Draft Site Selection Criteria for Consultation
As part of the continued engagement with the community and stakeholders Brown Edge Parish Council are now consulting for 2 weeks from 8th December 2017 on the draft site selection criteria. These criteria will be used to test all the proposed sites nominated previously through community engagement for the sites shown on this plan. Please take the time to read these criteria and send any comments to the Parish Clerk by 22nd December 2017.
You can view and download a copy of the criteria here.
Comments can be made either via email at firstname.lastname@example.org, or by making comments on this page (at the bottom). You can also comment by post by writing to the Clerk at 5 Meadow Road Brown Edge ST6 8SQ
What Happens Next?
After the consultation period has ended the comments checked to see if the documents require updating and the revised criteria will be prepared and we shall be undertaking site visits to test the sites. If you are interested in volunteering to help the Parish Council Neighbourhood Plan committee to test these sites please contact the Parish Clerk to register an interest and we shall send further details shortly. Once the sites have been visited, we shall publish the scoring which will inform which sites the Neighbourhood Plan will potentially be included for future housing development (if required) or if they are in the Green Belt, which sites the Parish Council will encourage Staffordshire Moorlands District Council to include in the emerging Local Plan.
5 HISTORIC COMMENTS
- Ken Turner / December 23, 2017 11:58 am / ReplyA further comment on my views on the method of ranking the various sites’ assessments using the ‘Proposed Site Selection Criteria’ I posted on this site yesterday (22nd Dec 2017) to the effect that any ‘scoring system needed to be be robust and published at the outset of the process. Here are some further thoughts:For each of the sites the process of assessment using the three colour system proposed applied to the fourteen ‘Criteria’ can statistically result in 364 colour combinations for each site! Of these results only three can be evaluated with certainty i.e. 3 greens,3 reds or 3 yellows. How is it proposed to evaluate the other 361 colour combinations without using figures? And if you’re having to resort to figures anyway why not start using them from the beginning and forget the colours? Having evaluated each site using figures it is possible that the values of many of the sites being assessed could ‘cluster’ very closely around (or even yield the same) value. To lessen the chance of this happening a figure based system could be refined by incorporating a ‘weighting’ system in the ‘Appropriateness for Development’ columns by using a range of values in what would have been the Green, Amber or Red columns thus indicating the perceived importance of that particular factor at that particular site. As emphasised in my previous submission any system of evaluation needs to be set out and clear to prior to implementation avoid later challenge.
- Jim Clowes / December 23, 2017 8:40 am / ReplyDear Sir
Further to your notice of consultation in regard to the site selection criteria I would make the following points.
A. The need to consult locals and the stake holders appears to be a little rushed with little visible notice of such requirements. The notice only appears in the Site Selection Criteria under the consultation tab within the BE Neighbourhood Plan Portal and is only limited to 2 weeks which is very tight for such a process. I could find no mention of or clear indications on the Parish Site or the opening page of the NP.brownedge.com site and would question if this could be challenged in terms of a true consultation process.In regard to the Criteria questions I would make the following observations
1) There are no reference number so any comments could be misread if not fully explained.
Access to the Highway Network (Select Green if the site is accessed onto the Main B5051 single carriageway with well lit, main highway lighting, Amber if it is accessed from a single carriageway with minimal street lighting or lane with designated passing places in the highway and Red if it is accessed by a lane).
Please see the attached highways plan for guidanceComment
What is the aim of this question as it appears to make no sense in terms of Highways. As there is only one site (20) which sits directly onto the B5051 then the framing of the question could be considered to be biased and would leave the assessor only obvious conclusions.The reference to the Highways plan in support of this question is also a little confusing as the B5051 is identified as having high quality lighting. To my understanding there is no such term in this regard and is again a misleading document.What is important in terms of Highways Access for any site selection which I assume is the aim of this question is related to road widths, speeds and lighting and ease of accessing the main Highway routes. Clearly from the site selection plan there are at least 5 sites which would be considered to have reasonable access onto the B5051 while the other site further to the north would be considered to be not as favourable in these terms.I believe that this question needs to be reconsidered or evaluation further as in it’s current format there is a high degree of challenge.3) Q2
Access to the Bus Service (Select Green if a bus stop is less than 50 meters, Amber if a bus stop is more than 50 meters but still in walking distance (suggest less than 500 mtrs), and Red if it is not within easy walking distance.
