derived following detailed consultation with the local community and sent to Solihull Council is early September 2016.

4. Recommendation 3 – Berkswell Station Car Parking (question 16) 4.1. The current car parking at Berkswell Station is overloaded with typically between 20 and 40 cars parked most days Monday to Friday on Hallmeadow Road. The peak number of parked cars on Hallmeadow Road counted and declared by residents to the Parish Council is 43. A short survey was conducted during w/c 6th February 2017 to verify this with data and the results of this are shown in appendix 1 with photographic evidence plus one random day in November 2016 where a photograph was taken to evidence the issue to HS2 Ltd. 4.2. With the additional housing proposed, much of it in excess of Solihull’s policy of 15 minutes’ walk we can expect significant increase in station users driving to the station. Any proposal to use Hallmeadow Road as a bypass/relief road will displace the current overflow parking but there is no obviously safe location for it to go. 4.3. The Solihull Plan must provide additional car parking or accept this as a constraint on housing to be built in Balsall Common and reduce the proposed numbers. This is particularly important given that the station will be well in excess of 400 metres from many of the new homes proposed for Balsall Common in the draft plan.

5. Recommendation 4 - Bus and Train Services (Question 18) 5.1. We support Policy 7 concerning access to public transport. We note that for developments of over 100 homes that a 30 minute bus service, evenings and weekends shall be provided within 400 metres and for other developments a 30 minute day time service. We do not support the reduction on bus frequency from 15 minutes with respect to bus frequency within Policy 7 and see no objective justification for it if the purpose is to achieve a reduced dependency on cars. We also do not support 19 | P a g e

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the change from a “walking distance of 400 metres” to “ a distance of 400 metres”. That is illogical. A radius of 400 metres could result in walking distances of many times 400 metres. The Policy should state “Walking distance“ and not “distance”. In addition we note that this change in Policy was not consulted upon in any meaningful manner and that consultation took place after the sites were selected. 5.2. We note that for Balsall Common there is not a 15 minute bus service during the day and no evening service. This makes daily commuting by bus impractical. The lack of an evening service presents major problems for our young people visiting evening facilities that are typically enjoyed by most young people e.g. cinema, sports centres etc. It also makes adults dependent upon cars for their travel to evening entertainment which is non-sustainable and for many activities inconsistent with the drink driving laws. We recommend that Solihull Council either implement a bus service of frequency prescribed by Policy 7 for Balsall Common now or do not build more homes in Balsall Common because such building would be non sustainable according to Policy 7. 5.3. We support Policy 8 about managing car usage and encouraging the use of public transport. This is critical to sustainable development. We note from Solihull Connect that Balsall Common (the rural east) has amongst the highest car use in the Borough. This is because Balsall Common is a non sustainable location with respect to housing development given that it fails to meet the provisions of policy 7 and any development on the greenbelt must be shown to be sustainable. 5.4. We note the objective of 50% affordable housing. Such housing tends to be more reliant on public transport. A failure of the provision of public transport in accordance with Policy 7 in Balsall Common is incompatible with the 50% affordable housing objective. 5.5. We recommend that the Solihull Plan either significantly reduces the level of housing and/or affordable housing targets proposed for Balsall Common or the public transport provision must be radically improved to meet the requirements of Policies 7 and 8. The Solihull Connect transport policy has no improvement shown for bus or rail transport for Balsall Common. A realistic plan for how this improvement in public transport is to be achieved must be included in the Solihull Housing Plan. Without it there is no justification for the proposed level of housing expansion in the Balsall Common area.

6. Recommendation 5 – Other infrastructure/facilities/Health & Supporting Local Communities (Questions 16 and 21) 6.1. We strongly support the inclusion of Concept Plans within the Solihull Plan for all large development. For proposed housing allocations 1 and 3 the following should be included within those Concept Plans 6.2. Significant green parkland/infrastructure both to meet the needs of the new development but also the loss of the significant footpath network on Barratt’s Farm (allocation 1) should be included within the Concept Plan. These footpaths are extensively used at all times of the year often in conjunction with the greenway by walkers, dog walkers and runners. The loss of these footpaths will be a major loss to the community and must be compensated for with extensive green infrastructure providing long walks as well as play areas for children. This meets Policy 19 and 20. This green parkland should 6.2.1. Retain all existing hedgerows, ponds, connecting ditches, trees etc to maintain as much of the current wildlife habitat as possible 6.2.2. The brook on Barratt’s Farm, which is a tributary of Bayliss , should be retained and enhanced as part of the green infrastructure. The brook not only drains Barratt’s Farm area but also land from Waste Lane and Old Waste Lane.

