|
Person ID |
Respondent |
Response Ref: |
Support/ Object/ Comment |
Main Mod Reference |
Legally compliant? |
Sound? |
Positively prepared? |
Response |
|---|---|---|---|---|---|---|---|---|
|
1303054 |
Gladman Developments Limited |
LPMM3318 |
Support |
MM3.2 |
|
|
|
Gladman support the spatial strategy for focusing growth in the main towns of Kidderminster, Stourport-on-Severn and Bewdley. The three main towns are the most sustainable locations for housing growth across the district. However, growth should not be precluded from the sustainable villages where there is an identified housing need, and consideration should be given to this. |
|
1301097 |
Mrs |
LPMM3630 |
Object |
MM3.3 |
No |
No |
No |
Building on the field at Low Habberley will not maintain the integrity of the Green Belt. Habberley Road is an ideal buffer between the built up area and the present Green Belt land near to Habberley Valley - a local nature reserve. |
|
231577 |
Persimmon Homes Limited |
LPMM3104 |
Support |
MM3.3 |
Yes |
Yes |
Yes |
We support the removal of the word ‘limited’ and also, support the alteration of the wording to “identify a necessary and justified level of strategic Green Belt release to enable delivery of the plan”. We agree that this modification will help ensure that the level of development that is required within the District over the whole plan period can be achieved. In respect of this point, RPS draw reference to our submissions in relation to the proposals map for Catchems End (PM34) and the necessary change needed there to ensure the delivery of the allocation. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3341 |
Object |
MM3.3 |
No |
No |
No |
The proposed revision of strategic green belt release from ‘limited’ to ‘necessary and justified’ is in principle to be welcomed (the restriction to a ‘limited’ release being inherently problematic) however the justification for this change is to ensure that the Plan is effective and positively prepared; to ensure that the level of development required over the Plan period can be achieved. The extent of green belt land to be released however still does not appear sufficient to enable an appropriate level of affordable housing provision to be made (as against the identified need for the same), does not appear to give any material flexibility within the Plan to enable appropriate reaction to changes occurring within the Plan period, nor to enable delivery of planned and necessary infrastructure. Moreover by adhering to a release of land which is ‘necessary’ for the draft Plan period only, the LPA appear to be committing to rounds of green belt boundary review alongside each Local Plan review process, contrary to NPPF 140, which provides that changes to green belt boundaries should have regard to their intended long term permanence and endure beyond the Plan period, in combination with the requirement at NPPF 143(e) that green belt boundaries should not need to be altered at the end of the Plan period. If the focus of green belt release in the draft Plan is solely that needed to meet the emerging Plan requirements, then future planned development needs will necessitate further green belt releases. Instead it would be appropriate, both for effective and positive preparation of the emerging Local Plan and to ensure that green belt boundary review is not an ongoing iterative process running alongside Plan preparation on each occasion, to seek to secure sufficient land release to meet anticipated future needs beyond the Plan period. Such land can (and should) be identified and appropriately safeguarded (see NPPF 143(c) and (d)). The proposed MM, and the draft Plan, does not appear to plan positively in this regard with the resultant effect being a continually reactive reassessment of green belt boundaries in future plan processes. |
|
1303054 |
Gladman Developments Limited |
LPMM3321 |
Support |
MM3.3 |
|
|
|
Green Belt release is supported where it is necessary and justified to support development in Kidderminster. However, in locations where there are development options outside of the Green Belt, these should be considered before releasing additional land from the Green Belt. |
|
1110090 |
Mr. |
LPMM5 |
Support |
MM6.1 |
Yes |
Yes |
Yes |
I believe that the main modifications are acceptable as the amendments generally reinforce the effectiveness of the document. |
|
231577 |
Persimmon Homes Limited |
LPMM3109 |
Support |
MM6.1 |
Yes |
Yes |
Yes |
We support the updating of Policy 6A to include the spatial distribution and quantity of development in the District. In addition, we support the clear inclusion of 227 net additional dwellings at Bewdley and the clear specification that the expected growth delivery is a minimum requirement. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3348 |
Object |
MM6.1 |
No |
No |
No |
The proposed modification at 6.1 adds text at “C” and adds table 6.0.2, seeking to direct growth towards ‘the most sustainable, larger settlements and towards the new village at Lea Castle’. This inherently identifies the new village at Lea Castle as being distinct from (and additional to) ‘the most sustainable, larger settlements’ of the District (the proposed modified text states that growth is directed to the most sustainable larger settlements, and also to Lea Castle). It is unclear how the proposed modification represents an appropriate strategy, given the Local Plan’s identification of Lea Castle as distinct from (and additional to) the ‘most sustainable, larger settlements’. The submissions previously made on behalf of Barberry have clearly identified a reasonable alternative, namely land to the rear of Baldwin Road, which, being adjacent to the eastern urban extension exhibits similar sustainability benefits as Lea Castle but benefits from being within walking distance of local schools (cf. Lea Castle). |
|
1137373 |
Mrs |
LPMM10 |
Object |
MM6.1 |
No |
No |
No |
MM6.1 is not sound or legally compliant in regard to Field at Habberley Road REF WA/KF3 Primarily this area is GREEN BELT Negative for Local services and facilities Negative Need to travel, poor Public Transport Negative for Soil and Land Negative for Water Resources and Quality and Flood Risk Negative for Landscape and Townscape Negative for Green Belt DOUBLE Negative for Biodiversity and Geodiversity I endorse these objections above provided by the local people’s group who have done extensive research into this proposed development. |
|
1301097 |
Mrs Kathleen Hill |
LPMM3634 |
Object |
MM6.2 (Page 34) |
|
|
|
a. "The right amount of land and type of employment uses at readily accessible locations..." The land at Low Habberley is currently farmland producing food. How can this be the right kind of land with readily available employment? b."...enables labour force to live locally." See a above - jobs? Public transport in this area is a 'joke'. d. "infrastructure that supports communities which are housing the labour force and facilitates the movement of people to their employment...and supporting free infrastructure." - See a and b above. Developing the land at Low Habberley will increase pressure on the already overburdened medical facilities and the road infrastructure that is clogged with traffic already and peak times and heavy most of the time. Crossing the road to that field now is fraught with danger and often dependent on the kindness of drivers to stop and hold up a line of traffic to enable pedestrians to cross. |
|
1301097 |
Mrs Kathleen Hill |
LPMM3653 |
Object |
MM6.7 |
|
|
|
Policy 6B - Locating New Development (page 38) iii. "Encourage the effective use of and re-use of accessible, available brownfield land" Land at Low Habberley is Green Belt A. (iv) "...enhance the open countryside." Not by building on this Green Belt land!! A. (v) "Maintain the openness of the Green Belt." Not by building on it! A. (vi) "Focus most development in and adjacent to the urban areas...effective public service provision..." The field at Low Habberley is completely separated from the present urban area by a road. Building on it will overstep that barrier and provide further opportunities to infill the rest of the Green Belt land between it and the hamlet of Low Habberley. This in turn will put great pressure on Habberley Valley Nature Reserve with all the attendant effects on the local wildlife. A. (vii) "Protect from development areas that are sensitive because of their landscape, heritage assets or biodiversity" An excellent modification. Now please show that you mean it by removing the Green Belt field at Low Habberley from your plan to build houses on it. D. "Development of land beyond settlement boundaries will be strictly controlled and will be limited to dwellings for rural workers, replacement dwellings and rural exception sites (Policy 8C); employment development in rural areas and buildings for agriculture and forestry (Policy 21B) and renewable energy projects (Policy 24B) and development specifically permitted by other Wyre Forest Local Plan policies" Yes. Prove that you mean this and remove the land at Low Habberley from building plans. |
|
260520 |
Campaign to Protect Rural England |
LPMM283 |
|
MM6.7 |
|
|
|
MM6.7: Policy 6B.D – We welcome the change, but we would ask for further clarification of what “beyond settlement boundaries” means. This is less of an issue where such land is Green Belt, where such applications are refused as a matter of course. However west of the Severn, there have been a series of recent applications relating to land adjoining but outside a village envelope boundary. It may be that this is covered in the glossary by a definition of settlement boundary. This is important because NPPF encourages infill in villages: it needs to be made clear that such infill is only permissible within the village envelope, as defined in the Plan. |
|
1298978 |
Mrs |
LPMM203 |
Object |
MM6.7 |
No |
No |
No |
This area of land is green belt. The findings of every assessment do not support the release of this land from The Green belt. This area of land provides the area with a significant area of contribution as Green belt land. There are significant negative impacts to building on this land access was deemed “poor” public transport links and local facilities are insufficient to support building on this land. There is no reasonable justification for building on this land I believe full consideration has not been given to local nature reserves and woods and the impact building on this land would have. The land is also not adjoining a built up area as stated in the sustainability report this statement is legally incorrect |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1975 |
Support |
MM6.7 |
Yes |
Yes |
Yes |
We welcome and support the new Principle 7 set out in Policy 6B and in particular the weight it gives to protection of biodiversity. We consider that this brings clarity to expectations in this area and that the principle reflects the requirements of national policy. |
|
1300044 |
Mr |
LPMM577 |
Object |
MM6.7 |
No |
No |
No |
This is a very sensitive area that supports a wide range of biodiversity as has been found during site assessments that have been carried out on behalf of WFDC. The significant upheaval of major development and associated degradation of the environment would destroy existing habitat and have a tremendous negative impact on the surrounding area. |
|
1303054 |
Gladman Developments Limited |
LPMM3323 |
Object |
MM6.7 |
|
|
|
In point ‘D’ of this MM which identifies acceptable development outside of the settlement boundaries. Entry Level housing should be considered appropriate as stated in Policy 8B alongside Rural Exception Sites. In addition to Rural Exception Sites, development outside of settlement boundaries should be considered if the Council is in a position where it cannot meet its housing needs. |
|
1301097 |
Mrs Kathleen Hill |
LPMM3696 |
|
MM6.8 |
|
|
|
"Locally, the Green Belt continues to serve all the purposes of national policy and the boundaries are considered to be strong and enduring. However, due to the exceptional circumstances of an increased housing demand coupled with a reduced amount of brownfield land..." There are many brownfield sites that are privately owned. The Council should find ways of persuading private owners to release this land for building the housing it needs. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3366 |
Object |
MM6.9 |
No |
No |
No |
The proposed modification at 6.9 is to accommodate the latest iteration of the Framework, however the same point as above applies, namely that unless a green belt review encompassing development needs beyond the draft Plan period is considered, the consequence is to leave review of green belt boundaries in lock-step with future emerging plans |
|
231577 |
Persimmon Homes Limited |
LPMM3116 |
Support |
MM6.11 |
Yes |
Yes |
Yes |
Our comments relate specifically to Policy 6E and the role of Bewdley as a Market Town. We support the proposed wording in relation to Bewdley and agree that the development of the allocated sites with additional housing will promote the vitality and viability of the market town. We agree the modification supports a sustainable pattern of development. |
|
1225187 |
Mrs |
LPMM2153 |
Object |
MM7.1 |
No |
No |
No |
MM7.1 • WFDC have not provided full and adequate evidence to justify the removal of the Green Belt land in Blakedown (WFR/CB/3); • WFDC are relying on an exemption to release land from Green Belt for ‘affordable housing’ and the draft policy states that ‘…any new housing should be provided… to meet any local housing need as shown in a Parish Needs Survey and/or the Housing Register…’. WFDC have not provided any evidence to support such a need in Blakedown and indeed the neighbourhood plan for the local parish, prepared by Churchill & Blakedown Parish Council, in collaboration with and supported by WFDC, does not identify such a need; • If WFDC can evidence such a need and that is then the exemption relied on to release the land from the Green Belt then surely the Local Plan should specify that the land can only be developed for the purpose of providing affordable housing? As it stands currently, the modifications to the plan do not make that stipulation; the draft Local Plan wording remains vague leaving that land exposed to any kind of development; and • In addition, if the land is to be released on the basis of the exemption for affordable housing then surely any reference to its use for car parking as part of WFDC’s ambition to create a transport hub should be removed? |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM3938 |
Object |
MM7.1 |
|
|
|
NPPF 2021 para 140 provides that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 141 provides that “authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development” “makes as much use as possible of suitable brownfield sites and underutilised land” It is not clear that WFDC has fully evidenced or justified the removal of Green Belt land in Blakedown (WFR/CB/3 NPPF paragraph 147 retains the “Very Special Circumstances” test of whether inappropriate development causing harm to Green Belt is outweighed by other considerations. The Local Plan amendments are based on the exemption that “affordable housing” on Green Belt land is given in the NPPF, but the Draft Plan is confused between serving “District wide” or “Local Housing Needs” Policy WFR/CB/3 (9) states the new housing should be provided …. to meet any local housing need as shown in a Parish Needs Survey and/or the Housing Register. WFDC has put forward no evidence in support of this and this Policy is in conflict with others in the Plan NPPF paragraph 150 C provides that local transport infrastructure which can demonstrate a requirement for a Green Belt location may not be inappropriate development But The Local Plan does not adequately consider the potential for expansion of Kidderminster Station Car park or of neighbouring authorities allocating more suitable sites for a “transport hub” before seeking to remove WFR/CB/3 from Green Belt |
|
260520 |
Campaign to Protect Rural England |
LPMM284 |
Object |
MM7.2 |
|
|
|
MM7.2: This change is unacceptable. The land at Station Road, Blakedown was primarily intended for additional station car parking, which was to be funded by allowing some housing. At the Examination it was established that the requisite parking could be adequately provided at Kidderminster Station and on other land at Blakedown (probably former sidings). Accordingly, there is no purpose in removing site WFR/CB/3 from the Green Belt. Under NPPF, “exceptional circumstances” have to be established for removing land from the Green Belt; and none have been shown. Even if part or all of WFR/CB/3 is required for additional railhead car parking (contrary to the case made at the Examination), this could be done by a planning consent applicant establishing that there were “very special circumstances” for allowing such a car park, something that would not (or hardly) adversely affect the openness of the Green Belt. The very special circumstance would be that the site adjoins the station and is the only piece of open land to do so available anywhere along the Kidderminster-Stourbridge-Birmingham line. |
|
1227041 |
Sue |
LPMM575 |
Object |
MM7.2 |
No |
No |
No |
Section MM7.2 refers to the removal of Green Belt status from areas around Kidderminster and Stourport as part of the review carried out prior to the development of the Draft Plan. The modification specifically adds Blakedown to justify the inclusion of the Land off Station Drive (WFR/CB/3) in the list of sites to be removed from Green Belt in the Pre-Submission Amendments of July 2019 without fulfilling the statutory requirements for consultation. The NPPF stipulates that any Green Belt review should "demonstrate it has examined fully all other reasonable options", "promote sustainable patterns of development" and "set out ways in which the impact of removing land from Green Belt can be offset through compensatory improvement to the environmental quality and accessibility of remaining Green Belt land" - none of which have been evidenced. Further the NPPF reiterates that the "very special circumstances" required for removal of Green Belt status "will not exist unless the potential harm to the Green Belt by reason of inappropriateness and any other harm resulting from the proposal is clearly outweighed by other considerations". The "considerations" relating to this piece of Green Belt have fluctuated: at the first stage of the Local Plan Review right up to the Pre-Submission Plan, the Green Belt status was not in question (the site having been identified as unsustainable at the 2006 Inspector's Report). At Amendment to the Pre-Submission Plan, the site was required for a car park, together with housing which would subsidise the car park development. Subsequently the requirement for the car park has disappeared, but the housing (which was originally an afterthought) has remained, although at no point has evidence been produced to show that such a high level of housing provision is or will be necessary to meet local housing needs for social, affordable or private market local housing needs This meandering path to the removal of Green Belt status fails to meet the "very special circumstances" of the NPPF, and is therefore neither justifiable, legal or sound. The land should not be removed from Green Belt at this point, but subject to detailed consideration in the event that the NPPF's "very special circumstance" requirement comes to pass. |
|
1225187 |
Mrs |
LPMM2161 |
Object |
MM7.2 |
No |
No |
No |
MM7.2 The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road. The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. The draft Local Plan utterly fails to respect the contribution made by this site and appears to be going ahead with its removal from Green Belt in advance of the review of the Green Belt boundary within the District having been undertaken or WFDC having presented evidence to demonstrate that such a review has been completed to an adequate standard. |
|
231577 |
Persimmon Homes Limited |
LPMM3122 |
Support |
MM7.2 |
Yes |
Yes |
Yes |
We support the retention of wording that specifies changes to the Green Belt boundary will be made at locations around Bewdley. |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM3939 |
Support |
MM7.2 |
|
|
|
As above. And as stated in ED20B – Technical Note 2 – Summary of Site Assessments: The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road. The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. The Local Plan does not respect the contribution made by this site ED20 – Green Belt Topic Paper paragraph 8.29 refers to “an identified local housing need” yet Policy 36.6A of the Submission Plan states “Housing to be provided in accordance with policies elsewhere in Local Plan and also to meet any local housing need shown in a Parish Housing Needs Survey” Clarity is needed what housing need this site is to satisfy – Local or District need? There is also no specific requirement for affordable housing over and above the policies elsewhere in the Submission Plan 36.6A again states “Housing development on the site would help to cover the costs of the car parking and would also help towards meeting the future housing needs in Blakedown village”. In order to cover the costs of the car park we suggest that a future developer’s viability assessment would negate or significantly limit the provision of affordable housing. If so this would be contrary to NPPF 149 (f) as the site is being released from Green Belt yet does not satisfy the exceptions in the NPPF. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3370 |
Object |
MM7.2 |
No |
No |
No |
The proposed modification at 7.2 is to clarify the exception of Blakedown from the green belt “…to enable the development needs for the District to be met most sustainable [sic] and economically” but does not do anything to meet the submissions made on behalf of Barberry that the Plan does not meet the District’s needs sustainably and economically given that it overlooks and omits the land to the rear of Baldwin Road which can not only meet but exceed the Plan’s (uninspiring) affordable housing policy requirements (which Lea Castle – and other allocations – cannot). It is more sustainably located than Lea Castle, which by the LPA’s own admission is not itself considered a sustainable location without the additional c.800 there proposed (and we query, in accordance with previous submissions, whether Lea Castle achieves sustainability as a location even following the additional 800 units (footnote 1)). 1 See further the RCA hearing submission (Matter 3) Appendix 2 : Lavigne Lonsdale report (November 2020) |
|
1225187 |
Mrs |
LPMM2162 |
Object |
MM7.3 |
No |
No |
No |
MM7.3 My objections to MM7.3 include all of the above and additionally as the NPPF states that ‘the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence’ I would reiterate my point that the draft Local Plan utterly fails to respect the part this site plays in preventing urban sprawl towards Hagley. |
|
1301097 |
Mrs Kathleen Hill |
LPMM3705 |
Object |
MM7.3 |
No |
No |
No |
"The important role of the Green Belt is fully recognised. The NPPF (para 133 137) states that “the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”" Building on the field at Low Habberley will increase urban sprawl and result in providing the way open for further development between it and the hamlet of Low Habberley. |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM3940 |
Support |
MM7.3 |
|
|
|
As above. And as stated in ED20B – Technical Note 2 – Summary of Site Assessments: The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road. The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. The Local Plan does not respect the contribution made by this site ED20 – Green Belt Topic Paper paragraph 8.29 refers to “an identified local housing need” yet Policy 36.6A of the Submission Plan states “Housing to be provided in accordance with policies elsewhere in Local Plan and also to meet any local housing need shown in a Parish Housing Needs Survey” Clarity is needed what housing need this site is to satisfy – Local or District need? There is also no specific requirement for affordable housing over and above the policies elsewhere in the Submission Plan 36.6A again states “Housing development on the site would help to cover the costs of the car parking and would also help towards meeting the future housing needs in Blakedown village”. In order to cover the costs of the car park we suggest that a future developer’s viability assessment would negate or significantly limit the provision of affordable housing. If so this would be contrary to NPPF 149 (f) as the site is being released from Green Belt yet does not satisfy the exceptions in the NPPF. |
|
1301097 |
Mrs |
LPMM3710 |
Object |
MM7.4 |
No |
No |
No |
“Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced..." I do not believe the circumstances are exceptional enough to warrant this incursion onto Green Belt land where this is creating an entirely new development - not an extension of one already established. (Low Habberley) |
|
1225187 |
Mrs |
LPMM2437 |
Object |
MM7.4 |
No |
No |
No |
MM7.4 Per my points above, I do not believe that any exceptional circumstances have been identified by WFDC to warrant the removal of this site from Green Belt. How could WFDC provide evidence of the need to remove the land from Green Belt when they changed their minds 3 times as to what the land would be used for and why? That kind of flip flopping does not instil confidence in the draft Local Plan or WFDC. |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM3941 |
Object |
MM7.4 |
|
|
|
Exceptional circumstances have not been fully evidenced and justified |
|
1225187 |
Mrs |
LPMM2446 |
Object |
MM7.5 |
No |
No |
No |
MM7.5 My concern here is that the removal of land from the Green Belt in Blakedown (WFR/CB/3) appears to be going ahead without a full review of the Green Belt boundary within the District having been undertaken or WFDC having presented evidence to demonstrate that such a review has been completed to an adequate standard. |
|
1225187 |
Mrs |
LPMM2449 |
Object |
MM7.6 |
No |
No |
No |
MM7.6 Per my point above, no evidence of local housing need has been provided to justify Policy WFR/CB/3. The Local Plan confuses District Wide and parish/village specific future housing requirements and indeed the neighbourhood plan for the local parish, prepared by Churchill & Blakedown Parish Council, in collaboration with and supported by WFDC, does not identify such a need. Finally, I can see no evidence whatsoever that WFDC have considered the joint impact of releasing this piece of land in Blakedown (WFR/CB/3) from Green Belt for affordable housing development in addition to the proposal to develop the land at Station Yard for additional parking. The cumulative effect on road traffic up to a potential of 600 additional vehicle movements on small village roads per day assuming: • 174 vehicle movements if all proposed spaces at Station Yard are utilised; would completely overload the A456/Station Drive/Lynwood Drive junctions, particularly when you consider the proximity to the level crossing. It will have a serious negative impact on a village road network not suitable to such a volume of additional vehicle movements; and significantly increase risks for both road traffic and pedestrian safety (including significant numbers of school children travelling to and from the village primary school and using the station for travel to high school). Not to mention the detrimental effect on local residents living in the Station Drive/Lynwood Drive/Roxall Close/Mill Lane/Mill Close/Sculthorpe Road. I would also refer you to the recently refused change of use planning application 19/0380/FULL, which was rejected by WFDC on the grounds of dangerous vehicle movement on Lynwood Drive and Roxall Close considered not suitable for a solely residential area and that was on the basis of 10 to 20 additional vehicle movements a day nothing like the hundreds of additional vehicle movements proposed by these two elements of the draft Local Plan. (Further details below.) |
|
1125905 |
Barberry Hurcott Limited |
LPMM3393 |
Object |
MM7.6 |
No |
No |
No |
The reasoned justification to MMs 7.6 and 7.7 seeks to highlight the need for the LPA to release green belt land to secure a five-year supply of housing and/or employment land through the draft Plan period, noting that affordable housing is a matter to be given very substantial weight and refers to NPPF 149(f) in support of affordable housing being of sufficient weight to potentially constitute an exception to green belt policy, whilst reiterating the Framework’s urging that land for future development needs is identified and safeguarded when setting green belt boundaries (NPPF 143(c) and (d)). This does not however reflect the approach taken by the draft Plan. The proposed release of green belt land will not enable the LPA to meet its year-on-year affordable housing need (noting that the draft Plan already seeks to make a reduced level of provision of affordable housing at 90dpa) let alone do anything to make inroads into the District’s extant need for affordable housing; moreover the release of green belt land is proposed in relation to development which itself falls short of the proposed policy requirements for affordable housing provision. The draft Plan does not meet the evidenced needs and the reasoned justification given in the text (the subject of the MMs here) does not match that evidence nor will it match the practical consequences of the draft Plan and its policies. On the LPA’s reasoning as given in the MMs more green belt land should be released to secure even further provision of affordable housing. Perhaps fittingly although MM 7.6 cites NPPF 149(f) as support for the LPA’s proposed ‘wider’ green belt release, NPPF 149(f) is concerned with exceptions from inappropriate development in the form of limited affordable housing for local community needs (including rural exception sites). It is not a Framework policy which considers green belt boundary review scenarios. The draft Plan, despite citing NPPF 143, does not reflect the approach required therein (namely to identify and safeguard land such that it can be demonstrated that green belt boundaries will not need to be altered at the end of the Plan period). The draft Plan does not plan positively in this regard; it does not seek to secure release of green belt land which meets current needs |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM3942 |
Object |
MM7.6 |
|
|
|
No evidence of local housing need has been provided to justify Policy WFR/CB/3, and it appears the Plan is confused between District Wide and Local/village specific future housing requirements Using market housing to fund the development of a car park suggests affordable housing provision will be limited. Unless significant affordable housing is to be provided then the release of WFR/CB/3 from Green Belt should not be an exceptional circumstance under NPPF 149(f). |
|
260520 |
Churchill & Blakedown Parish Council |
LPMM285 |
|
MM8.1 |
|
|
|
MM8.1 Table 8.0.1 We would have welcomed a target for 3-bedroom houses and another for 4-bedroom and above. WFDC is a Housing Market Area on its own. It should therefore not be seeking to provide housing for people moving out of Birmingham (or other parts of the conurbation), but still working there. For one thing, this aggravates the amount of commuter traffic on A456 through Hagley. Such people are observed particularly to acquire the larger kinds of dwelling. Separate targets should provided for these two classes of house. Para 8.8 The amendment is poorly drafted. Substitute accessible and adaptable dwellings conforming to M4(2) of the Building Regulations 2010. |
|
260520 |
Campaign to Protect Rural England |
LPMM286 |
|
MM8.2 |
|
|
|
MM8.2 The limit should be 4 houses (not 5), as 25% of 4 = 1. This threshold appears not to be applicable to small urban sites, which seems to be an unintended lacuna. |
|
1299978 |
Mr |
LPMM561 |
Object |
MM8.2 |
|
|
|
Affordable Housing Led Schemes - the number of enabling dwellings set at normally not more than 20% may restrict the ability of Providers to be able to viably develop if strictly applied. Can it be considered to increase the percentage to 30% of overall number..? |
|
1299978 |
Mr |
LPMM560 |
Object |
MM8.2 |
|
|
|
Reference Tenure Split - I do not believe that the text should be changed to "primarily social rent". This is likely to cause some providers to struggle greatly to get development schemes to work in their business plans which are generally balanced with social rent and affordable rent. Forcing a majority of social rent on a scheme may result in the overall numbers of new homes that a Provider can build being reduced. Note that further in the document (8.16) it is simply stated that social rent included - not primarily. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3410 |
Object |
MM8.2 |
No |
No |
No |
The “minimum annual average target” of 90 affordable dwellings per annum and a policy requirement of a minimum of 25% affordable housing provision remains too low given the clearly evidenced, and increasing, shortfall in affordable housing provision in the District and evidenced worsening of affordability. Tetlow King’s analysis, submitted previously on behalf of Barberry, shows an existing shortfall of 919 dwellings against SHMA targets with the LPA achieving delivery of only 45% of its identified affordable housing needs (footnote 2). Once losses arising from Right to Buy are allowed for, that shortfall increases to 1,053 dwellings (footnote 3). Forward analysis of affordable housing delivery shows that only 64 affordable dwellings per annum will be delivered from major permissions in the first five years of the emerging plan period (footnote 4). The proposed MM at 8.2 fails to remedy the problems identified (and outlined above) and is not an appropriate strategy given the evidence of existing and increasing shortfall in affordable housing provision in the District, which by setting minimum policy requirements of 90dpa/25% and by seeking to deliver below that level on major permission sites within the first five years of the emerging plan period. As recommended by Tetlow King in their analysis consideration should be given to amending policy 8B to secure 30% affordable housing on small- and medium-sized greenfield sites3, as indicated in the Viability Assessment (IFT06) to maximise the ability of the Plan to secure affordable housing to meet the identified needs. Both of these changes are necessary to ensure the Plan is positively prepared, and effective (footnote 5). Additionally, given the shortfall of affordable housing secured on main sites such as Lea Castle Hospital and Churchfields Business Park, additional greenfield sites should be allocated to bolster affordable housing supply. This will ensure that the Council has a far better chance of meeting its affordable housing need, overcoming any shortfalls which arise on brownfield sites (footnote 6). Moreover the proposed MM at 8.2 appears incoherent. It is proposed to assert: “Where viability assessments show that the developer will be unable to meet all policy requirements on site, prioritisation of infrastructure requirements have been agreed so that the provision of affordable housing is not always reduced first from developers’ obligations” Support for this proposition is claimed to be found within PPG on viability. However we are unable to find support in PPG for the proposition that ‘where a developer is unable to meet all policy requirements, prioritising infrastructure means that provision of affordable housing is not always reduced first’. The lack of support in PPG for such a proposition is perhaps unsurprising given that it makes no sense. If the LPA wishes to pursue a policy whereby if contributions are reduced from policy-minimum levels because of viability concerns it prioritises infrastructure, then this necessarily entails affordable housing provision being reduced first. The LPA cannot prioritise infrastructure contributions in such circumstances whilst also purporting to prioritise affordable housing provision. It must prioritise one or the other; if infrastructure provision is prioritised (per the proposed MM 8.2) then it necessarily follows that affordable housing provision is lesser.
