I believe it is right that Site 413 (land off Blue Lake Road, Dorridge - extended from Sites 104 and 109) is omitted from the Local Plan as a site for residential development. This view is based on:
1. Factors relating to the wider Knowle, Dorridge and Bentley Heath ("KDBH") area; and
2. Factors specifically relating to Site 413.

Broader factors
* Over the last five years there have been c. 500 additional housing units added to the KDBH area. That development has placed significant strain on local infrastructure, specifically roads and parking. These issues are articulated in Section 5.4 of the KDBH Neighbourhood Plan ("The Neighbourhood Plan").
* The Draft Local Plan subject to this consultation proposes an additional 900 to 950 residential units on two sites (8 and 9). Development at that level would place further material strain on local infrastructure that is already struggling to cope. Inclusion of Amber Sites as Allocated Sites would push that strain to beyond breaking point.
* It should be noted that options for land release of this scale (500+ dwellings even without Amber Sites) were considered by the Greater Birmingham and Black Country Housing Market Area Strategic Locations Study published in 2018. Such an option for Knowle or Dorridge was not put forward in that study. The Council should be paying more regard to the conclusions of that study in putting forward the Local Plan.
* Of particular note is the additional strain the development of sites 8 and 9 would put on the road infrastructure, in particular Station Road and Knowle High Street (which is within a Conservation Area). Congestion at peak hours is already chronic and both developments would further load these two key components of the road infrastructure.
* The Conservation Area is protected by national as well as local planning policy and, as such, impacts need to be taken into account in the development of the Local Plan. Yet no traffic impact study or proposed mitigation measures have been published. Options for mitigation are, in reality, extremely limited given the positioning of proposed development sites in relation to the key pinch points, in particular those in the Conservation Area.
* Adding either Amber Site in the KDBH area to the list of Allocated Sites would load both Station Road and Knowle High Street further. That would make the situation untenable in the context of preserving the character and quality of the area, even with maximum mitigation.
* The Council's assessment is that the KDBH area can accommodate growth in excess of its local needs. That may be true to a point, but even the proposed level of development (without admitting Amber Sites as Allocated Sites) would compromise many of the principles set out in the Neighbourhood Plan, in particular those around Village Character and Natural Environment. The Council seems not to be appropriately taking into account the Neighbourhood Plan in bringing forward this Draft Local Plan.

Specific factors relating to Site 413 (extended from sites 104 and 109)

* The promoter of Site 413 is proposing c. 340 dwellings on under 10 hectares.
* The Vision Document prepared by the promoters of development of Land off Blue Lake Road (referenced at para 13 of the Amber Sites document published by the Council) has not been published or been the subject of any public consultation. Therefore, it should carry no weight in the consideration of the possible nature, impacts or deliverability of new development.
* The Vision Document cover sheet indicates it was in "Final" form in February 2018. This would suggest that the promoter had plenty of opportunity to socialise and consult on its proposals with local residents. That has not taken place although there are suggestions locally that there has been extensive contact between the Council and the promoter. The fact that the Vision Document has still not been directly made available to local residents fuels concerns that the promoter may be reluctant to take resident views into account.
* The assessment of sites that led to the identification of Land off Blue Lake Road (ref A5) as an Amber Site where development would be considered "less harmful" than other in Green Belt locations seems fundamentally flawed. This is because it scores down landscape character and quality in areas that contain ribbon development no matter how well established it may be or how limited it may be in extent. This is explicitly the case in respect of this site where the intrinsic qualities of the areas of unbuilt development, and the contribution they make to landscape character and the visual amenity of local residents, is underestimated and so the parcel of land under-scored in the Local Plan's Site Selection process.
* Neither the Council or the promoter of this site has made any effort to objectively assess the feeling of local residents in relation to visual amenity of this site, despite plenty of time and opportunity to do so. Indeed, it may be telling that this proposal has come forward after an extensive period of consultation through the KDBH Neighbourhood Forum over potential development sites. In doing so the promoter of the site has missed a meaningful opportunity for consultation.
* The Council assesses Site 413 to be a lower performing parcel under the Green Belt Assessment. Although the assessment methodology has been refined, that assessment is fundamentally at odds with that performed on substantially the same site when it was rejected for inclusion in the last Local Plan. I can see no objective justification for such a shift.
* The Arden Triangle development proposition seems to be driving a major, strategic land release to the east of Knowle and Dorridge, yet it is in itself questionable, as evidenced by the weight of arguments put against it when the Draft Local Plan was published and, more recently by the findings of the Crestwood Environmental Landscape and Visual appraisal of it commissioned by the KDBH Neighbourhood Forum. That was published in January 2019, after the Supplementary Consultation documents were agreed. Therefore, this is new evidence that the Council needs to take into account as it considers responses to the Supplementary Consultation and in the developing of policies and proposals to be included in the next version of the Local Plan. The report recommends that that the public right of way that runs east-west some 300m north of Grove Road as the "natural limit to development" in this area. To extend the land release even further south through the release of Land off Blue Lake Road for development and excluding properties to the south of Grove Road from the Green Belt (as is proposed) is wholly unreasonable.
* A land release incorporating the Arden Triangle and Site 413 would result in the wholesale coalescence of Dorridge and Knowle, contrary to the purposes and objectives of Green Belts as set out in national planning policy and the recommendations of Heritage and Character Study commissioned by KDBH Neighbourhood Forum. Such an outcome would also be contrary to the objectives and policies of the Local Plan itself. The extent of the contravention would be much more significant than would be the case for the development of certain Red Sites (in particular Site 207), which have been rejected by the Council on grounds of coalescence which would seem to be flawed.
* Development at the density and level proposed for Site 413 would place an unsustainable strain on the immediately surrounding roads of Darley Green Road, Grove Road and Knowle Wood Road, none of which is designed for anything other than very light traffic. It is very difficult to see how sufficient mitigating measures could be put in place, developer funded or otherwise.
* The Neighbourhood Plan sets out clear principles around development of the Green Belt in Policy VC1. Under that policy "any development must be in harmony with the rural character of the villages' surroundings and sit well in the landscape." Development of Site 413 at anything near the density proposed would fundamentally contravene that policy.
* Policy D1 in the Neighbourhood Plan goes on to set out clear principles around character and appearance of development. In particular, it establishes the following criteria:
o Development should be in harmony with the village character and sit well within the landscape;
o Development layouts should be characteristic of the surrounding area;
o Development should be of a density characteristic of the area; and
o Development should be in keeping with the scale, siting and appearance of nearby buildings.
* On any objective assessment, development of Site 413, which is currently surrounded by low-density development sitting sympathetically around a well-established Green Belt boundary, score very low against the above criteria. There are several "Red Sites" in the KDBH area which would objectively score much higher.
* The National Planning Policy Framework requires that residential development should "promote local character". That requirement would not be met for development on Site 413 in the context of the existing developed area.