Appendix A – Responses to Preferred Draft Core Strategy consultation
Analysis of Green Belt and Areas of Development Restraint ...... 2 Attractive Facilities...... 22 Balance between housing and employment...... 45 Climate change and sustainability ...... 80 Cross Boundary...... 130 Delivery Strategy ...... 193 Design and Safety ...... 205 Development Strategy...... 208 Enterprise and Skills ...... 226 Historic Environment...... 256 Infrastructure...... 259 Landscape, open space, nature, pollution, Green Belt...... 269 Miscellaneous ...... 294 Open Space Needs Assessment ...... 306 Policy SP.3...... 307 Procedural ...... 321 Retail...... 341 Strategic Housing Land Availability Assessment...... 369 Sustainability Appraisal ...... 511 Sustainable Developments Strategy...... 518 Sustainable Transport...... 565 Vision and Objectives ...... 582 Waste...... 601 Water and Flooding...... 602 Winyates Green Triangle ...... 619
1
Analysis of Green Belt and Areas of Development Restraint
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representati on No. Analysis of 022/104; RPS Detailed Landscape Para. 2.1 of the Analysis of GB No change Green Belt Assessment Study makes it abundantly and ADR evident that a comprehensive within RPS note that this document is overview of Green Belt parcels Redditch intended to ‘tell the story’ of was undertaken by much Borough each of the Green Belt and reference to a diverse set of ADR sites and as such refers previous studies to to a number of other sources of demonstrate the various information. As such, it factors that would mitigate presents information regarding against development in the each site but does not Green Belt in Redditch. This undertake a detailed landscape paragraph concludes by stating assessment of each of the that this diverse set of studies parcels of land or qualify the provided and supported the findings as one would expect Council’s reasoning for against PPG2: Green Belt. avoiding development in the Green belt in Redditch.
The Plan at Appendix 1 of the
2 Analysis of GB Study is an abstract of information from the Worcestershire Landscape Character Assessment and gives a broad assessment of landscape sensitivity around Redditch. The plan indicates that the majority of the land which is the subject of the ‘north west urban extension’ promulgated by RPS on behalf of clients is of high landscape sensitivity and only a small tract of land to the north west to be medium landscape sensitivity. It is accepted that the Brockhill East ADR is also within the area of high landscape sensitivity but this will be discussed later in this response.
In relation to the references to PPG2 by RPS, it is pertinent to refer to two of the five purposes of including land in Green Belts in Paragraph 1.5 of PPG2 which are most relevant to the area of the Green Belt which is the subject
3 of this response viz:
• to check the unrestricted sprawl of large built-up areas • to assist safeguarding the countryside from encroachment
Paragraph 1.6 of PPG2 relates to ‘The use of land in Green Belts’ and it is also pertinent to restate that one of the objectives in relation to the use of land within Green Belts is:
• To retain attractive landscapes, and enhance landscapes, near to where people live.
The in-depth studies undertaken so far have been sufficient to assess the individual parcels of land in accordance with the spirit of PPG2 and particularly the purposes and objectives of
4 PPG2 set out above. Brockhill East Area of It is noted that RPS concurs Consider the contributions Development Restraint – with the Analysis of GB Study which could be made by the findings in relation to Brockhill ADRs following joint The study considers the ADR and that development consultation with Bromsgrove Brockhill East ADR in detail here is acceptable. This was District Council. which forms part of the the stance of the Council at the proposed North West Redditch time of drafting the Analysis of Update Key Diagram to show Urban Expansion and notes the GB Study when the report was the broad location of the SUE conclusion that it is ‘ acceptable drafted in the light of /SUEs boundary to be in planning terms and the Area information available to the determined in collaboration is preferable to other Green authority at that time. However, with Bromsgrove District Belt areas south-west of since the preparation and Council Redditch and west of Astwood completion of the Analysis of bank ’ based on the findings in GB Report, White Young the study. RPS fully concurs Green (WYG) completed their with the findings in the report Stage II Report. It is evidenced and the conclusion that in previous planning development at Brockhill is documentation relating to the acceptable. RPS also comment Borough of Redditch Local that it is worthy of note that the Plans 2 & 3 that the three findings apply in large measure ADRs had potential for to the adjoining land in the development. It should be Green Belt adjacent to Brockhill noted that during previous plan in Redditch and in Bromsgrove preparation, officers were Districts. restricted to searching for appropriate and suitable land for development within the Borough’s administrative boundary only. The three
5 ADRs offered the most appropriate locations for development at that time. Changes to the planning system have allowed for cross- boundary investigation for sustainable locations for Redditch related development. Officers will need to reconsider the contribution that ADR land could make to meeting the housing allocation following joint consultation with Bromsgrove District Council. Despite the Council reaching Paragraph 5.02 of the Stage II Consider the contributions conclusions independently, the Report explained that WYG which could be made by the evidence contained within the had reviewed sites within ADRs following joint Council’s document contrasts Redditch Borough including consultation with Bromsgrove with findings within the WYG Brockhill. WYG concluded in District Council. Stage 2 Report which RPS their understands was also an recommendation in Paragraphs Update Key Diagram to show independent assessment and 7.01 and 7.02 that “Whilst all the broad location of the SUE published at the same time. the options for urban /SUEs boundary to be RPS cannot therefore extensions are to a greater determined in collaboration comprehend how the Council lesser degree harmful, we with Bromsgrove District can attach significant weight to consider that a concentration of Council. two pieces of its evidence that development at Bordesley Park are contradictory and claim that demonstrates the greatest they are both robust enough to opportunity to accommodate inform and support a justified either development option
6 Core Strategy. within manageable impacts . The site is within the designated Green Belt but we are of the opinion that this section is less vulnerable than the Green Belt that separates Redditch from Astwood Bank or Studley and the topography of the area assists in containing the development and minimising the impacts on the surrounding countryside than would be the case at Webheath ADR, Brockhill ADR or Foxlydiate Woods”. Paragraph 7.12 of the Stage II Report went on to recommend that the three sites currently designated as ADRs including Brockhill in Local Plan No.3 should be added to the Green Belt and therefore should not continue to be considered for development. Officers will need to reconsider the contribution that ADR land could make to meeting the housing allocation following receipt of the WMRSS Phase Two Panel Report.
7 The Brockhill Area Green Belt RPS comment in Paragraph Consider the contributions – 5.5 of the representation that which could be made by the they are concerned to read that ADRs following joint Section 5 of the report conclusions in Section 5 for the consultation with Bromsgrove appraises the area of Green Brockhill Green Belt Area in the District Council. Belt within the Brockhill Area Analysis of GB Study report which is in part adjacent to the are contradictory to the findings Update Key Diagram to show Brockhill ADR. RPS is set out later in the report and the broad location of the SUE concerned that conclusions in repeated in respect of ADR /SUEs boundary to be Section 5 of the report for the land. However, the Council determined in collaboration Brockhill Green Belt Area are contend that this is not the with Bromsgrove District contradictory to the findings set case as it should be evident Council out later in the report and in from reading Section 5 of the respect of the ADR land, Analysis of GB report that the despite being adjacent to it. previous studies (including the This conflict is particularly 1973 Joint Study of Feasibility’ pertinent to issues that have and ‘Redditch Joint Study wider relevance than just site 1988) considered the ‘greater’ boundaries, such as landscape Green Belt area including land and visual impact. at Hewell Grange in Bromsgrove District. Despite the Joint Study of Feasibility and the Redditch Joint Study having been drafted some 30 and 21 years ago respectively, their findings are still valid today in the opinion of the Borough Council and it is relevant to reiterate some of those findings. The 1973 Joint
8 Study of Feasibility considered that the landscape quality in this area presented two kinds of restraint upon development in the Brockhill area namely the high landscape value and the extensive stands of trees (which were and still are particularly accentuated at Hewell Grange immediately abutting the Brockhill area) and both affected the areas feasibility for development. The Redditch Joint Study of 1988 drew attention amongst other things to ridges of high ground which would be prominent for some distance from the surrounding area contrary to prevailing Structure Plan policies. Ridge lines were identified at Hewell Park and Butlers Hill to the Northwest of Redditch and in the vicinity of the Brockhill area. Development in these areas was considered to be ill advised based on those findings. Although in
9 Bromsgrove District, parts of Hewell Park, Cladshill and Brockhill Wood were identified as being of high ecological value all of which lead to the conclusion that this part of the Green Belt is still considered unsuitable for development including the land to which RPS relates. The Landscape and Visual Assessment for the North West Redditch Master Plan (NWRMP) also emphasised the importance of this area and is discussed in Paragraph 8.3.11 et seq of the Analysis of GB Study. In addition to the references to this assessment in the Analysis of GB Study, Paragraphs 4.3 and 4.14 of the Landscape and Visual Assessment are particularly pertinent and are set out in full below:
Landscape Type 1: Wooded High Ground
4.13 The Wooded High Ground is defined by
10 large areas of irregular shaped woodland, such as Brockhill Wood, situated on or around high or steeply sloping ground. The ridge of Butler’s Hill, Brock Hill and Lowan’s Farm, forms a prominent and visually important landscape feature, enclosing the valleys below. Small farmsteads and clusters of farm buildings occur throughout the area. There is also evidence of mining scattered across the hillside. Aside from the large areas of woodland, there is little in terms of significant vegetation, with many field boundaries now solely enclosed by post and wire fencing. Hedgerows along farm tracks and the railway line provide some linear features, but, in general
11 the field boundaries are gappy and inconsistent throughout the area.
4.14 Most of the Wooded High Ground is designated as a Landscape Protection Area due to its visual prominence and well wooded character. This area would be sensitive to change and contains a number of valued landscaped features.
Although only indicating a broad indication of landscape sensitivity round Redditch, the abstract of information from the Worcestershire Landscape Sensitivity shown on Plan 1 is more than sufficient to highlight the importance of the landscape in the north west area around Redditch and supports the findings of those earlier studies. The RPS reference to a disparity between the conclusions in
12 Section 5 and Para 9.06 is hard to understand. Clearly, Section 5 of the Analysis of GB report discusses the ‘greater’ Green Belt in the Brockhill area whilst Paragraph 9.06 solely discusses the Brockhill ADR which had been examined in depth by the Inspector’s examining Local Plan No.2 and Local Plan No.3. Paragraph 5.7.0 refers to and For the avoidance of doubt, it Consider the contributions attaches weight to the WYG should be made clear that which could be made by the Report landscape and visual Paragraph 5.7.0 of the Analysis ADRs following joint analysis assessment, although of Green Belt Report consultation with Bromsgrove it is not clear as to which WYG (Paragraph 5.6 of RPS District Council. report the paragraph refers to, representations) refers to the as neither conforms with the ‘WYG Stage I Report’ prepared Update Key Diagram to show statement made. The WYG in December 2007. Although the broad location of the SUE report has not undertaken any dated 27 th October 2008, the /SUEs boundary to be form of assessment of the Analysis of GB report was in determined in collaboration Green Belt in respect of its fact drafted prior to the receipt with Bromsgrove District functions as set out in PPG2. It of the WYG Stage II Report Council has undertaken an over and explains why there is no simplistic and out of date identification to this being the SWOT analysis which is not a ‘Stage I Report’. Indeed, the tool fit for purpose for Bibliography to the Analysis of assessing such issues, in GB report concludes by particular Green Belt and visual referring solely to the ‘Joint impact. Such an approach will Study into Future Growth
13 not stand scrutiny at Implications of Redditch New examination and a Town to 2026’ prepared in comprehensive approach is December 2007 and not to the required that is qualified and later Stage II Report. The consistent in the opinion of outcome of the WYG Stage II RPS. The Green Belt land in Report arose from the further the Borough has not been independent studies considered in RPS’s view with undertaken by WYG following open mind by the authors of completion of the Stage I this report Report.
In relation to the assertions made by RPS in Paragraph 5.6 of their representations that the WYG report ‘ has not undertaken any form of assessment of the Green Belt in respect of its functions as set out in PPG2’ and that WYG ‘has undertaken an over simplistic and out of date SWOT analysis which RPS has already set out above, is not a tool fit for purpose for assessing such issues, in particular Green belt and visual impact’ cannot be accepted by the Council. The Council consider that both the WYG Stage I and Stage II Reports
14 demonstrate adequate consideration of the purposes and objectives of the Green Belt as set out in PPG2. Some specific references (although there are many) to both the Stage I and Stage II reports may be useful to demonstrate that there has been an adequate examination in line with PPG2 as follows:
WYG Stage I Report
Paragraph 2.04 et seq – Current Strategic Planning Context – aims and purposes of the Green Belt according to PPG2 restated.
Paragraph 7.04 SWOT Analysis – WYG assessed in each case the extent to which the Green Belt purposes (PPG 2) would be harmed.
Paragraph 8.28 South West Quadrant – loss of attractive countryside and coalescence.
15 Paragraph 9.05Conclusions – Options 2 and 3 perceived as major incursions into the countryside.
WYG Stage II Report
Paragraph 4.04 Constraints on Development – The Green Belt – PPG2 purposes of Green Belts
Paragraph 4.05 Constraints on Development – Redditch not a historic town but principal aim of Redditch Green Belt to prevent neighbouring towns coalescing, to prevent unnecessary sprawl and to safeguard the countryside.
Paragraph 5.13 Brockhill – potential effects of developing slopes in an area of landscape value outweigh benefits of location near town centre.
Paragraph 7.09 – Webheath ADR – not suitable for development – quality and
16 character of landscape. In the context of the Paragraphs 5.0.0 and 5.1.2 of Consider the contributions requirement to undertake a full the Analysis of GB Study report which could be made by the comprehensive assessment of drew attention to the concerns ADRs following joint the Green Belt in this area RPS expressed in the earlier studies consultation with Bromsgrove has set out a number of initial of 1973 and 1988 regarding the District Council. points in Paragraph 5.8 and high landscape value and ridge considered Bordesley Park lines of the Brockhill, Hewell Update Key Diagram to show against similar criteria. The Grange and Foxlydiate areas the broad location of the SUE North West Urban Extension which still hold good in the /SUEs boundary to be land should be positively opinion of the Borough Council. determined in collaboration considered for strategic site It is also relevant to draw with Bromsgrove District allocation on the grounds that: further attention to the Council • The landscape is not Landscape and Visual unduly prominent; Assessment of the NWRMP. • The development Paragraph 4.13 and 4.14 of effectively will be contained that assessment describe the within the bowls of the landscape of much of this area Batchley Brook and Red and Plan LO5 and Plan LO2 Ditch valleys; illustrate the landscape • Less best and most character and landscape versatile agricultural land planning context respectively. would be affected at North Just to recap, much of the West Redditch than at Woodland High Ground is Bordesley Park; designated as a Landscape • Existing woodland would Protection Area due to its be protected and linkages visual prominence and well provided between them; wooded character and it is • A lesser extent of sand and emphasised that the area would be sensitive to change
17 gravel deposits would be and contains a number of affected than at Bordesley valued landscape features. Park; This prominent and visually • Given that the Green Belt important landscape feature boundary needs to be incorporates the eastern half of reviewed, the proposals the North West Urban can provide a very Extension promoted by RPS. satisfactory altered Green Whilst RPS contend that these Belt boundary that is landscape protection areas are compliant with PPG2 no longer sustainable and advice. should be reviewed in the light of current advice, this view is conjectural and they are nonetheless designated areas in the Bromsgrove Local Plan and highlight the importance of this visually important area. Paragraph 5.10 of the Stage II Report draws attention to the Plan 5 showing the Brockhill topography and in particular, to the prominent ridge running into the site from north-west to south-east and that the site’s topography may reduce its capacity particularly as it would be necessary to take into account the distant views of the site from the surrounding area. According to the Ministry of
18 Agriculture, Fisheries and Food Land Classification Map published in 1969 there would seem to be little difference in the classification of agricultural land in both areas. Both areas are shown primarily as Grade 3 agricultural Land on the 1969 Land Classification Map. The North West Urban Extension is mainly Grade 3 interspersed with some land primarily in non-agricultural use i.e. woodland whilst Bordesley Park is primarily Grade 3 with some land predominantly in urban use around the A441 at Bordesley and B4101. It is accepted that the existing woodland could be incorporated within the potential development areas with appropriate linkages. Examination of the County of Hereford and Worcester Minerals Local Plan adopted in April 1967 would suggest that there is little real difference in sand and gravel deposits in either area. The proposals map
19 does show in broad terms, ‘Identified Minerals Deposits’ of sand and gravel both at Bordesley and Foxlydiate which may not be significantly different in extent if any development areas have finally been adopted in either area. It is also worthy of note that an The Council consider that this Consider the contributions element of the Green Belt land comment is perhaps which could be made by the adjacent to the Brockhill ADR is erroneous. The northern area ADRs following joint identified in the WYG open is identified in red as low value consultation with Bromsgrove space assessment as having a semi-natural open space as District Council. limited value in terms of a part of Site Ref 3 on Plan 1 of natural habitat and no amenity Appendix 1 but it is not Update Key Diagram to show value. This area referred to is designated as Primarily Open the broad location of the SUE illustrated in Plan 1 of Appendix Space in Local Plan No.3. /SUEs boundary to be 1 of the WYG Study. However, it is designated determined in collaboration Green Belt in Local Plan No.3 with Bromsgrove District and this particular area is not Council discussed in the Amenity Open Space Review Summary Sheets on Page 7 of Appendix 1. The study provides a good The Analysis of GB Study Consider the contributions starting point for collating makes it abundantly evident which could be made by the information on the Redditch that a review of Green Belt ADRs following joint Green Belt and ADR land but it parcels was undertaken by consultation with Bromsgrove cannot be considered a much reference to a diverse District Council.
20 comprehensive policy set of previous studies assessment of the Green Belt demonstrating the various Update Key Diagram to show and ADR land in itself as its factors that would militate the broad location of the SUE conclusions are not qualified on against development in the /SUEs boundary to be primary evidence, nor are the Green Belt in Redditch. The determined in collaboration references to other sources. As Council contend that the in- with Bromsgrove District a result of this, its findings are depth studies undertaken so Council inconsistent and also with that far have been sufficient to of other elements of the LDF assess land in the Green Belt evidence base. The Study in accordance with the should therefore be reviewed objectives set out in PPG2. In and be provided with relation to the Brockhill East supplementary primary Area of Development Restraint, evidence supplied through a RPS’s concurrence with the qualified and comprehensive findings and that development Green belt Review and here was acceptable was Landscape Character noted. This was the stance of Assessment of the area. This the Council at the time of will enable it to draw on more drafting the Analysis of GB appropriate evidence and Study in the light of information remove inconsistencies that available to the authority at that occur in the document. time. However, since the preparation and completion of the Analysis of GB Report, WYG completed their Stage II Report which was not available when the report was completed. The Council accept that these recommendations contrast with their previous
21 findings in Analysis of GB Report but having reviewed these and previous findings, the Council incorporated these new conclusions into what was presented in the Preferred Draft Core Strategy as an alternative approach, because options in and around Redditch are limited.
Attractive Facilities
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 017/241 Abbey Stadium. Due to Accept comments, but want to No action. facilities CPRE economic downturn, consider ensure that the scale of Policy SP.7 pursuing a smaller scale build? improved facilities serve the With swimming pool, renovate purposes of the local residents indoor /outdoor activity areas first and foremost and then whilst marking out those serve the needs of the public environmental areas that have further afield, as this would in to be protected such as :- turn generate tourism for the area. However, it is accepted Criterion viii River Arrow that any development of the Criterion ix Arrow Valley site would need to consider the
22 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Country Park sensitivity of some of the Cemetery and crematorium for environmental areas within the peace and quiet plus sensitive park and surrounding area, and consideration this is included within the body And respect setting of of the policy. Bordesley Lodge Farmhouse.
An Environmental Impact Accept comments. Officers to Refer to EIA guidance prior to Assessment regardless of consider EIA guidance to amending criterion iv. overall size and a sequential determine whether it still test as per criterion iv will be applies. required. CPRE consider an approach of designing in these facilities in situ and not cram the whole site with facilities that are not appropriate for Redditch residents.
Another opportunity needs to Comment is outside the remit No action. be taken up to interest the of the Core Strategy. Lawn Tennis Association in improving the tennis facilities and to promote the sport.
Attractive 017/246 Cinema has been left out of The first sentence of the No action.
23 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. facilities CPRE first sentence / paragraph. reasoned justification refers to Policy H.1 museums, visitor centres and accommodation such as hotels and guest houses. However, the second sentence states the purposes of the policy and includes reference to the cinema in addition to other sport and recreation uses as well as restaurants and bingo halls etc. Therefore there is no need to reference cinema in first sentence. Attractive 021/077 SP.7 generally aligns with Note comment. No action. facilities WMRA emerging WMRSS policy Policy SP.7 SR2D and other relevant WMRSS policies in particular emerging WMRSS policy PA10. Attractive 021/090 Policy H.1 is in line with Note comment. No action. facilities WMRA emerging WMRSS policy Policy H.1 PA.10. Attractive 021/092 H.3 accords with WMRSS Note comment. No action. facilities WMRA policy UR4 and SR2D Policy H.3
24 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 021/094 SC.2 accords with WMRSS Note comment. No action. facilities WMRA policies CF5A and CF6 Policy SC.2 Attractive 021/095 SC.3 accords with WMRSS Note comment. No action. facilities WMRA policy CF.7. Policy SC.3 Attractive 021/098 SC.6 is in line with WMRSS Note comment. No action. facilities WMRA policy CF.9 Policy SC.6 Attractive 027/474 Pleased that SP.7 ‘Abbey Note comment. Ensure that the contributions / facilities Highways Stadium’ makes provision for improvements etc. remains Policy SP.7 Agency developer contributions part of the policy SP.7 and towards infrastructure investigated in the improvements, including public development of an transport, pedestrian and cycle Infrastructure Delivery Plan. facilities and off site highway works. The Highways Agency assessed the planning application for the site in 2006, and while would be happy to reassess any future proposals, it remains possible that works may be needed at the junction to accommodate traffic generated by the development.
25 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 028/107 Pleased that the issue in Note comment. No action facilities GOWM respect to the needs of gypsies Policy SC.6 and travellers and travelling show people is being addressed. Attractive 029/710 Health and Well Being. The draft Core Strategy has No action. facilities Tetlow King Suggest that policy in health appropriately dealt with older H.3 RSL plng and well being be person accommodation under consortium supplemented with an Policy SC.1. additional policy on the provision of care for the elderly. Policy should highlight how ageing population is being accommodated within overall housing mix. National Strategy for Housing in Ageing Society (2008) highlights the need for policies to take into account the needs of the elderly. Important for Core Strategy to encourage separate consideration of this group. Reference should be made in policy regarding supporting development of residential care homes, extra
26 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. care facilities, sheltered housing and continuing care retirement communities. Provision of such housing offers choice, frees up under occupied family sized homes and improved quality of life including improved mental and physical well being of older people. Attractive 049/732 Note that how policy H.1 is Policy H.1 is recommended to Policy H.1 to be amended to facilities Worcs. CC worded it would require Abbey be changed to be more wide the following:- Tourism and Policy H.1 Stadium to be accompanied by ranging so it can set a leisure proposals, including and SP.7 a master plan. It is assumed framework for the Abbey new build, extensions or that this is the intention for Stadium to be implemented. It additions to existing facilities Abbey Stadium. is considered that a master will be promoted and supported plan is not required for the where the proposal is located Abbey Stadium but may be in places that are sustainable required for other large scale and accessible by a choice of tourism or leisure proposals transport modes and where that may come forward in the additional visitor numbers can Borough. be accommodated without detriment to the local environment, principally Redditch Town Centre.
27 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Tourism facilities may include museums, theatres, visitor centres and also accommodation such as hotels and guest houses. For the purpose of this policy, leisure facilities include intensive sport and recreation uses, cinemas, restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls, all of which are main Town Centre uses. Any proposals will therefore be required to comply with the relevant PPS4 tests and reference should be made to policy ES.5 Hierarchy of Centres and ES.6 Retail.
It is important that new and existing tourism and leisure facilities are supported provided that they are
28 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sustainable and of benefit to the local economy and community
Reference to the need to Accept comments and insert Insert in criterion viii, within the protect and enhance text into policy and/or context policy and its context, the need associated ecological habits referring to protecting the to protect the historic and floodplains under criteria historic landscape of Arrow landscape of Arrow Valley. viii of policy SP.7 and reasoned Valley. justification, reference should be made to the historic landscape of Arrow Valley. Attractive 049/749 Improving Health and Well Does not relate to specific No action. facilities Worcs. CC Being section – this section policy in this section. These H.3 could benefit from references Strategies have been to public rights of way network considered but references to in terms of benefits for health, these are not appropriate for reduction in car use, recreation the Core Strategy. and therefore tourism. Reference should be made to Rights of Way Improvement Plan (ROWIP) which is statutory instruments as well as the Countryside Access and Recreation Strategy.
29 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 049/750 Note – One of the issues facing This is outside the remit of a No action. facilities Worcs. CC development of heritage Core Strategy. tourism is that it has not been possible to maintain consistent approach to the development of Bordesley Abbey as an educational and amenity resource. Continued investment required to fulfil its potential. Attractive 049/751 Section has a practical and Now that the Strategy refers to No action. facilities Worcs. CC positive approach. However, attractive and cultural facilites, Policy H.1 could be a danger of silo it is considered that any thinking. Be useful to have possibility of one dimensional more cross referencing, so policy areas has now tourism would also be diminished. referenced in areas such as ‘sustainable communities’, economic devt, transport and open space.
To provide more clarity, To avoid potential confusion, ii. The proposal is located in criterion ii in policy H.1 could Criterion ii of Policy H.1 shall places that are sustainable and be amended to refer to policy have the wording principally accessible by a choice of ES.5 instead of using the term Redditch Town Centre omitted. transport modes and where
30 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. ‘principally Redditch Town additional visitor numbers can Centre’ because it reads to Some leisure and tourism be accommodated without mean that Redditch Town proposals may be appropriate detriment to the local Centre is the specific local outside the Town Centre so environment. environment to be protected. long as they meet the criterion Wording should be amended to of Policy H.1. Bearing in mind include reference to that not all leisure and tourism biodiversity eg. ‘without uses constitute Town Centre detriment to the local uses. environment and biodiversity’.
The last section of the policy that all proposals must be in Accept comment. Delete accordance with the rest of the appropriate wording in policy LDF policies is unnecessary. H.1. Attractive 049/753 Under ‘what you told us’ Accept comment, but No action. facilities Worcs. CC section, second sentence does information will not be carried Policy H.3 not make sense. Should it read forward in the Core Strategy. ‘in which health related uses The preferred approach is to No action. would NOT be acceptable’? enhance GP facilities in Town What does policy H.3 do about Centre and District Centres, the 2.5km distance away from including Astwood Bank. The doctors surgery which is stated nature of a rural area is that it as excessive on page 82? is inevitable that there are Seems as if an issue has been some longer travel distances to
31 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. identified, but nothing being a nearby service centre than done to address it. urban areas.
Policy could have wider aims of The Attractive Facility Strategy When formulating Attractive improving Health and Well is to be more wide ranging and Facility policies, incorporate Being by making links to incorporates many of these these issues where sustainable transport (walking issues. appropriate. and cycling, RSS policy SR2E), provision of greenspace and provision of leisure facilities clearer. Health and Well Being should recognise future health issues in relation to climate change from heat exhaustion etc. and also the future ageing of the Borough’s population. This may include building standards for adaptation (RSS policy SR1Cii) and CABE ‘Building for Life Standards’ RSS policy SR3B.