2 RCA hearing submissions (Matter 3) Appendix 1: Tetlow King Affordable Housing Report (November 2020) at Figure 4.2 and paragraph 4.4 3 Tetlow King (fn.1 above) at 4.9, noting that this data is incomplete as it is based on data from only two of five RPs 4 Tetlow King (fn.1 above) at 5.5 5 Tetlow King (fn.1 above) at 5.12 6 Tetlow King (fn.1 above) at 5.11 |
|
260520 |
Campaign to Protect Rural England |
LPMM287 |
|
MM8.4 |
|
|
|
MM8.4 The addition of the word “designated” is welcome, but we would welcome this becoming “within the boundaries of designated rural settlements”: see comments on MM6.7. MM6.7: Policy 6B.D – We welcome the change, but we would ask for further clarification of what “beyond settlement boundaries” means. This is less of an issue where such land is Green Belt, where such applications are refused as a matter of course. However west of the Severn, there have been a series of recent applications relating to land adjoining but outside a village envelope boundary. It may be that this is covered in the glossary by a definition of settlement boundary. This is important because NPPF encourages infill in villages: it needs to be made clear that such infill is only permissible within the village envelope, as defined in the Plan. |
|
231577 |
Persimmon Homes Limited |
LPMM3127 |
Object |
MM8.5 |
Yes |
No |
No |
RPS note that the threshold for considering self-build as part of major developments has increased from 10 dwellings to 50. Whilst this is considered to move in the right direction, there remains a question the justification underpinning the figure of 50 or more units in the modification: “Major development schemes of 50 or more units should take into consideration the demand shown in the Self Build and Custom Build Register and where possible provide suitable plots”. RPS believe the proposal would be better placed on larger schemes e.g. 100 dwellings or above where there is a stronger ability to provide choice and prevent delay on mid-sized schemes of 100 or less. Presently, the Council has not provided a justification why the threshold is most suited to 50 dwellings, particularly when RPS observes the 100 dwelling threshold commonly used in other Local Plans as a supported figure. RPS does however support the proposal that “the timescales for marketing will be reduced if the phasing of the site and build out rates are less than 12 months” otherwise there is a considerable risk that housing delivery will be stalled in the District. Where Policy 8d specifies that work will be undertaken with partners, RPS suggest the inclusion of public landowners in this section. For example, the District Council itself, County Council, NHS and other public bodies with land holdings and asset management/disposal strategies. |
|
260520 |
Campaign to Protect Rural England |
LPMM288 |
|
MM8.6 |
|
|
|
MM8.6 Surely the regulations are called “Building Regulations 2010” (no brackets). Para 8.30 The number of housing cases quoted is surely exceptional, resulting from the pandemic and is likely to revert to the lower level of preceding years. The use of data for an exceptional period is liable to give rise to inappropriate decisions. Either the unamended data should be retained or data should be provided for several years or if the amended text is retained, something should be added as to this being exceptional, as being from the time of the COVID-19 pandemic. |
|
1125905 |
Barberry Hurcott Limited |
LPMM3417 |
Object |
MM8.6 |
No |
No |
No |
The (very) sizeable change from 1,000 households approaching the LPA for housing advice in 2017/18 to 8,500 households in 2020/21 (and concomitant increase from 150 households owed a full rehousing duty to 415 households homeless or at risk of homelessness) is properly reflected in the proposed text pursuant to MM 8.6 however this step change does not appear to be reflected anywhere else in the LPA’s housing figures. It is unlikely (for example) that the submission Plan’s affordable housing provision of 90dpa was informed by the substantial increase in households in need or homeless/at risk as per the LPA’s 2020/21 figures. It is unclear whether or how the LPA’s proposed policies respond to such a change in evidence of need, and as a result whether the Plan’s proposed policies on affordable housing provision – or allocations – are an appropriate strategy to address such issues |
|
260520 |
Campaign to Protect Rural England |
LPMM289 |
|
MM8.7 |
|
|
|
MM8.7 – reference to “open countryside”. The use of this phrase has been eliminated from the overall strategy by MM6.7 in favour of “within settlement boundaries”. It is our position that Gipsies and other Travellers are entitled to a permanent residence to the same extent as the settled community, no more and no less. Accordingly, the provisions as to acceptable sites for travellers should mirror those for the settled community. |
|
1299978 |
Mr |
LPMM562 |
Object |
MM8.7 |
|
|
|
The additional site at Zortech Avenue for the traveller site seems inappropriate in terms of: a) the surrounding land use and the potential detriment to the highway (traffic and congestion and safety) b) the increased demand on the local infrastructure may be too great (schools, health services, etc) c) to what extent the adjacent nature reserve would suffer detriment |
|
1299943 |
Mr |
LPMM578 |
Object |
MM8.7 |
No |
No |
No |
The proposed site has previously been used as waste dumping ground by the Golf course that was previously there. Lorries used to come in full with various things, not just earth, (we complained to the council on various occasions). I feel digging all that up could be hazardous to existing residents and any new proposed ones. Before any digging work that ground should be thoroughly tested and residents given the results. Also, from a noise point of view, how can that possibly be controlled on what will essentially be a camp site right at the back of current residents gardens. Also, the cost of this would be extreme, there are many other sites where this could go, which would also be much better for the travellers, with much less effort and cost, so the council could spend that money in other important areas. |
|
1299540 |
Ms |
LPMM573 |
Object |
MM8.7 |
Yes |
Yes |
No |
The proposed changes will impact neighbouring houses and the travelling show people who already occupy part of the site and who are also afforded protection as a minority. When they were relocated here they were told they would be the only occupants of the site. When the golf course first became empty, there was a large, illegal encampment of travellers who occupied the site. There were also noise issues every night. How will neighbouring houses be protected from this? The travelling show people and the TVP factory make noise most of the time, is this suitable for residential use? How will access be granted if a substantial buffer zone is to be erected as per the amendment paperwork? How much will it cost to clear the site of the land fill as the Jennings were quoted £100k to have this done and this is why they refused this plot in the first place. |
|
260520 |
Campaign to Protect Rural England |
LPMM290 |
|
MM9.2 |
|
|
|
MM9.2 – New Policy 9.2.B HIAs are required for Major Developments. “Major Developments” needs to be defined in glossary. |
|
1301097 |
Mrs |
LPMM3722 |
Object |
MM9.3 |
No |
No |
No |
"A. Development should help minimise negative health impacts and maximise opportunities to ensure that people in Wyre Forest District lead healthy, active lifestyles and experience a high quality of life by: (i) Providing easy to maintain, safe and attractive public realm and green infrastructure including green spaces, footpaths, bridleways and cycle routes that encourage active travel opportunities. These spaces should enable formal and informal physical activity, recreation and play, and should support healthy living and social cohesion. The design of these spaces should be flexible and should consider older people and those living with dementia or disabilities." By building on land at Low Habberley you will be removing a valuable facility that many of the present population use to help them maintain a healthy active lifestyle. " (ii)Minimising and mitigating the impacts of negative air quality and reducing people's exposure to poor air quality." The Low Habberley development would cause an increase in pollution thus increasing the present population's exposure to poor air quality. |
|
1197572 |
Sport England |
LPMM566 |
Object |
MM9.3 |
|
No |
|
Sport England does not object to the proposed modification to move the reference to Sport England's Active Design Guidance from the policy wording in part 3 to the reasoned justification in para 9.8. However, in making this amendment, there is no longer explicit reference to sport within the wording of the policy. Given the well established inter relationship between sport and physical and mental well-being, Sport England would recommend the word sport is reinstated into the policy wording as follows: Ai. 'These spaces should enable formal and informal sport and physical activity, recreation and play...' In part 4 of the policy the former wording promoted opportunities for physical activity, exercise and recreation 'to serve all sections of the community, including older people and people with disabilities'. The modification states in part Ai) 'The design of these spaces should be flexible and should consider older people and those living with dementia or disabilities.' As drafted, the proposed modification moves the focus away from meeting the needs of all sections of society to focus on older people and those with dementia or disabilities. Whilst Sport England supports making reference to the elderly and those with disabilities, we object to the loss of reference to all sections of society, since our strategy relates to tackling inequalities of opportunity to be physically active for all sections of the community. To address this, Sport England would recommend a further modification to the wording of the policy as follows: 'The design of these spaces should be flexible and should consider the needs of all sections of the community, including older people and those living with dementia or disabilities.' |
|
1299978 |
Mr |
LPMM563 |
|
MM9.3 |
|
|
|
Question of clarification - will the requirements apply to regeneration schemes as well as development. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2731 |
Support |
MM9.3 |
Yes |
Yes |
Yes |
We support the amendments to Policy 9, which broadly accord with the joint Statement of Common Ground (examination document SD10a). |
|
231577 |
Persimmon Homes Limited |
LPMM3135 |
Support |
MM9.3 |
Yes |
Yes |
Yes |
We support the inclusion of wording to promote the provision of “easy to maintain, safe and attractive public realm and green infrastructure including green spaces, footpaths, bridleways and cycle routes that encourage active travel opportunities”. This modification supports the design aspirations of Site 34.4, Catchem’s End, Bewdley and the proposed linkages to the neighbouring green space to the west. |
|
260520 |
Campaign to Protect Rural England |
LPMM291 |
|
MM10.8 |
|
|
|
MM10.8 New Para 10.21 Some more wording is needed to ensure that the core of the town centre retains retail and other commercial uses (such as offices and clinics), with other uses mainly being welcomed in peripheral parts of the town centre. This will effectively be a continuation of old protected frontages policies, though these have now often been much eroded. |
|
260520 |
Campaign to Protect Rural England |
LPMM292 |
|
MM11.2 |
|
|
|
MM11.2 The change makes the present Design SPD applicable for the duration of the Plan, even if a new version is adopted. Add the word “currently”. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1978 |
Support |
MM11.6 |
Yes |
Yes |
Yes |
We note the updates to para. 11.31 of the Reasoned Justification for Policy 11D. We support these necessary changes, which bring the plan into line with the recently amended NPPF. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1979 |
Support |
MM11.7 |
Yes |
Yes |
Yes |
We welcome the proposed amendments to para. 11.32 of the Reasoned Justification for Policy 11D. We support the changes recommended and in particular the additional protection given to veteran trees, which we believe reflects the tenor and intent of guidance in the NPPF and importance of these features for biodiversity. |
|
231332 |
Natural England |
LPMM18 |
Support |
MM11.9 |
Yes |
Yes |
Yes |
We welcome the inclusion of new paragraph (11.39) to describe the theme related to the functionally linked watercourses of the Severn Estuary Special Area of Conservation and Ramsar site added as part of the environmental context, including reference to the requirement to consider potential impacts on migratory fish forming part of the reasons for the Severn Estuary designations in development proposals through the Habitat Regulations Assessment. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1980 |
Support |
MM11.9 |
Yes |
Yes |
Yes |
We fully support the new paragraph to be inserted as paragraph 11.39 in the Reasoned Justification for Policy 11D and agree that it is needed for clarity and effectiveness of the plan. |
|
1197572 |
Sport England |
LPMM507 |
Object |
MM12.1 |
|
No |
|
Sport England notes the modifications proposed to add part D to the wording of the policy which provides further clarity as to what is expected in terms of planning obligations and infrastructure requirements. The Council and Sport England have previously agreed a modification to para 12.8 of the reasoned justification to add the words including sport and recreation facilities in brackets to the list of infrastructure (see the completed Statement of Common Ground, page 3). To be consistent with this previously agreed amendment, Sport England would recommend that the same reference is added to the wording of the policy as follows: ‘Where appropriate, planning obligations will be required to fund infrastructure projects that are directly related to specific development, including but not limited to affordable housing, transport, green infrastructure (including sport and recreation facilities), education, health and other social infrastructure.’ This would ensure that the policy wording is consistent with the agreed modification to the reasoned justification, and would be consistent with the policy wording for the major housing allocations at Lea Castle and Kidderminster Eastern Extension where there is are specific requirements for provision of playing pitches to meet the needs of the proposed allocations. |
|
302433 |
West Mercia Police |
LPMM3480 |
Object |
MM12.1 |
Yes |
No |
Yes |
Policy 12 is not effective, justified or consistent with national planning policy in relation to emergency service infrastructure needs as currently drafted. The list of infrastructure types provided is almost a repetition of Section 216 (2) of the Planning Act 2008. This creates a problem in that whilst the list is not intended to be an exclusive one, it will be treated as such in practice. It was an issue that was recognised during the preparation of the Wyre Forest Core Strategy (adopted December 2010), which is why Policy CP07: Delivering Community Wellbeing of that document contained a full list of what ‘social infrastructure’ actually encompassed. In his report on the Core Strategy, Planning Inspector Philip A Goodman stated in relation to the list that: “81. I conclude that the plan is sound in this regard. The Council suggested other minor changes, including clarifying that Health and Safety includes the Emergency Services. I endorse suggested changes CC55-CC58 in the interests of clarity.” The reason given for the change to Policy 12 is that it will add further clarity. We contend that it will not, as the stated list of infrastructure types misses out a lot, such as the emergency services. We recommend instead that the list contained in Policy CP07 of the Core Strategy for social infrastructure is carried over into the new Policy 12 in the Local Plan. As well as addressing the clarity problem, this would make it consistent with the content of Chapter 3 of the Council’s Planning Obligations Supplementary Planning Document (adopted September 2016). The requested change would also enable Policy 12 to be fully consistent with paragraphs 8 (b), 20 (b), 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July 2021) (NPPF). It may be though that the emergency services have not been listed in the policy due to a concern about affecting the viability of developments in the District. In this respect it is clear from the NPPF and further guidance in relation to the consideration of viability, both at the plan-making and decision-taking stages, that there may well be developments which the proper seeking of obligations in relation to a raft of social and physical infrastructure would render such schemes unviable. If that is the case, the question of viability will be highly site-specific in relation to individual developments. It is however legitimate for the providers of infrastructure to be factored into such calculations from the outset and not be excluded without the local authority explaining and justifying this specifically on a site-by-site basis rather than through a blanket policy barrier. Ultimately a sustainable development cannot be such if it does not provide the emergency services infrastructure necessary to support it. Its absence means there will be a detrimental impact on the ability to create a safe and accessible environment where crime and disorder, and the fear of crime, do not undermine quality of live or community cohesion. In this respect emergency service delivery is not just responding to specific incidents or crimes. The ‘blue light’ services also must provide fire prevention advice, crime prevention advice, community assurance or lead at emergencies e.g. RTA’s, flooding and counter terrorism. The emergency services must also attend incidents involving deaths, crowds and events. They also attend and input to community safety and crime partnerships, and provide referral responses where there are expressed concerns about the safety of children, the elderly or those with special needs. Some or all of these will affect every development scheme during its lifetime. Notwithstanding the above, the methodology used by West Mercia Police (WMP) for Section 106 requests has been tested at numerous inquiries nationally, with the result that there are now 12 Secretary of State and 31 Planning Inspectorate decisions supporting Section 106 contributions for police infrastructure. Details of these are enclosed in Appendix 1. In these decisions the Inspectors accepted the following broad points:
The High Court has also confirmed the acceptability of developer contributions for police infrastructure. This concerned the case of Jelson Limited vs Secretary of State for Communities and Local Government and Hinckley and Bosworth Borough Council [2016] EWHC 2979 (Admin)(Appendix 2). Jelson Limited (JL) were appealing to the High Court against the decision of a Planning Inspector to refuse planning permission for 73 homes. The case revolved around a dispute between the parties over the calculation of ‘Full Objectively Assessed Need’ for housing. However, JL also objected in the case to making a Section 106 contribution to Leicestershire Police (LP), on grounds that such contributions did not comply with CIL Regulation 122. Their arguments against the police contribution are contained in paragraphs 73-76 of the enclosed judgement (Appendix 2). In essence, they argued that the Planning Inspector had not properly assessed the evidence submitted by LP. Had the Inspector done so, she would have rejected LP’s Section 106 contribution request. The High Court rejected also of JL’s arguments, as detailed in paragraphs 77-81 of the judgement (Appendix 2). In summary, the reasons for this were as follows:
The judgement provided support for Section 106 contributions for police infrastructure, as the methodology used by WMP to request such contributions follows LP’s. The overall conclusion that should be drawn from all of the above is that if it were a good argument that the police and emergency should not receive developer contributions, then the High Court, Secretary of State and Planning Inspectorate would have said so. Contributions to police infrastructure have been challenged and scruitinised on a number of occasions previously, as it is clear on the face of the decision enclosed in Appendix 1. Whilst it is common practice and of course right for individual planning officers and Inspectors to satisfy themselves that all of the tests within CIL Regulation 122 and reflected in paragraph 57 of the NPPF have been met; nevertheless Policy 12 needs to be amended as requested in order that there is clear guidance to planning officers and developers alike on how developer contribution requests from the emergency services should be considered. Finally and for the avoidance of doubt, the police and other emergency services are not seeking exceptional status relative to other infrastructure providers. Whilst it is true that they are unique in that they alone exist to save life and protect communities, it is recognised that others have equally vital roles to play in new development schemes. It is for this reason and all the others described above that the police and other emergency services seek formal parity with them, via the change to Policy 12 that we have requested to ensure compliance with paragraph 35 of the NPPF. Supporting documents for this response are included at Appendix 6 of this Summary of Responses. |
|
1217250 |
National Highways |
LPMM279 |
|
MM13.4 |
|
|
|
Consultation on the Proposed Main Modifications to the Wyre Forest District Local Plan (2016-36) - Town and Country Planning (Local Planning) (England) Regulations 2012, Section 19 and 35 National Highways welcomes the opportunity to comment on the main modifications to the Wyre Forrest District Local Plan (2016-36). National Highways, formerly Highways England, has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015, and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. The SRN is a critical national asset and as such works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. The SRN within and near to the area of Wyre Forest includes the M5 Motorway. We have reviewed the proposed modifications and are pleased to see that our recommended wording under the Transport and Accessibility section (paragraphs 13.4 and 13.5) are being proposed to be included. However, we would like to propose some additional changes: Firstly, reference to Highways England will need to be amended to National Highways following our name change in August 2021. NB: This is a simple name change and does not change the requirements as set out in our 2015 Licence agreement with DfT. Secondly, the Transport and Accessibility section of the Local Plan makes no reference to the Infrastructure Delivery Plan (IDP) which will set out the likely transport infrastructure needed to support the delivery of the local plan’s employment and housing supply. As per our signed Statement of Common Ground (SoCG), between ourselves, work is ongoing to identify the local plan’s specific transport impacts, including its impact on the M5 corridor and junctions forming part of the Strategic Road Network (SRN). Whilst it is not necessary to make specific reference to our SoCG within the local plan policies, it is necessary to reference the IDP as an important tool for bringing forward any required transport mitigation. As such, we would like to suggest the following revised wording to the below paragraph (new text in bold): |
|
260520 |
Campaign to Protect Rural England |
LPMM293 |
|
MM13.4 |
|
|
|
MM13.4 The new text is not wholly accurate, because M5 J6 is also a viable route from Kidderminster and Stourport to M5 southward and to the southwest. This should be mentioned in the text. |
|
1217250 |
National Highways |
LPMM280 |
|
MM13.5 |
|
|
|
Consultation on the Proposed Main Modifications to the Wyre Forest District Local Plan (2016-36) - Town and Country Planning (Local Planning) (England) Regulations 2012, Section 19 and 35 National Highways welcomes the opportunity to comment on the main modifications to the Wyre Forrest District Local Plan (2016-36). National Highways, formerly Highways England, has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015, and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. The SRN is a critical national asset and as such works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. The SRN within and near to the area of Wyre Forest includes the M5 Motorway. We have reviewed the proposed modifications and are pleased to see that our recommended wording under the Transport and Accessibility section (paragraphs 13.4 and 13.5) are being proposed to be included. However, we would like to propose some additional changes: Firstly, reference to Highways England will need to be amended to National Highways following our name change in August 2021. NB: This is a simple name change and does not change the requirements as set out in our 2015 Licence agreement with DfT. Secondly, the Transport and Accessibility section of the Local Plan makes no reference to the Infrastructure Delivery Plan (IDP) which will set out the likely transport infrastructure needed to support the delivery of the local plan’s employment and housing supply. As per our signed Statement of Common Ground (SoCG), between ourselves, work is ongoing to identify the local plan’s specific transport impacts, including its impact on the M5 corridor and junctions forming part of the Strategic Road Network (SRN). Whilst it is not necessary to make specific reference to our SoCG within the local plan policies, it is necessary to reference the IDP as an important tool for bringing forward any required transport mitigation. As such, we would like to suggest the following revised wording to the below paragraph (new text in bold): |
|
260520 |
Campaign to Protect Rural England |
LPMM294 |
|
MM13.5 |
|
|
|
MM13.5 The present wording fails to acknowledge the importance of the roads west of Bewdley (new) and Stourport bridges as access routes across the Severn towards mid-Wales. These are important as holiday routes. This is made very evident by traffic congestion on Fridays preceding bank holiday weekends and Sunday afternoons. |
|
1217250 |
National Highways |
LPMM3589 |
Object |
MM13.5 |
|
|
|
