Draft Local Plan - Supplementary Consultation

Object

Representation ID: 9363

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Consideration of HMA shortfall at Regulation 19 stage inappropriate/unlawful as may require revised strategy or propose additional green belt releases, which ought to require further Regulation 18 consultation. Otherwise this would be a completely new strategy resulting in a plan that has not been previously consulted upon. This approach would lead to a challenge to the lawfulness of the process and possible intervention by the Secretary of State. Any preferred options that may derive from a revised HMA contribution should be subject to consultation prior to stage 3 submission as described in the SCI and plan making regulations. Regulations make a distinction between Regulation 18 and Regulation 19 in order to aid sound plan making and to ensure that there is an appropriate opportunity for all those concerned to contribute to it and influence it.
Insufficient and unjustified contribution to wider HMA shortfall which reasonably should be more significant than 3,790 dwellings proposed by North Warwickshire BC, given Solihull's proximity to Birmingham and public transport links. Suggest 6,500 (17% of shortfall). Site 313 Fulford Hall Farm, Tidbury Green could make significant contribution to part of this shortfall, due to sustainable location as demonstrated by Mobility and Transport Strategy.

Comment

Representation ID: 9364

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Step 2 process lacks transparency and robustness in way it draws matters for consideration together and balances them in the decision making process, with little explanation.

A number of concerns with the way site 313 has been assessed both in terms of the assessment process and judgements made within this document itself, and also the robustness of the evidence base used to underpin it.

Methodology is applied incorrectly to Site 313 Fulford Hall Farm and is flawed, as Step 1 priority should be 6 rather than 9,in respect of judgements made on green belt and landscape sensitivity. Accessibility study concludes the site has high accessibility therefore logically should be categorised as 6 and not 9 contrary to SMBC evidence base. In the greenbelt assessment the site is within broad area 1 with all broad areas given a score of 3 (highest rating). This is fundamentally flawed and unsound, lacking the detail of a district level assessment and artificially inflating the contribution of the Fulford Hall Farm to safeguarding of the countryside. In terms of landscape character the site is classified within LCA2 and its visual sensitivity is classified as high. Contest the methodology used to establish visual sensitivity which appears to be weakly justified with no explanation of how the classification criteria have been assessed or judged.
11 of proposed site allocations fall under Category 3 in SHELAA and are classed as not currently developable.

Comment

Representation ID: 9365

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Chapter 6 Blythe fails to provide fair or reasonable assessment of Tidbury Green as a potential development location, as it downplays the settlement's sustainability credentials and ignores proposals to upgrade Wythall rail station and train service frequency. As a result, the SDLP pre-determines the spatial strategy inappropriately, based on inadequate evidence.

Comment

Representation ID: 9366

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Concern over the way Fulford Hall Farm has been assessed within the site assessment report in relation to its contribution to the green belt and visual sensitivity. 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 provided to show site well-contained, capable of accommodating development with limited visual impacts.

Comment

Representation ID: 9367

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Concern over the way Fulford Hall Farm has been assessed within the site assessment report in relation to its contribution to the green belt and visual sensitivity. 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 provided to show site well-contained, capable of accommodating development with limited visual impacts.

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: 9369

Received: 15/03/2019

Respondent: Summix (FHS) Developments Ltd

Agent: Framptons Planning

Non statutory consultation under Regulation 18 contradictory. Seeks to pre-determine spatial strategy via settlement categorisation/site selection matrix.
SCI indicates Review should be subject to formal Regulation 18 consultation, which should be next stage, not Regulation 19. SEA process fails to comply with guidance/regulations. Addressing HMA shortfall likely to result in further alternatives that need to be appraised which could have implications for spatial strategy and SA should be undertaken as part of Stage B/Regulation 18.
Formal SA Report should have been prepared/consulted on at this stage. Further deficiencies relating to lack of consideration of alternatives to Local Housing Need, reasonable site options not assessed, deficiencies at DLP stage not addressed, fails to evaluate significance of impacts against appropriate evidence, cumulative effects/mitigation not considered, green belt land not considered, no flood risk sequential test of proposed allocations, no explanation for selection/rejection of options or overall conclusions of sustainability of different alternatives. no explanation how SA informed SDLP in integrated way, fails to show how representations from statutory consultees/neighbouring authorities taken into account. Fails to assess 75 sites of which 15 identified as green and 9 as amber sites. SA fails to appraise all reasonable alternatives, demonstrate that strategy is appropriate or take into account alternatives. Appendix 1 attached as additional supporting information in connection with this site undertakes a review of the SEA process.