Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 6693

Received: 14/02/2019

Respondent: Gillian Griggs

Representation Summary:

The Council has identified most of the infrastructure requirements for the KDBH Area but only in vague terms with no information on how such needs can be met or consideration of whether such development will be harmful to the settlement. Concern that bus improvements will not be viable. Impacts on doctor's surgeries, pre school facilities and the capacity/parking at Dorridge Station should be included. Unclear whether new primary is replacement or new facility.
Supportive of Concept Masterplans, affordable housing. The limited benefits and lack of evidence on infrastructure impacts and mitigation is a serious omission.

Full text:

Concerns about the capacity of existing infrastructure and the additional pressure that large scale new development would place on it was one of the top issues raised by residents during the Knowle Dorridge and Bentley Heath (KDBH) Neighbourhood Plan (NP) process. This was reflected in the Neighbourhood Forum's objections in 2016 (see below) and is now also reflected in a number of the NP policies and Community Actions.
With this in mind, I agree with the infrastructure requirements listed, some of which have been highlighted through the NP work and its policies, subject to the following qualifications:
* Improved public transport: however, given the location of the selected sites (one not on a bus route and the other largely on a very poor rural route) it is difficult to see how such improvement will be viable. Even if bus services to the draft allocation sites are improved, there will still inevitably be considerable additional car borne traffic adding to the already acknowledged congestion within KDBH.
* Parking improvements: additional parking to serve Dorridge Station will be essential as the selected sites will lead to more car borne traffic and additional commuter demand. However, considerable care will be required with double decking to ensure no harm to the Conservation Area. Consideration should be given to decked parking for long stay parking at the rear of Sainsburys petrol filling station.
* Highway improvements - the proposed scale of growth will necessitate these but to date there is no indication of what these will be, what their impact will be and therefore how acceptable they will be to residents and businesses. (see further comments in response to questions 23 and 24.)
* New primary school. Yes, this is required but is it a replacement for St George and Teresa or a new primary school to meet the additional need arising from new development? If the former is to be replaced locally then two new primary schools will be required given that the existing schools are all at capacity. It is not clear how existing traffic congestion will be alleviated by a new school given that the existing primary schools are at capacity and will presumably remain so together with attendant parking issues.
* Sport and Recreation- this requirement is in line with national, local and neighbourhood plan polices. The latter also supports in principle improved sports and leisure facilities with better community access. See response to Q 23 re sports provision on Hampton Rd.
* Concept masterplans; very supportive provided that the NF is involved in meaningful engagement, particularly now that it has the benefit of its own Landscape Study, Heritage and Character Assessment and Masterplanning/Design and Design Coding Study. These will enable the Forum to make informed inputs to the masterplanning process with a view to achieving significantly amended and improved masterplans. See further comments below and in response to questions 23 and 24.
* Affordable housing and more small market houses. This is supported in the NP.
The following additional infrastructure requirements have been identified through the NP process:
* Additional Doctors and dental practices
* Pre school facilities
* The capacity of Dorridge Station to meet increased demand.

With regard to infrastructure issues generally within KDBH, there are two further points:
Firstly, looking at the proposed infrastructure priorities listed by the Council, it appears that there will be very limited benefits from such large scale development to KDBH residents, particularly if a new Arden Academy is not delivered. This was the main rationale for such large scale development to the east of Knowle. The community sports hub is the other main community benefit although that appears to be principally a relocation of existing facilities offering expansion and improvements.
Secondly, the Neighbourhood Forum's response to the 2016 DLPR consultation was critical of the lack of information on infrastructure impacts within KDBH and how they would be mitigated. Transport issues were a top local concern in the NP process. The 2016 objection of The NF in respect of infrastructure concluded:
'It is unreasonable to expect residents to accept any substantial further development in KDBH without any indication as to how the wider infrastructure impacts would be overcome'.
The Forum asked for more information to be made available on the infrastructure impacts of the scale of additional housing in KDBH to enable an informed response to be made. Very little information has been forthcoming and it appears no real progress has been made over the last 2+ years as far as informing residents is concerned.
The Forum is aware that the Council subsequently commissioned a Borough wide Transport Study and a Car Parking Study. It is understood that the Council agreed to work collaboratively with the Forum on the transport and car parking work in relation to the KDBH Area to avoid duplication of cost and effort by the Forum. The Forum is also aware that the Council has had a draft report on both the traffic implications and car parking study since early 2018, there has been no involvement or discussion of the findings with the Forum despite repeated requests. The Forum has been advised that there are measurable impacts at various junctions which can be mitigated but how they can be achieved is not known.
The 2019 DLP Supplementary Update provides no further information on these matters other than the reference above to various undefined highway improvements. The Council has indicated that the Transport and Car Parking Studies will not be published until the Submission version and the concept masterplans provide little further information as to how the wider infrastructure issues referred to above will be addressed.
Therefore, until such time as the Council provides sufficient information and evidence as to the impacts of this scale of development on the physical and social infrastructure of KDBH, and how it can be satisfactorily mitigated, I continue to support the original objections of the NF to the draft site allocations. Further information is also required in respect of the various other issues raised in the Forum response relating to, inter alia, inconsistencies with the Council's own evidence base and its spatial strategy.
Without prejudice to this 'in principle' objection, detailed comments are made in response to Q 23 and Q24 on the allocations and masterplans, taking account of the Forum's own Studies into Landscape Strategy, Heritage and Character Assessment and Masterplanning /Design and Design Coding.