The representations of the Knowle Dorridge and Bentley Heath KDBH) Neighbourhood Forum (NF) to the 2016 DLPR raised objections, inter alia, on the basis that;
* The Council's spatial strategy is not clear or coherent.
* There were inconsistencies in the site selections with the Spatial Strategy, the Strategic Transport Strategy and with the Council's own evidence base, particularly the Landscape Assessment, the Interim Sustainability Appraisal and the Green Belt Assessment.
* There was inadequate consideration of infrastructure impacts, particularly traffic impacts.
These comments still apply. In addition:
Spatial Strategy: The Supplementary Update does not revisit the Spatial Strategy. Both the HMA shortfall contribution and the alternative considerations raised by the Strategic Growth Study necessitate revisiting the Spatial Strategy. It is unacceptable to leave these fundamental issues to the Submission stage.
The Spatial Strategy and the site hierarchy assessment (at Appendix D) refer in places to sites in KDBH being consistent with Option G of the Spatial Strategy. However, this Option was one of the worst performing in the Interim Sustainability Appraisal. It is not clear which of the Options is the basis of the Spatial Strategy - it appears to be a mix of all the Options with no clear approach. Notwithstanding this, the aim of the Spatial Strategy is to ensure a sustainable pattern of development and to protect the character and distinctiveness of the Borough. This is inconsistent with the proposed scale of growth in KDBH.
There is no change in the assumption that the Local Plan will make a 2000 house contribution to meeting the HMA shortfall. This will not be reviewed until the Submission version of the DLP. It is widely believed that the Council will have to increase this number which could have significant implications for the overall Spatial Strategy. At present it appears that the Council is considering the amber sites as possible further releases. However, bearing in mind the flaws in the Spatial Strategy outlined in the previous response of the Neighbourhood Forum (NF) it is even more important to revisit the Spatial Strategy should the HMA number increase. Simply adding more amber sites will not provide the strategic approach that is necessary.
Methodology: There are flaws in the methodology and in the application of the methodology.
Step 1 of the hierarchy identifies those sites with a score of 1 to 4 as green. However, the Step 2 diagram appears to concentrate on refining only the yellow and blue sites. This is confirmed in para 68 which says that Step 2 is principally concerned with confirming whether the yellow and blue sites should be reallocated in the hierarchy. This suggests that if a site is assessed as green in Step 1, there is no proper assessment of how such sites fit with the overall spatial strategy or of site constraints.
The methodology gives insufficient weight to the impact and mitigation of site constraints, particularly in respect of 'green' sites. Step 2 must apply to all sites and should be given equal weight to Step 1 as compliance with strategy and the assessment of constraints are of vital importance to the assessment of all sites.
There are significant inconsistencies in the application of the methodology which undermine the integrity of the whole selection process. The following are a few examples where further explanation of the conclusion of the assessment process is required:
* Arden Triangle sites (nos. 148, 149, 150,151,152,153 and 154 and 157 excluding the Academy site) all appear in Appendix D to score 6 in step 1 and be assessed as blue (ie 'unlikely allocations') but are then assessed as green via Step 2. Without sight of impacts and proposed mitigation, it is not possible to understand how these sites fall into the green category ie that they have no or relatively low impact on relevant considerations; or that severe impacts can be mitigated. Such information is essential to enable residents and businesses to make informed responses to this consultation.
* Further apparent anomalies within the Arden Triangle include parcel 148 Lansdowne, assessed as medium/high accessibility and parcel 157 Land east of Knowle forming part of the Arden Triangle assessed as very high accessibility. Similar issues arise in the Interim Sustainability Appraisal in which the Arden Triangle is assessed as highly positive in terms of proximity to buses and trains and to convenience stores, positive in terms of healthcare and leisure, and neutral in relation to landscape. However, most of the Arden Triangle site lying beyond the Academy is not easily accessible and has valued landscape characteristics as demonstrated by both the Council's Landscape Assessment and the Landscape Study commissioned by the NF.
* Site 213 north of Hampton Rd is assessed as blue in Step 1 and then becomes green, despite performing highly in terms of purpose 1 of Green Belt. It is also assessed as having medium/ high accessibility even though there is no bus service and large parts of the site are a long walk from the High St. The other two northern parcels (sites 214 and 215) are assessed as red ie not suitable for development although they would become the site of the sports hub development.
* Yet further questions arise in respect of Site 244, part of Copt Heath Golf Course, which is only assessed as medium accessibility despite being close to a bus route. It is assessed as yellow in Step 1 but is red after Step 2: Jacobean Lane sites 323 and 324 score reasonably well but one is red and the other amber: and site 413 Land at Oak Green, Dorridge performs well with high accessibility but is assessed as amber.
These are a few examples which aim to demonstrate the point that many if the sites around KDBH have very similar scores but vary considerably in their assessment as green, red or amber. A clearer explanation is required of the assessment process to justify the draft allocation sites. Without this, the credibility and robustness of the process is undermined.
It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. The Strategy continues to focus only on large scale Green Belt releases around KDBH which is not consistent with government advice that a mix of sites should be encouraged. Some of the smaller sites should be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character.
Infrastructure impacts and mitigation. See answer to Q22, 23, and 24