32 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 049/761 Any reference to ‘screening’ of A level of screening / No action. facilities Worcs. CC gypsy/traveller sites should be landscaping is required for any Policy SC6 consistent with other housing form of development, and types. I.e. There should be no gypsy sites should not be any inference that some types of different from other forms of housing development should development, whether that be be screened more than others. offices, warehousing or housing. Screening / landscaping can be in the form of planting, walling, fencing etc. This would be necessary for all forms of development to protect amenities of neighbouring occupiers Attractive 085/527 Improving Health and Well Noted. None. facilities Turley Assoc. Being. Policy H.1? on behalf of Support for further leisure and Scottish tourism proposals is welcomed. Widows These facilities will play an important role in enhancing the vitality and viability of the town centre. Attractive 088/539 Welcome policy sustainability Accept comment. No action. facilities Natural credentials, particularly, Policy SP.7 England requirement that development
33 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. be accessible by means other than the private car, includes green architectural and engineering features, protects and enhances River Arrow and its corridor and includes landscaping should make real contributions towards sustainability of this future development.
Recommend that suitable Accept comments made. Amend policy appropriately. access opportunities are prioritised over the provision of the Bordesley Bypass. Policy justification quotes existing deficiencies in sports provision and social inclusion issues. Sustainable access should be prioritised in order to facilitate use of the facilities by local residents first and foremost.
Realistic alternatives to the Accept comments made. Amend policy appropriately. private car would also help minimise carbon emissions and
34 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. have health benefits. Recommend sustainable access, protection and enhancement of the River Arrow corridor and landscaping to protect the Country Park be considered within context of green infrastructure. A strategic consideration and delivery of the developments sustainability features would promote a better relationship with the local environment which contribute to the success of the development. E.g. attractive pedestrian and cycle links to the site are more likely to be used. If development done well, River Arrow corridor and Arrow Valley Country Park could be enhanced and promoted, engendering a sense of pride in the local environment and contributing towards the achievement of objectives 1, 2, 3, 4, 5, 6, 7 and
35 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 11 and to the aims of the Sustainable Community Strategy. Attractive 088/554 Support sustainability Note comments. Amend policy to ensure that facilities Natural requirements of this policy. The tourism, leisure and healthy Policy H.1 England natural environment offers lifestyle are combined in opportunities around tourism revisions made to policies. and leisure, and recommend that these are considered within the context of a wider consideration of green infrastructure. Attractive 089/518 Policy H.1 Leisure and Accept the comment that Amend policy to ensure that facilities Theatres Trust Tourism. Support policy and Theatre should be included in Theatre is included in revised Policy H.1 pleased to note that document the Reasoned Justification. policy / reasoned justification or acknowledges contribution However, paragraph intro. Palace Theatre offers to concerned may be rearranged tourism and leisure and that in revised policy. the Sustainability Appraisal states that existing facilities should be supported. Therefore disappointed that the Theatre is not included in the first para of the Reasoned Justification despite that the Theatre is in
36 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the opening paragraph of the section.
Query: Policy states that Intention of Policy H.1 is to Amend policy appropriately to proposals for existing facilities encourage tourism ensure that it is wide ranging will be supported ‘where they development and is intended to for the purposes of the Core genuinely support sustainable set a framework for more Strategy. tourism’. Not clear what this detailed policies at a later date. means and criteria an existing facility may be found not to be genuinely supporting sustainable tourism. Attractive 093/492 Abbey Stadium (page 36-38) Accept comments made. Will refer to PPS25 and SFRA facilities Environment We would expect consideration in respect to whether policy SP.7 Agency of this site to be made in needs to be amended in accordance with current respect to flood risk. planning policy for flood risk, PPS25 and SFRA Assuming that in considering this site for development within Core Strategy, Sequential Test in accordance with PPS25 and with regard to the SFRA. Given the potential flood risk at the location, based on the
37 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. indicative flood zone, you would expect a level 2 SFRA to determine appropriate requirements, ascertaining what areas of the site could be developed etc.
Note policy R.7 from the LP3 has been reproduced in the preferred draft document as policy SP.7 and make the following comments:-
First sentence of the policy A draft proposals map was No change. refers to draft proposals map. intended to be produced in We seek clarification on this order to provide some clarity matter. despite this not being required at this stage. A proposals map will accompany the submission version of the Core Strategy.
Within criteria viii in the policy Note comments. Officers will Consider amendments in line and reasoned justification refer to PPS25 and SFRA to with PPS25. reference is made to determine necessary policy ‘necessary mitigation works amendments in respect to flood arising’ from the development risk.
38 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and the ‘funding of provision and maintenance of flood defences that are required because of the development’. This is a potential concern as would expect any proposed development to be sited within flood zone 1 in the first instance, in line with PPS25 (sequential test) and the findings of the Level 1 SFRA. We would wish to see betterment to the flooding regime as a result of the proposed development and acknowledge that there is potential for this to be achieved through developer contributions.
Notwithstanding above, Accept comments made on this Define boundary of the support the part of criteria viii in matter. Officers will investigate ecological corridor for policy SP.7 to protect and this matter to determine clarification purposes. enhance the River Arrow, its whether measures conflict with associated ecological habitats what the Core Strategy is trying and its floodplain. Policy states to protect.
39 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. that ‘no built development will be permitted within the ecological corridor that is the River Arrow and its environs.’ Would question how the River Arrow’s ecological corridor and environs has been defined and would comment that defending a site may compromise and/or contradict this aspiration objective.
Criteria viii refers to Policy will be made more wide Amendment to policy to make it development ensuring that the ranging to reflect the Abbey more strategic. ecological value of the corridor Stadiums strategic site and floodplain is not allocation. undermined. Would also be looking for flood risk reduction (betterment) and ecological enhancement to be achieved, in line with current planning policy. Would seek further clarification on the above matters relating to this site?
40 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Attractive 093/502 Gypsies, Travellers and facilities Environment Travelling Show People (page SC.6 Agency 103 – 105) Recommend that last sentence of policy SC.6 is altered to include reference to flood risk as follows:
‘There will be a presumption Policy will be made more wide Amendment to policy to make it against proposals in flood zone ranging to reflect the Abbey more strategic. 3 and the Green Belt, unless Stadiums strategic site exceptional circumstances are allocation. demonstrated’. The reasoned justification for including a reference to flood risk would be that permanently occupied caravan, mobile home and park home sites (inc. gypsy and traveller sites) are regarded as highly vulnerable development in PPS.25. Acknowledged that the instability of these structures places their occupants at special risk and they are likely to be occupied during periods when flood risk is higher (all
41 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. year). Highly vulnerable development should not be permitted within flood zone 3. Attractive 102/149 Policy SP.7 viii (page 38) Note comments. Add detail in policy accordingly. facilities Worcs. Include reference to the historic Policy SP.7 Archlogy Unit landscape of the Arrow Valley.
Policy SP.7 Criterion viii (page Note comments. Add detail in policy accordingly. 41) Include reference to the historic landscape of the Arrow Valley. Attractive 117/185 Build a new swimming pool at Note comments. Ensure policy is addressing the facilities Randle Abbey Stadium, there is no needs of the local people first Policy SP.7 need for a snow dome and new and foremost and the level of roads. infrastructure is based on the extent of overall development. Attractive 153/512 To enhance the visitor This is appropriately dealt with No action. facilities Centro economy and Redditch’s elsewhere in the Core Strategy cultural and leisure and the Regional Spatial opportunities. Centro Strategy. recommends that development should be focussed in areas that are well served by Public Transport as outlined by RSS policy T.2. Centro also
42 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. recommends that a Travel Plan is produced for new developments to promote sustainable transport to and from the development. Attractive 199/324 The Trust is supportive of the Note comments submitted. Amend policy accordingly. facilities Worcs. Acute statement in the main Core Accept change to the rear Need to make changes to the Policy H.3 NHS Strategy that the Alexandra boundary of the site. proposals map to reflect this Hospital site should be amendment. protected for healthcare purposes and as noted above the boundary of the site shown on the Strategy plans should be amended to reflect the augmented hospital site/repositioned rear boundary (as per RB09 plan on page 64 of stage 3 Employment Land Review and certainly not as per the plan on pages 20 and 66 of the document which even incorporates a tongue of land forming part of the original hospital site within the area coloured pink or edged red
43 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. designated suitable for employment purposes. Attractive 263/436 Strategic Sites – Abbey Accept comments made. Amend policy accordingly to facilities English Stadium: Although the ensure that Bordesley Abbey is SP.7 Heritage proposed policy refers to the incorporated within the policy wider context of the River to protect its setting, but also Arrow (viii) and Arrow Valley use this opportunity to create Country Park ((ix) no specific important links between the mention is made of Bordesley sports facilities of the Abbey Abbey Scheduled Monument. Stadium and Bordesley Abbey We object to this as an to generate tourism for both omission. An explicit reference facilities. should be made to protecting the setting of the site under (ix) as well as has regards to the archaeological potential of the area. Additionally given its current condition status and the opportunities it offers for contributing to the leisure, recreational and cultural use of the wider area suggest that the policy also seeks to given positive promotion to securing enhancements in the
44 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. management of the site, its enjoyment, interpretation and access. Attractive 264/451 Account should be taken of the Officers are liaising with the No change. facilities CBRE on health needs arsing from the Primary Care Trust on Policy H.3 behalf of development of sites in the infrastructure matters in Mettis Borough. A locational strategy relation to health facilities. should be developed for the provision of health facilities in accordance with areas of identified /expected growth
Balance between housing and employment
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. ADRs 017/238 Considers that the rural aspect It is evidenced in previous Officers to consider capacities (CPRE) of Redditch is distinctive and planning documentation available within the ADRs to agrees with inclusion of ADRs relating to the Borough of meet the revised RSS target of
in the Green Belt (p.6, final Redditch Local Plans 2 & 3 that around 4000 dwellings up to para (PDCS)), as all ADRs are the three ADRs had potential 2026 and undertake a further boundary locations and well for development. It should be consultation period
45 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. established in rural, green and noted that during previous plan environmental terms. CPRE preparation, officers were understands that all three restricted to searching for Update Key Diagram to show the broad location of a ADRs are no longer considered appropriate and suitable land appropriate as Strategic Sites for development within the SUE/SUEs boundary to be Borough’s administrative determined in collaboration boundary only. The three with Bromsgrove District ADRs offered the most Council appropriate locations for development at that time. Changes to the planning system have allowed for cross- boundary investigation for sustainable locations for Redditch related development. WYG1 Study concluded that whilst planning up to its boundaries only, the ADRs offered suitable locations for development. However, the WYG2 Study concluded that land beyond the Borough Boundary offered more sustainable locations for development than the three ADRs.
46 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. ADRs 017/238 The WYG2 study was (CPRE) considered by the RSS Panel of Inspectors, who concluded
that there were no good reasons to overturn the ADR findings in WYG1 Policy SP.6 021/076 SP.6 is generally in conformity Noted On receipt of the WMRSS (Woodrow (WMRA) with emerging WMRSS Proposed Changes, officers Strategic Policies SR1C (Climate will check that any changes to Site) Change) and CF7 (Delivering WMRSS Policies SR1C and Affordable Housing) CF7 (if deemed necessary) are reflected appropriately within the Core Strategy ADRs 028/101 1. Examination of CS 1. Officers consider that 1. None (GOWM) evidence base will need to throughout the Core Strategy show that all reasonable consultation process, all options have been reasonable options for the considered ADRs were explored: 2. Officers to consider 2. Noted that Preferred Draft - The outcome of informal capacities available within the Core Strategy makes consultation used to inform the ADRs to meet the revised RSS reference to options in Issues & Options Paper pp.37- target of around 4000 dwellings relation to the potential use 40, 59, 63-64 (Webheath ADR up to 2026 and undertake a of the ADR land in Redditch – housing only, Brockhill ADR further consultation period for future housing & A435 ADR – housing and development employment) - Context to the Core Strategy Update Key Diagram to show
47 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Issues & Options document – the broad location of a SUE Issue 11, pp. 15-16 (Webheath /SUEs boundary to be ADR – housing only, Brockhill determined in collaboration ADR & A435 ADR – housing with Bromsgrove District and employment) Council - Core Strategy Issues & Options document – Issue 11, Q15, pp.42-43 (Webheath ADR – housing only, Brockhill ADR & A435 ADR – housing and employment) - The outcome of Core Strategy Issues & Options Consultation – Response to Q15, pp.48-51 (Alternative approaches for ADRs to be presented in CS) Webheath 036/115 1. Webheath ADR is 1. It is evidenced in previous 1, 2 & 3. Officers to consider ADR (Smith) unsuitable for development planning documentation capacities available within the and should be changed relating to the Borough of ADRs to meet the revised RSS back to Green Belt Redditch Local Plans 2 & 3 that target of around 4000 dwellings the three ADRs have potential up to 2026 and undertake a for development. further consultation period
WYG1 Study concluded that Update Key Diagram to show
48 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. whilst planning up to its the broad location of the SUE boundaries only, the ADRs boundary to be determined in offered suitable locations for collaboration with Bromsgrove development. However, the District Council WYG2 Study concluded that land beyond the Borough Boundary offered more sustainable locations for development than the three ADRs.
When preparing the 2008/09 Strategic Housing Land Availability Assessment (SHLAA), officers were minded consider the conclusions of the WYG2 study.
The WYG2 study was considered by the RSS Panel of Inspectors, who concluded that there were no good reasons to overturn the ADR findings in WYG1
2. Infrastructure is not
49 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Webheath 036/115 available 2. Infrastructure exists to ADR (Smith) sustain the development of 600 dwellings (maximum) (Arup Report – Residential Development, Webheath, Redditch – December 2001)
3. Area serves local residents and is almost used as a 3. Development on the ADR ‘park’ space would include open space provision
50 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Webheath 041/719/720 1. Inspector’s ruling for 1. Refer to response 036/115 1. Refer to action for response ADR (Bedford- previous Western Areas above 036/115 above Smith) proposal stated that it was not sustainable and should only be released if highway and foul drainage difficulties can be solved – which is not likely
2. Development north/northwest of Redditch is robust, valuable and 2. It is anticipated that funding 2. None speedy when compared for improvements to the with development south of Redditch to Birmingham Redditch. Any development railway line will come forward proposal for the Webheath as part of infrastructure ADR is likely to weaken the provision associated with opportunities for railway longer term growth options for improvements by wrecking, Redditch limiting and delaying any ‘critical mass’ necessary in the Arrow Valley Webheath 084/123/125 1. Agrees with p.6, final para 1, 2 & 3. Refer to response 1, 2 & 3. Refer to action for ADR (Philpotts) (PDCS), based on WYG2 036/115 above response 036/115 above that the ADR land, in particularly, Webheath, is unsuitable for future development and there are
51 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. more suitable locations beyond the Borough boundary 2. Agrees with p.6, final para (PDCS), that the ADRs have exceptional circumstances to demonstrate their allocation as Green Belt 3. Para 2 p.28 ( PDCS) should be removed as it conflicts with the CS ADRs 095/140 Agrees with p.6, final para Refer to response 017/238 Refer to action for response (Smith) (PDCS), that the three ADRs above 017/238 above are unsuitable for future development and there are exceptional circumstances to demonstrate their allocation as Green Belt
Brockhill ADR 104/034/043/ 1. Spatial strategy should 1. Refer to response 017/238 1. Refer to action for response meet requirements of above 017/238 above 044/052/054/ emerging RSS by
064 (RPS) identifying land for 3300 dwellings within the
52 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Redditch boundary to accommodate its requirements fully as land is available, in order for conformity with the RSS. Focus for the 3300 dwellings within the Borough should include ADR land which has already been proven to be suitable for development. The strategy is fragile and the Council should plan proactively to meet its own requirement of 3300 dwellings before deferring to other Authorities Brockhill ADR 104/034/043/ 2. (a) Seeking to designate 2(a) RBC has assessed a 2(a) Officers to consider Brockhill ADR as Green number of development capacities available within the 044/052/054/ Belt is unsound as this area alternatives throughout the ADRs and Green Belt to meet 064 (RPS) forms part of the North Core Strategy consultation the revised RSS target of West Redditch Urban process, including the option around 4000 dwellings up to Extension, which has not put forward by the objectors as 2026 and undertake a further been assessed within the part of the Technical Paper and consultation period development plan option SA refresh. It was important appraisal process. The that the consideration of all Council cannot identify this possible development options Update Key Diagram to show land for Green Belt without was not constrained. This the broad location of a
53 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. full consideration of would have been the case had SUE/SUEs boundary to be alternatives for this site. the WYG Joint Study determined in collaboration RPS objects to the use of considered the site with Bromsgrove District WYG2 to substantiate the development boundaries of Council allocation of Brockhill ADR options put forward by as Green Belt. RPS prospective considers this report is developers/landowners. It is flawed and cannot be relied therefore appropriate that the upon as robust WYG study did not consider the specific area noted as the North West Urban Extension in isolation. During plan preparation, officers have to act on the most up to date evidence available to them – at this point in time being WYG2. However, as it further transpires the WYG2 study was considered by the RSS Panel of Inspectors, who concluded that there were no
good reasons to overturn the ADR findings in WYG1.
2(b) Officers to consider 2(b) Identification of Brockhill 2(b) Officers consider that ADR as Green Belt fails to capacities available within the WYG1 assessed areas in and ADRs and Green Belt to meet comply with PPG2. PPG2 around Redditch for their identifies the purposes and the revised RSS target of
54 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. requirements of Green Belt. suitability for long term around 4000 dwellings up to The Council cannot include development contributions 2026 and undertake a further land at Brockhill ADR within the towards Redditch related consultation period Green Belt without justification growth. The WYG2 study was against PPG2. No reference considered by the RSS Panel has been made to these of Inspectors, who concluded requirements within Brockhill that there were no good proposals or WYG2. RBC reasons to overturn the ADR merely adopts the WYG findings in WYG1. approach that this land should
be used to off set the loss of Green Belt. PPG2 makes no The EiP Panel identified all reference to requiring land to those localities where it be offset as part of Green Belt considered that a Green Belt purpose. This is merely an alteration was required or may approach that seeks to pacify be an appropriate response to objections to loss of Green Belt seeking the most sustainable rather than a test of its development patterns. functions and purpose and is Paragraph 4.18 states that unsound. Neither WYG nor the once sites have been released Council has undertaken a from the Green Belt, the comprehensive Green Belt principle of their development review to appraise land at has been established and it is Brockhill ADR in the context of unnecessary to test their PPG2 para 1.5. Objection to sustainability further. This is inclusion of Brockhill ADR reflected in Recommendation without testing whether land R8.2. excluded from the Green Belt can meet the longer term
55 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. needs of the Borough without further amendment of Green Belt in the future 2(c) Refer to 2(b) above 2(c) None. Refer to 2(b) above 2(c) The Council is incorrect to assume that there needs to be an exceptional circumstance for the inclusion of land within the Green Belt and incorrectly refers to RRS Preferred Option para 3.9(d). It does not provide the basis for including additional areas of land within Green Belt, particularly when they have the potential to offer the most sustainable solutions to development and urban regeneration 2(d) Noted and agreed. PPG2 2(d) See 2(b) above. Contact 2(d) PPG2 [para 2.6] requires para 2.12 states that Green GOWM for steer on the Green Belt boundaries to be Belt boundaries should relate identification of safeguarded defined in a manner that to a time scale which extends land in and around Redditch for provides a degree of beyond the end of the plan the period beyond 2026 permanence. If Green Belt period which would give them boundaries are drawn too the permanence for which they tightly around built up areas it were intended. However, may not be possible to identification of safeguarded maintain the level of land for longer term planning
56 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. permanence they require. should be guided by a Regional/strategic framework. Officers consider that this has not been fully addressed in the WMRSS Phase 2 revision and that guidance should be sought on this matter. Given Redditch’s tight administrative boundaries, future growth into neighbouring districts/ Green Belt is a strong possibility and officers endeavour to plan proactively for this situation Brockhill ADR 104/034/043/ 3. Identification of Brockhill 3. Noted. Officers consider that 3. Refer to 2(b) above ADR for Green Belt collaborative work between 044/052/054/ presents further RBC and BDC is essential to 064 (RPS) inconsistencies with the achieve comprehensive spatial Bromsgrove CS, which planning across administrative indicates this area could boundaries. Refer to 2(b) form part of an urban above extension. Identification as Green Belt would prejudice the Bromsgrove CS Brockhill ADR 104/034/043/ 4. Relying on urban 4. Officers consider that the 4. Refer to 017/238 and 2(b) extensions to meet the SHLAA and WYG reports above 044/052/054/ shortfall of the Redditch presented the most appropriate housing requirement is evidence at the time the CS
57 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 064 (RPS) unsound. There are sites was prepared. available within the Borough boundary that can deliver housing early within Refer to 017/238 and 2(b) the plan period and have above already been proven as appropriate. They should be a priority for delivering the RSS requirement to ensure RSS conformity Brockhill ADR 104/034/043/ 5. Support for Council’s 5. Noted. Refer to 2(b) above 5. Refer to 2(b) above approach to identification 044/052/054/ and allocation of strategic 064 (RPS) sites as consistent with PPS12. However does not currently identify the most sustainable sites for development in the context of meeting the housing requirement for Redditch Brockhill ADR 104/034/043/ 6. There is no 6. Noted. Officers consider that 6. RBC and BDC officers to acknowledgement or collaborative work between work collaboratively to ensure 044/052/054/ strategy within Bromsgrove RBC and BDC is essential to comprehensive CS coverage 064 (RPS) to plan for Redditch’s achieve comprehensive spatial for both districts shortfall thus; there is a void planning across administrative in the housing provision of boundaries some 1050 dwellings which
58 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. is unsound Brockhill ADR 104/034/043/ 7. RPS has made the Council 7. Officers acknowledge the 7. Refer to 2(b) above aware of the potential of extensive amount of material 044/052/054/ Brockhill ADR to deliver submitted by RPS regarding 064 (RPS) housing early in the plan the North West Urban period in a sustainable Extension and their continued manner which would allow enthusiasm for early housing for an early lead in period to delivery on the site. However, an integrated North West this does not necessarily make Urban Extension the North West (Brockhill) the best option for Redditch related growth. Refer to 2(b) above Brockhill ADR 104/034/043/ 8. The Council should have 8. Refer to response 017/238 8. Refer to action for response full regard to the possibility above 017/238 above 044/052/054/ of emerging RSS requiring
064 (RPS) additional development at Redditch and the need to find additional land to accommodate this. Sites 1 & 2 as promoted by RPS offers an opportunity to deliver additional growth under this scenario and their potential should be investigated accordingly A435 ADR 105/165 1. Concern over impact of 1. If the A435 ADR was 1. None high density development of required to contribute towards
59 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. (Hattersley) HCA land at A435 ADR Redditch’s housing allocation then any proposal would need to comply with density criteria within CS policy
2. Tree screening within ADR needs to be maintained to 2. If the A435 ADR was reduce visual impact in required to contribute towards Mappleborough Green of Redditch’s housing allocation then any proposal would need Claybrook Drive 2. None development. Tree planting to address contributions to also mitigates CO2 open space within the site. The emissions on A435 tree screening within the ADR would be assessed for its contribution to this
development related element
3. Agree that HCA land at A435 ADR should be made 3. PPG2 para 2.12 states that permanent Green Belt Green Belt boundaries should relate to a time scale which extends beyond the end of the plan period which would give them the permanence for
which they were intended. However, identification of safeguarded land for longer 3. Officers to consider term planning should be guided capacities available within the
60 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. by a Regional/strategic ADRs and Green Belt to meet framework. Officers consider the revised RSS target of that this has not been fully around 4000 dwellings up to addressed in the WMRSS 2026 and undertake a further Phase 2 revision and that consultation period guidance should be sought on this matter. Given Redditch’s tight administrative boundaries, future growth into neighbouring districts/ Green Belt is a strong possibility and officers should endeavour to plan proactively 4. Considers that land at for this situation Broadacres Farm in the A435 ADR should not be changed to Green Belt as it would be ideal for low 4 & 5. Refer to response density, high quality 017/238 above. Officers development which would consider that points 3, 4 and 5 are contradictory fit better with the character of Mappleborough Green as opposed to high density development proposed by HCA 5. Proposals from multiple land owners in A435 ADR should be treated consistently
61 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
4 & 5. Refer to action for response 017/238 above
Webheath 107/169/232 Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR (Rose) unsuitable for housing above 036/115 above development and should be changed to Green Belt. Unsustainable location, inadequate roads, sewerage would have to be pumped up hill, inadequate services, protected species A435 ADR 114/179 Support for A435 ADR corridor Refer to response 017/238 Refer to action for response (Baker) being kept wooded and above 017/238 above included as Green Belt
Webheath 117/184 1. Support for Webheath ADR 1. Refer to response 036/115 1. Refer to action for response ADR (Randle) as unsuitable for housing above 036/115 above development and should be changed to Green Belt 2. Would like underground 2. Noted and actioned 2. Forward request to infrastructure providers at an electric cables in Crumpfields Lane appropriate time for their consideration of this issue
62 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Webheath 118/187 Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR (Hearnshaw/ unsuitable for housing above 036/115 above Bagnall) development and should be changed to Green Belt Webheath 119/189 (Best) Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR unsuitable for housing above 036/115 above development and should be changed to Green Belt Webheath 121/192 Webheath ADR could be Refer to response 036/115 Refer to action for response ADR (Barber) changed to Green Belt if above 036/115 above development took place in the north east of Redditch
Webheath 125/197 1. Objects to development of Refer to response 036/115 Refer to action for response ADR (Hemlis) Webheath ADR as existing above 036/115 above infrastructure is inadequate 2. Supports Webheath ADR designation being changed to Green Belt ADRs 133/211 Supports designation of ADRs Refer to response 017/238 Refer to action for response to Green Belt above 017/238 above (Waste Policy & Sustainability,
63 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. RBC) Webheath 134/214 1. Webheath ADR unsuitable Refer to response 036/115 Refer to action for response ADR (Haigh) for development due to above 036/115 above traffic impact and environmental impact 2. Supports Webheath ADR designation being changed to Green Belt Webheath 148/256 Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR (Rose) unsuitable for housing above 036/115 above development and should be changed to Green Belt Webheath 149/257 Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR (Rose) unsuitable for housing above 036/115 above development and should be changed to Green Belt Webheath 150/260 Webheath ADR is unsuitable Refer to response 036/115 Refer to action for response ADR (Stowell) for development and should be above 036/115 above changed back to Green Belt Webheath 152/265 Support for Webheath ADR as Refer to response 036/115 Refer to action for response ADR (Rose) unsuitable for housing above 036/115 above development and should be changed to Green Belt
64 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. ADRs & 158/270 1. Support for ADRs (in Refer to response 036/115 Refer to action for response Webheath (Bonham) particular, Webheath) as above 036/115 above ADR unsuitable for housing development 2. Webheath infrastructure (drainage and highways) is inadequate to support significant additional development 3. Support Webheath ADR being designated as Green Belt. High amenity value, rich in flora and fauna Webheath 159/273 Webheath ADR is unsuitable Refer to response 036/115 Refer to action for response ADR (Sullivan/ for development and should be above 036/115 above Cruxton) changed back to Green Belt. Area frequently used by walkers and ramblers Housing 160/274 1. Only social housing should 1. The Strategic Housing 1. None (White) be developed in and around Market Assessment for the Redditch South Housing Market Area (which includes Redditch) 2. Many homes in the district provides evidence on the are empty and some have different types and sizes of not been occupied since housing needed to enable the development development of balanced
65 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. communities within local authority areas
2. New build properties which remain empty following development are a consequence of the current economic climate. The housing 2. None allocation covers the period up to 2026. This timeframe allows for ‘peaks’ and ‘troughs’ in the housing market which averages out any under/over provision during the plan period Webheath 181/301 Objection to ADR designation Refer to response 036/115 Refer to action for response ADR (Lloyd) being changed to Green Belt above 036/115 above Webheath 182/302 Supports the decision that Refer to response 036/115 Refer to action for response ADR (Morris) Webheath ADR is not suitable above 036/115 above for development with respect to: 1. Narrow lanes suitable for 1 & 2. Capacities of existing riders, walkers and cyclists facilities and provision of but unsuitable for huge additional facilities would need traffic increase to be investigated if Webheath ADR has to be reconsidered 2. School, shopping and for housing development medical provision would be
66 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. inadequate ADRs 202/336 1. Seek the removal of a 1. It is not within the Local 1. None (Tetlow King) target for the delivery of Authority’s remit to remove the housing within Bromsgrove delivery of its housing District and seek that allocation within Bromsgrove Redditch’s housing District; housing allocation is requirements are met determined at the Regional entirely within its level. Redditch is unable to administrative area accommodate its WMRSS housing allocation entirely within its administrative area due to constraints associated with Green Belt to the south west of the urban area. This has been acknowledged by the WMRA, hence the split of the housing allocation within and beyond Redditch’s administrative boundary in the WMRSS Phase 2. With the absence of developable land in the Green Belt to the south west of Redditch’s urban area, there is insufficient alternative land to accommodate the full WMRSS housing allocation. ‘A Study of Green Belt Land & Areas of Development
67 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Restraint within Redditch Borough’ documents Study findings dating back to the 1960s which demonstrate the acute sensitivities of Redditch Green Belt
2. Refer to action for response 2. ADRs should be included 017/238 above as this would be a more 2. Noted. Inclusion of the ADRs sustainable option than for development would not seeking to build on land provide sufficient additional outside the Borough supply to meet the WMRSS housing allocation for Redditch. Refer to response 017/238 above Webheath 206/341 Objection to any potential Refer to response 036/115 Refer to action for response ADR (Gartside) development at Webheath above 036/115 above ADR with respect to: 1. Wealth of wildlife in the area 2. Road system from Callow Hill to Webheath is unsuitable to accommodate increased traffic. Increase in road would impact on wildlife and hedgerows
68 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. Support for Webheath ADR being changed back to Green Belt ADRs 262/417 (HCA) Premature and inappropriate to Refer to response 017/238 Refer to action for response place ADR land in the Green above 017/238 above Belt at this time. The designation of this land as Green Belt would establish a significant policy objection and could promote unsustainable patterns of development. Suggest that key diagram is modified so that ADR is not in Green Belt
69 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Webheath 267/573/579/ 1. Consider that the proposed 1. Refer to response 104/ 2(a) 1. Officers to consider ADR development is in a suitable above capacities available within the 581/588/767 location and offers an ADRs and Green Belt to meet (Barton opportunity to create a the revised RSS target of Willmore) sustainable urban extension around 4000 dwellings up to to Redditch town. ADR sites 2026 and undertake a further should be identified as consultation period strategic sites for development capable of meeting the Borough’s own needs within their administrative boundary. Council’s decision not to include ADR as suitable sites for development is flawed. Do not consider that the inclusion of existing ADRs within the Green Belt will assist in achieving overall objectives of urban regeneration Webheath 267/573/579/ 2. Evidence exists that the 2. Refer to response 017/238 2. Refer to action for response ADR Council and two previous above 017/238 above 581/588/767 Local Plan Inspectors (Barton consider that development Willmore) of the Webheath ADR is acceptable in principle and have acknowledged the site
70 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. as in a sustainable location. There has been no change in planning legislation of planning policy (PPG3 replaced by PPS3) which would result in a completely different emerging view of the sustainability of this site for development Webheath 267/573/579/ 3. There is no landscape and 3. Whilst Landscape and Visual 3. Refer to (Barton Willmore) 1 ADR visual evidence to back up Appraisal of sites is considered above 581/588/767 the claim that the site is of a important, Officers consider (Barton high landscape value which that WYG1 assessed areas in Willmore) is contrary to the Green Belt and around Redditch for their report which states that suitability for long term development of the site development contributions would have no serious towards Redditch related effect on the landscape. growth. The WYG2 study was Following the WYG considered by the RSS Panel suggestion to remove ADR of Inspectors, who concluded sites and propose their that there were no good reinstatement as Green reasons to overturn the ADR belt, respondent findings in WYG1. commissioned a Landscape and Visual Appraisal of Webheath ADR and a The EiP Panel identified all comparative assessment of those localities where it Bordesley Park and considered that a Green Belt
71 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Foxlydiate Woods. In alteration was required or may summary, Webheath ADR be an appropriate response to is suitable for development seeking the most sustainable and there would be no long- development patterns. term landscape or visual Paragraph 4.18 states that impacts as a result of once sites have been released development. Bordesley from the Green Belt, the Park is unacceptable for principle of their development development in landscape has been established and it is and visual terms due to its unnecessary to test their breech of the landscape sustainability further. This is boundaries of Redditch and reflected in Recommendation its extensive and harmful R8.2. impact on the Green Belt. Foxlydiate Wood would Refer to (Barton Willmore) 1 create a significant and above harmful visual impact due to its elevated location and lack of boundary definition Webheath 267/573/579/ 4. The findings of the 4. ‘A Study of Green Belt Land 4. Refer to (Barton Willmore) 1 ADR Council’s Green Belt report & Areas of Development above 581/588/767 are entirely contradictory to Restraint within Redditch (Barton the WYG report. The Green Borough’ documents Study Willmore) Belt report demonstrates findings dating back to the that development of the 1960s which demonstrate the Webheath ADR is acute sensitivities of Redditch appropriate to meet the Green Belt. Officers consider development requirements that WYG1 assessed areas in
72 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. in Redditch and around Redditch for their suitability for long term development contributions towards Redditch related growth. The WYG2 study was considered by the RSS Panel of Inspectors, who concluded that there were no good reasons to overturn the ADR findings in WYG1.
