Responses made on the Sustainability Appraisal of the main modifications to the Submission Wyre Forest District Local Plan (ED58)

1298642

Mr
Gordon
Bunn

LPMM24

Object

SA

I hereby object to ED57 & ED58 Habberley Road Development. 

1298606

Mr
Kev
Moule

LPMM20

Object

SA

I hereby wish to object to ED57 & ED58 Habberley Road Development. 

1298639

Caroline
Moule

LPMM22

Object

SA

I hereby wish to object to ED57 & ED58 Habberley Road Development. 

1285674

Dr
Merlyn
Wilcox

LPMM8

Object

Page 10

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:

1. That the Site makes a significant contribution to the Green Belt as it forms part of the arc of Green Belt which contains the northerly extent of Kidderminster, limiting extension of the contiguous built-up area of the town into open countryside and that as such it makes a significant contribution to Green Belt purposes of containing sprawl and preventing encroachment;
2. That whilst the Site is small and nominally adjacent to the urban edge of Kidderminster, it is nevertheless exposed visually and physically, being bounded by an insubstantial hedge to the north west and thereby physically and visually connected to the wider open countryside;
3. That whilst the Site can contribute to meeting the development needs of the District in a relatively sustainable location, the impacts on the Green Belt can only be mitigated to some degree through site design, and that the openness and permanence of the wider Green Belt are likely to be compromised through the absence of a substantial containing boundary and the creation of a new built edge affecting the openness of the remaining Green Belt. It also said that mitigation through the creation of a development boundary is likely to require significant intervention; 
4. That the harm to the Green Belt would need to be balanced against the sustainability of the Site as a development location;
5. In the accompanying appendix, which comprises a summary of the Contribution to the Green Belt and Likely Effect of Development on the Green Belt of each of the sites identified for removal from the Green Belt, the contribution made to Green Belt purposes is split into 5 categories for each site: Sprawl, Merger, Encroachment, Setting, and Overall Contribution. Each category is ranked as to whether the site makes a Limited Contribution, a Contribution, or a Significant Contribution. The Site is assessed as making a Significant Contribution in three categories - Sprawl, Encroachment, and, importantly, Overall Contribution. A review of the results of the other sites shows that few (if any) are considered to make as significant a contribution as the Site. Whilst the ‘Overall Contribution’ for a few other sites is also ‘Significant’, there are a much larger number of sites where the ‘Overall Contribution’ category is considered to be lower (i.e. ‘Contribution’ or Limited Contribution’).

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.

1299853

Mr
Neil
White

LPMM438

Object

Page 10,25,26 & ED57 MM3.1-3.6 (p23) , MM6.7- (p37, MM8.1-(p57), MM30.51, MM9.3- Policy 9 (p87), MM30.17- Policy 30.21 (280& p281)

No

No

Poor access to local services. Severe impact on a local nature reserve. Undue stress on local schools and facilities. Poor public transport. It’s a greenfield site. The area often floods causing water run off. 
It doesn’t adjoin a built up area it’s bordered by roads on 2 sides and field/ woods on the others. 

1284059

Mrs
Carol
Shakespeare

LPMM6

Object

Pages 25 & 26 REF Field at Habberley Rd WA/KF/3

No

No

No

FIELD AT HABBERLEY ROAD REF WA/KF/3

The proposed Habberley area land development carries the highest negative tariff of any development area & hits a double negativity rating in the Biodiversity & Geodiversity space.

This in itself makes it nonsensical to develop against the backdrop of climate change/COP 26/Earth Shot/brownfield development priority & wildlife impact (borders Habberley Nature reserve)-the field itself is stated in other documents as being a significant contributor to Green Belt Purposes.

In short

• Negative for Local Services & facilities
• Negative need to travel, poor public transport
• Negative for soil & land
• Negative for Water Resources, Quality & Flood Risk.
• Negative for Landscape & Townscape
• Negative for Greenbelt
• DOUBLE negative for Biodiversity & Geodiversity
• Stated as Neutral for Community & Settlement identities – although from a local resident standpoint this is extremely debatable.
• Neutral for Historic Environment (although again some of the local historians/historical date would find this debatable)

Developing / removing from Greenbelt against this backdrop & in the context of a very visible greenbelt border location will be against every ethical & data driven statement & promise made. It creates issues for local residents/services/wildlife & will never be well received as not data/science/credibility supported.

231332

Natural England

LPMM167

Support

Sustainability Appraisal

Yes

Yes

Yes

We have reviewed Sustainability Appraisal of the main modifications to the Submission Wyre Forest District Local Plan (ED58) and agree with findings and conclusions of this report.

1303087

Dr
Margreth
Becker

LPMM3557

Object

Page 10, 25 and 26

No

No

No

Significant Information against which the sustainability assessment should be read.

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. 

