Site Selection Methodology
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8278
Received: 14/03/2019
Respondent: Mr Robin Easterby
Please see attached letter.
(Letter not attached on JDi. Email sent 09.05.19 to respondent, Robin Easterby via PSP email address. Email reply on 09.05.19 stating that he was unable to resend letter but..."I suspect you may already have seen similar contents from other objecting residents on Widney Manor Road as it was a standard letter recommended by the Widney Manor Action Group. Basically I object to the proposed development as it would fundamentally change the nature of the area, is green belt, and is an example of garden grabbing at its worst. The traffic along Widney Manor Road has dramatically increased since I moved into 136 and the proposal will only make matters worse."
Please see attached letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8287
Received: 14/03/2019
Respondent: Mr Andrew Burrow
The methodology does not reflect the Harm to the greenbelt because it both fails to look at the cumulative impact of removing individual sites which were only assessed for their individual contribution to the purposes of the greenbelt and in some cases even ignores the Atkins greenbelt report. It also makes up public transport accessibility scores that ignore the Council's own Solihull Connect report. It also fails to take into account the relative public amenity benefits of sites in terms of their public accessibility and contribution to well being.
The methodology does not reflect the Harm to the greenbelt because it both fails to look at the cumulative impact of removing individual sites which were only assessed for their individual contribution to the purposes of the greenbelt and in some cases even ignores the Atkins greenbelt report. It also makes up public transport accessibility scores that ignore the Council's own Solihull Connect report. It also fails to take into account the relative public amenity benefits of sites in terms of their public accessibility and contribution to well being.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8296
Received: 15/03/2019
Respondent: Mr John Gibbs
There is a preponderance of new dwellings proposed in the Shirley area. Sites 11, 12 and 26 account for up to1940 dwellings, and, in addition, Site 4 is, in effect, butted up to Site 26. Site 4 adds an additional 700 dwellings to the area.
Additionally, Shirley is absorbing new homes within its boundaries, in developments like Poppy Fields in Haslucks Green Road, which comprises more than 100 dwellings, and Solihull Village on the previous Powergen site, which will comprise an additional 260 apartments. In addition other accommodation has been added recently in Shirley around the Parkgate development.
There is a preponderance of new dwellings proposed in the Shirley area. Sites 11, 12 and 26 account for up to1940 dwellings, and, in addition, Site 4 is, in effect, butted up to Site 26. Site 4 adds an additional 700 dwellings to the area.
Additionally, Shirley is absorbing new homes within its boundaries, in developments like Poppy Fields in Haslucks Green Road, which comprises more than 100 dwellings, and Solihull Village on the previous Powergen site, which will comprise an additional 260 apartments. In addition other accommodation has been added recently in Shirley around the Parkgate development.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8314
Received: 14/03/2019
Respondent: Mr Jon Sellars
1. Why are there so many new homes in South Shirley?
2. What are you going to do to support the local transport network that is already overloaded?
3. Why are you removing so much green belt?
4. Why are you not making denser populated housing?
5. Why do you not make it easier for elderly to move thereby freeing up housing stock?
6. Why are you not developing more brownfield sites?
7. Why are you not tackling unoccupied houses?
1. Why are there so many new homes in South Shirley?
2. What are you going to do to support the local transport network that is already overloaded?
3. Why are you removing so much green belt?
4. Why are you not making denser populated housing?
5. Why do you not make it easier for elderly to move thereby freeing up housing stock?
6. Why are you not developing more brownfield sites?
7. Why are you not tackling unoccupied houses?
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8354
Received: 14/03/2019
Respondent: David Sharpe
I think the methodology is lacking as there is no reference to the assessment of infrastructure needs, road improvements, traffic issues etc. in the assessment of sites. Infrastructure improvements needed for some sites may be significant, and have themselves land issues, It is not sufficient for the infrastructure improvement needs to be ignored at this stage and left for later assessment when sites may already be on the 'most suitable ' list. Infrastructure needs, road improvements, traffic issues should be dealt with and identified upfront when selecting sites as potential sites to take forward.
I think the methodology is lacking as there is no reference to the assessment of infrastructure needs, road improvements, traffic issues etc. in the assessment of sites. Infrastructure improvements needed for some sites may be significant, and have themselves land issues, It is not sufficient for the infrastructure improvement needs to be ignored at this stage and left for later assessment when sites may already be on the 'most suitable ' list. Infrastructure needs, road improvements, traffic issues should be dealt with and identified upfront when selecting sites as potential sites to take forward.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8381
Received: 14/03/2019
Respondent: Joanna Johnson
Why are there so many homes proposed near and around Shirley? There are other areas in Solihull, or in the areas of Birmingham that border onto Solihull that could be used, especially as they are brownfield sites, not Green Belt.
