Question 39 - Red Sites

Comment

Representation ID: 9300

Received: 20/03/2019

Respondent: Duchy Homes Ltd

Agent: Barton Willmore Planning

Yes, we consider our Client's Site (Site 1) should be reassessed as a 'green' site in light of the information we have provided in response to question 2. Related to this, the relocation of the village hall from Site 1 to Site 2 should also be assessed as suitable for inclusion within the draft Plan to facilitate this.

Object

Representation ID: 9319

Received: 15/03/2019

Respondent: Strategic Land and Property Team SMBC

Agent: Cushman and Wakefield

Red Site ref 52: Chester Road/Moorend Avenue.
Site should be released from the Green Belt to help the Borough meet its development needs.
Site is in a sustainable location and low scoring parcel of Green Belt.
Development of the site would positively meet the objectives of the Draft Local Plan Review.

Comment

Representation ID: 9332

Received: 13/03/2019

Respondent: Knowle, Dorridge & Bentley Heath Neighbourhood Forum CIO

The Council should review its site assessments as there are inconsistencies regarding several sites. Examples in KDBH include sites within Arden Triangle, Site 213, Site 244, but also smaller sites. Some of these perform well on a number of criteria, and some of the concerns may be able to be overcome. A mix of large and smaller sites in a more dispersed pattern would have less impact on the Green Belt, be more consistent with government guidance and potentially be less damaging to village character and infrastructure.

Comment

Representation ID: 9333

Received: 15/03/2019

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

Agent: Avison Young

Site ref 131: Birmingham Business Park, adj. Coleshill Heath Road.
St Philips is promoting the allocation of the land for the delivery of up to 135 dwellings within the first five years
of the new Local Plan period.

Object

Representation ID: 9336

Received: 15/03/2019

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

Agent: Avison Young

Do not agree that SHELAA Site 131 should be red but green after the Step 2 refinement criteria.
We assume that the Step 2 Assessment will have scored the site highly in terms of 'Factors in Favour' given the lack of hard constraints (and limited soft constraints) and that it comprises part of a 'Lower Performing Refined Parcel' (with a combined score of 3 against the 'threshold' score for lower performing parcels of a
combined score of 5).
The site complies with the Spatial Strategy in the 2016 DLP:
Not subject to any overriding hard constraints
Category 2 not 3 SHELAA site - Vision document shows how concerns can be mitigated.
Site would not breach strong defensible Green Belt boundaries, as not GB parcel boundaries not considered strong in the Green Belt assessment.
Site is in accessible location.
Landscape Character does not have very low capacity.
Sustainability Appraisal is generally favourable, and negative impacts can be overcome.

Comment

Representation ID: 9351

Received: 21/03/2019

Respondent: Halford Holdings

Agent: Tyler Parkes Partnership Ltd

Sites 16 and 17 land south of Hampton Lane and west of Ravenshaw Lane/south of Hampton Lane should be removed from the Green Belt and allocated for housing, or safeguarded for future needs. Sites are suitable, constraint free and deliverable. Conform with strategy to focus development in and around Solihull town centre. Lower performing green belt parcels supported by Sustainability Appraisal in landscape area capable of accommodating development. Site assessment reference to coalescence misleading as GBA indicates little contribution towards Purpose 2. Accessible to facilities and public transport.

Object

Representation ID: 9368

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Significant errors in site assessment for Site 313. Step 1 should be priority 6 as accessibility high and moderately performing in Green Belt Assessment. Step 2 important judgements on green belt/landscape not based on robust evidence. Assigning Broad Areas score of 3 for Purpose 3 in GBA is flawed/unsound and artificially inflates score. Evidence provided demonstrates site has limited impact on Purpose 3 and would not undermine remaining green belt.
Methodology to establish visual sensitivity in LCA muddled/poorly justified with no explanation how classification criteria assessed/judged. High classification based on ancient woodland not evident within site, whilst sub-urban influences in/around settlement ignored. Detailed robust evidence is provided to show site well-contained, capable of accommodating development with limited visual impacts.

Comment

Representation ID: 9388

Received: 15/03/2019

Respondent: Mr. James McBride

Agent: Tyler Parkes Partnership Ltd

Red Site 14: 2440 Stratford Road/Firs Paddock fully satisfies site selection criteria and should be green and allocated. No known constraints preventing redevelopment of this partly brownfield site. Site is in sustainable location, part of built up area of settlement and requires only a minor adjustment to Green Belt boundary. Lower performing in GBA and medium to high accessibility. Object to erroneous application of site selection methodology Step 1 as should be 3/5 not 6, and Step 2 criteria satisfied. Object to statement re lack of defensible boundary as provided by mature trees/hedgerows. Lack of local opposition to site.