The EiP Panel identified all those localities where it considered that a Green Belt alteration was required or may be an appropriate response to seeking the most sustainable development patterns. Paragraph 4.18 states that once sites have been released from the Green Belt, the principle of their development has been established and it is unnecessary to test their sustainability further. This is reflected in Recommendation R8.2.
73 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Refer to (Barton Willmore) 1 above Webheath 267/573/579/ 5. PPG2 advises that Green 5. PPG2 para 2.12 states that 5. See (Barton Willmore) 1 ADR Belt boundaries should not Green Belt boundaries should above. Contact GOWM for 581/588/767 be drawn tightly around relate to a time scale which steer on the identification of (Barton urban areas as it would be extends beyond the end of the safeguarded land in and Willmore) difficult to maintain the plan period which would give around Redditch for the period degree of permanence that them the permanence for beyond 2026 Green Belt should have. It which they were intended. is likely that Green Belt However, identification of boundaries may need to be safeguarded land for longer reviewed in the near future term planning should be guided as part of future housing by a Regional/strategic delivery proposals framework. Officers consider that this has not been fully addressed in the WMRSS Phase 2 revision and that guidance should be sought on this matter. Given Redditch’s tight administrative boundaries, future growth into neighbouring districts/ Green Belt is a strong possibility and officers should endeavour to plan proactively for this situation Webheath 267/573/579/ 6. WYG does not provide See (Barton Willmore) 1 above See (Barton Willmore) 1 above ADR evidence to demonstrate 581/588/767
74 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. (Barton exceptional circumstances Willmore) for the Webheath ADR to be put back into Green Belt
Webheath 267/573/579/ 7. Given the Council’s failure 7. Refer to response 017/238 7. Refer to action for response ADR to identify sufficient land for above. Refer to (Barton 017/238 above. Refer to 581/588/767 housing, the proposed Willmore) 1 above (Barton Willmore) 1 above (Barton identification of the land at Willmore) Webheath as Green Belt would unduly constrain the development of a suitable housing site which could be used to meet the identified housing requirement 267/587 8. DPD is not sufficiently 8. Refer to response 017/238 8. Refer to action for response (Barton flexible to deal with any above 017/238 above Willmore) changes i.e. housing figures from an emerging RSS. DPD fails to meet the PPS12 paragraph 4.10 housing requirements of the requires the Borough Council emerging RSS when there to show how the CS objectives are sufficient, suitable, will be achieved under different available and deliverable scenarios which may be sites within the Borough necessary in circumstances where provision is uncertain. The simplicity of the Core Strategy for Redditch means
75 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. that there are no significant uncertainties regarding provision therefore flexibility should be limited. Indeed, the objectives have been purposely drafted to be long- term and flexible under changing circumstances. In terms of the achievement of the objectives it is considered that the broad nature of the Strategic Site policies where detail is supplemented through other DPDs/SPDs provides sufficient flexibility Webheath 267/593(Barto Seek to address the perceived ADR n Willmore) disadvantages of the Webheath ADR stated in
WYG2 as well as comparing them against those identified for Bordesley Park and Foxlydiate:
9. Poor road network – WYG2 claims capacity of ADR reduced from 600 to 450 9. Officers consider that this is 9. Seek to revise traffic dwellings due to 150 an error in WYG2 but also assessment report for the already constructed consider that a revised traffic
76 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. assessment for the Webheath Webheath area area would be beneficial to update the Arup (Dec 2001)
report
10. Distant from Town Centre/ 10. RBC has assessed a 10. Officers to consider poor communications/ not number of development well linked to cycleways capacities available within the alternatives throughout the ADRs and Green Belt to meet and footpath systems/ Core Strategy consultation distant from employment the revised RSS target of process, as part of the around 4000 dwellings up to sites – WYG2 contradicts Technical Paper and SA the ‘Redditch Green Belt 2026 and undertake a further refresh. During plan consultation period Study’ which states that preparation, officers have to Webheath ADR act on the most up to date development would be evidence available to them – at consistent with PPG2 this point in time, being WYG2. Update Key Diagram to show advice and development However, as it further the broad location of a would be relatively transpires the WYG2 study SUE/SUEs boundary to be harmonious with existing was considered by the RSS determined in collaboration development. An Panel of Inspectors, who with Bromsgrove District accessibility study concluded that there were no Council undertaken in January 2009 good reasons to overturn the concludes that Webheath ADR findings in WYG1 ADR scores positively and therefore Webheath ADR should be scored the same as Bordesley park in WYG2
77 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
11. Difficult foul drainage – 11. Officers acknowledge the 11. See (Barton Willmore) 1 WYG1 does not list this as inconsistencies in WYG2. above a potential constraint for However, officers consider that Foxlydiate despite para WYG1 highlighted constraints 5.50 confirming the that may not be similarities with Webheath insurmountable but would have ADR as both sites would high costs associated with require the pumping of foul them. It is agreed that pumping drainage to Spernal STW. to Spernal is possible however, Discussions have been held alternative locations with Severn Trent Water investigated by WYG offer and STW has agreed to the more cost effective options and principle of connecting more sustainable approaches. Webheath ADR to the WYG1 also acknowledges that public drainage system. areas 3 & 4 (Webheath ADR & STW has also agreed to Foxlydiate) would require outline options proposed for sewerage pumping mitigating any potential impact of the new development on the existing sewage system. It is not considered that there are any ‘difficult foul drainage’ problems associated with the development of the Webheath ADR
78 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
12. Attractive Landscape – 12. See (Barton Willmore) 3 12. See (Barton Willmore) 3 WYG2 concludes that above above Webheath ADR is an ‘attractive landscape’ with no analysis of what constitutes this and no detailed appraisal to back this up. There is an inconsistency and unfairness with the approach to assessing Webheath ADR, Foxlydiate and Bordesley Park. Barton Willmore have commissioned an independent study which concludes that Webheath ADR would be more suitable in terms of landscape and visual impact than Foxlydiate or Bordesley Park 13. Other inconsistencies 13. Officers acknowledge the 13. See (Barton Willmore) 1 between Webheath ADR, inconsistencies in WYG2. See above Foxlydiate and Bordesley (Barton Willmore) 1 above Park exist i.e. Outside
79 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Landscape Protection Area & Area of Great Landscape Value, Ridgeline site but not prominent, Natural extension to urban form
Climate change and sustainability
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.3 005/483 Renewable energy provision It is firmly established at Amend policy in line with and Policy and sustainable building national level that new WMRSS. BE.1 requirements created in bullet development will need to be point (v) of SP.3 and point (ii) more sustainable. The ability to of BE.1 are contrary to national supply renewable energy is guidance and would constrain central to this. With regard to residential development in the the requirement for renewable Borough. A lack of any credible energy production in new and robust evidence base on development (point v of SP. 3), which policies have been this is set out in the WMRSS
80 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. based (as required by PPS 1 Phase II Revision, which Supplement). requires developments of 10 or more to supply 10% of their energy from a sustainable source. As the WMRSS has not yet been adopted Officers are still considering whether this requirement will still remain as part of the Core Strategy. As such this comment will be taken on-board. It is also part of national planning guidance (Supplement to PPS 1 and PPS 22) that renewable energy is produced. Therefore the need to incorporate sufficient renewable energy production facilities in new development is appropriate to achieve these national goals.
It is unclear how Bullet Point ii of BE.1 would constrain residential development as this is only applicable to offices and other non-domestic buildings.
81 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy BE.1 042/ 470 Point one None Reference to regional The timescale in the Core Standards in Point (i) should be Strategy is in accordance with removed as it is unlikely that regional and national targets. the Government will allow a timetable that is out of line with their own.
Point two None Point (ii) and (iii) refers to the The requirement for new need to incorporate renewable developments (over 5 units or or low carbon energy 1,000 square meters) to supply equipment within development 10% of their energy supply via to meet at least 10% of the sustainable sources is residual energy demand. This requested by the WMRSS. should only apply where viable Redditch Borough Council has (in line with PPS 22) and amended this to 5 dwellings therefore policy should be due to the limited capacity of reworded to reflect this sites that are over 10 dwellings approach. in the Borough.
Point three Amend policy in line with Point (iv) within the Policy The requirement for a WMRSS. requires a sustainability Sustainability Statement to be statement to be submitted with produced is detailed within the
82 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. planning applications. The WMRSS Phase Two Revision; supplement to PPS1 states the WMRSS then requires that that specific and stand alone these standards are detailed in statements of this nature are Development Plan Documents. not required where the The WMRSS is not yet requisite information can be adopted and as such Redditch incorporated in a submitted Officers are still considering Design and Access Statement whether this requirement or part of an Environmental should still remain within the Statement. Core Strategy.
Point four None Reference is made to the Although both tools consider sustainability checklist; it is not aspects of sustainability they clear how the checklist relates should be used in isolation. or indeed duplicates the Code The Code for Sustainable for Sustainable Homes. The Homes presently only Code is a more appropriate considers individual houses, benchmark. whereas the West Midlands Sustainability Checklist looks at an entire development and also considers issues that are outside of the remit of the Code. Therefore in order for Redditch Borough to deliver
83 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the best developments possible it is best practice for developers to consider their developments against the Checklist. The Code is a mandatory standard which carries significant weight, whereas the checklist is used as guidance and therefore given less weight. For this reason Officers consider both tools useful and best practice when considering how sustainable a development is.
Policy BE.1 027/475 Policy BE.1 should include It is considered that it would be Incorporate the text requirements relating to appropriate to include “development requirements will transport. In particular, for reference to sustainable modes be met in accessible locations developments to be accessible of transport in this policy, as and take account of the by sustainable modes of transport is a cross cutting accessibility needs between transport and for developers to theme of the Core Strategy. uses” as a principle in the provide, and implement Travel The policies contained within Climate Change Policy. Plans to encourage the use of the Core Strategy detail a these sustainable modes. strategic aspiration for the Borough, with detail on how the
84 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Vision for Redditch Borough can be achieved by 2026. The policies aim to steer future development in the Borough in the most sustainable way.
The need for new developments to provide travel plans is considered appropriate as a delivery tool within the Core Strategy and can be incorporated into the ‘Sustainable Travel’ Policy.
BE. 1 049/ 737a Policy repeats RSS Policy. Comment noted. A number of Amend policy in line with Policy should be amended to policies within the WMRSS WMRSS. remove sections which repeat require LDFs to incorporate regional planning policy. some of the standards that are set within the WMRSS. For example Policy SR1 Climate Change states that “Regional and local authorities, agencies and others shall include policies and proposals in their plans, strategies and
85 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. programmes to…” The WMRSS Phase Two Revision has not yet been adopted and therefore Officers are still considering whether some of the criteria within the Core Strategy will remain.
BE 1 (i) 049/ 737b This point need to be re- This sentence has been Amend sentence to read “new worded as the Code for incorrectly phased and should residential developments must Sustainable Homes does not have read “new residential meet the current Code for contain regional standards. developments must meet the Sustainable Homes standards current Code for Sustainable contained within the RSS .” Homes standards contained within the RSS .”
BE. 1 049/737c The term ‘climate-proofed’ is ‘Climate resilient’ will replace Replace term climate-proofed now being phased out; ‘climate the term ‘climate-proofed’ with climate resilient. resilient’ has become a more where used. acceptable way of describing this approach. BE. 1 049/ 737d There appears to be It is considered that the Amend policy in line with contradiction in wording in standards laid out in the policy WMRSS. Policy, in particular the are the optimum possible introductory text is ambiguous standards bearing in mind
86 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and suggests levels of other issues that must be sustainability that cannot be considered when planning for achieved by requirements set new developments and are in policy (optimum standards realistically achievable in would be higher than those in Redditch Borough. policy).
BE.1 049/ 737e Item (ii) should be expressed in This text is taken from the Please see action for In line terms of BREEAM terminology, requirements set out in the with response 049/ 737a. rather than improvements over WMRSS Phase Two Revision Building Regulations. Preferred Option (December 2007) Policy SR3 Sustainable Design and Construction point C. the WMRSS has not yet been adopted and therefore Officers are still considering whether this requirement will remain in the Core Strategy. Please see response to comment 049/ 737a which requested text that repeats regional planning policy to be removed.
BE. 1 049/ 737f Text in point (vi) should be It is considered appropriate Within the Natural Environment
87 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. amended to include the word that this point of the policy be Policy include the text ‘landscape’ and the words included within the Natural “…manage and enhance ‘historic environmental and Environment Policy. landscape, natural and historic heritage assets’ and the word environmental and heritage ‘built’ removed to read It is considered that large scale assets…” “…manage and enhance renewable energy projects can landscape, natural and historic cause harm to the environment environmental and heritage in terms of damage to habitats assets…” However this point and therefore there is a need to of policy would be more suited considered environmental to an environmental policy. protection when considering Although linking and creating large scale renewable energy new habitats to aid species projects. In particular there are dispersal is welcomed it is many distinctive aspects of questioned why renewable Redditch Borough that would energy developments have be under threat with regard to been singled out for more renewable energy projects for stringent environmental example the abundance of protection. species and biodiversity that is present in the many trees and hedge lined highways that are in Redditch.
BE. 1 049/ 737g Wording in relation to It is considered that the None. renewables is negative both in wording in these paragraphs is
88 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. item (vi) and final paragraph. not unduly negative and therefore the wording can remain.
It is questioned why the final The final paragraph was not None. paragraph does not have a given a bullet point as it was number and if it is linked to considered separate to other point (vi). points as it relates only to a limited number of development schemes that would affect designated sites.
O49/ 737h The table referred to at the end This table should have been Ensure supplementary of the end of page 52 – the included following the information is included within Code for Sustainable Homes Reasoned Justification. The the Submission version of the standards has not been supplementary table will be Core Strategy. included. included within the Submission version of the Core Strategy.
049/737i Include a statement to See comments to 049/736d See action to 049/736d. encourage methods to improve energy efficiency of existing historic properties without compromising conservation issues.
89 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
049/ 721 County Council has/ will The documents detailed have Ensure all documents produce a series of Natural and will inform the Policies produced by County Council Resource Papers on Planning within the Core Strategy. are considered in the for Water, Renewable Energy, background technical papers Climate Change, Green which in turn informs the Infrastructure and Soils. content of the policies. Policy BE. 1 088/ 542a Support for Policy. Support noted. None.
Policy BE. 1 088/ 542b Code for Sustainable Homes It is considered that there is Amend policy in line with requirements should be in line evidence available to show that WMRSS. with national standards not the targets set regionally can regional standards. As it is be achieved; this evidence considered that specifics about would be in the form of its application are still being background documents to the debated and keeping in line Regional Spatial Strategy. with national standards does Therefore if there is evidence not risk the policy becoming to show these targets can be out of date. delivered there is no reason for Redditch to diverge from them. Regional targets are also more distinctive than national targets and therefore more relevant to Redditch.
90 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy BE.1 088/ 542c It is not clear where point (ii) This text is taken from the Amend policy in line with originates from. Would support requirements set out in the WMRSS. instead reference to BREEAM WMRSS Phase Two Revision standards. Preferred Option (December 2007) Policy SR3 Sustainable Design and Construction point C. the WMRSS has not yet been adopted and therefore Redditch Officers are still considering whether the requirements detailed in this Policy would still be incorporated into the Core Strategy. Please see response to comment 049/ 737a which requested text that repeats regional planning policy to be removed.
Policy BE. 1 088/ 542d It is disappointing that a higher This standard reflects the None. target than 10% (energy standard requested in the requirements be obtained from WMRSS. However Officers renewable energy for new consider that it is more developments). The policy appropriate to focus on new should be more positively developments reaching high
91 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. worded to promote higher levels of the Code for standards where achievable. Sustainable Homes rather than renewable energy generation in isolation as the Code encompasses a wider range of sustainability benefits.
Policy BE. 1 088/ 542e Support the requirement for a The Sustainability Principles Amend policy in line with sustainability statement and Policy no longer exists in its WMRSS. use of the WM Sustainability present form and therefore it is Checklist; however this considered that the requirement would better be requirement for a Sustainability located in the Sustainability Statement is best located Principles Policy. within the Climate Change Policy.
Policy BE. 1 088/542f Welcome the requirement for It would be too prescriptive to None. particular schemes involving detail what each individual the production of renewable scheme would be required to energy to enhance, link and do to address this issue as extend natural habitats. every scheme is different Information on what schemes therefore it would not be would be expected to do could appropriate to detail these be provided in the justification measures within this policy. to add clarity.
92 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Policy BE. 1 088/542g Support the requirement for It is considered that the None. large-scale renewable energy protection of statutory generation applications to protected species are already ensure nationally designated sufficiently protected by sites are not compromised. national legislation as stated in However, this requirement Planning Policy Statement 9 should be expanded to include page 7 which states that “ many all statutory protected species. individual wildlife species Developers should provide receive statutory protection evidence that their proposals under a range of legislative would not result in provisions and specific policies unacceptable, unmitigated or in respect of these species uncompromised impacts on the should not be included in local natural environment. development documents” .
The Local Validation Checklist requires that an Environmental Impact Assessment is submitted alongside relevant applications.
Policy BE. 1 104/ 059a Policy is currently unsound in It is considered that the Policy Amend policy in line with its approach, as it is not is in line with regional and WMRSS. consistent with national policy, national standards. Officers are
93 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. nor is it justified by robust and still considering the content of credible evidence. Would refer this policy and therefore this the Council to the letter comment will be taken on- distributed by the Home board. Builders Federation illustrating the manner in which energy efficient targets should be applied to new homes in relation to PPS 1 and PPS 22.
Policy BE. 1 202/ 331 Support for Policy. It should be Support noted. None. acknowledged that RSL developments must already meet Level 3 of the Code for Sustainable Homes.
Policy BE. 1 208/ 343 It will be important to provide It would be the developers/ None. some flexibility within Criterion applicants responsibility to iii) to deal with circumstances demonstrate why they cannot where it will not be appropriate, achieve the requirement set, it or viable to achieve the 10% would then be decided by the renewable energy requirement. Development Control Officer whether these reasons were considered fair and reasonable.
94 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Paragraph 4.14 of the It is considered that the targets Amend policy in line with Companion Guide to PPS 22 that are set by the Core WMRSS. indicates that such policies Strategy are fair and reasoned should not be inflexible (not all and are appropriate in technologies are appropriate Redditch Borough. on all sites and locational constraints should be borne in mind) and not place undue burdens on developers (local authorities should be mindful of the level of development pressure in their area in setting generation targets).
Policy BE. 1 267/ 582a Point (iii) should be re-worded The requirement in paragraph Amend policy in line with to make reference to securing (iii) requests 10% of energy WMRSS. a 10% reduction in energy requirements to be supplied usage rather than requiring a from renewable sources is blanket 10% renewable energy based on the requirement set provision across all qualifying out in the West Midlands sites (in line with the Regional Spatial Strategy requirement in SP. 3 to reduce Phase II Review. The RSS energy use). requires this aspect of the Policy to be included. However the WMRSS is not yet adopted
95 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and therefore Officers are still considering the content of the Core Strategy Policy.
This is also listed as a It is considered that the 10% Include in Policy the following requirement rather than a requirement is a tried a tested statement, “If it is unviable for target and there is no flexibility percentage for new developments to meet this built into the policy for developments to meet for requirement for specific proposals where it may not be developments over 5 reasons the responsibility will viable for design related residential units (or 1,000 be on them to demonstrate reasons, appropriate to provide square meters). If it is unviable why this requirement would be renewable energy provision for developments to meet this unachievable.” (PPS 1 Supplement Para 26 (i) requirement for specific requires planning authorities to reasons the responsibility will set a target). be on them to demonstrate why this requirement would be unachievable.
Policy BE. 1 267/ 582b With regard to points (iii) and The majority of strategic sites None. (iv) the emerging regional detailed within the Preferred policy sets a qualifying Draft Core Strategy are for a threshold of 10 residential mix of uses for example retail, dwellings, however the Policy employment and leisure in proposes to reduce this to 5 which case the reduction from dwellings on the basis that the 10 dwellings to 5 dwellings
96 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. majority of sites in Redditch are threshold would not apply. The small sites below 10 dwellings. only strategic site that is for This is disagreed particularly 100% residential is Woodrow given the number of ‘strategic Strategic Site which is sites’ identified in the Core considered capable of Strategy. accommodating between 77 – 129 dwellings and therefore would be over the 10 dwelling and 5 dwellings threshold. All other housing sites in the Borough (identified through the SHLAA) are considerably and consistently smaller and therefore justify a 5 dwelling threshold approach.
An evidence base is required A Climate Change Technical None. to demonstrate local feasibility Paper will be produced which and potential for renewable demonstrates the evidence for and low carbon technologies. and the feasibility of the There appears to be no work requirements within the policy. undertaken to show potential A number of targets are impacts of a change to required to be included in the threshold over and above that Policy as part of the RSS, being tested at regional level. feasibility and potential of these Therefore qualifying thresholds targets for the region is
97 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. should be amended to fit with contained within the RSS regional targets. evidence base.
Policy BE.1 102/ 151 Should read ‘ natural and Agreed. Amend wording of Policy BE.1 (vi) historic environmental and Point (vi) to ‘natural and heritage assets…’ historic environmental and heritage assets…’
Policy BE.1 264/ 447 With regard to point (iii) it is The requirement in paragraph Amend policy in line with suggested that the proportion (iii) requests 10% of energy WMRSS. of renewable energy should requirements to be supplied depend on the individual from renewable sources is proposals, as per based on the requirement set representations made to the out in the West Midlands Issues and Options Document. Regional Spatial Strategy Phase II Review. The RSS requires this aspect of the Policy to be included. The WMRSS has not yet been adopted and therefore Officers are still considering the content of the Core Strategy Policy.
Sustainable 028/ 107 Support that Core Strategy is Support noted. None. Homes addressing the issue of
98 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sustainable homes. Better 049/ 735 Text should be amended in the The ‘Better environment for Ensure the new ‘Green’ Environment introductory paragraph to the today and tomorrow’ chapter is Strategy incorporates the for Today and ‘Better environment for today no longer in this format. The importance of the historic Tomorrow and tomorrow section’ to Core Strategy is to be split into environment. recognise the importance of new strategy areas which will the historic environment, not have a very brief introduction to just natural environment. the strategy. Therefore the suggestion cannot be applied in its current form but will be incorporated into the new section.
