Draft Local Plan - Supplementary Consultation

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Comment

Draft Local Plan - Supplementary Consultation

Site Selection Methodology

Representation ID: 10171

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Step 2 refinement is contrary to NPPF. Not appropriate to introduce physical boundaries in otherwise open green belt areas. Methodology should set out preferred criteria for defining clear defensible boundaries. Some red sites ruled out due to lack of defensible boundaries, whilst some sites rated green have caveat that physical boundaries will be created. Methodology not consistently and logically applied across all sites.
Absence of evidence eg more detailed studies following Strategic Growth Study/Landscape Character Assessment.
Contend that despite use of Standard Methodology based on 2014
household projections, there is still no signed Statement of Common Ground,
(contrary to NPPF),

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Support

Draft Local Plan - Supplementary Consultation

Question 38 - Amber Sites

Representation ID: 10172

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Amber Site Reference 116; Land at and to the rear of 146-152 Tilehouse Lane, Whitlock's End.

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Object

Draft Local Plan - Supplementary Consultation

Local Housing Need

Representation ID: 10173

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Insufficient deliverable residential site allocations identified which comply with site selection criteria and national policy recommendations. Plan should be future proofed by allocating land for more houses than recommended by standard methodology, recognising it is a minimum starting point and need to boost house building. More small and medium sized viable sites need to be allocated.
Housing Delivery Test misleading given lack of objectively assessed need in SLP2013 and DLP requirement. Requires 20% buffer and/or Action Plan.
Despite use of Standard Methodology based on 2014 household projections, there is still no signed Statement of Common Ground, contrary to NPPF.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 7 - Site 21 - Pheasant Oak Farm

Representation ID: 10174

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

No clearly defined physical feature along eastern boundary, and site does not follow field boundaries. Reliance on bypass line problematic, no evidence that route/funding agreed. Line likely to be further east so could not provide boundary.
Low level of accessibility, Sustainability Appraisal identifies only 3 positive v 6 negative (2 significant) effects.
Only one third of site is brownfield, the eastern part of the site makes the highest possible contribution towards the Green Belt purposes.
Should not be priority 3, but 8 for brownfield element and 10 for remainder according to site selection methodology, therefore unsuitable for allocation.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 14 - Site 12 - Land South of Dog Kennel Lane

Representation ID: 10175

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Lack of a clear defensible physical boundary and concern that there will be pressure for further development to south, as shown on the promoter's masterplan submission for site 26. Site needs to be assessed consistently with other sites rejected for lack of physical boundaries.
Severely compromises Green Belt purposes a to c.
Site should be re-evaluated and doubtful that stated capacity is realistic.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 15 - Site 26 - Whitlocks End Farm

Representation ID: 10176

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Lack of a clear defensible physical boundary and concern that there will be pressure for further development up to the Stratford Canal, as shown on the promoter's masterplan submission. Site needs to be assessed consistently with other sites rejected for lack of physical boundaries.
Severely compromises Green Belt purposes a to c.
Site should be re-evaluated and doubtful that stated capacity is realistic.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 17 - Site 6 - Meriden Road

Representation ID: 10177

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

The 'Draft Concept Masterplan' document, January 2019, acknowledges
that alternative premises would need to be found for the wood shaving operation to
enable the residential development of both sites. This is likely to be problematic
given the 'bad neighbour' characteristics of the use.
Site preparation works required for brownfield element questioning viability.
These significant doubts over deliverability mean site should not be allocated.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 23 - Site 8 - Hampton Road

Representation ID: 10178

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Many sites rejected where there are no existing physical features, yet there is no clearly defined physical boundary along northern edge of NW proposal and site does not follow field boundaries. Topography means site more visually intrusive in green belt and impacts on openness. Impact on Local Wildlife Site, TPOs, right of way and setting of Grimshaw Hall.
SE proposal occupied by Knowle FC so question over deliverability. Further land promoted with potential impacts on Grimshaw Hall. Land is highly performing in Green Belt Assessment.
No very special circumstances to justify sports hub in green belt.

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Object

Draft Local Plan - Supplementary Consultation

Question 27 - Site 17 - Moat Lane/Vulcan Road

Representation ID: 10179

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

The 5 ha urban site is expected to deliver approximately 200 dwellings. However,
the viability of the site for residential development has not been tested and the
potential land contamination on the site is unknown. Recommendation in concept masterplan that consideration given to relocation or removal of the telecommunications mast if possible.
Deliverability not demonstrated and should not be allocated.

Full text:

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Object

Draft Local Plan - Supplementary Consultation

Question 28 - Site 18 - Sharmans Cross Road

Representation ID: 10180

Received: 14/03/2019

Respondent: Mr P Benton and Mr T Neary

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

Concern over permanent loss of community playing field facilities in an
area identified in Playing Pitch Assessment/Strategy, 2017, as being deficient in this area. Unused pitches need to be replaced if lost and no information provided to suggest an alternative site.
Contrary to the strategic objective of protecting and promoting healthy
sustainable communities.

Full text:

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