Why are there so many homes proposed near and around Shirley? There are other areas in Solihull, or in the areas of Birmingham that border onto Solihull that could be used, especially as they are brownfield sites, not Green Belt.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8386
Received: 14/03/2019
Respondent: Mr Darren Douglas
We object to this further consultation being undertaken on sites that the Council have assessed and rejected. We are also unclear how the Council have concluded these sites are less harmful.
Please see attached letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8484
Received: 15/03/2019
Respondent: Simon Taylor
- Site selection methodology is flawed as:
- 2 criteria based purely on site assessment, with no consideration to other core principles within Local Plan such as retention of settlement demarcation.
- Suggest cap to any one area, based upon percentage increase versus existing housing stock
- Ignorant of supply versus demand in each settlement area.
Does not allow for recent development in certain areas
The site selection methodology is significantly flawed in that, in accordance with section 67 of the Supplementary Consultation, it does not take into account the number to be accommodated by each settlement, but rather it is based upon site appropriateness alone. This results in lack of spatial awareness, lack of consideration for the retention of intrinsic character of distinctive villages (as cited in the Local Plan) and ignorant of supply versus demand (for instance, Dickens Heath represents a 14% shortfall on 1 bed property and 4% shortfall on 2 bed. Contrast this to Knowle/Dorridge/Bentley Heath and there is a 17% shortfall on 1 bed property, and a 25% shortfall on 2 bed).
Using this methodology alone is therefore very short-sighted, for instance, if all suitable sites based on the assessment criteria were around Dorridge, would they all get the go-ahead?
A more reasonable methodology would be to use the current methodology, but with a third criteria to place a cap on the number of dwellings for each region/location based upon spatial awareness, retention of distinctive settlements and supply and demand (perhaps a cap of a maximum 50% increase in housing versus existing housing stock for any one area). This is further demonstrated in my response to questions 11 and 12.
The proposal therefore means an additional 2,290 homes in the vicinity of South Shirley and around Dickens Heath village.
This does not allow for the 200 homes have already built by David Wilson at Braggs Farm (71) and by Bellway at Dickens Heath Road (130).
Based on the proposed allocations within the Supplementary Consultation, this represents a gross imbalance of proposed new housing within the region as below (this imbalance is outrageous and simply cannot be justified). This is represented in the attached table.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8543
Received: 15/03/2019
Respondent: Joelle Hill
My understanding is that there are a number of flaws with the methodology of this review.
Sustainability. The government provides a sustainability calculator which if applied consistently does not produce a sustainable result in some cases for the sites identified in the plan. The sustainability measure has not been used for all the sites proposed in the plan.
There is an over emphasis on large release of green belt land rather than smaller infill developments that would have less impact on the borough. This is against government policy.
My understanding is that there are a number of flaws with the methodology of this review.
Sustainability. The government provides a sustainability calculator which if applied consistently does not produce a sustainable result in some cases for the sites identified in the plan. The sustainability measure has not been used for all the sites proposed in the plan.
There is an over emphasis on large release of green belt land rather than smaller infill developments that would have less impact on the borough. This is against government policy.
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 8546
Received: 14/03/2019
Respondent: Gladman Developments
Gladman agrees with the Council that the Standard Method represents the most appropriate
approach to defining the minimum housing needs of the authority
See Letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8553
Received: 14/03/2019
Respondent: Gladman Developments
In setting out the sources of housing supply the 10% deduction made towards sites which have not yet commenced but benefit from planning consent, sites identified within the SHLAA and sites identified on the Brownfield Register is welcomed to account for non / under delivery. Council should provide evidence on windfall delivery in order to clearly demonstrate that the 2,250 dwelling windfall allowance made by the Local Plan Review is justified and realistic. The Council should review its existing allocations before rolling forward the allocation of these sites through the Local Plan Review as these were first identified in the Core Strategy which was adopted 5 years ago and have still not come forward. The allocation of a site within a development plan is not on its own enough evidence to demonstrate reasonable prospect. Is concerned that there is insufficient flexibility provided within the supply to ensure full and consistent delivery of the housing requirement. The absence of a detailed housing trajectory within the Local Plan means that it is difficult to provide any comments on the deliverability of the housing requirement. It is unclear what assumptions the Council is making in terms of the lead-in time and build out rate for each of the sites identified within the supply. There is a need for the level of flexibility within the supply to be increased to at least 20%.