The chapter should also make Comment noted. Where Sentence to be amended to it explicit that biodiversity biodiversity is referred to in the “For the purposes of Redditch includes geodiversity. Core Strategy, a definition of Borough's Local Development geodiversity will be included. Framework, the Natural Environment is defined as trees, wildlife corridors, rivers, sites of national, regional or local importance and other sites of biodiversity and Geodiversity importance. Geodiversity refers to the non- biological aspects of nature
99 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. including rocks and minerals.”
The introduction to the chapter Comment noted. Text will be The first paragraph will be is too exclusive and specific amended to ensure that a amended to read “Natural with ‘trees’ rather than fauna general more strategic Environment is defined as more generally and ‘wildlife approach to fauna is made with fauna including trees…” corridors’ but no wildlife per se. specific references to Redditch’s distinctive features to follow.
Question whether mitigating It is considered that there are a None. and adapting to the effects of range of policies that seek to climate change can be mitigate and adapt to the achieved solely through the effects of climate change within application of sustainable the Core Strategy, as climate design and construction change is a cross-cutting principles, as is currently stated theme of the Core Strategy, in the second introductory however with regard to this paragraph. specific section there is one policy being referred to that deal with the contribution the built environment can make to this theme, therefore the reference is accurate.
100 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Third paragraph in the It is considered that it is a None. introductory section could be general approach of the Core expanded upon to reflect the Strategy to maintain and foster need to maintain and foster local distinctiveness and this is local distinctiveness rather than explicitly mentioned elsewhere just stating that trees make in the Core Strategy. Redditch distinctive.
Text should be amended in the The introductory chapter does Text will be amended to show third paragraph to include not exist in its current form; the importance of the historic reference to the historic however, where it is environment as part of the built environment, as such “natural considered appropriate the environment. “Natural and and historic environment … importance of the historic historic environment … risks to risks to the historic and natural environment as part of the built the historic and natural environment” environment will be amended. environment.
It may be important to reflect in It is considered that this None. the strategy that the present information is sufficiently distribution of settlements and detailed within the Landscape farmsteads in the borough is Character Assessment and directly related to its historic therefore does not need settlement pattern and its role repeating in the Core Strategy. as a former royal forest.
Reference should be made that Reference is already made in Insert reference into Policy
101 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. historic landscape boundaries Policy BE.3 ‘Landscape BE.3 regarding the need to should be respected and Character’ for ‘ proposals for respect and promote historic promoted within any new new development … to landscape boundaries through development and development demonstrate that the Borough’s proposals for new proposals should take account distinctive landscape is development. of information contained within protected, enhanced or County produced documents restored and that they are (list provided). informed by, and sympathetic to, the landscape character of the area in which they are proposed to take place.’ However an additional sentence can be inserted which refers to the need to respect and promote historic landscape boundaries. The principle of BE. 3 will be retained although this is now part of the ‘Natural Environment’ Policy.
The first part of paragraph four Comment noted. A shorter Amend text in paragraph four of the introduction to the Better more general reference to sites to make a more general Environment chapter with designations will be made. reference to designated sites introduction repeats within Redditch Borough.
102 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. information in the spatial portrait regarding designations and could be removed or amended.
Climate 049/ 736a The focus of the introduction to It is considered that the Core None. Change the policy on climate change is Strategy incorporates, as much predominately on mitigation as possible the need for through renewable energy, not adaptation methods to climate adaptation, whilst it is accepted change, for example the use of that other policies i.e. flood risk SUDS is required. However make reference to adaptation the Core Strategy only has a measures these should also be limited role with regard to brought forward within the adaptation as the Core climate change policy. Strategy seeks to ensure development mitigates climate change rather than adapt to it.
049/736b Documents produced by All documents produced by the None. County Council (list provided) County Council have been should be used to inform the considered and incorporated preparation of the Core into the Core Strategy where Strategy. appropriate. Documents and studies that emerge before submission of the Core
103 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Strategy will also be incorporated where appropriate.
049/736c Within the policies related to It is considered that reference Text to be inserted in the the natural environment (Trees, should be referred to in the introduction to the Natural Landscape character) introduction to the Natural Environment Policy which reference should be made of Environment Policy, as a refers to the Policy adapting the need to mitigate and adapt number of the principles and mitigating to the effect of for climate change in line with outlined in this Policy work climate change. Text to read, the principles of green towards mitigating and “A number of aspects of the infrastructure planning. adapting to the effects of natural environment can help climate change. to mitigate and adapt to the effects of climate change.” 049/736d Climate change issue should Retrofitting existing buildings is None not be discussed only in terms a very important issue; of new development, but also however the Core Strategy is should discuss existing very limited in what it can do in development. terms of existing buildings. It is considered that retrofitting is dealt with by other departments within the Council. Grants are available for the over 60's, private landlords and certain properties in the Town Centre
104 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. area which are 'hard to treat' for insulation measures. Redditch Borough Council will also be insulating all Council owned properties to current building regulations standard by 2012. Sustainability 101/ 144a Redditch should be self- This is an aspirational idea, None. sustaining by 2026. It should however is unrealistic for the produce it’s own energy and Core Strategy to deliver. food and use the River Arrow Targets that are contained for watermill power. within the Core Strategy should be deliverable and are considered as such.
101/144b Shops that provide sale points The Core Strategy cannot None. for local good should have control rents and rates for local subsidized rents or rates. businesses, this is a private function dictated by the market.
101/144c There should be no more There is an established need None. housing built as land should be for housing within Redditch to used for food production. ensure that everyone has access to a home in an area they desire. The housing
105 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. allocation for Redditch is based on the natural population projection and therefore on this basis is considered a sustainable approach. Housing figures for Redditch Borough are dictated by the West Midlands Regional Spatial Strategy; is currently still be prepared and therefore the final housing figures have not yet been decided, however Redditch Borough will have to accept some growth to ensure the natural population growth is catered for up to 2026.
Industrial sites should have There was a requirement within Amend policy in line with solar panels and wind power. the Core Strategy to ensure WMRSS. industrial development over 1000 square meters provide a proportion of their energy needs from renewable sources. However Officers are still considering whether this
106 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. requirement will remain within the final Core Strategy.
The only housing built should Planning Policy Statement 3 None be bungalows or sheltered ‘Housing’ requires that a mix of housing for older people and size and type of housing is should be within walking provided to ensure that all distance of shops and services. needs of the community are considered. With regard to location the Core Strategy requires that development is directed to the most sustainable locations.
104/ 059b Paragraph i) of the policy It is considered that regional None. aligns itself to the Code for targets should be supported by Sustainable Homes regional studies undertaken at the timescale but the regional regional level that should policy is unsound, the deliverability. With regard to Government Office response the deliverability within has made that clear. Redditch Borough the Technical Paper ‘Green Strategy’, demonstrates that the targets that are set regionally are deliverable within
107 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Redditch Borough. None.
Policy CF. 1 repeats the It is considered that the Core intention of regional policy and Strategy does not unduly is therefore unsound in itself as repeat regional or national spatial policies are not suppose planning policy and that to repeat regional or national requirements are only repeated policies. This does not add any when the RSS states this must additional value or local be done. distinctiveness to the regional policy.
104/ 059c Paragraph i) and iii) are It is considered that national None. conflicting. PPS 1 on Climate planning policy does not Change specifies that the prohibit the use of both the requirements for energy Code for Sustainable Homes efficiency should be included standard and a Merton style within references to the Code policy simultaneously. Both for Sustainable Homes as methods have overlapping but inferred through paragraph i). different objectives. Both aim to This is because Merton style reduce carbon emissions, policies are not appropriate however a renewable target where a Council uses the Code reduces the UKs reliance on for Sustainable Homes as they fossil fuel based energy, are conflicting. As the Code whereas the Code ensures that
108 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. advances bullet point iii) will be each new dwellings is as out of date sustainable as possible. Therefore it is considered that it is appropriate to use both methods of sustainable. It is considered that Level 6 of the Code for Sustainable Homes would be more efficient with regard to energy that requiring 10% of energy demand to be supplied from renewables, however supplying renewable energy allows national energy supply targets to be achieved.
104/ 059d It is a requirement of PPS 1: It is considered that comment None. Planning for Climate Change is made with full regard to that the local authority test its paragraph 33 of the PPS 1 requirements against securing Supplement the points of this the expected supply and pace paragraph will be answer of housing should in the respectively. housing trajectory in accordance with paragraph 33. “Planning Authorities should: it is also a requirement of the – ensure what is proposed is local authority not the evidence-based and viable,
109 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development industry to ensure having regard to the overall what is proposed is evidence costs based and viable having regard of bringing sites to the market to the overall costs of bringing (including the costs of any sites to the market. necessary supporting infrastructure) and the need to avoid any adverse impact on the development needs of communities;” All evidence relating to the viability of targets relating to sustainable buildings will be contained within the Technical Paper ‘Green Strategy’. In relation to the costs related to bringing forward housing sites, economic viability assessments are being conducted as part of the Strategic Housing Land Availability Assessment. In terms of infrastructure costs, research has been conducted which is being developed as part of the evidence for the Local Development Framework.
110 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. – “in the case of housing development and when setting development area or site- specific expectations, demonstrate that the proposed approach is consistent with securing the expected supply and pace of housing development shown in the housing trajectory required by PPS3, and does not inhibit the provision of affordable housing; and” The Core Strategy is not setting area or site specific targets for development areas. It is considered that the targets that have been set can be accommodated within the expected supply and pace of housing development within the Borough; please see the Technical Paper ‘Green Strategy’ for more information. – set out how they intend to advise potential developers on
111 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the implementation of the local requirements, and how these will be monitored and enforced. Implementation of the Core Strategy is fully detailed within the Delivery Strategy. 104/ 059e Would refer the Council to the Comment noted. None. recent Inspector’s Report for the examination of the Borough of Poole Core Strategy in respect of energy efficiency requirements and the removal of unsound onerous requirements. 104/ 059f PPS 1 Planning for Climate The requirement for a None. Change sets out in paragraph Sustainability Statement to be 11.3 that “specific standalone submitted for new assessments of new developments over a certain development should not be size is a requirement of the required where the requisite WMRSS Policy SR3 Point A. information can be made The WMRSS is not adopted available to the planning and therefore Officers are still authority through a submitted considering whether this Design and Access Statement, requirement is still appropriate
112 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. or forms part of any for inclusion within the Core environmental impact Strategy. It is considered that assessment or other regulatory the Sustainability Statement regime.” Bullet point iv) is does more than a Design and therefore inappropriate in that it Access Statement as it requires a sustainability requires consideration of the statement to be provided. This West Midlands Sustainability should be reworded to include Checklist. If Development reference to Design and Control Officers considered Access Statements not that all of the points that are additional standalone required to be addressed in the assessments. Sustainability Statement have been fully addressed by other statements such as the Deign and Access Statement, then this would be satisfactory. However it is still necessary for the Policy to require a Sustainability Statement for those developments who have not fulfilled the requirements elsewhere.
Climate 133/ 207 Typing error on page 50, Please see response to None. Change paragraph 2, the sentence 049/736d.
113 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. should read, ‘mitigate and adapt to the effects of climate change.’ This refers to new build, can this be widening to existing properties?
Text should be reworded on The Core Strategy no longer None. page 50 to, ‘it is now accepted has introductions that are as that the world’s climate is detailed and broad as this and changing and that the impacts therefore this comment is no of this are already being felt longer relevant. locally’ . There should also be reference to extreme weather events.
It should be mentioned the It is not considered that the None. opportunities that arise from a Core Strategy would be the changing climate e.g. tourism. appropriate medium to detail the benefits of climate change as this document intends to reduce the damaging effects of climate change by reducing carbon emissions.
It should be noted what level The Core Strategy no longer None. the housing development has introductions or sub
114 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. scored on page 50. sections that are as detailed and broad as this and therefore this comment is no longer relevant.
The % of renewables on site The principle of this is None. should exceed the Merton supported, however it is Rule, 15% would show a considered that Redditch strong commitment and gear Borough does not have developers up for zero carbon sufficient evidence as yet to housing in 2016. prove that higher targets are deliverable or achievable and therefore the national and 10% renewable rule is likely to be used.
Climate 133/ 212 Ambitious plans for combating Support noted. None. Change climate change but this is good. Climate 093/ 495 It should be noted that climate Climate change is a well None. change change is a cross cutting publicised issue and that it is theme which has impacts on not necessary to detail of all flood risk and biodiversity as the effects of climate change well as water availability and within this document, these quality. effects are detailed in national
115 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and regional planning policy. Climate 103/ 164(a) The reduction in the causes of CHP is a form of renewable None. Change climate change would be energy, which is a requirement achieved if all super of the Core Strategy. However communities were supplied it would not be appropriate to with heat from a CHP unit. This dictate which form of would reduce emissions by fifty renewable energy should be percent, rather than the ten used in each scheme due to percent set by the DPD. The the local differences in sites. A use of the Arrow Valley Lake form of renewable energy would mitigate against climate which is suitable for one site change, rather than simply may not be suitable for using insulation. another. It is unclear how the use of Arrow Valley Lake would mitigate against climate change and how this would be appropriate for inclusion within the Core Strategy. Sustainable 103/ 160 There may be a need to Specific construction standards None Buildings combat climate change by of properties are dealt with by insulating houses to a much Building Control standards and greater degree to reduce fuel are too detailed for consumption, there is a danger consideration within the Core of other effects resulting from Strategy. The requirement for this policy that do not seem to sufficient ventilation is also
116 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. be considered by the West assessed through the Building Midlands Spatial Strategy. For Control requirement. example occupants need to be comfortable – with heating With the Code for Sustainable None systems that heat the air in the Homes there is a credit house, not the fabric of the available if drying space is house. There is a need for provided. As applicants need to fresh air to be introduced into achieve certain levels of the highly insulated buildings. All Code this is a credit that is buildings that are required to available for applicants to meet sustainable homes implement as a way of standards should provide increasing their credit score. adequate facilities for drying washing outside the living space.
There is a danger that requiring Affordability is a key challenge None homes to provide 10% of the for the Core Strategy to deal energy demand will force up with and is considered a very the price to such an extent that important issue. The cost of the houses become providing 10% of energy unaffordable for many families. demand from renewable The trigger point for BE. 1 iii) resources does add an should be twenty homes rather additional cost to the build of a than five, and the industrial development, however this units should be 2,000 sq. cost will reduce as technology
117 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. metres. As smaller combined develops and renewable heat and power units are resources become more unsustainable and unreliable. common place. The renewable energy requirements need to be in place to ensure that the climate change targets are achieved. The trigger point for BE.1 iii) is 5 dwellings as a number of the development sites in Redditch are very small and if the trigger point is 20 this would diminish the opportunity for Redditch to produce renewable energy.
Page 49, 102/ 150 Should state ‘seeks to protect This no longer applies to the None. Para 1 and enhance the natural and structure of the Core Strategy historic environment…’ as the as the paragraph is deleted. two elements are interlinked elements of the environment as a whole. Paragraph 3 should read ‘natural and historic environment… and risks to the historic and natural environment…’ this includes
118 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. risk of flooding to historic properties (both structural and to fittings) and desiccation of waterlogged archaeological deposits, including peat, through drought.
The abundance of trees and This has been taken account None. the present distribution of of, however the Historic settlements and farmsteads in Landscape Characterisation for the borough is directly related Worcestershire is not yet to its historic settlement pattern complete. and its role as a former royal forest. Historic landscape boundaries should be respected and promoted within any new development. development proposals should take account of information contained within the Historic Landscape Characterisation for Worcestershire (on-going project 2008 - 10), Historic Farmsteads Survey (on-going 2008-9) and the County Historic Environment Record.
119 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Renewable 265/ 420 It is recommended that the Agreed. There is a policy within None. Energy and Council introduce specific the Preferred Draft Core Climate policies designed to deliver Strategy that seeks to achieve Change greater production of this. renewable energy and increased levels of energy efficiency, in order to minimise the impacts of climate change.
Renewable 265/ 421 It is recommended that the It is considered that the exact None. Energy and generic phrases which simply wording will incorporate the Climate seek to encourage the use of appropriate detail and Change energy efficiency, renewable commitment suitable to the energy and the minimisation Core Strategy. Officers are still and management of waste and considering the appropriate pollution are avoided, for wording to ensure the example, as such, phrases lack aspirations of the Core the detail and commitment Strategy are achieved. necessary to ensure that such aspirations are achieved. Officers are still considering the Therefore it is strongly policies to be included within recommended the inclusion of the final Core Strategy, an overarching climate change however an overarching policy policy within the Core Strategy may be appropriate to outline document, addressing the the climate change aspirations
120 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. above issues, and the inclusion for the Borough. of discrete, proactive policies on energy efficiency, renewable energy, sustainable design and construction, within the Development Control Development Plan Document, in order to provide detailed policy direction on each issue and to ensure that such environmental measures are delivered.
Renewable 265/ 422 The LDF should include a The Core Strategy contains a None. Energy Policy robust criteria based policy that policy that promotes the use of will be used to assess all renewable energy. A criteria applications for renewable based policy that would be energy developments. used to assess applications would be more appropriate for inclusion within the Site Allocations and Policies DPD.
It is recommended that there This may be a consideration for None. should be a specific the Site Allocations and
121 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Development Control policy on Policies DPD. It is envisaged renewable, focusing on the key this DPD will incorporate a criteria that will be used to number of specific policies that judge applications, and are Development Control providing direct reference to related where this is deemed PPS 22. More detailed issues necessary and related to the may be appropriate to allocations. Supplementary Planning Documents. Renewable 265/ 423 It is recommended that policies A study conducted by None. Energy Policy designed to safeguard the Worcestershire County Council character and setting of Listed has concluded that Redditch Buildings, Conservation Areas Green Belt does not have any and Green Belt, for example, capacity for large scale have regard to the positive renewable energy production. contribution that renewable With regard to Conservation energy can play. Areas and Listed Buildings, their capacity to accommodate renewable energy systems is adequately encouraged by national planning policy.
Planning Applications for This is a consideration for the None. renewable energy Site Allocations and Policies developments in areas such as DPD.
122 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. landscape and nature conservation designations should be assessed against criteria based policies set out on Local Development Documents. Any approach should be consistent with PPS 22 and should not preclude the supply of any type of renewable energy other than in the most exceptional circumstances.
Renewable 265/ 424 Planning Authorities should not Noted. None. Energy Policy make assumptions about the technical and commercial feasibility of renewable energy projects. Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable.
Local Planning Authorities Noted. None.
123 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. should not require applicants for energy development to demonstrate either the overall need for renewable energy or its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location.
Renewable 265/ 425 All information requested of Noted. None. Energy Policy applicants should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change, and be consistent with that needed to demonstrate conformity with the Development Plan and the Climate Change Supplement to PPS1.
Specific and standalone Noted. It is considered that if None. assessment of new the information is provided
124 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development should not be elsewhere this would be required where the requisite acceptable. It would need to be information can be made made clear to Officers where available to the planning this information can be found. authority through other submitted documents e.g. as part of a Design and Access Statement.
An applicant for planning Planning applications that seek None. permission to develop a to deliver the Key Planning proposal that will contribute to Objectives of the Climate the delivery of the Key Change Supplement to PPS1 Planning Objectives set out in will be looked on favourably, the Climate Change however each planning Supplement to PPS1 should application is required to go expect expeditious and through the standard sympathetic handling of the development control planning application. procedures.
Low and Zero 265/ 426 The planning system needs to The Core Strategy is in line None. Carbon support the delivery of the with the national timescales for Development timescale for reducing carbon the Code for Sustainable s emissions from domestic and Homes. It is also considered non-domestic buildings, and that the Core Strategy does
125 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. local planning authorities are encourage the development of expected to actively encourage small scale renewable energy smaller scale renewable schemes. energy schemes through positively expressed policies in Local Development Documents.
Alongside criteria – based A study has been completed by None. policy developed in line with Worcestershire County Council PPS 22, the Climate Change which considers the capacity of Supplement to PPS 1 Redditch Borough in terms of recommends that local large scale renewable energy authorities consider identifying development. This study has suitable areas for renewable identified that there is no and low-carbon energy capacity within the Borough for sources, and supporting any large scale renewable infrastructure, where this would projects and therefore there is help secure their development. no potential to identify land.
With regard to infrastructure that is required to support future developments, meeting have been held with infrastructure providers to
126 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. establish whether the current infrastructure is satisfactory to deal with future development, or if additional infrastructure is needed what this is, where it is required and the funding for this. Small renewable systems can The Core Strategy contains a None. make a contribution. It is urged policy which requires a that a policy is implemented for proportion of on-site the mandatory requirements of renewables that supplies 10% onsite renewables. Such a of a buildings energy needs. policy would require onsite Energy efficiency/ building renewables to provide for at performance is enhanced least 10% of all new buildings through the Code for energy needs (including Sustainable Homes – which is refurbishment) in addition to also contained within a policy stringent energy efficiency/ in the Core Strategy. With building performance regard to refurbishment there is requirements. little the Core Strategy can do to ensure established building incorporate a proportion of renewable energy; however there are grants available from the Council which can aid in
127 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. achieving this.
It is recommended that there is It is considered that the Policy None. a discrete policy on sustainable focusing on climate change design and construction fully addresses sustainable methods, and the introduction design and construction of minimum efficiency methods and an additional standards for extensions, policy is not necessary. The change of use conversions and principles set out in this policy refurbishments/ listed building would not be applicable to restorations. extensions, change of use conversions and refurbishments/ listed building restorations as this is too detailed for the Core Strategy.
Planning authorities should The ‘Green Strategy’ Technical None. have an evidence- based Paper will detail the feasibility understating of the local of renewable energy in the feasibility and potential for Borough. renewable energy and low- carbon technologies, including microgeneration, to supply new development in their area.
128 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Local authorities should – - set out a target All of these factors have been Amend policy in line with percentage of the considered and will be WMRSS. energy to be used in incorporated into the new development to renewable energy policy within come from decentralised the Core Strategy. and renewable low- carbon energy sources Where it is considered and - where there are demonstrated that a particular particular and site could deliver a higher demonstrable proportion of renewable energy opportunities area or than that stipulated in the Core site specific targets Strategy this will be outlined in should be used to the Site Allocations and secure this potential Policies DPD or any future - set out the type and size Area Action Plans. of development to which the target will be applied The ‘Green Strategy’ Technical - ensure there is clear Paper will detail the rationale rationale for the target for any targets within the Core and it is properly tested. Strategy. It is recommended that the It is considered that this would None. development plan provide a be too detailed for the Core brief outline of the different Strategy and would also make renewable energy generation the Core Strategy unduly long.
129 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. technologies and equally This detail is included in a encourage and promote all climate change leaflet which is forms of renewable energy. sent out to applications for planning permission.
Cross Boundary
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 002/068; Prof P Agree Bordesley area is the best The Panel Report following the Hold a joint consultation Boundary Sanders direction for houses because of its Examination in Public into the period with Bromsgrove infrastructure namely good roads, WMRSS Phase II Revision was District Council on the new school in Alvechurch, good published in September 2009. potential locations for cross- bus services and access to a train The report recognises that boundary development. service. It seems there is insufficient land within incomprehensible that all new the Borough boundaries to Update Key Diagram to show houses will gain access via the meet locally generated needs the broad location of the SUE minor roads of Dagnell End Road for either housing or boundary to be determined in or the Holloway. Surely the employment. The Panel report collaboration with boundary should be west towards recommends that that the Bromsgrove District Council the Cobbs Barn roundabout overall provision for Redditch following joint consultation instead of north towards Rowney should be 7,000 dwellings, of period.
130 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Green as suggested by the WYG which 4,000 should be provided report? within the Borough boundaries. The remaining 3,000 dwellings are to be located in Bromsgrove district adjacent to the boundary of Redditch with the precise location to be determined locally.
At the time of the production of the PDCS, the evidence base suggested that the most appropriate location for a SUE to Redditch would be Bordesley Park. The site boundaries and details regarding access of any SUE were not determined at the time of publishing the PDCS, also the precise boundaries are not required to be identified in Core Strategies in any case. Sufficient boundaries will be determined in further discussion with landowners, developers and Redditch and Bromsgrove
131 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Councils. It is anticipated that any precise Green Belt alterations will be detailed in either the Redditch or the Bromsgrove Core Strategies, depending on the outcome of further exploration. Cross 002/254; Prof P Except a road from area 4 to meet The site boundaries and details No change. Boundary Sanders up with Cobbs Barn roundabout to regarding access of any SUE carry the traffic from areas 2, 3 and were not determined at the time 4 rather than use minor roads of of publishing the PDCS; also Dagnell End and Storrage Lane. the precise boundaries are not Bordesley Bypass is essential. required to be identified in Core Strategies in any case. Sufficient boundaries will be determined in further discussion with landowners, developers and Redditch and Bromsgrove Councils. Cross 005/480; Welcome acknowledgement that See response to respondent Hold a joint consultation Boundary William Davis cross boundary growth and joint No. 002/068. period with Bromsgrove Ltd working with Bromsgrove and District Council on the Stratford-on-Avon Councils is potential locations for cross- needed. Support identification of boundary development. Bordesley Park as the most
132 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. suitable location for future growth. Update Key Diagram to show It is highly sustainable. the broad location of the SUE boundary - to be determined in collaboration with Bromsgrove District Council. Cross 005/481; Welcome the Council's indication The three Local Authorities No change. Boundary William Davis that they will liaise closely with have been continuously Ltd Bromsgrove/Stratford but are working together to produce the concerned that this joint working respective Core Strategies does not go far enough. Favour however there have been production of joint Core Strategy differences of political opinion for the three Districts. which has made progression through Core Strategy production difficult for the three Authorities. The possibility of a joint Core Strategy was explored however it was unanimously determined that this was unfeasible for the three Local Authorities involved for both practical and policitical reasons which would have significantly delayed any Core Strategy production. Cross 016/069; Mr JC Concerned that any new housing Agreed based upon the No change.
133 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Boundary Lane development built out from the Evidence Base. The Panel Batchley/Webheath areas into Report into the WMRSS Phase Brockhill and Hewell will have a II revision recommends that to detrimental effect on the wildlife in meet Redditch’s needs 3,000 the area. Argues that the woodland dwellings should be built in and lake on the estate are Bromsgrove district adjacent to important ecological areas which the Redditch boundary but that need to have green buffers around the locations should be them. determined locally. Further evidence will be collected to determine where Green Belt allocations should be made and where development would be more sustainable. Cross 017/251; CPRE Questions the line of the Bordesley The detail regarding the exact None. Boundary Bypass, scheduled for some time route of the Bordesley Bypass and long overdue. will be determined. The amount of growth to be accommodated in and around Redditch is likely to necessitate the construction of the Bordesley Bypass.
River Arrow is a constraint of the Agreed. Officers consider the None. smaller area identified. This is an ecological profile of the River intense wildlife corridor with flood Arrow to be of high importance.
134 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. terracing on both sides of the Potentially any open space River. It should not be built upon. provision should look to improve the biodiversity as part of any SUE.
Larger area has the Dagnell Brook It is considered that the extent Apply the provisions of more or less through the centre. It of river terracing is not likely to PPS25 to the north of goes through Lower Park Farm be high in this location. It is Redditch in determining the and is joined by another Brook agreed that any future uses for location of any SUE. further South which then forms a this area should comply with tributary to join the River Arrow. the provisions in PPS25. River terracing will occur both sides of each brook and again this has to be considered against any building of any type. The employment and housing None. 8Ha of employment land and 1,680 land requirements for Redditch residential units is an enormous Borough are determined by the build. WMRSS.
