Site Selection Methodology
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10133
Received: 15/03/2019
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Inconsistencies in Step 1 assessment for Site 199 Four Ashes Road. 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 199 should undergo Step 2 assessment and be identified as Green or Amber Site.
Please find attached a representation to the Solihull Draft Local Plan Review Supplementary Consultation, made on behalf of L&Q Estates. This representation relates to Land at Four Ashes Road, Dorridge, and comprises the following attached documents:
* Consultation Response Document
* Representations Report, dated February 2017 (Appendix 3)
* Vision Document, dated February 2017 (Appendix 4)
* Un-met Housing Need and Duty-to-Cooperate (Appendix 5)
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10149
Received: 15/03/2019
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Inconsistencies in Step 1 assessment which has led to higher scores and GBA approach has led to inconsistencies in assessing edge of settlement sites. Consider that there is no justification for Site 196 Bickenhill Road, identified as priority 5 in Step 1 and Red in Step 2, not to be identified as a Green or Amber Site, as evidenced in LVI statement.
Consideration of Amber Sites includes little additional analysis and there are inconsistencies between site assessments.
Site 199 should undergo Step 2 assessment and be identified as Green or Amber Site.
Please find attached a representation to the Solihull Draft Local Plan Review Supplementary Consultation, made on behalf of L&Q Estates. This representation relates to Land at Bickenhill Road Marston Green , and comprises the following documents:
* Consultation Response Document
* Representations Report, dated February 2017 (Appendix 3)
* Vision Document, dated February 2017 (Appendix 4)
* Un-met Housing Need and Duty-to-Cooperate (Appendix 5)
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10157
Received: 15/03/2019
Respondent: L&Q Estates - Land at Bickenhill Road, Marston Green
Agent: Pegasus Group
Inconsistencies in Step 1 assessment which has led to higher scores and GBA approach has led to inconsistencies in assessing edge of settlement sites.
Consideration of Amber Sites includes little additional analysis and there are inconsistencies between site assessments.
Assessment of Site 197 Berkswell Road, Meriden based on wider parcel rather than smaller area off Berkswell Road. Based on evidence in the LV Statement, it is considered that Site 197 should be lower performing in the GBA and identified as priority 5 in Step 1. Under Step 2 it should have been assessed as a Green or Amber Site.
Please find attached a representation to the Solihull Draft Local Plan Review Supplementary Consultation, made on behalf of L&Q Estates. This representation relates to Land at Berkswell Road, Meriden, and comprises the following documents:
* Consultation Response Document
* Representations Report, dated February 2017 (Appendix 3)
* Vision Document, dated February 2017 (Appendix 4)
* Un-met Housing Need and Duty-to-Cooperate (Appendix 5)
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 10167
Received: 15/03/2019
Respondent: Taylor Wimpey
Agent: Lichfields
Agree with approach taken by the Council to identify suitable sites for development. It is right to first consider brownfield sites and to then other accessible and sustainable locations, as required by paragraph 138 of NPPF.
Agree Step 2 conclusions for Site 122, but not fully with comments on accessibility and landscape. Accessibility comments not consistent with positive findings in Interim SA (January 2017). LCA not fully relevant to Site 122 as it covers much larger area, does not assess specific capacity levels, and includes landscape sensitivities and value not relevant to site.
We write on behalf of our client Taylor Wimpey UK Ltd (TW), with regards to the Supplementary Consultation document and Concept Masterplan for Site 12
.As you are aware, Taylor Wimpey own much of the land in the Proposed Housing Allocation 12 South of Dog Kennel Lane, Shirley. Taylor Wimpey therefore fully support the allocation of the site for residential development and can confirm that housing development at this site is deliverable. The site is well located to
shops, employment, public transport and schools and is therefore in a highly sustainable location.
To support the allocation and to demonstrate how this can deliver a new sustainable community, we include an updated Development Statement for Site 12 (Appendix 1) prepared on behalf of Taylor Wimpey. This clearly sets out how a masterplan for this site, prepared for Taylor Wimpey, has evolved to address all of the constraints and opportunities. In addition, the following technical reports have been provided in support of the allocation:
* Ecology Technical Note prepared by EDP (Appendix 2)
* Green Belt Position Note prepared by EDP (Appendix 3)
* Flood Risk Scoping Note prepared by BWB Consulting (Appendix 4)
* Transport Report prepared by Vectos (Appendix 5)
The Heritage Assessment will be finalised on receipt of the SMBC report currently being prepared.
