Comment

Draft Local Plan - Supplementary Consultation

Representation ID: 6696

Received: 14/02/2019

Respondent: Gillian Griggs

Representation Summary:

The NF objected to the scale of 1000+ houses in KDBH. As none of the matters raised in the 2016 objection have been satisfactorily addressed, a further 590 houses cannot be accommodated in the area without substantial harm to the character and appearance of the KDBH area, contrary to the aims of the Spatial Strategy and the Draft KDBH NP. Whether parts of these sites can be brought forward as alternatives to all or part of the draft allocations requires further consideration based on a clearer understanding of the site hierarchy assessments and site impacts/proposed mitigation.

Full text:

The Council is seeking views on two sites in the KDBH Area.
It appears that these are put forward as possible additional sites if the Council has to make further site allocations. It is not clear if they are candidates to replace sites which are currently draft allocations. However, if the Council is persuaded that any draft allocations are unacceptable, then it is assumed that these sites will either be possible alternatives or additional sites.
It is clear from the KDBH Neighbourhood Forum (NF) objections to the 2016 DLPR that residents were opposed to that scale of development for the reasons set out in its 2016 response and summarised below:
* 1400+ houses in Knowle is disproportionate and unsustainable
* 1400+ houses in Knowle is inconsistent with the spatial strategy which itself is inconsistent with other Council strategies and Draft Local Plan policies
* the scale of development proposed in Knowle is not justified by the Council's methodology and study findings
* the site selection methodology is unclear and its application seriously flawed
* the scale of development proposed in KDBH fails to take into account the impact on services and infrastructure
* the views of residents as expressed in the KDBH Residents Survey have not been taken into consideration
* there has been inadequate consideration of reasonable alternative patterns of distribution either Borough wide or at the KDBH level
* the proposed scale of growth will lead to an unacceptable loss of village intimacy, identity and character with adverse impacts on the Knowle Conservation Area and the wider KDBH area.
These comments still hold good and therefore the suggestion of any additional housing in KDBH, over and above the scale that is already opposed, is not acceptable. However, if some parts of the amber sites could be developed as alternatives to all or parts of the draft allocations, then there may be some merit in considering those further.
Once again, there is no indication of possible impacts or community benefits on which to make a proper assessment in the Supplementary Update.

Golden End Drive, Kenilworth Road
As a highly performing parcel of GB, it would be contrary to the Council's assessment criteria to allocate this site. It has some advantages because of its proximity to the centre of Knowle but could only be considered if small scale rounding off were possible that retained views of the church/Conservation Area and protected the canalside environment by a substantial green buffer.
Blue Lake Road, Dorridge
When the original, much smaller, submission was displayed at NF Developer Day, it attracted a number of positive comments. The original part (site 104) and part of 413 have merit as they are closer to Dorridge centre and the station and are on less well performing Green Belt. However, there is no bus access and the far parts of the site are similar to the Arden Triangle site in terms of distance from shops and services.
It is unclear if site 109 Land south of Grove Rd is intended to be included in this wider proposal.
Overall, if Arden Academy stays in its current location, the western end of the Blue Lake Rd site performs better than the remainder of the Arden Triangle site as it is lower performing GB which integrates better into the landscape and existing settlement. This site, or a clearly defined part of it, may be considered as an alternative to the Arden site (not in addition to it) and only in the event that the Academy is not relocated. For the reasons previously given, the KDBH infrastructure cannot accommodate even the 900 plus houses proposed without serious harm to village life and character.
The Council should consider the possibility of taking only parts of some of these sites out of the GB. This does not mean that substantial permanent boundaries will not exist. Well defined field boundaries can be appropriate which could lead to more sympathetic development and a less blunt approach than the Council is currently taking.
The Council should also review its assessment of sites in its Appendix D. I referred in my response to Q2 to the apparent inconsistencies in the assessment of several sites. In particular, many of the small sites were not included in the Interim Sustainability Appraisal and some appear to perform reasonably well but are placed in the red category. Examples in KDBH include those referred to in Q2 but also small sites such as 207, 210, 344 and 135. Some of these perform well on a number of criteria and may be able to overcome concerns such as defensible GB boundaries through the creation of new boundaries (as proposed at Hampton Rd). Consideration of some smaller sites could also enable more 'rounding off' or infill of the built area in some places as well as spreading the impacts across a wider area. A mix of large and smaller sites in a more dispersed pattern would have less impact on the GB, be more consistent with government guidance and potentially being less damaging to village character and infrastructure.