This is a detailed consideration Consider the rights of way to which will influence the likely the north of Redditch in In both areas there are footpaths location of any SUE. determining the location of which are Public Right of Way: any SUE. • Lower Park Farm to the North
135 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. of Poplars Farm • Beoley Hall to and crossing Dagnell End Road into the Abbey Golf Club site • Bordesley Park Farm crossing Dagnell End Road • Rowney Green to Bordesley Park Farm • Rowney Green through Lower Park Farm to Poplars Farm • Lower Park Farm to Bordesley Park Farm And footpaths exists both sides of the River Arrow in the smaller area. Cross 017/252; CPRE Ravensbank Business Park - The The status of Drovers Road Redraft cross-boundary Boundary black shaded area of 10Ha for being listed in the County elements of the Core Strategy employment is Green Land. It is Council's list of streets does not and include reference to the more flat land attached to the preclude any potential need to protect any relevant existing Ravensbank Business development. The sensitivity of SWS. Park buildings. Along these is the SWS needs to be Drovers Road with the status of considered should any SWS. The line of the Drovers development occur in this area. Road is in Redditch Borough only, the built on land is in Bromsgrove.
136 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. The Drovers Road is entered in the List of Streets. The Ancient Highway has already been breached three times. Any further breaching for business purpose will destroy the total amenity. It is therefore a constraint for development. None. The employment land Miss J Kirkbride states in her requirements are to meet the submission for the EiP that needs of Redditch's population Bromsgrove has a surplus of and should be within or employment land. So why is this adjacent to the Borough. location being identified as it is in Bromsgrove District. Also the land appears to be an ADR by BDC, who it is understood, do not have the knowledge of the protection accorded to the whole Drivers Road from Beoley Village to Longhope Close in Winyates Green. The Far Moor Lane stretch None. is nothing to do with BDC. At 01.04.09 the remaining capacity at Ravensbank was How much more of the 4.18ha, this is to meet Redditch Ravensbank Business Park area is Borough Council's
137 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. there earmarked as employment requirements. The site was land, and is it for BDC or RBC? designated to meet RBC's With surplus employment land employment land requirement, BDC will not require this site. Is therefore it does not have an this how it works? It was RBC who effect on Bromsgrove's wanted the Business Park, not designations, apart from being BDC. in their District. However the remaining capacity is not surplus and it is expected to be developed in due course. None.
Those sites identified in Local Plan No.3, inclusive of Much employment land and Ravensbank, were not buildings in Redditch is also allocated on a sequential basis. available and needs to be Some vacant units are not considered for future use before considered to meet the needs releasing this identified site and of the current market, and CPRE object strongly to its early therefore prohibiting economic release before all unused development elsewhere would employment locations are utilised. be unsustainable. Cross 017/253; CPRE Foxlydiate - a woodland reserve It is not clear what the Hold a joint consultation Boundary site: The Green Area is two blocks, representation is referring to in period with Bromsgrove one each side of the Bromsgrove terms of impacts on Batchley District Council on the Highway A448. The road bridge is and Webheath; however any potential locations for cross-
138 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. an advantage for both blocks as a impacts would be investigated boundary development. main road access. The Northern as part of the sustainability Block reaches to the Hewell appraisal process. It is Re-draft cross-boundary Grange area and impacts on accepted that the public rights elements of the Core Batchley. The Southern Block of way would need to be Strategy. impacts on Webheath. Foxlydiate considered when concluding LNR is nearby but not included. the most appropriate location Both blocks have footpaths which for any SUE. The provisions of are Public Rights of Way and will PPS25 will be adhered to with be constraints where development regard to the flooding constraint is concerned, as are the rivers identified. It is considered that passing through both blocks. The the WYG study referred to size of these two blocks has not residential development been given and whether it would predominantly for the be for housing only. As an Foxlydiate Woods option. It is extension for housing and as there acknowledged that the nature are no employment facilities, of the location is distant from building here will produce other employment areas, and dormitory districts. Would need to this will be taken into account include new schools and other of in the sustainablitlity infrastructure. appraisal and in determining the location of any SUE.
The required environmental survey Full ecological surveys would None. along the river arrow will need to be appropriate before any be established initially and development can come
139 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. monitored. forward. Cross 021/100; WMRA Suggests that the level of housing The Panel Report following the Consultation period to be held Boundary growth outlined for Redditch in the RSS Phase II Examination for the purposes of consulting Core Strategy falls around 30% recommends that the housing on potential locations for short of that required by the target for Redditch should be development that have not Preferred Option of the WMRSS. increased to 7,000 dwellings, of previously been the subject of which 4,000 should be consultation. accommodated within Redditch’s boundaries. The publication version of the Core Strategy will reflect the increased target and a period of public consultation will be held to allow consideration of potential locations for the increased number in conjunction with Bromsgrove Whilst the Redditch draft Core District Council. No change. Strategy makes reference to Bromsgrove and Stratford-on-Avon It will be for the Core Strategies accommodating a higher level of of neighbouring Districts to housing growth than set out in the refer to its proportion of Preferred Option in order to Redditch related growth. compensate for the shortfall in Redditch, neither of the draft Core
140 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Strategies for these districts adopts this extra growth.
Cross 024/112; C Support for growth in three areas See response to respondent Re-draft cross-boundary Boundary Wittingham identified by White Young Green. No. 002/068. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 028/102; Considers that the Council has Please Refer to Technical No change. Boundary GOWM accepted the findings of the White Paper 1 - Sustainability and the Young Green Study and SA Refresh which appraises all incorporated them into the draft development options in and Core Strategy, but asks whether around Redditch against the conclusions have been tested, Redditch's SA Framework. particularly through the sustainability appraisal. Suggests this will be a factor in the Examination of the Core Strategy. Cross 036/114 Endorses the allocation of housing See response to respondent Re-draft cross-boundary Boundary growth in the Bordesley area. Cites No. 002/068. elements of the Core Strategy the capacity for Alvechurch Bypass to support any growth in traffic; the Update Key Diagram to show
141 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. accessibility to industry on the east the broad location of the SUE side of Redditch and; accessibility - to be determined in to the Town Centre and Abbey collaboration with Stadium sites as justifications for Bromsgrove District Council. housing development in Bordesley. Cross 036/116 Disagrees with plans for Foxlydiate The housing requirements are No change. Boundary as a site for housing allocations, set out in the WMRSS and the arguing it is piecemeal and would required provision will be set overload a dual carriageway that out in the Core Strategy. The already experiences a number of Redditch Green Belt site at accidents. Foxlydiate would be subject to the consultation period between Redditch and Bromsgrove and factors such as road capacity would be considered. Cross 041/718; Mr The site at Bordesley has See response to respondent Re-draft cross-boundary Boundary Bedford Smith immense residual advantages No. 002/068. elements of the Core apart from gravity drainage, of Strategy. proximity to Sainsbury's and recreational facilities and Abbey Update Key Diagram to show Stadium the broad location of the SUE - to be determined in collaboration with Bromsgrove District Council.
142 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 042/462; Show the preferred locations for Green Belt alterations to Hold a joint consultation Boundary Stoneleigh 4,350 homes and 24ha of accommodate development period with Bromsgrove Planning c/o employment land beyond requirements will be detailed in District Council on the Gallagher Redditch's boundary. the Redditch and Bromsgrove potential locations for cross- Estates Core Strategies as appropriate. boundary development. The site boundaries and details regarding access of any SUE Update Key Diagram to show were not determined at the time the broad location of the SUE of publishing the PDCS; also to be determined in the precise boundaries are not collaboration with required to be identified in Core Bromsgrove District Council. Strategies in any case. Sufficient boundaries will be determined with further discussion with landowners, developers and Redditch and Bromsgrove Councils. Cross 042/463; There is an absence of an The approach to delivering Re-draft cross-boundary Boundary Stoneleigh appropriate policy approach to the Redditch's development elements of the Core Planning c/o future growth of Redditch based on requirements both within the Strategy. Gallagher the WYG Study, delaying core Borough and cross-boundary Estates strategy preparation. has been explained at each stage of Core Strategy production despite the constraints on the Borough
143 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Council and the lack of clarity throughout the progression of the WMRSS Phase Two revision. Redditch Borough Council has been unable to include policies on land outside of the boundary of the Core Strategy DPD area. Cross 042/466; Clients remain committed to See response to respondent Re-draft cross-boundary Boundary Stoneleigh delivery of a strategic mixed use No. 002/068. elements of the Core Planning c/o development at Bordesley Park Strategy. Gallagher Farm and agree that land in this Estates area represents the most Update Key Diagram to show sustainable location for the future the broad location of the SUE growth of Redditch to 2026. to be determined in collaboration with Bromsgrove District Council. Cross 084/122 Concerned with the number and The number of houses to be No change. Boundary location of houses to be provided provided for Redditch is in the Borough to 2026. Believes determined by the WMRSS that it is disappointing that green Phase Two Review process. belt land will need to be utilised in The requirements for Redditch order to satisfy growth and the exhaustion of sites requirements in Redditch. Argues within the urban area mean that firmly against the WMRSS it is inevitable that some Green
144 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. classification of Redditch as a Belt land in or around Redditch Settlement of Significant will need to be used for Development, suggesting that development. The designation rather this designation should be of Redditch as SSD is not switched to Bromsgrove. Suggests carried forward in the Panel that the use of green belt land for Report. Bromsgrove has not development in Redditch been classified as an SSD. contradicts the WMRSS aim of urban regeneration. Cross 084/124 Strongly recommends directing the See response to respondent Hold a joint consultation Boundary majority of housing growth at No. 002/068. period with Bromsgrove Bordesley rather than Foxlydiate. District Council on the Firstly, all of the growth that cannot potential locations for cross- be accommodated within the boundary development. Borough boundary can be provided for in one location at Re-draft cross-boundary Bordesley. Secondly, the use of elements of the Core Bromsgrove green belt land can be Strategy. partly offset by returning the three ADR locations in Redditch back to Update Key Diagram to show green belt. Finally, recommends the broad location of the SUE expansion at Bordesley given the to be determined in lack of growth opportunities collaboration with elsewhere, the existing and Bromsgrove District Council. potential road infrastructure at
145 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Bordesley and the area’s accessibility to the Town Centre and future Abbey Stadium development. Cross 095/139 Strongly supports the designation See response to respondent Hold a joint consultation Boundary of housing at Bordesley as it is a No. 002/068. period with Bromsgrove large enough site to accommodate District Council on the all of the housing. Believes this potential locations for cross- would be the logical option given boundary development. the area’s road structure and access to the Town Centre and Re-draft cross-boundary business sites, as well as the elements of the Core planned development at the Abbey Strategy. Stadium. Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/004 Criticises the WYG report’s RBC has assessed a number No change. Boundary omission of the North West Urban of development alternatives, Extension for Redditch outlined by including the option put forward RPS as an option for consideration by the objectors in the SA. It for future housing development. was important that the consideration of all possible
146 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. development options was not constrained. This would have been the case had the WYG Joint Study considered the site development boundaries of options put forward by prospective developers/landowners. It is therefore appropriate that the WYG study did not consider the specific area noted as the North West Urban Extension in isolation. Cross 104/006 Expresses concern for First and It was always intended that the No change. Boundary Second Stage reports from WYG, WYG Stage 2 report identified acknowledging that whilst the the specific constraints to Stage 1 report undertook a fairly development with the aim of comprehensive assessment of determining the preferred possible growth options, the Stage location so that the split to the 2 report was neither development requirements comprehensive nor robust. between the three authorities could be made by the WMRSS Examination in Public and is by its nature more focussed that the Stage 1 report.
147 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 104/007 The Stage 2 report cannot be In addition to comments No change. Boundary reliably used to inform received during consultation on development choices within the the Core Strategy, the Stage 2 Bromsgrove District of Redditch Report was used in conjunction Borough. with the Redditch SHLAA, Sustainability Appraisal and the Public Open Space Standards in the Borough document to inform development choices for Redditch in the Preferred Draft Core Strategy. Cross 104/008 Suggests that in lieu of the proper There are a number of Re-draft cross-boundary Boundary and clear SHLAA methodology, elements which will be elements of the Core the WYG report uses simplistic, considered when revising the Strategy. inappropriate and primitive SWOT development strategy for the analysis methods for assessing the Borough following the WMRSS developability and deliverability of Panel Report. land that are insufficient for advising a development strategy for the Borough or the wider requirements of Redditch town on a cross-boundary basis. Cross 104/009 The Council should revert back to SHLAA updates will be No change. Boundary developing and expanding upon its undertaken annually, but it is existing SHLAA process as part of not necessary for these to be
148 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. a joint assessment undertaken undertaken jointly. The with Bromsgrove District Council. Borough Council will explore potential ways to improve the SHLAA process. Cross 104/010 Considers that the WYG Stage 2 The SHLAA process for No change. Boundary Report falls significantly short in Redditch Borough has been respect of its project brief and does developed in line with PPS3 not provide an objective and equal guidance and includes assessment of growth options for consideration of potential Redditch. The project brief also deliverability and viability makes no reference to assessing issues. It was never the the deliverability or developability intention of the WYG Stage 2 of sites in the context of PPS3. study to do this. Cross 104/011 Questions the entire removal of Justification for this can only be No change. Boundary area 6 and partial removal of area given in the WYG2 Second 5 from the assessment without Stage Report. Further SA of justification, despite these sites areas 5 and 6 indicate that area being given considerable support 6 is favourable whereas area 5 in the site analysis stage. may have some constraints. In Considers the removal of these addition the Water Cycle Study sites, without proper reasoning or and SFRA indicate that consultation as rendering the study development of this area is unsound and inequitable. likely to be difficult and hence more costly. Cross 104/011b Given the removal of areas 5 and The initial evidence base No change.
149 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Boundary 6, questions are raised as to indicated to RBC that as a whether the full details of the North general direction of growth, the West SUE proposal promoted by north of Redditch was RPS were given to WYG or preferable and the whether either the Council or WYG development option put forward had predetermined that the area by the objector was considered should not be included in the as a valid alternative option. study. Seeks justification as to why Indeed at Issues and Options the area promoted by RPS was not stage RBC presumed that parts included in the study in its entirety of area 6 would inevitably be and the reasoning behind the developed. removal of area 6, despite it including the Brockhill East ADR land accepted by the Council as the most sustainable peripheral housing site at the last Local Plan Inquiry. Cross 104/014 Challenges the exclusion of area 6 WYG conclusions as well as No change. Boundary from the assessment, given the the SA of their options were findings in the WYG report that considered to be the main there is no reason to assume that factors influencing the a technical solution to water and decisions on the preferred foul drainage cannot be found and option for Redditch at this as such these issues have not stage. influenced the conclusions
150 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. regarding the most sustainable locations for extensions to Redditch’s urban area. Cross 104/015 Criticises the approach to Landscape character was given No change. Boundary sustainability in relation to further consideration in the final landscape character and visual revisions to the WYG resources used by WYG as conclusions. outdated and flawed. Suggests WYG is out of step with current Government guidance on the delivery of Green Infrastructure. 104/015a Focus on 'significant weight of Landscape designations are No change. qualitative considerations' is appropriate considerations outdated methodology. Landscape when looking at the types surrounding Redditch are development potential of sites. based on the 'A New Look at the It is understood that both the Landscapes of Worcestershire, 2004 and the 2008 Landscape 2004' as opposed to the stated Character Assessment was document 'Planning for considered during the Landscapes in Worcestershire : preparation of the WYG Report. Worcestershire Landscape Character Assessment : Process, Products and its role in the Planning System' June 2008. No change.
151 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Assessment level of Landscapes The Worcestershire Landscape for Worcestershire is a large scale Character Assessment is a county assessment rather than very detailed assessment for local area of Redditch. use by District Council's as well Questionable whether there is as providing a general County sufficient local information for use function. No more detail can be as an assessment tool in terms of added to a District wide LCA. sensitivity and quality. In the The landscape designations document landscape sensitivity were given significant weight in weighting is given on the basis of forming the conclusions in the landscape types without reasoned WYG Report. justification for their classification. No change. The sensitivity information was Discrepancies regarding sensitivity determined from the sensitivity weighting of landscape types e.g. mapping rather than the Area 2 Brockhill ADR Advantages description of the landscape and Disadvantages table states types. the area is "a highly sensitive wooded estateland landscape. Highly visually sensitive. Development here would be visually intrusive". But there is no mention of this area being visually sensitive in the original wooded estatelands landscape type information. Plan 5 Brockhill
152 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. topography shows land north and west of the ADR as contained with direct visual links with surrounding development. Lack of handedness regarding sensitivity rating with Area 1 Bordesley Park classed as 'low or medium sensitivity' despite being adjacent to Brockhill Character Area and in the same No change. wooded estates landscape type. The WYG report was No justification for change of commissioned jointly by the definition. three Local Authorities of Redditch, Bromsgrove and North West Masterplan SPD has Stratford and Worcestershire been overlooked by WYG in County Council and the West second stage study. Midlands Regional assembly as an independent and comprehensive assessment of development options, hence the report not considering the outcomes of other assessments including the landscape assessment accompanying the NWMP. Hold a joint consultation period with Bromsgrove Officers cannot find the District Council on the
153 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. reference to paragraph 4.21 potential locations for cross- comments in the draft NWMP. boundary development. The landscape assessment The opportunities for accompanying the NWMP found development will be Re-draft cross-boundary that at Brockhill ADR (para 6.6) investigated further when elements of the Core "the area of Site A (ADR land) determining the location for any Strategy. north of the railway is visually potential SUE. sensitive. It forms part of the Avon Update Key Diagram to show Valley Character area. From many the broad location of the SUE viewpoints to the north it appears - to be determined in unconnected with Redditch" (RPS collaboration with emphasis). In contrast land to the Bromsgrove District Council. west of the railway line within the ADR is identified as having visual sensitivity at higher ground but with opportunities to restore landscape character. Para 6.7 states the lower part of Site A is visually well contained, is least sensitive to change and provides a good opportunity for development. In respect of the Bordesley Parkland Landscape Type (Cooper Partnership Plan L05) the comment on constraints and opportunities was that the
154 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. landscape character of Bordesley Parkland would remain unchanged by development of Site A. The None. importance of retaining that Landscape sensitivity has been character is addressed in Chapter determined in the 4 of the report (Para 4.21). Worcestershire Landscape Character Assessment which ADR west of the railway except for will inform the potential extreme north western fringes is locations for any SUE. identified by Cooper Partnerships as being in the Redditch Bowl Landscape Type (Type 3 on Plan L05). This area has low sensitivity to change (Para 4.19). This conclusion also relates to land in the Green Belt north of Lowans Hill Farm and west of Brockhill development area in Bromsgrove surrounding Oxstalls Farm. Land North and North east of the railway line in the ADR is in Landscape Type 2 Arrow Valley Area. Character extends north from the Redditch urban edge between the railway and the A441. Sensitivity to change is low adjacent to the
155 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. urban area but increases north where land becomes rural (para 4.19). Land west of the railway and north of the ADR and Brockhill development area is Wooded High Ground Landscape Type 1. There are prominent ridges but also enclosed valleys (para 4.13) and No change. concluded to be 'sensitive to change' with valued landscape All local evidence will be used features contrasting with intact to inform all Core Strategy nature of Bordesley Parkland area approaches. No change. and its high sensitivity to change. It is understood that the Regrettable that the Council has representative from STW disregarded local evidence in referred to pumping of consideration of the Core Strategy. sewerage as being 'unsustainable' which would STW commented that land west of concur with the findings of the the town would require pumping of SA Refresh of development sewerage which would be less options. No change. desirable than gravity based solutions. STW have confirmed that there would be no comparative advantage for Noted. Hold a joint consultation development to the north or north period with Bromsgrove
156 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. west of the town. District Council on the potential locations for cross- SUDS can be achieved in the It is agreed that more detailed boundary development. Batchley Brook and Red Ditch understanding of the drainage corridors. infrastructure required for any Sustainable Urban Extension is Include assessment of NW required and this is being Undertake further Redditch option in the Water Cycle investigated. investigation on transportation Strategy. matters. Hold a joint Agreed. Transportation matters consultation period with will be investigated when Bromsgrove District Council determining the location of a on the potential locations for SUE for Redditch in cross-boundary development. collaboration with Bromsgrove Requires a more detailed District Council. assessment of transportation issues relating to all options. Bordesley is on the A441 and is more likely to encourage car borne commuting to the conurbation. Cross 104/016 With regard to the principal aim of The SA suggested that area 6 No change. Boundary Redditch Green Belt to ‘prevent would be sustainable option, neighbouring towns coalescing, to more so than area 5. The WYG prevent unnecessary sprawl and to report suggests that the area safeguard the countryside’, it is would be less preferable for
157 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. suggested that North West development because of the Redditch (areas 5 and 6) is a prominence of the ridge and its preferable location for highly sensitive landscape. development as topography and With regards to coalescence, landscape features form robust Rowney Green is not a defined and defensible outer boundaries. settlement. Also suggests the inappropriateness of Bordesley Park given the risk of coalescence with Rowney Green. Cross 104/016b WYG acknowledge that their Coalescence of settlements is No change. Boundary proposed expansion at Bordesley not applicable in this location Park will result in coalescence with because Bordesley is not Bordesley itself, thus failing their classified as a defined own key PPG2 test. settlement.
Area 1 is virtually undevelopable No change due to the lack of access and Any development potential of fragmentation caused by the sites is determined in line with central floodplain corridor of the PPS25. River Arrow. Cross 104/017 Challenges WYG’s reliance on the WYG’s landscape No change. Boundary Bromsgrove ‘High Landscape interpretations are logical and Value’ designation and its can also be supplemented by application to Redditch in line with consideration of WCC
158 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. national policy that directs the Landscape Character replacement of such historic Assessment. landscape quality designations with recommended Natural England/Landscape Institute characteristic approach. Cross 104/018 Questions why no photographs are Inclusion or exclusion of No change Boundary provided to illustrate the North photographs is not considered West SUE proposal whilst to represent anything of photographs are used to illustrate relevance. both Areas 7 (Beoley) and 8 (Bordesley Park). Cross 104/019 Suggests that WYG’s analysis of The location, topography and No change. Boundary Areas 1 (Webheath) and 3 (South other site features make these West green belt) at Foxlydiate two sites incomparable. Woods demonstrates a marked lack of impartiality. Both topographically and in terms of orientation these areas are very similar to Webheath, rejected earlier in the report. Cross 104/020 Suggests that the WYG report fails Advantages/Disadvantages of No change. Boundary to recognise the full potential for each location were assessed in development to the North West of the WYG Stage 2 report. Redditch and therefore does not
159 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. consider the benefits that could be delivered through a mixed use Sustainable Urban Extension (SUE) located in this area. Cross 104/021 Proposes that development to the It is considered that all No change. Boundary North West of Redditch would development options would have better transport links than at involve some infrastructure Bordesley Park, with 5 or 6 vehicle investment. access points to the existing highway network and connections to the A441 and A448. In contrast, Bordesley Park relies heavily on the existing A441 for access to the town centre as well as Ravensbank Drive to which vehicle access would be concentrated to one loading point to the South East. Suggests development would introduce delays and congestion on the route for traffic leaving Redditch towards the M42 corridor. Cross 104/024 Criticises WYG Sustainability The SA Refresh undertaken by No change. Boundary Appraisal and argues against its Redditch Borough Council adoption. Suggests that the appraises all development
160 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. assessment is a very simplistic options in and around approach to SA in which the short Redditch. SA of background responses to the sustainability documents/evidence base was criteria cannot be considered not required. The WYG Second appropriate or robust enough to Stage Report is accompanied assess the significance of by a simple SA matrix which environmental, social and builds upon the draft SA economic effects of growth options completed for the Core associated with major urban Strategy. The SA matrix extensions. accompanying the WYG Report does not purport to be a formal assessment as it does not relate to either a plan or programme as defined by the relevant SEA Regulations. However, it was produced to provide a basis for assessing and understanding the sustainability implications of development in different Hold a joint consultation Criticises the lack of consultation, locations. period with Bromsgrove identifying that stakeholders have District Council on the not been presented with the The preparation of two Core potential locations for cross- opportunity to comment on the Strategies to deal with the boundary development. range of options thus denying the cross boundary issues coupled inclusion of the North West Urban with uncertainties in the RSS
161 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Extension option. Equates the Phase Two Revision process Council’s processes with the has made the process failings of the Restormel Borough complex. Consideration of all Council Core Strategy which was alternative options with cross criticised for its lack of public boundary implications have consultation and fell short of the been dealt with as far as approach required by SA. practicable within RBC's core strategy, sustainability appraisal and evidence base. There have been many opportunities over and above the normal opportunities, for consultees and stakeholders to be involved in the core strategy process and it is noted that the objectors have used these opportunities to make their No change. Concludes that the WYG appraisal comments. process is superficial in content, does not contain the most The WYG report fulfils the brief reasonable of all the alternatives to in determining the preferred the preferred strategy, and the location for future growth in and options have not been subject to around Redditch. There have consultation as set out in the been many opportunities over Project Brief. The Council would, and above the normal therefore, be challenged if it relied opportunities, for consultees
162 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. on the document. and stakeholders to be involved in the core strategy process Cross 104/026 Argues that neither Redditch nor The residential requirements Change the development Boundary Bromsgrove authorities have for the Borough as set by the requirements to be satisfactorily identified specific land WMRSS will be reflected in the accommodated in Redditch to accommodate 3,300 dwellings Redditch Core Strategy and the Borough. in a justified or effective manner. remainder in Bromsgrove Neither has the Redditch Core District will be reflected in the Strategy identified specific land to Bromsgrove Core Strategy. meet its own requirements within its administrative area. Furthermore, it is suggested that the Core Strategies do not align in any kind of coherent strategy compatible with RSS Policy CF3. Cross 104/027 Suggests there is an absence in See response to respondent Re-draft cross-boundary Boundary the spatial planning for Redditch No. 002/068. elements of the Core Strategy by Bromsgrove District Council to plan proactively for the 8ha of Update Key Diagram to show employment land required to be the broad location of the SUE provided within Bromsgrove and/or - to be determined in Stratford. It is suggested that an collaboration with urban extension within Bromsgrove District Council. Bromsgrove is the most sustainable option and therefore
163 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. the Council should be more proactive in identifying suitable land. Cross 104/028 Suggests there is an absence of a The WMRSS provides Hold a joint consultation Boundary sound policy to address Green Belt adequate reasoning for Green period with Bromsgrove issues around Redditch in the Belt adjustments within District Council on the Core Strategy. Green Belt policy Redditch. The development potential locations for cross- around the periphery of Redditch requirements set will boundary development. will require a substantial necessitate Green Belt release. assessment in order to determine It is anticipated that reference Re-draft cross-boundary the most appropriate location for to Green Belt alterations will be elements of the Core growth within the district of detailed in Redditch's and Strategy. Bromsgrove. It is suggested that Bromsgrove Core Strategy as the current evidence base appropriate once the prepared by Redditch Borough development strategy for Council and WYG is neither Redditch and the broad credible nor robust. There is a location for growth in need for a comprehensive and Bromsgrove is determined objective based assessment of the following consultation. Green Belt around Redditch. Cross 104/031 Suggests that the findings that The residential requirements Re-draft cross-boundary Boundary 2,243 dwellings can be provided for the Borough as set by the elements of the Core within the Borough with the WMRSS will be reflected in the Strategy. remaining 4,357 to be provided in Redditch Core Strategy. Bromsgrove are based upon weak
164 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. evidence. It is also contrary to RSS policy which requires 3,300 dwellings within the boundary, for which there is capacity on the sites promoted by RPS. Cross 104/032 Suggests that the two spatial See response to respondent Re-draft cross-boundary Boundary approaches to cross-boundary No. 002/068. elements of the Core spatial planning to be found in the Strategy. Redditch and Bromsgrove Core Strategies are incompatible, and Update Key Diagram to show despite both being Preferred the broad location of the SUE Options documents, do not to be determined in propose development in the same collaboration with location as each other. Bromsgrove District Council. Cross 104/033 Suggests that the Core Strategies See response to respondent Re-draft cross-boundary Boundary do not provide a comprehensive No. 002/068. elements of the Core Strategy spatial development strategy for the area that is consistent with Update Key Diagram to show each other and as such fail the test the broad location of the SUE of deliverability outlined in to be determined in paragraph 4.45 of PPS12 which collaboration with requires local authorities to align Bromsgrove District Council. development plans with other relevant plans and strategies relating to adjoining areas.
