Object

Representation ID: 23603

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

10.7
Proposed allocation: Land at Greenwood Road, Aldridge
The site is located to the north Greenwood Road and west of Lazy Hill Road, Aldridge. The site
currently comprises 2.5ha of open pasture land, enclosed on 3 sides by exiting residential
development. A site location plan is provided at EP3.
Proposed allocation
The site proposed for an allocation of approximately 60 dwellings.
We have submitted a sketch layout plan (EP4) which illustrates how the proposed quantum of
development could be accommodated on site, which would integrate and sit conformably
within the existing built form Of the surrounding area. The development Of the site would represent
a logical rounding-off of the settlement and can deliver housing early in the plan period with no
significant requirements for infrastructure.
Exceptional circumstances
Exceptional circumstances at the strategic level are discussed in our response to policy CBI. The
BCA accept the need to release land from the Green Belt to meet the need for development.
At the site-specific level, Green Belt considerations can form part of the exceptional
circumstances. This site is surrounded by existing housing on 3 sides, and its development would
represent a rounding-off of the settlement that would not result in bringing Aldridge or Walsall
Wood any closer together. The allocation Of the site would result in very little harm to the Green
Belt. This is discussed further below in our response to the Site Assessment report.
Site Assessment Report
As discussed in Section 10 of this statement, we consider that the application of the site selection
methodology is flawed. Specifically, we object to the assessment of our client's site at
Greenwood Road, Aldridge (parcel SA-0059-WAL). We hereby address each aspect Of the site
assessment in turn.
Green Belt and Landscape Sensitivitv Assessment
This is a key stage of the site selection process as, under stage 3 of the current site selection
methodology, sites "where development would cause very high harm to remaining Green Belt and moderate-high or high harm to landscape sensitivity" a automatically fi tered out.
consider that the assessment Of parcel SA-0059-WAL against these criteria is fundamentally
flawed, for the reasons discussed below.
Green Belt considerations
10.8 Our client's site is assessed as part of sub-parcel 8120As2 within the Black Country Green Belt
Study (2019). The study identifies the parcel of land as having a harm rating Of 'high' if developed.
10.9 The Stage 2 Assessment as contained within Appendix 3 of the document, does not provide a
detailed assessment Of the sub-parcel, rather a single paragraph commentary is provided within
the assessment section to qualify the 'high' harm rating given:
'The sub-parcel makes a strong contribution to preventing the sprawl of the
West Midlands conurbation, maintaining the separation of Aldridge and
Brownhills and preventing encroachment on the countryside. Greenwood
Road forms a consistent boundary along the edge of Aldridge, but the field at
the eastern end is further from Holly Bank, more contained by existing built form
and has a constrained woodland block to the north which adds to separation
from the inset settlement to the north. Release of this area would therefore
cause only a limited weakening of the adjacent Green Belt. '
10.10 The conclusions provided within the commentary on the sub-parcel appear at Odds with the
overall 'high' harm rating of the wider parcel, noting the release would only result in •limited
weakening' Of the adjacent Green Belt. '
10. I I The site is well contained and is boarded on three sides by existing housing, with Greenwood
Road to the south and south-west. and Lazy Hill Road to the east. The future development Of the
site would not result in the physical or perceived closing of the gap between Aldridge and Walsall
Wood to the north. Rather it would represent the rounding-off Of the settlement. As a result Of the
alignment of Greenwood Road and the houses to the east of the site which extend north along
Lazy Hill Road. the development Of the site would not result in the extension Of the built form Of
Aldridge any further north than that which already exists.
Landscape Sensitivity
10.12 The site forms part of parcel BL35 in the Black Country Landscape Sensitivity Assessment (LSA). It
is assessed as being of moderate-high landscape sensitivity. As such, the BCA Site Assessment
scores the site as 'moderate-high' landscape sensitivity for residential development, and 'high'
sensitivity for employment development. It is not clear why the site assessment draws this distinction given that the site has never been promoted for employment development and the
LSA does not identify that this specific site would be any more or less sensitive to other uses than
any other site.
10.13 Parcel BL35 covers a far more extensive area Of land than the site being promoted. It includes
potentially sensitive features, such as areas of woodland, which would be not form part of the
developable area for the site. The assessment Of BL35 in the LSA also states that:
"The area also plays an important role in providing the perception of a rural
gap between Walsall Wood and Aldridge. "
