Draft Local Plan - Supplementary Consultation

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Comment

Draft Local Plan - Supplementary Consultation

Local Housing Need

Representation ID: 8879

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Support the adoption of the Standard methodology and consider there are no exceptional circumstances to deviate from this.
- Regrettable that the Council have elected not to, as yet, tackle the issue of the contribution to the wider Market Housing Area.
- There is clear justification for Solihull Metropolitan Borough Council to make a higher contribution to the Wider Birmingham Housing Market Area (WBHMA) shortfall in comparison to other local authorities. (Details set out in detailed representation).

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Site Selection Methodology

Representation ID: 8885

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Do not consider there to be any issues with the first stage of the site selection/assessment process.
- Second stage of process is highly complex and respondent does not agree with the methodology of the site selection process. The numerous elements of the Council's assessment process allow for a higher incidence of error or for assessments to be overly subjective.
- The site selection process relies heavily on the accompanying Sustainability Appraisal. The use of the Sustainability Appraisal in assessing sites for allocation has not provided a firm framework for the individual evaluation of potential sites.
- Stratford-upon-Avon utilises a better approach to their site assessment methodology in accordance with Planning Practice Guidance
- Solihull Councils' assessment framework does not allow for constraints to be weighed differently and does not allow for mitigation of soft constraints.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 22 - Infrastructure Requirements at Knowle, Dorridge and Bentley Health

Representation ID: 8889

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Support the detailed assessment as to what is required for the settlement for the future since underpinning the Draft Local Plan Supplementary Consultation is an anticipation that KDBH will make a major contribution to accommodating not only the Borough's housing needs, but also those of the wider HMA.
- It is noted that paragraph 227 sets out a short justification for a new primary school in the area which is proposed on site 9.
- Masterplans only identify features of sites that 'may' need to be retained. Details would need to be refined through a iterative planning application process.

Full text:

see attached document

Support

Draft Local Plan - Supplementary Consultation

Question 24 - Site 9 - Land South of Knowle

Representation ID: 8897

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Update of the evidence base re-enforces and re-supports the allocation of the site.
- Kler Group Ltd have engaged consultants dealing with a range of issues in relation to the site. All the evidence supports inclusion of the site.
- Consider that the housing requirement for Solihull will increase in order to meet requirements of the wider Housing Market area so those already identified will need to increase their effectiveness.
- The Representation gives detailed comment on the draft Concept Masterplan for the site including: (I) Access and Highway Capacity, (ii) Biodiversity (Area mapped as LWS is incorrect),(iii) Landscape and trees and (iv) Heritage.
- Notional yield of 600 houses for the site is low and does not fairly reflect the constraints and opportunities which the site presents
- The Council should re-visit the Concept Masterplans for Site 9 in order identify the actual deliverable yield from the site and in turn inform the residual housing requirement required of the other 'green' proposed allocations.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 34 - Washed Over Green Belt Settlements for Potential Removal

Representation ID: 8899

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

In the specific circumstances the washed over Green Belt status of settlement/areas should be removed since it will make for a more rational, logical and defensible boundary to the West Midlands Green Belt where it is situated within Solihull.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 35 - Washed Over Green Belt Settlements to be retained

Representation ID: 8901

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- It is the correct time to undertake a wholesale and detailed Green Belt boundary review as this can only be re-defined through a Local Plan Review.
- Opportunity to rationalise and re-define boundaries that were designated within the a very diferent planning policy context.
- It would not be logical to say that villages of any sort have any character which contributes to the 'openness' of the Green Belt.
- Apart from isolated dwellings and other similar limited exceptions, any concentration of buildings, structures, hard surfacing or boundary features should not be washed over as Green Belt.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 36 - Washed Over Green Belt Settlements Review

Representation ID: 8904

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- The washed over status should be reviewed in relation to the large area of existing development at Warwick Road, Pool Meadow Close and Riverside Drive. (This relates back to the Green Belt Assessment undertaken by Atkins in 2016 and specifically Refined Parcel 32).
- Widney Manor Road: suggest new boundary to the east of all development fronting Widney Manor Road including the sixth form college up to the Malvern Park boundary but excluding Lovelace Avenue.
- Warwick Road: new boundary from the entrance to Brueton Park adjacent to all development in Oldway Drive/Pool Meadow Close up to the M42 and then along the M42 to the Solihull Bypass, and the Bypass where it joins the existing boundary to the Marie Curie hospital.
- The comment regarding Refined Parcel 31 in the Atkins Green Belt Assessment under Purpose 1 is to be noted. It makes it clear that boundaries are defined by the A41 (bypass) and M42 and hence these boundaries are already recognised as clear boundaries to the proposed removed area.
- The large areas of trees around Riverside Drive do not need Green Belt protection as already protected under other designations.
- Land at Gentleshaw Lane should therefore be brought out of the washed over Green Belt given the inconsistencies embedded in the evidence base underpinning the current consultation.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 37 - Compensatory Provision for removal of land from Green Belt.

Representation ID: 8908

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Compensatory measures should be framed around the provisions of paragraph 141 of the National Planning Policy Framework.
- Sites being removed from the Green Belt should incorporate compensatory provision as part of the master planning approach.(ie. Site 9 - Arden Triangle).
- Public open space should be provided on site which meets the requirements not only for outdoor sport and recreation but also proves access to the area.
- Opportunities should be taken to enhance landscapes through for example retaining existing trees and hedgerows with measures to ensure long term stewardship though management companies or similar.
- Biodiversity enhancements should be made wherever possible. (Additional native planting or enhancements within the existing built up area ie. bird and bat boxes).
- Where land is damaged and/or derelict - bringing this back into beneficial use.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 38 - Amber Sites

Representation ID: 8909

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Sites to be taken forward, should be assessed against a PPG compliant assessment methodology, which has not been the case in the Council's site selection Framework.
- The Council are deferring the issue of ensuring that there are enough housing allocations to meet the overall housing requirement during the plan period, including that of the WBHMA shortfall. The Council have not included enough amber sites within this consultation process to meet its own need and that within the WBHMA.
- Cerda Planning have applied a PPG compliant assessment procedure to each of the 7 Amber sites and conclude that 5 of the sites should remain as Amber and sites A1 and A4 should become 'red'.
- Site A1 (Land r/o575A and 587 Tanworth lane, Cheswick Green)would form back land development and is not accessible from Tanworth Road. There is new residential development directly to the north of the site (Cheswick Place development).
- Site A4 (Golden End Farm) would constitute inappropriate development in the Green Belt and there are more appropriate sites on which to develop.

Full text:

see attached document

Comment

Draft Local Plan - Supplementary Consultation

Question 39 - Red Sites

Representation ID: 8911

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

Representation Summary:

- Two red sites should be upgraded to amber and arguably green: Site 135 (land at Dorridge Road, Dorridge) and Site 107 (Land at Gentleshaw Lane, Knowle).
- Site 135: Council's main constraint is the site's lack of strong Green Belt boundary raising concerns over the site's impact on the openness of the Green Belt and the need to release additional land. Do not agree with this view as defensible boundaries are clear especially when considering the 2 parcels in the site assessment (which is not made clear in Councils' accompanying map) as distinct from the 4 parcels assessed in the Sustainability Appraisal.
- Site 107: Site is considered 'amber' in the tabulated assessment and 'red' within the site assessment map with no explanation for the drafting error. Site is in a highly sustainable location and would represent a 'rounding off' of the settlement in this location. The presence of TPOs and a high pressure gas line should be afforded a moderate weighting which they are not granted in the Councils' assessment. Both of these issues can be easily mitigated.

Full text:

see attached document

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