Agree in principle with the two step site selection process which applies a sequential preference towards non green belt sources of supply. However considers that step 1 and step 2 assessments should be applied to all sites which do not score red. Whilst national planning policy sets out that Green Belt land is to be considered sequentially, this should not be at the cost of other sustainability factors, site suitability and deliverability. Does not object in principle to any allocation shortlisted by the Council but considers that the amount of allocations will need to substantially increase.
Considers that the Council should consider the identification of safeguarded land through the Local Plan review. The benefit of Safeguarded Land being to ensure the longevity and permanence of the Green Belt, whilst providing flexibility for future needs to be accommodated if necessary.
See Letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8562
Received: 15/03/2019
Respondent: Warwickshire Wildlife Trust
No. Local Wildlife Sites and potential Local Wildlife Sites (LWS) have been inconsistently considered in decision making. Some potential LWSs have been assessed by the LWS team against the criteria to inform decision making and some have not. Those that have not should be assumed likely to qualify under the precautionary principle until further survey can be undertaken. LWSs should form a significant constraint to development - currently some sites are included for allocation which would destroy one of these sites of country value to nature conservation.
No. Local Wildlife Sites and potential Local Wildlife Sites (LWS) have been inconsistently considered in decision making. Some potential LWSs have been assessed by the LWS team against the criteria to inform decision making and some have not. Those that have not should be assumed likely to qualify under the precautionary principle until further survey can be undertaken. LWSs should form a significant constraint to development - currently some sites are included for allocation which would destroy one of these sites of country value to nature conservation.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8599
Received: 15/03/2019
Respondent: Paul & Anne Wilson Ramsay
- Insufficient brownfield sites allocated of 35 ha (p84) within the borough for housing. More brownfield sites should be allocated.
- Kingshurst Village Centre has no masterplan, and future housing proposals are not provided.
- Majority of residential sites allocated in the plan are located within green belt of 379 ha (p84).
- Atkins Green belt assessment in support of SMBC allocated residential sites is flawed. As a result some sites have already been redesignated as brownfield sites by SMBC, when they are clearly located within green belt, including Lansdowne House in Site 9 South of Knowle.
There are insufficient brownfield sites allocated of 35 ha (p84) within the borough for housing.
More brownfield sites should be allocated.
Kingshurst Village Centre has no masterplan, and future housing proposals are not provided.
The majority of residential sites allocated in the plan are located within green belt of 379 ha (p84).
Green belt assessment carried out by Atkins in support of SMBC allocated residential sites is flawed. As a result some sites have already been redesignated as brownfield sites by SMBC, when they are clearly located within green belt, including Lansdowne House in Site 9 South of Knowle.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8601
Received: 15/03/2019
Respondent: Stoford Developments
Agent: Barton Willmore
We reiterate our support for the release of land at Damson Parkway from the Green Belt, but strongly suggest that the proposed restriction to JLR related uses and supply chain is removed. This restriction is not required given the scale and nature of the employment land shortfall and the need for flexibility. Therefore, we request that Policy P1 and Site 20 be amended to reflect an unrestricted allocation for Class B1c, B2 and B8 uses at Damson Parkway. Please see attached letter for our full representations.
We reiterate our support for the release of land at Damson Parkway from the Green Belt, but strongly suggest that the proposed restriction to JLR related uses and supply chain is removed. This restriction is not required given the scale and nature of the employment land shortfall and the need for flexibility. Therefore, we request that Policy P1 and Site 20 be amended to reflect an unrestricted allocation for Class B1c, B2 and B8 uses at Damson Parkway. Please see attached letter for our full representations.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8629
Received: 15/03/2019
Respondent: Mr Andrew Freeman
The site selection process is flawed and inconsistently applied. All reasonable alternatives have not been examined, in particular, options put forward in the Strategic Growth Study. The overarching Spatial Strategy is poorly applied and has not been up-dated to address identified strategic development opportunities. Undue reliance on larger sites. No consideration of safeguarded land, long-term development needs or enduring green belt boundaries.
