Object

Representation ID: 9587

Received: 15/03/2019

Respondent: Berkswell Parish Council

Seriously flawed and fails to meet NPPF requirements.
Green belt analysis inadequate as assesses sites individually rather than cumulative impact, fails to consider loss of amenity/accessibility, takes no account of wider pressures that should be included in cumulative harm analysis, such as HS2, and gives precedence to greenfield sites that add to openness whilst ignoring sites not connected to open green belt.
Takes no account of potential housing productivity of sites eg Site 3 where area of high ecological value/setting of listed building reduces capacity from green belt deletion. Ignores NPPF requirement for proportion of housing to be met on sites less than 1 hectare.
Fails to give sufficient weight to effective public transport as demonstrated by frequency of services and car usage, or to costs of improvements. Balsall Common has high car dependency and less effective public transport than Dorridge, which has lower/zero housing target. No highway assessment or analysis of by-pass options, particularly western option which could serve JLR facility. Fails to consider where best location for affordable housing in Borough.
Takes no account of house prices as indicator of unmet demand despite inclusion in national methodology.
Should include capacity of centres to meet increased demand.