Development Allocations

Showing comments and forms 91 to 120 of 145

Comment

Draft Black Country Plan

Representation ID: 21443

Received: 07/10/2021

Respondent: Mr Stephen Parr

Representation Summary:

I knew nothing about this plan until a few days ago when I received a newsletter called Focus issued by the Lib Dems. It mentioned a green belt site they named as Tanhouse Playing Fields which is listed as a site for possible house building . The site is adjacent to a busy rail line carrying heavy freight trains day and night, it is adjacent both to the Sandwell Valley and the Tanhouse RSPB sanctuary, it is on ground beneath which disused coal mining tunnels lie or are nearby (previously used until the 60's and linking Hamstead colliery with the Jubilee colliery) ,already busy roads in Tanhouse Avenue and Hamstead Road, the site having a right of way by usage - about 70 years to my knowledge etc etc. I have lived [location redacted] since the early 1950's.

Support

Draft Black Country Plan

Representation ID: 21446

Received: 10/10/2021

Respondent: Steve Beesley

Representation Summary:

I would like to pledge my support for the Council's decision to exclude the Peak House Farm/Wilderness Lane
from the Draft Black Country Plan

Object

Draft Black Country Plan

Representation ID: 21522

Received: 02/09/2021

Respondent: Miss Karen Riley

Representation Summary:

I am deeply concerned of the level of development proposed in my local area. I am a local resident of the proposed redevelopment of beautiful open space, formerly a golf course, in Brandhall which we use daily for exercise and wellbeing. It is pur only open space in walking distance and having no garden, just a small paved yard, it is vital for exercise [personal details redacted]. We use it for mental health wellbeing, exercise and to meet and chat with local people. [personal details redacted], removing this open space will isolate us even more. Reduce the quality of our living environment, cause more heavy local congestion and strain on services. It worries me greatly

Comment

Draft Black Country Plan

Representation ID: 21600

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Representation Summary:

We write on behalf of Oldbury (Smethwick) Limited, a subsidiary of Pall Mall Investments,to make representations to the draft Black Country Plan (BCP) Regulation 18 Consultation.

Pall Mall Investments are the owners of residential development land situated off Heath Street/Cranford Street. The land is immediately to the north-east of the new Midland Metropolitan Hospital, and comprises approximately 1.78 hectares (4.39 acres).
The site falls within an area earmarked for residential development by the draft BCP, and is within a Core Regeneration Area (CRA) by virtue of draft Policy CSP2. In addition, the site is also a proposed residential site allocation known as SAH 085 in the draft BCP. The site is currently allocated for residential use by virtue of Policy H12.9 of the Sandwell Site Allocations Documents (SAD) which was adopted in 2012.
There is therefore an established residential planning policy context for the redevelopment of the site for residential use, and my client welcomes that this is continued in the draft BCP.
We understand that the site was previously used for employment purposes and other similar uses. A
large part of the existing complex of buildings have however now been demolished. We also understand that a small part of the neighbouring land originally
formed part of the site, but was subject to a Compulsory Purchase Order (CPO) in order to facilitate the construction of the nearby Midland Metropolitan Hospital.

More recently, the majority of the site is being used for car parking to facilitate the construction of the Midland Metropolitan Hospital. The car parking was originally used by Carillion but following their collapse, is now being used by the Sandwell and West Birmingham Hospitals NHS Trust to facilitate the completion of the hospital.
Our client now intends to put forward residential proposals for the site in anticipation of securing a house builder to bring forward the residential development of the site when the Trust's occupation of the site ceases, on completion of the Hospital.

Support

Draft Black Country Plan

Representation ID: 21604

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Representation Summary:

Land at Heath Street/Cranford Street, Smethwick,
Sandwell, B66 2QZ
Accordingly, our client supports the continued allocation of this site for residential development that is proposed by site allocation SAH085 in the draft BCP.

The subject site is included within Table 22 - Sandwell Residential Site Allocations (BCP
Policy HOU1) and hence is a proposed residential site allocation in the BCP.

