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Webheath (Neighbourhood) Action Group Pre-Hearing Statement

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Webheath (Neighbourhood) Action Group Pre-Hearing Statement Webheath (Neighbourhood) Action Group Pre-Hearing Statement March 2016 1.0 Introduction: 1.1 - This statement is written as an overview and summary of the evidence contained in documents submitted for consultation by: • PJ Planning Ltd. Hereafter referred to as PJP. • Enfusion (Environmental Planning and Management for Sustainability) Ltd. Hereafter referred to as Enfusion • Webheath (Neighbourhood) Action Group, Webheath residents and local County Councillor. Hereafter referred to as WAG. 1.2 - The aim of this statement is to offer further evidence that reinforces WAG’s submitted evidence for the past ten years. WAG, Consultants and residents, have proved, beyond reasonable doubt, that Redditch Borough Council’s (RBC) recommendations to build 3,200 houses in Webheath ADR (Area 3) and Foxlydiate (Area 4) are flawed. These areas are not sustainable when compared to Areas 8 (Bordesley) and Area 5 (Brockhill West - the south east sector). 2.0 Preliminary Statements: 2.1 - PJP/WAG fervently objects to the Council’s recommendations to build upon Area 3 (the Webheath ADR) and Area 4 (Foxlydiate). 2.2 - PJP/WAG submit that the Narrative fails in its intention to form an authoritative evidence for BORLP4. 2.3 - PJP/WAG contend that the Narrative fails to comply, address and inform the HMI’s concerns as expressed in his Letters, Notes and Post Hearing Statements, throughout 2014 and 2015. The detail of each one can be obtained via the RBC/HMI online List of Documents, posted by Helen Wilson, Programme Officer (including ED/19, ED/21, ED/31, ED/32, ED/35, ED/38, ED/40). 3.0 Flaws identified through Enfusion’s review of the ‘Narrative’: 3.1 - A review of the site selection and SA process carried out by Enfusion (XB1/6c) found that a fair and consistent appraisal of Broad Area Options had not been carried out. Page | 1 3.2 - The justification for the nature and significance of effects has not been made clear throughout the process and there are numerous inconsistencies in relation to how Broad Area Options have been assessed against SA Objectives and how mitigation has been taken into account. 3.3 - No further SA work has been carried out in relation to updated alternative scenarios - the SEA Directive and Regulations require the assessment of all reasonable alternatives. 3.4 - Given the lack of appraisal narrative and justification for the nature and significance of effects provided in Appendix D of the BORLP4 SA Report (May 2015), it is difficult for an experienced SA/SEA specialist, let alone a member of the public to easily understand what the effects of the different scenarios may be against the SA Framework as whole. 3.5 - Enfusion’s review of the ‘Narrative’ found that any reasonable alternative scenarios should be considered through the SA process to ensure compliance with the SEA Directive and Regulations. 3.6 - RBC’s rejection of site options 2 and 3 is flawed; these options are reasonable alternatives. 4.0 Supporting rationale for statements: For each of the following, please read the details contained in evidence supplied by consultation responses … PJ Planning Ltd, Enfusion (Environmental Planning and Management for Sustainability) Ltd., Webheath (Neighbourhood) Action Group and Webheath residents. 4.1 - RBC’s technical analysis is poor quality: • Bias against development at Area 8 (Bordesley) • Bias against development at Area 5 (Brockhill West) • Bias in favour of development of Area 3 (Webheath ADR) • Bias in favour of development of Area 4 (Foxlydiate) • To conduct a subjective SWOT analysis as the culmination of 10 years local planning is baffling and a final desperate attempt to justify a flawed pre- determined hypothesis. 4.2 - RBC has issued incorrect Statements & Information: There are numerous examples of incorrect statements and information, which aim to justify a flawed technical analysis, which in turn purports to prove a pre- determined decision (see detailed evidence in Ref. 50, PJP/WAG Representations – Appendix B and other critiques, Refs. 18, 25, 30, 30{2}, 59). 4.2.1 - An Important Example of this is: Page | 2 RBC evidence is false … “The route along the main road into the Town Centre is particularly unattractive, with inadequate footways, isolated sections with no overlooking, large-scale roadside laybys and a forbidding major roundabout junction.” (16.19). A walker does not walk past a large-scale roadside lay-by and a forbidding major roundabout junction; they walk safely via the footpath access to the Birmingham Road. RBC also state … “Area 8 is 4.1km away from the Town Centre” (9.48). It is not … Google maps says 2.2km. (Ref. 58) 4.3 - RBC has issued Inconsistent Information: There are numerous examples of incorrect statements and information, which attempt to justify a flawed technical analysis, which in turn seeks to prove a pre- determined decision (see detailed evidence in PJP/WAG Representations – Appendix B and other critiques). 