Object

Representation ID: 9392

Received: 15/03/2019

Respondent: Christopher Fellows

Call for Sites 233: land NW of Balsall Common well-suited for development, if west side of village favoured for expansion, to reduce construction traffic through village. Sustainability Appraisal only has one more negative than positive effects, land moderately performing in Green Belt Assessment, and defensible green belt boundaries could be provided in form of drainage swales/bunds. Equidistant to economic assets to sites on eastern side.
Site 82: land at Kenilworth Road is suitable, yet also priority 6 and rated red. Error in commentary on SA, whilst reference to no defensible green belt boundary is inaccurate, as woodland to SW and part NW.
Site 421: Silver Tree Farm, Balsall Street also priority 6 and rated red, but could be part of larger site with Sites 233/198 and has well established field boundary to NW.
Site 422: Rose Bank, Balsall Street has Step 1 priority 5, and identified as suitable as windfall, so should be rated green/amber, not red. Existing green belt boundary not defensible, lower performing in GBA and stands inclusion as smaller site.

Comment

Representation ID: 9403

Received: 15/03/2019

Respondent: Mr M Trentham

I recommend that the proposed Oldway Drive Area be removed from the Green Belt as part of the review of washed over areas, and therefore that Site 107 - Land at Gentleshaw Lane - be changed from Red to Green. Site 107 has never before been assessed as part of a wider area, already containing c200 dwellings, to be removed from the Green Belt.

Object

Representation ID: 9458

Received: 14/03/2019

Respondent: Roger Howles

Alternative proposal for a new settlement north of Balsall Common needs serious consideration, instead of the significant expansion proposed for the settlement.

Comment

Representation ID: 9493

Received: 15/03/2019

Respondent: Catesby Estates Limited

Agent: WYG

Site 20 south of Hampton Lane, Solihull is a deliverable option to accommodate additional housing. Significantly larger site now being promoted covering approximately 13.69ha. The land constitutes a comprehensive and developable site in an area of lower performing green belt that would provide a strong and defensible Green Belt boundary with established woodland to the east and south. Would not harm purposes of remaining land in green belt, and reduction in openness restricted to well-contained area closely related to settlement edge.

Comment

Representation ID: 9499

Received: 15/03/2019

Respondent: Catesby Estates Limited

Agent: WYG

Site 144 north of Fillongley Road, Meriden is a deliverable option to accommodate housing. Site now covers approximately 8.33 hectares allowing a more comprehensive and developable site whilst delivering a strong and defensible Green Belt boundary to the east and west. Land is lower performing in the GBA and release would not harm purposes of the remaining green belt. Reduction in openness restricted to well-contained area close to settlement edge. Could be considered as part of larger allocation.
Part of site could provide additional educational development/improvements.
Existing green infrastructure within and surrounding could be enhanced.

Comment

Representation ID: 9513

Received: 15/03/2019

Respondent: The Knowle Society

Eight alternative sites (as suggested in 2017 DLP response).
Site ref: 34, 103, 199, 13, 14, 57, 121
The consultation has sought to demonstrate the suitability of site allocations in its selection process.

Object

Representation ID: 9520

Received: 15/03/2019

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

Agent: Savills

Site 207 is adjacent to the settlement boundary, there are limited suitability constraints, the site is bound by roads which are a physical feature that could provide a new Green Belt boundary. Redevelopment of the site would not compromise the five purposes of the green Belt.
The site represents a location which supports the Council's strategic direction of growth.
Seek reassessment of site 207 to correctly be categorised as a Priority 5 site.
Site 207 should be included as an allocation.

Comment

Representation ID: 9547

Received: 15/03/2019

Respondent: Richard Lloyd

There are a large number of smaller sites around the fringe of the built-up area of Knowle, Dorridge, and Bentley Heath, which would seem to have good accessibility and relatively low impact on the Green Belt.
However, the largest missed opportunity is the rejection of the concept of new settlements. The new settlement opportunity identified in the G L Hearn study falls into the area of Sites 76 and 212 at Mercote. The area is well sited for access to UK Central and the major road network. Good quality high frequency bus services already operate in the area. Area does not have high green belt value and proposal supported by Parish Council.

