Object

Draft Local Plan - Supplementary Consultation

Representation ID: 6695

Received: 14/02/2019

Respondent: Gillian Griggs

Representation Summary:

Too many outstanding issues regarding the justification for allocation. Future of Arden Academy not resolved, no comprehensive Masterplan meetings, or information on transportation impacts. Spatial Strategy one of worst performing. If Arden Academy not relocated, no community benefit/justification for site against others on S&E edge. Must include significant improvements to school. No indication of location for primary school or shops/health facilities. No indication of traffic impacts or how public transport will be improved. Topography/levels not addressed. Development in sensitive southern area should be limited/further justified. Density too high, should reduce N>S, W>E. Open space should be separate from natural areas, which should protect linkages and be deliverable. Future of Lansdowne House unclear. Strong structural planting required. Support recommendation that development should be subject to SPD/Design Code.

Full text:

My response to Questions 2 and 22 sets out why I consider an 'in principle' objection to this allocation should be maintained pending further information from the Council on infrastructure and other matters raised in the Forum's original objection.
This is expanded upon below in relation to the Site 9, the 'Arden Triangle'.
In its submission to the 2016 DLPR consultation, the Neighbourhood Forum made comments on this site which raised questions over the allocations given the Council's own evidence base and asked for further information on a range of matters including:
* The scoring on this parcel of Green Belt should be revisited
* The findings of the Council's own LCA says the area is suitable only for small scale development
* The findings of the Accessibility Study that large parts of this site are not accessible even with a relaxation of standards
* Additional information on the case for relocating Arden Academy including viability vis a vis housing numbers, funding, alleviation of traffic congestion, location and role of new primary school
* The future of the MIND garden
* Engagement of residents in masterplanning.
Since then, Arden Academy has confirmed that the future of the MIND garden is secure in its current location and the Supplementary Update is proposing 600 houses, rather than 750. Both these changes are welcomed. In addition, the imposition of a Tree Preservation Order around Lansdowne House is welcomed although it only followed the loss of mature trees and was not imposed, as requested by the Neighbourhood Forum, on the whole site area.
Progress on resolving the other matters has been minimal. The future of the Academy has not been resolved; there have been no masterplanning meetings on the site as a whole although the promoters of the southern part have invited the NF to attend some meetings; and virtually no information has been forthcoming on transportation impacts.
The following comments are made in the above context and having the benefit of the studies undertaken for the Neighbourhood Forum on Landscape, Heritage and Character Assessment and Masterplanning/Design and Design Coding. These have helped shape my response on the draft concept masterplan for this site.
1.The Council states that this allocation is consistent with Option G of the Spatial Strategy for the significant expansion of rural villages. However, the Spatial Strategy does not appear to favour any one Option and this option was one of the worst performing in the Interim Sustainability Appraisal.
2. Without the original rationale for large scale housing in this location, ie the relocation of the Academy, there is no longer term community benefit from this allocation and no overriding justification for developing this site over and above others on the eastern and southern edges of the area. All these are assessed as performing the same Green Belt role and some perform better in terms of integration with existing built area and have better access to the rail station and to Dorridge centre. A decision on the future of the Academy is required and either a new building or significant improvements to the existing buildings should be an outcome that benefits existing as well as new residents.
3. If development of the scale proposed can be justified in this location, then only Option 2 makes any sense. Option 1 offers no wider community benefits and places large tracts of new housing in a location that does not integrate at all well with the existing built area. The Academy serves as a barrier to achieving any satisfactory integration of old and new as the new development would effectively turn its back on the rest of Knowle and Dorridge, contrary to the principles of achieving good integration with the existing community and good accessibility. If the Academy stays in its current position, the remainder of the area should be reassessed as one parcel in the site hierarchy as it would score differently. Option 2 offers the potential for new Academy premises although significant question marks remain over the size of the site to accommodate the new school and over its suitability given the topography of part of the proposed Academy site. In particular, extensive car parking areas are required for staff and 6th formers as existing on-site provision is inadequate. Whichever Option is chosen, improvements to the existing school buildings and facilities will be necessary and the questions previously raised by the NF relating to viability, scale of enabling development and range of facilities for shared use still remain to be satisfactorily addressed.
4. No indication is shown on the masterplans of the location of a new primary school nor of a small local centre (shop, health facilities etc previously referred to). Also, it is not clear if this is a replacement school (for St George and Teresa) or a primary school to meet the additional demand from new development. This is an important point as a relocation would not achieve the additional places necessary to accommodate new development.
