Comment

Representation ID: 47045

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Birmingham Road, Great Barr (site ref: SA- 0003-SAN) site assessment

HIMOR is promoting land at Birmingham Road, Great Barr for residential development. The site provides an opportunity to create a sustainable and high quality new community, delivering a wide range of new family and affordable homes in a highly accessible and sustainable location, which is fully supported by a robust site specific evidence base which we have discussed and introduced at section 2 of these representations.

Our evidence base does not support the Council’s site assessment of the above site, which is then followed through to the SA, as evidenced by our critique at Appendix 9. Indeed the site should score much more positively, which reflects the pressing need for sites of this nature in Sandwell given the deficiencies in its proposed housing land supply, the scale of the shortfall, and its chronic under supply of affordable housing. We summarise the key findings from the critique below:

• The Councils’ Green Belt Review assesses the entirety of HIMOR’s land ownership scoring it ‘High’ harm. When a reduced area is assessed based on the actual proposed development area (based on either options 1 and 2), development at the site scores a much reduced ‘Low-Medium’ harm.

• As demonstrated by the Ecology Solutions Biodiversity Technical Note (Appendix
5) and its associated documents, it is clear the biodiversity value of the site has been overplayed and is not justified. Firstly the process for making the designation is not transparent and has not been subject to appropriate public consultation or independent scrutiny. Also the status of the designation is not clear as it has not been formalised in any Policies Map. The designations validity is therefore questionable, as is how much weight, if any, can be given to it. Secondly, the assessment of the site undertaken by the Wildlife Trust is seriously flawed, it significantly overplays the site’s ecological value. Its findings on the site’s ecological value are not evidenced, it over values the grassland habitat, its assessment of naturalness is inaccurate, and it over scores species rarity. We contend that the site’s value is lower than that stated in the Assessment and accordingly would not meet the criteria for it being made a SINC. Notwithstanding this, our proposals are capable of preserving the key features of the proposed SINC and existing SLINC, including through the retention and bolstering of existing hedgerows within the site, as well as achieving a net gain in biodiversity. The site should therefore score ‘Green’ for ecology.

• Any non-designated archaeological remains at the site will be undeveloped and maintained as part of any development proposals for the site. The historic field pattern will be incorporated into both proposed development options. This would preserve the features which are proposed as justification for designating the site as an Area of High Historic Landscape Value. There is no evidence that there are remains greater than local importance. The site should therefore score ‘Green’ for heritage.

• PJA’s Transport Technical Note demonstrates that the site is in a much more accessible location than the Site Assessment indicates, for instance the site is located adjacent to the Q3 Academy which is much closer than the Site Assessment acknowledges. There is also the opportunity to provide a health centre.

• At the moment the site is completely inaccessible to the public. Our proposals would deliver significant area of public open space, such as through the provision of a new country park in a location which is not currently accessible to the public. This is a significant benefit.

4.3 Notwithstanding the above, there is also concern with the application of the site selection methodology. Section 3 of the methodology for Green Belt sites states the criteria for filtering our sites include where development would cause ‘Very High’ harm to the Green Belt and ‘Moderate-High’ harm to landscape sensitivity, and where there is one or more significant planning constraint which cannot be mitigated.

4.4 As set out above, there is clear evidence that Green Belt and landscape sensitivity has been overstated for HIMOR’s site at Birmingham Road, Great Barr, largely because the Councils’ assessments have assessed a wider area of land than is proposed for development.

4.5 The methodology has been applied inconsistently, there are examples where sites which have scored ‘Very High’ Green Belt harm and ‘Moderate-High’ landscape harm have been proposed for allocation – land at Stonnall Road, Aldridge in Walsall Borough (site ref: SA-0309-WAL).

4.6 The Council has also over valued the site’s biodiversity and its proposed SINC designation is not justified.

4.7 In summary, our evidence demonstrates that the role the site would play in delivering new homes sustainably in Sandwell has been underplayed by the Site Assessment and SA, and this has followed through to the Councils’ approach to site selection. It should therefore be a proposed allocation in the plan, not least because of its range of benefits, including the provision of extensive public open space and the contribution it will make to Sandwell’s chronic affordable housing shortfall.