Emma Newfield

From: Sent: 08 April 2015 23:07 To: Consult Planning Subject: Borough of Local Plan No4 and Bromgrove District Plan- Sustainability Appraisal Consultation Attachments: RBC Local Plan No.4 - response.doc

Dear Sir

Studley Parish Council's written consultation response to the Borough of Redditch Local Plan No:4 remain unchanged when consulted in November 2013. I attached a copy of the response to be resubmitted for the above.

Kind regards

Linda Stanton Assistant Clerk to Studley Parish Council Studley Parish Council Studley Village Hall High Street Studley B80 7HJ

1

Borough of Redditch Local Plan No.4 Proposed Submission Document

Representation Form

Please return by 5pm on Monday 11th November 2013

Redditch Borough Council is asking for representations on its Proposed Submission version of the Borough of Redditch Local Plan No.4 (BORLP4), which outlines the strategic planning policy framework for guiding development in the Borough up to 2030. It comprises a long-term spatial vision and strategic objectives, a spatial strategy, core policies, strategic and non-strategic site allocations, and a monitoring and implementation framework. The Plan also includes a copy of the Redditch Cross Boundary Development policy (Appendix 1), which appears in the Bromsgrove District Plan as Policy RCBD1.

Whether or not you have been involved in any of the earlier stages of the plan making process, there is still the opportunity to be involved by commenting on the legal compliance or soundness of the Plan. Any representations should be made using this Form and returned by 5pm on Monday 11th November 2013 to:

Development Plans Team Redditch Borough Council Walter Stranz Square Redditch Worcs B98 8AH

Or emailed to: [email protected]

Please complete a separate form for each representation you wish to make

This form has two parts:

Part A: Personal Details • You do not need to complete Part A more than once, but please ensure you state your name or organisation as applicable at the top of each Part B form you submit.

Part B: Your representations • Please complete Part B of this form for each representation you wish to make. • You do not need to complete Part A more than once, but please ensure you state your name or organisation as applicable at the top of each Part B form you submit. • Please refer to the attached Guidance Notes on making representations so that they address issues of legal compliance and/or soundness.

Please note that when representations are submitted Part B of the form will be published and therefore cannot be treated as confidential. Contact details on Part A will not be published.

Part A (see Note 8)

How we will use your details: The personal information you provide on this form will be processed in accordance with the requirements of the Data Protection Act 1998. It will be used only for the preparation of local development documents or any subsequent statutory replacement. However, your name and representation will be made publicly available when displaying and reporting the outcome of the consultation stage, and cannot be treated as confidential. Other details including your address and signature will be treated as confidential.

Personal Details Agent’s Details (if applicable) Title: Title: Mrs First Name: First Name: Lesley Last Name: Last Name: Gailey Job Title: Job Title: Clerk to the Council (if applicable) (if applicable) Organisation: Organisation: Studley Parish Council (if applicable) (if applicable) Address 1: Address 1: Studley Village Hall Address 2: Address 2: High Street Address 3: Address 3: Studley Address 4: Address 4: Warwickshire Postcode: Postcode: B80 7HJ Telephone No: Telephone No: Email address: Email address:

Notification Request: Please tick the boxes below if you wish to be notified at any of the following Local Plan stages: √ that the BORLP4 has been submitted for independent examination √ the publication of the recommendations of the person appointed to carry out an independent examination of the BORLP4 √ the adoption of the BORLP4

If the notification address is different to that stated above, please specify here:

Your details will remain on our database and will be used to inform you of future Policy Planning matters and procedures following the adoption of BORLP4. If at any point in time you wish to be removed from the database, please contact us and we will remove your information.

Part B (see Note 1 and Note 8 para 4.2)

Please use a separate Part B form for each representation you wish to make

Name or Organisation (see Note 8 para 4.1)

Studley Parish Council

1. To which part of the BORLP4 does this representation relate?

Page: Paragraph: Policy: Policies Map: Other document: Any part of the document that refers to or has an implied impact on Studley

If your representation does not relate to a specific part of the document, or it relates to a different document, for example the Sustainability Appraisal, please make this clear in your response.

2. Do you consider the BORLP4 is legally compliant? (see Note 2)

No:

3. Please give details of why you consider the BORLP4 is not legally compliant. Please be as precise as possible. If you wish to support the legal compliance of the BORLP4, please also use this box to set out your comments. (Continue on a separate sheet /expand box if necessary)

RBC has failed to consult with any of the local Parish Councils that the proposals contained in BORLP4 will affect. This is contrary to Objective 13 Page 20.

There are many other areas where consideration has not been given as to the wider area the proposals will affect. The following pages all include proposals that will have a detrimental impact to the residents of Studley and the surrounding area.

