Site Selection Methodology

Object

Representation ID: 8953

Received: 15/03/2019

Respondent: Mr Stephen Harvell

Why are there so many homes being built near Shirley

Comment

Representation ID: 8958

Received: 15/03/2019

Respondent: Natural England

Natural England welcomes the inclusion of landscape capacity in the factors against in the refinement criteria.

We advocate allocations on land of least environmental and amenity value.
In particular they avoid:
* designated sites/priority habitats
* Best and Most Versatile (BMV) Agricultural Land
* areas at risk of flooding
* brownfield sites of high environmental value

Object

Representation ID: 9028

Received: 15/03/2019

Respondent: Mr Steve Coathup

The spatial strategy states that green belt development should be the last of the various options available, but this plan has moved significantly towards green belt development than previous versions. The strategy also states that there needs to be a balance between large singular developments and dispersed smaller sites. Clearly, this objective has been disregarded in the current plan

Comment

Representation ID: 9034

Received: 15/03/2019

Respondent: Mr Christopher McDermott

I'm not sure I understand why the methodology has been used or the methods chosen

Object

Representation ID: 9052

Received: 15/03/2019

Respondent: Mrs Carla Meyer Davies

Why is such a large percentage (38%) of new houses being built in Shirley area, this seems unfair.

Object

Representation ID: 9083

Received: 15/03/2019

Respondent: Mrs Debbie Hatfield

Green belt land should not be included - brownfield sites have to take priority.

Object

Representation ID: 9100

Received: 15/03/2019

Respondent: Mr Brian Hillman

I object to the conclusions on Site Assessment Methodology for the proposed Arden Triangle draft allocation and also the Blue Lake Road Amber Site and I completely support the arguments put forward in the KDBH and the Pegasus Planning Representations.

Object

Representation ID: 9126

Received: 15/03/2019

Respondent: Dr Paul Rylah

I object to the methodology in so far as , from the onset, it has discounted the most obvious place to develop, that being the so-called Solihull gap, bordering and south of the M42, between junctions 4 and 5. It is the area that will create the least traffic congestion for existing communities, is significantly larger than the total area required for development, and hence can easily be developed while still maintaining a "gap". A methodology that omits the serious consideration of this area must be deeply flawed.

Object

Representation ID: 9129

Received: 15/03/2019

Respondent: Gemma Welch

Objection to housing in Blythe/Shirley:
- Why are there so many homes near Shirley? Shirley is already pressured an any additional housing would add further strains on the infrastructure.
- There are alternative development opportunities which could be explored in Solihull, such as Knowle, Dorridge, Blythe Valley
- These areas aren't as heavily polluted

Object

Representation ID: 9150

Received: 15/03/2019

Respondent: CPRE Warwickshire Branch

No, because there are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The analysis of sustainability does not meet the standards as set out in the NPPF2 Para. 3.32.
The Council should consider reviewing their Sustainability Appraisal in line with the Government's sustainability scorecard. When applied to Site 4 at Dickens Heath, this site only scored a 30% sustainability rating which puts it in the 'red' not 'green' category. There are other sites that are inconsistent with Option G of the Spatial Strategy.
It is not possible to understand how some of the sites fall into the green category. If an updated sustainability scoring was used the results on site selection would be different. Without this, the credibility and robustness of the process is undermined. It is also noted that the assessment excludes a number of smaller sites from the Sustainability Appraisal. The Plan's strategy continues to focus only on large scale Green Belt releases. This is not consistent with government advice in the NPPF that a mix of sites should be encouraged. Many of the small sites which have not been accepted as allocations in the Plan need to be reassessed to see if they could contribute to housing growth in a more sensitive way which has less overall impact on the Green Belt and on local character, and whether they are more readily deliverable.

Comment

Representation ID: 9160

Received: 14/03/2019

Respondent: The Home Builders Federation Midland Region

The HBF do not comment on the merits or otherwise of individual sites selected for allocation. The Council should also provide maximum flexibility within its overall housing land supply to respond to changing circumstances, to treat the housing requirement as a minimum rather than a maximum and to provide choice and competition in the land market.

Comment

Representation ID: 9221

Received: 14/03/2019

Respondent: Mr & Mrs J King

Agent: PRW Strategic Advice

Simple overlay of built up areas of Earlswood/Wythall would illustrate land owner/developer interest. Potential for clustering sites to explore sustainable new settlement has not been assessed by methodology.

Such a proposition is recognised to require effective cross-boundary working between a number of different local planning authorities and so would engage the Duty to Cooperate but it is a reasonable alternative strategy to that being pursued by the Local Plan Review and so should be the subject of Sustainability Appraisal.

Object

Representation ID: 9222

Received: 14/03/2019

Respondent: Mr & Mrs J King

Agent: PRW Strategic Advice

Rather than packaging sites which are geographically clustered together precludes the effective exploration of the potential for strategic land releases which could, through comprehensive treatment of an area, deliver new homes, services & green infrastructure in a way which minimises impacts on landscape & the Green Belt and which so would establish Green Belt boundaries which are clear.