Q2 - Site Selection Process
The site selection process is flawed:
All reasonable alternatives have not been examined (bearing in mind the need to extend the Plan period to at least 2035)
* All reasonable alternatives have not been examined, in particular, options put forward in the Strategic Growth Study
* The Spatial Strategy has not been up-dated to cover options identified in the Strategic Growth Study
* The site selection process is flawed / applied inconsistently
* There is undue reliance on larger sites rather that small and medium-sized sites
* There is no consideration of safeguarded land, long-term development needs and an enduring Green Belt boundary
The housing requirement figure is too high
* The margin is excessive
* The housing requirement figure would result in build rates that are unachievable
* Suitable sites to meet the requirement have not / cannot been identified
* The housing requirement figure needs to be reduced
* The sustainability of the proposed contribution to the HMA shortfall needs to be examined bearing in mind the principal contribution of the Green Belt in key parts of the Borough and the shortage of suitable sites
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8649
Received: 15/03/2019
Respondent: Birmingham City Council
Birmingham City Council has no specific comments on the Site Selection methodology itself. However, it is not clear whether the assessment of the 70+ additional 'call for sites' submissions since the Draft Plan stage has contributed positively to the overall land supply already identified in the Local Housing Need section of the document. If so, this would provide some additional capacity on top of the 2,000 additional homes already identified to meet the HMA shortfall.
Birmingham City Council has no specific comments on the Site Selection methodology itself. However, it is not clear whether the assessment of the 70+ additional 'call for sites' submissions since the Draft Plan stage has contributed positively to the overall land supply already identified in the Local Housing Need section of the document. If so, this would provide some additional capacity on top of the 2,000 additional homes already identified to meet the HMA shortfall.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8721
Received: 15/03/2019
Respondent: Councillor Max McLoughlin
Subjectivity of methodology is a weakness:
Ability to judge performance of green belt requires intimate knowledge of Borough.
Negative feedback loop where lack of concentrations of people using alternative travel modes, public transport options limited, with little expansion and cuts in services.
Measure success by results produced. Where settlements designed with private car in mind, issues are compounded eg Dickens Heath.
Need to focus on future growth corridors rather than urban extensions which create car dependency indicates potential weaknesses in the methodology. Extent of growth in Blythe draws into question the functioning of the methodology that is producing these results.
Whilst there are significant elements I agree with, there are aspects I do not.
Whilst the methodology appears to perform well on paper, there is a glaring weakness in it.
Most notably, the ability to consider the performance of Green Belt requires intimate knowledge of the area. Despite having been born in the borough and spending the vast majority of my life here, I would not venture to say, with confidence, that I can confirm the performance of the Green Belt in all areas.
The compounding criticism of this model is the degree of connection an area has. There is a negative feedback loop with regards to travel. Where there are not concentrations of people who currently use alternative travel (i.e. not private cars), transport options are limited. As the provision of these services is primarily determined by private provision (business case) we see little expansion of services. More recently we have seen significant reduction in provision of bus routes across the region.
Added on to this, where we design and develop settlements with private car travel in mind, we compound existing issues. The example of Dicken's Heath, where buses cannot get to the centre of the settlement, should serve as a lesson learned.
Where this can be corrected is taking an approach that accounts for future growth corridors. There may be sites that can perform well in terms of sustainable travel, as well as create a viable business case for alternative modes of travel, that might not be included in the existing methodology.
The current methodology emphasises urban extension over new settlement creation. In short, if we take the same approach as we have in the past, we shouldn't expect different results.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8746
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
We broadly agree with the methodology but raise issues with the manner in which it has been applied to the site assessment process. We object to the manner in which our site (site assessment reference 404) has been assessed as 'red'. We do not agree with the conclusion that it will have 'severe or widespread impacts that are not outweighed by the benefits of the proposal'. Given the geographic similarities, we make a direct comparison to site 41, Land at Whitlock's End Farm; and site 176, Land to the West of Dickens Heath, both of which are assessed as 'green' sites
and are identified as draft allocations (draft Plan sites 26 and 4 respectively).
Site has been assessed as low accessibility to the primary school despite being adjacent to it. There is a formal agreement with Bellway to create footpath linkages through adjacent site which would reduce time taken to walk to the school. Public transport is also incorrectly assessed as being low / medium for same reason walking distance to station is reduced. Assessment states no footpaths however as stated above a new footpath will be provided along Rumbush Lane. These conclusions on accessibility are supported further by the appeal decision for the adjacent Bellway site. It is clear the site is close to a variety of services and facilities at Tidbury Green and Dickens Heath and a number of sustainable transport options are available which will be enhanced through the development of the enhanced Bellway scheme. The site is similar to the proposed draft allocations in terms of contribution to the purposes of the green belt. Requests site is reassessed based on evidence submitted. In terms of landscape the site has been assessed as 'within a landscape character of high sensitivity,medium landscape value and very low capacity to accommodate change'. However landscape and visual appraisal undertaken by Barton Wilmore Landscape concludes that the site can accommodate development which is of a type and scale that reflects the existing development within Tidbury Green. Mitigation is proposed to reduce visual permeability to ensure that the development can be accommodated without undermining the function of the Green Belt and without causing harm to the landscape. As such landscape should not be a reason to object to the principle of development on the site. Disagrees with the conclusion 'the development would result in an unacceptable incursion into the countryside and cause coalescence by narrowing the gap between Dickens Heath and Tidbury Green'. Nothing in the Council's evidence that places a higher protection of the area between Dickens Heath and Tidbury Green (for our site) than between Dickens Heath and Shirley (for the draft allocation at Whitlock's End Farm).