165 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 104/033b Considers that the existing See response to respondent Re-draft cross-boundary Boundary approach does not provide strong No. 002/068. elements of the Core Strategy direction and requires additional work to resolve inconsistencies Update Key Diagram to show and incompatibility. the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/035 Support for North West Redditch See response to respondent Re-draft cross-boundary Boundary SUE in particular with reference to No. 002/068. elements of the Core Strategy the potential for higher housing implications following the Update Key Diagram to show examination of the RSS. the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/040 Support for North West Redditch See response to respondent Re-draft cross-boundary Boundary SUE. No. 002/068. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/041 Sets out detailed support for the See response to respondent Re-draft cross-boundary
166 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Boundary North West Redditch SUE, No. 002/068. elements of the Core Strategy including the suitability of the 3 parcels of land at Brockhill East, Update Key Diagram to show Brockhill West and Brockhill North. the broad location of the SUE Outlines the merits of the site in to be determined in terms of landscape and green collaboration with infrastructure, ecology, drainage Bromsgrove District Council. and flood risk, transport and accessibility, retail, health, education and employment opportunities. Identifies both the availability and deliverability of the site. Cross 104/042 Criticises the Council’s disregard See response to respondent Re-draft cross-boundary Boundary for proposals at North West No. 002/068. elements of the Core Strategy Redditch made by RPS and the Council’s incomplete approach to Update Key Diagram to show assessing the alternative options the broad location of the SUE for providing the levels of growth to be determined in indicated in the RSS. collaboration with Bromsgrove District Council. Cross 104/045 Supports Redditch Council’s See response to respondent Re-draft cross-boundary Boundary decision for Bromsgrove Council to No. 002/068. The residential elements of the Core Strategy identify the exact location of the requirements for the Borough sites to deliver growth adjacent to as set by the WMRSS will be Update Key Diagram to show
167 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Redditch, but recommends greater reflected in the Redditch Core the broad location of the SUE consistency between the two Core Strategy. to be determined in Strategies. Suggests that without a collaboration with clear strategy compatible with Bromsgrove District Council. Bromsgrove, Redditch Borough Council cannot demonstrate a clear housing delivery trajectory for the full plan period. In order to be sound, the Core Strategy for Redditch must ensure that its own regional requirements are accommodated. Cross 104/047 Proposes that Redditch must See response to respondent Re-draft cross-boundary Boundary identify the location for growth in No. 002/068. elements of the Core Strategy co-operation with Bromsgrove. This should be done as a strategic Update Key Diagram to show site that enables the Council to the broad location of the SUE deliver its own requirement to be determined in through a phased approach to the collaboration with urban extension to the North West Bromsgrove District Council. of the town. Cross 104/049 Suggests that should the Council The site referred to as the Hold a joint consultation Boundary continue with its current approach North West SUE was period with Bromsgrove to cross-boundary growth, RPS will considered by WYG, and also District Council on the be able to demonstrate that throughout the Core Strategy potential locations for cross-
168 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. proposals for the North West SUE process. Consultation on boundary development. have been overlooked within the development options in and WYG Phase 2 Report, Redditch around Redditch will be Re-draft cross-boundary SHLAA, Redditch Core Strategy undertaken. In determining the elements of the Core Strategy SA Report and equivalent locations for development, all Bromsgrove documents. evidence will be considered to Update Key Diagram to show Furthermore the proposals have justify that choice. the broad location of the SUE not been subject to public to be determined in consultation nor have been collaboration with considered within the Strategic Bromsgrove District Council. Flood Risk Assessment or Water Cycle Survey. Suggests that the North West SUE proposal be reconsidered. Cross 104/053 Argues that the Council has not See response to respondent Re-draft cross-boundary Boundary undertaken a robust assessment No. 002/068. elements of the Core of the land that currently forms Strategy. Green Belt to determine whether it can provide sustainable solutions Update Key Diagram to show to the delivery of housing and the broad location of the SUE suggests there are viable options to be determined in for growth to the North West of collaboration with Redditch. Suggests that the Bromsgrove District Council. Council should rely neither on the WYG report nor the Redditch
169 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Green Belt document, but rather should undertake a review of the Green Belt and determine the most appropriate locations for development adjacent to Redditch. Identifies the Council’s own evidence in the WYG report as favouring growth into Bromsgrove and suggests that the North West SUE would facilitate the Green Belt role of checking the unrestricted sprawl of large built-up areas. Suggests that the North West SUE would not only prevent neighbouring towns merging into one another as required for Green Belt land, but would enhance the area of urban fringe to protect existing surrounding settlements from encroachment. In contrast, it is suggested that the preferred option of Bordesley Park would undermine the role of the Green Belt. Identifies the North West SUE as fulfilling the role of safeguarding the countryside from
170 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. encroachment. The site forms a sensitive, logical and well- integrated expansion of the existing urban area and provides a significant amount of green infrastructure. Suggests that development to the North West of Redditch would not only preserve but enhance the setting and special character of Redditch as a new town, whilst development at Bordesley would not provide such opportunities given its detachment from the existing urban area. Argues that development at the North West of Redditch would assist in urban regeneration, whilst development at Bordesley Park would not, given the need to provide housing outside of the administrative boundary of Redditch. Cross 104/056 Suggests that the provision of new There are no perceived No change. Boundary retail facilities within a North West constraints to the provision of extension of Redditch would new retail facilities in the form
171 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. contribute to creating a sustainable of a new District Centre at the development adjacent to the site known as the North West existing urban area, whereas the SUE or Bordesley Park. proposals at Bordesley would not address the issues identified in the Council’s Retail Needs Assessment. Cross 104/058 Support for North West Redditch See response to respondent Re-draft cross-boundary Boundary SUE with regard to its potential as No. 002/068. elements of the Core a high quality, safe environment Strategy. integrated into the existing urban environment. Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/061 Details surface water drainage Further detail on flood Re-draft cross-boundary Boundary issues and flood risk of Brockhill mitigation measures would elements of the Core East, Brockhill West and Brockhill need to be investigated prior to Strategy. North, with measures for dealing any SUE allocation. with drainage successfully at each site. Concludes that in contrast to the WYG report which identifies foul water drainage as a potential issue with the North West SUE,
172 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. RPS finds neither foul water issues for the area nor any significant issues of water drainage that cannot be resolved through normal measures. Adds that discussions with Severn Trent Water have identified a sewer capacity issue but have offered a range of solutions. Furthermore it has been identified by Severn Trent that whilst flooding issues can be resolved at the SUE, the preferred option of Bordesley will not facilitate such flood alleviation. Cross 104/062 Outlines support from FCPR and See response to respondent Re-draft cross-boundary Boundary Worcestershire Wildlife Trust for No. 002/068. elements of the Core development relating to the Strategy. Brockhill area in terms of landscape, ecology and green Update Key Diagram to show infrastructure. the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 104/063 Promotes the North West Redditch See response to respondent Re-draft cross-boundary Boundary SUE in terms of its ability to deliver No. 002/068. elements of the Core
173 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. necessary employment land at Strategy. different locations adjacent to existing employment sites and Update Key Diagram to show transport links and at different the broad location of the SUE stages. The opportunity to provide to be determined in employment uses and new collaboration with housing will create a sustainable Bromsgrove District Council. urban extension and will assist Redditch and Bromsgrove in delivering cross-boundary strategic employment requirements. Cross 104/067 Objects to the Key Diagram as it This comment conflicts with the Re-draft cross-boundary Boundary seeks to determine a location for respondents other requests for elements of the Core growth outside of the Council’s Redditch Borough Council to Strategy. administrative boundary, which determine a SUE boundary at neither aligns with the proposals the area known as North West Update Key Diagram to show for Bromsgrove nor offers the most Redditch outside the Borough the broad location of the SUE sustainable option. boundary. The site boundaries to be determined in and details regarding access of collaboration with any SUE were not determined Bromsgrove District Council. at the time of publishing the PDCS. Broad locations will be determined following further consultation. Cross 107/168; David Opposes new housing in See response to respondent Re-draft cross-boundary
174 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Boundary Rose Webheath (ADR) and rather No. 002/068. elements of the Core Strategy supports building at the Bordesley Park site. Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 107/231; David Future housing should be See response to respondent Re-draft cross-boundary Boundary Rose developed at Bordesley Park - this No. 002/068. elements of the Core will open up access to Abbey Strategy. Stadium for much needed development. It is closer to the Update Key Diagram to show M42 and road systems and is the broad location of the SUE more sustainable (Page 8, Second to be determined in Stage Report). collaboration with Bromsgrove District Council. Cross 108/170 Argues that to build on Green Belt The opportunities for any No change. Boundary is a disgrace and asks whether potential development within there are not sufficient brownfield the Redditch urban area, on sites in Redditch to cover the brownfield and greenfield site required housing allocations. have been exhausted. The SHLAA details the sites with potential. From the Scoping Report stage it was clear that the amount of Brownfield sites
175 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. available to the Council would be limited. Cross 111/175; Mr Refers to the designation of open The opportunities for any No change. Boundary Hemming space when constructing the new potential development within town areas of Winyates, the Redditch urban area, on Matchborough, Woodrow and brownfield and greenfield site Church Hill leading to excessive have been exhausted. The infill of west areas to make up SHLAA details the sites with target shortfall. This development potential. It is not appropriate to in gardens and creation of mini- redesignate open space as estates overloaded infrastructure brownfield land. and destroyed existing communities. Believes new development should take place by infilling open spaces in the under- populated new town areas and designating these areas as brownfield sites for developers to focus on before any extension to the boundaries. Cross 112/177 Opposes encroachment on the The opportunities for any No change. Boundary Green Belt. potential development within the Redditch urban area, on brownfield and greenfield sites have been exhausted. The
176 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. SHLAA details the sites with potential. Cross 115/180 Agrees with the majority of the See response to respondent Re-draft cross-boundary Boundary Core Strategy with the exception of No. 002/068. Bordesley Bypass elements of the Core Strategy the possibility of building on land is likely to be an essential adjacent to Dagnell End Lane at infrastructure addition to be Update Key Diagram to show Bordesley, unless this refers to the required associated with any the broad location of the SUE Bordesley by-pass which has SUE to the north of Redditch. to be determined in previously been overlooked. collaboration with Bromsgrove District Council.
Update Key Diagram/Proposals to display intended location of Bordesley Bypass Cross 117/183 Supports housing development at See response to respondent Re-draft cross-boundary Boundary Bordesley Park. No. 002/068. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 118/186 Supports housing development at See response to respondent Re-draft cross-boundary Boundary Bordesley Park. No. 002/068. elements of the Core Strategy
177 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No.
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 119/188 Expresses support for Bordesley See response to respondent Re-draft cross-boundary Boundary Park as the most suitable site for No. 002/068. elements of the Core Strategy future housing development, citing existing infrastructure, proximity to Update Key Diagram to show schools, expanding supermarket, the broad location of the SUE recreational facilities and links to to be determined in M42 as justification. collaboration with Bromsgrove District Council. Cross 120/190 Expresses concern for the The need to develop in No change. Boundary proposed growth of the Stratford- neighbouring Districts is on-Avon and Bromsgrove districts determined by the WMRSS. situated by the green belt Environmental concerns will be boundary for Redditch Borough taken into account when because of the need to protect this determining the broad locations land for environmental and for cross boundary growth. conservational purposes. Believes preservation of land is equally as important as the growth and development of housing and
178 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. employment in the Borough. Cross 121/191; Mr Supports the Core Strategy’s plans Agreed. This is also a No change. Boundary Barber for future housing development consideration in the SA of all which satisfies the requirement major and strategic that development should be development sites. located on existing A-roads and motorways to reduce any impact on the local community. Cross 122/193; R Best Suggests the opportunity for cross- See response to respondent Re-draft cross-boundary Boundary c/o Mr and Mrs boundary growth to the northwest No. 002/068. elements of the Core Strategy Tolley of Redditch, as promoted by RPS. Landowners of the area that wraps Update Key Diagram to show around Brockhill wood offer their the broad location of the SUE support for development in the to be determined in area highlighting the area’s collaboration with potential for housing, a link road Bromsgrove District Council. between the A448 and A441 and green buffers. It is disappointing that the Re-draft cross-boundary Oppose the preferred directions for respondent has not recognised elements of the Core Strategy growth, namely to the north of the Borough Council's efforts to Redditch – Bordesley Park – as consult as extensively as Update Key Diagram to show proposed in the White Young possible on its background the broad location of the SUE Green Report. This report is papers and evidence base in to be determined in considered to be flawed in three addition to its formal Core collaboration with
179 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. respects. Firstly, the first stage Strategy drafts. As a Bromsgrove District Council. study which fed into the final background document, the document was not available for Borough Council has no consultation and therefore is requirement to consult but has deemed to have unreliable done so wherever practical. In conclusions. Secondly, the study addition, the actions taken as a fails to recognise the proposal by result of the outcomes of WYG RPS for the site at Northwest reports have always been Redditch. Finally, the study subject to consultation in line demonstrates an inconsistency of with the SCI. See response to approach between the preferred respondent No. 002/068. Bordesley Park site and other areas, particularly in application of No change. Green Belt policy. The WYG report as a background paper has never Whilst the Core Strategy insists on been intended to be a DPD in the requirement for Redditch- its own right and is not related growth across the therefore subject to 'tests of administrative boundary, the WYG soundness'. The Core Strategy report is considered to fall short on will rely upon an extensive tests of soundness. The Northwest evidence base justifying the Redditch proposal offers a suitable preferred option. and deliverable option for housing development and should be considered for allocation.
180 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 123/195; Believes the Spatial Strategy Agreed. No change. Boundary Warwickshire Examination in Public is the correct County Council forum for establishing the distribution of development beyond Redditch’s boundaries.
Maintains that instead of the 50/50 See response to respondent Re-draft cross-boundary split for growth between No. 002/068. elements of the Core Strategy Bromsgrove and Stratford-on-Avon districts, designation of Update Key Diagram to show development outside of the the broad location of the SUE borough should be based on to be determined in sustainability principles, notably collaboration with transport and accessibility. Any Bromsgrove District Council. development to the east and southeast of Redditch will result in increased car-based trips through or around the urban area and would place additional pressure on the A435 through King’s Coughton, Studley and Mappleborough Green. From a transport perspective therefore, development to the north of Redditch is preferred particularly given it proximity to the train
181 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. station and town centre. Similarly, if car journeys are made from the north of Redditch towards the conurbation they will have a much reduced impact on the urban area given their location on the A441 and A435. Cross 123/233; The Preferred Strategy takes into See response to respondent Re-draft cross-boundary Boundary Warwickshire account the conclusions of the No. 002/068. elements of the Core Strategy County Council WYG Study and Policy SC1 makes provision for 2243 dwellings which Update Key Diagram to show is 1000 less that the RSS the broad location of the SUE requirements. This has an effect to be determined in on provision of Bromsgrove and collaboration with Stratford which would be required Bromsgrove District Council. to provide higher levels of housing. The supported and more sustainable growth areas are located in Bromsgrove rather than Stratford. Cross 129/202; Clive Strongly opposes any major Further detail on flood No change. Boundary Wilson development occurring at mitigation measures would Bordesley Park. Suggests a need to be investigated prior to number of significant drainage and any broad location being flooding issues affect the Dagnell determined. Infrastructure
182 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Brook and River Arrow which can requirements associated with render the A441 at Bordesley, the the development of a A441 bridge over the River Arrow Redditch/Bromsgrove SUE and Dagnell End Road would contribute towards these impassable. Flooding of properties improvements. already occurs all too frequently. Refers to significant run-off problems affecting Batchley Brook, Red Ditch and Blacksoils. This is due to abnormally high rates of run-off from notionally undeveloped, soft, rural areas, probably due to soil saturation conditions, but the problem has worsened in terms of both frequency and magnitude. Although Batchley Brook is in part protected by a culvert, it has limited effect and requires improvement. Argues that the Borough’s Foul Sewage network is also non-sustainable. Developments remote from the areas concerned are unlikely to be capable of funding an appropriate improvement strategy. Both Priest
183 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Bridge and Spernal sewage treatment works have an increasing number of pumped facilities which are not sustainable and, with the gravity options available, makes their continued use unjustifiable. Cross 132/205 Concern about the housing options Agreed based upon the Re-draft cross-boundary Boundary given to Redditch and the potential Evidence Base. See response elements of the Core Strategy impacts on the green belt area to respondent No. 002/068. between Redditch and Studley. Update Key Diagram to show Wishes to preserve the green belt the broad location of the SUE areas around the village and to to be determined in maintain the land between Studley collaboration with and Redditch in order to prevent Bromsgrove District Council. the urban sprawl of Redditch encroaching any further towards Studley. Agreed. The Borough Council Re-draft cross-boundary Whilst there is no objection to the intends to explore the potential elements of the Core Strategy employment use designated for of the Winyates Green triangle the Winyates Triangle, there is a for a Diversity Park. A need for a traffic strategy to avoid Transport Assessment has placing extra pressure on the A435 been commissioned to consider corridor. the potential access to the site.
184 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Cross 133/209; Suggests that the developments See response to respondent Re-draft cross-boundary Boundary Ceridwen John outlined for the north, and No. 002/068. elements of the Core Strategy secondly the northwest, of the Borough are the most sensible Update Key Diagram to show ideas as they will benefit from the broad location of the SUE better train links into Birmingham to be determined in and preserve the open spaces in collaboration with the south of the Borough. Bromsgrove District Council. Cross 134/213; Mr and Expresses support for See response to respondent Re-draft cross-boundary Boundary Mrs Haigh development at Bordesley Park No. 002/068. elements of the Core Strategy and Foxlydiate as these sites have more suitable access to the Update Key Diagram to show motorway network and local the broad location of the SUE industry. to be determined in collaboration with Bromsgrove District Council. Cross 135/215; Mrs Questions the need for all of the Sites within Redditch should be Re-draft cross-boundary Boundary Smith proposed housing and argues that developed first. A thorough elements of the Core Strategy new development will mean more search for sites as detailed in industrial sites, schools etc which the SHLAA highlights a limited will take over the green spaces capacity within Redditch to and some of the green belt. deliver the houses needed to support the growing population, meaning that development on Green Belt land is inevitable.
185 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. There could also be a small loss of open space in the Borough. Cross 135/216; Mrs Suggests that any thought of There is no suggestion to Re-draft cross-boundary Boundary Smith extending Beoley is totally extend Beoley, although in elements of the Core Strategy abhorrent. Bromsgrove District, both Council's have agreed that this Update Key Diagram to show area is warranted to be the broad location of the excluded from consideration in SUE/to be determined in the further consultation on collaboration with development options. Bromsgrove District Council.
Cross 148/255; E Support building at Bordesley Park See response to respondent Re-draft cross-boundary Boundary Rose for development No. 002/068. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 149/258; S J Support proposals to build on land See response to respondent Re-draft cross-boundary Boundary Rose at Bordesley Park. Site is more No. 002/068. elements of the Core Strategy sustainable and would be an ideal opportunity to develop the road Update Key Diagram to show structure in that area as well as the the broad location of the SUE
186 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. much needed improvement of the to be determined in Abbey Stadium (page 8 of Second collaboration with Stage Report) Bromsgrove District Council. Cross 150/259; Mrs J Support building at Bordesley Park See response to respondent Re-draft cross-boundary Boundary Stowell No. 002/068. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 151/262; V Strongly object to proposed Agree that the sites within No change. Boundary Wilcox changes to green belt boundary. Redditch should be developed There are sites within Redditch's first. A thorough search for boundary that should be re- sites as detailed in the SHLAA developed, for example near the highlights a limited capacity fire station which should provide within Redditch to deliver the approximately 500 dwellings. houses needed to support the growing population, meaning that development on green belt land is inevitable. Cross 152/264; M Bordesley Park is a more suitable See response to respondent Re-draft cross-boundary Boundary Rose location for development No. 002/068. elements of the Core Strategy
Update Key Diagram to show
187 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 153/508; Centro Redditch falls within the West See response to respondent Re-draft cross-boundary Boundary Midlands 'journey to work' area No. 002/068. elements of the Core Strategy and it is important that residents of any new development can have Update Key Diagram to show sustainable access to regional the broad location of the SUE services and wider employment to be determined in and education opportunities. Cross collaboration with boundary issues should be given Bromsgrove District Council. further consideration particularly in regards to Redditch railway and improved rail services. Cross 158/271; H Given the identified need for See response to respondent Re-draft cross-boundary Boundary Bonham further housing development, No. 002/068. elements of the Core Strategy advocates development in the Bordesley Park area which has Update Key Diagram to show good potential links to local trunk the broad location of the SUE roads. to be determined in collaboration with Bromsgrove District Council. Cross 159/272; Mr and Fully support proposals for See response to respondent Re-draft cross-boundary Boundary Mrs Sullivan development at Bordesley Park. No. 002/068. elements of the Core Strategy
188 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. This is because all the required development can be located in one Update Key Diagram to show area which limits disruption for the broad location of the SUE Redditch residents. The to be determined in infrastructure is also currently in collaboration with place to support this development, Bromsgrove District Council. reducing the redevelopment required to accommodate a new housing estate. A housing development in the Bordesley area will be beneficial due to the planned redevelopment of the Abbey Stadium. Cross 160/277; R Green Belt should not be Agree that the sites within No change. Boundary White encroached upon for development. Redditch should be developed Countryside and Wildlife is first. A thorough search for needed. Infilling which has taken sites as detailed in the SHLAA place in Redditch affects quality of highlights a limited capacity life of residents and no more within Redditch to deliver the should be done. Overcrowding houses needed to support the contributes to crime, anti-social growing population, meaning behaviour and neighbour disputes. that development on green belt land is inevitable. Cross 202/335; Tetlow Concerned about any development See response to respondent Re-draft cross-boundary Boundary King c/o of Bordesley Park to meet No. 002/068. elements of the Core Strategy
189 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Bromsgrove Redditch's housing requirement on District Housing green belt land. Note that Redditch Update Key Diagram to show Trust and West Borough Council seeks to deliver the broad location of the SUE Mercia Housing 4,430 dwellings in this location, to be determined in Group which is over 1,000 more than collaboration with envisaged by the RSS. Such an Bromsgrove District Council. allocation is unlikely to make a meaningful contribution to meeting Bromsgrove's acute housing needs. Cross 210/346; MFG Willingness and support for land The housing requirements as Hold a joint consultation Boundary Solicitors c/o allocations at Foxlydiate Woods to set out in the WMRSS will be period with Bromsgrove various meet future housing requirements identified in the Core Strategy. District Council on the landowners for Redditch growth. Areas 1 and 3 Although beneficial, developer potential locations for cross- have received developer interest. interest does not make any boundary development. The land has considerable merit location more preferable than when considering future housing another as a location for future needs. The land abuts existing development. development at Webheath and it is envisaged that there would be no substantial infrastructure problems as it represents a logical extension to an existing built up development in a sustainable location with all available facilities including public
190 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. transport. Cross 261/404; Land at Foxlydiate Woods - The housing requirements as Hold a joint consultation Boundary Thomas Guise landowners willing to submit their set out in the forthcoming period with Bromsgrove Ltd c/o various respective parcels of land for WMRSS will be identified in the District Council on the landowners consideration for residential Core Strategy. potential locations for cross- development in areas 1 and 3. boundary development.
Cross 262/412; HCA A coordinated approach to cross See response to respondent Hold a joint consultation Boundary boundary issues has not been No. 002/068. period with Bromsgrove arranged between local planning District Council on the authorities involved. Two (Redditch potential locations for cross- & Stratford) appear to be pursuing boundary development. a broadly similar strategy, but it is not clear that Bromsgrove Council Re-draft cross-boundary also support the strategy. elements of the Core Strategy
Update Key Diagram to show the broad location of the SUE to be determined in collaboration with Bromsgrove District Council. Cross 262/414; HCA An urban extension at Bordesley It is envisaged that the No change Boundary Park would require construction of Bordesley Bypass would be an the Bordesley Bypass and there is essential part of infrastructure no certainty over whether funding provision to the north of the
191 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. will be available or when Borough associated with any construction will begin. The SUE; therefore work will infrastructure required to support continue to ensure its delivery. the urban extension would have to be built from scratch. Cross 262/415; HCA Agrees that greenfield and The WMRSS Phase Two Re-draft cross-boundary Boundary brownfield land in Redditch in the revision Panel Report has phasing elements of the Core SHLAA could deliver units quickly. indicated that there may be Strategy in conjunction with There is risk that there will be a issues with the lead times for Bromsgrove District Council. shortfall in the provision of new bringing forward large sites, housing when supply from urban therefore phasing will need to sites in Redditch begins to dry up be carefully considered and before the proposed new between the two Districts. settlement at Bordesley Park delivers units Cross 267/575; Barton WYG Report fundamentally flawed Landscape character was given No change. Boundary Wilmore c/o in that it has not assessed the further consideration in the final ADR site within Redditch nor has it revisions to the WYG undertaken a comprehensive conclusions. review of the Green Belt around Redditch. The report is not supported by robust landscape and visual evidence and caution should be exercised when using it.
192
Delivery Strategy
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Delivery 049/762 1. Bordesley By-pass would 1. Noted 1. None Strategy (WCC) need to be reviewed in the light of emerging WMRSS.