Whilst our client welcomes the continued allocation of the site for residential use, as it will enable them to bring forward residential development of the site when the current use (facilitating the construction of the Midland Metropolitan Hospital) ceases, we have several
comments/observations on the draft site allocation

Comment

Draft Black Country Plan

Representation ID: 21606

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Representation Summary:

Land at Heath Street/Cranford Street, Smethwick,
Sandwell, B66 2QZ

Accordingly, our client supports the continued allocation of this site for residential development that is proposed by site allocation SAH085 in the draft BCP.

The subject site is included within Table 22 - Sandwell Residential Site Allocations (BCP Policy HOU1) and hence is a proposed residential site allocation in the BCP.

Whilst our client welcomes the continued allocation of the site for residential use, as it will enable them to bring forward residential development of the site when the current use (facilitating the construction of the Midland Metropolitan Hospital) ceases, we have several
comments/observations on the draft site allocation

Reference: SAH085 included at Page 458, as follows:
• ‘Appropriate Uses’ - despite being included a residential site allocation, the ‘appropriate uses’ column for the draft allocation in Table 2 states that ‘mixed use’ is appropriate rather than ‘housing’ (as is the case for this site, and for some, but not all, of the neighboring sites within the CRA).

We can find no clarity, definition or justification in the BCP for the residential site allocation being earmarked as ‘mixed use’ in the column rather than ‘housing’.
Hence, this should be clarified in the revised version of the BCP.

Whilst our client would welcome flexibility for some mixed (i.e. small scale ancillary mixed uses) to be included as part of a future residential scheme, given the brownfield nature of the site, any uses other than residential would need to be subject to both market demand being identified, and the viability test.

• Gross Site Area (ha) (Brownfield/Greenfield) – the gross site area has been calculated to be 1.85
hectares of land. We assume, having regard to the draft BCP Policies Map for Sandwell, that the proposed allocation includes both our client’s land, and the small parcel of land that originally formed part of the site, but is now in the control of the NHS Trust by virtue of the CPO. To confirm, our client’s land therefore comprises the large majority of this proposed allocation and hence will be able to deliver the large majority of the proposed site allocation.

• Indicative Development Capacity and Density (dph) - the net density per hectare is highlighted as 38 dwellings per hectare (dph). This equates to 70 dwellings over the
1.85 hectares assumed in the draft allocation.

Our client is currently preparing a masterplan/layout plan for the site in anticipation of commencing pre-planning application discussions with Sandwell Metropolitan Borough Council (SMBC). However, we anticipate that the 38 dph (which we believe is based upon the gross site area) is at the lower end of the range of development densities that we would anticipate being achievable for this site, and that the achievable site capacity falls between the range of approximately 80 to 90 dwellings (based upon initial masterplan work undertaken to date). This would equate to a density
of approximately 43 to 49 dph.

It should be noted that the proposed density of 38 dph falls below the minimum requirement for residential sites set out in draft Policy HOU2, which requires a minimum of 40 to 45 dph respectively, depending upon site location and accessibility (etc.).

The indicative site capacity should therefore be increased for proposed site allocation SAH 085 from 70 to approximately 80 to 90 dwellings, to ensure that the allocation is realistic and in line with the likely density achievable.

• Further Information - the column entitled ‘Further Information’ states that the capacity of the site will be confirmed following ‘the masterplan work’. We understand that this masterplan work is currently being undertaken for the wider Grove Lane area by Sandwell MBC, and will be due for public consultation later this month. Our client will review this masterplan work when released, and will make representations to this consultation process in due course.

The ‘Further Information’ column also refers to the ‘phasing’ of the site. We anticipate that it is unlikely that a site of this nature and scale would need to be phased to the market (given the size of approximately 90 dwellings which will equate to approximately two to three years of residential development, depending
upon the market conditions at the time). Therefore, we are confused as to why the draft allocation refers to the site being delivered in multiple phases. Hence, this
text should be omitted from the ‘Further Information’ column.

