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Bloor Homes Midlands Land Off Bridgnorth Road, Wombourne

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Bloor Homes Midlands Land Off Bridgnorth Road, Wombourne Site Allocations Publication Plan Response Form Part A: Your Details (Please Print) Please ensure that we have an up to date email wherever possible, or postal address at which we can contact you. Your Details Agent’s Details (if applicable) Title Mr First Name Gary Last Name Stephens E-mail Address gary.stephens@marrons- planning.co.uk Job Title Planning Director (if applicable) Organisation Bloor Homes Limited Marrons Planning (if applicable) Address Bridgeway House, Bridgeway, Stratford-upon-Avon Post Code CV37 6YX Telephone Number 01789 339963 Please note the following: Representations cannot be kept confidential and will be available for public scrutiny, however your contact details will not be published. Your details will be added to our Local Plans Consultation database. All comments made at the Preferred Options stage have been taken into account in the production of the Publication Plan and will be submitted to the Inspector. The Publication Plan is a regulatory stage and any representations should relate to the legal compliance and soundness of the document. Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change as there will not normally be a subsequent opportunity to make further representations. After this stage, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination. Part B: Please use a separate sheet for each representation Please complete a new form for each representation you wish to make. 1. To which part of the Site Allocations (SAD) Publication Plan does this representation relate? Paragraph Policy SAD2: Wombourne C: Site Reference 283 Proposals Map 2. Do you consider the Site Allocations Publication Plan is Legally Compliant? Yes No Please give reasons for your answer. Please be as precise as possible: 3a. Do you consider the Site Allocations Publication Plan to be Sound? Yes No 3b. Do you consider the Publication Plan to be unsound, because it is not: Tick Positively Prepared: The plan should be prepared based on a strategy, which seeks to meet objectively assessed development and infrastructure requirements. Justified: The plan should be the most appropriate strategy, when considered against the reasonable alternatives. Effective: The plan should be deliverable. Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies of the NPPF. Please give reasons for your answer. Please be as precise as possible: 1. The allocation of land off Bridgnorth Road, Wombourne (site ref 283) for a minimum of 80 dwellings is supported. 2. Bloor Homes Limited have an interest in the site and it is their intention to develop the land for residential uses. They are a national housebuilder with no funding or capacity constraints that would affect the early delivery of the site. 3. The site is available for development now, with a willing landowner, and no unresolved ownership, legal or other constraints likely to render it undeliverable in the plan period. Furthermore there are no constraints that will affect the timescales for deliverability – e.g. relocation of existing use or remediation. 4. In order to support the Council’s evidence base as to the suitability and deliverability of the site, technical reports in respect of transport and accessibility, flood risk and drainage, ecology, and landscape and visual impact are appended to these representations. 5. On this basis Bloor Homes are confident that a policy compliant scheme can be viably delivered on this site (for example with regard to the provision of affordable housing). 6. Having prepared a conceptual masterplan appended within the figures of the Landscape and Visual Report, and undertaken an initial assessment of the housing capacity, Bloor Homes Limited are confident that the minimum dwelling delivery figure can be met. 7. As noted in Appendix One, the site performs well in the Council’s Site Assessment Process and its allocation is therefore justified by the evidence base. However, the following observations are made in relation to the evidence base for this site. Green Belt 8. The site was assessed alongside adjoining land to the north east, as part of Parcel 4 within the Partial Green Belt Review 9. The parcel as a whole was assessed as making the third least contribution to the Green Belt when compared to other parcels around Wombourne. Suitable and available land within the two parcels that made less contribution to the Green Belt (Parcels 1 and 3) have also been allocated in the Plan. 10.Notwithstanding the above, the assessment has overstated the potential contribution the allocation makes to the Green Belt. 11.In respect of the contribution this parcel makes to preventing neighbouring towns from merging into one another, the parcel was assessed as playing a major role in maintaining separation between Wombourne and the hamlet of Himley. This is stated as being a consequence of the hamlet being less than 500m from the parcel, and there being no significant natural features that could prevent the settlements from merging with one another. 12.Whilst it is appreciated this is an assessment of the parcel as a whole, this is incorrect as it fails to acknowledge the existing woodland block between large parts of the parcel and Himley as illustrated on the Wombourne Map on page 46 of the Review. This woodland is associated with Himley Plantation that lies to the south of Bridgnorth Road, and is a significant natural feature within the landscape that provides a clearly defined, physical barrier between the majority of the parcel (including the allocation) and Himley. 13.The existence of the woodland is recognised later in the Review when assessing the parcels contribution to safeguarding the countryside from encroachment, where it states that the woodland ‘protects the wider countryside from encroachment’. The significance of the woodland is also similarly referenced within the Landscape Sensitivity Study (see below). 14.Woodland is a significant natural feature that can be regarded as a robust Green Belt boundary, as acknowledged within paragraph 3.25 of the Review. Its omission therefore from the assessment has led to an overstating of the contribution this parcel makes to preventing neighbouring towns from merging into one another. 15.This is particularly the case in respect of the land to the west of the existing woodland block. It is visually separated from Himley, and the presence of the woodland forms a distinct natural feature in the landscape that contributes to the sense of separation between Himley and Wombourne. Its development would not therefore harm the character and local distinctiveness of the hamlet. Landscape Sensitivity Study 16.The Landscape Sensitivity Study also considered the allocation as part of a similar wider parcel of land (WM8). The Study concludes the area containing the allocation is of ‘low sensitivity’, being ‘visually more contained due to the presence of a significant woodland block immediately to the east’. That conclusion is agreed. Site Assessment Paper 17.In considering landscape sensitivity and Site 283 (land north of Bridgnorth Road), the Paper states that ‘the track running through the site marks a differentiation in terms of the impact on the landscape. Development to the west of the site would result in low impact, while development to the east of the track would have a high impact on the landscape. Considering this it is considered that overall the site is medium sensitivity.’ 18.The Site Assessment Paper states it has been directly informed by the Landscape Sensitivity Study. However, the Study did not conclude that there was any differentiation between land east and west of the track. The Study states that ‘the extent of any development should be limited to the western edge of the woodland block to the south east.’ There is no reference to the track within the Study, which is further west than the western edge of the woodland, and outside of the allocation in any event. 19.It follows therefore that the Site Assessment has misinterpreted the conclusions of the Landscape Sensitivity Study, and that Site 283 should have been scored as ‘low impact’ rather than ‘medium impact’. 20.In terms of its impact on the local environment, there are no environmental designations within the site, and so the site should have been scored as having a ‘low-medium impact’ as opposed to a ‘medium impact’. The Assessment appears to have mistakenly included the woodland within the site, and therefore scored a ‘medium impact’. 21.Similarly, there are no designated or undesignated heritage assets within the site, it is not adjacent to a Conservation Area, and there is no risk development could impact on the setting of a listed building. The site should therefore have been scored as having ‘low-medium impact’ as opposed to ‘medium impact’ in terms of its impact on the historic environment. Conclusion 22.Notwithstanding the above, and that the evidence base has overstated the potential impact of development on the Green Belt, landscape sensitivity, and the natural and historic environment, the evidence is considered sufficient to demonstrate that the allocation is sound and justified when considered against reasonable alternatives. 4. Please set out below what change(s) you consider necessary to make the Publication Plan sound or if you wish to support the legal compliance or soundness of the document. 5. If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? Tick No, I do not wish to participate at the oral examination Yes, I wish to participate at the oral examination 6. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: In order to respond to any questions from the Inspector on these matters, and explain the basis for the representation.
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