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6.2.3. All such green space should be linked in a meaningful green manner to retain “connectivity” to foster biological diversity and a conducive environment for wildlife development and retention. 6.3. In addition, to green parkland any development should retain all specimen trees of around 100 years and older and all existing woods/spinneys should also be retained as green infrastructure for wildlife. The areas should be surveyed urgently and specimen trees and woods/spinneys included in the Concept Plans. 6.4. Wide substantial green gaps or tree belts between existing any new homes to protect the amenity of current residents and encourage acceptability of the Solihull Plan housing proposals for Balsall Common which are the most significant increase of any proposals within the borough. 6.5. The provision of safe access that does not interfere with other residents must be planned and included within Concept Plans. Unacceptable access routes include the following and must not appear in the concept plans. 6.5.1. Oxhayes Close . This cul-de-sac is narrow with sharp right hand bend at its midpoint. The road is used for resident parking making it only one car wide. 6.5.2. Meeting House Lane. This is a relic of a narrow country lane and for most part without pavements. It is used as a pedestrian route by those from south Balsall Common going to the shops. It is also used by school children. Observation shows that it already used as a commuter rat run at peak times. 6.5.3. Barratt’s Lane. This is a narrow road which gives onto Barratt’s farm travelling via the Sunnyside Housing Estate. It has a pavement down one side and is used, particularly in the summer, by school pupils to get to the schools by walking across the playing fields next to the Catholic Church on Meeting House lane. Access to Barratt’s Lane is also very limited for HGVs and/or a significant volume of cars due to the restrictions on Sunnyside Lane. 6.6. No access road should simply connect Waste lane with Station Road. This will encourage rush hour rat running down Windmill Lane by cars held up on the A452 by the traffic lights at Kelsey Lane. The junction of Windmill Lane and Waste lane has poor sight lines. The road traffic signs at the junction of Windmill Lane and the A452 were removed some time ago discouraging vehicles on the A452 turning into Windmill Lane. 6.7. No access should be provided from any development onto Windmill Lane. This road is narrow, with a difficult junction with Waste lane as detailed above and no footpaths for safe pedestrian access to Balsall Common. This should be included within the Concept Plan 6.8. We note that the draft plan recognises the need to provide additional schooling. 6.8.1. The location of new primary school facilities will need careful planning to avoid the car parking/congestion issues that plague both Berkswell and Balsall Common primary schools and should be included in the Concept plan. 6.8.2. The NDP Committee was advised by the Heart of England School that only half of current students come from Berkswell or Balsall Parishes. The remaining students come from Coventry, Marston Green, Meriden etc. This importing of students, often by car, adds to congestion and is non sustainable on terms of Policy 8. In considering secondary school provision the application of Policy 8 should form part of the considerations. 6.9. In Berkswell Parish Council’s submission in response to the Policy and Options document we detailed with photographs flooding issues at the Station Road underpass at Berkswell Station. These are caused by water flowing down the Baylis Brook from the flood plain on Barratt’s Farm. The additional run off from HS2 will add further water to this area. Whilst HS2 balancing ponds will help control the flow, the additional hard standing of HS2 will reduce the capacity of the ground to absorb water. The building

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of homes on Barratt’s Farm will significantly increase hard standing adding to flood risks at the underpass. A comprehensive plan to prevent this will need to be included within any development of Barratt’s Farm.

7. Recommendation 6 – Inset Study (questions 1, 2, 16) 7.1. The scale of change facing Balsall Common is potentially overwhelming. It will turn a village into a town. This will bring unprecedented challenge in terms of schools, highways, the need for public recreational facilities etc. To expect a Neighbourhood Planning Process to cope with this scale of change would be beyond almost all Parish Councils. We recommend that a holistic study of Balsall Common is undertaken to provide a blueprint for all of the change so that it conflicts between objectives are avoided and the benefits of development are realised without avoidable overloading or damage to the community’s social and physical infrastructure. 7.2. We understand that such a study is called an “Inset Study” and should be undertaken in consultation with the local community but brings the expertise of Solihull Council to promote a high quality of place (Policy15)

8. Recommendation 7 - Sustainable Economic Growth – Question 4 & 6 8.1. Berkswell Council supports Policy 1 and 1A. But believes that planning rules should be used to discourage distribution or warehousing in UK Central because of the negative impact this will have on the roads of the area. Development should be focused on high productivity, high talent enterprise c.f. the existing importance of Land Rover and Consulting companies such as Ove Arup.

