FAO Lawrence Osborne
Solihull
MBC
Planning
Services
P
O Box 11652
Solihull
West
Midlands
B91 3YA
8th March 2011
Dear
Mr Osborne,
Planning
Application Ref: 2011/154 - Moat House
Farm, Elmdon Road, Marston Green
Proposal:
To erect 125 no. dwellings with associated car parking, access, infrastructure
provision and open space
I am writing to advise you of
the views of Bickenhill Parish Council on the above
planning application which is currently before the Council for consideration
and in which members have taken a close interest. The Parish Council wish to
make a number of comments and observations which we ask be
reported to the Planning Committee when the application comes before them for
decision.
However the Parish Council will
preface those with a number of important background points that we
wish to draw to the Council’s attention.
Bickenhill Parish
Council has undertaken a community wide consultation in Marston Green in respect
of the Council’s Emerging Core Strategy. A copy of the community questionnaire
is attached. In our letter to the Council of 4th January 2011 a copy
of which is also attached, we set out the results of that consultation,
together with the Parish Council’s comments on the various policies and other
matters in the Consultation document.
Bickenhill Parish
Council has produced a summary leaflet of the views of those Marston Green
residents who responded to us and I attach a copy of this for your attention.
We ask you to note particularly the following – that new housing should be
directed elsewhere rather than in Marston Green; that it should meet the needs
of the local community rather than any wider demands of Solihull or beyond;
that housing should be mainly for older people; and the concern about issues of
parking in the village centre and the current severe pressure on schools and
doctors serving the community.
It is important to note in
respect of the first point that the Parish Council are reflecting the clear policy
thrust from Central Government in that it is consulting with the local
community in developing a future set of policies and proposals for Marston
Green that will reflect local views. The current Localism Bill seeks to
empower communities to do things their way – by creating
rights for people to get involved with, and direct the development of, their
communities.
On that theme, last autumn the
Parish Council, with other resident groups in the community, embarked on the
preparation of a Community Plan for Marston Green – again following in the
light of government principles outlined in the Localism Bill, currently going through Parliament. That work had been put on
hold temporarily while views were being obtained to inform the Parish Council’s
response to the Emerging Core Strategy, work is now proceeding on the Community
Plan. The Localism Bill is intended to radically
reform the planning system to give local people new rights to shape the
development of the communities in which they live, and the Community Plan for
Marston Green which is being prepared is intended to do that.
Turning now to the application
itself, the Parish Council’s concerns are grouped under a number of headings.
Principle
of Development – We
recognise that the application site has been identified as a possible long term
housing site for a number of years. While the first tranche of Moat House Farm
was developed some years ago, this second part was intended to be released only
as part of the development plan process.
The Council has yet to produce
its Preferred Strategy which will follow on from the Emerging Core Strategy, consultation
upon which has only recently ended. As we understand it, the Preferred Strategy
will then have to be subject to proper formal scrutiny, which, on the present
timetable, will not be until at least 2012. If it has to be developed, the Moat
House Farm site is not scheduled in the Emerging Core Strategy to be released
until 2016, so that any development now is clearly premature.
The Solihull Housing Market Assessment
(EOTEC, 2009) places the Bickenhill
Ward – which includes Marston Green - in the wider Rural Area rather than the
Urban Area West or Regeneration Area to the north. Erroneously both the
Developer in his planning submission, and the Council in their list of
suggested release of long term housing sites in the Emerging Core Strategy, put
Moat House Farm and Chelmsley Lane/Bickenhill Road sites in the Urban West area, not in the
Rural Area which the evidence base, and hence the need for new housing, should
be so assessed.
Having regard to that correct
interpretation of the evidence base, it is the view of the Parish Council that
if there is a proven need for more affordable housing to meet the needs of Solihull’s
Rural Area then the Council should look to other sites more closely related to
that area – such as Knowle, Dorridge,
Balsall Common or Meriden - rather than Marston
Green, which is on the very northern fringe.
Alternatively, if the justification
for release of the Marston Green sites is based, wrongly in our view, on the
perceived needs of Chelmsley Wood, then the Council
have already indicated that they are looking to release two sites in the North Solihull
Regeneration Zone. The Moat House Farm site itself is well beyond the southern
fringe of the Regeneration Zone in the rural market housing assessment area,
and its release is thus not justified on that account.
Moreover, the Council has
clearly indicated that there is to be a further review of the north Solihull
Green Belt which may look at other sites that might be suitable for release for
housing. Parts of two sites (184/185)
close to the centre of Chelmsley Wood have been
indicated for release in the Emerging Core Strategy, and the Parish Council
believes that release of further parts of those sites could also be considered.