Summary
In summary, our client, Pall Mall Investments, welcomes the continued allocation of the site for residential redevelopment proposed by the emerging BCP. Our client has already commenced master planning work in anticipation of undertaking pre-application discussions with Sandwell MBC and securing a residential planning consent, so that the site can be brought forward when it is no longer required by the NHS Trust for car parking to facilitate the construction of the nearby Midland Metropolitan Hospital.
However, our client has made several observations on the emerging policies as currently drafted, and in particular, the indicative site capacity of 70 dwellings should be increased to 80 to 90 dwellings. The indicative site capacity currently proposed by the allocation is below the density aspirations set out in draft Policy HOU2. The initial masterplan work undertaken to date by my client suggests that a density range of 80 to 90 dwellings is achievable. This increase in site capacity will assist with ensuring that the proposals are both in line with the emerging Policy HOU2, but also, will assist viability and deliverability,along with the delivery of housing throughout the BCA areas.

In addition, the ‘mixed-use’ annotation included in Table 2 for the site should be clarified,as any other uses as part of a wider residential development of the site will need to be subject to market demand being identified and the impact on development viability.

Object

Draft Black Country Plan

Representation ID: 21922

Received: 30/09/2021

Respondent: Mr Tyson

Number of people: 2

Representation Summary:

we would like to raise an objection to building on the old brandhall golf course under the black country plan.......We use this green space often to walk watch wildlife and meet the community.....It helps with our fitness and mental health.....it means we can enjoy green space without getting into a car.

Object

Draft Black Country Plan

Representation ID: 22052

Received: 10/10/2021

Respondent: Pete Nash

Representation Summary:

Proposed housing in Tanhouse Avenue needs to be in another area, preferably a brown filled site. Any major building adjacent , with its traffic , destruction of the green land, with its attendant Nature, grasses butterflies, dog walking, is necessary for the wellbeing of us all. Look again Sandwell Council.

Object

Draft Black Country Plan

Representation ID: 22053

Received: 10/10/2021

Respondent: Peter Hackett

Representation Summary:

I object strongly to the provision of 50 homes on Tanhouse Avenue, Great Barr. This application shows a flagrant disregard to the wildlife habitat of the area. Nothing short of disrespect to the RSPB who have their entrance at the earmarked site. The field has been a well trodden path for dog walking away from the cyclists and joggers which make a lot of paths around Sandwell Valley around Sandwell Valley a pretty frenetic experience. The view across the field will be totally ruined by this development. Being close to Hamstead School the road is hard to navigate during morning and afternoons already. Facilities for potentially 200 residents are non existent in the area, not forgetting the parking for potentially another 100 cars. As the two car parks are small at the RSPB many use Tanhouse
Avenue opposite the field for parking, this development will greatly exacerbate the parking problems and will cause local residents much anxiety as visitors look for parking space. In this day and age of mental well-being coming to the fore building on green belt land seems several steps backward towards the dark ages, do people not agree? Finally approximately half a mile away at the top of Hamstead Road at Newton Road junction is a now a defunct church and a now unused I believe scout hut and car park. Maybe the planners should go into availability within the area in greater
detail, or maybe it’s just seeking an easy option!

Object

Draft Black Country Plan

Representation ID: 22088

Received: 10/10/2021

Respondent: Roger Burns

Representation Summary:

Tanhouse Planning Application.
The building of fifty dwellings just metres away from RSPB Sandwell will disturb sensitive species which use the reserve.
The area has very few green places left and construction will be to the detriment of not just wildlife but people too.
There is already heavy traffic on Tanhouse with the local School . Scarce species of flyover birds who are looking to feed on the Valley could easily overlook it if more houses are built there. Please see common sense and throw out this application

Object

Draft Black Country Plan

Representation ID: 22103

Received: 05/10/2021

Respondent: Royston Randall

Representation Summary:

If the new boundary laws come into effect in 2017 as planned , Rowley Regis will be incorporated into Smethwick as you now. How therefore can we have a debate on the future of Warley and Rowley Regis when at this time it does not exist. If it goes ahead I would assume Warley would have to accommodate most of the people on Smethwicks housing list, even though Warley and Brandhall have as we speak the least amount of green spaces in Sandwell. Therefore the closure of the 116 year old Brandhall golf course would in no way be beneficial to the residents of the area.
Sandwell has many sites suitable for housing, as you already now but I will refresh your memory as I don’t suppose many councillors who will represent Rowley Regis and Smethwick, actually live anywhere near . But there is plenty if land adjacent to Black patch park that used to have housing and still could in the future.
Unfortunately I do believe this consultation is a waste of ratepayers money , because if history has anything to do with the black country plan the council will do as they
want.