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8772
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Widney Manor Road
Agent: Barton Willmore Planning
We broadly agree with the methodology but raise issues with the manner in which it has been applied to the site assessment process. Specifically, we object to the manner in which our site (site assessment reference 407) has been assessed as 'red'. We do not agree with the conclusion that it will have 'severe or widespread impacts that are not outweighed by the benefits of the proposal'. We disagree that no defensible Green Belt boundary can be established. The site comprises predominantly grassland pasture and surrounding vegetation. The sense of openness is, therefore, already limited to some extent. Development of the site would contribute towards increasing the built form and therefore reduce the sense of openness experienced in views across the site where available. However, that sense of openness has already been eroded by the surrounding built form. The site has clear boundaries that follow Widney Manor Road to the west, strong vegetation to the east and the built form and rear gardens of properties along Lovelace Avenue to the south. development of the site will not contribute to 'unrestricted sprawl' or 'the merging of neighbouring towns'. We do not agree that landscape presents a constraint to development as the character assessment is broad in nature and a more site-specific assessment may come to a different view. We consider the site has very high accessibility. It is within a highly sustainable location, being in very close proximity to Widney Manor Station, St. Alphege primary school and Solihull Sixth Form College. A number of secondary schools are also relatively close. There are no constraints which cannot be mitigated.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8793
Received: 15/03/2019
Respondent: Mr Eric Homer
Site 13 to become a formal public open space.
Disproportionate 38% of additional housing in Shirley South.
The potential of other areas in the Borough that can absorb some of this capacity should be more ardently examined.
Proposals are contrary to the objective of protecting key gaps between urban areas and settlements.
Developing residential buildings in the town centre makes good sense.
Unacceptable increase in traffic volumes and decreasing air quality.
Increase in urban sprawl.
Full utilisation of Brownfield sites across the West Midlands Combined Authority has not been made.
Build near employment areas, not miles away in Shirley.
Q2 Site Selection Methodology
The Council should be praised for listening to the residents of South Shirley who have demonstrated the importance of the informal open space of site 13 which has been removed from the plan. This area should now be made into a formal public open space.
However the revised plan still proposes a totally iniquitous and disproportionate 38% of Solihull's additional housing needs concentrated in the Shirley South area. The effect will be to completely change the character of the area from a semi-rural location to an urban sprawl.
The potential of other areas in the Borough that can absorb some of this capacity should be more ardently examined. I know that houses are needed but they need to be far more evenly allocated and close to the employment growth areas of the borough.
There isn't equal weighting given to the natural environment that borders Shirley. Sites 4, 12 & 26 are areas of biodiversity and habitat of value, an important area for local wildlife in Shirley. We have lost too many of these areas already.
Building houses on sites 4, 12 & 26 is contrary to the objective of protecting key gaps between urban areas and settlements. Sites 4, 12 & 26 provide a valuable green, healthy area separating the areas of Shirley, Cheswick Green and the ever expanding Dickens Heath Village. To virtually adjoin these areas with more developments would turn a well balanced Mature Suburb into a vast urban sprawl and would destroy the semi rural feeling of the area and be detrimental to the identity and community of the areas.
Developing residential buildings in the town centre makes good sense especially in terms of offering good transport connections and supporting the local economy in the town centre. However, the concentration of settlements to the south of Shirley does not make any sense. The Shirley area is already subject to a huge amount of congestion which affects the whole of the Stratford Road from the M42 junction and all arterial routes, including Dog Kennel Lane, Tanworth Lane, Shakespeare Drive, Blackford Lane, Haslucks Green Road and Bills Lane. Some of the local rat runs such as Stretton Road constantly has drivers coming along the road at ridiculous speeds, in an area with two schools and a large elderly community. The addition of thousands of new homes will compound congestion and traffic flow to a catastrophic level and also increase rat run traffic.