In terms of their Green Belt
function, those sites do not measure up to the quality and importance of the Moat
House Farm site which should be considered for reinstatement to Green Belt in
that review. It has far greater merit for retention free from development that
the other sites, and is not previously developed land. Its release should not
be considered in front of other sites which might better meet the planning
preference for using previously developed land.
Solihull Council has made it
clear in the Emerging Core Strategy that no decision has been taken on the
future allocation of any of the long-term housing sites, although eight of the
long-term housing sites are suggested for allocation for phased release in
Policy 4 of the Emerging Core Strategy, including Moat House Farm. The Parish
Council consider that having regard to all of the above, there is no convincing
case for release of the Moat House Farm site either now or in the future as it
would be both unnecessary and premature, and should be reinstated to Green Belt.
With the impending development
of the Chelmsley Lane/Coleshill
Road site, and all the recent housing development in Marston Green, the Parish
Council consider that the community has absorbed as much as it can, and the
serious consequences on services and functioning of the village can readily be
seen.
Housing
Mix –
Notwithstanding the above concerns, and having
regard to the clear views of Marston Green residents in our very recent
consultation, the application proposals do nothing to meet the local needs of
Marston Green or offer the sort of accommodation that would enable Marston
Green residents to stay within the community for all of their lives.
Density
– The
125 dwellings proposed would result in a density of 44dph,
well above the former minimum density that had been required under PPS3. The density requirements have now been abandoned by
Government, and there is no justification for such a high density unrelated to
the pattern and density of existing development around.
Noise
– The
site is adjacent to the West Coast main line, and close to Birmingham International Airport. The site falls into
Noise Exposure Category B (Day and Night) in relation to Birmingham
International Airport whereby conditions should be imposed to ensure an
adequate level of protection against noise. The application is supported by a
Noise Assessment which suggests that the impact of both noise and vibration
from both sources can be mitigated. However the Parish Council consider that
this impact is understated and that the Council should undertake a thorough
independent assessment to establish the impact and the appropriateness of new
housing in this location.
Impact
on Community Services – Again in the light of the views of
residents recorded in our recent survey, the existing primary schools, and
doctors’ surgery are experiencing severe pressure, and the Parish Council
believe that any further housing development will exacerbate present problems.
Developers should be required to fund practical and proper improvements of all those
facilities if development is allowed.
Traffic
– The
development would be served via two existing access ways through the adjoining
estate and via Elmdon Road linking to the village
centre. Additional traffic would impact on the existing housing alongside those
accesses, on Elmdon Road which is already congested
at times with kerbside and pavement parking, and on the junction of that road
with Land Lane. If blocked by any incident, that junction effectively cuts off
a number of housing estates to the south and east from access by any motor
vehicle including emergency services.
Parking
–
The recent residents’ survey has highlighted the major local issue of lack of
parking space in the village centre that further development will only exacerbate.
The distance of the proposed housing from the village centre, schools, station
and main bus services will inevitably lead to occupiers of the new housing
using cars to travel to the centre where there is nowhere to park.
Flooding
– The
site is prone to flooding and lies within the floodplain of the Lowbrook. The Parish Council believe that the Flood Risk
Assessment understates the likely impact of development on flooding further
along the course of the stream, and the risk that the site itself will remain
waterlogged after development.
Other
layout issues –
There are a number of ‘no man’s land’ areas in the layout that will become
areas where no maintenance will occur in the long term. The layout allows for
further land adjoining to the north and east to be added as further housing development in due course. The central
open space is dominated by large trees which should be protected and retained,
but their presence leaves little effective space for children to play games.
History
and Ecology of Site – Moat House Farm is mentioned in the
Doomsday Book and has elements of ridge and furrow remaining. This historic
site is far more important locally than the developer is suggesting in his
submission. It also has significant ecological interest which should be
investigated further by independent assessment.
Statement
of Community involvement – The applicant has submitted a Report that
seeks to relate the comments made by local residents at an event that the
developer held in June 2010. The Report merely relates the responses to the
questions that the developer posed in his questionnaire. Little is mentioned of
the many letters of objections sent to object to the very principle of
development of the site.
In conclusion the Parish
Council believe that it would be wholly wrong to approve this application having
regard to the above matters. Continuing work on a Community Plan for Marston
Green will allow proper consideration of many of these matters and the future
of development in the village to be influenced by the community itself, in line
with the clear thrust of Government policy.
Yours sincerely
Mrs Carole M Cox
Clerk to Bickenhill
Parish Council
Cc: To Ward Councillors