Spatial Strategy

Object

Representation ID: 14628

Received: 14/12/2020

Respondent: Heyford Developments Ltd (Dorridge Site)

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site Selection approach not fully justified. Concerns with the application of the methodology in terms of its transparency and consistency. Some Green Belt sites rejected unjustifiably and capacity for further Green Belt release in accordance with the spatial strategy has been unduly constrained.
Not clear from the site assessment commentary on what grounds a site has been rejected.
Inconsistencies between the different evidence base documents used to inform the Site Selection process e.g. the SA and accessibility study. Site Assessment commentary does not appear to reflect the most up to date SA commentary i.e. in terms of the number of effects and whether these are positive or negative.
Inconsistencies between why some sites allocated others not. E.g. site Policy KN1 notes Grimshaw Hall as a constraint. The site assessment makes no reference to it under constraints.

Object

Representation ID: 14647

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Comments on Draft topic paper on overall approach

There is no explanation why only rail and not bus is included as high frequency travel corridors in rural areas within Option A and no explanation why certain villages are categorized as limited or significant expansion within Options F and G.
Growth Option A – High Frequency Public Transport Corridors misses an opportunity as it refers solely to rail in the rural areas. Meriden has a high frequency bus service, as well as a local service, between Coventry and Birmingham. It is an express service with limited stops, it runs approximately every 20 minutes almost 24 hours a day, 7 days a week and there is a bus stop within 100m walking distance of the site proposed north of Main Road. The bus runs via the NEC and airport and will pass the HS2 interchange station presenting many employment opportunities. Meriden is a settlement that has a good level of services and facilities and is highly accessible. Growth Option F allows for the settlement to take proportionate growth and IM Land consider it is suitable and capable of accommodating a higher level of growth than the 100 houses proposed.
The Topic Paper concludes in respect of Meriden village, a medium to high accessibility rating and land to the east moderately performing in Green Belt terms but it is only included for limited expansion. The land promoted north of Main Road lies to the east so is not covered by mineral safeguarding constraint.
There is however no explanation in the Topic Paper or in the Topic Paper 4 of the previous consultation plan how the rural settlements have been split into two groups between Growth Options F and G as either for limited expansion or significant expansion of rural settlements.
It would appear that for significant expansion a settlement could be highly accessible or have a wider range of services including a secondary school, it does not have to have both. Dickens Heath for example is not as accessible as Meriden and has no secondary school. The Topic Paper provides a very similar assessment to that of Meriden but on capacity finds that Dickens Heath has capacity for significant growth. It gives no explanation how it reaches the conclusion. The accessibility study finds sites in Meriden to be highly accessible scoring higher than Dickens Heath. Meriden has a wide range of facilities and services. It is suggested that the settlement is constrained by lack of capacity at the primary school however no evidence has been out forward to comment on this. IM Land has therefore sought its own evidence and Turley have
prepared a report Education Assessment. This indicates that the primary school is already operating over capacity and neither the allocation of 100 houses in Policy ME1 or the land north of Main Road Meriden can be accommodated without school expansion. The level of demand for primary places generated by Policy ME1 West of Meriden (100 houses) and land north of Main Road (100 houses) together at 50 primary school places could be accommodated through expansion of the existing school. Meriden is capable of taking additional growth over and above that proposed and has site opportunities potentially more accessible and less constrained than other locations in the Borough.

Object

Representation ID: 14650

Received: 14/12/2020

Respondent: Rainier Developments Limited (Stratford Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan should contain strategic policies which set out the overall strategy for development, and therefore the Plan is not sound on this basis.
The absence of a clear Spatial Strategy and indeed settlement hierarchy therefore makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.
Furthermore, within the evidence base, the Site Selection Topic Paper includes an entirely new set of hierarchy criteria, which has been used to inform the site selection.

Object

Representation ID: 14689

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan should contain strategic policies which set out the overall strategy for development, and therefore the Plan is not sound on this basis.
The absence of a clear Spatial Strategy and indeed settlement hierarchy therefore makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.
Furthermore, within the evidence base, the Site Selection Topic Paper includes an entirely new set of hierarchy criteria, which has been used to inform the site selection.

Object

Representation ID: 14717

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Uncertainty and lack of clarity resulting from using different expressions in the evidence base and Site Selection e.g. in relation to sites being "adjacent to" or "isolated.

Object

Representation ID: 14718

Received: 14/12/2020

Respondent: Mr Ian Williams

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Site Selection: The selection process and allocations are not in accordance with NPPF para 139 and other amendments are needed for clarity and soundness.
Clarity is needed on the various uses of the words "adjacent/next to/close to/near" to villages etc throughout the Draft Plan and Evidence Base as there is uncertainty around the tests being applied based on inconsistent use of these types of phrases. Accordingly the use of the word "isolated" is misleading.
Non-compliance with NPPF para 139 e) as it is likely that Green Belt boundaries will need to be altered at the end of the plan period.
The spatial strategy diagram should reflect Knowle, Dorridge and Bentley Heath as a rural village identified for limited expansion based on the allocation of site KN1.