Comment

Representation ID: 9567

Received: 15/03/2019

Respondent: Richard Cobb Planning

Site 82 - Land north of Dengate Drive, Balsall Common
Site is within moderately performing parcel in the Green Belt Assessment, but would not result in an indefensible boundaries. Site has a medium level of accessibility, is in an area of high visual sensitivity with very low capacity for change and is deliverable, subject to some constraints. The SA identifies 5 positive and 5 negative effects, although only the distance to jobs is a significant negative. Settlement identified as suitable for significant expansion, and site would have defensible green belt boundary to the south at Dengate Drive, a woodland to the west and track to the north. This site should be elevated to amber if not green, and considered for release in conjunction with Grange Farm or at a later date

Comment

Representation ID: 9572

Received: 15/03/2019

Respondent: IM Land

Agent: Stansgate Planning LLP

Site 420 north of Main Road, Meriden should be allocated for up to 100 houses. Site Selection topic paper demonstrates Meriden has good level of services and is highly accessible. Suitable for limited expansion and could take more than 100 dwellings.
Site Assessment scores well other than defensible boundaries, which is capable of remedy using existing hedgerows/watercourse. Accessibility Mapping finds very high level of accessibility. Maximum SHELAA score. Moderate impact on green belt. Visually well-contained. Can provide significant green infrastructure.
Site performs well against Step 2 factors, other than very low landscape capacity, which applies to Site 10 and elsewhere. Site more positive in SA than other Meriden sites.
Assessment incorrectly states 170 rather than 100 dwellings.

Comment

Representation ID: 9577

Received: 15/03/2019

Respondent: Bloor Homes

Agent: Savills

Site 192 should be a 'green site'. The site performs better in some areas than Site 41 and is located in an area identified as being suitable for significant growth. The site has many benefits that outweigh the harm, arising from inappropriate development. The site has no hard constraints, limited soft constraints, and provides Solihull with an opportunity to deliver a
comprehensive development in this area. The Railway line to the west of Tidbury Green could provide a new defensible boundary to the Green Belt and wider opportunities where the Green Belt wash is removed from Tidbury Green.

Comment

Representation ID: 9585

Received: 15/03/2019

Respondent: Mr J Allen

Agent: Cerda Planning Ltd

Site 5 land at Grove Farm Knowle should be included. Site performs well in the SHELAA and Green Belt Assessment and SA is too broad and fails to recognise site specifics of this land.

Object

Representation ID: 9632

Received: 25/02/2019

Respondent: Mrs Wendy Wilson

Call for Sites 76 and 212 at Berkswell Quarry should be properly assessed as a suitable response to the Strategic Growth Study, as the location is accessible to main employment centres to the north.

Object

Representation ID: 9635

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

We strongly object to the way in which Site 209 has been assessed in the site selection process for the reasons which are set out below - and on that basis, object to the inconsistent application of the methodology.
see detail in letter

Object

Representation ID: 9644

Received: 13/03/2019

Respondent: Mr J Davies

Sites around Meriden. This area can be developed instead of Shirley, for example, as it would benefit from the more than adequate road network and draw road use and services use away from the already crowded areas elsewhere in the plan.

Comment

Representation ID: 9648

Received: 15/03/2019

Respondent: Mr & Mrs Williams

Agent: Oakwood Planning Ltd

Site 127 Grange Road, Dorridge should be Green as incorrectly appraised in Site Selection Methodology.
Step 1. Should be higher priority 3/5 rather than 9 as partly brownfield, and assessed as medium accessibility. Should be medium/high accessibility based on Accessibility Study as should be 80 for accessibility to train services.
As a high performing site, more significant harmful impacts required in Step 2 to exclude.
Step 2. SHELAA should be Category 1 as suitability score of at least 43, and agricultural land should be 5. Accessibility not part of refinement and already found accessible. Breaching green belt boundary not a conclusive factor as majority of sites allocated do similarly. Site has clear physical boundaries that could form defensible green belt boundary without opening up adjoining land. Least harmful site within lower performing green belt parcel. LCA capacity a guide only and accepts likely to be able to accommodate small areas of new development.
SA has 4 positive and 3 not 4 negative effects. Site not accurately reflected by amalgamated site AECOM58 scores. Should be 6 positive and only 2 negative impacts. SA4 should be positive as site contains no agricultural land. SA9 should be neutral as Site not affected by LWS. sa16 should show significant positive effect

Comment

Representation ID: 9662

Received: 15/03/2019

Respondent: Mr & Mrs Michael & Marion Joyce

Agent: Tyler Parkes Partnership Ltd

Site 21, which is part of Site 2, and Site 96 represent viable and reasonable site and should not be identified as red sites. Site is gap between houses close to development within Catherine de Barnes to east, with bus route to Solihull. Sites in close proximity, notably 147/230/339 and allocated Site 24 are assessed as green and Sites 21/2/96 compare positively. Very limited contribution to green belt as part of lower performing parcel compared to Site 24, and would not lead to coalescence. Sustainable location, no constraints, deliverable and disputed that there are severe/widespread impacts not outweighed by benefits.

