Draft Local Plan - Supplementary Consultation
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Draft Local Plan - Supplementary Consultation
Site Selection Methodology
Representation ID: 9587
Received: 15/03/2019
Respondent: Berkswell Parish Council
Seriously flawed and fails to meet NPPF requirements.
Green belt analysis inadequate as assesses sites individually rather than cumulative impact, fails to consider loss of amenity/accessibility, takes no account of wider pressures that should be included in cumulative harm analysis, such as HS2, and gives precedence to greenfield sites that add to openness whilst ignoring sites not connected to open green belt.
Takes no account of potential housing productivity of sites eg Site 3 where area of high ecological value/setting of listed building reduces capacity from green belt deletion. Ignores NPPF requirement for proportion of housing to be met on sites less than 1 hectare.
Fails to give sufficient weight to effective public transport as demonstrated by frequency of services and car usage, or to costs of improvements. Balsall Common has high car dependency and less effective public transport than Dorridge, which has lower/zero housing target. No highway assessment or analysis of by-pass options, particularly western option which could serve JLR facility. Fails to consider where best location for affordable housing in Borough.
Takes no account of house prices as indicator of unmet demand despite inclusion in national methodology.
Should include capacity of centres to meet increased demand.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Comment
Draft Local Plan - Supplementary Consultation
Question 3 - Infrastructure Requirements at Balsall Common
Representation ID: 9588
Received: 15/03/2019
Respondent: Berkswell Parish Council
Welcome identified infrastructure needs. Additional issues;
Infrastructure timing - many facilities at capacity, schools, village centre, station parking, provision for young people. Enhanced provision needs to be in place very early.
Public transport - increased rail capacity/frequency, enhanced bus timetables with express services for commuting.
Balsall Common centre - welcome proposal for SMBC to lead and involve Parish Councils/Residents Association/Society. Requires significant investment/improved maintenance of public realm.
Parking - must find additional parking as given distance to centre, a greater proportion of new residents will use cars. Significant additional parking at station required.
Education - 2 new primary schools plus further work on secondary provision.
By-pass - case not proven. Through capacity constrained at commuting peak times with low traffic otherwise. No increase in through traffic since by-pass line removed. Concerned that by-pass would create more traffic, be unattractive to through traffic, will cause hardship to some residents and inconvenience others, whilst Kenilworth Road residents aware that living on through route.
Provision for youth - inadequate, need for land for multi-purpose sports centre.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Object
Draft Local Plan - Supplementary Consultation
Question 4 - Site 1 - Barratts Farm
Representation ID: 9589
Received: 15/03/2019
Respondent: Berkswell Parish Council
Site selection criteria not applied correctly as large part is higher performing within BA4 in GBA and should be priority 7 (not 5) in Step 1, unlikely allocation. Will reduce gap between Balsall Common and Burton Green/Coventry already compromised by National Grid site and line of HS2. Likely that Site 1 performs better than GBA RP51 to north-west of settlement. Would contravene purposes of green belt.
Concept masterplan
Support medium density closer to existing homes, inclusion of public green space/identification of ecological areas. However, ignores/contrary to emerging NDP as fails to locate green space between existing and new housing, proposes access from existing residential roads when not required, flood plain should not be included as green space as not accessible for much of year, and increase in site area not reflected in capacity.
Unclear why corridor adjacent HS2 excluded from masterplan as paragraph 103 indicates Barratt's Farm to be phased later in Plan period. Should be medium/high density as building to BS standards will ensure noise levels within WHO guidelines.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Object
Draft Local Plan - Supplementary Consultation
Question 6 - Site 3 - Windmill Lane
Representation ID: 9590
Received: 15/03/2019
Respondent: Berkswell Parish Council
Object as failed to study alternatives and there are errors in the site selection methodology. Green belt deletion disproportionate to development area due to ecological restrictions, and greater than required elsewhere.
Concept masterplan underestimates impact on setting of listed building and SMBC has failed to engage properly with owner, particularly relating to impact on wind flow.
Site beyond acceptable distance to centre/surgery/station and outside desirable distance to schools, so will be highly car dependent and unsustainable.
Concerned estate roads will impact on protected species, and that ecological report shows building on 2 areas of importance.
Concept Masterplan
Ignores emerging NDP as green space not provided between existing (Wellfield Close) and new development.
