Object

Representation ID: 23380

Received: 11/10/2021

Respondent: Councillor Adam Collinge

In relation to wider strategic proposals, I note that the Council has promoted greenfield and green belt Council owned land into the plan and draw attention to Wood Hayes open space (WOH271/CSA2)) /playing fields and land at Grapes Pool/Moseley Road (WOH273). These areas I believe will be highly valued by local residents. I note that Paragraph 99 of the National Planning policy Framework (NPPF) protects open spaces and playing fields and this may have been a legitimate stance to take in terms of strategy in relation to all open space. Para 99 reads: "Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use".

Whilst there may be the intention of wider open space enhancements or provision, the clear purpose of the strategic releases is housing development; therefore Part c) does not appear relevant and it is difficult to understand at this stage the wider open space provisions that could be made. At this stage, I cannot see from the evidence a clear assessment as to why the playing fields/open space have been declared surplus to requirements by the Council, with reference to relevant open space standards adopted by the Council. In this case, I believe it would likely be useful to assess the land in the context of wider population growth to 2039 (over the plan period), the pressure this would place on open space standards and also accounting for any cumulative effects from adjacent proposals by other authorities. Additionally, Part b) of Para 99 requires replacement provision of better quantity and quality. Irrespective of any enhancements elsewhere, the total amount of accessible open space will likely reduce as a result of allocation and any future development and this would be adverse in relation to quantity open space standards and how this relates to future population growth. I believe existing opens spaces and playing fields can be protected under Paragraph 99 and should not be released for development without clear transparent evidence they are surplus to requirements.