The 'partial approach' results in poor scores for individual sites in terms of Green Belt boundary definition and also impacts on assessments of accessibility and service provision.

Flaw in methodology- clusters of sites need to be assessed as a group not individually

Support

Representation ID: 9239

Received: 14/03/2019

Respondent: Dickens Heath Parish Council

we agree with the council's site selection methodology.

Comment

Representation ID: 9266

Received: 15/03/2019

Respondent: IM Land

Agent: Barton Willmore Planning

we raise certain concerns with the methodology of the site selection processes. Mainly, the reliance on the Accessibility Study, and lack of consideration of other sustainable modes of transport, is a failing which needs to be remedied. Further, there would appear to be anomalies within the assessment process and the Council should ensure this is standardised. the Site at Jacobean Lane (submitted to the Council in December 2018), should be included as a preferred option given its positive assessment against the SHELAA and site assessment methodology.

Comment

Representation ID: 9284

Received: 20/03/2019

Respondent: L&Q Estates and Barratt David Wilson Homes

Agent: Avison Young

See attached letter for full question response.
We do not agree with the methodology deployed by the Council. Importantly, the starting point is fundamentally flawed
Further comments on housing land supply, Solihull Local Plan Allocations (2013), Windfall Housing Land Supply (2018-2033), UK Central Hub Area, Site Selection Methodology
we do not consider the Council's delivery estimate to be robust and we will be interrogating its assertions in respect of its other proposed allocations when the Council publishes a detailed housing trajectory

Comment

Representation ID: 9296

Received: 20/03/2019

Respondent: Duchy Homes Ltd

Agent: Barton Willmore Planning

Whilst we broadly agree with the methodology, we raise issue with the way this has been applied inconsistently across the borough

Comment

Representation ID: 9304

Received: 15/03/2019

Respondent: Spitfire Bespoke Homes

Agent: Ridge and Partners LLP

The approach to not seek to allocate a particular number to be accommodated in each settlement is welcomed. Concern that DLP does not include any small sites within the methodology. Whilst it is acknowledged that Step 2 assessment is subject to planning judgement, it is not particularly clear as to why some sites have been excluded.
Part Site 102 Waste Lane, identifies distance to key economic assets yet conclusion indicates site could be considered as part of larger site, when parts are further away.
Site 101 Old Waste Lane is priority 7 but should be 6 as adjacent site.

Object

Representation ID: 9327

Received: 13/03/2019

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

There are significant flaws in both the methodology and its application. The site selection process must be set in the context of the overall housing need and Spatial Strategy, neither of which have been updated for this consultation but should be in the light of new evidence.
In testing the appropriateness of sites, consideration must be given to the impact of new development on the physical, economic and social infrastructure of the settlement and on its character and distinctiveness. The methodology does not do so. There are also significant variations in the scoring assessments of sites which require justification.

Object

Representation ID: 9335

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Avison Young

St Philips does not disagree with the general approach of providing a RAG classification to each site assessment.
Stage 2: No explanation is given, however, as to how the significance of potentially harmful impacts is to be assessed in the exercise of planning judgement.
More generally, no guidance is provided on how the Factors in Favour and Factors Against are ranked and/or weighted. Without such an explanation it is not clear how the individual, or relative, merits of sites are assessed. This is a weakness given that Step 2 is used to either include or reject sites for allocation.

Comment

Representation ID: 9364

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Step 2 process lacks transparency and robustness in way it draws matters for consideration together and balances them in the decision making process, with little explanation.

A number of concerns with the way site 313 has been assessed both in terms of the assessment process and judgements made within this document itself, and also the robustness of the evidence base used to underpin it.

Methodology is applied incorrectly to Site 313 Fulford Hall Farm and is flawed, as Step 1 priority should be 6 rather than 9,in respect of judgements made on green belt and landscape sensitivity. Accessibility study concludes the site has high accessibility therefore logically should be categorised as 6 and not 9 contrary to SMBC evidence base. In the greenbelt assessment the site is within broad area 1 with all broad areas given a score of 3 (highest rating). This is fundamentally flawed and unsound, lacking the detail of a district level assessment and artificially inflating the contribution of the Fulford Hall Farm to safeguarding of the countryside. In terms of landscape character the site is classified within LCA2 and its visual sensitivity is classified as high. Contest the methodology used to establish visual sensitivity which appears to be weakly justified with no explanation of how the classification criteria have been assessed or judged.
11 of proposed site allocations fall under Category 3 in SHELAA and are classed as not currently developable.