10.14 Furthermore, the BCA Site Assessment states:
"Large scale development would disrupt the valley landform, historic field
pattern and reduce the role Of the area in providing a rural gap between
Walsall Wood and Aldridge. "
10.15 However, that finding does not apply to parcel SA-0059-WAL due to the physical containment of
the site and the fact that it would not result in the extension of the built form Of Aldridge any
further north than that which already exists (as discussed above in relation to Green Belt).
Furthermore, the development of this site would not result in 'large scale development'.
Therefore, applying the findings of the LSA to this site is erroneous.
10.16 Notwithstanding the negative assessment of the site in relation to these criteria, we note that
other draft allocations receiving similar scorings still go on to be allocated (see Section 9 of this
statement). It is not clear why such an approach not applied to this site.
Environmental, social and economic criteria
10.17 The Site Assessments addresses various other 'environmental, social and economic' criteria. We
address below the aspects of the assessment which we consider to be incorrect and/or flawed.
Impact on visual amenitv of adjacent land users
10.18 The assessment of the site under this criterion states:
"The site is in an elevated position, the surrounding development to the South
and East is predominantly single storey. The presence of buildings above single
storey in height would have a significant visual impact on the area and the
submission comes with a proposal for just single storey units. The greater, wider
impact would be from the North, the site is in an elevated position and development would significantly impact on the openness which characterises
this part of Aldridge and would be seen from the Chester Road 750m away, the
existing topography ensures that the single storey houses are not visible from
the North, however the submission site goes beyond the ridge and even single
storey here would be visible. For these reasons it is considered there would be
a strong negative impact from any development at this site. "
10.19 This appears to be an attempt to undertake a detailed assessment of the visual impact of the
proposal, but the assessment is extremely crude and the overall conclusion is unduly negative.
Visibility of the site does not necessarily equate to harm of the highest level. Furthermore, simple
mitigation such as landscaping or setting back development from the ridge could resolve the
issues identified, but is not considered.
10.20 The assessment also fails to note that the existing urban edge along Greenwood Road benefits
from no landscaping or screening. A development with a high-quality landscaping scheme could
provide a far stronger boundary than currently exists in this location. This could be a benefit in
landscape and visual terms.
Accessibilitv
10.21 The Site Assessment claims that the site is more than a 15-minute walk from a primary school.
However. the site is within 1.2km walking distance Of Leighswood School. and therefore within a
15-minute walk. The assessment therefore appears to be incorrect. Furthermore, Castlefort
Primary School is also within walking distance of the site (1.8km walk).
10.22 In addition to primary schools, the site is in a highly accessible location in relation to key services,
facilities and public transport links:
• Local bus stops are immediately adjacent to the site, providing an hourly service
between Walsall and Leighswood, via Aldridge.
• A range of local GP surgeries and dentists are within 2km of the site.
• The site is within 600m of nearest local convenience store, pharmacy and post office
located within Lazy Hill centre.
10.23 The site is therefore well served by public transport for the purposes of the Framework and IS
sustainably located with a range Of services and facilities nearby Other considerations
10.24 The Site Assessment report does not identify any significant harm in any other area, including
access, trees, residential amenity, air quality, ground conditions, flood risk or heritage. We agree
that these factors do not present any constraints to the sustainable development of the site.
Conclusions
10.25 The overall conclusion of the BCA Site Assessment is as follows:
"Development here could cause significant harm to the visual amenities Of the
wider area due to the topography surrounding the site which the adjacent
bungalows have been designed to take account Of. In addition the site scores
high Green Belt and landscape harm. "
10.26 For the reasons set out above, we consider that this assessment erroneous. The assessment of
visual amenities is flawed and fails to consider potential mitigation, such as landscaping or
development being set back from the ridge. The Green Belt and landscape assessments relate
to a much wider parcel of land and the conclusions cannot be attributed to the subject site.
10.27 The site represents a logical, small-scale rounding-off opportunity, that would have a very minor
local impact upon the Green Belt. The site is deliverable and can contribute to meeting the
identified development needs of the Black Country in a sustainable way. We therefore propose
that the site is allocated for residential development in the BCP. 11.1