Object

Representation ID: 14770

Received: 14/12/2020

Respondent: Rainier Developments Ltd - Land at Widney Manor Road

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Ambiguity and confusion within the Options and which Option a site may fall within. For instance, a limited expansion of a rural village/settlement (F) could well be near a high frequency public transport corridor and hub (A).
Paragraph 65 adds confusion by introducing three further criteria which inform the location of growth but don’t relate in any way to Options A to G. It is unclear which takes precedence (A to G or Paragraph 65).
No definition of urban edge/ highly or less accessible settlements.
The absence of a clear Spatial Strategy and settlement hierarchy makes it impossible to understand how the scale and pattern of development is to be delivered within the Plan.

Support

Representation ID: 14919

Received: 14/12/2020

Respondent: ZF Automotive UK Ltd

Agent: Turley

- Broad support for Spatial Strategy in Para.’s 63-67.
- Could be more robust if set out a settlement hierarchy to guide site selection to strongly support development on edge of the main urban area around Shirley, due to connectivity to town centres, railway stations, services and facilities.

Object

Representation ID: 14958

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Strongly challenge scale of proposed development in Blythe, Knowle and Balsall Common.
- Disproportionate and not justified by site selection methodology, or consistent with its spatial strategy and objectives
- Proposed site allocations perform poorly against sustainability measures, with adverse effect in these areas.
- In addition to previous comments, we add to this analysis following the updated information in the supporting documentation of the Plan below:
o Strategy fails to link adequately housing distribution to its economic and transport policies. These emphasise growth in accessible corridors inc. A45, A34 and Solihull town centre, as well as the corridor linking the town centre to the A45 hub.
o Spatial strategy does not reflect findings of assessment work, as demonstrated by large scale allocations in Balsall Common, Knowle & Dickens Heath.

Object

Representation ID: 14963

Received: 11/12/2020

Respondent: CPRE Warwickshire Branch

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Site Selection
- Sites BL1, BC1 and BC3 do not conform with site hierarchy in DSP Para. 68.
- Not possible to understand how some sites fall into the green category, when they clearly have high impacts
- A sustainability score in line with recent Government policy would provide a different result.
- Credibility and robustness of process is undermined.

Object

Representation ID: 14975

Received: 11/12/2020

Respondent: Mrs Jean Walters

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Disagree with site selection process, and certain sites considered ‘green’. Credibility and robustness of process is undermined.
Site BL1 should be 'red' site, doesn't accord with spatial strategy.

Object

Representation ID: 14991

Received: 11/12/2020

Respondent: Mrs Jean Walters

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

- Site selection flawed and part of site BL1 (south of Tythe Barn Lane) unsuitable for development
- Amber sites in lower performing Green Belt should be brought forward instead.

Object

Representation ID: 15007

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

- Support Para. 63-67 and focus on Options E-G
- Failed to account for specific settlement hierarchy.
- Preferred Growth Options should be accompanied by a settlement hierarchy, that would identify how vision and spatial strategy will be delivered through plan period.
- This should be supported by SA taking into account factors such as public transport
- Would assist Development Management and delivery of windfall sites.

Object

Representation ID: 15008

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Site Selection Methodology (see also Topic Paper):
- Raised concerns previously and these have not been addressed
- Step 1 – Hierarchy criteria does not align with NPPF Para. 138, and preferring Green Belt sites well served by public transport
- Site Hierarchy should reference land well served by public transport
- Step 2 of refinement criteria (p.14 Topic Paper) do not include sites well served by public transport as ‘factors in favour’. Therefore not accord with NPPF.

Object

Representation ID: 15024

Received: 14/12/2020

Respondent: Kier Living Ltd - Coleshill Road

Agent: Mr Hywel James

Legally compliant? No

Sound? No

Duty to co-operate? No

Council’s own evidence base raises significant issues with a number of the sites that
are allocated in the Emerging Plan, and their development would therefore conflict with the
Framework. As such, the site selection process is not based on proportionate evidence and the
Emerging Plan is consequently not justified as it fails to propose an appropriate strategy.
Sites include: BL2, BC1, BC3, BC4, KN2, SO1.

Support

Representation ID: 15120

Received: 13/12/2020

Respondent: Woods Farm (Christmas Trees)

Agent: Twelve Twenty One Planning Services

Spatial Strategy (Page 24) –
The spatial strategy is supported as it is considered that this represents the most effective and sustainable means of delivering the scale of housing growth that is necessary to meet the affordability and other housing needs set out in the Draft Submission Plan. In particular Growth Option G is considered to be the preferred option strategy for the bulk of housing delivery.

Support

Representation ID: 15128

Received: 13/12/2020

Respondent: Woods Farm (Christmas Trees)

Agent: Twelve Twenty One Planning Services

Support Spatial Strategy in Para. 63