Comment

Representation ID: 4885

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Land east of Dunsley Drive (Omitted site)

Land east of Dunsley Drive was initially included proposed to be removed from the Green Belt and allocated for development up to an including the Preferred Options stage of the Local Plan Review, as housing site allocation 272 (Figure 2).
The allocation was for a minimum of 22 dwellings on a site featuring good access and a natural extension to Kinver. The 2021 Housing Site Selection Topic Paper stated that, unlike some of the other potential Green Belt sites around Kinver, the Dunsley Drive site is free from ’significant constraints’ (e.g. Highways Authority concerns, potentially significant impact upon the historic environment). Paragraph 5.7.8 noted that the site is of a similar landscape sensitivity to most other land around the village but is of lesser Green Belt harm than other sites in this area.
The HESA states that development on the site would not in itself compromise the cultural heritage value of the overall Conservation Area to the extent that the values
that led to its designation would be diminished. The Assessment contends however, that it would inevitably compromise the setting of the small character zone within the Conservation Area that is defined by Dunsley House and its hilltop position, as well asthe setting of the non-designated asset itself. The HESA states that mitigation is unlikely to be possible and therefore a high (red) impact is predicted.
The site does adjoin the Conservation Area in the far east (where it extends to include Dunsley House – a ‘positive’ building within the Conservation Area). The site does form part of Dunsley House’s setting, however in the context of the Conservation Area as a whole, its contribution to Dunsley House’s significance (the Conservation Area’s special interest) is likely to be very small and so the ‘harm’ arising from its development would also be ‘very small’. In terms of the NPPF this harm would, at worst, be less than substantial harm towards the lowest end of that broad spectrum.
The evidence base enclosed with these representations also demonstrates the site is not subject to any constraints which cannot be overcome. As such the evidence base does not justify the omission of land east of Dunsley Drive as a proposed allocation.
Policy SA5 should therefore be modified to reduce the capacity of land south of White Hill or delete it completely, to reflect its constraints (in particular heritage) and the additional land north of the proposed Hyde Lane allocation and / or the omitted Dunsley Drive site should be added into the policy for a minimum capacity of around 40 homes each.