Please see the attached highways plan for guidanceComment
Again, this question makes little sense in its formation. Where has the 50m distance been generated from? In terms of transport Bus routes and stops should form a key element of a walkable neighbourhood. The County Council’s Passenger Transport Section can provide guidance on the need for bus stops and shelters. Where these are required they should generally be located at intervals of about 300-500 metres to satisfy local demand.The 50m distance is an unrealistic level and only favours on one the sites under consideration and would leave the assessors with little options. I have attached a PDF which indicates the 50 m radius, a 200m radius and a 300m radius which should help to indicate the issues.I believe that this question needs to be reconsidered or evaluation further as in it’s current format there is a high degree of challenge.4) Q3
Visibility to Join Highway Network: (Select Green if the existing access includes clear visibility splays onto the highway, Amber if it has partially clear visibility and could be improved, Red if it has limited visibility and could be improved)The term ‘visibility’ is used in the context of: “Visibility splays shall be provided to enable emerging drivers using the direct access to have adequate visibility in each direction to see oncoming traffic in sufficient time to make their manoeuvre safely without influencing the major road traffic speed.” Para 2.17, Chapter 2, Vehicular Access to All-Purpose Trunk Roads, Volume 6 Section 2 Part 7 Standard TD 41/95, March 1995Please see the attached highways plan for guidanceComment
As most of the site have yet to be put forward for development at which point specific junction details will need to be approved by the highways is it possible to answer such a question.If it is answered there will be a high level of subjective assessment in its conclusion. The only support to the assessor is the Highway Plan which is given as guidance – in what way does this guidance exist in regard to this question which relates to visibility.Such questions are subject to specialist knowledge of highway design and it is my opinion that should this element be a requirement then the Parish should seek professional advise in this respect. Clearly the same issues were identified by SMDC in their earlier assessment and these can be seen in their own supporting evidence.As a minimum, I would suggest that a technical summary document be sort from SMDC as a form assistance in this area which should provide a quick visual aid although unless you know where an access point is little can be achieved.I believe that this question needs to be reconsidered or evaluation further as in it’s current format there is a high degree of potential challenge from technically qualified engineering quarters.5) Q4
Does not increase pressure on the safety critical areas marked on the Highways planSelect Red if there if the development directly increases the pressure on the safety critical areas amber if incidental increased pressure and Green if little impactPlease see the attached highways plan for guidance of locations of safety critical areasComment
The Highways plan appease to be a marked-up plan. Where is the evidence for this? Such information can be obtained officially from Staffordshire County Council who have all the necessary data both in table and visual formats.You appear to have designated safety critical areas on the plan which from my inspection of the real data is unfounded. For example the data reports that there were 3 minor accidents within Willfield lane between 2007 and 2015 compared with 9 minor accidents on High Lane between 2005 and 2013While I don’t doubt that additional care is required within the areas indicated red is it reasonable and fair to miss represent the recorded facts.In terms of increased pressure how can this be defined. Do you know the capacity of the road network? Again a very subjective question which could lead to challenges if not considered correctly.6) Q5
Does not compromise the degree of separation between Brown Edge and neighbouring settlements. For clarification this means that the proposed site would not adjoin neighbouring settlements or parish boundariesComment
The assessment of this question could again be very subjective. Clearly this is of interest to all and it is important to develop a supported conclusion. The clarification point however adds a level of confusion as it is none specific.I have attached a plan which provides measured distances from key points within the village towards the adjoining settlements. Clearly if something like this was used in support then a reasonable and logical conclusion should be achieved.I would suggest that in order to avoid future questions you consider the clarification part of this question.In addition there is no evaluation score process in place – is this a mistake?7) Q6
Integrates with existing settlement and does not create sprawl into the open countryside without defensible boundaries (such as walls, watercourses and roads; this could include sites on the edge of the settlement that include defensible boundaries).Particular care should be applied to any sites on the southern side of the village boundary to maintain a degree of separation between the conurbation of Stoke On Trent and the rural village of Brown EdgeComment
The first part of the question is fair and reasonable although its needs a couple of reads to fully get the objective.I believe you mean that the potential site should where possible be within the main hub of the village and not detached or out on a limb. You may want to consider using village rounding as a description which at least 3 sites provide.In regard to the second part I am confused why the southern side boundary has been identified. Clearly again this only leads the assessor to focus on one or two sites (34 & 35) when considering this question. The simple facts are that either of these site have no more detrimental impact on the area than other sites under consideration if due diligence is given to the plan I have attached.I would suggest that in order to avoid future questions you consider the clarification part of this question and the assessment criteria being sort which appears to be missing – is this correct?.8) Q7
In the Green Belt (Select Red if it is in the Green Belt, and needs to be included in the Local Plan and Green if it is not in the Green Belt and could be included as a site allocation in the Neighbourhood Plan).Comment
None – a black and white question.
