Comment

Representation ID: 23200

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

7.1. The Site Assessment Report: Assessment and Selection Methodology and Results (August 2021) (SAR) paper is part of the evidence base which informs the plan. It draws including the
Sustainability Appraisal of the Black Country Plan (Lepus Consulting June 2021 and

July 2021 versions). It is by consequence the main document which appears to have


justification for its spatial strategy.



7.2. The assessment undertaken is a multi-stage one. In simple terms, sites which progressed removed were then subject to more detailed site assessment against a range of criteria grouped under the headings: Green Belt and landscape sensitivity; Environmental; , amber, and
The Bloor site passed the initial filter stages and is not . For the avoidance of doubt, a red score is negative and green positive. It is not clear from the assessments or the published methodology what weight is given to each of the scoring criteria. The following section considers the Bloor site alongside a number of the proposed allocations under each of the wider headings.


Green Belt and landscape sensitivity


7.3. This element of the assessment is based on the Black Country Landscape Sensitivity

Assessment (LUC September 2019) and the Black Country Green Belt Study - Stage 2

Report (LUC September 2019). The SAR identifies that sites considered in the assessment as being likely to cause very high harm to the remaining Green Belt and where landscape sensitivity is likely to be moderate-high or high, have been considered




7.4. The Bloor site scores very high in terms of its Green Belt harm and moderate-high in terms of its landscape sensitivity and it is assumed that this is the main reason for it
.
7.5. In comparison, it is noteworthy and a cause of significant concern that a number of allocated sites score the same in terms of harm against these same criteria as the Bloor site (see Table 2 below) begging obvious questions around the fairness and robustness of the Site Assessment process especially in the context of such a significant housing shortfall. The SAR does go on to state that the Green Belt and Landscape assessments were based on larger parcels of land, and where the Council consider that a smaller site is judged to result in a lower level of harm, the level of harm has been downgraded as per the commentary in the table below.

7.6. It is our opinion that the landscape sensitivity rating for the Bloor site has incorrectly

- from the wider parcel, where the site itself

shoul Architects landscape evidence. These detailed assessments consider that the site as originally proposed (circa 700 dwellings) would not result in residual landscape effects beyond moderate significance, which is also the case for the reduced site. The Council has erred in not judging this site separately from the wider landscape parcel, as they have with a number of the proposed allocations as detailed in the table below. As our evidence shows if the Bloor site had been considered separately from the wider parcel the site would score better in the assessment of landscape sensitivity than a number of allocated sites and should have been considered suitable for development and allocated accordingly.

Table 2: Green Belt Harm and Landscape Sensitivity

Table 2: Green Belt Harm and Landscape Sensitivity

[Headings:] Policy (SA Reference) / Green Belt Harm / Landscape Sensitivity / Corrected Landscape Sensitivity Score / Comments

Stencils Farm/Very High/Moderate -/Moderate/The detailed comments
(SA-0066-WAL)//High//repeat the comments of the wider parcel assessment with no specific comments on the site itself.
Land north of/Very High/Moderate -/Moderate - High/Considered to have a high
Stonnall Road,//High//sensitivity based on its
Aldridge WSA3////topography (in places) and

(SA-0034-WAL)////its strongly rural and
////undeveloped character.
/////Overall conclusion
/////considered the site to have

limited visual impact due to
/////surrounding uses and
/////topography.
Calderfields/Very High/Moderate/-/Moderate - High/The comments note that
West WSA7//High///the site may have to be
(SA-0078-WAL)/////reduced to minimise impact
on the Green Belt and landscape sensitivity. No
/////explicit mention of this
/////within the allocating policy.
Land between/Very High/Moderate/-/Moderate - High/The fact that the assessed
Doe Bank Lane//High///parcel is larger than the
and Aldridge/////proposed site is noted as is
Road WSA8/////mention of the edge to
(SA-0017-WAL)/////Pheasey being more open

and forming a hard edge
/////which is considered to
/////reduce the landscape
/////sensitivity to less than
/////moderate-high or high.

Comments on the proposed allocations detailed above


7.7. WSA3 Land north of Stonnall Road, Aldridge: In terms of Policy WSA3 (Land north of Stonnall Road, Aldridge) the assessment appears to miss the conclusion to the Landscape Sensitivity Judgement. That is, the land to the north of the golf course (which includes the site) is considered to have a slightly higher (than moderate-high) sensitivity to residential development, and views of the site are considered to have sensitivity to development by virtue of the open views of the site. This assessment runs contrary to the conclusion of the SAR which considers the site to have limited visual impact due to surrounding uses and topography.


7.8. WSA7 Calderfields West: In reaching a judgement on the allocated site directly to the south of the Bloor site, WSA7 (Calderfields West), rather than disagree with the level of harm in the assessment, the SAR merely identifies the fact that the site area may need to be reduced. It does not appear that the same level of flexibility has been given to the Bloor site in undertaking these assessments, and we are happy to consider suggestions
by the Council which appear to have been missed for our site but forthcoming on a number of allocations including WSA7 which is immediately adjacent to the Bloor site with the same landscape and Green Belt harms ratings. In simple terms, if the landscape and Green Belt harm ratings are the same for this site which is adjacent to the Bloor site, and there are no other gateway constraints identified by the council, then there is no objective or evidence based reason to not allocate the Bloor site.

