Object

Draft Black Country Plan

Representation ID: 23081

Received: 11/10/2021

Respondent: Bromsgrove District Council

Representation Summary:

Policy HOU1 and CSP3
7. Sites DUH206, DUH207 and DUH209 are being proposed to be taken out of the green belt and allocated for development of 115 houses. This has been done irrespective of the fact that (DUH209) was rated as causing very high harm to the GB, and all three sites are found to be within an Area of High Historic Landscape Value. This development is in close proximity to the settlement of Hagley which is within Bromsgrove District. Table 14 indicates that policy CSP3 provides further information regarding these allocations. CSP3 provide little detail on how it is expected that this site will be developed, it not clear how these allocations relate to the requirements of CSP3. BDC is aware that there is a significant policy base by which this allocation will be determined should a planning application be submitted, subject to the site being allocated.
8.BDC has also reviewed the site assessment work (Appendix A pages 96-107) accompanying these three sites, and would wish to understand the full impact on the infrastructure in the surrounding area, before forming a view on the suitability of these sites for allocation.
9.It is noted that the sites have been ranked as follows with the following comments in relation highways access and transportation and impact on the wider road network.
Site Known as Highways access and transportation Impact on the wider road network
RAG Rating RAG Rating
SA-0010- DUD-A / DUH206 Worcester Lane North , Green , Access via Worcester Lane, Green Potential junction improvement Racecourse Lane / Worcester Lane to North. To south Park Rd/ Worcester Rd
SA- 0010- DUD-B / DUH207 Worcester Lane Central, Green Access via Worcester Lane, potential mitigation junction improvement Racecourse Lane / Worcester Lane to North, To south Park Rd/ Worcester Rd Green Further information would be required to assess this
SA- 0018- DUD-C / DUH209 Worcester Lane South, Green Access via Worcester Lane. Loss of hedgerow should be kept to a minimum. Green If developed with call for sites site to north (SA-0010-DUD A and B) potential junction improvements Racecourse Lane/Worcester Lane to the north and to the south Park Rd/ Worcester Rd.




10. For these sites to be ranked green, it is a requirement of the published methodology that they have for:
• highway access and transportation - No / negligible access constraint (Site Assessment Report – page 23)
• impact on the wider network - No / negligible impact (Site Assessment Report – page 24)
11. There is inconsistency in the narrative which accompanies these site assessments:
• Does the mitigation at the junctions north and south of the sites get assessed under the highways access and transportation section, or impact on the wider transport network section? At the moment this is not clear or consistent.
• Irrespective of the point above, for a potential mitigation scheme to be identified, that would suggest that there is some form impact under either of the categories which is more than negligible, and therefore an amber rating would be more suitable.
• For site DUH207/SA-0010-DUD-B it appears no assessment has been carried out of the impact of the wider network and still the site is ranked green, it is concerning that
this ranking can be determined without any assessment taking place.
12. BDC would suggest this assessment is re-run and the outcomes shared with BDC and other interested parties prior to the publication of the next stage of plan making.
13. Other elements of the infrastructure assessment also require clarification, the assessment of: Primary schools, Secondary Schools, GP/Health Centre/Walk in Centre, Strategic Centre/Employment areas, and Centre/Foodstore all refer to walk times which are achieved ‘following any viable mitigation’. BDC would like clarification on what this mitigation is and that it is in fact viable. Unviable mitigation is not considered to be appropriate mitigation.
14. These comments are officer only comments at this stage, BDC members will be considering the formal response at committee meetings following the deadline for submission of comments, should any additional comments be required officers will submit them following these meetings.
15. Bromsgrove District Council remains committed to successful plan making and will continue to engage with the BCA under the Duty to Cooperate. Upon receipt of these and any additional comments, officers will be happy to meet with BCA representatives to discuss all the points raised in further detail. less