9. Recommendation 8 - Providing Homes for all – Question 11 9.1. Balsall Common has an aging population with many homes under occupied by old people. There is a shortage of Bungalow and other single story accommodation with gardens that are attractive to older residents without children living at home. 9.2. Similarly, some groups of younger disabled people require single story accommodation 9.3. Both groups are covered by the Disability Discrimination Act if they cannot perform a normal day to day activity. Climbing stairs is such a normal day to day activity and hence the Disability Discrimination Act applies. 9.4. It should be also noted that simply providing flats for those unable to climb stairs could be seen as indirectly discriminatory because the people involved could be prevented from enjoying private outdoor space. 9.5. A survey of the need for such accommodation should be undertaken and the needs reflected the housing mix policy.

10. Recommendation 9 - Delivery and Monitoring – Question 22 10.1. Berkswell Parish Council supports the general approach to Policy 21. However, the Policy allows for the diversion of funds away from areas with development to other areas of the Borough. This is unjust and must not be permitted. The basic principle should be that all funds raised by development should be spent in the area where they are raised “except in very exceptional circumstances”. An exceptional circumstance would only exist where the money being spent out of the areas taken housing provides clear and obvious benefit to those in the area taking the housing.. 10.2. Within this context such funds include all section 106 payments, all CIL monies, all new Homes Bonus and profit from the sale of Solihull Council land for development.

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10.3. Given the scale of proposed development and the infrastructure issues facing Balsall Common Berkswell Council considers this approach proportionate. Policy 21 should be modified to prevent the diversion of funds from those areas taking housing “except in very exceptional circumstances”.

11. Phasing of House building 11.1. We note that the proposed phasing for Barratt’s Farm is over all 3 phases from year 0 to year fifteen 11.2. We note that the construction of HS2 in the Balsall Common area is planned for 2017/8 (start) to 2025/26 finish. The construction of HS2 is adjacent to the Barratt’s Farm development and will use the same roads for access: Hallmeadow Road, A452, Kelsey/Waste lanes. Such concurrent mass development is in reality inconceivable in logistical terms. 11.3. Coupled with the overflow car parking issues on Hallmeadow Road highlighted in appendix 1, this could cause significant logistical/congestion issues 11.4. It is recommended that further in depth study and thought is given to this issue including how in reality the scheduling of the construction of HS2 and housing will be planned and how it will in reality work. A failure to manage the interface with HS2 construction programme could significantly impair the deliverability of the Barratt’s Lane site

12. Balsall Common bypass 12.1. Berkswell Parish Council is not against a bypass in principle but considers that any bypass must meet the normal national traffic flow/congestion criteria for justifying the building of a bypass. 12.2. The 2012 Solihull Plan concluded that there was no objective highways/traffic justification for building a bypass and the bypass line was removed from the Plan. 12.3. Berkswell Parish Council is not aware of any updated traffic projections that change the 2012 decision to remove the bypass line from the Plan. We have asked for such information from Solihull Council and it has not been produced. 12.4. The HS2 Ltd environmental statement states that the operation of the new railway will not result in any significant change in road use. Hence, HS2 cannot justify a bypass. 12.5. Berkswell Parish Council considers that the justification for a bypass should stand on its own merits. The Council considers that allowing housing to be built on greenbelt as a methodology for financing a bypass is an illegitimate breach of greenbelt policy as defined in the NPPF. 12.6. The draft plan states that no line for the possible bypass has been defined. However, at the Balsall Common SMBC consultation forum/exhibition on 7th January 2017 officials indicated the intention to use Hallmeadow Road. 12.7. Our residents are very concerned at any proposal which transfers traffic from outside houses on the Kenilworth Road to Hallmeadow Road without compensation for those residents who will be impacted by the change. Homeowners on Kenilworth Road bought their homes in the full knowledge that their homes were situated on a national trunk road. That is not the case for those facing Hallmeadow Road. 12.8. Further factors that must be considered are 12.8.1. Full consideration needs to be given to how the three current access points on that road will be integrated safely onto the new bypass (namely Riddings Hill Road, Grovefield Crescent and the access road to the Medical Centre/ housing site allocation 19 in the 2012 Plan. 12.8.2. Noise mitigation arrangements must be put in place through a mixture of low noise tarmac for tyre noise and where appropriate noise bunds for engine noise. Engine noise, particularly

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from HGVs, is likely to be an issue given the incline on Hallmeadow Road and the multiplicity of junctions/roundabouts required by the current entrances onto this road 12.8.3. Additional car parking must be provided at the station given that Hallmeadow Road is currently an extensive overflow car park as evidenced by Appendix 1.