5.There is no mention of transport impacts other than that Station Rd congestion will be alleviated if the Academy relocates. There is no indication in the Supplementary Update of what the assessed traffic impacts are and how they will be addressed. There is also no indication as to how public transport will be improved, particularly to those parts of the site that are furthest away from village centres. It is unacceptable to be asked to comment without such vital information which the NF knows the Council has.
6. There is no mention of topography and levels. The levels rise significantly up Stripes Hill into Knowle and also rise gently from the Warwick Rd up towards Lansdowne Farm, increasing the visibility of the site. The masterplan must demonstrate development will take account of the topography, particularly on the rural approach into Knowle and its nearby Conservation Area.
7. Based on recommendations in the NF Landscape Study, Heritage and Character Study and Masterplannng/Design and Design Coding, the southern part of the Triangle site is the most sensitive and should have only very limited development, if at all. Both the Council's own assessment and that of the NF's Landscape Study and Masterplanning/Design and Design Coding work is that it has low development capacity. The Landscape Consultants for the NF have strongly advised that the site should be masterplanned as a whole and that development should commence in the north and extend southwards. Development in the sensitive southern part needs further justification. The acknowledgement in the Supplementary Update that this site must be dealt with in a comprehensive masterplan is welcomed.
8. Densities: The areas of low density housing should flow not only north to south as shown on the masterplan but also west to east, creating a transition towards the retained countryside. The area to the south should be primarily devoted to the LWS and public open space with only minimal housing on the southern boundary as it leads towards the rural character of Grove Rd and the open countryside.
The densities of both options are shown as 30-40dwph. This cannot be correct as Option 2 has an area of high density housing on the Station Rd frontage. Densities above 40 dwph will be out of character with the area, contrary to the layout and design policies of the NP, unless they include specific areas of purpose built housing (such as sheltered accommodation for the elderly). Densities of 30 to 40 dwph on the rural edges of development sites will not achieve the transition to countryside advocated in the NF Landscape and Masterplanning studies. It will also not accord with the Council's own Landscape Assessment of low capacity to accommodate new development.
9. It is unclear if the area of significant local wildlife value is being treated as public open space. This is not a satisfactory way forward if it is. The provision in of public open space looks very limited for 600 houses.
10. The area of significant ecological value is shown as extending to the Warwick Rd frontage adjoining the POS. If this southern area is to be developed, these linkages are essential. However, information from the promoters of this area indicates that delivery of this link is not achievable due to ownership issues. In addition, a wider buffer area is required on the northern side of the LWS to protect it from adjoining development.
11. The future of Lansdowne House in not clear. Whilst its retention as shown would be welcomed as it would help retain the existing parkland setting around the house, it is on the brownfield land register and therefore is presumably available for redevelopment.
12. The masterplans show very little new tree planting. If this area is to be developed, the masterplans should incorporate a strong structural planting scheme within which new development would sit. The masterplans are inadequate in this respect. It is known, for example, that all the trees on the Warwick Rd frontage south of the access to Jacknetts farm will be removed yet there is no indication of a strong replacement boundary with trees along the Warwick Rd.( It should be remembered that the promoters of this site stated in 2016 that development of the site would be almost entirely obscured from view from the Warwick Rd ).
13. Design Coding: I support the recommendation of the Landscape Study that any allocation at the Arden Triangle site should be subject to a Supplementary Planning Document or Design Code to inform development which should be consulted on with the Neighbourhood Forum. In addition, matters relating to levels, green infrastructure, landscape and visual impacts and floodlighting should be properly considered in advance of any allocation.

Concluding comments on the Arden Triangle draft allocations and draft masterplans:
There remain far too many outstanding issues regarding the justification for development in this area to be able to support this allocation in principle. The studies undertaken on behalf of the NF raise significant concerns about the scale of development, particularly the development of the southern, most sensitive landscape area. Fundamental issues regarding the future of Arden Academy and the impacts of this scale of development on local social and physical infrastructure have still not been addressed. It seems clear that if Arden Academy is not relocated, there is no real benefit from such a scale of development to the wider community and there is no justification for the release of the land to the east of the Academy as it performs worse than other sites in and around KDBH. If it is feasible to relocate the Academy, that would be the better option subject to satisfactory justification of deliverability, accessibility, traffic impacts, site size and suitability as well as addressing the other matters raised above in relation to masterplanning.