Draft Local Plan - Supplementary Consultation

Object

Representation ID: 9849

Received: 14/03/2019

Respondent: Schools of King Edward VI in Birmingham

Agent: Avison Young

Whilst our Client is of the view that SMBC has applied the Standard Method in accordance with the NPPF,
the housing target for the Borough that is ultimately proposed at Pre-Submission stage must include: i) an
evidenced, justified contribution to the unmet needs arising within the HMA; and ii) an allowance for the
safeguarded land so that Green Belt boundaries can endure beyond the plan period in accordance with
the NPPF.

Object

Representation ID: 9850

Received: 14/03/2019

Respondent: Schools of King Edward VI in Birmingham

Agent: Avison Young

The short answer to this question is 'no'. The deficiencies stem firstly from a flawed approach to calculating housing supply over the plan period, and then from an approach to reviewing potential housing sites that is beset by weaknesses.
Generally support approach in Step 1 of prioritising brownfield, accessible and Green Belt locations.
Do not support allocating colour status to each site. Summary explanation does not agree with diagram, as some yellow sites become red rather than amber. Text should be updated to reflect diagram.
No guidance on how factors for and against are weighted/ranked.
Green Belt issues should be considered in totality, and not piecemeal, i.e. the extent to which individual sites contribute to the purposes of the Green Belt.

Object

Representation ID: 9851

Received: 14/03/2019

Respondent: Schools of King Edward VI in Birmingham

Agent: Avison Young

SHELAA Site 11, Widney Manor Road.
Do not agree with categorisation as a red site. Contend this is a consequence of: i) a flawed site selection methodology; and ii) flawed judgements that have been applied in the assessment of Site 111.
- Disagree that site is isolated, as reflected in PBA SHELAA
- Site has medium accessibility as referred to in evidence
- SA and Accessibility Study differ in assessment of proximity to primary school
- Disagree with Green Belt Assessment, should be lower performing parcel
- SHELAA Assessment is incorrect, is not in a Flood Zone
- Site promoter working with Cadent Gas on gas pipeline
- Disagree with Landscape Assessment's relevance to site
- Disagree with elements of Sustainability Appraisal (see letter)
- Site has achievable capacity of 79 dwellings.