Emma Newfield
From: Ben Sinclair Sent: 16 February 2016 00:12 To: Consult Planning Subject: Comment/objections to Narrative BORLP4 Document Attachments: Comment on Narrative Feb 2016.docx
Categories: Blue Category
Dear Sir,
I am writing to object to the revised narrative of the BORLP4 document on the site selection process for the growth areas at Redditch (January 2016).
This document is flawed and would appear to be misleading, repeating significant mistakes found in previous versions of the selection process and presenting further unsound changes, as evidence.
It would appear that this document has been produced in order to legitimise a decision already been taken by RBC with regard to site selection of areas for development.
OBJECTION 1
My first objection is to the quality of the document itself, which is poor, & a turgid piece of work.
The document is extremely difficult for a layman to interpret, being confusing, monolithic, of great length, and verbose.
It would appear that its primary purpose is to deter ordinary members of the public from participating in the commentary process. Many will fail to object, as a direct result of its literary quality. The low numbers of objections will be a reflection of this, rather than a mirror of how few people are minded to comment
OBJECTION 2. Page 58 - 9.89 When considering the impact of proposed development on the significance of a designated heritage asset, the NPPF requires that great weight is given to the asset’s conservation. The NPPF also recognises that the significance of a heritage asset can be harmed or lost by development within its setting. For this reason, the potential impact on heritage assets outside of the Area boundaries has also been considered/assessed.
This Document makes no reference what so ever to the presence of, or effect upon, Norgrove Court, the only grade 1 listed building in the Redditch area. All water/effluent run off from the developed area at Foxlydiate, or the Webheath ADR will run down to Norgrove Court. If the sewage pumping system ever fails at Foxldiate, then contamination will flow directly downstream to Norgrove and its pools and immediate environment, and then on downstream.
OBJECTION 3 Page 63 9.117 It is considered therefore, that the presence of flooding is not a key determining factor in the site selection process. This is partly because relatively large study areas were examined and sites affected by flood zone 3 did not cover entire areas, Flood zone 3 generally presenting the highest risk 1 in flooding terms. Therefore subsequently defined developable area boundaries could avoid such areas. 9.118 If flooding was identified as a risk factor in the Areas, it was generally regarded that this could be incorporated as a positive feature in terms of Green Infrastructure, for example, this could be designed into any development which, although this could affect overall site capacities likely to be achieved, it could be resolved at masterplanning stages of development. 9.119 The HGDS SA sustainability objective E6 covers flooding issues and refers to the Levels 1 & 2 Strategic Flood Risk Assessments (SFRA) in the commentaries for each Area. Scoring is related to the extent of historic and potential for flooding in each of the Areas. Most Areas consistently score negatively in this respect. Therefore in conclusion, it is considered that the presence of flooding is not a key determining factor in the Area selection process.
The document has taken no consideration as to the likely effects of this development down stream of the Webheath ADR or of Foxlydiate. The consequences downstream to Norgrove, Elcocks Brook, Feckenham and onwards to Shell and Himbleton have not been addressed.
Please acknowledge receipt of this communication.
Ben Sinclair. 159 Heathfield Road, Webheath, Redditch, Worcestershire B97 5RG 3 May 2015
2 Dear Sir,
I am writing to object to the revised narrative of the BORLP4 document on the site selection process for the growth areas at Redditch (January 2016).
This document is flawed and would appear to be misleading, repeating significant mistakes found in previous versions of the selection process and presenting further unsound changes, as evidence.
It would appear that this document has been produced in order to legitimise a decision already been taken by RBC with regard to site selection of areas for development.
OBJECTION 1
My first objection is to the quality of the document itself, which is poor, & a turgid piece of work.
The document is extremely difficult for a layman to interpret, being confusing, monolithic, of great length, and verbose.
It would appear that its primary purpose is to deter ordinary members of the public from participating in the commentary process. Many will fail to object, as a direct result of its literary quality. The low numbers of objections will be a reflection of this, rather than a mirror of how few people are minded to comment
OBJECTION 2. Page 58 - 9.89 When considering the impact of proposed development on the significance of a designated heritage asset, the NPPF requires that great weight is given to the asset’s conservation. The NPPF also recognises that the significance of a heritage asset can be harmed or lost by development within its setting. For this reason, the potential impact on heritage assets outside of the Area boundaries has also been considered/assessed.
This Document makes no reference what so ever to the presence of, or effect upon, Norgrove Court, the only grade 1 listed building in the Redditch area. All water/effluent run off from the developed area at Foxlydiate, or the Webheath ADR will run down to Norgrove Court. If the sewage pumping system ever fails at Foxldiate, then contamination will flow directly downstream to Norgrove and its pools and immediate environment, and then on downstream.
OBJECTION 3 Page 63 9.117 It is considered therefore, that the presence of flooding is not a key determining factor in the site selection process. This is partly because relatively large study areas were examined and sites affected by flood zone 3 did not cover entire areas, Flood zone 3 generally presenting the highest risk in flooding terms. Therefore subsequently defined developable area boundaries could avoid such areas. 9.118 If flooding was identified as a risk factor in the Areas, it was generally regarded that this could be incorporated as a positive feature in terms of Green Infrastructure, for example, this could be designed into any development which, although this could affect overall site capacities likely to be achieved, it could be resolved at masterplanning stages of development. 9.119 The HGDS SA sustainability objective E6 covers flooding issues and refers to the Levels 1 & 2 Strategic Flood Risk Assessments (SFRA) in the commentaries for each Area. Scoring is related to the extent of historic and potential for flooding in each of the Areas. Most Areas consistently score negatively in this respect. Therefore in conclusion, it is considered that the presence of flooding is not a key determining factor in the Area selection process.
The document has taken no consideration as to the likely effects of this development down stream of the Webheath ADR or of Foxlydiate. The consequences downstream to Norgrove, Elcocks Brook, Feckenham and onwards to Shell and Himbleton have not been addressed.
Please acknowledge receipt of this communication.
Ben Sinclair. 159 Heathfield Road, Webheath, Redditch, Worcestershire B97 5RG 3 May 2015