Object

Draft Black Country Plan

Representation ID: 22106

Received: 30/09/2021

Respondent: Sandwell Liberal Democrats

Representation Summary:

Ref SAH225 (Charlemont Community Centre)
The proposal for this site is for one house, and that will have no impact on the housing stock while opening up the possibility of developers encroaching on the neighbouring open space. This proposal should therefore be rejected and the Council should instead look for ways to make use of the building as a community centre. This could be either through the Council itself, or inviting community groups to make use of it.

in addition to this site depriving the local community of a community centre, and threatening local green space, there is a vacant plot of land less than 200 meters from this site (corner of Beacon View Road and Wyndmill Crescent) that looks like it could accommodate two or three houses. Such sites should be used before opening up Green Belt and open space.

Support

Draft Black Country Plan

Representation ID: 22110

Received: 30/09/2021

Respondent: Rebecca Duffield

Representation Summary:

I live in Poolehouse Road. I wish for this email to be taken as my official objection to the proposed development of Peak House Farm.

Support

Draft Black Country Plan

Representation ID: 22116

Received: 01/10/2021

Respondent: Antony Cockitt

Representation Summary:

I wish to support the councils decision not to include the Peak House Farm Site(off Wilderness Lane] in the Draft Black Country Plan.

Support

Draft Black Country Plan

Representation ID: 22118

Received: 20/01/2022

Respondent: Michael and Patricia Breakwell

Representation Summary:

we support Sandwell council in their decision to exclude the Peak house farm/wilderness lane sites from the draft Black Country plan.
local schools will not be able to cope with more pupils our doctor's surgeries are full and our local roads will not be able to cope with such a large amount of traffic

Support

Draft Black Country Plan

Representation ID: 22122

Received: 03/10/2021

Respondent: Maureen Fenton

Representation Summary:

This is to confirm that Maureen Fenton is in favour of the removal of Peak House Farm from the Black Country Plan for housing development.

Support

Draft Black Country Plan

Representation ID: 22126

Received: 01/10/2021

Respondent: Mrs J Lewis

Representation Summary:

I object to houses being built peakhouse farm and wilderness lane.
The traffic - mornings and afternoons due to the children coming out of Q3 school.
The lane is narrow, they start parking 1/2 hour before they come out.
Going back over 30 years my late husband and other people went to the council meeting and they said it had to be green belt.

Support

Draft Black Country Plan

Representation ID: 22132

Received: 04/10/2021

Respondent: Mr & Mrs C D Harris

Number of people: 2

Representation Summary:

I am writing to you supporting your decision to exclude Peakhouse farm/ Wilderness Lane from Draft Black Country Plan.

Support

Draft Black Country Plan

Representation ID: 22139

Received: 30/09/2021

Respondent: Mrs J Horton

Representation Summary:

I support the decision to EXCLUDE the development of Peak House Farm from the Draft Black Country Plan.

Support

Draft Black Country Plan

Representation ID: 22143

Received: 28/09/2021

Respondent: Norman Reeves

Representation Summary:

May I first of all put on record that I fully support the Sandwell Council's decision in NOT including the developer's proposal to build houses on Peak House Farm (Wilderness Lane) site.
This is a very desirable part of the world to reside but it is becoming more unpleasant by the day and to build houses on this site would be a disaster for the area and local amenities. The traffic in the area is becoming a nightmare by the day, the vehicles in the area is becoming intolerable with some houses having anything up to 5 vehicles per household and to build more houses in the area would only exacerbate the situation.
Peak House Road is becoming a race track for some vehicle users and very soon I feel there is going to be a serious accident. The traffic at sometimes of the day is very heavy and I feel to make it worse would be trouble. The volume of traffic at Scott Arms is getting worse and any further houses in the area would only add to the misery of getting around not to mention the problems of overcrowding of schools and the problems of getting appointments with local doctor.
Again I can only say that I support the council's decision and I hope and pray that this is not changed in order for the developers to make a handsome profit at the expense of our quality of life. SAVE GREAT BARRS GREEN BELT.

