The council received the following 8 objections from 556 individual respondents
|
Document |
Support/ Object/ Comment |
Main Mod Reference |
Legally compliant? |
Sound? |
Positively prepared? |
Response |
|---|---|---|---|---|---|---|
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM3.1 |
No |
No |
No |
ED57 Main Modifications Document MM3.1 – Overall Sustainable Development Objectives: c) Environmental Role: ii) Improving biodiversity – It is noted in the sustainability report that development will have a significant negative impact on local biodiversity. The notion that development will improve biodiversity is plainly ridiculous. |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM3.3-3.6 page 23 |
No |
No |
No |
MM3.3 – 3.6 (p23) – Plan Objectives “a necessary and justified level of strategic Green Belt release”. – to ensure that the level of development that is required within the District over the whole plan period can be achieved. – As per the Inspector’s comments in ED6, there is no justified evidence for the removal of the site, which has been consistently found to have a significant contribution to the Green Belt. |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM6.7 (page 37) |
No |
No |
No |
Policy 6B – Locating New Development. The Spatial Development Strategy and the site allocations in this Plan (as described by Policies 6C – 6F) are based upon the following principles: vii) Protect from development areas that are sensitive because of their landscape, heritage assets or biodiversity. – This is a sensitive landscape with significant biodiversity, as found and established in the site assessments carried out on behalf of WFDC. |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM8.1 |
No |
No |
No |
MM8.1 – (p57) Kidderminster and Stourport-on-Severn provide a good range of jobs and services and the opportunities for accessing the public transport network within these urban areas are higher. The higher density levels indicated for these towns reflect their roles within the settlement hierarchy and will help to support existing public transport infrastructure into the future. – but it has been shown that this site is not sustainable in terms of access to local facilities or public transport (WFDC Officer views p26 sustainability report) |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM9.3 |
No |
No |
No |
MM9.3 – Policy 9 (p87) A) (Quote) 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. The proposed Low Habberley Site allocation conflicts with the policy requirement, given that it has been shown not to be sustainably located, and would result in the loss of agricultural land. The field at present does have a natural and well-trodden path around 3 sides out of four of its perimeter. This path is very frequently used for walking with or without dog. People choose to walk inside the hedge to give distance from the traffic noise and fumes. These paths have been in regular use for in excess of 40 years. Walking in natural environment has been shown to be very beneficial for physical and mental health and is far more likely to be sustained through life than gym membership. Development would have major negative impact on this criterion. Development would significantly mar the ability to enjoy walking. Development would have significant negative impact on physical and mental health of humans and their dogs alike! v) Encouraging opportunities for access to fresh food, for example through the provision of allotments, community orchards, fruit trees, local markets, and usable private amenity space — shown not to be sustainably located and would be a loss of agricultural (food producing) land that to date has the added benefit of irrigation. |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM30.17 |
No |
No |
No |
P281 —4 . The rear hedge-line should be strengthened to provide a new defensible boundary to the Green Belt. — The highway is the best defensible boundary as it is. Allocation of the site to housing will, and can only, weaken the defensible boundary to the Green Belt P281 - 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. Habberley Valley is a very special heathland and acid grassland environment and should be maintained as such. There is no justification to introduce new habitats to gain biodiversity as suggested. The present habitats are fragile and should be protected. The site already has significant biodiversity. It is not a dead and sterile environment. The hedges and field margins teem with life. Some of the hedges could be further improved but this does not need the building of houses to achieve. Butterflies, moths, birds and bats are currently present in abundance P281 - 7. Proposals should specify how existing and surrounding habitats including Habberley Valley and Eastham's Coppice will be taken into consideration. Measures to protect and mitigate for bats and brown hare should also be considered —The inherent and identified harm the allocation of the proposed Low Habberley Site would cause significant harm to local biodiversity and thus significant mitigation work required in itself runs entirely contrary to the requirements of Policy 6B as set out in MM6.7 I, the undersigned, agree with and support the statements made within this section labelled Part B —Comments/Representations. I DO NOT support the development of WA/KF/3 —Land at Low Habberley or its removal from Green Belt and allocation for housing. For these reasons I do not consider that the main modifications proposed, particularly MM30.17 make the plan sound, and that instead draft policy 30.21 should be deleted in its entirety. |
|
Schedule of Proposed Main Modifications to the Wyre Forest Local Plan (2016 – 2036) (ED57) |
Object |
MM30.17 |
No |
No |
No |
(Quote) The site is located on the NW edge of Kidderminster’s urban area, approximately 1.5km from the town centre. THIS IS FACTUALLY INCORRECT. The distance from the town centre is 2.6km from the shortest feasible route. Also (Quote)” The retention and enhancement of the western hedgerow boundary will allow for an improved residential edge to Habberley when seen from the north and provide a strong defensible Green Belt boundary”. Because of the almost triangular shape of the field, the suggestion of the benefit of forming an improved residential edge is false in that a development here would result in an incursion of at least 100 metres (over the length of a football field) further than the present edge of development the other side of Habberley Lane. |
|
Sustainability Appraisal of the main modifications to the Submission Wyre Forest District Local Plan (ED58) |
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)
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
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. 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. |