Site Selection Methodology

Object

Representation ID: 9552

Received: 15/03/2019

Respondent: Richard Cobb Planning

There are significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process. The Council should consider reviewing the SA in line with criteria set out in the Governments sustainability scorecard. For example using this to analyse site 4, the site only scored 30% sustainability putting it in a red rather than green category. It is difficult to see how some of the sites fall into the green category when they clearly have high impact. The SA excludes some smaller sites. There are missed opportunities for some red and amber sites to come forward in lesser performing green belt locations. Provision should be made for employment for existing and proposed residents in Dickens Heath, Balsall Common and Knowle.

Comment

Representation ID: 9569

Received: 15/03/2019

Respondent: IM Land

Agent: Stansgate Planning LLP

Methodology is useful, but Step 1 should focus on accessibility as well as green belt, and Step 2 should take account of other evidence such as SHELAA, Landscape Character and SA, and allow for refinement as evidence, such as LCA relates to large parcels and not necessarily sites, that may be a small part of a parcel.
Accessibility needs to be weighted similar to green belt as evidence available and updated and should reflect Accessibility Mapping.
Site Assessments document should follow same sequence with Step 1 at the beginning of the Assessment followed by Step 2 factors.

Object

Representation ID: 9574

Received: 15/03/2019

Respondent: Bloor Homes

Agent: Savills

Object to the scoring of site 192has received in the Site Assessment document .
Do not support the Step 2 'refining criteria' and the lack of clarity of how sites have been assessed against the factor listed in the table.
Sites have been scored inconsistently, when they are in close proximity to each other.
Site specific benefits have not been considered.

Comment

Representation ID: 9583

Received: 15/03/2019

Respondent: Mr J Allen

Agent: Cerda Planning Ltd

Do not disagree in principle, but issues with execution and lack of transparency.
The SA is part of the refinement process, but some sites are still assessed as clusters and not given a full SA, therefore disregard for site specifics.
Need further evidence of how the overall assessment has been arrived at. The selection process is subjective and confused. Stratford-upon-Avon use a more refined approach.
Assessment methodology is illogical, overly subjective and inconsistent. The assessment framework does not allow for constraints to be weighted differently (e.g hard and constraints). The process does not allow for mitigation of soft constraints.

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.

Comment

Representation ID: 9616

Received: 15/03/2019

Respondent: Albanwise Ltd

Agent: Barton Willmore

- Supportive of first step in Site Selection Methodology
- SHELAA Site 125 scores favourably and agree with appraisal
- Deem that SHELAA Site 125 should be specifically allocated for minimum 20 dwellings

Comment

Representation ID: 9618

Received: 15/03/2019

Respondent: Balsall Parish Council

The methodology does not consider the cumulative impact of sites assessed as appropriate. A better approach would be to develop a strategic plan taking into account the locations best suited for new residents/infrastructure. Should not be driven by 'cherry picking' most desirable sites to achieve numbers but from a strategic settlement expansion plan. In considering this 'settlement first' approach, the proposal to amend the green belt boundary to the east (paragraph 97) would support retention of the existing green belt boundary to the south-west of Balsall Common and negate sprawl.

Object

Representation ID: 9634

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

We strongly object to the way in which SHELAA Site 209 has been assessed in the site selection process for the reasons set out below - and on that basis, object to the inconsistent application of the methodology.
SHELAA Site 209 should be Priority 5 (yellow) as it is accessible in a lower scoring Green Belt location.
Site 209 scores lower in GB terms than proposed allocation Site 4.
Site has existing strong defensible Green Belt boundaries.
Would provide significant amenity open space above requirements.
Medium/High Accessibility location.
Site therefore would accord with the Spatial Strategy in DLP 2016.
SHLEAA scoring should be amended as contaminated land issues can be overcome. N.B. TPOs would be unaffected.

Object

Representation ID: 9645

Received: 15/03/2019

Respondent: Mr & Mrs Williams

Agent: Oakwood Planning Ltd

It is agreed that brownfield sites should be prioritised, but sites which are partly brownfield and partly greenfield should be prioritised over solely greenfield.
If a site is not correctly assessed as Green at Step 1, it is agreed the accessibility criteria should be refined as part of Step 2, but this needs to be carried out accurately.

Comment

Representation ID: 9650

Received: 15/03/2019

Respondent: Mr & Mrs Michael & Marion Joyce

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.

Object

Representation ID: 9675

Received: 15/03/2019

Respondent: Kendrick Homes Ltd

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.

