Draft Local Plan - Supplementary Consultation
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Draft Local Plan - Supplementary Consultation
Local Housing Need
Representation ID: 8741
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Given the findings of the Employment Land Review (2017), we query whether there is adequate evidence regarding employment needs to answer this question. There is scope for an uplift in the housing requirement as a result of the HS2-related growth, as well as the potential to capitalise on the clear need for wider than local employment growth identified through evidence such as the 2015 West Midlands Strategic Employment Site Study (WMSESS), which identifies the M42 corridor as the area of highest demand for strategic industrial and commercial uses (Area A). The forthcoming new WMSESS is likely to be published before the draft Plan is adopted. On top of Birmingham's unmet
housing needs, the potential for higher housing numbers as a result of these points is something we consider could be an exceptional circumstance to justify an uplift beyond the standard method minimum (which we currently calculate to be 777 dwellings per annum).
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Site Selection Methodology
Representation ID: 8746
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
We broadly agree with the methodology but raise issues with the manner in which it has been applied to the site assessment process. We object to the manner in which our site (site assessment reference 404) has been assessed as 'red'. We do not agree with the conclusion that it will have 'severe or widespread impacts that are not outweighed by the benefits of the proposal'. Given the geographic similarities, we make a direct comparison to site 41, Land at Whitlock's End Farm; and site 176, Land to the West of Dickens Heath, both of which are assessed as 'green' sites
and are identified as draft allocations (draft Plan sites 26 and 4 respectively).
Site has been assessed as low accessibility to the primary school despite being adjacent to it. There is a formal agreement with Bellway to create footpath linkages through adjacent site which would reduce time taken to walk to the school. Public transport is also incorrectly assessed as being low / medium for same reason walking distance to station is reduced. Assessment states no footpaths however as stated above a new footpath will be provided along Rumbush Lane. These conclusions on accessibility are supported further by the appeal decision for the adjacent Bellway site. It is clear the site is close to a variety of services and facilities at Tidbury Green and Dickens Heath and a number of sustainable transport options are available which will be enhanced through the development of the enhanced Bellway scheme. The site is similar to the proposed draft allocations in terms of contribution to the purposes of the green belt. Requests site is reassessed based on evidence submitted. In terms of landscape the site has been assessed as 'within a landscape character of high sensitivity,medium landscape value and very low capacity to accommodate change'. However landscape and visual appraisal undertaken by Barton Wilmore Landscape concludes that the site can accommodate development which is of a type and scale that reflects the existing development within Tidbury Green. Mitigation is proposed to reduce visual permeability to ensure that the development can be accommodated without undermining the function of the Green Belt and without causing harm to the landscape. As such landscape should not be a reason to object to the principle of development on the site. Disagrees with the conclusion 'the development would result in an unacceptable incursion into the countryside and cause coalescence by narrowing the gap between Dickens Heath and Tidbury Green'. Nothing in the Council's evidence that places a higher protection of the area between Dickens Heath and Tidbury Green (for our site) than between Dickens Heath and Shirley (for the draft allocation at Whitlock's End Farm).
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 4 - Site 1 - Barratts Farm
Representation ID: 8749
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 5 - Site 2 - Frog Lane
Representation ID: 8751
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 6 - Site 3 - Windmill Lane
Representation ID: 8752
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 7 - Site 21 - Pheasant Oak Farm
Representation ID: 8753
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 8 - Site 22 - Travellion Stud
Representation ID: 8754
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 9 - Site 23 - Lavender Hall Farm
Representation ID: 8755
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Whilst we agree with the spatial approach to development in Balsall Common, we query whether there is evidence on the deliverability of some sites, for instance Barratts Farm (site 1), which has over 10 landowners within the allocation and relies on significant infrastructure for its delivery. Evidence is required to demonstrate delivery and the build rate will be crucial in the Regulation 19
Plan. Sites that have less land assembly issues that are available for development now (such as our Client's) are much more deliverable in the early years of the Plan, as demonstrated by the adjacent Bellway scheme.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 12 - Site 4 - Land West of Dickens Heath
Representation ID: 8757
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
Given the amount of detail that is provided, our main concern at this stage is with the loss of the playing fields and whether the allocation has reference to the recently published Solihull Playing Pitch Strategy (January 2019). Further evidence is required to establish whether the relocated provision is in a suitable location and deliverable. In the absence of this evidence, our Client's site would be more
appropriate, particularly given it is adjacent to Dickens Heath Sports Club and could feasibly contribute to the identified shortfall in provision.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 15 - Site 26 - Whitlocks End Farm
Representation ID: 8759
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
As noted in our response to question 2, we have concerns with the site selection process and the conclusions raised regarding this site, when compared to our Client's site at Tidbury Green.
Please see covering letter