Comment

Representation ID: 9373

Received: 15/03/2019

Respondent: Mr. James McBride

Agent: Tyler Parkes Partnership Ltd

Step 2 refinement is contrary to NPPF. Not appropriate to introduce physical boundaries in otherwise open green belt areas. Methodology should set out preferred criteria for defining clear defensible boundaries. Some red sites ruled out due to lack of defensible boundaries, whilst some sites rated green have caveat that physical boundaries will be created. Methodology not consistently and logically applied across all sites.

Comment

Representation ID: 9394

Received: 15/03/2019

Respondent: Christopher Fellows

Concerns about consistency of application of methodology.
- difficult to see how some sites included as green in Step 2, when identified as priority 5 or above in Step 1, and Sustainability Appraisal identifies more negative than positive effects.
- some sites are indicated as having no defensible boundary, when these do have clearly marked boundaries. Other sites have been proposed providing suitable boundaries can be provided.
- some sites excluded because they are isolated, whereas others included because they could become attached to larger parcels of land.
Examples provided in response to questions 6-9, 38, 39 and 44.

Comment

Representation ID: 9451

Received: 15/03/2019

Respondent: Hampton Road Developments Ltd

Agent: Savills

Generally agree with the approach taken to the site selection process at Hampton Road, but scoring of sites 214 and 215 is inconsistent in step 1. Both sites are located adjacent to site 213 but have different scores.
Whilst the further away the site is from the urban area, footpaths and roads, the site may become decreasingly accessible, but accessibility increases closer to the canal. A score of 6 rather than 9 is more appropriate and consistent with the score attributed to site 213.

Comment

Representation ID: 9477

Received: 15/03/2019

Respondent: Heyford Developments Ltd

Agent: Lichfields

Heyford Developments agree with the methodology of the site selection process but strongly disagree with the resulting scores in Step 2 for Draft Allocation Site 8 Hampton Road and Amber Site A5 Land at Blue Lake Road.
Sites 166/213: identified as blue in Step 1, exhibit a number of concerns, setting of listed building, Local Wildlife Sites, TPOs/hedgerows. Whilst could be mitigated, nonsensical to score green in Step 2. Should be red.
Sites 104/413: yellow in Step 1, no significant impacts, should be identified as green in Step 2.

Comment

Representation ID: 9492

Received: 15/03/2019

Respondent: Catesby Estates Limited

Agent: WYG

Approach agreed in principle as it focusses new development in and around existing settlements. Long established that green belt land will be required and that housing need constitutes exceptional circumstances. Requirement to consider all reasonable options before green belt met through Brownfield Land Register, Call for Sites exercises and spatial strategy. Methodology accords with NPPF.

Object

Representation ID: 9497

Received: 14/03/2019

Respondent: IM Properties

Agent: Marrons Planning

Criteria b i and ii of the sequential approach in DLP2016 should be merged to reflect paragraph 138 of NPPF, as no distinction between previously developed land and land well-served by public transport. Delete reference to land lost to committed development as not consistent with NPPF.

Object

Representation ID: 9508

Received: 15/03/2019

Respondent: The Knowle Society

The requirement for new housing is a borough-wide problem. The provision of sites required appears to be unfairly balanced against Knowle. This imbalance is purely due to Green Belt land which is considered to be readily available.
The increase is disproportionate to the size of the settlement.
Suggested that the number of new homes should be based on a more appropriate increase in population numbers such that infrastructure will not become overloaded.

Object

Representation ID: 9519

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

We object to the assessment of our client's site (207) in the Site Assessment document. As a priority 5 site, the land should fall within the 'potential inclusions' (yellow sites) category.
Do not support the Step 2 'refining criteria' and the lack of clarity on how sites have been assessed against the factors listed in the table.
Requires more clarity on step 2 assessment.

Object

Representation ID: 9533

Received: 15/03/2019

Respondent: Richard Lloyd

Fails to consider harm caused by cumulative impact of loss of green belt, takes no account of encroachment within Coventry or of HS2 structures on narrowest part of Meriden Gap, which should be most valued, fails to consider agricultural land quality or accessibility, and envisages green belt release without first exhausting potential for increased densities in town centres and areas well-served by public transport.
Accessibility assessment of Balsall Common inaccurate, as public transport poor and infrequent with trains over capacity, whereas Chiltern line is more frequent and under capacity. Berkswell station poorly served by bus and beyond walking distance for most of community and from proposed developments, with parking oversubscribed.
Selection process distorted by Balsall Common bypass but need not substantiated as nothing in DLP refutes factors causing removal in SLP2013. Surveys show no traffic growth and HS2 not expected to generate significant growth. No evidence that alternative routes, such as shorter western bypass linking UKC with JLR at Fen End, have been evaluated. No evidence that eastern bypass can be funded by proposed developments. Much traffic originates in Balsall Common, and bypass may be ineffective due to number of roundabouts.
Affordability not included which would direct housing to areas of highest value such as Dorridge.
No account taken of scale and deliverability of necessary enhancements to Balsall Common centre.
Criteria should include school availability.