However reference should be made to the SMDC evidence :- https://www.staffsmoorlands.gov.uk/media/1885/Appendix-C—Brown-Edge-to-Cheadle/pdf/APPENDIX_C_PART_2.pdf9) Q8
Would not harm the character of the area, by diminishing the open appearance of the settlement, and does not dominate the skyline. The development must respect the natural topography and visual intrusion.Comment
Another subjective question. I believe you have a couple of threads here which should be separated possibly in order to make the assessment easierFirstly, would the site impact on the open nature of the village? Eg by infilling this site will the existing surrounding become more closed or joined together.Secondly would the site directly expand the village? Eg are there existing building on 3 sides, 2 sides or 1 side. If only one side this considered as an expansion.Thirdly, will the site have any landscape visual impacts? Eg is the site higher that surrounding areas. (Note – in general terms this is not a local impact as such and should be viewed at distance.)By separating the issues as above the assessment becomes simpler as cross conflicts are removed.10) Q9
Does not result in the loss of open space in village or an existing or proposed Local Green Space. Open Space and proposed and existing Local Green Spaces are shown on map Red if it does and green if it doesn’t Please see the environmental map for guidanceComment
I believe that this could be addressed by the first part of my comments in Q8.11) Q10
Is of ecological value
Green if Low, Amber if of value, Red of significant value
(use ecological study to asses)Comment
I am not aware of any walk over surveys undertaken in the first place which will be required for any development process.I note that there are 5 categories in regard to Ecological importance against the level 3 criteria identified. You may wish to clarify how these are to be assessed.12) Q11
Is of low agricultural value (select Green if it is Grade 5, Amber if it is Grade 4 and Red if it is Grade 3a or 3b or above)
Please see the environmental map for guidanceComment
I can find no agricultural value within the report issued. Without this how are the sites to be assessed?13) Q12
The site includes mature trees or hedgerows (select Green if they are on the boundary or close to edges and would not compromise the development of the site, Amber if they are of high quality or value and could be incorporated easily into a development, and Red if they are of high quality and may affect the development potential.)Comment
Subjective in part as a developer would need to have input into this. I would suggest that on completion of this question reference should be made back to the landowner to qualify the conclusions.14) Q13
This site is known to flood locally or contains marshy areas (mark red) the site has no impact on flooding (amber). Development of the site will alleviate existing flooding of homes. (Green) Please see the environmental map for guidanceComment
Is the land currently available for development within the lifetime of the plan?
(Green is yes and Red is no.)Comment
Jim ClowesAttachments 2No. sent as a email attachment to the Clerk
- Ken Turner / December 22, 2017 9:05 pm / ReplyWhat is the point of using colours to indicate degree of “Appropriateness for Development” when these will have to be converted to figures to enable evaluations relating to the various sites to be understandable. This should be done as the early as possible in the assessment process or it could lead to allegations that these could have been adjusted ‘after the event’ to favour certain sites (by Mr X’s high priced legal team!) There needs to be a clear and obvious ‘audit’ trail to avoid this and therefore the values should be allocated to each of the Green, Amber and Red’ designations as the forms are completed ‘on site’.
- David McGrath / December 21, 2017 11:05 pm / ReplyWith regards to the Highways Plan I have to ask what is the evidence base for the Safety Critical Areas and what does this classification actually mean. Most people would assume as it is a Highways Plan it is Traffic/Pedestrians and Accidents. If you look at http://www.crashmap.co.uk you will find evidence of where all recorded accidents have occurred in our Village which supports most of the locations marked and some that are not and some that are ie Sandy Lane/Coppice Farm.
With regards to the Bus Stops marked I believe it is general knowledge D&G intend removing the service in 2018 along Sytch Road and Church road and the stop marked by the Church has not been in operation for at least 12 months.
I will make no comment with regards to the Environmental Plan only to say I gave up attempting to look at it.
- David McGrath / December 18, 2017 11:18 pm / ReplyBefore I pass my comments on the Commercial Zone, Green Space or Site Allocations I feel I must cover consultation which it would appear is either being given as they say “Lip service”. Consultation with regards to a Neighbourhood Plan is a ongoing process not just when it is felt we should involve the community as in this instance. It is a shame as I can see some people are working very hard to produce this plan. It is obvious this first direct consultation with the Community is being rushed through. The Village has numerous sites to ensure maximum public exposure for this and as of 10 days into the very short 14 day period coverage is via this website and Brown Edge Parish News. We have a Facebook Page, Parish Council Website, Notice Boards, this is simple basics. I am sorry but due to this rushed not thought through process the majority that are being consulted on this subject are just the Landowners concerned. I attended the last meeting of the NP and it was of interest that it was disclosed no minutes are taken or circulated, that forms part of the ongoing consultation keeping the people aware of what is happening.