Object

Draft Black Country Plan

Representation ID: 22397

Received: 08/10/2021

Respondent: Inland Waterways Association Lichfield

Representation Summary:

Policy HOU1 - Site SAH226 - Land to north of Painswick Close substation, Sandwell
This site is an important area of countryside alongside the Rushall Canal. It is part of the West Midlands Green Belt which serves to check the sprawl of built-up areas, to encourage the regeneration of urban land, and to safeguard the countryside. Its proposed removal from the Green Belt would undermine those purposes and damage the setting and economy of the canal. Therefore, IWA objects in principle to its allocation for development. However, if exceptional circumstances can be proven then it is important that the adverse impact of development on the canal is limited and mitigated by sensitive layout, design and landscaping.
The Rushall Canal is a historic waterway and a valuable amenity and recreational corridor, providing leisure boating, walking, angling, cycling and nature conservation benefits to the area. It is part of the national waterway system which attracts millions of visits each year from local people and holidaymakers from home and abroad, and is a major component of the nation’s tourism industry.
The rural environment of the canals plays a vital role in attracting and sustaining the recreation and tourism use of the whole canal system, which contributes to the visitor economy and helps support local businesses. The income from boating activities provides a major part of the funding necessary for the Canal & River Trust to maintain the canals for public use and enjoyment.
Although much of the canal network in the Black Country is urban or suburban in character, the northern parts of the system in Walsall in particular include several attractive countryside sections. Because of their limited extent, these are of particular value to sustaining tourism as well as an important amenity for nearby residents.
However, major built developments in the countryside adjacent to the canal system destroy the rural setting that contributes to their heritage interest, wildlife, amenity value and recreational use. Visually intrusive built development alongside the canals damages their tourism potential and economic benefits.
The Rushall Canal currently enjoys a pleasant open rural outlook across this site that enhances its attractiveness for recreational use. The canal towpath is open to the public and provides an accessible footpath. However, the attractive countryside setting of this section of the canal will be largely lost by this proposed allocation. Whilst the canal corridor will provide an amenity for the new residents, its overall value to the local community and the visitor economy would be diminished if the development is visually intrusive.
It is therefore important that the visual impact of the development on the canal is limited by sensitive design, layout and landscaping of the site. The site includes a Site of Local Importance for Nature Conservation (SLINC) which the canal contributes to. This should be preserved and enhanced by setting back the built development behind a broad buffer zone alongside the canal with only limited built development forming a corridor of open amenity land to help preserve and enhance the canal environment. This corridor could encompass Public Open Space, parkland, woodland, wildflower meadows, sports fields, children’s play areas or informal recreation space.
This will be in line with the aspirations of Policy ENV7 – Canals, that development affecting the canal network should (1) “deliver a high quality environment”, (2e) “protect and enhance its visual amenity, key views and settings”, (3a) “enhance and promote its role in providing opportunities for leisure, recreation and tourism activities”, and (3d) “positively relate to the waterway by promoting high quality design, including providing active frontages onto the canal and by improving the public realm”.
The comments in Table 22 (page 446) recognise the Rushall Canal as the greatest asset of this site, but the suggestion that heights of buildings overlooking the canal should be raised is fundamentally misguided. This may provide a few residents with better views, but at the expense of a more visually intrusive development as seen from the canal by its many users.

Object

Draft Black Country Plan

Representation ID: 22612

Received: 05/10/2021

Respondent: RCA Regeneration Ltd

Representation Summary:

Objects to SAH097 as 16 indicative dwelling numbers unviably low, 40 dwellings are req to make site deliverable

Comment

Draft Black Country Plan

Representation ID: 22636

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Representation Summary:

Proposed development sites crossed or in close proximity to National Grid assets:
Following a review of the above Development Plan Document, we have identified that one or
more proposed development sites are crossed or in close proximity to National Grid assets.

Details of the sites affecting National Grid assets are provided below.