We have reviewed the proposed modifications and are pleased to see that our recommended wording under the Transport and Accessibility section (paragraphs 13.4 and 13.5) are being proposed to be included. However, we would like to propose some additional changes: Firstly, reference to Highways England will need to be amended to National Highways following our name change in August 2021. NB: This is a simple name change and does not change the requirements as set out in our 2015 Licence agreement with DfT. Secondly, the Transport and Accessibility section of the Local Plan makes no reference to the Infrastructure Delivery Plan (IDP) which will set out the likely transport infrastructure needed to support the delivery of the local plan’s employment and housing supply. As per our signed Statement of Common Ground (SoCG), between ourselves, work is ongoing to identify the local plan’s specific transport impacts, including its impact on the M5 corridor and junctions forming part of the Strategic Road Network (SRN). Whilst it is not necessary to make specific reference to our SoCG within the local plan policies, it is necessary to reference the IDP as an important tool for bringing forward any required transport mitigation. As such, we would like to suggest the following revised wording to the below paragraph (new text in bold): Therefore, National Highways, who maintains and manages the M5 Corridor, continues to work with Worcestershire County Council, and other key stakeholders to identify and develop improvement schemes and potential funding opportunities at these locations. This will enable the growth across this area to be accommodated within the operational capacity of the Local and Strategic Road Network. Once identified, any infrastructure improvements, and potential funding avenues, will be clearly set out in our Infrastructure Delivery Plan (IDP). |
|
1125905 |
Barberry Hurcott Limited |
LPMM3442 |
Object |
MM13.5 |
No |
No |
No |
We welcome the recognition in the draft Plan (through MM 13.5) that the District does not have direct access to the strategic road network, however the proposed text at MM 13.5 amounts to little more than ‘a plan to have a plan’. There does not appear to be support in the submitted evidence base for the proposition at MM 13.5 that the Plan’s potential for increased trips on the strategic road network being a “minor” impact and we query where the evidence to the Plan process is in support of this proposition. Since improvement schemes (and ‘funding opportunities’ have yet to be identified and/or developed it is unclear how this constitutes a justified or effective policy response. The observation that ‘in combination’ impacts of the proposed Plan “…cumulatively with further housing and employment growth in Birmingham, Black Country, Bromsgrove and South Worcestershire it is likely that improvements will be required at these junctions” is strongly suggestive of a need for effective joint working to deal with matters rather than defer them. The approach at MM 13.5 however is precisely that – to defer matters and (seemingly) to respond reactively to development impacts and infrastructure needs arising cumulatively with development from other planning authority areas, rather than to proactively plan infrastructure provision in connection with planned development and to do so with effective joint working. |
|
231332 |
Natural England |
LPMM148 |
Support |
MM14.1 |
Yes |
Yes |
Yes |
We welcome amendment to Policy 14 (B.iii and new paragraph 14.8 in reasoned justification ) to clarify requirements with regard to the provision of Green Infrastructure on brownfield sites. We welcome the inclusion of additional section H to Policy 14 Strategic Green Infrastructure and new paragraph 14.12 in reasoned justification setting out Councils commitment to safeguard and implement a scheme on land between Kidderminster and Stourport-on-Severn for development as the Burlish Country Park which will provide access to nature for local communities and opportunities for enhancement of the natural environment (NPPF Para 20 c) and d) and 92 c) are relevant) |
|
1197572 |
Sport England |
LPMM508 |
Object |
MM14.1 |
|
No |
|
Sport England supports the proposed modification to part Fii) of the policy which reads ‘replacement of, or investment in, GI of at least equivalent quantity and quality of community and technical environmental benefit is secured in a suitable location agreed with the LPA’, in line with the completed Statement of Common ground between the Council and Sport England (see page 6). However, Sport England does not support the proposed modification to add part H of the policy in respect of the creation of Burlish Country Park on land of the former Burlish Golf Course, since this relates to Sport England’s maintained objection to the loss of this sports facility without appropriate mitigation in line with para 99 of the NPPF, as set out in Sport England’s previous objections, and explained in the Statement of Common Ground (see in particular pages 8-11). |
|
231691 |
Mr |
LPMM1981 |
Support |
MM14.1 |
Yes |
Yes |
Yes |
We welcome and support the proposed changes to Policy 14. These provide additional clarity and appropriate national policy compliance to the wording. The final (additional) paragraph H. is helpful and offers important support for a welcome and positive council initiative. |
|
817914 |
Mr |
LPMM1015 |
Support |
MM14.1 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM14.1, |
|
231332 |
Natural England |
LPMM155 |
Support |
MM14.2 |
Yes |
Yes |
Yes |
We welcome amendment to Policy 14 (B.iii and new paragraph 14.8 in reasoned justification ) to clarify requirements with regard to the provision of Green Infrastructure on brownfield sites. We welcome the inclusion of additional section H to Policy 14 Strategic Green Infrastructure and new paragraph 14.12 in reasoned justification setting out Councils commitment to safeguard and implement a scheme on land between Kidderminster and Stourport-on-Severn for development as the Burlish Country Park which will provide access to nature for local communities and opportunities for enhancement of the natural environment (NPPF Para 20 c) and d) and 92 c) are relevant) |
|
260520 |
Campaign to Protect Rural England |
LPMM295 |
|
MM14.2 |
|
|
|
MM14.2 New Para 14.10 is welcome, but it should either appear in the glossary or be cross-referred from there. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1982 |
Support |
MM14.2 |
Yes |
Yes |
Yes |
We welcome and support the revised wording in the Reasoned Justification for Policy 14 and the additional clarity it brings to the requirements and proposals underpinning the district’s GI policy. |
|
817914 |
Environment Agency |
LPMM1016 |
Support |
MM15.1 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM15.1, |
|
817914 |
Environment Agency |
LPMM1017 |
Support |
MM15.3 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM15.3 |
|
817914 |
Environment Agency |
LPMM1018 |
Support |
MM15.4 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM15.4 |
|
817914 |
Environment Agency |
LPMM1019 |
Support |
MM15.5 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM15.5 |
|
817914 |
Environment Agency |
LPMM1020 |
Support |
MM15.6 |
|
|
|
We support the proposed changes as presented to reflect the suggested amendments and agreements as previously set out in our statement of common ground. For example, some updates/changes to MM15.6 |
|
231332 |
Natural England |
LPMM173 |
Support |
MMKD.1 |
Yes |
Yes |
Yes |
We welcome amendments to paragraph 30.74 supporting Policy 30.31 South Kidderminster Enterprise Park (SKEP), Key Diagram and policies map PM.20 to clarify changes to the area of SKEP to exclude Wilden Meadows and Marshes SSSI and the associated former settling ponds west of Wilden Lane. We welcome inclusion of wording in reasoned justification paragraph 30.74 highlighting requirement that potential impacts on this land should be considered as part of any application for development and positive benefits consistent with Policy 11(d) secured to enhance this area. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2951 |
Support |
MMKD.1 |
Yes |
Yes |
Yes |
We welcome the proposed update to the Key Diagram for the South Kidderminster Enterprise Park (SKEP) so that it does not incorporate Wilden Marsh Meadows SSSI and the adjoining settling ponds west of Wilden Lane. This change accords with our previous comments. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2692 |
Object |
MINOR MI/16.3 and MI/16.5 not Main Modifications |
|
No |
|
In Table 3 of the ‘Statement of Common Ground between Wyre Forest District Council and Worcestershire County Council’ (examination document SD10a), Wyre Forest DC stated that: “WFDC are agreeable to the suggested amendment to Policy 16C and Paragraph 16.27 of the Local Plan to read "such facilities" rather than "waste management facilities". This suggested amendment will be progressed as a suggested modification to the Local Plan.” The amendment has not been addressed within the schedule of Main Modifications, but has instead been included as Additional Modifications MI/16.3 and MI/16.5. WCC continues to consider that these modifications are necessary as a point of soundness, and therefore would ask the Inspectors to consider including them within their recommended Main Modifications. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2735 |
Support |
MM16.3 |
Yes |
Yes |
Yes |
We welcome the amendment to the footnote in Policy 16B, in line with our previous comments and the joint Statement of Common Ground (examination document SD10a). |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2736 |
Support |
MM16.4 |
Yes |
Yes |
Yes |
We welcome the removal of section 3 of policy 16B, in line with our previous comments and the joint Statement of Common Ground (examination document SD10a). The removal ensures that the policy does not go beyond the remit of the Wyre Forest Local Plan. Minerals development is a county matter and, as such, policies governing mineral development are contained in the emerging Worcestershire Minerals Local Plan (MLP). For information, the MLP is currently in the examination stage. Consultation on the proposed main modifications to the MLP closed in October 2021. |
|
260520 |
Campaign to Protect Rural England |
LPMM296 |
|
MM16.5 |
|
|
|
MM16.5 We would have thought there ought to be an explicit reference in this paragraph to minerals issues being dealt with in the Worcestershire Minerals Local Plan: it appears that it is merely to be alluded to in a footnote. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2738 |
Support |
MM16.5 |
Yes |
Yes |
Yes |
We welcome the proposed reference to Mineral Safeguarding Areas, in accordance with the 2021 NPPF. |
|
260520 |
Campaign to Protect Rural England |
LPMM297 |
|
MM16.6 |
|
|
|
MM16.6 (Sites where mineral safeguarding has been highlighted) There is something highly contradictory about allocating sites for early development, and then also requiring mineral safeguarding procedures to be undertaken. The effect is to make the whole strategy of the Plan undeliverable and hence fundamentally unsound. In most cases the mineral involved is sandstone (described as solid sand). This is an extremely abundant mineral in the area, where the available resource, even if the sites are sterilised by being developed, is likely to be sufficient for many centuries. Imposing mineral safeguarding requirements on such sites is likely to require the mineral to be extracted before development and then the resultant hole filled with waste, which will delay development for a decade or two. This would be the equivalent of not allocating the sites, contrary to the whole strategy of the Plan. The Worcestershire Minerals Plan requires that mineral considerations should be taken into account in making allocations, so that such sites should be released from restrictions requiring resources to be safeguarded from being fossilised by development. Anything else is a case of the proverbial “dog in the manger”. Either the safeguarding of these site should be withdrawn or they should be de-allocated and alternative ones allocated. Alternatively, the Mineral Planning Authority should specify what measures are required to work the minerals before they are fossilised and how long this will take to deliver before the site can be available for development. This might be different if it related to locally scarce minerals, such as glacial sand and gravel or crushed rock. We would add that as we oppose Lea Castle village and Kidderminster East Extension, we would welcome these sites being fossilised. |
|
260520 |
Campaign to Protect Rural England |
LPMM298 |
|
MM18.2 |
|
|
|
MM18.2 in item i, As with MM16.7, the proposed wording fails to make clear that infill is only allowed within the designated boundary of a village etc Reference should not be made to the housing register, here or in Policy 6B, as this is a blunt instrument for determining actual housing need, due to multiple counting of applicants, who are liable to be counted in each settlement (even estate) where they ask to be houses and even in multiple housing authorities. If housing register data is used at all, there should be an additional requirement for the applicant to have a local connection with the place where they seek to be houses. If this is not done, an applicant could justify a development of 100 houses in the midst of open country, because the housing list had at least 100 applicants living in (say) Kidderminster. While there is certainly a need for affordable housing, it needs to be in the appropriate place, preferably on an allocated site. (This also applies to para 18.8). |
|
260520 |
Campaign to Protect Rural England |
LPMM299 |
|
MM18.3 |
|
|
|
MM18.3 Policy 18D The present plan contains a policy largely prohibiting new mobile home parks on landscape grounds. This policy is about the temporary used of caravans etc; and is appropriate as far as it goes. However there is a major gap in it as it says nothing about the permanent (or nearly permanent) use of caravans etc (where new developments should be prohibited). In referring to nearly permanent, we are thinking of sites where occupation is allowed for as much as 11 months per year, with the resident being absent for a month as a holiday. This may be implicit in saying “only permitted temporarily”, but there should be something explicit. The exclusion from this policy of accommodation for Gipsies and other Travellers is appropriate, but the reasoned justification should merely state that provision for their needs is made elsewhere in the Plan (with a cross-reference). |
|
376324 |
The Canal and River Trust |
LPMM1200 |
|
MM18.3 |
|
|
|
We are the charity who look after and bring to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our waterways and promoting their use we believe we can improve the wellbeing of our nation. As you aware the Inspector posed a question in relation to liveaboards boaters as part of the EiP and the Trust and Council agreed a Statement of Common Ground and I provide an extract below. a) Both parties accept that the matter is not covered in the plan as proposed, and that the recent evidence base has not yet properly established whether there is a houseboat need. I note that the main modifications include at 18.15 'The Wyre Forest District Gypsy and Traveller Accommodation assessment (2020) also identified that there be a need for residential boat moorings in the District. However, there is currently insufficient evidence on this matter. The Council will work with the Canals and Rivers Trust to establish an accurate figure of need residential houseboat moorings. This will establish whether any allocation for moorings may need to be made in the review of the Local Plan'. As identified at e) the Trust offered to work with the council on a moorings policy, but as you will see at b) above the Trust cannot help with establishing need, and this was explained in detail in the SoCG. This modification is not acceptable to the Trust as it implies that we will help the council in establishing need. It is suggested that the modification be amended. 'If further evidence shows there is a need for any type of new moorings, the Canal & River Trust will work with the council to create a suitable moorings policy'. |
|
1197572 |
Sport England |
LPMM509 |
Support |
MM20.6 |
|
Yes |
|
Sport England supports the modifications to paras 20.16, 20.18, and 20.19 of the reasoned justification which are consistent with the modifications agreed between the Council and Sport England in the completed Statement of Common Ground (see pages 4 and 5), to provide clarity for how playing pitch requirements will be calculated, and provision will be made, in line with the Council’s evidence base in the Playing Pitch Strategy. |
|
1197572 |
Sport England |
LPMM512 |
Support |
MM20.7 |
|
Yes |
|
Sport England supports the modifications to paras 20.16, 20.18, and 20.19 of the reasoned justification which are consistent with the modifications agreed between the Council and Sport England in the completed Statement of Common Ground (see pages 4 and 5), to provide clarity for how playing pitch requirements will be calculated, and provision will be made, in line with the Council’s evidence base in the Playing Pitch Strategy. |
|
1197572 |
Sport England |
LPMM551 |
Support |
MM20.8 |
|
Yes |
|
Sport England supports the modifications to paras 20.16, 20.18, and 20.19 of the reasoned justification which are consistent with the modifications agreed between the Council and Sport England in the completed Statement of Common Ground (see pages 4 and 5), to provide clarity for how playing pitch requirements will be calculated, and provision will be made, in line with the Council’s evidence base in the Playing Pitch Strategy. |
|
1201410 |
McDonalds Restaurants Ltd |
LPMM3607 |
Object |
MM22.11 |
|
|
|
We have considered proposed Policy 22G – with regard to the principles set out within the Framework. We fully support the policy’s aim of promoting healthier living and tackling obesity. However, the proposed policy approach is unsound and fails to provide an evidence-based way of achieving the policy’s objective. It has also been found unsound by several planning inspectors. It is too restrictive and prevents local planning authorities from pursuing more positive policy approaches. The London Borough of Waltham Forest has had such a policy in place for over a decade and its application has proven ineffective in tackling obesity to date. Within these broad points we have the following policy objections to draft Policy 22G: A. The 400m exclusion zone is inconsistent with national planning policy B. The policy is inconsistent, discriminatory and disproportionate. C. Examination of other plans have found similar policy approaches to be unsound. D. There needs to be further exploration into policies that are more positive, have a reputable evidence base and that comply with the Framework. In summary, Planware Ltd consider there is no sound justification for a policy such as Policy 22G, which imposes a blanket ban on restaurants that include an element of hot food takeaway “within 400m the boundary of a school.” This is unsound and it should be deleted from the plan. However, as stated in the opening paragraph, Planware Ltd supports the aim of promoting healthier living and tackling the obesity crisis. We acknowledge that planning can have a role in furthering these objectives. We would therefore welcome and support any studies between obesity and their relationship with development proposals, including examination of how new development can best support healthier lifestyles and tackling the obesity crisis. When a cogent evidence base has been assembled, this can then inform an any appropriate policy response. This has still not emerged. Given the lack of any clear agreement between experts on the indices of obesity or poor health, analysing the evidence is a necessary part of this objection by way of background. McDonald’s supports the policy objective of promoting healthier lifestyles and tackling obesity. It does not consider that the proposed Policy 22G is a sound way of achieving those objectives. The underlying assumption in the policy is that all hot food takeaways (and any restaurants with an element of takeaway use) are inherently harmful to health. In fact, this is not supported by evidence. McDonald’s own business is an example of a restaurant operation which includes takeaway but which offers healthy meal options, transparent nutritional information to allow healthy choices, and quality food and food preparation. The business itself supports healthy life styles through the support given to its staff and support given to football in the communities which the restaurants serve. In addition, the policy fails to acknowledge the wider benefits that restaurants can have, including benefits relevant to community health and wellbeing. McDonald’s own business is an example of a restaurant operation that supports sustainable development through the use of renewable energy, the promotion of recycling, the use of energy and water saving devices. The economic benefits of its restaurants in supporting town centres and providing employment opportunities and training are substantial, and important given that improved economic circumstances can support improved health. The policy fails to acknowledge that food choices which are high in calories and low in nutritional value are made at premises trading with Class E consents and can be delivered from the latter. The policy makes no attempt to control these uses. For the reasons given in this objection the proposed policy is very clearly inconsistent with government policy on positive planning, on supporting economic development and the needs of businesses. There is no justification in national policy for such restrictions to be applied to hot food takeaways. The effect of the policy had it existed in the past would have been to exclude restaurants such as McDonald’s from major commercial and tourist areas. For the reasons given in this objection the proposed policy lacks a credible evidence base, and similar policies have been found to be unsound by inspectors who have examined other plans. In the one London Borough that has had a similar policy, concerning a school exclusion zone, for around a decade (LB Waltham Forest). It has had no discernible effect on obesity levels, which have in fact increased since its introduction. Given the overall objective of improving lifestyles and lowering obesity levels, restrictive policy regarding hot food takeaway development is a narrow-sighted approach. There is no mention of other possible reasons behind the national high levels of obesity. To discriminate against hot food takeaways alone is worrying and using the planning system to influence people’s daily lifestyle choices is not acceptable. See attachment for full objection. Supporting documents for this response are included at Appendix 6 of this Summary of Responses. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2742 |
Support |
MM24.5 |
Yes |
Yes |
Yes |
The proposed modifications to part (B) of policy 24B include a requirement that new developments should be built to the highest standards of energy efficiency, but it does not state what this highest standard is. We assume that this would be beyond Building Regulations standards. We would welcome the inclusion within the Local Plan of some further explanation/supportive text prior to the introduction of the ‘Future Homes’ standard. The proposed modifications to part (B) of policy 24B maintain the existing 10% requirement for renewable or low-carbon energy. We would welcome an increase in this proportion, if viable, to 12% or 15%. |
|
1197572 |
Sport England |
LPMM552 |
Support |
MM25.1 |
|
Yes |
|
Sport England supports the modifications to part ii) of the policy which is consistent with the modifications agreed between the Council and Sport England in the completed Statement of Common Ground (see pages 5 and 6), to ensure that the wording of the green belt policy is consistent with the NPPF in respect of both existing uses of land and changes of use. |
|
231723 |
Historic England |
LPMM564 |
Support |
MM26.1 |
|
|
|
Historic England welcomes proposed main modifications MM26.1 - Historic Environment policy |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2749 |
Support |
MM29.2 |
Yes |
Yes |
Yes |
We welcome this modification, which addresses comments we made at previous stages of plan preparation.
|
|
1303087 |
Dr Margreth |
LPMM3562 |
Object |
MM30.6 |
No |
No |
No |
MM30.6 Policy 30.5 Land at Bromsgrove Street Lion Fields BH/2 Bullet Point 1: Former Glades Site Proposal to build cinema and new leisure centre The proposal to extend Lion Street across at the site of the former Woolworths building to Worcester Street seems to us superfluous. It is only a short walk around and the land would be better used for further dwellings. The former Woolworths building has been boarded up for years. Could this building (and others) be viewed as “Pollution” and the owner be required to remove it under the principle of “Polluter pays?” |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2752 |
Support |
MM30.10 |
Yes |
Yes |
Yes |
We recommend that the proposed modifications to policy 30.11 are further amended to improve clarity, as follows (n.b. suggested changes apply only to policy point (1). No changes are sought for any other policy point in policy 30.11). Our proposed amendments are shown as double strikethrough and double underlined, to distinguish from the existing proposed modifications. Policy 30.11 Sladen School Site BW/3 The land This site is allocated as a mixed use site comprising of a new Alternative Provision Primary school and residential development. for residential development. ProposalsDevelopment should:
For clarity, we also recommend further amendments to the proposed modifications to paragraph 30.28 of the Reasoned Justification to add a full description of school provision, as follows: 30.28 This site is in the ownership of Worcestershire County Council. There have been a number of proposals put forward for the site since the school closed. It is now proposed to release the site for residential development. Provision of a small playing field on-site should be considered as part of these plans, perhaps in the form of a ‘village green’ overlooked by the housing.It is proposed to develop it to deliver a new 60 place Alternative Provision school and approximately 36 class C3 dwellings. The Alternative Provision Primary Free School (Unity Academy) will cater for children aged between 4-11 years old with social, emotional and mental health difficulties. It is anticipated that approximately 10 places would be for pupils who have been permanently excluded from mainstream education with 50 places for pupils with social, emotional and mental health difficulties who require an alternative to mainstream schooling in the short-term. It will be necessary to ensure that both parts of the scheme are appropriately integrated with each other and the neighbouring areas. The role of Green Infrastructure in and around the whole landholding will be an important component of this.