In terms of benefitting from HS2, I can understand the logic of building residential
properties in the vicinity of UK Central, but if properties were built around Shirley, residents would need to access both the A34 and the M42, worsening what are already congested roads.
The loss of green belt around the existing estates of Shirley, increased traffic volumes and decreasing air quality will have to be borne by residents of Shirley South. The development of these sites would bring about an increase in urban sprawl. I do not consider that full utilisation of Brownfield sites across the West Midlands Combined Authority has been made. Sites to the east of Solihull should be looked at with greater intensity. There is greater opportunity to develop infrastructure around the edge of the smaller conurbations, offering the opportunity to provide better public transport links and connect more readily and conveniently with HS2. There is less risk of merging of settlements with distinctive identities, as the gap between settlements is far larger. These sites are also closer to the growth areas of JLR, the airport the NEC and HS2. Put the houses where the employment areas are, not miles away in Shirley.
Also, the town centre offers an opportunity for higher density housing more than anywhere else in the Borough. The benefit to the community should be put before property developers.
The government has stated that housing should concentrate on high density smaller, affordable homes, such as terrace, mews and flats. The footprint of these is much smaller than large detached houses. Developing sites in this manner close to the employment growth areas in the east of the Borough would alleviate the need to develop important green belt locations such as sites 4, 12 & 26 preserving an area of diverse eco systems, full of wildlife and of immense value to the community.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8795
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land North of School Road
Agent: Barton Willmore Planning
We broadly agree with the methodology but raise issues with the manner in which it has been applied to the site assessment process. Specifically we object to the manner in which our site (site assessment reference 416) has been assessed as 'red'. We do not agree with the conclusion that it will have 'severe or widespread impacts that are not outweighed by the benefits of the proposal'. Site is well enclosed by defensible boundaries to the west by Ashford Lane and a detached dwelling; to the south by School Road and a detached dwelling; and to the north by another detached dwelling and agricultural buildings. Do not agree that landscape presents a constraint to development, the character assessment is broad in nature and a more site-specific assessment would arrive at a different conclusion having regard to the context of this site. A number of larger allocations have similar landscape characteristics. Site adjacent to 84 School Lane is assessed as green and our site could result in an identical conclusion. Site contains good accessibility to services and facilities in the village. This includes Hockley Heath Primary School and a bus service to Dorridge, which contains a rail station with direct links to Solihull and Birmingham. Other nearby services in Hockley Heath can be accessed by a short walk or cycle. Hockley Heath should be higher in the settlement hierarchy and identified as suitable for higher levels of growth.
We consider that Hockley Heath is a sustainable location for additional housing growth as it has a sufficient range of services and facilities within the village, including a primary school.
There are no constraints which cannot be mitigated, including heritage, flooding, ecology, trees and access. Development here would not adversely impact upon the character of the settlement.
Improved accessibility is proposed for properties along School Road to and from the village centre through the provision of a footpath.
The site is in single ownership and is available for development with no legal or ownership problems.
It is free from significant constraints and there is strong market demand for housing in this area, it can therefore be considered deliverable (from the point of Local Plan adoption) in terms of the definition within the NPPF.
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8812
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land West of Stratford Road
Agent: Barton Willmore Planning
Objection to site selection methodology relates to SHELAA Site 417.
Do not agree with commentary or conclusions:
- Appropriate landscape and vegetation buffer could be included in development
- Disagree site would result in reduction in the gap between Hockley Heath and BVP/Cheswick Green, especially vis-à-vis proposed site at Whitlocks End Farm
- Landscape Character Assessment only broad in nature, need to look at site context
- Site similar to land adj. to 84 School Road and RAG should also be green
- Site has good accessibility to services and facilities
- Consider Hockley Heath should be considered higher in the hierarchy
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8833
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land Fronting Waste Lane
Agent: Barton Willmore Planning
Site 79 (part of wider site allocation 21 - Pheasant Oak Farm). We broadly agree with the methodology but note there are issues with the manner in which it has been applied
to the site assessment process across the Borough. Whilst we support the positive assessment of this site, we
would query the Council's conclusions that the site has a 'low level of accessibility'. By the Council's own criteria on page 18 of the draft Plan, the site is accessible as it is 'on the edge of an urban area' and 'on the edge of a settlement that has a wide range of services including a primary school and a range of retail facilities'. The site is around 15 minutes' walk from Balsall Common Primary School.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8849
Received: 15/03/2019
Respondent: Mr Bob Holtham
The methodology and conclusions made in the document on the sites within the Arden Triangle and the Blue Lake Road 'Amber' site are too broad brush and do not address local landscape and character issues.