7.9. WSA8 Land between Doe Bank Lane and Aldridge Road: The assessment for site WSA8 (Land between Doe Bank Lane and Aldridge Road) is considered to underplay both the local and wider sensitivity of developing the site. The small-scale fields to the southeast between Doe Bank Lane and Birdle Lane are considered to have a higher sensitivity to development as detailed within the Landscape Sensitivity Assessment, with the Great Barr Conservation Area and Grade II Listed Buildings also identified as having higher sensitivity to development. The site contributes to the rural gap between these settlements. Large scale development would disrupt the small-scale field pattern, particularly to the east of Doe Bank Lane, which provides a rural and open backdrop to Streetly and Pheasey.

7.10. Instead, the SAR appears to concentrate on a small comment on the Landscape Sensitivity Assessment which is that the settlement edge of Pheasey becomes more open, forming a hard edge. This comment is not considered to relate to the draft allocated site, it is more a comment on the existing development on the western side of Doe Bank Lane. In terms of Green Belt harm the assessment is accepted that is, the development of the site would result in a very high level of harm and the site currently preserves the separation of Streetly and Pheasey as set out in the assessment which would be entirely lost by the development of the site. Correct consideration of the Landscape Sensitivity Assessment undertaken would not see the site proposed for allocation.
Environmental


7.11. The environmental assessments undertaken are generally accepted in relation to Stencils Farm (the Bloor site), but it is necessary to highlight what appears to be a contradictory statement made in relation to the impacts on visual amenity (which includes impact on adjacent land users and local character) insofar as this assessment comments West. The limited leisure uses to the South contribute to a rural character which would be lost if the site was developed. Limited impact on nearby residential outlook due to the orientation of houses. For these reasons there would be a significant local impact, due to the topography and surrounding development there would be a limited wider impact. This conclusion is welcomed as a site-specific assessment rather than the wider landscape harm identified when a larger parcel of land was assessed under the Landscape Sensitivity and Green Belt assessments. Nevertheless, the site scored red in this assessment which would appear to be an incorrect score based on the observations made in the assessment. This view is further evidenced in the Paul Gray Landscape Architects landscape evidence appended to this submission.


7.12. A number of the proposed allocations also score red in this assessment namely WSA2, WSA4 and WSA5. The table below considers the Bloor site against sites proposed for allocation which also score red in the assessment and proposed allocation WSA8 which scores amber. However, in our opinion, WSA8 should score red due to the significant local impacts identified. In addition, we disagree than the wider impacts would be reduced to such an extent that it performs better than the Bloor site in this element of the assessment.

Table 3: Impact on Visual Amenity

[Headings:] Policy (SA Reference)/Impact on Visual Amenity/RAG Score/Corrected RAG Score/Assessment Comments

Stencils Farm///Large open site prominent from
(SA-0066-WAL)///Aldridge Road and Open Space to the

North West. The limited leisure uses to
///the South contribute to a rural
///character which would be lost if the site was developed. Limited impact on
///nearby residential outlook due to the
///orientation of houses. For these
///reasons there would be a significant local impact. due to the topography and surrounding development there would be a limited wider impact.
Land at Vicarage Road, High Heath WSA2 (SA-0048- WAL)///Significant impact on visual amenities

from existing dwellings and users of
///PROW. Existing semi-rural character
///lost. Location close to existing
///development and favourable
///topography limits wider harm
Yeildsfield Farm///Strong local impacts by residents and
WSA4 (SA-0014-///users of the highway. Landscape
WAL)///design could mitigate this impact. The
site would be seen some distance away on Stafford Road. Semi-rural
///landscape lost and the visual
///separation between Bloxwich and
///Great Wyrley reduced. On balance mitigation can be achieved though sensitive design and mitigation.
Land at Yorks///The canal is a barrier between Pelsall
Bridge WSA5///and the rural character, any
(SA-0030-WAL)///development beyond the canal will have a significant detrimental impact on the visual amenities of the canal and local occupiers. Flat topography results in a moderate wider impact.
Land between///Significant local impact from residents

who face the site (on three of four sides). The site is level with Queslett Road and it is considered that this impact would reduce any wider visual impact.
Doe Bank Lane///
and Aldridge///
Road///

7.13. The assessments in the main identify significant local harm, and whilst the weighting in the final scoring of sites from this part of the assessment is unclear, it remains in our opinion that the Bloor site performs much better in this assessment that a number of the proposed allocations.