Object

Representation ID: 9738

Received: 15/03/2019

Respondent: Heyford Developments Ltd

Agent: Harris Lamb

Call for Sites reference 418 Diddington Lane HiA should be allocated as within main settlement capable of accommodating new development. Site 6 has uncertain delivery, whereas Site 418 available and can contribute to early Plan period needs. Capacity has flexibility to meet wide range of needs depending on Plan target, and could be phased over Plan periods. Will deliver market and affordable housing, accommodate public open space and well-located to village centre, shops, school, surgery, PH, and railway station. New pedestrian and cycle links will increase permeability. HS2 line will provide strong defensible green belt boundary.

Object

Representation ID: 9748

Received: 14/03/2019

Respondent: Mr D Deanshaw

Red Sites 82, 142, 198, 233, 421 Grange Farm, Balsall Common
Grange Farm and adjoining land would enable provision of relocated housing from Sites 2 and 22, together with new/relocated Primary School away from B4101 traffic and not affected by HS2 or phasing restrictions.

Comment

Representation ID: 9756

Received: 15/03/2019

Respondent: IM Land

Agent: Turley

SHELAA Site 141 should be further considered for allocation.
It can be included within the opportunity area 'South of Birmingham' a broad, non-specific area of land between Birmingham and Stratford upon Avon (location NS5) which was identified as having potential for a new settlement in the GL Hearn Strategic Growth Study 2018.
Site Selection Methodology is flawed and Site should have been considered to Step 2 due to proximity to Earlswood Station.
Could provide up to 500 homes, provide Green Belt compensation, provide 11 ha of open space, provide opportunity for supported uses such as schools, adjacent to underutilised station.

Object

Representation ID: 9780

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL strongly objects to the omission of their site at 'Land off Old Station Road, Hampton in Arden' (Assessment Site Ref. 6). Site selection methodology has been inconsistently applied and as a result DLPSC has unfairly discounted this site. Evidence within the site assessment document confirms the site to be highly achieving against a number of the matrices, the site performs better than proposed allocations of a similar size and location within settlements of the same Settlement Hierarchy class. Attached appendix A comparison table compares the application of the methodology and associated evidence base in relation to the site (Land off Old Station Road)and comparable sites. It shows a lack of consistency in the justification and associated decision-making set again that same evidence base, resulting in Land off Old Station Road being identified as unsuitable and excluded from further consideration. The sites used for comparison are of similar size and character; having a similar capacity, being wholly or predominantly greenfield, lying within the Green Belt, and lying within a settlement that is within a settlement of the same hierarchy as Hampton in Arden. The table demonstrates that the findings contained with the site assessment document and associated evidence base reinforce that Land off Old Station Road continually performs highly when assessed against the key criteria; including in relation to the spatial vision, site constraints, deliverability, accessibility, impact on Green Belt performance, and sensitivity of landscape character. Significantly, the site adheres to the DLP's spatial vision, reaching a 'Yellow' score of 5 overall in Step 1 of the Site Selection process. Notably, the site scores more favourably than Land South of School Road, Hockley Heath, which is proposed for allocation as DLP Site 25.
Evidence in stage 2 of the site assessment also confirms the site is suitable for development particularly when compared with sites proposed for allocation. Suitability was also demonstrated in the 2016 SHELAA where it was assessed as a category 1 which could commence within 5 years but by comparison the southern parcel of the DLP proposed site 10 was assessed as category 2 and DLP site 6 is identified as category 3 as not currently developable. Site also performs extremely well within the accessibility study. Again findings are inconsistent when compared to other sites. Site also performs to a similar standard or better than comparable sites that have been proposed for allocation within the greenbelt assessment. Despite all of this the site is designated as a red site. Site lies within landscape character parcel which only has medium sensitivity and is more favourable when compared to proposed allocations within Meriden and Hockley Heath. The Sustainability appraisal is also favourable to the site having fewer negative and more positive impacts than other sites proposed for allocation.
The issues of 'indefensible boundaries' and 'visual intrusion' are given a considerable amount of weight in the site assessment process despite the site being assessed favourably in other areas. This is unfounded as this can be readily mitigated and is not permanent. In fact, the advice given by SMBC within the DLPSC (para 75) states that "sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt" would be considered favourably. It is clear that SMBC have shown inconsistency in the application of site assessment methodology notably this is reflected in the lack of a robust definition for clearly defined boundaries. The DLPSC gives conflicting views on the definition and approach to this, in some instances placing significant emphasis on defensible boundaries as permanent and physical boundaries.

Object

Representation ID: 9787

Received: 14/03/2019

Respondent: Mr G Frost

Alternative proposal for a new settlement north of Balsall Common needs serious consideration, instead of the significant expansion proposed for the settlement