|
|
1298943 |
Miss |
LPMM178 |
Object |
MM30.17 |
|
|
|
See attached signed copies to stop the development at the habberley green belt. (only pages 2 and 8 attached) |
|
1298478 |
Mr Julian Rose |
LPMM16 |
Object |
MM30.17 |
|
|
|
Topic paper ED20 which was produced after the site was selected for removal from green belt assessed the site to make significant contribution for 1) containing sprawl 2) preventing encroachment and importantly in 3) overall contribution (three out of five). A review of results of other sites shows that few if any make as much contribution to green belt as this site does. |
|
1197092 |
Amy Hyde-Flynn |
LPMM2758 |
|
MM30.17 |
No |
No |
No |
Whilst I am not against the building of new houses, we feel strongly that brownfield sites should be used first, rather than destroying Green Belt land and land currently used to grow food. As we have seen with the recent delays and supply issues from abroad, the UK needs to make sure that we are as self-sufficient in food as possible. There is also the impact that removing this habitat would cause to the local wildlife and plant-life, not to mention the negative impact on local residents who use the field to walk through, and which proved itself a life-saver during the lock-downs. As mental health is an increasingly recognised issue, access to open, green spaces has been proven as an aid to positive mental health. Thank you for taking the time to read this, and I hope that you come to agree with our point of view, and keep this land as Green Belt. |
|
1299145 |
Mr |
LPMM277 |
Object |
MM30.17 |
No |
No |
No |
See attached documents for comments. Pages 2-4 could not be uploaded! My comments align with the ‘Stop The Habberley Road Development Group’. In addition: This is viable agricultural land that makes a significant contribution to the area in terms of amenity, recreation and food production. Development in this greenbelt area will increase urban sprawl; it will have a negative impact on the environment and on the local communities health and well-being. |
|
1285674 |
Dr |
LPMM7 |
Object |
MM30.17 |
No |
No |
No |
In her initial comments (document ED6), the Inspector said that she had not found a comprehensive, integrated and consistent level of explanation of the local-level, site- specific exceptional circumstances that, in the Council’s view, justify the release of each individual site from the Green Belt, and that that explanation should summarise the purposes that each individual site serves in the Green Belt, the effect of its release on these purposes and the overall integrity of the Green Belt, and the other relevant factors in each case that, cumulatively, may amount to exceptional circumstances justifying its release. The Inspector raised a number of Matters and Questions for the Examination (document ED16), including Matter 6, which relates to Allocations for Housing. The Questions include whether the selection of the site allocations was based on an adequate assessment of all potential sites, including a sustainability appraisal and assessment of their roles in serving Green Belt purposes. The Council subsequently produced a Topic Paper (document ED20), which assessed each site in more detail. In relation to the land at Low Habberley (ref WA/KF/3) (‘the Site’) it says:
The Inspector’s note to the Council dated 22 February 2021 (document ED46) on the initial drafting of the main modifications dealt with the broad scope of the modifications that appeared to be necessary, so far as they had been identified at the Hearing stage (such that there could be more). The note made clear that it was without prejudice to (i) the outcome of further work that the Council needed to undertake and (ii) the Inspector’s final conclusions on the soundness of the Plan. Whilst Appendix A to the Inspector’s note set out how some remaining issues affecting specific policies could be resolved, clearly the Inspector had a number of important concerns with the emerging plan, including with policy 30.21. The Council’s Sustainability Appraisal dated August 2021 (document ED58) considers (at pages 9 and 10) the sustainability impacts of the proposed site allocations. In the first instance, the appraisal is incorrect in that it says that the land at Low Habberley (ref WA/KF/3) has an area of 92.87 hectares. However, the draft plan says that the extent of site ref WA/KF/3 is 5.6 hectares, and so the appraisal should have been in relation to that area, not a larger area. In relation to policy 30.21, the appraisal says that in respect of Local services, Travel, Soil & land, Water & flooding, Landscape, and the Green Belt, there will be a minor negative impact compared with the current situation. Importantly, in relation to Biodiversity it says that there will be a major negative impact compared with the current situation, which will cause problematic sustainability issues, and that mitigation will be difficult and/or expensive. The impacts on community, historic environment, employment and housing are considered to be either neutral or positive. The Site is therefore of the highest importance in terms of its contribution to the Green Belt. Developing the Site for housing would have a significant harmful impact on the Green Belt. This harm must be balanced against the sustainability of the Site. The Sustainability Appraisal confirms that the Site is not particularly Sustainable, and that development would cause significant harm, particularly in terms of Biodiversity. It is not therefore considered that the exceptional circumstances required to justify the removal of the Site from the Green Belt exist. It is considered that the Council acted prematurely in selecting the Site for removal from the Green Belt before they had adequately considered the contribution it made to the Green Belt in their Topic Paper (ED20), which was produced after the Site was selected. The Site had not been adequately assessed prior to that, and should have been discounted when that document was produced. Now that the position is clearer, the Site should no longer be considered suitable for development. It should also be noted that the Reasoned Justification to policy 30.21 says that the site is approximately 1.5km from the town centre. That is considered to be incorrect; our clients have measured the distance and consider that, using the shortest possible route, it is in fact 2.6km. Therefore, it is not considered that MM30.17 makes the local plan sound and that for the reasons outlined above proposed policy 30.21 should be deleted in its entirety. |
|
1298606 |
Mr |
LPMM19 |
Object |
MM30.17 |
|
|
|
I hereby wish to object to ED57 & ED58 Habberley Road Development. |
|
1298639 |
Caroline |
LPMM21 |
Object |
MM30.17 |
|
|
|
I hereby wish to object to ED57 & ED58 Habberley Road Development. |
|
1298642 |
Mr |
LPMM23 |
Object |
MM30.17 |
|
|
|
I hereby object to ED57 & ED58 Habberley Road Development. |
|
1298643 |
Mr |
LPMM25 |
Object |
MM30.17 |
|
|
|
I am a resident of 7 years in Kidderminster. Having seen the plan proposal for the 140 homes on an area of natural beauty adjacent to the nature valley. I have to formally voice my objection to the planned development. I strongly support the development of redundant commercial areas of the town, which i believe would be far more reaching to the success of Kidderminster than the destruction of Kidderminster’s valued natural beauty areas. I hope the council will reconsider the plans and will look to encourage investors to bring life back to a town which once prospered so much, rather than destroying what is the main value to all inhabitants who live here today and the future. |
|
1300076 |
West Midland Bird Club |
LPMM579 |
Object |
MM30.17 |
No |
No |
No |
Objection to Change in Policy 30.21 Land at Low Habberley WA/KF/3 This land shown on the Policies Map is removed from the Green Belt and allocated for residential development. This is an objection and representation to the above-mentioned Policy amendment and any references to it in ED 57, ED58 and ED59 made on behalf of the West Midland Bird Club. David Jackson - Conservation Officer The RSPB have published a List of Bird species which are at risk nationally. The UK's birds can be split in to three categories of conservation importance - Red, Amber and Green. The Red list Red is the highest conservation priority, with species needing urgent action. The Amber list Amber is the next most critical group. The Green list Species on the green list are the least critical group. They are Species that occur regularly in the UK The proposed development land at LOW Habberley hosts several species on the Red List. Red Listed species are those of the highest conservation priority, such species needing urgent action on a national basis, and those species which nest or occur at the proposed development site include:- Curlew, Lapwing, Skylarks (3 breeding pairs recorded), Linnets, Yellowhammer and Song Thrush. In common with the rest of the UK, and indeed the planet, Worcestershire has suffered huge losses of natural habitats and species. The 2018-2027 Worcestershire Biodiversity Action Plan (BAP) identifies 17 habitats and 26 species, or species groups, which are of particular conservation priority in the county. The Worcestershire Biodiversity Partnership is an association of local government, statutory, voluntary and public bodies committed to working together to deliver the BAP. Each individual Action Plan gives an overview of the current status of the habitat or species in Worcestershire, identifies threats to it and current areas of work or activity being undertaken by partners. The plan then presents aims and objectives for the conservation of that habitat or species over the ten-year lifespan of the BAP. I would refer the Council to the individual Action Plans :- H1 Arable Farmland Habitat Action Plan; and S20 the Farmland birds Species Action Plan which has regard to Red Listed birds:-Skylark: Long-term change -58% decline between 1970 and 2016 (trend: weak decline) Short-term change +1% increase between 2011 and 2016 (trend: no change). Yellowhammers which breed either on or close to the ground within thick hedges, usually where there is a wide uncut grass margin or ditch. They can breed late into the season so even cutting or flailing during August can have a detrimental impact on the success of the last brood. The adults feed almost exclusively on seeds but chicks are largely dependent on insects. Linnets are dependent on plentiful seed sources throughout the year, in particular arable weed seeds, which are eaten by both adults and chicks. They nest in thick, thorny hedgerows or areas of scrub Lapwing: Long-term change -63% decline between 1970 and 2016 (trend: weak decline) Short-term change -3% decline between 2011 and 2016 (trend: no change). Grey partridge: Long-term change -92% decline between 1970 and 2016 (trend: strong decline) Short-term change -16% decline between 2011 and 2016 (trend: strong decline). crub and bramble within open farmland. Reference: Extract included by permission. Pleydell Smithyman Limited March 2021 S:\M20.128 Habberley Review\Document_Report\M20.128.R.001 Ecological Review\M20.128.R.001A Ecological Review.docx In 2021Pleydell Smithyman Limited were instructed by Mr Richard Merlyn Wilcox to assess the ecological value of the land off Habberley Road, Kidderminster following the proposals for the development of 130 residential properties at the site. The proposals have been put forward by Richborough Estates. Their proposals bring forward outline plans to develop the site to include the following: - 130 new homes, 25% being affordable; - A variety of house types to meet local needs; - Two points of vehicular access from Habberley Road, with six new points of pedestrian access; - Two pedestrian crossings and improvements to the footpath on Habberley Road along the frontage of the site; - Significant new planting and landscaping with a sensitive layout design to create a landscaped edge to Kidderminster; - Provision of 40% open green space, meeting local open space standards and delivering a net biodiversity gain for the site; - New footpath connections to existing public rights of way, improving connectivity to Habberley Valley Nature Reserve; and - A Sustainable Drainage System that creates an overall improvement to drainage of the site, and help protect the existing road network from flooding. The site offers suitable habitat for breeding and wintering birds in the form of arable land and hedgerows. During the bird survey Skylarks (Alauda arvensis) were recorded on the arable field and Woodpigeon (Columba palumbus) It is reported that Skylarks and Lapwings (Vanellus vanellus) have been recorded on the arable field frequently, and therefore the site is likely to form an important part of the feeding and breeding resource for these species. The site also offers suitable habitat for foraging Barn Owls (Tyto alba). There are a number of mature trees in close proximity to the site that could offer nesting and roosting potential for Barn Owls. It is also reported that Tawny Owls (Strix aluco) and raptors have been seen on or flying over the site. An extensive list of bird species have been recorded on the site between 1999 and 2020 by local keen birdwatcher Chris Rudge. Regularly occurring species include Woodpigeon, Collared Dove (Streptopelia decaocto), Red-legged Partridge (Alectoris rufa), Goldfinch flocks (Carduelis carduelis), Linnet flocks (Carduelis cannabina), Chaffinch (Fringilla coelebs), Greenfinch (Carduelis chloris), Lesser Redpoll (Carduelis sp.), Meadow Pipit (Anthus pratensis), House Sparrow flocks (Passer domesticus), Starling (Sturnus vulgaris), Redwings (Turdus iliacus), Fieldfares (Turdus pilaris) use the land for feeding. Species recorded frequently within the hedgerows include Yellowhammer (Emberiza citronella), Blue Tits (Cyanistes caeruleus), Great Tits, Long-tailed Tits (Aegithalos caudatus), Blackcaps (Sylvia atricapilla), Chiffchaffs (Phylloscopus collybita), Song Thrushes (Turdus philomelos), Blackbirds (Turdus merula), Dunnocks (Prunella modularis), Wrens (Troglodytes troglodytes), Goldcrests (Regulus regulus) and Robins (Erithacus rubecula). Nests of Linnet, Greenfinch, Wren and Dunnock have been recorded. More occasionally occurring species include Pied Wagtails (Motacilla alba), Grey Wagtails (Motacilla cinerea), Wheatear (Oenanthe oenanthe), Curlews (Numenius arquata), Lapwing, Common Buzzard (Buteo buteo), Siskin (Carduelis spinus), Brambling (Fringilla montifringilla) and Yellowhammer. Birds of prey recorded include regular Kestrel (Falco tinnunculus), Sparrowhawk (Accipiter nisus) and Tawny Owls. Barn owls have been seen hunting and Hobbies (Falco subbuteo) have bred in an ash tree bordering Habberley Valley Nature Reserve approximately. Quail (Coturnix coturnix) have also been heard and seen rising vertically out of the crop in various years. Grey partridge (Perdix perdix) have also been seen. The belt of trees at the southern end of the site is reported to support an extensive Jackdaw and Rook (Corvus frugilegus) roost. Great spotted Woodpecker (Dendrocopos major) and Green Woodpecker (Picus viridis) are also seen here, as well as the occasional Tree Creeper (Certhia familiaris), Nuthatches (Sitta europaea) and Jays (Garrulus glandarius). Conclusions and Recommendations The site offers suitable habitat for a wide range of bird species. Any development should consider the potential for impacts to occur on all bird species and on and surrounding the sites. Adequate desk study and survey effort should be included to substantiate all impact assessments. Impacts upon all designated sites within proximity to the site must be considered as a result of the proposed development, and where development is allowed to occur, adequate measures must be installed to mitigate for any additional impacts as a result of increased human pressure, particularly on Habberley Valley Nature Reserve. It will be vital to adequately justify the need of the development, particularly with regards to the location being within a designated Green Belt. All other possibilities should be explored before development is allowed to occur within designated Green Belt. The West Midland Bird Club object to the land being taken out of Green Belt and would recommend that the land be afforded protection from development due to the land being a valuable feeding and breeding resource for farmland birds as the land Any housing development will have no biodiversity net gain. |
|
1200165 |
Richborough Estates |
LPMM2667 |
Support |
MM30.17 |
Yes |
Yes |
Yes |
These representations have been prepared by Turley on behalf of Richborough Estates Limited in relation to Land at Low Habberley (‘the site’) which they are promoting through the Local Plan Review (LPR), including most recently attending the Examination of the plan where they provided support for the proposed allocation of the site (Policy 30.21). In addition to engaging with the LPR, alongside the examination of the Plan, Richborough Estates submitted an outline planning application for up to 124 dwellings on land at Low Habberley (Ref. 21/0421/OUT). As we go on to note below, the submission of the planning application has demonstrated that the site is not subject to any technical constraints, and following the adoption of the LPR the application can be determined in accordance with the newly adopted Plan, allowing for the delivery of new homes early on in the plan period. Main Modification MM30.17 Proposed modification MM30.17 relates to Policy 30.21 and represents the refinement of wording to respond to the live outline planning application, as well the alteration of wording to ensure that the policy requirements are precise, appropriate and measurable. The main changes to the policy are found within the list of requirements (seven in total), which development of the site should meet. In the context of NPPF paragraph 35, Richborough Estates agree that the proposed main modifications are sound and ensure the policy is effective and deliverable, as required by the NPPF. As set out previously, the submitted planning application shows how Richborough Estates proposals accord with the relevant policy requirements, as set out below:
|
|
859769 |
Mrs |
LPMM3174 |
Object |
MM30.17 |
|
No |
No |
My client objects to proposed Main Modification MM30.17 on the basis that it only amends specific details relating to this proposed allocation, informed by current planning application proposals, rather than address fundamental principles which run to the heart of the objectives of the Local Plan. The National Planning Policy Framework (NPPF), in paragraph 119, states that “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land”. NPPF paragraph 141 states that “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for identifying need for development”. NPPF paragraph 141 a) identifies that the assessment approach should make as much use as possible of suitable brownfield sites and underutilised land. NPPF paragraph 142 states that “Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed”. It should also be noted that more recently the message from the Conservative Government is one of seeking to focus attention on ‘building beautiful homes on brownfield sites’. Local Plan Objective 5 seeks to maximise the use of previously developed land in order to ensure that the best use is made of available land both within and beyond the main towns. Proposed Policy 6B also seeks to encourage the effective use and re-use of accessible, available and environmentally acceptable brownfield land. Wyre Forest District Council (WFDC) therefore appears to respond positively to the requirement of NPPF paragraph 119 through the objectives of the Local Plan. However the actual execution of this through the sites included for allocation does not demonstrate an approach that makes as much use as possible of previously developed land. My client recognises that there is a need for land to be released from the Green Belt adjacent to Kidderminster in order to meet the development targets for the new Plan period and as part of this there will be a need for development to take place on previously undeveloped land in the Green Belt. The approach taken through the Local Plan to pursue a housing target that is greater than the calculated housing need is commendable and supported by my client. Through ensuring a flexible supply of housing sites of different types and sizes WFDC is putting in positive measures to assist it with both meeting its housing need also boosting significantly the supply of housing, including affordable housing. My client also recognises that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns” (NPPF paragraph 73) and therefore that there is a role for large-scale strategic urban extensions to Kidderminster as part of the Local Plan approach. 5 The role that site WA/KF/3 (Land at Low Habberley) plays within the Local Plan approach still remains unclear. Site WA/KF/3 is in the Green Belt, lacks an existing strong defensible Green Belt boundary on all sides, does not contain any previously developed land and cannot be considered to be or even form part of a large-scale urban extension to Kidderminster. Main Modification MM30.17 does not shed any further light on this. In making only minor changes to site WA/KF/3 in the Main Modifications consultation the presumption would be that WFDC, through the Plan-making process has first maximised the use of previously developed land and that the only way to ensure that there is a sufficient and flexible supply of suitable residential development sites around the edge of Kidderminster is to pursue an approach that relies on the allocation of non-strategic, non-previously developed, sites in the Green Belt which need the creation of new defensible landscape boundaries. My client considers that this is however not the case. My client accepts that site WA/KF/3 would make a contribution towards ensuring a flexible supply of housing sites of different types and sizes. However WFDC would still have a housing target in excess of its housing need if site WA/KF/3 was not included. It is therefore confusing that site WA/KF/3 remains in the Plan when potential residential site WFR/ST/1 (Land at Captains) has been excluded. Site WFR/ST/1 features on the WFDC brownfield land register. This site is considered to be a sustainably-located partially previously developed site on the eastern edge of Kidderminster, adjacent to the proposed strategic allocation, which can accommodate residential development in tandem with appropriate mitigation for ecological/landscaping features. As explained within the responses issued on behalf of my client to the Local Plan Examination Hearing sessions the technical studies within the WFDC evidence base provide support for development at site WFR/ST/1. Most notably the 2018 Green Belt Review concludes, in term of site WFR/ST/1, that “the site makes only limited contribution to the Green Belt, being well bounded with limited visual connection” and identifies that “development would extend the current built edge of Kidderminster along the A448 but this would not be substantial and would be visually contained by substantial boundary vegetation”. Site WFR/ST/1 is not a late entry to the Local Plan review process, being specifically identified in the Preferred Options consultation document as a core housing site. The suitability of the site for accommodating residential development was acknowledged by WFDC during the Local Plan Examination discussions and also subsequently through the pre-application process. WFDC has therefore not appropriately taken into account the reasonable alternatives in deciding on the Local Plan allocations. This point was made through previous representations made by my client in declaring the Local Plan approach to: not be justified; not be positively prepared and; therefore be unsound. This stance remains valid, not least through the acceptance by WFDC that site WFR/ST/1, which contains previously developed land, can accommodate residential development and the willingness of my client to pursue development on the site as evidenced through constructively engaging with the WFDC pre-application process. The proposed Main Modifications do not address either the deviation from the national objective to maximise the use of previously developed land or justify the approach taken to continue to allocate non-strategic non-previously developed Green Belt sites. The proposed Main Modifications are accordingly not considered to make the Plan approach sound. It is considered that a revised review of alternative sites, including previously developed sites, should be undertaken and consulted on before the Local Plan moves forward to adoption to ensure that the Local Plan is genuinely based on an approach that maximises the use of previously developed land. |
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1302954 |
Rosemary |
LPMM2666 |
Object |
MM30.17 |
|
|
|
I write to put forward our objection to the above development, Hospitals, GP’s , Schools, can not cope now, also this is green belt , brown belt is the way forward, to save the environment! |
|
1302962 |
Mr |
LPMM2668 |
Object |
MM30.17 |
|
|
|
The planned development, if permitted, will inevitably increase the footfall in the Habberley Valley Nature Reserve, not only by the residents of the houses in question. Historically, when the Valley was owned by the Lord of the Manor, the site was subjected to various outrageous uses – for example, training dispatch riders during WWII, motor-cycle trials round the edge of Pekket Rock shortly after the war, and so on. Since its purchase by Wyre Forest District Council it has been converted into a local nature reserve, and access, though never denied, has been kept within bounds by limiting the number of car parking spaces and use mainly by local residents has been on foot with some small effort. The access roads in any new development will inevitably increase the numbers of human visitors (these days often with dogs – increasingly because of the new occupation of ‘dog walker’). There is absolutely no way that this can benefit wildlife in the valley, and the notion that biodiversity might be one outcome of the housing development is patently absurd. I have been involved in working parties organised by the WFDC rangers and I know that a few years ago it was feared the adder population in the valley had deserted the site. Fortunately, their continuing presence was eventually confirmed. I can’t see any chance that this will remain so as a result of the extra housing supply. |
|
1302951 |
Pamela |
LPMM2659 |
Object |
MM30.17 |
|
|
|
I object to the building plans to erect 140 new homes on this beautiful green belt field. The extra traffic to enter exit this new build would make this already busy road more dangerous. Also probably extra traffic onto Coningsby Drive would make more problems. A beautiful area would be robbed of the birds wild life trees/hedges etc. Surely there are more areas in and around Kidderminster that new homes could be built not using green belt. |
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1299550 |
Mrs Elizabeth Jones |
LPMM2848 |
Object |
MM30.17 |
|
|
|
Please no more housing. Roads blocked. Cars parked on grass at Franche Estate. Bowling Green closed at White Wickets - moved to Stourport. used by many pensioners who are unable to get there). Our little walks in country will not be enjoyable. Keep all green belts. |
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1301410 |
Mr Peter Hill |
LPMM3783 |
|
MM30.17 |
|
|
|
Many of the statements put forward in support of the Habberley field development are questionable. For example: MM30.51 - "The retention and enhancement of the hedge on the western edge will provide a strong defensible Green Belt boundary" Clearly the B4190 road is a far more defensible boundary MM30.17 Policy30. 6 "The impact of any development on the nearby Habberley Valley Nature Reserve and Local Wildlife Site should be balanced out through biodiversity net gain." How is this building of a housing estate on a Green Belt field going to enhance biodiversity?! MM9.3 Policy 9 v. "Encouraging opportunities for access to fresh food, for example through the retention and provision of allotments, community orchards, fruit trees" Really!? On a 5.6 hectare field containing a housing estate?? MM9.3 Policy 9 A "Development should help minimise negative health impacts.." Again by removing existing scenically attractive Green Belt and existing paths much relied on by local population?? Really! These are just four random statements among countless others which are highly controversial, misleading and inaccurate. MM8. "Kidderminster and Stourport-on-Severn provide a good range of jobs and services and the opportunities for accessing the public transport network" At peak times traffic on the B4190 and adjoining roads leading in and out of Kidderminster is heavy and congested. There is no opportunity for employment in the vicinity. All working people would have to commute into or through the town and there is no viable bus service.