If funding were available, the proposal would need to be supported by a technically robust business case that would have to be
resourced, scheduled and managed by WCC and include identifying costs, benefits and funding. It would also need to meet
local, regional and national policies
2. Officers understand that the 2. None 2. Query what role was new Landscape Character foreseen for WCC in webtool at WCC enables the addressing the indicator WCC landscape officers to BE.3 (Landscape track the use of the webtool Character). WCC does not with reference to planning
193 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. collect data on the application numbers. It is percentage of planning anticipated that RBC officers permissions that would will request usage information comply with RBCs from WCC landscape officers landscape policy and supplement this with additional information from RBC DC officers
3. It would be useful to see the 3. RBC officers have relied on Delivery 049/762 HER for input into SHLAA site 3. Include HER reference when Strategy (WCC) existing relationship of the Delivery Strategy is updated County Historic information. The SHLAA is Environment Service to updated annually and it is RBC more strongly anticipated that involvement expressed within the from HER will continue. Due to the restructuring of the CS Delivery Strategy. This would encourage greater layout, the Delivery Strategy recognition and use of its will be re-worked prior to expertise. It is important to submission. Reference to HER maintain timely consultation could be included at this stage and advice on historic environmental issues as these may include a requirement for evaluation which can delay determination
194 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Delivery 088/560 1. SP.3 – Sustainability 1. Officers will investigate the 1. Investigate the relevance of Strategy (Natural Principles: West Midlands relevance of the West Midlands the West Midlands England) Sustainability Checklist Sustainability Checklist to Sustainability Checklist to could be used as a basis for locally distinctive monitoring locally distinctive monitoring
monitoring policy indicators indicators compliance
2. BE.1 – Climate Change: Number of developments 2. Officers will investigate the 2. Investigate the possibility/ meeting BREEAM possibility/ accuracy of accuracy of monitoring standards should be monitoring BREEAM standards BREEAM standards
monitored
3. BE.2 – Flood Risk: 3. Noted. This information is 3. Consider incorporating an Incorporate an indicator for readily available and could be indicator for the number of the number of applications recorded easily applications granted against granted against the advice the advice of the Environment of the Environment Agency Agency
4. H.2 – Primarily Open Space: Monitor permissions 4. Compliance with open space which deliver open space in 4. Investigate the possibility/ accordance with specific standards forms part of the accuracy of incorporating standards. Delivery of monitoring process monitoring green infrastructure
green infrastructure should provision through the Green 088/560 be monitored Infrastructure Study Delivery (Natural Strategy A Green Infrastructure Study England) will be completed by Officers,
195 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the study will consider what Green Infrastructure is needed within the Borough and how the delivery of Green Infrastructure can be monitored Policy SC.7 - 089/519 1. Support this policy as it 1. Noted 1. None Infrastructure (Theatres states that the key Trust) infrastructure requirements for development will encompass the CS Objectives and assume that cultural facilities will be included 2. Although would not expect a long list of items, policy should be clear with respect to the relevant topics and 2. Noted. It may be appropriate 2. Consider description of suggest an overarching to describe the likely infrastructure provision in description of topics is used infrastructure provision in the Delivery Strategy pre-amble instead of a long list e.g. pre-amble to the Delivery “infrastructure that provides Strategy for the health, welfare, social, educational, leisure and cultural needs of the community”. This would ensure all topics were included
196 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Delivery 093/504 1. For SP.3 – Sustainability 1. Officers consider that it is 1. Confirm with Waste Strategy (Environment Principles, an example possible to include these Management that this Agency) indicator could be the additional indicators provided information is capable of being percentage of waste fully that the Council’s Waste Team monitored and add to Delivery recovered rather than are able to collect this Strategy landfilled or sent through information Civic Amenity sites. This
could be further sub-divided e.g how waste has been put to use, energy generation, reprocessing into finished products
2. BE.2 – Flood Risk could
include additional indicators for, number of planning permissions granted contrary to the advice of the EA on flood risk grounds; Number of additional and/or 2. Noted. Officers will consider inclusion of these indicators 2. Consider inclusion of percentage of all new devt suggested indicators in with SuDS Delivery Strategy 3. BE.2 – Flood Risk, the Sequential Test should be added to the third indicator i.e. ... unless complying with the sequential test and exception test (where required)
3. Noted. Officers will consider 3. Include this text in the inclusion of this text in the indicator indicator 197 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Delivery 102/155 4. It would be useful to see the 4. RBC officers have relied on 4. Include HER reference when Strategy (Worcestershir existing relationship of the HER for input into SHLAA site Delivery Strategy is updated e Archaeology County Historic information. The SHLAA is Unit) Environment Service to updated annually and it is RBC more strongly anticipated that involvement expressed within the from HER will continue. Due to Delivery Strategy. This the restructuring of the CS would encourage greater layout, the Delivery Strategy recognition and use of its will be re-worked prior to expertise. It is important to submission. Reference to HER maintain timely consultation could be included at this stage and advice on historic environmental issues as these may included a requirement for evaluation which can delay determination WYG2 104/012 (RPS) 1. Report does not provide 1. Officers consider that WYG1 1. Officers to consider detailed information on the assessed areas in and around capacities available within the likely impacts of Redditch for their suitability for ADRs and Green Belt to meet development and its long term development the revised RSS target of suitability. Only provides contributions towards Redditch around 4000 dwellings up to broad brush, unqualified related growth. The WYG2 2026 and undertake a further statements on each of the study was considered by the consultation period locations appraised. In RSS Panel of Inspectors, who some instances, only 3-4 concluded that there were no paragraphs are provided to good reasons to overturn the deal with the topics
198 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. (outlined by RPS, pg.24) ADR findings in WYG1. and in most cases do not have any regard to the issues required. Many The EiP Panel identified all comments also relate to out those localities where it of date procedures or considered that a Green Belt references alteration was required or may be an appropriate response to seeking the most sustainable development patterns. Paragraph 4.18 states that once sites have been released from the Green Belt, the principle of their development has been established and it is unnecessary to test their sustainability further. This is reflected in Recommendation R8.2.
Delivery 104/036 (RPS) 2. There are no clear 2 & 3. WYG1 Study concluded 2 & 3. Officers to consider Strategy arrangements for managing that whilst planning up to its capacities available within the the CS. There is no clear boundaries only, the ADRs ADRs to meet the revised RSS
deliverable housing offered suitable locations for target of around 4000 dwellings trajectory within the CS or development. However, the up to 2026 and undertake a evidence base that can WYG2 Study concluded that further consultation period demonstrate the current land beyond the Borough
199 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. approaches are deliverable Boundary offered more sustainable locations for 3. There is a requirement for development than the three core strategies to be flexible ADRs. and to demonstrate how they can accommodate changing circumstances. The CS cannot The WYG2 study was demonstrate this at the considered by the RSS Panel moment of Inspectors, who concluded Update Key Diagram to show that there were no good the broad location of the SUE reasons to overturn the ADR boundary to be determined in findings in WYG1 collaboration with Bromsgrove District Council
Further SHLAA work, in collaboration with the SHLAA Update housing trajectory and Working Partnership, will include in Core Strategy gather landowner information on availability of sites which will in turn feed into the housing trajectory
200 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Delivery 104/036 (RPS) Strategy
Delivery 104/037 (RPS) 4. It is not clear how the 4. Officers agree that the level 4. Policy to be revised and to Strategy current and higher levels of of development likely to be form part of the joint housing will be delivered required on land currently consultation with Bromsgrove
from a single proposal. The designated as Green Belt will in February 2010 development and build out need to be phased sooner in rates for such schemes the plan period to enable have not been investigated development to continue to to determine the practicality come forward in a satisfactory
of delivering such sites manner without compromise to development in Redditch’s urban area. This should be addressed through a revision to Policy SP.2
5. Unclear from CS how 5 & 6. See response to housing within the administrative area will be 104/036 above delivered, in particular the urban areas. Strategy must
201 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. establish how it will 5 & 6. See response to accommodate new homes 104/036 above should the urban capacity
not come forward
6. Spatial strategy proposed by RPS will enable the Council to demonstrate flexibility in achieving its housing requirements within its administrative area through use of the Brockhill ADR and Green Belt land at Foxlydiate as part of the lead-in to the SUE north west of Redditch. This is essential in demonstrating a flexible and deliverable supply of housing
Delivery Strategy 104/037 (RPS) Delivery 104/046 (RPS) 7. PPS12, para 4.8 states that 7. Limited information was 7. Continued contact with Strategy the Council is required to available at this stage due to infrastructure providers to demonstrate, by way of uncertainties regarding progress Core Strategy
evidence, what physical, locations for development, infrastructure delivery social and green however officers continue to
202 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. infrastructure is needed to meet with infrastructure enable the amount of providers to progress Core development proposed for Strategy delivery an area, taking account of its type and distribution. The current approach for the extension of Redditch includes no reference to any infrastructure requirements associated with such a significant element of its strategy and is therefore unsound
203 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Delivery 217/358 Page 119 refers to the Noted The additional text suggested Strategy (Network Rail) Redditch Branch by Network Rail to be included (SC.4 – enhancements. Would like to in Delivery Strategy table Sustainable see the following added to the where appropriate Travel and table: Accessibility, Principle 1. Add Network Rail to ‘Lead means of & Key Partners’ column as Implementati Network Rail is leading the on 4, p.119) development phase and currently funding the entire project 2. Alter ‘Timescale’ from ‘ongoing’ to “Completion is scheduled before the end of Control Period 4 ‘up to 2014’ “ 3. In ‘Target’ column, the percentage is 5%, as GRIP 2 is nearly complete (Guide to Railway Investment Projects)
204 Design and Safety
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. CS. 1 021/ 079 Policy CS.1 generally accords Comment noted. None. with the relevant parts of emerging WMRSS policies SR1, SR2 and SR3. CS. 1 028/ 105 Support approach of Policy. Support noted. None. CS. 1 029/ 706 Support Policy. Support noted. None. CS. 1 042/ 469 Clause (i) Do not consider it is the role of It is considered that new None. policies in the Core Strategy to buildings and developments in enforce the application of the Redditch should aim to be a Building for Life Standards sustainable and as well since it is not mandatory for designed as possible. The developers to obtain a Building Building for Life Standards for Life Award. These cover a range of sustainability standards cannot be enforced, issues and is therefore particularly where they have considered important. Officers not been the subject of within Redditch Borough rigorous testing through the Council are trained to assess RSS procedure and other new developments against this development plan consultation standard and therefore can as to their applicability. apply it to new developments.
The West Midlands Regional None.
205 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Spatial Strategy Phase II Revision Preferred Option contains Policy SR3 ‘Sustainable Design and Construction’ which states that all new housing developments must meet CABE Building for Life ‘silver’ standard and that all medium and large scale developments (greater than 10 residential units) meet the ‘very gold’ standard. CS. 1 091/ 135 Disappointing that the policy The requirement for medium None. does not go any further than and large developments to the provisions of the existing meet Building for Life ‘gold’ Supplementary Planning standards is a new concept. Document ‘Designing for However there is no Community Safety’ (Dec 2006). justification for any addition standards to be achieved, so they cannot reasonably be expected.
The provisions of Policy CS. 1 Noted. Noted. essentially ensure that a development scheme
206 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. incorporates ‘Secured by Design’ principles. However, whilst the inclusion of design measures to reduce the opportunities for crime will assist in delivering sustainable communities, they will not remove all crime and disorder activity. There will remain a key role for the West Mercia Constabulary (WMC). 091/ 137 and New commercial development Achieving the ‘Secured by None. 137b and developments such as Design’ Principles is bars and clubs should referenced in the High Quality incorporate ‘Secured By and Safe Design Policy and is Design’. therefore encouraged as part of new development. Policy CS.1 262/ 410 Support for Policy. Support noted. None. Policy CS.1 085/ 524 Support for Policy. Support noted. None. Policy CS.1 088/ 541 The need for open space to be Noted. It is considered that it is and feel safe is recognised appropriate to consider the within the justification, but not design and integration of open within the policy itself. It is space recommended that the policy includes a requirement for
207 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. proposals to consider the design and integration of open space. Policy CS.1 263/ 437 Welcome this policy, Support noted. None. particularly criterion (iii). 103/164(f) An attractive feature of the This kind of requirement would None. town is the architectural details be more appropriate within a on the fronts of many of the Development Control and Victorian houses, using Policies DPD, it would not be sculptured brickwork. There appropriate for the Core should be a policy preserving Strategy. this feature along with houses of architectural interest.
Development Strategy
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 021/073 Policy generally accords with Discussions with the SHLAA Consider inclusion of the Development (WMRA) emerging WMRSS Policy CF4 Working Partnership concluded approach to windfalls in the Strategy (Phasing of new development) that a windfall allowance Delivery Strategy preamble in but should address the should be excluded from the accordance with
208 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. approach to be taken to first 10 years of the Plan to recommendations in the EiP windfalls in line with CF4D and ensure robustness and Panel Report (September CF10B (Managing housing conformity with PPS3. This will 2009) and SHLAA refresh land supply) be reflected in the April 2010 SHLAA refresh. Only brownfield historic windfall trends will be taken into account to avoid an unrealistic expectation for greenfield development i.e. barn conversions which form part of past trends but which may already have been depleted and should rightly be excluded from future trends analysis Policy SP.2 – 042/468 1. Agree strategic sites should 1 & 3. It should be noted that 1 & 3. Reference Redditch Development (Stoneleigh be regarded as immediately the Redditch CS does not related growth split between Strategy Planning) available. Important in include provisions for the neighbouring authorities relation to the development development of land at of land at Bordesley Bordesley. This site is in the because of the sustainable Bromsgrove DC administrative and necessary contribution area and as such, sites to meet the site will make towards the needs of Redditch related meeting the Borough’s growth will need to be needs addressed in the Bromsgrove CS. Officers continue to work closely with officers from neighbouring authorities and it
209 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. is anticipated that joint consultation with respect to Redditch related growth options will commence February 2010 Policy SP.2 – 042/468 2. Consider it unlikely that Development (Stoneleigh sites within the urban area Strategy Planning) will consistently deliver 330 dwellings per annum 2. PPS3 stresses that LPAs between 2006-2013. should set out a housing implementation strategy to deal Therefore programmed release of important with the managed delivery of housing. Work with relevant greenfield site (i.e. Bordesley) should not be stakeholders has began on this programmed for release in in autumn 2009 2. Work to continue on Implementation Strategy with the second part of the plan period. It will need to key stakeholders from autumn 2009 contribute to the provision of new homes from 2011 onwards
3. Object to wording to the final part of Policy SP.2 and consider that it should be
revised as follows: “Land at Bordesley/Bordesley Park will be developed for 3. Following receipt of the EiP housing and employment Panel Report, the identification throughout the plan period. of Bordesley Park in the WYG 2 Report was regarded as too
210 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. The scale of the inflexible to deliver Redditch development, the range of related growth in Bromsgrove uses and the necessary District and greater flexibility in supporting services and terms of achieving and infrastructure are such that maintaining housing output the development of this could be provided through land will need to commence parallel pursuit of a number of during the early phases of development options. As such, 3. None the plan period to ensure joint consultation between the continuous delivery of Redditch Borough and new homes to meet the Bromsgrove District Councils needs of Redditch over the will take place from February period to 2026” 2010 to explore development options to accommodate its part of the housing target and employment targets.
Policy SP.2 – 042/468 Development (Stoneleigh Strategy Planning) Policy SP.2 – 049/730 1. Policy appears to address 1, 2 & 3. Prior to submission of 1, 2 & 3. Continued work on Development (WCC) the phasing of housing the CS, officers will continue to Delivery Strategy and the CS Strategy development rather than re-structure its format. It is revised format
211 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the development strategy considered that the Delivery Strategy pre-amble will more 2. First paragraph could cross fully address the development refer to the strategic sites issues facing Redditch policies Borough. Policies will be re- 3. Second paragraph could be worded and ‘shuffled’ from current locations in the PDCS amended to make it clear that it applies to non- to new locations under the strategic sites most appropriate sub-strategy. It is considered that this will be an appropriate location to address, et al, phasing, windfalls, delivery rates and
cross references to strategic sites
4. Final section of policy 4. Consider wording of final 4. Noted paragraph in policy should be reworded as appears to be incomplete
5. This would seem to be the 5. See 1 above 5. See 1 above most logical place to include approach to windfalls having regards to
Policy SP.2 – emerging WMRSS Policies Development CF4D and CF10B
Strategy 6. Second paragraph of RJ 6. See 1 above
212 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 049/730 should be clearer as to 6. See 1 above (WCC) what the purpose of an SPD will be. CS provides no guidance as to required rates of delivery and should be rectified 7. With respect to final two 7. Following receipt of the EiP 7. Consider future use of ADRs paragraphs of RJ, it does Panel Report, the Bordesley and other options to meet the not necessarily follow that Park identification in the WYG revised EiP Panel objective d (WMRSS 2 Report was regarded as too recommendation for the Spatial Strategy Objectives) inflexible to deliver Redditch housing target of 4000 allows for the inclusion of related growth in Bromsgrove dwellings within Redditch the ADRs as Green Belt District and greater flexibility in Borough terms of achieving and maintaining housing output could be provided through parallel pursuit of a number of development options. The Panel recommended that land for 4000 dwellings should be identified within the Borough boundary. As such, joint consultation between Redditch Borough and Bromsgrove District Councils will take place early in 2010 to consider development options for Redditch related growth and
213 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the contribution of other sites, including the ADRs within Redditch Borough Policy SP.2 – 088/533 1. Broadly support proposed 1. Officers agree with these 1. Consider revising wording in Development (Natural development hierarchy comments. There are Policy SC.2 to protect Strategy England) provided that brownfield brownfield sites within Redditch brownfield land with land is not of value for which have been scrutinised biodiversity/ open space value biodiversity and/or open and afforded protection from space. Each location should development due to the be judged on its own merits contribution made to the with decisions informed by townscape/landscape in their a robust evidence base. present state. It is anticipated Appropriate policies should that this level of scrutiny and be put in place to ensure protection will continue on a that valuable brownfield site by site basis or through land is protected from SHLAA/ ELR updates. Officers development will give consideration to the inclusion of brownfield protection criteria in Policy SC.2 – Efficient use of land Policy SP.2 – 091/130 WMC consider that the most The Infrastructure Delivery Add the following paragraph to Development (Atisreal) sustainable sites are those Plan will demonstrate costs Policy SP2; Strategy where there is sufficient needed to deliver the funding to deliver the required infrastructure required for the ‘In all cases, the suitability of infrastructure to support the sites. This information will feed sites to be brought forward sites. If there is not then into a future CIL document. for development will be contributions from development tested against the provisions of Policy SC7 –
214 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. are justified as per the tests of Infrastructure to ensure the Circular 05/05. compliance with the objectives of the core WMC suggest that the strategy’ . following extra paragraph be added to Policy SP2 as follows; ‘In all cases, the suitability of sites to be brought forward for development will be tested against the provisions of Policy SC7 – Infrastructure to ensure compliance with the objectives of the core strategy’. Policy SP.2 – 093/489 1. Support policy reference to 1. Strategic sites have been 1. None Development (Environment other policies within the the subject of additional Strategy Agency) plan such as infrastructure, scrutiny through mechanisms flood risk and contaminated such as the SHLAA, WCS and land. However, would place SFRA. Any obstructions to their emphasis on the need for successful development in a the timing and phasing of timely manner would have sites for development to been identified and included in have been informed by strategic site policy flood risk and
environmental infrastructure requirements (WCS & SFRA will provide evidence for this)
215 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 2. Where contaminated land 2. This has been addressed in 2. None may be an issue, this Policy SP.3 of the PDCS should be addressed at an
early stage as there may be negative effects for the environment. Also, there may also be time and financial implications on any
regeneration project. This approach is essential to ensure the protection of controlled waters (Surface and groundwaters) Policy SP.2 – 093/489 3. Note that policy favours 3. This issues has been 3. None Development (Environment development of brownfield addressed in Policy SP.3 of the Strategy Agency) sites over greenfield sites. DPCS Suggest that reference is made in the policy for the need to consider the SFRA & WCS which will inform the siting as well as the phasing of sustainable development
216 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 202/330 1. Object to policy. Rigid 1. PPS3 stresses that LPAs 1. Work to commence on Development (Tetlow King) phasing policy fails to take should set out a housing Implementation Strategy with Strategy into account the current implementation strategy to deal key stakeholders autumn 2009. economic circumstances with the managed delivery of Consider revision to policy
and the difficulty of bringing housing. Work with relevant wording in para 2 forward sites in a strictly stakeholders will begin on this phased manner. The use of in autumn 2009. ‘Must’ may be the word ‘must’ in the inappropriate is this context second paragraph is
inappropriate as it is not within the Council’s control to enforce the order in which sites come forward. That this is the case is
obvious from the lack of explanation as to how this could practically be achieved
2. Consider it appropriate for 2. Policy SP.2 details the broad 2. Consider policy reference in policy to include third and phasing order and further SC.3 to sites for 100% forth categories of reference to 100% affordable affordable housing coming development namely housing and rural exception forward in advance of the allocated sites for 100% schemes is not considered settlement phasing in Policy affordable housing and the appropriate in this policy. Rural SP.2 rural exception schemes exception sites are dealt with in
permitted under Policy BE.7 Policy BE.7. Affordable (Exceptions Housing at housing is dealt with in Policy Astwood Bank and SC.3, however further Feckenham) reference to sites for 100% affordable housing could be
considered for inclusion in Policy SC.3 217
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 202/330 3. Second and third 3. Officers recognise that the 3. Consider wording of Policy Development (Tetlow King) paragraphs should be level of development likely to SP.2 to allow for development Strategy reworded to allow for the be required on land currently to come forward on sites timely release of land for designated as Green Belt will currently designated as Green affordable housing need to be phased sooner in Belt in a manner which will not development to come the plan period to enable be to the detriment of forward in Green Belt development to continue to development in the urban area locations. Only permits come forward in a satisfactory on brownfield and greenfield such development on manner without compromise to sites exceptional basis once development in Redditch’s other sites have been urban area. This should be exhausted. This is overly addressed through a revision restrictive; the proposed to Policy SP.2 approach would not be effective in tackling housing needs as required by Strategic Objective 9 (To have sufficient homes meeting demographic needs, including affordable housing, providing for a range, mix and type in the best locations, including on strategic sites)
218 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 262/406 (HCA) 1. Broadly supports the policy 1 & 2. It is evidenced in 1 & 2. See 049/730 above Development as it seeks to promote previous planning Strategy sustainable patterns of documentation relating to the development. Suggest that Borough of Redditch Local Update Key Diagram to show policy is changed to include Plans 2 & 3 that the three the broad location of the SUE field land, but not green belt ADRs had potential for boundary to be determined in land, adjacent to Redditch development. It should be collaboration with Bromsgrove urban area as a potentially noted that during previous plan District Council suitable alternative to preparation, officers were brownfield and greenfield restricted to searching for land within a defined appropriate and suitable land settlement for development within the Borough’s administrative boundary only. The three 2. Greenfield land outside the ADRs offered the most urban area of Redditch appropriate locations for should be preferable to development at that time. Green Belt land outside the Changes to the planning urban area system have allowed for cross- boundary investigation for sustainable locations for Redditch related development. WYG1 dismissed Redditch’s rural south west as unsuitable for development and WYG2 concluded that land beyond the Borough Boundary offered more sustainable locations for development than the three ADRs.
219
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 262/406 (HCA) Following receipt of the EiP Development Panel Report, the Bordesley Strategy Park identification in the WYG 2 Report was regarded as too inflexible to deliver Redditch related growth in Bromsgrove District and greater flexibility in terms of achieving and maintaining housing output could be provided through parallel pursuit of a number of development options. The Panel recommended that land for 4000 dwellings should be identified within the Borough boundary. As such, joint consultation between Redditch Borough and Bromsgrove District Councils will take place early in 2010 to consider development options for Redditch related growth and the contribution of other sites, including the ADRs within Redditch Borough
220 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Development 263/434 1. The preferred direction for 1. Officers consider that it is 1. Continue to work closely Strategy (English future growth as shown on inappropriate to include more with neighbouring LAs on Heritage) the key diagram should be detail on development beyond matters relating to Redditch more clearly highlighted in its administrative boundary in related growth beyond the this section the CS. Officers will continue to Borough boundary work closely with neighbouring LAs to ensure correct and adequate reference is made in their Core Strategies to reflect the RSS with respect to Redditch related growth
2. Based on the information 2. None presented, principally the 2. Benefits for surrounding Study of the Future Growth environmental resources would Implications of Redditch, be secured through S106 main comment with respect and/or CIL policy. The to the Bordesley Park Development Strategy does proposal is the need to link not need to address this issue any major development here to securing benefits for the surrounding environmental resources including Bordesley Abbey SAM which In turn will contribute to the Borough’s green infrastructure and recreational and cultural infrastructure
221 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 264/445 1. Support the promotion of 1. Noted 1. None Development (CBRE) the most sustainable sites Strategy and the request for those sites to be developed earlier in the CS period 2. On receipt of the EiP Panel 2. Consult on revised policy 2. Consider that criterion i Report, the Panel wording early 2010 should be amended to refer recommended that land for to brownfield sites within 4000 dwellings should be the ‘urban area’ [as identified within the Borough opposed to brownfield sites boundary. As such, within a defined settlement] contribution of other sites, including the ADRs and Green Belt land within Redditch Borough need to be considered to meet the housing target. Consequently, the wording of this policy will need to be revised to reflect the timely contribution of these sites
3. With respect to the findings 3. None 3. Suggest that policy includes of the ‘Accessibility Study and the requirement for new Settlement Hierarchy’, officers development to be consider that the ‘defined focussed in accessible and settlements’ referred to in the sustainable locations policy offer the most focussed
222 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and sustainable locations for development
223 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 267/574 1. Development Strategy 1, 2, 4, 5, 6 & 7. See 262/406 1, 2, 4, 5, 6 & 7. See 049/730 Development (Barton proposes delivery of only above above Strategy & Willmore) 2243 dwellings within Policy SC.1 – Redditch which is 1057
Housing short of the emerging Update Key Diagram to show Provision requirement for the the broad location of the SUE Borough boundary to be determined in
2. 2006 base projections collaboration with Bromsgrove increases the requirement District Council for dwellings in Redditch to
8000. As a former New Town, Redditch should continue to fulfil such a function in the North Worcestershire area and as
merited by its proposed status as SSD in the emerging WMRSS 3. None 3. Development and 3. Officers consider that the CS investment should be does indeed direct directed towards the town development and investment towards the town 4. An increase in the number of dwellings to be provided within the Borough will ensure Redditch can meet
its own local housing needs
224
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.2 – 267/574 5. Strategy is flawed and Development (Barton unsound. Strategy requires Strategy & Willmore) the agreement of the Policy SC.1 – adjoining authority Housing Provision 6. There are no significant environmental or physical constraints to the achievement of the WMRSS Preferred option figure of 3300 dwellings Redditch
7. Disagree with the conclusions of WYG2 on the suitability of using safeguarded land to meet this target to be delivered within 8. Noted 8. Policy rewording to be 8. Inconsistency of policy considered wording. First line of policy states that Strategic Sites can come forward immediately. Second sentence makes reference to a phasing proposal under which brownfield sites come forward before greenfield sites. As the phasing
225 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. element refers to proposals for residential development, which would include some Strategic Sites, further clarification is required within the policy to determine whether Strategic residential sites can come forward immediately or whether they are restricted by phasing
Enterprise and Skills
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy ES.2 024/111 Support for Employment in the Noted. No action required. Town Centre. Policy ES.2 103/163 The 50,000 sq. m gross The WMRSS requires Redditch No action required. and Policy comparison floor space Borough Council to plan for the ES.6 detailed in Policy ES.6 should construction of 45, 000 sq.m of take precedence over the 45, new office floor space within or
226 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 000 sq.m floor space detailed on the edge of the town centre. in Policy ES.2. In addition, Redditch Borough Council is also required to plan for the construction of 50, 000 sq.m of retail floorspace within the town centre. The draft Office Needs Assessment determines that the 45, 000 sq.m is not appropriate and a 30, 000 sq.m figure would be more appropriate. However both of these land use requirements need to be planned for. Policies ES.6 and ES.2 of the Preferred Draft Core Strategy incorporated the retail and revised office figures. The Council currently has no evidence to justify any preference for which of the figures should be prioritised.
In order to accommodate the Officers of the Council in The draft study proposes a Office requirement 10 new association with appointed revised office requirement of Town Halls would be needed, planning consultants have 30, 000 sq m, of which the therefore “does the policy imply carried out a draft Office Needs town centre can accommodate
227 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the raising of these Assessment to identify 22, 000 sq. m; consequently communities to the ground?” appropriate locations for new the policy will need to reflect office development in, or on the the findings of this study. edge of, the town centre. The Extract from revised Core policy is not intended to raise Strategy policy: “ Based on a the community to the ground, local assessment, the Council rather it is hoped that the policy aims to deliver 30, 000 sq.m of will enhance and develop the office development for the town community as a place to live centre”. and work.