I support the Representations made on the Plan by KDBH and Crestwood and also the Representation made by Pegasus Planning Group on the two sites.
The methodology and conclusions made in the document on the sites within the Arden Triangle and the Blue Lake Road 'Amber' site are too broad brush and do not address local landscape and character issues.
I support the Representations made on the Plan by KDBH and Crestwood and also the Representation made by Pegasus Planning Group on the two sites.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8851
Received: 15/03/2019
Respondent: Mrs Lyn Holtham
The methodology and conclusions made in the document on the sites within the Arden Triangle and the Blue Lake Road 'Amber' site are too broad brush and do not address local landscape and character issues.
I support the Representations made on the Plan by KDBH and Crestwood and also the Representation made by Pegasus Planning Group on the two sites.
The methodology and conclusions made in the document on the sites within the Arden Triangle and the Blue Lake Road 'Amber' site are too broad brush and do not address local landscape and character issues.
I support the Representations made on the Plan by KDBH and Crestwood and also the Representation made by Pegasus Planning Group on the two sites.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8852
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We broadly agree with the methodology but raise issues with the manner in which it has been applied to the site assessment process. Below we set out our concerns with the Council's previous assessment of the site for housing (reference 305). The site was assessed as 'red' and we do not agree with the conclusion that it will have 'severe or widespread impacts that are not outweighed by the benefits of the proposal'. The site is relatively free from constraint. Issues such as heritage, given the Grade II and II* listed buildings on Lavender Hall Lane, can be satisfactorily addressed through good design. This is bearing in mind the Council's conclusions on how their setting will already be affected by HS2. The site is within a large parcel (BA04) that is assessed as high performing this parcel probably the largest within the Borough. This is a meaningless assessment of the site's contribution
to the Green Belt, particularly as it does not take into account the amendments to the Green Belt around Balsall Common that are proposed through the draft Plan. HS2 should be considered in the assessment as the proposed route runs through the site and crosses Park Lane. HS2 will provide the site with an even stronger defensible boundary to the east. In addition, Park Lane is being upgraded alongside the provision of a new roundabout with the A452 to provide construction access for HS2. Accordingly, a more site-specific Green Belt assessment which accounts for committed development would clearly result in a significantly poorer score for this parcel of land. Landscape character assessment is broad and does not take into account HS2 and the upgraded Park Lane, which will have significant implications for the surrounding landscape and its capacity for further change. the Council have identified a number of allocations with similar landscape character, including other Balsall Common allocations such as the nearby Land at Wootton Green Lane and Kenilworth Road (reference 240). Consistency in the approach to assessments is required. We consider the site has high accessibility. It is less than 15 minutes walk from Berkswell Station, less than 10 minutes walk from the Sainsburys Local. Significant number of residents within walking and cycling distance of the employment opportunities presented by this site, including several 'green' assessed sites nearby. The site should be reassessed as a green site and identified as a draft allocation for employment purposes towards the end of the Plan period.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8868
Received: 14/03/2019
Respondent: Mr D Deanshaw
This is very poor, a wider view of potential development is essential. Many sites have been considered in isolation. In some cases adjacent sites could be absorbed and create interesting enclaves
See Letters
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8880
Received: 15/03/2019
Respondent: Ms Wendy Gault
The methodology used to identify sites has not been applied in a systematic transparent way particularly with regard to the green belt analysis, and additional pressure on the green belt with HS2, local amenity and infrastructure e.g rail services in Balsall Common, the line cannot accommodate more trains and they are already massively overcrowded vis a vis other local areas where infrastructure more able to cope with housing but sites not identified. The selection methodology is not transparent and it is not clear how sites have been selected or how the assessment criteria have been scored and applied.
The methodology used to identify sites has not been applied in a systematic transparent way particularly with regard to the green belt analysis, and additional pressure on the green belt with HS2, local amenity and infrastructure e.g rail services in Balsall Common, the line cannot accommodate more trains and they are already massively overcrowded vis a vis other local areas where infrastructure more able to cope with housing but sites not identified. The selection methodology is not transparent and it is not clear how sites have been selected or how the assessment criteria have been scored and applied.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8885
Received: 14/03/2019
Respondent: Kler Group - Gentleshaw Lane
Agent: Cerda Planning Ltd
- Do not consider there to be any issues with the first stage of the site selection/assessment process.