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|
1299552 |
Mr Robert Ward |
LPMM2689 |
|
MM30.17 |
|
|
|
There is no comment on fuel line across the land affected by this proposal |
|
1300127 |
Mrs |
LPMM2733 |
|
MM30.17 |
|
|
|
I live on Franche Estate and I think the extra traffic going through the estate is going to make life worse than it is now. Access to site is going to be dangerous whichever road it's put on. We are supposed to look after environment not spoil it. It's only a tiny bit of land leave it alone. |
|
1303118 |
Enal Holdings Limited |
LPMM3757 |
Object |
MM30.18 |
|
|
|
We are writing to you to object to the above planning application for a gypsy site at the rear of the golf club by Birchen Coppice. We are objecting against consultation documents ED57, ED58 and ED59. We are objecting on the following grounds: - 1.Safety of Students and Users – Centre of Sporting Excellence (‘CoSE’), which is the land that we own, is used by users of all ages. CoSE is used as the site where students are taught about football and can achieve qualifications in football. These students are both male and female and the majority of the students are between the age of 16 - 18. However, students who are undertaking Higher Education also use the facilities. At CoSE, we provide a friendly social environment where users of all ages come to enjoy sport. The users that use the site range from the Under 8’s team learning to play football all through the age range to include boys, girls, ladies and men’s football teams. The site is also used by mature retirees who frequent the two bowling greens. We are fortunate to have a facility where a wide range of users can come and participate in sports such as football, bowling, judo and model car racing within our grounds in the knowledge that the users are largely safe from any outside factors. We are also concerned that students will decide to no longer learn at this site as they will not feel safe walking to and from the site. If they decide to go to other learning establishments, this will have an enormous financial impact on all businesses that use the CoSE site along with local colleges and universities who use the site as training grounds. We ask the committee to look at the objective at 3.1 (page 16) of ED57, which supports that the Council should be looking to support the economic and social growth of the area and create safe and accessible environments where crime and disorder and the fear of crime do not undermine quality of life or community cohesion. 2. Financial Loss Companies Cannot Afford to Lose – As well as the financial loss that we, the education company, the two bowling clubs and judo club would all suffer if the users stopped using this site, a lot of time and money has been invested into the facilities and the necessary equipment to make the sporting experience enjoyable and attractive. Improving the security of our grounds even further will take significant investment, which is an expense we would prefer not to incur as our business recovers from the impact of Covid. 3.Effect on the Tranquillity of the Area - The area in which our facility is located is beautiful. We are extremely lucky to have the Burlish Nature Reserve as the backdrop to our grounds. Converting this green belt of land to brown belt to allow the traveller site will diminish the aesthetics of the area significantly. This could make users of our facility think differently about whether they continue to utilise our facility in the future, which goes against our planned intention to increase the number of users at CoSE. We ask the committee to read policy 6B of ED57 which supports the protection of landscapes. 4.Environmental Issues - Green belts should be retained as much as possible. This will help the current environmental issues that the planet is current experiencing. Green land encourages users to walk and exercise which will assist in less pollution as users will not be using their cars as much. It also helps the NHS, as exercise is recommended to keep users fit and health. Supported by the objective at 3.1, MM9.2 and MM7.4 of ED57 which states that ‘once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified’. We do not believe that the planning of a traveller’s site is an exceptional circumstance. 5.Loss of Privacy to Young Children and Users - One of the reasons why we feel our junior programme is so attractive to the parents of young boys and girls (under 8 years of age) wishing to take up football, is the privacy that our facility offers. A traveller site on our doorstep puts this privacy at risk. This could make parents think twice about whether our location is somewhere they feel comfortable allowing their child to play football. We also object to the application because despite CoSE being some 52 acres in size, our football pitches are currently over utilised. This is largely due to the size of our football programme which commences at U8 level and goes up to our U23’s. Both the ladies and men’s football teams are also using the facility. There is potential for further demand on our facility as a result of our new and exciting partnership agreement with Kidderminster College, who have ambitions to expand their sports provision on our site, as well as expand their courses in non-sporting areas such as horticulture and catering, which will also be undertake within our grounds and within our education building. As a business, we are looking to expand our site to ensure that we can satisfy the additional demand that could be placed on our facility, so that we don’t damage what we already have. Our future vision includes approaching the Council to discuss whether there is an opportunity to lease/purchase land that was previously part of the now defunct golf clubs. We would also use any such opportunity to expand our sports programme beyond football, so that we can provide residents with the opportunity to pursue other sports, such as rugby and cricket. We are aiming to invest in a 3G facility at CoSE so we can take some of the pressure of our grass pitches and provide a venue where supporters can watch our floodlit league teams play football, as well as open the use of the facility to the wider community. Should our vision be realised, the area would be a hub for sport, when you combine it with the facilities at Stourport High School, the facilities at Stourport Sports Club and the facilities at the Wyre Forest Leisure Centre a short drive towards Kidderminster. Our vision is in line with MM20.6 paragraph 20.16 and MM20.8 paragraph 20.19 of ED57 for providing recreational facilities for all age groups. Our concern is that the traveller site will prevent us from realising the vision for our facility and the benefit it will bring to the area and the wider community who will benefit from it. |
|
1303119 |
Kidderminster Harriers |
LPMM3773 |
Object |
MM30.18 |
|
|
|
We are writing to you to object to the above planning application for a gypsy site at the rear of the golf club by Birchen Coppice. We are objecting against consultation documents ED57, ED58 and ED59. We are objecting on the following grounds: - 1.Safety of Students and Users – Centre of Sporting Excellence (‘CoSE’). CoSE is used as the site where students are taught about football and can achieve qualifications in football. These students are both male and female and the majority of the students are between the age of 16 - 18. However, students who are undertaking Higher Education also use the facilities. We use the site for our first team to train as well as to assist in the education of the students along with KHFC ED Ltd. At CoSE, we provide a friendly social environment where users of all ages come to enjoy sport. The users that use the site range from the Under 8’s team learning to play football all through the age ranges to include boys, girls, ladies and men’s football teams. The site is also used by mature retirees who frequent the two bowling greens. We are fortunate to have a facility where a wide range of users can come and participate in sports such as football, bowling, judo and model car racing within our grounds in the knowledge that the users are largely safe from any outside factors. We are also concerned that students will decide to no longer learn at this site as they will not feel safe walking to and from the site, and if they decide to go to other learning establishments, this will have an enormous financial impact on all businesses that use the CoSE site along with local colleges and universities who use the site as training grounds. We ask the committee to look at the objective at 3.1 (page 16) of ED57, which supports that the Council should be looking to support the economic and social growth of the area and create safe and accessible environments where crime and disorder and the fear of crime do not undermine quality of life or community cohesion. 2.Financial Loss Companies Cannot Afford to Lose – A lot of time and money is invested into the facilities and the necessary equipment to make the sporting experience enjoyable and attractive. Improving the security of our grounds even further will take significant investment, which is an expense we would prefer not to incur as the business recovers from the impact of Covid. 3.Effect on the Tranquillity of the Area - The area in which we train is beautiful. We are extremely lucky to have the Burlish Nature Reserve as the backdrop to the grounds. Converting this green belt of land to brown belt to facilitate the traveller site will diminish the aesthetics of the area significantly. This could make users of the facility think differently about whether they continue to utilise the facility in the future, which goes against our planned intention to increase the number of users at CoSE. We ask the committee to read policy 6B of ED57 which supports the protection of landscapes. 4.Environmental Issues - Green belts should be retained as much as possible. This will help the current environmental issues that the planet is current experiencing. Green land encourages users to walk and exercise which will assist in less pollution as users will not be using their cars as much. It also helps the NHS, as exercise is recommended to keep users fit and healthy. Supported by the objective at 3.1, MM9.2 and MM7.4 of ED57 which states that ‘once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified’. We do not believe that the planning of a traveller’s site is an exceptional circumstance. 5.Loss of Privacy to Young Children and Users - One of the reasons why we feel the junior programme is so attractive to the parents of young boys and girls (under 8 years of age) wishing to take up football, is the privacy that our facility offers. A traveller site on our doorstep puts this privacy at risk. This could make parents think twice about whether our location is somewhere they feel comfortable allowing their child to play football. We also object to the application because despite CoSE being some 52 acres in size, our football pitches are currently over utilised. This is largely due to the size of our football programme which commences at U8 level and goes up to our U23’s. Both the ladies and men’s football teams are also using the facility. There is potential for further demand on our facility as a result of our new and exciting partnership agreement with Kidderminster College, who have ambitions to expand their sports provision on our site, as well as expand their courses in non-sporting areas such as horticulture and catering, which would also be performed on our grounds and in our education building. We would also use any such opportunity to expand our sports programme beyond football, so that we can provide residents with the opportunity to pursue other sports. We are aiming to invest in a 3G facility at CoSE so we can take some of the pressure of our grass pitches and provide a venue where supporters can watch our floodlit league teams play football, as well as open the use of the facility to the wider community. Should our vision be realised, the area would be a hub for sport, when you combine it with the facilities at Stourport High School, the facilities at Stourport Sports Club and the facilities at the Wyre Forest Leisure Centre a short drive towards Kidderminster. Our vision is in line with MM20.6 paragraph 20.16 and MM20.8 paragraph 20.19 of ED57 for providing recreational facilities for all age groups. Our concern is that the traveller site will prevent us from realising the vision for our facility and the benefit it will bring to the area and the wider community who will benefit from it. |
|
1303124 |
Kidderminster Harriers Football Club Academy |
LPMM3775 |
Object |
MM30.18 |
|
|
|
We are writing to you to object to the above planning application for a gypsy site at the rear of the golf club by Birchen Coppice. We are objecting against consultation documents ED57, ED58 and ED59. We are objecting on the following grounds: - 1.Safety of Students and Users – Our business works alongside Kidderminster College and the University of Worcester. We provide the practical and educational studies for students keen to explore in sport, but primarily football. Our facility also hosts a number of football matches every week which all of our teams, from our youngest team of U8’s through to our higher education students in the U23’s, compete in. We operate from the Centre of Sporting Excellence (‘CoSE’). CoSE hosts all students on our education programme, with students being taught their programme within the classrooms of the Old Chainwire Club, before performing their practical skills on our football pitches. These students are both male and female and with our students ranging between the age of 16 - 21. At CoSE, we provide a friendly social environment where users of all ages come to enjoy sport. The users that use the site range from the Under 8’s team learning to play football all through the age ranges to include boys, girls, ladies and men’s football teams. We are fortunate to have a facility where a wide range of users can come and participate or watch sports such as football in the knowledge that the users are largely safe from any outside factors. We are also concerned that students will decide to undertake their studies and football coaching with alternative providers, as they will not feel safe walking to and from our site. This will have an enormous financial impact on us and all businesses that use the CoSE site, including the college and university with whom we are partnered. We ask the committee to look at the objective at 3.1 (page 16) of ED57, which supports that the Council should be looking to support the economic and social growth of the area and create safe and accessible environments where crime and disorder and the fear of crime do not undermine quality of life or community cohesion. 2.Financial Loss Companies Cannot Afford to Lose – As well as the financial loss that we would suffer if the students stopped using this site, owing to their fear of being in a close proximity to a travellers site, a lot of time and money has been invested into the facilities to purchase the necessary equipment to make the sporting experience enjoyable and attractive. Improving the security of our grounds even further will require significant investment, which is an expense we would prefer not to incur as our business recovers from the impact of Covid. 3.Effect on the Tranquillity of the Area - The area in which our business is located is beautiful. We are extremely lucky to have the Burlish Nature Reserve as the backdrop to our grounds. Converting this green belt of land to brown belt to facilitate the traveller site will diminish the aesthetics of the area significantly. This could make users of our facility think differently about whether they continue to utilise our facility in the future, which goes against our planned intention to increase the number of users at CoSE. We ask the committee to read policy 6B of ED57 which supports the protection of landscapes. 4.Environmental Issues - Green belts should be retained as much as possible. This will help the current environmental issues that the planet is current experiencing. Green land encourages users to walk and exercise which will assist in less pollution as users will not be using their cars as much. It also helps the NHS, as exercise is recommended to keep users fit and healthy. Supported by the objective at 3.1, MM9.2 and MM7.4 of ED57 which states that ‘once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified’. We do not believe that the planning of a traveller’s site is an exceptional circumstance. 5.Loss of Privacy to Young Children and Users - One of the reasons why we feel our junior programme is so attractive to the parents of young boys and girls (starting from 7 years of age) wishing to take up football, is the privacy that our facility offers. A traveller site on our doorstep puts this privacy at risk. This could make parents think twice about whether our location is somewhere they feel comfortable allowing their child to play football. We also object to the application because despite CoSE being some 52 acres in size, our football pitches are currently over utilised. This is largely due to the size of our football programme which commences at U8 level and goes up to our U23’s. Both the ladies and men’s football teams are also using the facility. There is potential for further demand on our facility as a result of our new and exciting partnership agreement with Kidderminster College, who have ambitions to expand their sports provision with us. |
|
1285677 |
Mr |
LPMM9 |
Object |
MM30.25 |
No |
No |
No |
This proposal must not be allowed to go ahead as it will have both detrimental on the environment, the green belt land that is used by many to access the rifle range nature reserve, the detrimental implications on the local services schools and access roads, not to mention the already suffering housing market. There are far better more suitable areas on brown fields land to accommodate any builds and to even suggest building on this green belt land is an absolute outrage and one that will not be forgotten at the next local elections. To down grade green belt land just so the council can easily fulfil a duty without actually taking measures to fulfil that duty is a disgrace especially when there are far better sites on brownfields, a reasonable person could only conclude that cost is a primary factor in this proposal. The area is an area on natural beauty and historically important to the local history of this country particularly the events of World War Two and anyone who lived in this area would be aware of that. Watching the live stream of the planning committee, it was wrongly concluded that the road at Kinver Avenue / Zortec Avenue of Walter Nash Road was suitable for heavy vehicles that the traveling community use. The road is not suitable or sufficient and would in my professional opinion will create a safety hazard to pedestrians who use this area to access the beautiful nature reserve, it is an accident waiting to happen and yet the council do not respond to any queries and requests on the assessments that outline any control measures as to the above. As a professional highly qualified Health Safety and Environmental Officer, I would dispute the conclusion that the road is safe and would further ask to see what suitable and sufficient risk assessments have been carried regards access and egress to justify this awful proposal bearing The health and Safety At Work Etc Act 1974 and the Construction Design and Management Regulations 2015 and would seek further proof that the assessments take into consideration that children and other pedestrians would be sharing this already busy area to access the old Golf field and nature reserve! I have requested on many occasions to see the full risk assessments to various parties from the council and planning depts, but these have never been provided despite the legal requirement to provide them. Despite the blatant untrue propaganda issued in the form of statements there was no consultation regarding the original process, the Birchen Coppice area has not had a local paper now for nearly 20 years, there were no leaflets delivered and no one in this area I have spoken to were aware of this proposal. |
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1197572 |
Sport England |
LPMM553 |
Object |
MM30.25 |
|
No |
|
The proposed modifications to paras 30.69 and Policy 30.29 (Former Burlish Golf Course Clubhouse), does not address Sport England’s maintained objection to the loss of the former sports facility without appropriate mitigation in line with para 99 of the NPPF, as set out in Sport England’s previous representations, and summarized in the completed Statement of Common Ground between the Council and Sport England (see page 8). |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2753 |
Support |
MM30.26 |
Yes |
Yes |
Yes |
We note that the site-specific policy AM30.30 for the new allocation “Land off Zortech Avenue LI/13”, previously included a requirement for a minerals resource assessment. This requirement is now proposed to be removed, as it is covered by the comprehensive list of minerals resource assessments proposed in MM16.6. As stated in our response to MM16.6, although removing the requirements from each allocation policy and placing them in the reasoned justification may weaken the emphasis given to minerals (and waste) safeguarding, we are nonetheless satisfied that the combination of MM16.6 and MM29.2 addresses the comments we made at previous stages of plan preparation, and we therefore also support MM30.26 to maintain consistency of approach.
|
|
231332 |
Natural England |
LPMM17 |
Support |
MM30.27 |
Yes |
Yes |
Yes |
We welcome amendments to paragraph 30.74 supporting Policy 30.31 South Kidderminster Enterprise Park (SKEP), Key Diagram and policies map PM.20 to clarify changes to the area of SKEP to exclude Wilden Meadows and Marshes SSSI and the associated former settling ponds west of Wilden Lane. We welcome inclusion of wording in reasoned justification paragraph 30.74 highlighting requirement that potential impacts on this land should be considered as part of any application for development and positive benefits consistent with Policy 11(d) secured to enhance this area. |
|
231573 |
Worcestershire County Council, Planning Economy & Performance |
LPMM2754 |
Support |
MM30.27 |
Yes |
Yes |
Yes |
We welcome the proposed changes to paragraph 30.74, which accord with our previous comments.
|
|
1300042 |
Mrs |
LPMM574 |
Object |
MM31.1 |
No |
No |
No |
Although we agree with the 600 houses on the brownfield site that was once Lea Castle, we totally disagree with the destruction of the beautiful, unspoiled greenbelt countryside surrounding the site which will be totally out of character with the surrounding area. The old hospital site is tree lined which has a good visual impact as you approach the area but the planned extra houses will have a massive detrimental effect both visually and regarding light pollution. We regularly walk our dog around this area and see polecats, deer and bats - all of whose habitats will be destroyed. We would also like to express our total disgust at the disrespect for the views of the local people in the fact that tester holes have already been dug on the A451 and on Axborough Lane. This seems very underhand as if a deal has already been agreed with the developers. |
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1125905 |
Barberry Hurcott Limited |
LPMM3443 |
Object |
MM31.1-3 |
No |
No |
No |
The proposed MMs at 31.1 to 31.3 do not reflect the position as accepted by the LPA at the EiP, namely the LPA’s acceptance that the proposed new village at Lea Castle is not (of itself) a sustainable location and that it is only the proposed additional c.800 units that renders the allocation sustainable. Given that it is the addition of the c.800 units to the existing c.600 units (which are themselves not in a sustainable location) it remains unclear how the requirements of NPPF 73 have been considered or met (both for the Lea Castle allocation, and in relation to other potential allocations of c.800 units to other areas which themselves may currently be thought of as unsustainable or otherwise constrained but may be made acceptable by an 800-unit allocation extending them). NPPF 73 requires that new settlements or significant extensions are: a. well located; b. well designed; and c. supported by the necessary infrastructure and facilities, including a genuine choice of transport modes. Whilst granting the 600 units may have been granted with the intention of pursuing development on brownfield sites (albeit in a location with poor sustainability) the further release of green belt land with the purpose of increasing the sustainability of that location (given its poor transport and sustainability credentials) appears unjustified. We refer back to the submissions made on behalf of Barberry as to the LPA’s failure to properly consider the extensive and substantial adverse impacts of the proposed Lea Castle village(footnote 7), particularly when considered against the provision of NPPF 142 that “Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.”. Moreover NPPF 142 goes on to state that plans “…should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.”; in addition NPPF 174(d) requires that plans should provide net gains for biodiversity (and NPPF 179 that opportunities to secure measurable net gains should be pursued). It is inexplicable therefore that MM 31.3 deletes the requirement to provide biodiversity net gain (deleted paragraph 18). Its replacement – the ‘expectation of incorporating biodiversity measures in building design’ (see proposed paragraph 20) does not appear to meet the requirements of the NPPF to secure through policies a biodiversity net gain. The proposed text at paragraph 12 (the ‘expectation’ of “…a net positive effect on the local Green Infrastructure network”) is not an effective equivalent to securing biodiversity net gain in accordance with the Framework. It is particularly difficult to understand the proposed MM deletion of requiring biodiversity net gain in the context of the Environment Act 2021 have recently secured Royal Assent (and having been well publicised and broadly discussed on its route to the same) and the imminent coming into force of Schedule 14 of that Act (inserting s90A and Schedule 7A into the Town and Country Planning Act 1990 requiring a 10% biodiversity net gain from development). For the reasons set out above we are of the view that the MMs proposed do not result in a Plan which is positively prepared, justified, or effective. The draft Plan does not appropriately release green belt land, leaving a large unmet need for affordable housing whilst making allocations at sites to bolster an otherwise unsustainable location (Lea Castle). It does not provide for a green belt release which seeks to meet current and anticipated future needs nor avoid the need for further green belt boundary reviews either before, or at, the end of the draft Plan period. It is internally inconsistent in its purported prioritisation of both infrastructure and affordable housing provision, and continues to overlook and omit sites which are more policy-compliant than proposed allocations. 7 RCA hearing submission (Matter 3) Appendix 2 : Lavigne Lonsdale report (November 2020) |
|
1126889 |
Gillian |
LPMM2 |
Object |
MM31.1 MM31.2 MM7.4, MM25.1 &2 |
No |
No |
No |
Lea Castle: The whole world is saying NOT to remove anymore wildness, green belt, habitats etc and yet you propose to remove certain green belt boundaries! Secondly, how does human made landscaping help wildlife, flora and fauna which rely on wildness? The fallow deer have now disappeared from the site, even the muntjac have moved on. Thirdly, it states for Lea Castle that attempts must be made to safeguard mature trees - well that's certainly not happened has it, 100s cut down amongst the 1000s of younger ones. Fourthly, the plan refers several times to 'sustainable village'. I cannot see any real sustainability - no solar, no wind, no heat pumps, no hydrogen fuel. How is all the carbon released going to be captured? Trees take years to mature to undo our carelessness. Is the wood used FSC etc? It is all brick, blocks and sand. Fifthly, the removal of the farmers fields to extend the build is criminal. We need locally sourced food in our ever threatened world - less travel miles, less carbon and provides employment in the sowing, harvesting, packaging etc. Finally is there now to be no school with this huge build? So the hundreds of children who will live on the site - where will they go? |
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1298221 |
Homes England |
LPMM14 |
Support |
MM31.2 |
|
|
|
Homes England is the Government’s housing accelerator tasked with using public land and working collaboratively with partners to deliver houses where they are most needed. Within this context, Homes England remains committed to the delivery of Lea Castle Wider Site to help address the housing challenges in Wyre Forest District. We are currently preparing an outline planning application (with accompanying site specific infrastructure delivery strategy) for submission in 2022 to compliment the timeframes for the Local Plan adoption. All necessary technical assessments and supporting documents will be prepared which will demonstrate a deliverable and policy compliant scheme when assessed against the emerging policies in the Local Plan. Comments on the Main Modifications We support the modifications proposed by Wyre Forest regarding Lea Castle Village (Chapter 31: Lea Castle Village). However, since the examination, discussions have been held regarding the suitability of a 3G pitch on the Lea Castle Village site and whether an alternative site would be more appropriate. These conversations are ongoing between the local authority, Sport England, and all other relevant parties. To allow for flexibility in delivery of this facility, we would therefore request that the wording in Policy 31.1 (Reference MM31.2) is amended to “ Retain Retention and upgrading of 3 existing grass playing pitches and changing facilities together with provision of land for either an artificial grass pitch (3G) or an additional grass pitch or alternative suitable outdoor sport/ recreation facilities”. For the avoidance of doubt, we are still committed to facilitating delivery of a 3G pitch for the boroughs needs in line with proposed main modification policy 20.19. |
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1197572 |
Sport England |
LPMM554 |
Support |
MM31.2 |
|
Yes |
|
Sport England supports the proposed modification to part 5 of the policy allocation referencing provision of land for either an artificial grass pitch (3G) or an additional grass pitch, in line with the modifications agreed between the Council and Sport England in the completed Statement of Common ground ( see page 7). |
|
231723 |
Historic England |
LPMM565 |
Support |
MM31.3 |
|
|
|
Historic England welcomes proposed main modifications MM31.3 - Lea Castle criteria. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1986 |
Support |
MM31.3 |
Yes |
Yes |
Yes |
We are particularly pleased to support the additional clarity and requirements added to Policy 31.2 in new parts 13 and 18. We believe that these considerations will be important in delivering development in line with national planning policy. |
|
817914 |
Environment Agency |
LPMM1181 |
Support |
MM32.1 |
|
|
|
We also support the amended wording to some of the site specifics e.g. Kidderminster Eastern Extension - (Amended criteria for clarity, effectiveness and consistency with sustainable development). |
|
1299299 |
Dr |
LPMM300 |
|
MM32.3 |
|
|
|
MM32.3-4: information, not an objection: Since the Examination took place, I have prepared an article on the irrigation system, which I expect to be published in a forthcoming issue of Transactions of Worcestershire Archaeological Society. I have supplied a copy of the latest draft (it not being quite finished) to an archaeologist advising the developer and can supply it to the Council. |
|
1299299 |
Dr |
LPMM301 |
|
MM32.4 |
|
|
|
MM32.3-4: information, not an objection: Since the Examination took place, I have prepared an article on the irrigation system, which I expect to be published in a forthcoming issue of Transactions of Worcestershire Archaeological Society. I have supplied a copy of the latest draft (it not being quite finished) to an archaeologist advising the developer and can supply it to the Council. |
|
1197572 |
Sport England |
LPMM555 |
Support |
MM32.4 |
|
Yes |
|
Sport England supports the proposed modification to part 2d of the policy allocation 32.3 referencing provision of playing pitches, in line with the modifications agreed between the Council and Sport England in the completed Statement of Common ground ( see page 7). |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1988 |
Support |
MM32.4 |
Yes |
Yes |
Yes |
We welcome the additional commentary on the treatment of the Hoo Brook and in particular the wording regarding the brook corridor’s protection and enhancement as a wetland reserve. This brings welcome clarity to this part of the policy. |
|
1299944 |
Mrs |
LPMM556 |
Object |
MM33.5 |
Yes |
No |
No |
In the case of Pearl Lane, Wyre Forest DC appear to be disregarding their own statements which appear within the local plan in which they state that they will protect green landscapes and historic sites and place development on brownfield sites close to existing employment, services and schools. The proposed site on Pearl Lane is not, as suggested in The Reasoned Justification MM33.5 p338, sustainable “the site lies in a sustainable location with good access to schools and buses”. The proposed site is not close to existing employment, the local primary school is full to capacity and the nearest secondary school is three miles away across the bridge. Furthermore, the only transport system is the number 3 bus route which is regularly delayed due to the extensive traffic problems that are a daily problem in Stourport town centre. Diamond buses were fined £10,000 by the traffic commissioner following their continued poor timekeeping which was due to traffic congestion within the town. In addition, the only means of access to and from Areley Kings is via the one sole bridge across the river. This constantly exacerbates the already congested area through and around the town centre. I question why ED57 MM33.5 p336 “there is an opportunity to design an area of open space in the northern part and conserve archaeology” has been removed. Building on the proposed site in Pearl Lane will not “protect from development areas that are sensitive because of their landscape and heritage assets”. Similarly, ED57 MM33.5 p338 appears to intimate that “the capacity (250 homes) may be exceeded” which is a major concern. Wyre Forest DC received in excess of 250 objections to the proposed development on Pearl Lane, via the website, a petition and postal objections, yet the local plan “consultation” appears to be ignoring these valid objections. I strongly feel that ED57 MM6.11 p47 “focus will be on suitable green field sites such as Pearl Lane” needs to be removed from the local plan. The objections Wyre Forest DC received voiced local residents concerns about the environment, raised air pollution within the town, increased traffic congestion, and the loss of countryside as well as an archaeological historic site. In addition, the inclusion of Pearl Lane is also strongly opposed by Astley and Dunley Council. I feel that the local plan is contradictory. Wyre Forest DC Local Plan Preferred Options Sustainability Report p29 clearly states that “there are significant amounts of brown field land in Stourport without need for urban extension” and yet the plan is to build on greenfield sites despite previous objections. I feel strongly that the local plan is not sound and is not positively prepared. Consequently, Pearl Lane should be removed from the local plan due to the points raised above. |
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1299736 |
Areley Kings, Save Pearl Lane & Dunley Road from Development |
LPMM568 |
Object |
MM33.5 |
No |
No |
No |
Page 336 policy 33.5 point 4. The statement 'There is an opportunity to design an area of open space in the northern part and conserve archaeology' has been deleted. This should remain due to a) the historic roman remains b) lessen the impact on Areley Wood SSSI, the site falls into the buffer zone (Natural England) c) there are desire lines through the hedge in the northern part which are used by walkers from the adjacent development via Cotswold Avenue |
|
1299736 |
Areley Kings, Save Pearl Lane & Dunley Road from Development |
LPMM570 |
Object |
MM33.5 |
No |
No |
No |
