Draft Local Plan Review

No

Representation ID: 3745

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Proposed strategy for housing growth is not sound. Need a range of small, medium and large sites. Concentrating on fewer large sites will result in over-dependence on volume housebuilders, and lower delivery rates.

No

Representation ID: 6196

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Unclear if proposed 2,000 additional units (arising mainly from Birmingham's housing needs) will be sufficient to address the wider HMA shortfall.
Proposal of 2,000 dwellings to contribute to HMA shortfall has not been agreed; may well be subject to pressure from other local authorities to increase.
Contrary to NPPF Para. 47.

No

Representation ID: 6197

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Propose to put a smaller part of the original SHELAA Site 64 as a Rural Exception Site. Should be noted that whole of site is available.
Important to specifically allocate sites that do not site close to the villages identified for housing growth as the lack of such allocations will leave a good deal of the Borough where the affordable housing requirement will not be addressed.

No

Representation ID: 6198

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Land at Barston Lane/Oak Lane.
SHELAA Ref: 64
Meets objectives of Growth Option F.
Sites are deliverable and developable.
Development would be compatible with adjacent residential uses and would ensure protection and facilitate enhancement of services and facilities.
Would result in new defensible Green Belt boundaries.
Compares favourably to some proposed allocations: less Green Belt impact, less landscape character impact.
See attached supporting evidence.
Rejection of site not been justified.
Allocation would accord with Government Housing White Paper.

No

Representation ID: 6199

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P5: Policy justification should include identified part of SHELAA Site Ref:64 in the summary of allocated sites as a Rural Exception Site and within Appendix C, for housing development in first 5 years of plan period.

No

Representation ID: 6200

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Insufficient housing land provided, more Green Belt release required, or at least provide safeguarded sites.
Too many large sites in too few areas have been proposed, contrary to Government's commitment to delivery across range of site sizes.
Will result in disproportionate pressure on services and facilities, and community cohesion.
Better to distribute housing across Borough, particularly close to public transport.
Many proposed sites will result in displacement of community facilities, e.g. sport pitches. VSC for outdoor sport and recreation in Green Belt would be difficult to prove if alternative GB sites available that do not require loss of such facilities.

No

Representation ID: 6201

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P5: Contend that windfall supply will not continue at past rates. Insufficient grounds for continuing with such a high windfall allowance. Furthermore, such sites are unlikely to contribute to affordable housing due to lower site size.
Absence of evidence to support record of delivery on Rural Exceptions Sites, therefore more should be allocated.

No

Representation ID: 6202

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P7: object to restrictive wording. Prevents a flexible interpretation of sustainable development.
Sustainability is not a formula and suitability of a site for housing development should not be solely measured by distance from high frequency bus stops.
If distance to public transport is included, then should also include proximity to train station, safe cycle and walking routes.
Reword to state: '...unless justified by local circumstances...and investment in improvements to local transport provision, cycling and/or walking measures will be sought in association with development proposals...' to improve accessibility where appropriate.

No

Representation ID: 6203

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

Policy P17: Does not qualify when changes of use to accommodate outdoor sports and recreation uses could be regarded as 'very special circumstances'. Contrary to the spirit of NPPF paragraphs 87-89.

No

Representation ID: 6204

Received: 17/02/2017

Respondent: Cosmic Fireworks Directors Retirement Fund

Agent: Tyler Parkes Partnership Ltd

In relation to reduced portion of SHELAA Site 64:

Misleading assessment of site in SHELAA report;
Inaccurate and misleading accessibility mapping scores;
Misleading interpretation of site in GBA.
Misleading interpretation of site in Landscape Character Assessment.
Not included in interim sustainability assessment for consideration as Rural Exception Site. Should be included in SA.