- Second stage of process is highly complex and respondent does not agree with the methodology of the site selection process. The numerous elements of the Council's assessment process allow for a higher incidence of error or for assessments to be overly subjective.
- The site selection process relies heavily on the accompanying Sustainability Appraisal. The use of the Sustainability Appraisal in assessing sites for allocation has not provided a firm framework for the individual evaluation of potential sites.
- Stratford-upon-Avon utilises a better approach to their site assessment methodology in accordance with Planning Practice Guidance
- Solihull Councils' assessment framework does not allow for constraints to be weighed differently and does not allow for mitigation of soft constraints.
see attached document
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8922
Received: 15/03/2019
Respondent: Mrs Linda Homer
Site 13 to become a formal public open space.
Disproportionate 38% of additional housing in Shirley South.
The potential of other areas in the Borough that can absorb some of this capacity should be more ardently examined.
Proposals are contrary to the objective of protecting key gaps between urban areas and settlements.
Developing residential buildings in the town centre makes good sense.
Unacceptable increase in traffic volumes and decreasing air quality.
Increase in urban sprawl.
Full utilisation of Brownfield sites across the West Midlands Combined Authority has not been made.
Build near employment areas, not miles away in Shirley.
Q2 Site Selection Methodology
The Council should be praised for listening to the residents of South Shirley who have demonstrated the importance of the informal open space of site 13 which has been removed from the plan. This area should now be made into a formal public open space.
However the revised plan still proposes a totally iniquitous and disproportionate 38% of Solihull's additional housing needs concentrated in the Shirley South area. The effect will be to completely change the character of the area from a semi-rural location to an urban sprawl.
The potential of other areas in the Borough that can absorb some of this capacity should be more ardently examined. I know that houses are needed but they need to be far more evenly allocated and close to the employment growth areas of the borough.
There isn't equal weighting given to the natural environment that borders Shirley. Sites 4, 12 & 26 are areas of biodiversity and habitat of value, an important area for local wildlife in Shirley. We have lost too many of these areas already.
Building houses on sites 4, 12 & 26 is contrary to the objective of protecting key gaps between urban areas and settlements. Sites 4, 12 & 26 provide a valuable green, healthy area separating the areas of Shirley, Cheswick Green and the ever expanding Dickens Heath Village. To virtually adjoin these areas with more developments would turn a well balanced Mature Suburb into a vast urban sprawl and would destroy the semi rural feeling of the area and be detrimental to the identity and community of the areas.
Developing residential buildings in the town centre makes good sense especially in terms of offering good transport connections and supporting the local economy in the town centre. However, the concentration of settlements to the south of Shirley does not make any sense. The Shirley area is already subject to a huge amount of congestion which affects the whole of the Stratford Road from the M42 junction and all arterial routes, including Dog Kennel Lane, Tanworth Lane, Shakespeare Drive, Blackford Lane, Haslucks Green Road and Bills Lane. Some of the local rat runs such as Stretton Road constantly has drivers coming along the road at ridiculous speeds, in an area with two schools and a large elderly community. The addition of thousands of new homes will compound congestion and traffic flow to a catastrophic level and also increase rat run traffic.
In terms of benefitting from HS2, I can understand the logic of building residential
properties in the vicinity of UK Central, but if properties were built around Shirley, residents would need to access both the A34 and the M42, worsening what are already congested roads.
The loss of green belt around the existing estates of Shirley, increased traffic volumes and decreasing air quality will have to be borne by residents of Shirley South. The development of these sites would bring about an increase in urban sprawl. I do not consider that full utilisation of Brownfield sites across the West Midlands Combined Authority has been made. Sites to the east of Solihull should be looked at with greater intensity. There is greater opportunity to develop infrastructure around the edge of the smaller conurbations, offering the opportunity to provide better public transport links and connect more readily and conveniently with HS2. There is less risk of merging of settlements with distinctive identities, as the gap between settlements is far larger. These sites are also closer to the growth areas of JLR, the airport the NEC and HS2. Put the houses where the employment areas are, not miles away in Shirley.
Also, the town centre offers an opportunity for higher density housing more than anywhere else in the Borough. The benefit to the community should be put before property developers.
The government has stated that housing should concentrate on high density smaller, affordable homes, such as terrace, mews and flats. The footprint of these is much smaller than large detached houses. Developing sites in this manner close to the employment growth areas in the east of the Borough would alleviate the need to develop important green belt locations such as sites 4, 12 & 26 preserving an area of diverse eco systems, full of wildlife and of immense value to the community.