Draft Local Plan - Supplementary Consultation
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Draft Local Plan - Supplementary Consultation
Local Housing Need
Representation ID: 8850
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
Given the findings of the Employment Land Review (2017), we consider that the Council have not produced the necessary 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. In addition to 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). Based on what we know regarding the issues with the Council's Employment Land Review, more employment land is required. A further increase in housing need (for instance in helping to meet Birmingham's unmet housing need) would require a further increase in employment land to ensure
growth is balanced.
The Council's approach to employment is inadequate as currently proposed, and further housing growth over and above this will require a further increase in employment land to ensure growth is balanced. Land at Park Lane Balsall Common is well placed to meet this employment land need. The site presents an opportunity to capitalise on HS2-related development and provide a sustainably located, well enclosed employment site which can serve the needs of the Balsall Common as it grows through the Plan period. The site will be used as a compound during the construction of HS2 and therefore cannot come forward until completion of this part of the route and/or it is released earlier as it is no longer needed by HS2. Employment land would therefore be delivered post-2025/6.
Barton Willmore LLP is instructed by Rainier Developments Ltd (the 'Client') to submit representations to Solihull Metropolitan Borough Council's Draft Local Plan Regulation 18 Supplementary consultation (the 'draft Plan') in relation to their land interests at land south of Park Lane, Balsall Common (hereafter referred to as the 'site'). Prior to our Client's involvement promoting this site, it was
previously promoted for residential development and assessed by the Council in their Site Assessment Document as Site 305. We enclose a new Call for Sites submission alongside these representations which proposes employment development on the site.
Object
Draft Local Plan - Supplementary Consultation
Site Selection Methodology
Representation ID: 8852
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
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. Below we set out our concerns with the Council's previous assessment of the site for housing (reference 305). The site was assessed as 'red' and 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'. The site is relatively free from constraint. Issues such as heritage, given the Grade II and II* listed buildings on Lavender Hall Lane, can be satisfactorily addressed through good design. This is bearing in mind the Council's conclusions on how their setting will already be affected by HS2. The site is within a large parcel (BA04) that is assessed as high performing this parcel probably the largest within the Borough. This is a meaningless assessment of the site's contribution
to the Green Belt, particularly as it does not take into account the amendments to the Green Belt around Balsall Common that are proposed through the draft Plan. HS2 should be considered in the assessment as the proposed route runs through the site and crosses Park Lane. HS2 will provide the site with an even stronger defensible boundary to the east. In addition, Park Lane is being upgraded alongside the provision of a new roundabout with the A452 to provide construction access for HS2. Accordingly, a more site-specific Green Belt assessment which accounts for committed development would clearly result in a significantly poorer score for this parcel of land. Landscape character assessment is broad and does not take into account HS2 and the upgraded Park Lane, which will have significant implications for the surrounding landscape and its capacity for further change. the Council have identified a number of allocations with similar landscape character, including other Balsall Common allocations such as the nearby Land at Wootton Green Lane and Kenilworth Road (reference 240). Consistency in the approach to assessments is required. We consider the site has high accessibility. It is less than 15 minutes walk from Berkswell Station, less than 10 minutes walk from the Sainsburys Local. Significant number of residents within walking and cycling distance of the employment opportunities presented by this site, including several 'green' assessed sites nearby. The site should be reassessed as a green site and identified as a draft allocation for employment purposes towards the end of the Plan period.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Question 3 - Infrastructure Requirements at Balsall Common
Representation ID: 8853
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
Balsall Common is identified as suitable for significant expansion and there are several allocations for large-scale housing growth here, alongside other sites which are not allocated but will be released from the Green Belt, meaning additional housing is likely to come forward beyond the numbers allocated. We support the growth of Balsall Common given it is a sustainable location. However, there is clearly a serious disconnect between the level of housing and employment growth proposed. Despite the acknowledgement in the plan that the village does not have significant employment uses the requirements for the area do not list employment. It is not clear how the Council propose to address this significant issue, which will only serve to exacerbate out-commuting and the associated environmental issues. HS2 presents an excellent opportunity to deliver employment land in this location. The upgraded Park
Lane and the new roundabout with the A452 would provide a suitable access to our Client's site, and the proposed bypass to the east of the village will avoid through traffic. Include reference to Class B employment as a requirement for Balsall Common and identify our Client's site (Land at Park Lane, Balsall Common) as a suitable location for employment.
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 4 - Site 1 - Barratts Farm
Representation ID: 8854
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However it is clear that employment land will be required.
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 5 - Site 2 - Frog Lane
Representation ID: 8855
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However as above, it is clear that employment land will be required
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 6 - Site 3 - Windmill Lane
Representation ID: 8857
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However as above, it is clear that employment land will be required
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 7 - Site 21 - Pheasant Oak Farm
Representation ID: 8858
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However as above, it is clear that employment land will be required
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 8 - Site 22 - Travellion Stud
Representation ID: 8860
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However as above, it is clear that employment land will be required
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 9 - Site 23 - Lavender Hall Farm
Representation ID: 8861
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree with the identification of the Balsall Common sites given the sustainable nature of the settlement. However as above, it is clear that employment land will be required
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Question 10 - Green Belt Changes
Representation ID: 8862
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land South of Park Lane
Agent: Barton Willmore Planning
We agree that the Green Belt boundary should be amended to reflect HS2 and other growth, however we disagree with the proposed amendment around Park Lane. We have identified a suggested Green Belt boundary shown in the Context Plan, which we consider presents a more logical boundary based on the committed infrastructure development around Park Lane, and the proposed allocation at Lavender Hall Farm to the east. HS2 will ultimately provide a new defensible boundary to Balsall Common and our Client's site (Land south of Park Lane) falls within this boundary, therefore ensuring there will be no encroachment into the open countryside.
Please see covering letter