3) Page 339 policy 33.9 is the new statement 'the capacity (250 homes) may be exceeded if information is provided to demonstrate highway and education capacity is not constrained.' 250 homes originally mentioned in the local plan is a lot of extra demand on local services for a community like Areley Kings and putting this line in gives the developer an opportunity to increase the figure. We are yet to see the effect of the additional forthcoming development at the bottom of Pearl Lane (Malvern Hills). |
|
1299736 |
Areley Kings, Save Pearl Lane & Dunley Road from Development |
LPMM569 |
Object |
MM33.5 |
No |
No |
No |
Page 338 policy 33.9 Reasoned Justification also concerns residents as the following has been added 'the site lies in a sustainable location with good access to schools and bus services.' This is very subjective as the problem of lack of school places was raised by the County Education spokesperson during the zoom local plan meeting. Indeed the local school on Dunley Road has gone, there are no buses to the nearest Primary School at Princess Way and the Secondary School is a distant 3+ mile distance away at the opposite end of town on the Minster Road, thus exacerbating traffic through the town centre and increasing noise and air pollution for residents. Also, how can it be claimed 'good bus services' when bus company Diamond were issued with a £10,000.00 fine by the traffic commissioner due to punctuality/delay issues specifically relating to the service 3 Areley Kings route. At the public hearing Traffic Commissioner Nick Denton branded the Areley Kings route 'problematic'. Consequently I suggest the additional word of 'sustainable' very subjective. |
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929261 |
Barratt Homes West Midlands |
LPMM2887 |
|
MM33.5 |
|
|
|
Harris Lamb Planning Consultancy (“HLPC”) are instructed to submit Representations to the Wyre Forest Local Plan Main Modifications consultation by Barratt Homes. These representations relate to proposed Main Modification MM33.5 – Pearl Lane / AKR/14. Barratt Homes control the Pearl Lane site and have submitted a full planning application to Wyre Forest District Council proposing the development of the site for 331 dwellings with associated infrastructure and public open space (reference 21/0031/FUL). The proposed Main Modifications seek an amendment to the policy text to refer to the site providing 250 dwellings. The proposed change to paragraph 33.9 of the Reasoned Justification advises that the 250 dwelling capacity may be exceeded if information is provided to demonstrate that local highways and education capacity are not a constraint to development, and subject to meeting all other policy requirements. This statement has now been overtaken by events. WCC County Council Highways have confirmed that the Transport Assessment submitted with planning application 21/0031/FUL demonstrates that there are no highways constraints to the development of a scheme of 331 dwellings. The response of WCC Education has confirmed that education constraints are not a constraint to development, subject to the applicant entering into a S.106 agreement to fund the creation of primary school place provision. Barratt Homes have confirmed that they are happy to enter into such an agreement. The policy text should, therefore, be amended to reflect the latest available information. It should confirm that the site is expected to provide 331 dwellings. |
|
929261 |
Barratt Homes West Midlands |
LPMM2892 |
Support |
MM33.5 |
|
|
|
We also support the proposed changes to Part 6 of the policy text. It is not necessary for a 10 metre buffer to be provided either side of the Astley Aqueduct, and the amended text requiring the scheme to take it into account is entirely appropriate. |
|
929261 |
Barratt Homes West Midlands |
LPMM2894 |
Support |
MM33.5 |
|
|
|
We also support the removal of Part 9 of the policy, that suggested development should front onto Pearl Lane to help manage the new development into the existing urban area. This would result in the loss of a significant number of trees |
|
929261 |
Barratt Homes West Midlands |
LPMM2889 |
|
MM33.5 |
|
|
|
In terms of the other proposed changes to the policy we support the amendment to access being taken from both the Dunley Road and Pearl Lane. This reflects the application submission. |
|
929261 |
Barratt Homes West Midlands |
LPMM2891 |
Support |
MM33.5 |
|
|
|
We also support the reference to removal of Part 4 of the policy, that refers to an area of open space being provided in the northern part of the site and the need to potentially conserve archaeology in situ. It is not necessary for this section of the site to remain open to buffer the settlement of Dunley, which is approximately 450 metres away from the edge of the site at its closest point. The Landscape and Visual Impact Assessment submitted with the application does not suggest there is any sensitivity in terms of the schemes impact on Dunley. The planning application was accompanied by a Geotechnical Study, and a trial trenching report, which have not identified any archaeological constraints to the development of this section of the site. |
|
929261 |
Barratt Homes West Midlands |
LPMM2893 |
Support |
MM33.5 |
|
|
|
We also support the changes proposed to Part 7 of the policy as it is not practically possible to open up the spring fed culvert watercourse that runs through the site given its depth below ground level. |
|
1300164 |
Mr |
LPMM2641 |
Object |
MM33.5 |
No |
No |
No |
Although the Wyre Forest DC local plan contains many statements & assertions about protecting green landscapes & historic sites, placing development on brownfield sites close to existing employment, services & schools, all of this seems to be irrelevant to the case of Pearl Lane. There have been many modifications to the ED57 document including MM6.7vii p38 "protect from development areas that are sensitive because of their landscape & heritage assets" & MM9.3A p84 "development should minimise negative health impacts...providing green spaces". Why is it then that in ED57 MM33.5 p336 "there is an opportunity to design an area of open space in the northern part & conserve archaeology" has now been deleted? Similarly, ED57 MM33.5 p338 now seems to suggest "the capacity (250 homes) many be exceeded". The Reasoned Justification MM33.5 p338 now states " The site lies in a sustainable location with good access to schools & buses". Who says "sustainable". The main secondary school is a distant 3 miles away right over the other side of town & the bus service is very poor, as anybody in Areley Kings would tell you. Buses are regularly delayed due to problems getting over the sole bridge due to congestion in the town centre. Indeed, the Areley Kings route was the subject of a £10,000.00 fine by the traffic commissioner. here is also virtually no employment on the Areley Kings side. Approximately 250 people objected to proposed development on Pearl Lane via the Wyre Forest DC planning portal & a petition, yet the local plan "consultation" seems to be doing exactly the opposite in the case of Pearl Lane by ignoring objections, proposing to destroy green landscapes (with a historic site) & placing development away from schools, railways & employment. I feel that statement ED57 MM6.11 p47 "focus will be on suitable green field sites such as Pearl Lane" needs removing from the local plan. Not only due to the negative effect development would have on the residents & environment, but also it contravenes the WFDC Local Plan Preferred Options Sustainability Report p29 statement "there are significant amounts of brownfield land in Stourport without the need for urban extension". Sadly, the local plan is in danger of being contradictory claiming one set of values but choosing to do the opposite. Consequently, unless Pearl Lane is removed I consider the local plan not sound & not positively prepared. The inclusion of Pearl Lane is also strongly opposed by neighbouring authority Astley & Dunley Council. |
|
231691 |
Worcestershire Wildlife Trust |
LPMM1990 |
Support |
MM33.6 |
Yes |
Yes |
Yes |
We welcome the amendments made to Policy 33.7. We are pleased to support the changes made in (renumbered) parts 5,6 and 7 and welcome the additional clarity they bring. This should help to make the policy more effective. |
|
1197572 |
Sport England |
LPMM557 |
Object |
MM33.7 |
|
No |
|
The proposed modifications to para 33.12 and policy allocation 33.8 (Land west of former school site Coniston Crescent) do not address Sport England’s objection to the loss of the existing golf course without equitable mitigation in line with para 99 of the NPPF, as explained in Sport England’s previous representations and summarized in the completed Statement of Common ground (see page 8-11) |
|
1197572 |
Sport England |
LPMM558 |
Object |
MM33.12 |
|
No |
|
The proposed modifications to para 33.27 & 33.28, and policy allocation 33.16 (School site Coniston Crescent) do not address Sport England’s objection to the loss of playing field without equitable mitigation in line with para 99 of the NPPF and Sport England’s Playing Fields Policy and Guidance, as explained in Sport England’s previous representations and summarized in the completed Statement of Common ground (see page 8-12) |
|
536839 |
Taylor Wimpey West Midlands |
LPMM3065 |
Object |
MM33.12 |
|
|
|
Harris Lamb Planning Consultancy (“HLPC”) are instructed to submit representations to the Wyre Forest District Local Plan Main Modifications Consultation by Taylor Wimpey. Our representations relate to proposed Main Modification MM33.12 - Proposed Changes to Policy 33.16 - School Site Coniston Crescent MI/38. The proposed Main Modifications seek to amend the policy text to advise that “vehicular access to should be taken from the Kingsway adjacent to the allotments.” The Reason for the Change given is to amend the criteria for clarity and effectiveness. As detailed in our Representations to the Submission Plan and our Hearing Statements it is our view that the policy should refer to vehicular access being taken from either the Kingsway or Coniston Crescent. Indeed, of the two proposed access points it is clear that Coniston Crescent should be the preferred option. The Kingsway access necessitates development within the Green Belt, unlike Coniston Crescent. Attached to Appendix 1 of these Representations is a copy of the Committee Report for planning application 21/0030/FUL. This planning application proposed the development of 110 dwellings, including 18 affordable units, together with associated infrastructure, access and public open space at site 33.16 - School Site Coniston Crescent MI/38. The application was submitted as a ‘full’ application. Access was proposed off Coniston Crescent. As confirmed in Section 2.2 of the Committee Report Worcestershire County Council Highways have no objection to the scheme on highways grounds. It is confirmed that whilst it is acknowledged that Coniston Crescent is likely to generate objections from existing residents in the local community, the highway is in an appropriate standard to accommodate the increased traffic during the school drop off and pick up periods. As detailed in paragraphs 4.54 through to 4.61 the District Council have appointed independent Highways Consultants (Hub Transport Planning) to review the Transport Assessment. The HTP Assessment concludes that “it would (the Coniston Crescent access) not have an unacceptable impact on highway safety nor would the traffic have a “severe” impact on the operation of the local highways network”. There is, therefore, no technical reason why the Coniston Crescent access should not be supported. Whilst Members refused to grant planning permission for the development contrary to the Officers recommendation on highways grounds there is no evidence to underpin any suggestion that Coniston Crescent is not a suitable access. Furthermore, the development of the Kingsway access will introduce additional built development in the Green Belt. It is necessary to create a road between the edge of the development site and the Kingsway urbanising this section of Green Belt. The road would result in additional building material being required, that is less sustainable than using the Coniston Crescent access. It would also result in significantly increased development costs, that would reduce the quantum of affordable housing that can be provided on viability grounds. This matter was agreed with Officers during the course of the determination period. It is, therefore, our view that Main Modification 33.12 should be revised to refer to access being taken from either Coniston Crescent or The Kingsway given that there are no technical issues associated with the Coniston Crescent access. This modification is required for the plan to be found sound. Suggesting that development should be take from the Kingsway as opposed to Coniston Crescent is not “justified” (NPPF 33.b) or “consistent with national policy” (NPPF 33.5) given that the development of the Kingsway access will result in development within the Green Belt when a non Green Belt option is available. Supporting documents for this response are included at Appendix 6 of this Summary of Responses. |
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1197572 |
Sport England |
LPMM559 |
Object |
MM33.17 |
|
No |
|
The proposed modification to the final line of para 33.38 is not factually accurate to describe the type of existing artificial grass pitches (AGP’s). The existing AGP’s are sand dressed hockey pitches, not 3G AGP’s which are a different type of surface filled with rubber crumb. There are no 3G pitches currently at Stourport Sports Club, but there are three sand AGP’s for hockey. The reference to football/3G AGP’s is incorrect and should be removed from the proposed modification. |
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1299737 |
Bewdley Civic Society |
LPMM571 |
Support |
MM34.2 |
Yes |
Yes |
Yes |
The Bewdley Civic Society has considered the document Local Plan (July 2021) as it affects Bewdley. We note 34.2 and 34.4 and have no objection to either of these. |
|
1299727 |
Mrs |
LPMM439 |
Object |
MM34.3 |
No |
No |
No |
NO NO NO Green belt land must not be built on under any circumstances. That’s why it’s green belt….protecting open spaces, flora and fauna for future generations. If allowed to be developed it would never be returned to open land destroyed forever. I do not believe that the suggested development is for local people and any incoming population will only add further crises to our roads, schools and local facilities. There are insufficient jobs in this area too meaning that any incoming population will have to travel out of the district for work creating further traffic problems. Specifically the Stourport road triangle will create such intense traffic problems….it’s a major source of traffic fumes and congestion as it is now. The land should always remain in green belt for all the wildlife that has existed there for many many years |
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1199839 |
Euro Property Investments Ltd. |
LPMM1916 |
Support |
MM34.3 |
Yes |
Yes |
Yes |
Harris Lamb Property Consultancy are instructed by Euro Property Investments Ltd. (“EPIL”) to submit representations to the Proposed Modifications Consultation to the Wyre Forest Local Plan. Paragraph 34.7 We support the introduction of the revised text that confirms that the site is to be allocated for approximately 100 homes with access from Stourport Road. EPIL currently have a planning application lodged with the Council seeking outline planning permission for up 100 dwellings which was submitted to accord with the draft policy at the time. The revised wording provides the opportunity to seek approval for in excess of 100 units if desired. We, therefore, welcome the Similarly, we agree that access to the site should be taken from Stourport Road. The submitted outline planning application is submitted with all matters reserved apart from access. The access Policy 34.2 Stourport Road Triangle We refer to the numbers used in the Proposed Modifications Document. 1. The change confirms that access is to be taken off Stourport Road. As noted above, we support this change and confirm that the current outline planning application proposes such an access arrangement into the site. The proposed change is acceptable to EPIL. 2. We agree and support the clarification that states that the northern part of the site should remain as open space as it is part of the former walled garden. We also support the deletion of the requirement to provide pedestrian gate through the retained brick wall and reiterate again that the representor does not have legal title to the wall and, therefore, would not have the ability to comply with such a requirement. Notwithstanding this, a new footpath connection from the western extent of the site onto Stourport Road close to the 3. We have no objection to the introduction of the word ‘The’ to this part of the policy. 4. We welcome the change to the policy that seeks to restrict storey height to the equivalent of two storeys noting that in doing so, this would allow the roof space to be used for additional accommodation if needed or desired. This change addresses our concern and provides the flexibility that we were seeking. In proposing the change, we note that this will not result in an adverse impact on nearby heritage assets so again are content with these changes to the policy. 5. We have no objection to the requirement to provide enhanced green infrastructure to the Riddings Brook in the form of a buffer strip. The current masterplan submitted in support of the outline application incorporates such a buffer and therefore, we are happy that the submitted scheme is in accord with the proposed change. 6. We welcome the deletion of the two requirements to provide SUDs and a Flood Risk Assessment. Both requirements are covered elsewhere and are not, therefore, needed in the policy. We support this change. 7. We have no objection to the requirement to provide a noise survey to support development on the site. EPIL have done this as part of the outline planning application and agree that the findings of the survey will be used to inform any mitigation that is required in order to deliver an acceptable noise environment for new residents on the site. The exact mitigation required will be determined at the time when approval of reserved matters is sought as this will relate to the detailed planning layout under consideration, as opposed to an indicative masterplan. 8. We have no objection to the requirement to supplement hedgerows on the site in order to help create connectivity to the woodland to the north. Paragraph 34.8 We welcome the introduction of the text in this paragraph confirming that the site is a sustainable location and that it will help meet the housing needs of Bewdley. Similarly, we welcome the clarification on the building height point in that rooms in the roof would equate to a third storey but would not necessarily increase the height of the proposed dwellings. This provides an acceptable way forward for EPIL. We, therefore, ask that you take our comments into consideration and note our general support for the changes that you are now proposing to make to the Plan. Should there be a need to comment on the Plan further, we ask that we are informed of this process. Otherwise, we trust that you have everything you need and that you are able to conclude the consultation and Examination process. |
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1299737 |
Bewdley Civic Society |
LPMM572 |
Support |
MM34.4 |
Yes |
Yes |
Yes |
The Bewdley Civic Society has considered the document Local Plan (July 2021) as it affects Bewdley. We note 34.2 and 34.4 and have no objection to either of these. |
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231577 |
Persimmon Homes Limited |
LPMM3140 |
Object |
MM34.4 |
Yes |
No |
No |
RPS support the majority of the modifications in relation to MM34.4, notably the increase to the scale of the proposed allocation from 75 to 80 dwellings. RPS consider that this quantum is grounded in evidence, and draws on capacity plans shared with the Council. For clarity, RPS can confirm that there will be no impact on the existing lay-by, as requested by the Council’s proposed addition to the policy. The proposed access will not encroach on this land either directly or indirectly, and this aspect of the policy can be satisfied. However RPS has some main points of concern. Firstly, there is an error on the Proposals Map which relates to section 7 of the policy. RPS advocate that the entire parcel (including the western flank adjacent to the existing north-south footpath) is taken out of the Green Belt to ensure that the proposed western footpath and cycle link can be provided easily alongside other necessary infrastructure such as the Pumping Station. It will be difficult to deliver a comprehensive scheme unless this is achieved. We have made separate representations on the matter in relation to the Proposals Map. Secondly, it is noted that Persimmon Homes are proposing to gift the western land parcel (to the east of the church) to the Town Council. This is not a policy requirement but a proposal willingly offered during our discussions, creating a wider compensation benefit to support the Local Plan. As such, RPS therefore question the need for further planning contributions to bring forward improvements to the rear of Lodge Close. Lastly, RPS observe the need to connect to the wider footpath network where feasible. This principle is supported, though RPS consider that the policy should be more specific – noting the potential connection to Route 648(B) to the west, to avoid any ambiguity about what the wider network refers to. |
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541228 |
Mr |
LPMM567 |
Object |
MM/36.2 |
|
No |
|
I objected to this site in 2018 as being an unsustainable location, in open countryside, and too remote from the settlement boundary of Far Forest. The main modification (MM/36.2) contains factual errors: the site is not previously developed land because it is agricultural (as defined by Sec 336 of the 1990 Act) and therefore contradicts the definition of pdl as set out in the NPPF (paras 70/71). Also it is not 'located just outside the settlement boundary at Far Forest,' it is some 150m from the western boundary of the proposed settlement boundary. This site should be remove from the Local Plan, as it is not a sustainable location and is contrary to the NPPF. |
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260520 |
Campaign to Protect Rural England |
LPMM302 |
|
MM36.1 |
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MM36.1 As in MM18.2 the use of data from the Housing Register is inappropriate, unless this is explicitly limited to persons on the Register who have a close link to the Far Forest area, for example by living there, working there, or having relatives there who need care. |
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260520 |
Campaign to Protect Rural England |
LPMM303 |
|
MM36.2 |
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|
As in MM18.2 the use of data from the Housing Register is inappropriate, unless this is explicitly limited to persons on the Register who have a close link to the Far Forest area, for example by living there, working there, or having relatives there who need care. |
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1298333 |
Mr |
LPMM15 |
Object |
MM36.2 page 383 |
No |
No |
No |
I'm not qualified to say if the document is legally compliant therefore I have had to tick "no" because there is not a N/A option. The plan still includes the Bill White Nursery (also recently called Lem Hill Nursery) and clearly has difficulty with the justification because it states the need to retain and strengthen hedges and set back from the road to retain the rural nature of the location, and the danger of water contamination into the nearby SSSI. In my mind this site is outside the village boundary and hence should not be a development site. The plan talks about other sites in the Far Forest area having been considered but rejected due to ecology issues. This is surely not "reasoned justification" to include the nursery site; in fact if you consider other local sites difficulties then this site may share those issues. Other local applications have been rejected due to concerns over traffic on the main road, and yet this proposed development will suffer the same traffic issues. Any development in this area will create significant commuter journeys to find employment, which is contrary to the economic plan. The inclusion of this site does not match the wider justification and aims as stated in the previous 382 pages of the document, hence the site should be removed from the plan. I've spoken with a number of local residents who would like to have responded but they felt that after receiving an email, that contained a letter, that called a web site, that referenced separate documents, and then requested the use of a response portal, that required registration, to record their concerns; well they simply gave up. Many of the residents of Far Forest are older and not ICT literate hence responses received will be biased to the young. |
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1298333 |
Mr |
LPMM576 |
Object |
MM36.2 page 383 |
No |
No |
No |
I have shown my previously provided comments to Mr Gerald Lewis and he has asked me to submit his objections to the plan on the same grounds that I objected. He does not have access to email at this point in time. Gerald believes the inclusion of Bill White Nursery (also recently called Lem Hill Nursery) is inappropriate because it is outside the village boundary, and if developed will just lead to further requests to develop the land between it and the existing village thus creating a large scale development in a small village. The document itself states the need to retain and strengthen hedges and to be set back from the road to retain the rural nature of the location, and the danger of water contamination into the nearby SSSI. The site is outside the village boundary while there is still land available for modest development within the existing village area. The document talks about other sites within the Far Forest area having been considered but rejected due to ecology reasons. This is surely not "reasonable justification" to include the nursery site, rather it is reason to reject the other sites, and if anything it should suggest that the difficulties experienced with those sites are likely to be shared with this site. Other local planning applications have been rejected due to concerns over traffic on the main road, and yet this proposed development will suffer the same traffic issues. Any development in this area will create significant commuter journeys to find employment, which is contrary to the economic plan, and will remove one of the few employment opportunities within Far Forest. There is ample scope in the plan to expand Kidderminster to the east, plus development in Bewdley and Stourport, to enable all targets to be achieved, and these are areas with demand, infrastructure, and employment opportunities. The site at Far Forest does not fit with the other logical expansion required within the Wyre Forest area. Other local residents also object to the inclusion of this site within the greater plan but they are frustrated in expressing their concerns due to the complexity of the consultation process. |
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260520 |
Campaign to Protect Rural England |
LPMM304 |
|
MM36.3 |
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|
|
As in MM18.2 the use of data from the Housing Register is inappropriate, unless this is explicitly limited to persons on the Register who have a close link to the Far Forest area, for example by living there, working there, or having relatives there who need care. |
|
1225187 |
Mrs |
LPMM2455 |
Object |
MM36.5 |
No |
No |
No |
MM36.5 • The site is accessed from Station Drive adjacent to the level crossing. There is no existing access into the site from Lynwood Drive, a residential cul de sac, and therefore this point is factually incorrect in the draft Local Plan and should be corrected. It raises a concern that it infers an existing right of access onto Lynwood Drive that does not exist; • The evidence base for the need for such a large development of parking was flawed to begin with; and the evidence and growth forecasts provided by SLC Rail have not been tested. In addition, I would argue they are no longer relevant given the pandemic (I refer you again to the fact that commuter passenger numbers remain at 45% of pre pandemic levels nationally (see BBC) and demand within Blakedown itself is negligible); • The treatment of Kidderminster and Blakedown Stations should not be interchangeable. Kidderminster has more frequent and varied services, hence its greater use. Creating additional parking at Blakedown with a less frequent and frankly, at the moment at least, an utterly unreliable service will not attract commuters to park there; even if people were using trains to travel to work, which clearly they are not. Blakedown should not be used as the scapegoat because the authorities have failed to solve a parking problem at Kidderminster Station and the quality of life for Blakedown residents should not be sacrificed for a perceived parking need that is no longer there; • WFDC have also not sufficiently considered the potential for expansion of Kidderminster Station car park to accommodate the perceived need for the transport hub; nor have they collaborated with neighbouring local authorities to identify more practical/viable transport hub. FFor example, Hartlebury Station (Wychavon District Council) is arguably more accessible to residents of the southern and western sides of Kidderminster, Bewdley and Stourport; it is adjacent to large parcels of brownfield land and has a significantly more appropriate surrounding road network than the narrow village streets and often single file country lanes approaching Blakedown. I would challenge WFDC to be more holistic in their approach; just because Blakedown is the only alternative station in the WFDC area, does not make it the right answer to any perceived transport needs; • The lapsed planning consent for Station Yard 08/0430/FULL - Change of use to car park, landscaping and associated works was for only 34 cars, so the current proposal is a significant increase and again the need has not been adequately evidenced by WFDC. Additionally, that lapsed planning permission contained numerous conditions to safeguard the amenity of neighbouring residents including landscaping, lighting, hours of use, and retention of boundary trees – many of which have now been removed. (Again please also refer to 19/0380/FULL as highlighted above); • In the recently refused application for residential development of Station Yard 14/0661/OUTL, there was concern by the Planning Officer about significant loss of amenity to residents of neighbouring houses on Lynwood Drive and Swan Close. This view was shared by the Planning Inspector at Appeal. The proposed access/egress to the car park from Lynwood Drive only serves to exacerbate that situation. • Lack of detail and consideration of highways issues, access and proximity to level crossing. Junction layouts, in particular the proximity to A456/Station Drive, Lynwood Drive and Roxall Close and proximity to level crossing will cause significant access issues into and out of the site; • In addition, should the development of Green Belt land at (WFR/CB/3) off Station Drive and opposite Lynwood Drive go ahead, as is proposed in the current draft of the WFDC Local Plan, then the combination of additional traffic from that plus the Station Yard development could create up to 400 additional vehicle movements a day at a junction and on roads that are not designed to cope with that level of traffic . (Again please also refer to 19/0380/FULL as highlighted above); • The road network in immediate vicinity of site is inappropriate for such an intensification of use. It is designed to primarily serve a small residential area. Lynwood Drive is a cul de sac of circa 35 houses. Lynwood Drive/Station Drive were not designed to cope with 180+ additional vehicle movements per day associated with an 87 space station car park; • Requirements for traffic calming and on street parking management have not been considered; • Concern over use of unsuitable country lanes; already congested A and B road network to reach Blakedown station namely: • There are significant numbers of school children who utilise the train station to get to nearby secondary schools arriving at the station from all directions; and the proposed increase in traffic will bring additional safety risks for them; • Additionally, there are significant numbers of school children and their families who walk to school using Churchill Lane, Mill Lane, Sculthorpe Crescent, Lynwood Drive and Station Drive to get to Blakedown Primary School with a considerable number of parents using Station Drive/Lynwood Drive as a short term parking option for drop off and pick up of both primary and secondary school children. That has an implication both for the safety of pedestrians and the flow of traffic during the morning peak period in general and in particular for the junction of Churchill Lane and Mill Lane which narrows to single file and has no pavement for pedestrians from that junction up to the junction with Sculthorpe Crescent; • Additionally, there significant numbers of horse riders, dog walkers and ramblers who regularly use the surrounding country lanes and increased traffic will again create a safety issue for them; • Should the proposed development go ahead, careful consideration needs to be given to a number of safety concerns namely: It is in fact feasible that this proposal would drive local residents to using their cars far more for short distances and certainly between the two villages of Churchill and Blakedown as it would be deemed safer than being a pedestrian which could isolate the villages from each other and create unnecessary vehicle journeys and pollution; • Loss of amenity to neighbouring houses due to traffic and pollution; • Residents of Station Drive, Lynwood Drive and Mill Lane will suffer from all during current rail operating hours of circa 06.00 to 23.30 - ie anti-social residential hours in mornings and evenings based in the current rail timetable which we anticipate could be changed to reflect the increased use of the Station; • In the recently refused application 19/0380/FULL, relating to a proposed change of use for a residential home in Roxall Close (off Lynwood Drive) to be used for business purposes, the application was rejected by WFDC on the grounds of dangerous vehicle movement on Lynwood Drive and Roxall Close not suitable for a solely residential area. The Council said “the additional and frequent vehicular movements to and from the property are considered to be harmful to the amenities and ambience of this otherwise solely residential area”. • Please also refer to Planning Inspector’s Appeal Decision re APP/R1845/W/19/3234813 dated 18 December 2019, In particular paragraphs: 9. To my mind and based on all that is in the evidence before me, the use generates a discernible level of activity over and above the activities associated with the predominantly residential uses on the street. The regular comings and goings associated with the business activities are out of step with the quiet residential character of the area. 10. For the foregoing reasons I conclude that the development unacceptably harms the character of the area. That change of use application would have only added at the most 10 to 20 daily additional vehicle journeys to this residential neighbourhood not the potential for 180 under the proposal for the car park at Station Yard. Finally, per my point above, I can see no evidence whatsoever that WFDC have considered the joint impact of developing the land at Station Yard for car parking and the development of the Green Belt land in Blakedown (WFR/CB/3) for affordable housing development/parking. The cumulative effect on road traffic up to a potential of 600 additional vehicle movements on small village roads per day assuming: • 174 vehicle movements if all proposed spaces at Station Yard are utilised; would completely overload the A456/Station Drive/Lynwood Drive junctions, particularly when you consider the proximity to the level crossing. It will have a serious negative impact on a village road network not suitable to such a volume of additional vehicle movements; and significantly increase risks for both road traffic and pedestrian safety (including significant numbers of school children travelling to and from the village primary school and using the station for travel to high school). Not to mention the detrimental effect on local residents living in the Station Drive/Lynwood Drive/Roxall Close/Mill Lane/Mill Close/Sculthorpe Road.