Economic



7.14. The main area of concern within the Economic section of the SAR relates to the inconsistency with which the Highway a




7.15. More specifically, the individual site assessments identify that 7 of the proposed allocations have not been appropriately assessed for their impacts on the wider highway network which raises concerns as to their deliverability. In addition, the consistency with which these constraints are identified within the assessments vary in terms of their RAG score, specifically relating to the impact on the wider road network. The RAG scoring for Highway Access and Transportation relates to the following: Red = Access constraints
/ severe highway safety impact which cannot be viably overcome; Amber = Access constraints / highway safety impact which can be viably overcome; Green = No / negligible access constraint. The table below highlights a number of anomalies / questionable scoring.

Table 4: Impact on the wider road network corrected RAG scoring

[Headings:] Policy (SA Reference)/RAG Score/Corrected RAG Score/Comments

Stencils Farm

(SA-0066-WAL)///Impact assessment of highway

capacity required.
Home Farm, Sandhills WSA1 (SA-0022-WAL)///No assessment of the capacity

of Chester and Lichfield Road undertaken.
Land north of Stonnall Road, Aldridge WSA3 (SA-0034-WAL)///Highway impact assessment

required to fully assess what infrastructure works required.


7.16. When considering the proposed corrections in the RAG scoring it is important to highlight the scoring from comparable allocations where similar identified constraints score amber rather than green as tabulated in table 5 below:

Table 5: Impact on the wider road network appropriate RAG scoring

[Headings:] Policy (SA Reference/RAG Score/Comments

Land at Vicarage//Likely significant wider impacts
Road, High Heath//identified and a requirement for a
WSA2 (SA-0048-//traffic impact assessment identified.
WAL)//
Land at Yorks//A highway impact assessment is

required.
Bridge WSA5 (SA-

0030-WAL)//
Land off Sutton//Could be wider impacts which may

need to be assessed
Road WSA6 (SA-

0012-WAL)//
Calderfields West//Housing numbers proposed are likely
WSA7 (SA-0078-//to require a Highways Impact
WAL)//Assessment.
Land between Doe//Surveys would be required to assess

impacts.
Bank Lane and//
Aldridge Road//
WSA8 (SA-0017-//
WAL)//

7.17. It is unclear how proposed allocation WSA2 with its red score i.e. there is a very substantial negative effect that is unlikely to be capable of mitigation in terms of its impact on the wider road network has been allocated for development without certainly that the network can accommodate the development.


7.18. Stencils Farm (the Bloor site), scored red in the same assessment with a simple comment that an impact assessment of highway capacity is required. This is even when a site accessed from the same road (Aldridge Road) proposed as an allocation (WSA7) scores amber. This is clearly an error that requires correcting and removes another of

Social



7.19. The scoring in this respect is generally accepted. However, there appears to be an error in the scoring for all sites albeit the comments clarify the scoring. The methodology for access time, which details the times identified will be walking times for access to primary schools only with other times being public transport times. As such the site should only score red for the walking times to a primary school (noting that a primary school is proposed on the site which would overcome this minor shortcoming of the site) and not for access to a GP/Health Centre/Walk in or Centre/Foodstore.


Conclusion on the Site Assessments



7.20. Having regard to these significant assessment anomalies it is asserted that the site should not have been discounted for housing development. With corrected assessment scores as detailed above the site scores at least as well if not better than the sites proposed for allocation under policies WSA3, WSA7 and WSA8 in terms of landscape sensitivity, better than proposed allocations under policies WSA2, WSA4, WSA5 and WSA8 in terms of visual amenity, and better than proposed allocation WSA2 and equal to WSA1, WSA3, WSA5, WSA6, WSA7 and WSA8 in terms of impact on the highway network. Proper consideration of the Bloor site within the Site Assessments would see the site allocated, which raises serious questions about the robustness and fairness of

8. Conclusion and case for allocation of the site.



8.1. The inability for the existing urban areas of the Black Country to accommodate the housing need arising over the plan period is fully acknowledged and the case for Green Belt release fully accepted by the Black Country Authorities. Bloor welcome this stance.


8.2. Of great concern however is the fact that despite some Green Belt release to deliver new homes, the Plan falls a long way short of delivering sufficient homes to get anywhere close to meeting the identified housing need.

8.3. We submit that basing a plan on the non-delivery of almost 30,000 homes and the expectation that the wider housing market area can and will deliver them is an entirely unsound strategy. This is particularly so in the context of a HMA which has struggled with the legacy of significant unmet arising from Birmingham City in the recent past and where question marks remain over the successful absorption of those homes amongst neighbouring authorities.

8.4. We submit that the plan should meet its housing need in full and that if Green Belt release is fully accepted as mechanism to do this, then there is further capacity within the Green Belt to allow additional homes to be delivered within the Black Country.

8.5. The Bloor site represents additional capacity in a sustainable location where the



allocation WAS7.


8.6. We contend that any landscape harm identified is not of a sufficient magnitude so as to prevent the allocation of the site in full. Nevertheless, Bloor remain committed to exploring options for a lesser quantum of development on the site in order to overcome any landscape concerns that the council may perceive. We note that such flexibility has been extended to other allocations.

8.7. There are no substantive reasons not to allocate the Stencils Farm site which can be delivered in the early years of the plan.