[Table headings: Development Plan Document Site Reference/Asset Description]

SAH228 Brandhall Golf Course
YJ ROUTE: 275Kv Overhead Transmission Line route: KITWELL - OCKER HILL
[See Attached Map 1]

SAE256 Site off Bilport Lane, Wednesbury
VT ROUTE TWR (001A - 016): 400Kv Overhead Transmission Line route: BERKSWELL - OCKER HILL
[See Attached Map 4]

SAE158 Roway Lane, Oldbury
VT ROUTE TWR (019 - 036): 400Kv Overhead Transmission Line route: KITWELL - OCKER HILL
[See Attached Map 5]

Comment

Draft Black Country Plan

Representation ID: 23047

Received: 04/02/2022

Respondent: Mr Mark Smith

Representation Summary:

Objects to SAH226 Land to north of Painswick Close Sub Station Objects to loss of community facilities for housing, refusal is req unless playing fields retained.

Object

Draft Black Country Plan

Representation ID: 23048

Received: 04/02/2022

Respondent: Mr Mark Smith

Representation Summary:

Objects to SAH224 - Land off Tanhouse Avenue citing loss of playing fields to community, loss of biodiversity -SINC Hedgrows & adjacent bird reserve- requested acknowledgment of 1908 mine disaster.

Object

Draft Black Country Plan

Representation ID: 23049

Received: 04/02/2022

Respondent: Mr Mark Smith

Representation Summary:

Objects to SAH225 - Charlemont Community Centre proposal as is a precedent to encroach on open space, but not impact housing stock.
Objects as should be community facility, and on flood risk grounds

Object

Draft Black Country Plan

Representation ID: 23114

Received: 30/09/2021

Respondent: RSPB FAO Natalie le Brun

Agent: RSPB FAO Natalie le Brun

Representation Summary:

Objects to SAH224.
Cites adverse impacts on wildlife populations of local and county importance, loss of nature-rich greenspace at 'green entrance' to Sandwell Valley.
Further objects as site adj Sandwell Valley, which supports various fauna/flora.
Urges consideration of less damaging allocations.
SAH224 needs to show it won't damage wildlife in RSPB Sandwell Valley reserve & SAH224 itself.
Further objects as adverse impact loss of greenspace on physical & mental well being.
Objects to potential impacts on wildlife and habitat, inc. red listed species.
Objects as site will require buffers to mitigate effects, meaning scale of proposal not feasible & alternative locations should be found.

Comment

Draft Black Country Plan

Representation ID: 43834

Received: 11/10/2021

Respondent: Mrs Val Rutter

Representation Summary:

Peak House Farm (Sandwell) is a similar situation [to Grande Country Park (Walsall) - see full text] and helps link the Sandwell Valley through and on to Cannock Chase. A large number of animals including deer use this corridor. I would support Sandwell Planners in maintaining this areas current status.

Object

Draft Black Country Plan

Representation ID: 44806

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Representation Summary:

Existing Allocations in Sandwell
5.31 The supply figures relied on from existing allocations in Sandwell are lower. The Strategic Centre in question is West Bromwich for which an AAP was adoptedin 2012. The evidence base was older than that, with Issues and Options in June 2006, Preferred Options in June 2008 and Changes to Preferred Options in January 2011.

5.32 The AAP should have delivered 201 homes before 2026, however it is difficult to identify specific numbers allocated as the adopted AAP is vague.

5.33 It is acknowledged that delivery may be slow in the AAP itself with paragraph 4.3 stating that some of the opportunity areas are considered to be more long term and in some instances will require other proposals to have come forward first before they can be delivered.

5.34 It is apparent that there are a number of allocations where delivery issues have come to light in the period since adoption of the AAP. The Lyng Industrial Estate, for example, was relied on for 300-430 homes, but Table 9 of SHLAA now assigns this site under the category “Sites allocated for housing but now considered not suitable / developable up to 2039”. The change arises from the viability and feasibility study commissioned which highlighted significant viability issues. In addition, the Eastern Gateway North site was identified for around 100 dwellings in the AAP and is now acknowledged in the SHLAA to have delivery issues relating to its occupation, the generally poor condition of the buildings and external environment and the fact that businesses would need relocating if the site was to come forward for residential development.

Object

Draft Black Country Plan

Representation ID: 44818

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

SAH068 Hawes Lane, Rowley Regis - WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• WTBBC understand the allocation is an area of public open space. It is WTBBC’s position that due to the broad range of benefits that these sites provide local communities that no public open space should be allocated for development. Objection on this basis