Object

Representation ID: 9684

Received: 15/03/2019

Respondent: Belle Homes Ltd

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.
Absence of evidence eg more detailed studies following Strategic Growth Study/Landscape Character Assessment
Contend that despite use of Standard Methodology based on 2014
household projections, there is still no signed Statement of Common Ground,
(contrary to NPPF),

Comment

Representation ID: 9716

Received: 15/03/2019

Respondent: Avison Young

The Council's approach under Step 1 - Site Hierarchy Criteria - is considered appropriate and compliant with NPPF.
Considered appropriate to seek land for housing in low performing Green Belt due to evidence in SHELAA on lack of supply on non-Green Belt sites.
Agree that DLP Site 16 is a Priority 5 site and suitable for Green Belt release as it lies within a parcel of low-performance Green Belt with strong, defensible boundaries and is proximate to the facilities and services of Solihull town centre.

Object

Representation ID: 9724

Received: 15/03/2019

Respondent: Mrs Jean Walters

Disagree with methodology.
Significant inconsistencies in the application of the methodology which undermine the integrity of the whole site selection process.
Sustainability analysis does not comply with Para 3.32 of NPPF. E.g. Site 4 would score 30%.
Assessment excludes a number of smaller sites from the SA.
Strategy continues to focus on large scale Green Belt release for developments.
Smaller sites should be reassessed as could meet housing need in more sensitive way, with less impact on Green Belt and local character.

Comment

Representation ID: 9754

Received: 15/03/2019

Respondent: IM Land

Agent: Turley

Considered Step 1 - Hierarchy criteria does not fully align with NPPF recommendations.
Accessibility should be more strongly featured in Step 1 and not as in Footnote 35.
Five purposes of Green Belt should not be considered ahead of Acessibility.
Step 2 should include sites well served by public transport in 'factors in favour'.
In reference to Site 141, this site would be advanced to Step 2 as proximity to Earlswood Station is an accessible location.

Object

Representation ID: 9760

Received: 14/03/2019

Respondent: Terry Clayson

Far too many houses being planned for the Blythe area and Shirley is taking the brunt of the allocations. The allocations are not being evenly distributed across the Borough.

Object

Representation ID: 9772

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

Strongly object to application of two stage site selection methodology. A more detailed assessment of the step 2 assessment specifically in relation to sites identified within Hampton in Arden clearly indicates that the planning judgement has not been applied consistently, on a like-for-like basis, across sites within a single settlement or that are comparable in character and/or size. Does not object to the methodology but does object to the inconsistency of its application.

Object

Representation ID: 9781

Received: 14/03/2019

Respondent: Mrs Brenda Clayson

Far too many houses being planned for the Blythe area and Shirley is taking the brunt of the allocations. The allocations are not being evenly distributed across the Borough.

Object

Representation ID: 9850

Received: 14/03/2019

Respondent: Schools of King Edward VI in Birmingham

Agent: Avison Young

The short answer to this question is 'no'. The deficiencies stem firstly from a flawed approach to calculating housing supply over the plan period, and then from an approach to reviewing potential housing sites that is beset by weaknesses.
Generally support approach in Step 1 of prioritising brownfield, accessible and Green Belt locations.
Do not support allocating colour status to each site. Summary explanation does not agree with diagram, as some yellow sites become red rather than amber. Text should be updated to reflect diagram.
No guidance on how factors for and against are weighted/ranked.
Green Belt issues should be considered in totality, and not piecemeal, i.e. the extent to which individual sites contribute to the purposes of the Green Belt.

Comment

Representation ID: 9855

Received: 15/03/2019

Respondent: Historic England- West Midlands Region

Noted that the relative suitability of a site will be judged against whether harm to the historic environment can be mitigated.
Would be helpful for the Council to confirm that the above accords with the need to:
-Take sufficient account of the evidence base to avoid or minimise harm to the significance of heritage assets (NPPF para 190)
-Attach great weight to the conservation of effected heritage assets (NPPF para.193), and
-Have had due regard to the desirability of preserving the setting of effected listed buildings in accordance with S66 of the Planning (Listed Buildings and Conservation Areas) Act, 1990.

Comment

Representation ID: 9880

Received: 15/03/2019

Respondent: Stephen Dunn

Agent: Sworders

Site selection process appears to be sound to a certain extent. However, step 2 using planning judgement, appears to be too subjective and as such, leads to inexplicable inconsistencies. Paragraph 69 states that there may be some 'exceptional reasons' why certain sites fall into certain categories, however, going through just some of the assessment criteria, the required justifications are not explicit.