SUSTAINABILITY REPORT ED58

Page 10, 25, 26 (Comments regarding the Sustainability Appraisal)

1. Site area assessed is not specific to the site itself (92.8 hectares vs. 5.6 actual)
2. The statement “Adjoining Built Area” is false and misleading. It is separated from the built area by highways and is only adjoining another agricultural field. The correct phasing is “adjacent to built up area

Table 5 (p10) Sustainability impacts of the Wyre Forest District Local Plan site allocations WA/KF/3 – Land at Low Habberley: (KEY as in Sustainability report ED58): Red = Double Negative, Yellow = Negative, Blue = Neutral, Green = Positive, Dark Green = Double Positive

• Local services – yellow (Poor access, as judged by the HELAA (Housing Economic Land Availability Assessment) form)).
• Housing Double positive green (Housing site>40ha) (THIS IS FACTUALLY INCORRECT. Site is ONLY 5.6 Hectares) Hence should be only single positive (pale green)
• Travel – yellow (Poor public transport access as judged by the HELAA form; with 200m of AQMA)
• Soil and land – yellow (Greenfield grade 2 agricultural land; development could affect other soil/land)
• Water and flooding – yellow (Partly in flood zone 2 or significant surface water flooding; in aquifer protection zone or similar
• Landscape – yellow (Some negative impact)
• Biodiversity – red (Adjacent to or on designated conservation site; other significant cumulative impact on biodiversity) Double Negative
• Employment = blue (No potential)
• Historic – blue (No impact)
• Green Belt – yellow (In Green Belt)
• Community – Neutral

The allocation has only one positive, that being the provision of housing. Any housing allocation would realise the same ‘positive’ But NOT Double Positive as stated in the document. This field is far less than the 40 hectares definition ED58 for double positive. (FACTUALLY INCORRECT STATEMENT). Other than three neural impacts, the proposed allocation is shown to have seven negative Impacts out of the eleven. This includes six ‘minor negative’ impacts, and one ‘major negative’ impact, deemed as (Quote) “problematic sustainability issues, mitigation difficult and/or expensive”. What is startlingly apparent, which has been shown previously in every single analysis of the Low Habberley site, is the number of negatives and lack of positive impacts, particularly when compared to the other proposed allocations.

It is also worthy to note and highlight that the ‘Green Belt’ criterion in the sustainability report is a simple ‘in or out’ assessment. However, as has been demonstrated in every Green Belt assessment undertaken for the Council (Amec Foster Wheeler – ‘Green Belt Review Strategic Analysis September 2016, and the Green Belt Topic Paper – Summary of Site Assessments October 2020) this site is highly important and makes a significant contribution to the Green Belt. The findings of every assessment undertaken DO NOT support the release of this field from the Green Belt.

An Ecology report done by Pleydell Smithyman Ltd (Ecological Consultants) on the site in March 2021 when the proposal to build on this site first came into the public domain and this is attached.  

It is considered that the Council acted prematurely in selecting this field for removal from the Green Belt before they had adequately considered the contribution that it made to Green Belt in topic paper ED20 which was produced after the site was selected. The site had not been adequately assessed before that and it should have been discounted when this assessment was produced. The Sustainability Appraisal confirms that the site is not particularly sustainable and that development would cause significant harm, particularly in biodiversity. It is therefore considered that the exceptional circumstances required to justify the removal of the site from Green Belt DO NOT exist.

The examination Inspector has asked for evidence to justify the release of each proposed site from the Green Belt (document ED6). All assessments undertaken demonstrate that this site provides a significant positive contribution to the Green Belt, and therefore evidences that it should remain as Green Belt, and not be released for development. The Sustainability assessment of the Low Habberley site (p25) makes the following comments: The site is ticked to be ‘adjoining built up area’. THIS IS FACTUALLY INCORRECT AND MISLEADING. The site only ‘adjoins’ an open agricultural field. It is separated from the ‘built up area’ by highways to three sides. The correct phrasing would be that the site is ‘adjacent’ to a built up area.

The sustainability assessment notes that: - The site has (Quote) ‘Overall poor access to local facilities’, as well as ‘poor public transport access’. – The site is (Quote) Former open heath, and a ‘sensitive location what would impact on views to Habberley Valley Nature Reserve, Wassell Wood and receptors and Low Habberley and the northern boundary of Habberley Estate’. – The site is adjacent to the Habberley Valley Local Wildlife Site/Nature Reserve, and along boundary of Easthams Coppice. Protected trees on site, and BAP protected fauna, Pipistrelle bat and brown hare present.

The only ‘reason for inclusion’ given is that it was a call for sites submission. Given the significant negative impacts, and the officer-assessed ‘poor’ access to local facilities and public transport, there is no reasonable justification for the allocation of this Green Belt land for building.

Supporting documents for this response are included at Appendix 6 of this Summary of Responses. 

1299552

Mr Robert Ward

LPMM2694

pages 10,25,26

There is no comment on fuel line across the land affected by this proposal (Low Habberley)

1137373

Mrs
Sonia
White

LPMM11

Pages 10 and 25

MM6.1 is not sound or legally compliant in regard to Field at Habberley Road REF WA/KF3

Primarily this area is GREEN BELT
The surrounding infra structure is inadequate for housing.
Transport egress from this field will endanger lives.
Pedestrian routes to local facilities from this field will endanger lives.
The area is rich in wildlife throughout the year, hence its status as GREEN BELT
It is a prime area, surrounded by other land, absolutely suited to agriculture/farming.

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.