Concerned at impact of access onto Windmill Lane as no pavements, traffic will affect rural character and traffic hazard at Kenilworth Road junction. Access should be solely to Kenilworth Road, achievable with by-pass.
Traffic calming measures on Meer Stones development not effective, so concern about speeds on Windmill Lane.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Comment
Draft Local Plan - Supplementary Consultation
Question 7 - Site 21 - Pheasant Oak Farm
Representation ID: 9591
Received: 15/03/2019
Respondent: Berkswell Parish Council
Support building on brownfield sites and part of site included on BLR. Object to inclusion of significant area of greenfield/green belt, as evidence supports alternatives that will not impact on openness, such as Sites 1/43 bounded by roads.
Site beyond acceptable distance to centre/surgery/station and outside desirable distance to schools, will be highly car dependent and unsustainable.
Recommend exclusion of greenfield element other than for public open space which could remain in green belt. Suggest adopt approach as per Site 22 in SLP2013.
Paragraph 113 is untrue as by-pass will not be within 200m of proposed boundary of Site so inclusion of greenfield land not justified. Greater part of Site in higher performing green belt parcel in GBA.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Support
Draft Local Plan - Supplementary Consultation
Question 8 - Site 22 - Travellion Stud
Representation ID: 9592
Received: 15/03/2019
Respondent: Berkswell Parish Council
Berkswell PC would not normally comment on sites within Balsall Parish. However, the Council notes that this site is classed as brownfield and Berkswell PC supports the development of brownfield sites before greenfield sites.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Support
Draft Local Plan - Supplementary Consultation
Question 9 - Site 23 - Lavender Hall Farm
Representation ID: 9593
Received: 15/03/2019
Respondent: Berkswell Parish Council
Berkswell PC are pleased that SMBC have responded to consultation responses and included brownfield sites within the local plan. Therefore, the Council supports the inclusion of this site for medium/high density housing.
Concept Masterplan
Footpath access possible to station/surgery/Hall Meadow Road but will need improvement. If Hall Meadow Road becomes by-pass, suitable access across road will be required. Access to Lavender Hall Lane will need careful planning in conjunction with new HS2 bridge as existing access problematic.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Object
Draft Local Plan - Supplementary Consultation
Question 10 - Green Belt Changes
Representation ID: 9594
Received: 15/03/2019
Respondent: Berkswell Parish Council
No justification given in the plan for such a step. There is a presumption in favour of sustainable development within the NPPF for land not within the green belt. The removal of green belt status as proposed for land south of Old Waste/Waste Lanes will remove all protection from development and result in unstructured, random development as individual sites are promoted for development through the normal planning system.
Predominantly highly performing green belt in GBA of strategic importance to Meriden Gap, in maintaining separation of settlements and in providing setting for Windmill Support statement in Concept Masterplan that rural character of Hob Lane/Windmill Lane should be safeguarded, and best achieved by retaining green belt designation.
Cannot understand logic of removing land from green belt without it being needed for housing or safeguarded for future needs. Suggest southern boundary formed by Waste Lane/Old Waste Lane, with Pheasant Oak Farm washed over or inset.
.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Comment
Draft Local Plan - Supplementary Consultation
Question 37 - Compensatory Provision for removal of land from Green Belt.
Representation ID: 9595
Received: 15/03/2019
Respondent: Berkswell Parish Council
Concerned about loss of easy access to countryside from east Balsall Common currently provided by network of footpaths on Barratt's Farm, which is not possible to mitigate. Suggest creation of circular walks from Truggist Lane with improvements to difficult sections, replacement of stiles and footway linking to Station Road, designation of new circular walks east of Balsall Common, and provision of cycleway/footpath on Lavender Hall Lane linking Balsall Common and Berkswell.
Footpath M196 could be extended full length of woods northwards from Railway Inn to junction of Lavender Hall Lane/Hall Meadow Road.
Plant woodland on land r/o Sainsbury/PFS on A452.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Comment
Draft Local Plan - Supplementary Consultation
Question 40 - Affordable Housing Approach
Representation ID: 9596
Received: 15/03/2019
Respondent: Berkswell Parish Council
Residents' interest is primarily smaller homes to buy so that the children of Balsall Common residents can buy a property in Balsall Common. The affordable housing definition does not help this group and that is disappointing.
Support higher proportion of shared ownership/Starter/discounted homes.
Plan should make specific reference to providing land on large developments for alms houses by Berkswell Charities.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.