Overall, we consider that a housing allocation at this site could deliver in the order of 1,200 new homes together with associated social and physical infrastructure and public open space within a well landscaped and high quality designed masterplan.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10171
Received: 14/03/2019
Respondent: Mr P Benton and Mr T Neary
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),
See Letters
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10198
Received: 14/03/2019
Respondent: Terry Clayson
Too many houses planned for Blythe 38% of the boroughs allocation is unfair
See Letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10275
Received: 14/03/2019
Respondent: Mr Adam Hunter
Site 4 does not perform well against Refinement Criteria:
Not in accordance with spatial strategy which only supports 'proportional additions' to lower order settlements.
Category 3 site within the SHELAA.
Masterplans document shows strong landscape boundary and Ancient Woodland on boundary between site and Dickens Heath. This is an existing strong defensible green belt boundary that would be breached.
Proposed Green Belt boundaries would be narrow rural lanes with open countryside beyond, and not represent strong defensible boundaries.
Medium/High Accessibility Score, yet other sites with similar score have been discounted on accessibility grounds.
Very low landscape capacity rating/important historical landscape.
I wish to object to the proposal to develop for housing, Site 4, west of Dickens Heath, I have attached my objections as they are over 100 words.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10289
Received: 13/03/2019
Respondent: Mark Taft
Methodology of site selection failure to meet NPPF2 par 3.32 and government sustainability scorecard.
38% of Solihull housing in Blythe Valley
No road capacity for another 400 cars for 2000 new homes
Loss of green belt for community use
Methology of site selection failure to meet NPPF2 par 3.32 and government sustainability scorecard
No recognition of existing air pollution levels
Lack of info structure expansion options
Limited Parking at stations
Removal of Playing fields
Congestion and grid locked roads already a problem
Lack of schools and GP surgery's
Flooding
We agree with the expert view of Jean Walters, see attached document.
What is needed :-
Parking at Earlswood station, Cycle paths through Area13
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10346
Received: 14/03/2019
Respondent: Susan Roberts
Object to further consultation being undertaken on the Amber sites that the Council have already assessed and rejected. (In particular Amber site ref A7). It potentially gives promoters of these sites a 'way in' which is contrary to the Council's own assessment and conclusions reached.
Reference Sites 134, 205 and 308
I strongly object to the removal of these areas from the Green Belt. Site 134 was the subject of a refused Planning Application (2010/2) and the Appeal which followed was dismissed at the Inquiry. I can see nothing which has changed to now justify the removal of these sites from the Green Belt.
see supporting letter and appendices
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10435
Received: 15/03/2019
Respondent: Amber REI Ltd
Agent: Pegasus Group
The Amber sites are not identified as having any particular purpose and the whole concept of Amber sites is considered to be flawed.
Key weakness in the approach is the reference to the scoring of Green Belt purposes. the Site Hierarchy Criteria has artificially moderated these scores, increasing the scoring base to 5 for lower performing Green Belt sites, condensing moderately performing sites to just 6 or 7, and increasing the range for higher performing sites to 8 or more.
Pegasus Group are instructed by Amber REI Limited to consider the
appropriateness of the proposed 'Amber Sites'. These representations relate to
question 38 of the Draft Local Plan Supplementary Consultation. In particular the
representations made relate to the land known as Land off Blue Lake Road,
Dorridge (Reference A5).
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10436
Received: 15/03/2019
Respondent: Grove Road Residents
Agent: Pegasus Group
The methodology utilised in the site selection process has not been applied
consistently and robustly across all of the sites that have been put forward.
The Council's approach has significantly underscored the Green Belt and landscape significance of site 9.
There is failure to distinguish between particular areas of the site which are more important in Green Belt and landscape terms than others.
Pegasus Group have been instructed by Grove Road residents to appraise and
respond to the Local Plan (LP) relative to the Arden Triangle site allocation (site
9). This site lies within the Green Belt and is immediately adjacent to the
settlement.
see attached letter
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10447
Received: 14/03/2019
Respondent: Jeanette McGarry
Factors such as accessibility, hard constraints and sustainability are subjective and require quantifiable measures, categorisation and weighting where appropriate. A similar approach to that adopted for the SHELAA.
There is no consideration given to any assessment for highways.
See Letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 10503
Received: 15/03/2019
Respondent: CPRE Warwickshire Branch
Significant inconsistencies in application of site selection methodology.
Sustainability analysis does not meet NPPF criteria, in Para. 3.32.
Assessment excludes some of smaller sites from the sustainability appraisal.
Smaller sites need to be reconsidered that have not been allocated as they could provide more sensitive development.
see attached letter of response