4.3.1 - An Important Example of this is: Despite the Webheath ADR (Area3) adjoining Norgrove Court, the only Grade I listed building in Redditch, there is no mention within the Narrative of a full Impact Assessment being carried out for this site. The ADR is clearly visible from and wouldsignificantly impact upon, the ‘High(est) Value Sensitive to Change’, Historic Setting of Norgrove Court, as illustrated in previous submissions. Brockhill West (Area 5) however, receives extensive attention in relation to the setting of Hewell Grange (location of HMP Hewell), despite the fact it has far superior screening in terms of woodland than is the case with Norgrove Court. The reason for this anomaly is not explained anywhere within the Narrative document, which is a significant omission given that development on Site 5 is more or less decided by its proximity to a Heritage Asset. A short piece of aerial video footage has been included as part of WAG’s submission, which covers the area above the Webheath ADR, across to Norgrove Court. If you watch the video, it is clear how close the ADR development comes to Norgrove Court, and how its setting will be irreversibly damaged by development on this land. 4.4 - RBC has Omitted Important Information: 4.4.1 - Access to employment for Bordesley (Area 8) – RBC only discuss employment opportunities in Redditch Town Centre. Why do they not mention the close proximity to the Enfield Industrial Estate, hotel, hospitality, leisure industry (including RBC), Redditch Eastern Gateway (1,500 new jobs) or the West Midlands Combined Authority (500,000 new jobs)? 4.4.2 - Land contamination – GeoRisk report (September, 2014) records contamination upon the Webheath ADR (Area 3). Why do we mention this? Because, there is historic dumping (night soil collections) across all of the Webheath ADR (Area 3), including this newly proposed sector of the Webheath ADR. (SOURCE: Adrian Bedford Smith and A Dozen Dreams by Catherine Drabble – 2005, pages 24/25). Page | 3 4.4.3 - Webheath ADR (Area 3) and Foxlydiate (Area 4) are visible from an Area of Outstanding Natural Beauty (AONB) Bredon Hill and the Malvern Hills. 4.4.4 - Worcestershire Wildlife Trust’s response to the Narrative and SA consultation highlighted that, with regard to the Webheath ADR and Foxlydiate, there is at present a grave risk to downstream water quality and flooding affecting the Bow Brook catchment, which is subject to an EU Water Framework Directive. Will building over 3,500 new houses upstream of this sensitive watercourse improve or damage water quality and eco systems? In all probability the Bow Brook catchment will be damaged. 4.4.5 - There is a lack of effective analysis of the transport/traffic impact upon the existing inadequate lanes and roads in the Webheath ADR (Area 3) and Foxlydiate (Area 4). The Webheath and Bentley communities will, in all probability, suffer consequential road safety impact affecting the health and safety of residents. 4.4.6 - White Young Green 1 (2007), and 2 (2009) clearly states how unsustainable the Webheath ADR (Area 3) and Foxlydiate (Area 4) are. The ‘Narrative’ is inconsistent. If RBC can quote these documents to support their case, WAG must reference those that support their views also. Nothing has changed, the Webheath ADR (Area 3) and Foxlydiate (Area 4) still display a range of, “significant disadvantages”. 4.4.7 - As 4.3.1, the poor RBC analysis of Norgrove Court and the inexplicable over- protection of Hewell Grange. 4.4.8 - Please see detailed evidence in PJP/WAG Representations – Ref. 50, PJP/WAG Representations – Appendix B and other critiques, Refs. 18, 25, 30, 30{2}, 59). 4.5- There is New Information to Note: 4.5.1 - The emerging site capacity (10.2 & 10.3) of the Webheath ADR will be compromised due to the number of developers that intend to exceed the proposed net developable area. RBC propose the site is suitable for up to 400 new houses. There are at least three other developers, apart from Barratt/Taylor Wimpey who propose building up to 400 new houses, with planning proposals or applications for other plots on the site … Plan It (Garage+) – 80 houses, Redditch BC (Upper Norgrove House) – 40 houses, unknown developer proposed capacity. How many more houses will be built upon the Webheath ADR? 4.5.2 - The Webheath ADR (Area 3) and Foxlydiate (Area 4), south west of Redditch, is the wrong geographic location to build new houses The Birmingham-dominated West Midlands Combined Authority (of which Redditch is a member) will bring 500,000 new jobs to the region. The Redditch Eastern Gateway will create thousands of jobs for Redditch. Evidence: Government HM Treasury, ‘Fixing the Foundations : Creating a More Prosperous Nation’ (2015) says on page 43 to Page | 4 build houses where the jobs are located.
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