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231629 |
Churchill & Blakedown Parish Council |
LPMM3943 |
Object |
MM36.5 |
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The evidence base for the requirement of land at Station Yard, Blakedown, is flawed The statistics and growth forecasts adopted by SLC Rail have not been verified or tested. Blakedown has a limited need for additional parking spaces by 2043. The evidence base in SLC Rail’s Report pre-dates that used in Worcestershire County Council’s LTP4 Report. It is contradictory and embellishes the need for further parking in Blakedown. The additional evidence produced by the Council contradicts that of Worcestershire County Council’s LTP 4 and appears to be based on unsubstantiated evidence. The future need for parking has been manufactured to justify the substantial urban extension at Lea Castle, which is clearly going to have significantly adverse impacts upon the surrounding infrastructure. Effect of Covid Pandemic Given commuter passenger numbers remain at 45% of pre pandemic levels nationally (see BBC) and demand within Blakedown itself is negligible we would question whether the development is in fact required at all. The treatment of Kidderminster and Blakedown Stations should not be interchangeable Kidderminster has more frequent and varied services, hence its greater use. Moving a perceived (and questioned) car parking requirement 3 miles along the road to meet WCC’s plans will not solve the problem. The identified housing sites in The Plan to the eastern side of Kidderminster are not sustainable in transport terms which has caused the “push” eastwards to Blakedown The proposed extension to the eastern side of Kidderminster and Lea Castle has resulted in significant sustainability concerns in terms of the capacity for Kidderminster to support such growth from a transport point of view. The Council have effectively pushed the additional growth and transport pressures from Kidderminster on to Blakedown. Using a small scale village such as Blakedown to overcome the sustainability issues of Kidderminster fundamentally undermines the sustainability credentials of this Local Plan. The Council’s approach is contrary to NPPF A proper assessment of alternative potential sites, including both non-Green Belt and Green Belt locations does not appear to have been carried out, especially in co-operation with neighbouring Authorities. The Council has not demonstrated proper regard to sustainable development objectives, or that the proposed brownfield and green belt sites are the most sustainable options taking account of all relevant factors including travel impacts, loss of amenity, and seriously compromising the basic purposes of including land in Green Belts. In particular, Hartlebury Station (Wychavon District Council) is arguably more accessible to residents of the southern and western sides of Kidderminster, Bewdley and Stourport, and which is adjacent to large parcels of brownfield land. No regard to the adopted Churchill & Blakedown Neighbourhood Plan Adequate requirements for traffic calming and on street parking management have not been considered Lack of detail and consideration of highways issues, access and proximity to level crossing Junction layouts, in particular the proximity to A456/Station Drive, Lynwood Drive and Roxall Close and proximity to level crossing will cause significant access issues into and out of the site. In addition, should the field opposite the entrance to Lynwood Drive be released from Green Belt for housing development, as is proposed in the current draft of the WFDC Local Plan, then the combination of additional traffic from that plus the Station Yard development will further exacerbate the situation potentially creating in excess of 150 additional vehicle journeys at a junction and on roads that are not designed to cope with that level of traffic The site is accessed from Station Drive adjacent to the level crossing. Policy states “This narrow site is accessed off Lynwood Drive and lies adjacent to the main railway line”. There is no access into the site from Lynwood Drive, a residential cul de sac. It is accessed from Station Drive. Road network in immediate vicinity of site is inappropriate for such an intensification of use It is designed to primarily serve a small residential area. Lynwood Drive is a cul de sac of circa 35 houses. Lynwood Drive/Station Drive were not designed to cope with 174+ additional vehicle movements per day associated with an 87 space station car park. Concern over suitability of wider local road network - use of unsuitable country lanes; already congested A and B road network to reach station and increased speeding: The surrounding road network that would be used to bring traffic into Blakedown comprises narrow country lanes and already congested A and B roads.
Safety of pedestrians and other road users There are significant numbers of school children who utilise the train station to get to nearby secondary schools arriving at the station from all directions; and the proposed increase in traffic will bring additional safety risks for them. Additionally, there are significant numbers of school children and their families who walk to school using Churchill Lane, Mill Lane, Sculthorpe Crescent, Lynwood Drive and Station Drive to get to Blakedown Primary School with a considerable number of parents using Station Drive/Lynwood Drive as a short term parking option for drop off and pick up of both primary and secondary school children. That has an implication both for the safety of pedestrians and the flow of traffic during the morning peak period in general and in particular for the junction of Churchill Lane and Mill Lane which narrows to single file and has no pavement for pedestrians from that junction up to the junction with Sculthorpe Crescent. Additionally, there significant numbers of horse riders, dog walkers and ramblers who regularly use the surrounding country lanes and increased traffic will again create a safety issue for them. Should the proposed development go ahead, careful consideration is needed of:
No consideration has been given to the use of The Avenue which will inevitably become a short cut for pedestrians, not Lynwood Drive, which is, for the most part, simply a dirt path and unsuitable for commuters and particularly wheelchair users. It is feasible that this proposal would drive local residents to using their cars more for short distances (and certainly between the two villages of Churchill and Blakedown) as it would appear safer than being a pedestrian. This could isolate the villages from each other and create unnecessary vehicle journeys and pollution. Loss of amenity to neighbouring houses due to traffic and pollution. Residents of Station Drive, Lynwood Drive and Mill Lane from traffic, intensification of use of both sites, light and noise pollution, extended hours of use over and above the levels of historic activity on Station Yard. Residents of Station Drive, Lynwood Drive and Mill Lane will suffer from
All during current rail operating hours of circa 06.00 to 23.30 - ie anti-social residential hours in mornings and evenings based on the current rail timetable which we anticipate could be changed to reflect the increased use of the Station. Planning precedent relating to compromised Access, over intensification of use of site and loss of amenity to neighbouring residents Application for residential development of Station Yard 14/0661/OUTL, was refused due to significant loss of amenity to residents of neighbouring houses on Lynwood Drive and Swan Close. This was shared by the Planning Inspector at Appeal. The proposed access/egress to the car park from Lynwood Drive only serves to exacerbate that situation. The lapsed planning consent for Station Yard 08/0430/FULL - Change of use to car park, landscaping and associated works was for only 34 cars, so the current proposal is a significant increase. That permission contained numerous conditions to safeguard the amenity of neighbouring residents including landscaping, lighting, hours of use, and retention of boundary trees – many of which have now been removed. 19/0380/FULL, relating to a proposed change of use for a residential home in Roxall Close (off Lynwood Drive) to be used for business purposes, the application was refused by WFDC on the grounds of dangerous vehicle movement on Lynwood Drive and Roxall Close not suitable for a solely residential area. The Council said “the additional and frequent vehicular movements to and from the property are considered to be harmful to the amenities and ambience of this otherwise solely residential area”. Planning Inspector’s Appeal Decision APP/R1845/W/19/3234813 18 Dec 2019 In particular paragraphs: 9 To my mind and based on all that is in the evidence before me, the use generates a discernible level of activity over and above the activities associated with the predominantly residential uses on the street The regular comings and goings associated with the business activities are out of step with the quiet residential character of the area 10. For the foregoing reasons I conclude that the development unacceptably harms the character of the area. That change of use application would have only added at the most 10 to 20 daily additional vehicle journeys to this residential neighbourhood not the potential for 174+ under the proposal for the car park. 21/0030/FUL - Stourport High School And Sixth Form Centre And Playing Fields Coniston Crescent Stourport On Severn Erection of 110 dwellings including 28 affordable units was refused on 18 November 2021 on the grounds of 1 The proposed would significantly increase traffic movements via single point of access onto Coniston Crescent which would result in an unacceptable impact on highway safety to all users of the highway network, including pedestrians, particularly at peak school drop off and pick up times, and that the residual cumulative impacts of vehicle movements on the surrounding road network would be severe. As such a safe and suitable access cannot be provided to the development as required by paragraphs 110 and 111 of the National Planning Policy Framework. Significant weight is given to Policy 33.16 of the Emerging Wyre Forest Local Plan, which states that access for this development site should be provided from Kingsway. To approve the development with the proposed access in these circumstances would be contrary to Policy CC1 of the Site Allocations and Policies Local Plan, Policies 13 and 33.16 of the Emerging Wyre Forest Local Plan and Government advice in the National Planning Policy Framework. |
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231629 |
Churchill & Blakedown Parish Council |
LPMM5638 |
Object |
MM36.5 |
|
|
|
Negative Effect of these Policies on Local Amenity in Isolation and Cumulatively The cumulative effect if both Policies are adopted and the sites subsequently developed would cause significant harm to the amenity of residents nearby and users of most of the roads in the area. If Station Yard is developed with up to 87 spaces as currently proposed by WCC would create circa 180 additional vehicle movements per day. If Station Drive is developed with 50 houses (each with 2 cars being used twice per day on average) could create 200 additional movements per day. This would mean an additional 380 journeys using Station Drive and/or the A456 junction and almost half of those vehicles turning into the residential cul de sac of Lynwood Drive. Until proposals are confirmed for the reserved land for extra parking at Station Drive the overall cumulative impact is uncertain, but if the “Developer Option” is put forward as outlined in IFT03 - SLC Rail’s Report For Worcestershire County Council on Blakedown Station Car Park Options 27th June 2019 , being 50 dwellings plus 170 car spaces the latter could generate a further 340 movements per day ie a total of 720 vehicle movements. |
|
1188945 |
Marmaris Investments Ltd. |
LPMM13 |
Object |
MM36.6 |
Yes |
No |
No |
“and part of the site, the location of which is to be established following an appropriate study, is safeguarded for parking spaces for station related use. The reservation of this land for car parking will be reviewed by monitoring of the demand for car parking at Blakedown Station, the projected future requirement for station parking at Blakedown and the amount of parking that can be accommodated on the Station Yard site within the plan period.” |
|
260520 |
Campaign to Protect Rural England |
LPMM305 |
|
MM36.6 |
|
|
|
MM36.6: Evidence given at the examination very clearly showed that the development of this site was wholly unjustified. The justification was formerly providing funding for a station car park, but that has evaporated as parking to be provided at Kidderminster and for 111 cars at Blakedown are now considered adequate. Nevertheless, this is a unique site as it is the only place on the railway line where addition railhead parking could be provided. The site should accordingly remain undeveloped and should remain in the Green Belt. See also comments on MM7.2. MM7.2: This change is unacceptable. The land at Station Road, Blakedown was primarily intended for additional station car parking, which was to be funded by allowing some housing. At the Examination it was established that the requisite parking could be adequately provided at Kidderminster Station and on other land at Blakedown (probably former sidings). Accordingly, there is no purpose in removing site WFR/CB/3 from the Green Belt. Under NPPF, “exceptional circumstances” have to be established for removing land from the Green Belt; and none have been shown. |
|
1225187 |
Mrs |
LPMM2640 |
Object |
MM36.6 |
No |
No |
No |
MM36.6 My objections are as follows: • WFDC have not provided full and adequate evidence to justify the removal of the Green Belt land in Blakedown (WFR/CB/3); • WFDC are relying on an exemption to release land from Green Belt for ‘affordable housing’ and the draft policy states that ‘…any new housing should be provided… to meet any local housing need as shown in a Parish Needs Survey and/or the Housing Register…’. WFDC have not provided any evidence to support such a need in Blakedown and indeed the neighbourhood plan for the local parish, prepared by Churchill & Blakedown Parish Council, in collaboration with and supported by WFDC, does not identify such a need; • If WFDC can evidence such a need and that is then the exemption relied on to release the land from the Green Belt then surely the Local Plan should specify that the land can only be developed for the purpose of providing affordable housing? As it stands currently, the modifications to the plan do not make that stipulation; the draft Local Plan wording only refers to housing not affordable housing and car park provision leaving that land exposed to any kind of development; • In addition, if the land is to be released on the basis of the exemption for affordable housing then surely any reference to its use for car parking as part of WFDC’s ambition to create a transport hub should be removed? • NPPF paragraph 150 C provides that local transport infrastructure which can demonstrate a requirement for a Green Belt location may not be inappropriate development, but the Draft Local Plan does not adequately consider the potential for expansion of Kidderminster Station Car park or of neighbouring authorities allocating more suitable sites for a “transport hub” before seeking to remove WFR/CB/3 from Green Belt; • I would highlight ED20B – Technical Note 2 – Summary of Site Assessments which says: The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road. The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. The draft Local Plan utterly fails to respect the contribution made by this site and appears to be going ahead with its removal from Green Belt in advance of the review of the Green Belt boundary within the District having been undertaken or WFDC having presented evidence to demonstrate that such a review has been completed to an adequate standard; • No evidence of local housing need has been provided to justify Policy WFR/CB/3, and it appears the Plan is confused between District Wide and Local/village specific future housing requirements and indeed the neighbourhood plan for the local parish, prepared by Churchill & Blakedown Parish Council, in collaboration with and supported by WFDC, does not identify such a need; • The evidence based is flawed; the statistics and growth forecasts adopted by SLC Rail have not been verified or tested and are almost certainly out of date given the pandemic and I refer again to the fact that national commuter numbers are only at 45% of prepandemic levels; • Blakedown has a limited need for additional parking spaces by 2043; • The evidence base in SLC Rail’s Report pre-dates that used in Worcestershire County Council’s LTP4 Report; • It is contradictory and embellishes the need for further parking in Blakedown; • The additional evidence produced by the Council contradicts that of Worcestershire County Council’s LTP 4 and appears to be based on unsubstantiated evidence; • The future need for spaces has been manufactured to justify the substantial urban extension at Lea Castle, which is clearly going to have significantly adverse impacts upon the surrounding infrastructure; • The treatment of Kidderminster and Blakedown Stations should not be interchangeable; • Kidderminster has more frequent and varied services, hence its greater use and popularity; • Moving a perceived (and questioned) car parking requirement 3 miles along the road to meet WCC’s plans will not solve the problem; • The Council has failed to demonstrate the need for the very large number of spaces in this location proposed now and in future; The identified housing sites in The Plan to the eastern side of Kidderminster are not sustainable in transport terms which has caused the “push” eastwards to Blakedown; • The proposed extension to the eastern side of Kidderminster and Lea Castle has resulted in significant sustainability concerns in terms of the capacity for Kidderminster to support such growth from a transport point of view; • The Council has effectively pushed the additional growth and transport pressures from Kidderminster on to Blakedown; • Using a small scale village such as Blakedown to overcome the sustainability issues of Kidderminster fundamentally undermines the sustainability credentials of this Local Plan Review; • The Council’s approach is contrary to NPPF; no exceptional circumstances have been demonstrated to remove this land from the Green Belt; • A proper assessment of alternative potential sites, including both non-Green Belt and Green Belt locations does not appear to have been carried out, especially in co-operation with neighbouring Authorities; • The Council has not demonstrated proper regard to sustainable development objectives, or that the proposed brownfield and green belt sites are the most sustainable options taking account of all relevant factors including travel impacts, loss of amenity, and seriously compromising the basic purposes of including land in Green Belts; • In particular Hartlebury Station (Wychavon District Council) is arguably more accessible to residents of the southern and western sides of Kidderminster, Bewdley and Stourport, and which is adjacent to large parcels of brownfield land; • Given commuter passenger numbers remain at 45% of pre pandemic levels nationally (see BBC) and demand within Blakedown itself is negligible we would question whether the development is in fact required at all; • Over intensification of use of site and loss of amenity to neighbouring residents; • Compromised Access : residents of Station Drive, Lynwood Drive and Mill Lane and surrounding areas will suffer from traffic intensification, light and noise pollution; • In the recently refused application 19/0380/FULL, relating to a proposed change of use for a residential home in Roxall Close (off Lynwood Drive) to be used for business purposes, the application was rejected by WFDC on the grounds of dangerous vehicle movement on Lynwood Drive and Roxall Close not suitable for a solely residential area. The Council said “the additional and frequent vehicular movements to and from the property are considered to be harmful to the amenities and ambience of this otherwise solely residential area”. • Please also refer to Planning Inspector’s Appeal Decision re APP/R1845/W/19/3234813 dated 18 December 2019, In particular paragraphs: 9. To my mind and based on all that is in the evidence before me, the use generates a discernible level of activity over and above the activities associated with the predominantly residential uses on the street. The regular comings and goings associated with the business activities are out of step with the quiet residential character of the area. 10. For the foregoing reasons I conclude that the development unacceptably harms the character of the area. That change of use application would have only added at the most 10 to 20 daily additional vehicle journeys to this residential neighbourhood not the potential for 180 under the proposal for the car park at Station Yard. • No “Exceptional Circumstances” have been evidenced or reasoned to justify the removal of this site from the Green Belt; • The proposal allocation fails on all 5 purposes of the Green Belt – sprawl, merging, encroachment, character, urban regeneration; • It is unnecessary and is not supported by any robust or reliable evidence; • WCC’s LTP identifies a need for 79 parking spaces. These can be accommodated in WFR/CB/2, notwithstanding concerns over the reliability of evidence used to arrive at the future need for that site; • There is no need for any further train station car parking within Blakedown that cannot already be met by the car park allocation at Station Yard (WFR/CB/2) under the lapsed planning permission; Flawed and unreliable evidence that WFDC appear to be relying upon to remove this allocation from the Green Belt and allocate it for a mixed use development but primarily for an additional 170 car parking spaces and 50 houses they have been unable to accommodate elsewhere in the District that have an identified need for housing that Blakedown does not have; • This is a Major Development that has not received full and proper Consultation or proper consideration; • The provision of 50 houses and reserved future car parking will result in a major development; • This allocation proposes major development of a scale, which is completely out of character with the village of Blakedown; • The density and massing of this allocation will be significant and will completely erode this important gateway site, encroaching significantly east along the Birmingham Road; • The site will be clearly visible from surrounding areas and would not be physically or visually contained; • Whilst no details are provided on the final design of the proposed allocation there are likely to be significant infrastructure works required to deliver the scheme; • This will result in the site being more visible and prominent within the Green Belt; • The surrounding openness would be severely harmed; • The proposed allocation encroaches further towards the town of Hagley, which will shortly be subject to significant areas of land being removed from the Green Belt to accommodate the significant growth required to meet the housing needs of Bromsgrove District and Birmingham under its own ongoing Green Belt Review and I would question whether WFDC have undertaken an appropriate Duty to Cooperate with adjoining authorities in this case; • As part of the Neighbourhood Plan adoption, there was evidence of need for only 7 affordable houses and 18 market houses required over the plan period and therefore the provision of 50 dwellings would go well beyond what Policy AM6B is seeking to achieve in village and rural settlements; • This is not due to the village being the most appropriate location of new residential development in the District, but solely as a means to deliver the proposed train station parking area, the need for which is questioned; • The Wyre Forest District Housing Need Study 2018 has identified that there was only an annual affordable housing need within Churchill and Blakedown of 3 dwellings per annum; therefore the use of the exemption for affordable housing as a means to release land from the Green Belt is questionable at best in this case • Blakedown is not as sustainable as the proposed Plan suggests : it has limited local services, very limited employment opportunities, no healthcare facilities and the primary school is currently full; • The station, bus route and limited local facilities might benefit the occupiers of any new homes, but the lack of employment/need to travel for services far outweighs these perceived advantages; • For most facilities (including secondary schools, main retail provision and healthcare) residents have to travel to larger centres; • There are no reasons on housing supply grounds to represent the exceptional circumstances necessary to release the site from the Green Belt and indeed if that is the grounds used to then it should be specified in the modifications to the local plan that the land is released for the purpose of the development of affordable houses and not just housing in general; • Adverse effects on local ecology; • Inadequate Ecological and Environmental Assessments have been undertaken before promoting this site; • The area of wetland to the north of the site is Blakedown Brook which feeds into the SSSI at Hurcott Pool and should be protected; • Use of SuDs should be carefully considered, and in the event that is not suitable then the capacity of existing stormwater sewer network needs to be considered; • Viability has not been demonstrated, save for a “Developer’s Option in SLC Rail’s Report, which has not been reviewed or analysed, which completely undermines the justification for the 50 houses and the future car parking spaces in Blakedown; • 50 houses are not necessary according to all recent Housing Needs Surveys; • All recent Housing Needs Surveys have identified a need for small scale local housing – lower cost or affordable small dwellings for First Time Buyers, new families, and downsizing need for elderly residents which frees up the existing stock of larger houses for those established on the housing ladder; A residential development of 50 dwellings, which needs to provide 25% affordable housing (in line with Policy 8B) and other tariff style contributions (i.e. highway improvements; open space; education; recycling etc) is very unlikely to be able to financially support the development of the car park; • The Council has not considered the viability implications of this allocation in terms of the delivery of the car park; • This allocation places a significant financial burden on any future developer wishing to build out the residential allocation if they are required to contribute towards a future car park; • There is no detail as to the amount of affordable housing proposed, yet that is the sole reason for seeking to remove the site’s Green Belt status and the wording of the plan should specify that the land is being released for affordable housing; • Lack of detail and consideration of highways issues, access and proximity to level crossing; • Junction layouts, in particular the proximity to A456 and the level crossing will cause significant access issues into and out of the site; • Concern over use of unsuitable country lanes; already congested A and B road network to reach station and increased speeding: ▪ The surrounding road network that would be used to bring traffic into Blakedown comprises narrow country lanes and already congested A and B roads
• There are significant numbers of school children who utilise the train station to get to nearby secondary schools arriving at the station from all directions; and the proposed increase in traffic will bring additional safety risks for them; • Additionally, there are significant numbers of school children and their families who walk to school using Churchill Lane, Mill Lane, Sculthorpe Crescent, Lynwood Drive and Station Drive to get to Blakedown Primary School with a considerable number of parents using Station Drive as a short term parking option for drop off and pick up of both primary and secondary school children. That has an implication both for the safety of pedestrians and the flow of traffic during the morning peak period in general and in particular for the junction of Churchill Lane and Mill Lane which narrows to single file and has no pavement for pedestrians from that junction up to the junction with Sculthorpe Crescent; • Additionally, there are significant numbers of horse riders, dog walkers and ramblers who regularly use the surrounding country lanes and increased traffic will again create a safety issue for them; Should the proposed development go ahead, careful consideration needs to be given to a number of safety concerns namely: • the safety of the increased numbers of commuters moving between Station Drive, a poorly lit residential street, to the station itself; • the impact of the increased pedestrian traffic over the level crossing to access Platform 2 (to Birmingham) which currently has quite a narrow space for pedestrians and the proximity of pedestrians to vehicles whilst on the level crossing; • While the suggested inclusion of a pedestrian access to the station being incorporated are welcomed, there is no suggestion of a footbridge to reach Platform 2 – the busiest platform as it serves, Hagley, Stourbridge/Black Country and Birmingham. Finally, and per my objection above, I can see no evidence whatsoever that WFDC have considered the joint impact of releasing this piece of land in Blakedown (WFR/CB/3) from Green Belt for affordable housing development in addition to the proposal to develop the land at Station Yard for additional parking. The cumulative effect on road traffic up to a potential of 600 additional vehicle movements on small village roads per day assuming: • 174 vehicle movements if all proposed spaces at Station Yard are utilised; • Upwards of 300 vehicle movements if the car park is built on the land released from Green Belt; and • 100 vehicle movements assuming 50 houses with 2 cars per household would completely overload the A456/Station Drive/Lynwood Drive junctions, particularly when you consider the proximity to the level crossing. It will have a serious negative impact on a village road network not suitable to such a volume of additional vehicle movements; and significantly increase risks for both road traffic and pedestrian safety (including significant numbers of school children travelling to and from the village primary school and using the station for travel to high school). Not to mention the detrimental effect on local residents living in the Station Drive/Lynwood Drive/Roxall Close/Mill Lane/Mill Close/Sculthorpe Road. |
|
231629 |
Alison |
LPMM3959 |
Object |
MM36.6 |
|
|
|