Page 20: Objective 1. Developing industrial units on land to the West of will have a massive visual impact from Studley and most of Redditch which will not “maintain the high quality natural, rural and historic environment”. The same applies for building along the A435 and behind the Alexandra Hospital. Objective 4. As above Objective 5. Industrial units on the West of Gorcott Hill will not encourage safer sustainable travel patterns

Page 26: Policy 4 There is no capacity along the A435 for additional development. It has been widely accepted that the a435 is at capacity by several planning inspectors and any development feeding traffic onto the A435 will not be acceptable.

There has been no discussion with any of the Parish Councils along the A435 regarding development.

Page 34 Policy 8 The proposal to develop land to the west of Gorcott Hill that is in the Green Belt has not been tested properly against other sites within Redditch. It is in a location remote from public transport connections and housing meaning any employees will have to use private motor vehicles. Its impact on the landscape is also ignored. Industrial use of this type is defined as inappropriate in the NPPF.

Page 38 Creating and Sustaining a Green Environment Any proposal for developing along the A435 will involve felling trees and impacting on a natural wildlife corridor that separates Redditch from Mappleborough Green. Building Industrial units on Green Belt when there are green field and brown field sites within Redditch that would be far less damaging cannot be considered as sustaining a green environment.

Page 54 Policy 19 viii No proposals have been included for reducing the impact that additional traffic the present proposals will have on the A435 and the AQMA within Studley. Without amelioration works to reduce traffic flows on the A435 the objectives of Policy 19 cannot be met.

Page 57 This page states “there are no AQMA’s within the Borough” and states that regard should be paid to AQMA’s in neighbouring areas yet chooses not to mention the ones in Studley and nearby Henley in Arden, both of which will be impacted by any increase in traffic expansion of housing and employment sites will have. No discussion has been held with SDC on ways to minimise the impact on these AQMA’s.

Page 58: Policy 20 The proposal for additional housing behind the Alexandra Hospital cannot be considered to be within “250m of local services. No consideration has been given as to how these proposals will impact on the traffic flows in and around Studley, and Mappleborough Green whose roads will suffer even further by redditch residents using them as a rat run to avoid Redditch Road network bottlenecks.

Page 119 Policy 47 Any development that reduces the separation between Studley/Sambourne/Mappleborough Green and Redditch will be unacceptable. The amalgamation of Redditch with the surrounding villages in Warwickshire has always been strongly resisted as it would have a massive detrimental impact on those settlements.

The location is far removed from local centres promoting the use of the car for the majority of journeys, further exacerbating the traffic problems around this area.

The suggestion of a “multi model transport facility at the Alex misses a real opportunity for Redditch to do something positive. Instead of relying on buses and cars, RBC should investigate extending the railway from Redditch station, through the existing tunnel and along the Highway. This would benefit many areas in Redditch and this could be put to good use with a park and ride to reduce car travel rather than more houses that can only make it worse.

Appendix 5 RCBD1 Redditch Cross Boundary Development. No discussions have been held with Studley PC on any of the proposals contained in this policy. RBC has chosen to ignore the residents of Studley to the detriment of them all. Failure to include Studley in the forward planning can only lead to a poor quality Plan that will not meet the Councils duty to consult with neighbours.

The whole plan needs re-writing after taking more interest in its closest neighbours and how the expansion proposals will affect them.

4. Please set out what change(s) you consider necessary to make the BORLP4 legally compliant, having regard to the issue(s) you have identified above. You will need to say why this change will make the BORLP4 legally compliant. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. (Continue on a separate sheet /expand box if necessary) (see Note 8 para 4.3)

The complete document needs to be reassessed taking into consideration the impact the proposals will have on the surrounding villages and the transport network.

5. Do you consider the BORLP4 is sound? (see Note 3)

No:

Do you consider the BORLP4 is unsound because it is not:

(1) Justified (see Note 4) yes (2) Effective (see Note 5) yes (3) Consistent with national policy (see Note 6) yes (4) Positively prepared (see Note 7) yes

6. Please give details of why you consider the BORLP4 is unsound. Please be as precise as possible. If you wish to support the soundness of the BORLP4, please also use this box to set out your comments. (Continue on a separate sheet /expand box if necessary)

Lack of consultation and disregard of a widely available evidence base show that RBC has chosen to disregard the NPPF, Parish Plans, adjoining Councils Proposed Strategies, and local residents and their representative Residents Associations.

7. Please set out what change(s) you consider necessary to make the BORLP4 sound, having regard to the test you have identified at 6 above. You will need to say why this change will make the BORLP4 sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. (Continue on a separate sheet /expand box if necessary) (see Note 8 para 4.3)

By addressing the objections, comments and suggestions made above, RBC could produce a plan that does meet with its admirable objectives instead of the one that in its present form is at odds with many of them.

Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change(s), as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage.

After this stage, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination.

8. If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination.

No, I do not wish to participate at the oral examination Yes, I wish to participate at the oral examination yes

9. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary. (Continue on a separate sheet /expand box if necessary)

As RBC has chosen not to consult with its neighbours, being given the opportunity to address the concerns of residents to an Inspector is vital if the plan is to be considered sound.

Signature: Lesley Gailey Date: 11/11/2013