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Appendix 1- Photographs showing overflow Station Parking on Hallmeadow Road

th 30th November 2016 20 parked cars 8 February 2017. 20 parked cars/vans

th 6th February 2017. 21 cars parked 9 February 39 parked cars

7th February 2017. 31 cars parked 10th February 2017. 11 parked cars

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Appendix 2 - Results of 2015 Car Parking Survey The survey was conductedin 2015 whilst the private Partco car park was open and used (without authority) by mororists. This car park is no longer available as homes have been built upon it. In addition the pedestrian access between the Coop car park and Balsall Common centre has now been closed. This has severaly restricted the ability of users, to park in the Coop car park and visit the shops on Station Road shopping precinct.

The two graphs below show the results of the vacant spaces survey in two forms. The first assumes that there is no direct pedestrian access between the Coop car park and the shopping centre. (the current situation) and if that connectivity is restored.The second assumes that this connectivity is available.

Vacant car parking spaces Balsall Common excluding Co-op Excludes Co-op and assumes all Partco parking is distributed into Station Road/Library car park

90 80 70 Line of best fit 60 50 40 Without Co-op and Partco 30 8% of time there would be no vacant parking places

20 Raw data Vacant spaces Vacant 10 0 -10 -20 2 12 22 32 42 52 62 72 82 92 % of time

Vacant car parking spaces – Balsall Common Centre (assumes Partco not available and cars in Partco redistributed to legitimate spaces) 173 legitimate spaces in Library car park, Station Road, Coop, Barclays and Motorists shop.

140

120 Line of best fit 75% of time 100 43 spaces available 25% unoccupied 80

60 Raw data

Vacant spaces Vacant 40 90 %of time 20 32 spaces available 18% unoccupied 0 2 12 22 32 42 52 62 72 82 92 % of time

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Appendix 3 – Greenbelt analysis by land parcel

Refined Parcel RP52

GBA Comment BPC Response GBA Score BPC Score

Purpose 1: To check the unrestricted sprawl of large built-up areas.

The boundary of the Refined Parcel RP52 is weak This is an important open area mainly used for 2 2 and dissects gardens of residential properties playing fields and recreation purposes. The along Kenilworth Road north of Lavender Hall parcel is defined by the railway line and existing Lane. Eastern boundary is far stronger being development, and is affected by roads. formed by the railway line. Boundary to the Nevertheless, it is important that the area is not south is formed of well-established hedgerows developed in order to provide sporting and and tree lines. No development is present. leisure facilities for local residents and to act as a green transitional wedge. The railway is in cutting and development would be seen as further sprawl.

Purpose 2: To prevent neighbouring towns merging into one another.

Refined Parcel RP52 forms part of an The parcel is approximately 1.0 kilometre from 2 3 approximate 1.3 kilometre gap between Balsall the edge of the village of Berkswell and the Common and Coventry to the east. designated conservation area. The intervening land (excluding the railway line) is largely free of existing development. Built development on the parcel would lead to coalescence.

Purpose 3: To assist in safeguarding the countryside from encroachment.

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Refined Parcel RP52 forms a wedge between the Development on the parcel would be seen as an 2 3 existing development of Balsall Common, A452 encroachment into the countryside on the north and rail line. It’s mainly open parkland with eastern side of Balsall Common toward patches of woodland and adjoining open Berkswell. It performs an important purpose in countryside to the north. safeguarding the countryside.

6 8

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Refined Parcel RP53

GBA Comment BPC Response GBA Score BPC Score

Purpose 1: To check the unrestricted sprawl of large built-up areas.

Development is already present within Refined RP53 is an artificial construct including land on 1 2 Parcel RP53 along Hallmeadow Road and Station both sides of Station Road and is not a logical Road which is detached from the main built-up parcel. Housing is already committed at Riddings area of Balsall Common. Hill on the North side but the south side only has ribbon development around Barratt’s Farm and protects against sprawl Purpose 2: To prevent neighbouring towns merging into one another.

Refined Parcel RP53 forms part of an The bigger portion of this land included current 2 2 approximate 3 kilometre gap between Balsall and projected areas for housing. The north Common and Coventry to the east. eastern section is mainly PDL land between Hallmeadow Road and the rail line of no greenbelt value with some tree belt screening the rail line in parts. The Southern part beyond station road is part of Barratt’s Farm which has significant greenbelt value. Purpose 3: To assist in safeguarding the countryside from encroachment.

Refined Parcel RP53 forms a wedge between the This criteria highlights the artificial nature of 2 2 existing development of Balsall Common and rail RP3. The northern and southern parts are split by line. It’s mainly covered in woodland and Station road. The main value of this parcel lies in adjoining open countryside to the north. its southern part beyond Station Road where it helps protect Barratt’s Farm and provides public footpath access to that large area of green belt. 5 6

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Refined Parcel RP54

GBA Comment BPC Response GBA Score BPC Score

Purpose 1: To check the unrestricted sprawl of large built-up areas.