Conformity with NPPF NPPF 2021 para 140 provides that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 141 provides that “authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development” “makes as much use as possible of suitable brownfield sites and underutilised land” It is not clear that WFDC has fully evidenced or justified the removal of Green Belt land in Blakedown (WFR/CB/3 NPPF paragraph 147 retains the “Very Special Circumstances” test of whether inappropriate development causing harm to Green Belt is outweighed by other considerations. The Local Plan amendments are based on the exemption that “affordable housing” on Green Belt land is given in the NPPF, but the Draft Plan is confused between serving “District wide” or “Local Housing Needs” Policy WFR/CB/3 (9) states the new housing should be provided …. to meet any local housing need as shown in a Parish Needs Survey and/or the Housing Register. WFDC has put forward no evidence in support of this and this Policy is in conflict with others in the Plan NPPF paragraph 150 C provides that local transport infrastructure which can demonstrate a requirement for a Green Belt location may not be inappropriate development, But The Local Plan does not adequately consider the potential for expansion of Kidderminster Station Car park or of neighbouring authorities allocating more suitable sites for a “transport hub” before seeking to remove WFR/CB/3 from Green Belt As stated in ED20B – Technical Note 2 – Summary of Site Assessments: The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road. The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. The Local Plan does not respect the contribution made by this site. ED20 – Green Belt Topic Paper paragraph 8.29 refers to “an identified local housing need” yet Policy 36.6A of the Submission Plan states “Housing to be provided in accordance with policies elsewhere in Local Plan and also to meet any local housing need shown in a Parish Housing Needs Survey” Clarity is needed what housing need this site is to satisfy – Local or District need? There is also no specific requirement for affordable housing over and above the policies elsewhere in the Submission Plan 36.6A again states “Housing development on the site would help to cover the costs of the car parking and would also help towards meeting the future housing needs in Blakedown village”. In order to cover the costs of the car park we suggest that a future developer’s viability assessment would negate or significantly limit the provision of affordable housing. No evidence of local housing need has been provided to justify Policy WFR/CB/3, and it appears the Plan is confused between District Wide and Local/village specific future housing requirements Using market housing to fund the development of a car park suggests affordable housing provision will be limited. Unless significant affordable housing is to be provided then the release of WFR/CB/3 from Green Belt should not be an exceptional circumstance under NPPF 149(f). A proper assessment of alternative potential sites, including both non-Green Belt and Green Belt locations does not appear to have been carried out, especially in co-operation with neighbouring Authorities. The Council has not demonstrated proper regard to sustainable development objectives, or that the proposed brownfield and green belt sites are the most sustainable options taking account of all relevant factors including travel impacts, loss of amenity, and seriously compromising the basic purposes of including land in Green Belts. In particular Hartlebury Station (Wychavon District Council) is arguably more accessible to residents of the southern and western sides of Kidderminster, Bewdley and Stourport, and which is adjacent to large parcels of brownfield land. Proposed Policy 36.6A, point 5 – LWS buffering We request this is strengthened in line with Document GI07 - Worcestershire County Council’s September 2018 Addendum to Preliminary Ecological Appraisal of potentially ecologically sensitive sites on WFDC's list of sites for allocation in the 2018 Local Plan. This concludes: The Local Wildlife Site located to the north of this site is a sensitive receptor which requires buffering. Utilising up to one third of the northern area of the site to provide both a buffer and sensitively designed green infrastructure (e.g. new public open space) will help protect the LWS from the adverse effects of development. This will inevitably have a significant impact on net developable area. And recommends that The northern end of the site must not be developed and needs protecting from additional footfall – due to the slope of the land a buffer of at least 100m should be incorporated into development plans from the earliest stages Use of SuDs should be with caution and consideration to the local watercourse network and Hurcott SSSI. In the event that is not suitable then the capacity of existing local stormwater sewer network needs to be considered. Proposed Policy 36.6A, point 6 – Trees Modification proposed partly accepted to protect all trees on the boundary but appears to have been diluted compared to the recommendation in Document GI07 - Worcestershire County Council’s September 2018 Addendum to Preliminary Ecological Appraisal of potentially ecologically sensitive sites on WFDC's list of sites for allocation in the 2018 Local Plan that: The large oak tree beside the gateway on the south-western site boundary must be protected during development and in the longer term. A (permanent) root protection zone should be set up and the area should not be lit. Adverse effects on local ecology Inadequate Ecological and Environmental Assessments have been undertaken before promoting this site The area of wetland to the north of the site is Blakedown Brook which feeds into the SSSI at Hurcott Pool and should be protected better as noted above Contradicts WFDC’s Green Belt Topic Paper 2020 as noted above as ED20 and their 2017 Review WFDC considered this to be an important gateway site into Blakedown and makes an important contribution because of its containment of the village along the A456. The Council’s Green Belt Review and site analysis was based on a smaller site allocation than now proposed, and no station parking. Their analysis is therefore flawed and does not fully assess the implications of this proposed new allocation. WFDC’s Green Belt Review, Part II – Site Analysis undertaken by Amec Foster Wheeler in April 2017 noted the site’s characteristics in regard to Green Belt and NPPF Policies as CONTRIBUTION The site makes a contribution to Green Belt purposes because of its containment of Blakedown particularly along the A456 Birmingham Road, The high degree of physical and visual containment limits the impact of development on the Green Belt, although this is a gateway site into Blakedown which is locally significant in turn demanding particular attention to edge treatment, built density and massing. Supporting documents for this response are included at Appendix 6 of this Summary of Responses. |
|
231629 |
Churchill & Blakedown Parish Council |
LPMM5637 |
Object |
MM36.6 |
|
|
|
Negative Effect of these Policies on Local Amenity in Isolation and Cumulatively The cumulative effect if both Policies are adopted and the sites subsequently developed would cause significant harm to the amenity of residents nearby and users of most of the roads in the area. If Station Yard is developed with up to 87 spaces as currently proposed by WCC would create circa 180 additional vehicle movements per day. If Station Drive is developed with 50 houses (each with 2 cars being used twice per day on average) could create 200 additional movements per day. This would mean an additional 380 journeys using Station Drive and/or the A456 junction and almost half of those vehicles turning into the residential cul de sac of Lynwood Drive. Until proposals are confirmed for the reserved land for extra parking at Station Drive the overall cumulative impact is uncertain, but if the “Developer Option” is put forward as outlined in IFT03 - SLC Rail’s Report For Worcestershire County Council on Blakedown Station Car Park Options 27th June 2019 , being 50 dwellings plus 170 car spaces the latter could generate a further 340 movements per day ie a total of 720 vehicle movements. |
|
1283977 |
Wendy |
LPMM4 |
|
MM36.7 |
|
|
|
l still do not see how changing the planning to 4 dwellings will have any affect on the original planning application to use the private access along Fold Lane. As l have pointed out previously , parts of this lane is owned by Fold court residents and it is actually a public footpath and very well used by people. There is no room to put a side footpath once you move past the buildings fronting onto the High Street. l would also point out that this footpath route is also intended for use by the local school children in order to walk along to the village school, as the council have chosen not to provide a footpath along our very busy main road all the way past Rowberries Nursery to the School. This l presume is because they are trying to encourage people to use the footpath and walk, cutting down on car use! Also the residents who have to use the exit onto the village High Street . more often than not, have to come out with no sight line to the right up the Street due to continuous lines of parked cars, as the village is very popular with visitors and there is no provision for off road parking. Also cars turning off the main road into the village come along very often way above the speed limit causing even more problems to exiting safely. If this development is allowed to go ahead using Fold Lane , who is going to maintain it as it is already deteriorating. l must say that if this development is regarded as essential then the exit to it should be along the farm road to the main road, which still has a speed limit of 30 mph and an excellent sight line compared to Fold Lane. |
|
1297948 |
Chaddesley Corbett Parish Council |
LPMM12 |
Object |
MM36.7 |
No |
No |
No |
We do not believe that this site should be included in the Local Plan and should be deleted. Please see our report below: Section MM36.7 Policy 36.7 – Fold Lane, Chaddesley Corbett Chaddesley Corbett Parish Council note that the above site has been retained in the Local Plan, with capacity reduced from 6 to 4 dwellings and with added requirements that the properties should meet the needs of new households or older downsizers. The Parish Council remains opposed to any development of this site. The site is in the Conservation Area of Chaddesley Corbett village, washed over by the Green Belt and is currently used for agriculture. The proposed access road is an unadopted single track ‘footpath’ used extensively by walkers to access Chaddesley Woods, children to the school, agricultural vehicles, users of the Allotment site and Orchard and other residential properties. It would be unsafe to extend the use of this access any further, as reflected in previous comments from Highways. The review and update of our Neighbourhood Development Plan is well advanced, and identifies this site as an important Local Green Space. The revised NDP will also allocate a nearby site on Bromsgrove Road as a Rural Exception Site to meet the 2019 survey’s identified local need for 10 affordable homes over the next 10 years. Retaining the Fold Lane site in the Local Plan would prejudice the development of the almost adjacent Bromsgrove Road site, putting this needed housing supply at risk. Paragraph 8.15 of the draft Local Plan notes that affordability is a marked issue in the Parish, and “rental products are far more accessible to Parish residents.” The proposed allocated capacity of the Fold Lane site is below the proposed threshold for affordable housing on sites in Rural Areas (Policy 8B), and would deliver only market housing for sale. Based on the outcome of the redevelopment of the former Village school site, it is possible that some of this might become available for private rental (but unlikely to be at ‘affordable’ levels), or possibly short[1]term/holiday rental, and therefore will not address even a portion of the identified local need. Policy 8c (reference MM8.4) of the draft Local Plan restates a previous commitment for the District Council to work closely with Parish Councils and Neighbourhood Planning Forums to identify appropriate sites for rural exception schemes. By definition, the allocation of any greenfield site in the Green Belt would be an Exception Site, but here there is a clear lack of ‘close working’. There was a brief dialogue on the subject in January 2018, but nothing since. In January 2018 the Parish Council was asked to respond to the possible allocation of one of three sites in the Local Plan. One was Fold Lane, one was the NDP’s proposed Exception Site off Bromsgrove Road, and the third was the field between these two. There was inadequate time to consult with residents about these options, hence the Parish Council’s decision not to support the allocation of any site in the Local Plan, but to address the question in the review of our NDP. After a rigorous call for sites exercise and site evaluation, the NDP’s preference is for the site off the A448 Bromsgrove Road. Our verbal evidence to the Local Plan’s external examiner set out all of this background, and a recent draft of our emerging revised NDP has been shared with WFDC Planning Officers, which confirms the results of our site selection exercise during which, despite Covid, we were able to consult with our residents. One of the prime aims of the introduction of Neighbourhood Planning in the 2011 Localism Act was to empower communities to shape development in their local area, to choose where they want new homes, and have their say on what those buildings should look like. The Parish Council strongly objects to the allocation of the Fold Lane site for any scale or type of development in the District Council Local Plan. We would also urge the District Council to take account of representations from residents of Fold Lane. We would refer you to the Planning Practice Guidance for Neighbourhood Planning, see link below: https://www.gov.uk/guidance/neighbourhood-planning--2#evidence-to-support-a-neighbourhood-plan “The local planning authority should take a proactive and positive approach, working collaboratively with a qualifying body particularly sharing evidence and seeking to resolve any issues to ensure the draft neighbourhood plan has the greatest chance of success at independent examination. The local planning authority should work with the qualifying body so that complementary neighbourhood and local plan policies are produced. It is important to minimise any conflicts between policies in the neighbourhood plan and those in the emerging local plan, including housing supply policies. This is because section 38(5) of the Planning and Compulsory Purchase Act 2004 requires that the conflict must be resolved in favour of the policy which is contained in the last document to become part of the development plan.” Supporting documents for this response are included at Appendix 6 of this Summary of Responses. |
|
1299251 |
Mr |
LPMM281 |
Object |
MM36.7 |
No |
No |
No |
Fold Farm, Chaddesley Corbett (0.31 ha) MM36.7 Clause 36.11 ‘This small paddock is accessed along a private road which serves Fold Court and other dwellings’. This statement is inaccurate in its entirety. There is no access to the paddock from Fold Lane which is an unadopted road not a private road. The proposed development site is fenced all along Fold Lane, as it always has been historically. There is no dropped kerb, and a kerb exists all along the border with Fold Lane. There is also no gateway directly into the paddock (site area MM36.7), and therefore there is simply no current access to this paddock from or onto Fold Lane. In addition to the above point the landowner has no right to legally bestow vehicular access to others along Fold Lane. The landowner also has no rights to the land below the lane for utilities provision for any development i.e. the land owner has no right to dig up the lane at all so how are the services to be provided. The legal soundness and compliance of this application is fundamentally flawed. Clause 36.12 ‘designed to meet the needs of newly formed households or older people looking to downsize’ This statement is also inaccurate. In accordance with The Parish Housing Needs survey another site has already been allocated for Affordable Housing as per the explicit requirements from the survey and therefore the Neighbourhood plan. No other housing was required. Therefore the site MM36.7 is additional to any housing needs required. There is no further housing need to satisfy. The most recent planning application (20/0675/FUL) has been withdrawn, so this cannot be valid “reason for change” to the Wyre Forrest District Council Local Plan i.e. there is no actual planning permission being sought currently. Source Wyre Forest District Council Planning Portal 19/11/2021 19:44. |
|
1281062 |
Mr |
LPMM3 |
Object |
MM36.7 |
No |
No |
No |
The latest parish housing needs survey does not identify a housing need for development on this site. The Parish Council have identified an alternative site to fulfill any housing need there is. As a result the whole basis of the proposal is misconcieved. The site is in the green belt and is in a conservation area so again the allocation is misconcieved. The proposed allocation is outside of the Parish Council Neighbourhood plan. |
|
1298682 |
Andrew |
LPMM35 |
Object |
MM36.7 |
No |
No |
No |
I wish to bring to your attention an inaccuracy in the text of the Proposed Main Modification associated with Reference MM36.7 of the 'Schedule of Proposed Main Modifications to the Wyre Forest District Local Plan (2016-2036)'. Para 36.11 states 'This small paddock is accessed along a private road which serves Fold Court and some other dwellings....'. This statement is incorrect. There is no access to the paddock from Fold Lane. The paddock is accessed from Fold Farm via an agricultural vehicle access road off the A448. I refer you to Planning Permission WF241-89 dated 11th April 1989 which authorised the construction of an agricultural vehicle access road off the A448 to and from Fold Farm, Fold Farm House and Vicarage Farm. The right of access to and from Fold Farm House was not transferred in the Conveyance to the developer of Fold Court dated 14th October 1991. In addition the Conveyance contains a covenant requiring the fencing with a 'good and sufficient stockproof fence' of the unfenced part of the paddock fronting Fold lane within two months of the date of the agreement. So there has been no direct access to or from the paddock and Fold Lane since, at least, early 1992 and probably considerably earlier. Fold Lane is a public right of way. Section 34(1 and 2A) of the Road Traffic Act 1988 provides that anyone driving a mechanically propelled vehicle on a road that is a footpath, bridleway or restricted byway is guilty of an offence unless it can be shown that immediately before the commencement of section 47(2) of the Countryside and Rights of Way Act 2000 on 2nd May 2006 there was a private right in use for obtaining access to the land by the driving of mechanically propelled vehicles by a person with an interest in the land or by visitors to the land. As the land has been fenced off from Fold Lane since 1992 the occupiers of any properties that may be constructed on the paddock cannot, therefore, have a right of vehicular access to or from their properties via Fold Lane. |
|
1299187 |
Mr |
LPMM278 |
Object |
MM36.7 |
No |
No |
No |
Para 36.11 states 'This small paddock is accessed along a private road which serves Fold Court and some other dwellings....'. This statement is incorrect. There is no direct access to the paddock from Fold Lane. There is no dropped kerb and the land is fully fenced off from Fold Lane. Fold Lane is a public footpath over a private road and any new access on to the footpath/right of way would be restricted under Section 34(1 and 2A) of the Road Traffic Act 1988. |
|
1299258 |
Mrs |
LPMM282 |
Object |
MM36.7 |
No |
No |
No |
MM36.7 - Fold Farm, Chaddesley Corbett (0.31 ha) Clause 36.11 ‘This small paddock is accessed along a private road which serves Fold Court and other dwellings’. This statement is inaccurate. There is no access to the paddock to or from Fold Lane. The proposed development site is fenced all along Fold Lane, as it always has been historically, with no access points. There is no dropped kerb, and a kerb exists all along the border with Fold Lane. There is no gateway directly into the paddock to/from Fold Lane. The access to this field is not from or onto Fold Lane – there is no access for the proposed development nor for their construction traffic. In addition to the above point: There is also no right by the landowner to legally bestow vehicular access to others along Fold Lane. The landowner also has no rights to the land below the lane for utilities provision for any development. The legal soundness and compliance of this application is fundamentally flawed. Clause 36.12 ‘designed to meet the needs of newly formed households or older people looking to downsize’ This statement is also inaccurate. In accordance with The Parish Housing Needs survey another site has already been allocated for Affordable Housing as per the explicit requirements from the survey and therefore the Neighbourhood Plan. No other housing was required. Therefore the site MM36.7 is additional to any housing needs required. There is no further housing need to satisfy. The most recent planning application (20/0675/FUL - WITHDRAWN) included one large 4-bed family home as part of the plans – which also goes against the Housing Needs Survey requirements identified for Chaddesley Corbett village. However, this planning application was withdrawn and there is no current planning permission listed (WFDC planning portal accessed 19.11.21 – no planning permission listed) so why is this mentioned as a valid reason for change to the WFDC Local Plan if there is no actual planning permission being sought currently? |
|
1299410 |
Mr |
LPMM1965 |
Object |
MM36.7 |
|
|
|
I wish to object to the proposed allocation of land at Fold Farm, Chaddesley Corbett for residential development as proposed in the Wyre Forest District Local Plan Main Modifications (Section MM36.7 refers). The proposed main modification allocates this site for residential development to meet local needs as demonstrated through a parish housing needs survey and/or the Housing Register. The modification also sets out the requirements which would need to be met. The Parish Council has previously recommended a development of affordable housing for a site off the A448. The Parish Council believes that this development will meet all the needs identified in the Housing Needs Survey. This further site is therefore not required and, as such, should not be included within the Local Plan. Furthermore, I object to the inclusion of this site as any development on it will have a significantly detrimental effect on the amenity of Hunters Ride, its gardens and Coach House impacting negatively on my enjoyment of the property and future sale value. Hunters Ride’s status as a non designated Heritage Asset and its location within the conservation area and green belt should be protected. In addition to the impact of any proposed development on my property, future development of the site would also give rise to a number of highway safety concerns affecting the residents of Fold Lane. For the reasons set out above, I wish to object to the allocation of this site for residential development as proposed in the Wyre Forest District Local Plan – Main Modifications. |
|
1302580 |
Diane |
LPMM1911 |
|
MM36.7 |
|
|
|
I do not support the proposed housing development in Fold Lane for the following reasons: 1 The proposed site is in the Green Belt in the heart of the Conservation Area. It should therefore remain protected. The Chaddesley Corbett draft NDP proposes development on a number of sites which more than meet the needs indicated by the Housing Needs Survey. The ‘Call for Sites’ exercise conducted by the Parish Council in response to local needs was rigorous, thoroughly consulted upon and reflects the views of the community. The Parish does not need to sacrifice a green space in the Conservation Area as its needs will be met through implementation of the Neighbourhood Development Plan. 2. There is a Public Right of Way through Fold Lane which also makes up part of the designated ‘walk to school’ route for Primary aged pupils. Additional traffic would make the route less safe. 3. Fold Lane is a Private Road and is narrow at its intersection with The Village and visibility is poor. Any increase in traffic would pose additional hazards. 4. The Fold Lane Conservation Area is proposed as a Local Green Space in the NDP and affords views towards the Malvern Hills on a clear day. 5. Whilst there is access to the farmyard there is no direct access to the space in question from Fold Lane. 6. In the recent past flooding has occurred from the top of Fold Lane, resulting in considerable amounts of water affecting the garden and drive area to the corner property opposite the farm entrance. |
|
1302641 |
Mrs |
LPMM1951 |
Object |
MM36.7 |
No |
No |
No |
MM36.7 - Fold Farm, Chaddesley Corbett (0.31 ha) Clause 36.11 ‘This small paddock is accessed along a private road which serves Fold Court and other dwellings’. The site for this proposed development named as this small paddock doesn’t have any point of access to or from Fold Lane, there is fencing which covers the whole parameter of the proposed site along its border with Fold Lane. There is also a fully constructed kerb with no modifications to allow any vehicular access to the site, as is there no gated access for pedestrians anywhere along the border, the only way to access the proposed development site from Fold Lane (or vice versa) would be to climb over the fencing. In my opinion this would make the statement clause 36.11 inaccurate. Clause 36.12 ‘designed to meet the needs of newly formed households or older people looking to downsize’ It is my understanding that another site has already been allocated for development and construction of properties meeting the criteria of Affordable Housing, I would have assumed that this would satisfy the requirements of the Neighbourhood Plan for Chaddesley Corbett Village. As the last planning application submitted 20/065/FUL was withdrawn I was confused as to why discussions were even taking place to consider changing the WFDC local plan, I have checked surrounding areas close to the proposed site to see if there are any new notices that have been posted to inform of a new planning application being submitted and have found nothing, have also checked the Wyre Forest District Council planning portal which also shows that no new planning application has been listed, In my opinion this would make the statement clause 36.12 inaccurate. If I may I would also like to give an update on some of the issues I mentioned in previous objections to the proposed development site known as ‘small paddock’ that have worsened since then. The vehicles volume of traffic using Fold Lane has continued to increase, especially larger vans making deliveries, which initially started to grow just after the initial Covid 19 lockdown. The condition of the footpath / road surface has deteriorated significantly in the last 12 months, with quite deep potholes appearing in several places. Exiting Fold Lane onto the Village continues to be a nightmare at times due to the volume of vehicles being parked either side, and directly opposite Fold Lane. |
|
1302629 |
Mr |
LPMM1938 |
Object |
MM36.7 |
No |
No |
No |
MM36.7 - Fold Farm, Chaddesley Corbett (0.31 ha) Clause 36.11 ‘This small paddock is accessed along a private road which serves Fold Court and other dwellings’. The site for this proposed development named as this small paddock doesn’t have any point of access to or from Fold Lane, there is fencing which covers the whole parameter of the proposed site along its border with Fold Lane. There is also a fully constructed kerb with no modifications to allow any vehicular access to the site, as is there no gated access for pedestrians anywhere along the border, the only way to access the proposed development site from Fold Lane (or vice versa) would be to climb over the fencing. In my opinion this would make the statement clause 36.11 inaccurate. Clause 36.12 ‘designed to meet the needs of newly formed households or older people looking to downsize’ It is my understanding that another site has already been allocated for development and construction of properties meeting the criteria of Affordable Housing, I would have assumed that this would satisfy the requirements of the Neighbourhood Plan for Chaddesley Corbett Village. As the last planning application submitted 20/065/FUL was withdrawn I was confused as to why discussions were even taking place to consider changing the WFDC local plan, I have checked surrounding areas close to the proposed site to see if there are any new notices that have been posted to inform of a new planning application being submitted and have found nothing, I have also checked the Wyre Forest District Council planning portal which also shows that no new planning application has been listed. In my opinion this would make the statement clause 36.12 inaccurate. |
|
1302855 |
Mr |
LPMM2132 |
Object |
MM36.7 |
|
|
|
Para 36.11 states ‘This small paddock is accessed along a private road’ There is no access to the paddock from the road referred to |
|
859769 |
Mrs |
LPMM3162 |
Object |
MM36.8 |
|
No |
No |
My client objects to proposed Main Modification MM36.8 on the basis that it seeks to amend the approach taken to Reserved Housing Sites within the Local Plan by only removing a site specific policy rather than address a fundamental principle relating to the sufficiency of the supply of Reserved Housing Sites. The National Planning Policy Framework (paragraph 139) makes specific reference to identifying areas of safeguarded land between the urban area and the Green Belt where necessary, when defining Green Belt boundaries, in order to meet longer term development needs stretching well beyond the Local Plan period. Local authorities also need to be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the Plan period. The principle for being able to safeguard land has therefore been established in national planning policy. My client recognises that Main Modification 36.8 does not seek to further reduce the supply of identified safeguarded land (Reserved Housing Sites). This stance is welcomed. Reserved Housing Sites are still considered to play an important role as part of the Local Plan strategy. If site-specific constraints or other considerations do delay or slow down the delivery of development on some of the allocated housing sites then it will be important for WFDC to be able to still demonstrate that it does have a wider suitable and flexible supply of deliverable sites in sustainable locations which can come forward to assist with maintaining a five year housing land supply position against the Local Plan housing need target. As acknowledged in the Local Plan supporting text, and unless alternative sites are allocated through a further (partial) review of the Local Plan, Reserved Housing Sites “provide the first option to consider for development if sites are not available to meet the desired requirement in other, sequentially preferable locations”. The most recent household projections for the District are higher than the level of growth chosen by WFDC as its housing need figure for the Local Plan period. WFDC should be mindful of the anticipated future requirement to plan for meeting an increased need, both through making additional allocations in the next Local Plan Review and ensuring the ability of WFDC to demonstrate a deliverable five year housing land supply position based on a greater housing need position. The expectation is that future Local Plan Reviews will also find that there are insufficient previously developed sites within the urban areas to meet the housing need and therefore there will still be a need to review and alter Green Belt boundaries. There is accordingly considered to be a need to give regard to the requirement for Green Belt boundaries to endure beyond the end of the Plan period by safeguarding additional land in suitable and sustainable locations as part of the current Local Plan review process. The total identified capacity within the included Reserved Housing Sites amounts to c.116 dwellings. This would not make a significant contribution to the housing land supply and is accordingly not considered to be sufficient to meet the anticipated increase in local housing need and resultant pressure for further releases from the Green Belt. As a consequence it is contended that WFDC should be planning for additional reserved housing sites, notably around the edge of Kidderminster. Main Modification 36.8, being the only proposed change in relation to the approach to Reserved Housing Sites, therefore does not go far enough. It is not considered to be sufficient to simply ensure that the approach taken within the Local Plan to the already identified Reserved Housing Sites is consistent. The approach should go further and recognise the need for further Reserved Housing Sites to be included. The proposed Main Modifications are therefore not considered to address the national requirement to identify areas of safeguarded land between the urban area and the Green Belt, when defining Green Belt boundaries, in order to meet longer term development needs stretching well beyond the Local Plan period. My clients accordingly consider that WFDC has still not demonstrated that Green Belt boundaries will not need to be altered at the end of the Plan period and contend that the Local Plan is therefore still not sound in this regard. In order to rectify this it is considered that further Reserved Housing Sites should be reviewed and consulted upon before the Local Plan moves forward to adoption, to ensure that the Local Plan is genuinely based on an approach that can allow Green Belt boundaries to endure well beyond the Local Plan period. |
|
260520 |
Campaign to Protect Rural England |
LPMM307 |
|
MM36.9 |
|
|
|
As in MM18.2 the use of data from the Housing Register is inappropriate, unless this is explicitly limited to persons on the Register who have a close link to the Far Forest area, for example by living there, working there, or having relatives there who need care. |
|
260520 |
Campaign to Protect Rural England |
LPMM308 |
|
MM36.10 |
|
|
|
As in MM18.2 the use of data from the Housing Register is inappropriate, unless this is explicitly limited to persons on the Register who have a close link to the Far Forest area, for example by living there, working there, or having relatives there who need care. Additionally: this site is within the area of the medieval hamlet of Caunsall. Accordingly, a heritage assessment will be needed before development takes place. |
|
260520 |
Campaign to Protect Rural England |
LPMM309 |
|
MM37.1 |
|
|
|
MM37.1 Policy MM36.6A ought not to be classified as a strategic policy, when clearly it is not one. Policies 31 and 32, each covering about 1400 houses are clearly strategic. Having 50 houses at Blakedown is on a completely different scale from that. There is no justification for declaring these 50 houses as strategic when numerous allocations in the three towns, some on a similar or greater scale are not. |
|
260520 |
Campaign to Protect Rural England |
LPMM306 |
|
MM37.7 |
|
|
|
MM37.7 Evidence given at the Examination very clearly showed a grave lack of local support for this site, with others potentially being promoted through a Neighbourhood Plan. The allocation of this site is a non-strategic one, so that the District Plan is detracting from the ability of a Neighbourhood Plan to make appropriate allocations to meet local needs according to the wishes of local people, contrary to the Localism Act. The District Plan should have this allocation deleted, instead providing an appropriate housing target for the village to be met from land within or adjoining the village envelope boundary to be allocated through a Neighbourhood Plan. |