Support

Representation ID: 9884

Received: 15/03/2019

Respondent: Real Christmas Trees Ltd

Agent: Twelve Twenty One Planning Services

The methodology for the site selection process is agreed.

Object

Representation ID: 9894

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

We strongly object to the way in which Site 426 has been assessed in the site selection process for the reasons which are set out in the attached letter - and on that basis, object to the inconsistent application of the methodology

Comment

Representation ID: 9902

Received: 15/03/2019

Respondent: Generator (Balsall) & Minton

Agent: DS Planning

Basic elements of the Methodology acceptable and workable. Other elements are flawed and over complicated.
Non-compliant with Government policy on strong defensible Green Belt boundaries as no reference to creating boundaries in NPPF.
Lack of consistency, particularly when comparing sites in the same location.
Site assessments incomplete in some instances.
Flawed judgements or lack of sound reasons why some sites allocated/rejected /de-allocated.
No advantage in creating yellow, blue and subsequently amber sites. This is unnecessary and adds to confusion and complexity. Delete this element of the methodology and either allocate the amber sites or reject them as proposed allocations.

Comment

Representation ID: 9949

Received: 15/03/2019

Respondent: Rosconn Stategic Land

Agent: DS Planning

Basic elements of the Methodology acceptable and workable. Other elements are flawed and over complicated.
Non-compliant with Government policy on strong defensible Green Belt boundaries. No reference to creating boundaries in NPPF.
Lack of consistency, particularly when comparing sites in the same location.
Site assessments incomplete in some instances.
Flawed judgements or lack of sound reasons why some sites allocated/rejected /de-allocated.
No advantage in creating yellow, blue and subsequently amber sites. This is unnecessary and adds to confusion and complexity. Delete this element of the methodology and either allocate the amber sites or reject them as proposed allocations.

Comment

Representation ID: 9989

Received: 15/03/2019

Respondent: Stonewater

Agent: DS Planning

Basic elements of the Methodology acceptable and workable. Other elements are flawed and over complicated.
Non-compliant with Government policy on strong defensible Green Belt boundaries. No reference to creating boundaries in NPPF.
Lack of consistency, particularly when comparing sites in the same location.
Site assessments incomplete in some instances.
Flawed judgements or lack of sound reasons why some sites allocated/rejected /de-allocated.
No advantage in creating yellow, blue and subsequently amber sites. This is unnecessary and adds to confusion and complexity. Delete this element of the methodology and either allocate the amber sites or reject them as proposed allocations.

Comment

Representation ID: 10029

Received: 15/03/2019

Respondent: Mr T Khan

Agent: DS Planning

Basic elements of the Methodology acceptable and workable. Other elements are flawed and over complicated.
Non-compliant with Government policy on strong defensible Green Belt boundaries. No reference to creating boundaries in NPPF.
Lack of consistency, particularly when comparing sites in the same location.
Site assessments incomplete in some instances.
Flawed judgements or lack of sound reasons why some sites allocated/rejected /de-allocated.
No advantage in creating yellow, blue and subsequently amber sites. This is unnecessary and adds to confusion and complexity. Delete this element of the methodology and either allocate the amber sites or reject them as proposed allocations.

Comment

Representation ID: 10070

Received: 15/03/2019

Respondent: Minton (CdeB) Ltd

Agent: DS Planning

Basic elements of the Methodology acceptable and workable. Other elements are flawed and over complicated.
Non-compliant with Government policy on strong defensible Green Belt boundaries. No reference to creating boundaries in NPPF.
Lack of consistency, particularly when comparing sites in the same location.
Site assessments incomplete in some instances.
Flawed judgements or lack of sound reasons why some sites allocated/rejected /de-allocated.
No advantage in creating yellow, blue and subsequently amber sites. This is unnecessary and adds to confusion and complexity. Delete this element of the methodology and either allocate the amber sites or reject them as proposed allocations.

Comment

Representation ID: 10116

Received: 15/03/2019

Respondent: Mr David Varley

Methodology is questionable in determining the sites selected in the Borough, specifically Site 1. Fails to recognise importance of protecting the Meriden Gap at this narrowest point between settlement and Coventry, or merits of development on west of Balsall Common.
HS2 is not new committed development and should not be used to justify rating for Site 1.

Comment

Representation ID: 10130

Received: 15/03/2019

Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green

Agent: Pegasus Group

Inconsistencies in Step 1 assessment for Site 195 Damson Parkway. Consider that site should be priority 5 (not 6) and be assessed under Step 2, as evidenced in LVI statement.
Consideration of Amber Sites includes little additional analysis and there are inconsistencies between site assessments.
Site 195 should be identified as Green or Amber Site.