Other development is present along the The development on Station Road does not fall 1 3 northern edge of Refined Parcel RP54 along within the RP. The RP is free from development Station Road which is detached from the main (other than farm buildings). This is an important built-up area of Balsall Common. area of open countryside on the eastern side of Balsall Common. It contributes greatly to the control of sprawl and performs a highly important purpose, which is not compromised by the development on Station Road. The whole of the RP should properly be within Broad Area 4.

Purpose 2: To prevent neighbouring towns merging into one another.

Refined Parcel RP54 forms part of an The area between Balsall Common and the 2 3 approximate 3 kilometre gap between Balsall western side of Coventry is part of the vital Common and Coventry to the east. strategic Meriden Gap. The Gap is at its narrowest with only approximately 1.6km between the built area boundary of Balsall Common and the urban development on the south western side of Coventry. Retention of the open land is of critical importance bearing in mind the existing development in and around Carol Green, Beechwood, along Duggins Lane, and at Catchems Corner. Further the area will be severely affected by the line of HS2.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Purpose 3: To assist in safeguarding the countryside from encroachment.

Refined Parcel RP54 is adjoined by countryside There is no development present in the top right 2 3 to the north and east, and is made up of corner of the RP. Even if there were it is agricultural fields. There is very limited inappropriate to allow any such development to development present in the top right corner. influence the scoring. The RP is made up of agricultural fields, across which there is a network of very well used public rights of way. From these rights of way the character and feeling of the area is very much of being within the countryside. As a whole the parcel is not adversely impacted upon by the existing development to the north, west and south. Further the topography of the land allows extensive views across the parcel and surrounding countryside. The RP is part of the vital strategic Meriden Gap and performs highly across this purpose of the Green Belt. 5 9

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Refined Parcel RP55

GBA Comment BPC Response GBA Score BPC Score

Purpose 1: To check the unrestricted sprawl of large built-up areas.

The boundaries of Refined Parcel RP55 are The RP is an important section of open land 2 3 relatively clear to the eastern edge of the parcel between the existing development on the and are made up of established field patterns northern side of Kelsey Lane and that on the with established hedgerows and tree lines. northern side of Old Waste Lane. Release of this Parcel boundaries to the west of the parcel are parcel of land separately or together with RP54 less clear and are formed by gardens at the rear would lead to the merging of existing ribbon of residential properties along B4101 Kelsey developments and adversely impact on this Lane/Waste Lane. purpose of the Green Belt.

Purpose 2: To prevent neighbouring towns merging into one another.

Refined Parcel RP55 forms part of an At this point the gap between the built-up area 2 3 approximate 3 kilometre gap between Balsall of Balsall Common and the western side of Common and Coventry to the east. Coventry is around 1.6km, less if the housing facing Old Waste Lane is taken into account. Within the gap there is other existing development but this makes it even more important not to allow further housing. The gap will be severed and adversely impacted by the line of HS2. The RP highly performs against this purpose of the Green Belt.

Purpose 3: To assist in safeguarding the countryside from encroachment.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Refined Parcel RP55 is adjoined by countryside For the reasons given in connection with 2 3 to the north and west, and is made up of purposes 1 and 2 the RP is important to protect agricultural fields. There is very limited the countryside from further encroachment. development present in the south.

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Berkswell Parish Council PO Box 6379, Coventry, CV6 9LP

Refined Parcel RP56

GBA Comment BPC Response GBA Score BPC Score

Purpose 1: To check the unrestricted sprawl of large built-up areas.

Other development is present within Refined Windmill Lane forms a permanent and 1 3 Parcel RP56 including caravan storage along Hob substantial physical feature and should be Lane which is detached from the main built-up considered to be the eastern boundary for area of Balsall Common. further development in the area. The existence of caravan storage is a reason to resist further development in the RP, not to encourage it. This is a particularly vulnerable section of the Green Belt and the RP performs an important function in preventing coalescence.

Purpose 2: To prevent neighbouring towns merging into one another.

Refined Parcel RP56 forms part of an The RP is within a narrow 1.6km gap between 2 3 approximate 2 kilometre gap between Balsall Balsall Common and urban development to the Common and Coventry to the east. SW of Coventry. It is vitality important that it is retained.

Purpose 3: To assist in safeguarding the countryside from encroachment.

Refined Parcel RP56 is adjoined by developed The existence of development is a reason to 1 3 area and it has been largely developed. There resist further encroachment into the are both employment and residential uses countryside. The RP plays an important function present. in this respect.

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