If half of the office workers In terms of specific car parking No change to policy. came by bus and the other half requirements for Offices, these by car this would mean that are as follows: there would need to be • For developments of up development to the equivalent to 2500 sq.m. GFA – 1 of car parks 1, 2 and 3. space per 25 sq.m. GFA. • For development over 2500 sq.m. GFA – 1 space per 30 sq.m. GFA. There are additional car parking requirements for disabled, cycle, motorcycle and
228 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. lorry/coach parking (if necessary), however these are considered to be minimal in the context of the total car parking (these requirements can be supplied upon request).The purpose of locating development within the town centre is because it is considered sustainable due to the variety of modes of transport that access the town centre e.g. buses, trains etc. As a consequence of its accessibility, transport links and the car parking requirements outlined above, there would be no need for such intensive car parking to cater for any new office development.
[Office] Employers do not want This representation does not No change to policy to be located in the Town provide any evidence that this Centre, due to high rates and is the case. The draft Office high rents. There would be an Needs Assessment does not
229 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. impact on local shops due to identify that office employers the increased number of Office do not want to locate in the workers moving through the town centre. In addition to this Town Centre who may jostle the draft Office Needs the shoppers. Assessment and Town Centre Strategy do not provide any indication that an increase in offices would result in shoppers being jostled. The need to deliver Office development to create vital and vibrant Town Centres is a National and Regional Planning Requirement.
The Strategy should reflect the Officers agree with the concept Rewrite policy, making type of Offices that Redditch is of this representation, however reference to the REDS, suitable for, e.g. Headquarters. given how fast the economy specifically referring to how the changes, it is not considered Council is aspiring to grow the appropriate to be defining the local economy. type of office development that is required. Both the Preferred Draft Core Strategy and the Redditch Economic Development Strategy (REDS) do, however, make reference
230 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. to the need for High Technology Development in the Borough. The REDS is a document that can be modified efficiently to reflect the changing economy, consequently the Core Strategy should make reference to this document and ensure the detail in the REDS is acknowledged and implemented by decision makers. Sustainability 103/164b The requirement for a The Employment Land Review No change to policy. Objectives knowledge based economy identifies sites for employment does at least identify land for purposes, these sites have new enterprises, but it fails to been designated to meet the say how and where the economic requirements of the education facilities will be Borough i.e. they should be established, other than mention suitable for the type of uses the discussions with appropriate Council set out in the bodies. The DPD needs to go forecasting stage of the further, identifying land for high Employment Land Review. A quality offices and for an draft Office Needs Assessment appropriate learning centre. has been prepared which will
231 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Without this is will be difficult to identifies sites in the town attract the necessary centre to meet the 30, 000 investments. sq.m requirement set out in the assessment. In relation to the point made regarding the learning centre, the Core Strategy is considered flexible enough to allow for a ‘learning centre’ or a higher education establishment to be developed. The allocation of sites can be considered when preparing the Site Allocations and Policies DPD. Land to the 016/070 Concerned about any potential The Employment Land Review Rewrite the Land to Rear of Rear of development on the Land to emphasises the need for some Alexandra Hospital to take Alexandra the Rear of Alexandra Hospital of the Land to the Rear of account of the suggestions Hospital or Wirehill Wood, as previous Alexandra Hospital to be used contained within the housing development has had for Office development. Employment Land Review. detrimental impact on However, in order to be Extract from revised Core scrub/grassland habitat, and compliant with the WMRSS, a Strategy policy “ The Borough potential loss of open space. maximum of 5000sq.m. of B1 Council will issue a use can be provided at this Supplementary Planning location. Therefore the Document to guide the Employment Land Review development of this site.”
232 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. suggests that additional research be undertaken on this site to identify an approach in terms of additional mixed uses. This work will need to account for impacts on the scrub/grassland and wider impacts e.g. the impact on current housing in the area. However the Employment Land Review does not include the Primarily Open Space within the potential development site. Officers would also point out that the principle for development on this site has been established in this location in previous Local Plan documents. Development 160/275 New factories should not be It is accepted that certain No change to policy. of new developed as there are current industrial units in the Borough factories ones vacant and being re- have been redeveloped for developed as housing. housing. However it is not considered a sustainable argument that the future
233 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development of factories should not be planned, as it is necessary to the successful growth of the Borough that future provision is identified. There is a positive correlation between the provision of future housing and the need for employment development to cater for housing growth, such that as housing increases so does the need for employment. In addition, both the Council’s Employment Land Review and the REDS seek to influence the economy of the Borough by setting out the direction of economic growth. The current, redundant factories do not necessarily suit the type of future uses that are being planned for the Borough and the current market requirements do not necessarily meet the current stock of facilities, therefore new
234 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. factories are needed. Land to the 199/321 The Core Strategy does not Officers concur with this point. Change the Core Strategy to Rear of appropriately define the land reflect the Employment Land Alexandra ownership for the Land to the Review. Extract from revised Hospital Rear of Alexandra Hospital; it Core Strategy policy context is correctly labelled in Stage 3 “The site is within the of the Employment Land ownership of the Secretary of Review. the State for Health, Worcestershire NHS Trust and Redditch Borough Council”
The Trust supports the The Employment Land Review Officers to progress this work Statement in Stage 1 of the states “Although there is an to identify appropriate future Employment Land Review identified need for offices uses for Land to the Rear of which states that employment through the projections set out Alexandra Hospital. This work is not the only suitable use on in stage 2, it is considered should also take account of the site. more suitable at this point to any other evidence that is recommend that the site be produced, which will assist in progressed as a mixed use identifying potential future land development encompassing uses for this site. office development. As a consequence further investigation of this site is required”. It is anticipated that the site will
235 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. constitute a mix of uses including offices and housing. Land to the 199/323 The Trust does not support the Officers concur with this point. The Core Strategy to be Rear of statement in the Core Strategy updated to take account of the Alexandra which states that the site Employment Land Review. Hospital should be developed as B1 Extract from revised Core use. The Trust adds that the Strategy policy “ To deliver policy in the Core Strategy is at significant housing and odds with the Employment employment land Land Review which advocates requirements, proposals for a mixed use development. this site must:
1. encompass a minimum of 5000 sq.m of high quality B1 only development, which constitutes office (other than that classified in A2); 2. provide a comprehensive housing scheme on the land to level of development identified in the Borough Council’s Strategic
236 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Housing Land Availability Assessment (i.e. 65% of land mass is developable)” Land to the 224/367 B1 office development of the Officers do not consider that As above. Rear of site is unrealistic for the whole the whole of the site should be Alexandra site. In order to be compatible reallocated to meet residential Hospital – with the hospital use, any uses. It is more likely that a mix Policy SP.8 employment development of uses will be incorporated on would have to be high class B1 the site with a mix of housing use, although the site location and employment. does not suit this. The site should be reallocated to meet residential uses. Policy ES.1 027/476 Highways Authority are The Core Strategy does not set Where sites are being concerned about employment out every future employment progressed, Officers will development located along site. However it is likely that consult with the Highways major transport routes such as both the A441 and A435 would Authority, and any other the A441 and A435, where be close to residential relevant body, regarding the these are not in easy reach of communities. It is also most appropriate way to bring residential communities, where anticipated that there would be these sites forward. there is not high quality public access to high quality public transport and where there is transport and infrastructure to not the infrastructure to encourage walking especially encourage walking. as these are likely to be
237 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. located near the major development areas. Policy BE.6 049/743 The ongoing Historic and Officers agree with this point. Officers to liaise with Farmstead Survey by Worcestershire County Council Worcestershire County Council in order to assist with policy will provide assistance development in this area. informing policies on the protection and conversion.
It is not clear what the policy is Officers consider retail No change to policy. referring to with regards to development to mean any form neither retail development nor of development that falls under new development. A1 use. In terms of new development this is defined under the 1990 Town and Country Planning Act as "the carrying out of building, engineering, mining or other operation in, on, over or under land, or the making of any material change in the use of any building or other land." Most forms of development require planning permission (see also "permitted
238 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development").
Biodiversity needs referencing Officers agree that biodiversity No change. in the policy, and ecological and ecological enhancement enhancement should be are elements that should be incorporated into building considered within planning design. policy. However Officers would emphasise that there is a need to be careful not to repeat other elements of policy that is cited elsewhere.
There is a typing error on page Noted. Officers to amend typing error. 63 (RJ) regarding the use of Extract from revised Core the word beneficial. Strategy policy context “that there are no beneficial or harmful effects on town and village vitality, and that it does not undermine any other aspects of the rural economy” Policy SP.8 049/733 It is welcomed that the policies Noted. No change to policy. recognise the ecological value of the site. Policy ES.1 049/746 Policy ES.1, iii. should be Officers concur with this Officers to re-write policy reworded as follows “in all representation. Extract from revised Core
239 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. cases, development should be Strategy policy “In all cases, acceptable in terms of their development should be impact on biodiversity and the acceptable in terms of their wider environment and impact on biodiversity and the demonstrate adequate wider environment and infrastructure including Green demonstrate adequate infrastructure.” infrastructure including Green infrastructure”
Waste management facilities The Core Strategy does not Make reference waste SA should not be excluded from make reference to the objectives in the policy. future employment land exclusion of waste provision, it should also be management from future noted that it does not fall within employment land provision. one specific use class. The Employment Land Review, Therefore specific reference which contains the detail on could be made to waste potential future employment management in order to ensure site allocations, simply sets out necessary development is not the most suitable type of land ignored. use class for that site, but does not make specific reference to any particular facilities. In relation to waste management falling under different use classes, Officers acknowledge this point. It is considered
240 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. appropriate to make reference to the waste SA Objective in order to draw attention to the issue.
The key factor is to ensure Officers agree that this is a key Make reference to Air Quality pollution is minimised, and factor that should be Strategy in Policy. amenity is protected, this considered in the Core should be a key factor in the Strategy. Indeed a reference to Core Strategy, rather than a the Air Quality Strategy in the focus on use classes. policy. In terms of amenity, this is covered in a number of areas within the Core Strategy, for example Policy H.2 ‘Primarily Open Space’. These factors should also be a consideration in the determination of a planning application for employment purposes and therefore Officers do not consider it appropriate to repeat policy information. In terms of use classes that are referred to in the policy, Officers consider that these are appropriate,
241 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. although the policy is being reviewed as a result of this consultation. Land to the 017/242 CPRE remain in objection to The Employment Land Review No change to policy as a result Rear of employment building at this has initially assessed the site of this representation. Alexandra location. It is a sensitive area and comments were received Hospital both at the hospital and the regarding the environmental SSSI wood, the RJ does not sensitivities in the area. cover the adjacent locations to However policy regarding Land land identified at Land to the to the Rear of Alexandra Rear of Alexandra Hospital. Hospital needs to be reviewed as part of this consultation. At this stage Officers do not consider that there has been sufficient information provided that should rule out the Land to the Rear of Alexandra Hospital site out for future development. The principle of development at this site has been established in previous Local Plans. Policy ES.4 017/245 CPRE agrees with items a, b & Noted. No change to policy. c in Part ii of this policy. Policy SP. 8 021/078 Generally accords with SR2. It The Employment Land Review Officers to progress this work also generally aligns with PA6A states that there is a need to to identify appropriate future
242 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and PA13B, however the need carry out further site uses for Land to the Rear of for development would also investigation for the Land to the Alexandra Hospital. Extract have to be demonstrated in line Rear of Alexandra Hospital. from revised Core Strategy with PA13B. The draft Office Needs policy “To deliver significant Assessment identifies the need housing and employment land to identify some town centre requirements, proposals for office needs outside of the this site must: town centre due to limited capacity in the town centre. 1. encompass a minimum However further consideration of 5000 sq.m of high of potential sites to meet this quality B1 only need is required. It is development, which anticipated that the Land to the constitutes office (other Rear of Alexandra Hospital than that classified in development proposal will A2); constitute a mix of housing and 2. provide a employment. comprehensive housing scheme on the land to level of development identified in the Borough Council’s Strategic Housing Land Availability Assessment
The Borough Council will prepare a Supplementary
243 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Planning Document to guide the development of this site.”
Policy BE. 6 021/081 Generally accords WMRSS Noted. No change to policy. policy PA 15. Policy ES.1 021/083 In line with emerging WMRSS Officers do not consider it Make reference to SA Policy PA6A and Table 4. In appropriate to single out a objectives for waste in the Core application of part iv, part B specific end use in the Core Strategy. should recognise that waste Strategy, particularly where the treatment facilities may be focus of the strategy is to not appropriately located on be overly prescriptive. However employment sites. reference to the SA objectives for waste can be referenced in the policy. Policy ES.2 021/084 Generally in line with emerging Officers agree with this Amend policy to reflect WMRSS Policy PA13A, but the representation. However, a representation. amount of floorspace should be local assessment has expressed as ‘at least’, determined that the 45, 000 Extract from revised Core because the RSS specifies a sq.m figure proposed in the Strategy policy: “Based on a specific requirement. Policy RSS is unrealistic. A figure of local assessment, the Council ES.2 should also require that 30, 000 sq.m is proposed, aims to deliver at least 30, 000 the need for large scale offices which is also reflected in the sq.m of office development for outside the town centre needs revised policy. the town centre.” And “Where to be demonstrated. large scale (over 5000 sq.m gross and above) office
244 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development is proposed outside of the town centre, the need for this must be demonstrated in line with RSS policy PA13B.” Land to the 021/085 The site is out of centre and Officers agree with this Officers to revise Land to the Rear of therefore if carried forward as representation and previous Rear of Alexandra Hospital Alexandra B1 use its need must be Officer responses have policy, taking account of this Hospital justified. outlined the need to review this representation and Office policy. Needs Assessment. Extract from revised Core Strategy policy: “1. encompass a minimum of 5000 sq.m of high quality B1 only development, which constitutes office (other than that classified in A2)”.
Policies ES.3 021/086 In line with emerging WMRSS Noted. No change to policy. and ES.4 Policies PA6 and PA6B respectively. Policy SP.8 088/540 There is a presence of a Officers are aware that there No change to policy. lowland meadow, a UK BAP are constraints on the site and priority habitat, and a its immediate locale, and the hedgerow classed as Employment Land Review ‘important’ under the Hedgerow emphasises the need for
245 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Regulations 1997 on the site. further site investigation. The site is also in close However, based on the proximity to Rough Hill and research undertaken to date, Wirehill Woods SSSI. Due to the constraints are not these factors it is questionable considered sufficient to warrant why the site is deemed suitable the site being removed. It is for development. anticipated that where there are constraints, any development will have to take account of this as part of any potential scheme and incorporate necessary mitigation measures.
The area should be promoted Officers agree that this could Issue to be taken forward as as a green infrastructure be considered as part of any part of the further investigation network, linking it with the potential development on site. into the development of site. SSSIs, this should occur regardless of the development. Policy BE.6 088/547 Policy should include Officers agree that biodiversity No change to policy requirements to protect and and landscape are key issues enhance biodiversity and for for this site and should be conversions to be in keeping considered as part of any with the landscape. application for development. However Officers do not
246 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. consider it to be appropriate to repeat other policies and consider that this is dealt with in sufficient detail in the Natural Environment section. Policy ES.1 088/548 Recommend the promotion of Officers agree that this is No change to policy. sustainable access links important and is considered to between residential and be a key requirement of good employment areas over use of planning. Indeed the policy the private car. makes reference to sustainable modes of transport. This is also a key theme of the Core Strategy. Policy ES.2 088/549 Appropriate policy. Noted. No change to policy. Policy ES.3 088/550 Developments which would The purpose of this policy is to No change to policy. substantially increase traffic create an opportunity for high along the A448 to join the A38 technology development, but would increase carbon does not identify any particular emissions. sites for development. Officers also recognise the need to be careful in allocating sites to ensure there is limited impact on neighbouring districts. Policy ES.4 088/551 No comment. Noted. No change to policy. Land to the 093/493 Any consideration of The Employment Land Review No change to policy.
247 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Rear of development on this site sets out the need for further Alexandra should take account of all of site investigation; this will Hospital the site and its immediate encompass all of the site and locale. its immediate surroundings. Location of 093/499 Reference to the draft The proposals map is draft until No change to policy. new proposals map. adopted. employment development The Environment Agency All of the sites proposed to be No change to policy. seeks to protect groundwater taken forward for employment based upon groundwater development were assessed sensitivity models, it is noted against the Strategic Flood that some employment sites Risk Assessment, and where may overlie superficial there were issues it was watercourses, which are considered that mitigation classed as minor aquifers and measures could be have water resource potential. implemented. However as part of any potential employment development the Environment Agency will be consulted. Office 151/263 Retail needs have shrunk Noted. The number of houses, A revised Office figure of floorspace considerably in the past year amount of employment land, 30,000 sq.m is proposed. requirements therefore the present provision retail and offices required to be negates the planned increase. accommodated in Redditch is allocated by the West Midlands Regional Spatial Strategy. The
248 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. draft Office Needs Assessment identifies a revised office figure of 30, 000 sq.m which is less than the 45, 000 sq.m identified by the WMRSS. Location of 153/515 Targeting jobs along public The Core Strategy does not No change to policy. jobs transport routes would be allocate sites to the extent appropriate as dispersed where every future developments are more difficult employment site is set out. to serve via public transport. However the Core Strategy Development should be does make reference to the focused in places that are well Employment Land Review served. which contains the potential site allocations. When identifying the potential employment sites to meet future needs, each of the sites were subjected to a series of tests which sought to assess their suitability. The location and accessibility to sites constituted part of this test. However due to the limited amount of land available, there are some sites which are
249 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. further away from public transport routes, although in the view of Officers these are still accessible. It should also be noted that the nature of Redditch being relatively small means that within the urban area, most locations are accessible by public transport. Policy BE.6 263/441 Relevant to criterion (ii): Officers agree that this Officers to liaise with Worcestershire County Council information will be of use in the Worcestershire County Council is in the process of completing development of Policy BE.6. regarding this subject area. a historic farmsteads survey. This information will add to the detail produced by English Heritage, and will assist in guiding sustainable use of historic farms. Policy ES.4 264/450 Policy ES.4 makes reference to Noted. Officers would like to No change to policy. the draft proposals map, refer to the proposals map in however the draft proposals the final Core Strategy, map is not available as part of however Officers point out that this consultation. Therefore the Council is not obliged to reference to it should be produce a proposals map as removed from the policy. part of this consultation.
250 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
The Policy states that Officers agree that this is a Amend policy as follows applications in existing suitable criterion to consider Extract from revised Core employment areas will not be applications for non- Strategy policy: “When permitted unless the criteria set employment uses in considering applications for out are met. It is suggested employment areas, based on non employment uses that an additional criterion be emerging national and regional consideration should be given added, which should read, “it is policy. However it is not to national Planning Policy, no longer viable as an suitable to repeat regional or particularly Planning Policy employment area either national policy. Based on this Statement 4, and the RSS, following a period of information the policy does particularly Policy PA6B.” unsuccessful marketing or need reviewing, to ensure any undertaking a viability applicants are aware of the assessment”. criteria that would be considered as part of a policy i.e. directing them to national policy. Employment 264/457 Stage 1 of the Employment Promotion of Employment sites Officers to pass comments Land Review Land Review: Brockhill and falls under the remit of onto Economic Development Land to the Rear of Alexandra Economic Development. for their consideration. No Hospital (allocated employment change to policy. sites in Local Plan No.3) should be made attractive so that employment development is achieved. Lower quality
251 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. employment sites, could be offered up for alternative employment uses.
Stage 1 of the Employment Officers agree that evidence No change to policy. Land Review: Based on does indicate that smaller units evidence contained in the are more favourable to the Employment Land Review it Borough. However there is a would be appropriate to target need to have a balanced supply of employment land to portfolio of employment land, meet the demand (smaller and it is not considered enterprises). Smaller units appropriate to focus all should be offered, and larger allocations on smaller sites to employment sites could be deliver smaller units. Larger released for alternative uses. employment sites contribute towards Redditch Borough being able to achieve this balanced portfolio .
Stage 2 of the Employment The Employment Land Review No change to policy. Land Review: The Council sought to achieve a balanced should consider the likely portfolio of employment land. In demand for manufacturing and terms of manufacturing sites, distribution in accordance with the current protocol is to follow the anticipated decline. Those through paragraph 2.10 of the less attractive manufacturing Supplementary Planning
252 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sites could be reassessed with Guidance on Employment the potential for them to be Land Monitoring. offered up for more appropriate uses. This would assist with bringing forward IN67.
Stage 3 of the Employment Noted. Given the fact that at No change to policy. Land Review: Site RB32 fronts this stage reference to the site Windsor Road and due to the states that it “could become age of the existing premises, available” it would not presently existing built layout and be appropriate to start planning potential consolidation in the the re-use of the site. However, aviation industry, the site could Officers would like to point out become available for that if the site were to become redevelopment in the medium available at any time, planning term, particularly if a more policy would encourage that modern facility were to be the site is either re-occupied or made available in the Redditch redeveloped for employment area. purposes, to ensure limited losses to stock. In addition, the process of bringing forward a redundant employment site would have to follow the guidance contained in the SPG on Employment Land Monitoring.
253 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
The configuration of site RB32 The above comments apply to No change to policy. means it is inadequate for its this response. existing occupiers, Mettis. Consequently there is a need for redevelopment if it were to remain in employment use. On- site constraints are significant, and addressing these would compromise the viability of delivering an employment use, particularly now with the falling value of land. These constraints could be addressed and mitigated against through the provision of a non- employment related high value end use, whilst ensuring the re- use of a brownfield site.
The size of the site conflicts If a site is functioning, as is No change to policy. with the demands set out in the RB32, it is not considered Employment Land Review i.e. suitable to be identifying the smaller enterprises. site for an alternative use. Traditionally the site would Officers accept that if the site have been taken up by large becomes vacant it is likely that
254 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. scale manufacturing; the work will need to be completed Employment Land Review has in order to make it viable. identified that this type of use is However at this stage the site in decline. is not vacant and therefore not open to consideration.
Site RB32 is a suitable site to The above comments apply to No change to policy. be considered for an this response. alternative use to employment.
The Mettis site was deemed If this site is lost from No change to policy. suitable for retention for employment to any other non- employment use and was employment use, it would be therefore not fully assessed in classed as a loss to stock with the Employment Land Review. no guarantee that this loss The site should be re-assessed would be made up elsewhere. on the basis of its suitability for Consequently Officers aim to retention as an employment ensure that the site is taken use. The on-site constraints forward for employment should be taken into purposes if it were to become consideration when assessing available again. the suitability of the site to be retained in employment and the financial viability of any redevelopment of the site.
255
Historic Environment
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. CS. 1 021/ 079 Policy CS.1 generally accords Comment noted. None. with the relevant parts of emerging WMRSS policies SR1, SR2 and SR3. CS. 1 028/ 105 Support approach of Policy. Support noted. None. CS. 1 029/ 706 Support Policy. Support noted. None. CS. 1 042/ 469 Clause (i) Do not consider it is the role of It is considered that new None. policies in the Core Strategy to buildings and developments in enforce the application of the Redditch should aim to be a Building for Life Standards sustainable and as well since it is not mandatory for designed as possible. The developers to obtain a Building Building for Life Standards for Life Award. These cover a range of sustainability standards cannot be enforced, issues and is therefore particularly where they have considered important. Officers not been the subject of within Redditch Borough rigorous testing through the Council are trained to assess RSS procedure and other new developments against this development plan consultation standard and therefore can as to their applicability. apply it to new developments.
256 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
The West Midlands Regional None. Spatial Strategy Phase II Revision Preferred Option contains Policy SR3 ‘Sustainable Design and Construction’ which states that all new housing developments must meet CABE Building for Life ‘silver’ standard and that all medium and large scale developments (greater than 10 residential units) meet the ‘very gold’ standard. CS. 1 091/ 135 Disappointing that the policy The requirement for medium None. does not go any further than and large developments to the provisions of the existing meet Building for Life ‘gold’ Supplementary Planning standards is a new concept. Document ‘Designing for However there is no Community Safety’ (Dec 2006). justification for any addition standards to be achieved, so they cannot reasonably be expected.
The provisions of Policy CS. 1 Noted. Noted.
257 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. essentially ensure that a development scheme incorporates ‘Secured by Design’ principles. However, whilst the inclusion of design measures to reduce the opportunities for crime will assist in delivering sustainable communities, they will not remove all crime and disorder activity. There will remain a key role for the West Mercia Constabulary (WMC). 091/ 137 and New commercial development Achieving the ‘Secured by None. 137b and developments such as Design’ Principles is bars and clubs should referenced in the High Quality incorporate ‘Secured By and Safe Design Policy and is Design’. therefore encouraged as part of new development. Policy CS.1 262/ 410 Support for Policy. Support noted. None. Policy CS.1 085/ 524 Support for Policy. Support noted. None. Policy CS.1 088/ 541 The need for open space to be Noted. It is considered that it is and feel safe is recognised appropriate to consider the within the justification, but not design and integration of open within the policy itself. It is space
258 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. recommended that the policy includes a requirement for proposals to consider the design and integration of open space. Policy CS.1 263/ 437 Welcome this policy, Support noted. None. particularly criterion (iii). 103/164(f) An attractive feature of the This kind of requirement would None. town is the architectural details be more appropriate within a on the fronts of many of the Development Control and Victorian houses, using Policies DPD, it would not be sculptured brickwork. There appropriate for the Core should be a policy preserving Strategy. this feature along with houses of architectural interest.
Infrastructure
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 021/099 SC7 deals with developer Noted None contributions and lists key
259 infrastructure requirements to deliver the objectives of the core strategy. The emerging WMRSS has no policy on developers contributions 027/479 Highways Agency support the The Core Strategy will include Continue with Infrastructure inclusion of Policy SC7 as the a delivery strategy and an Delivery Plan policy will help to ensure that Infrastructure Delivery Plan new development is supported within the evidence by necessary infrastructure. demonstrating whether sites The evidence base should are deliverable or not. contain the necessary information to demonstrate that this infrastructure is deliverable. 049/762 Infrastructure Providers Contact will be made with the (including the county) should County Council with regards to be involved in continued infrastructure requirements; dialogue with the council. this information will be included Criterion i is unreasonable as it within the Infrastructure is inevitable that some Delivery Plan which will inform pressure will be placed on the Delivery Strategy. infrastructure, criterion ii and iii are more appropriate. Would like to see habitat creation include the management of existing habitats, particularly existing semi natural habitats. Question
260 why ‘waste disposal’ has been removed when it was included at the issues and options stage. 088/559 Welcomes Policy SC7 and the Noted None inclusion of Green Infrastructure, Open Space and Recreation, landscape character and biodiversity, including habitat creation and local environmental improvements. 091/130 WMC consider that the most The Infrastructure Delivery Add the following paragraph to sustainable sites are those Plan will demonstrate costs Policy SP2; where there is sufficient needed to deliver the ‘In all cases, the suitability of funding to deliver the required infrastructure required for the sites to be brought forward infrastructure to support the sites. This information will feed for development will be sites. If there is not then into a future CIL document. tested against the provisions contributions from development of Policy SC7 – are justified as per the tests of Infrastructure to ensure the Circular 05/05. compliance with the WMC suggest that the objectives of the core following extra paragraph be strategy’ . added to Policy SP2 as follows; ‘In all cases, the suitability of sites to be brought forward for development will be tested against the provisions of Policy SC7 – Infrastructure to ensure
261 compliance with the objectives of the core strategy’. 091/131 2 omissions to Policy SP3 in Making reference to providing that there is no reference to infrastructure for general providing the general development within each policy infrastructure required to is not needed as an individual support a development and infrastructure Policy is there is no reference to the provided. Sustainable Communities strategy theme of ‘Safer Reference is not needed Communities’. Supporting paragraph to Policy SC7 states that without policies covering infrastructure none of the SA objectives would be achieved and that there could be a potential negative effect on achieving the objectives. Therefore why the omission in Policy SP3? 091/134a Policies SP6, SP7 and SP8. Contact will be made with the Inform Development Control WMC feel that proposals for Police with regards to regarding early engagement these sites must involve infrastructure requirements; with the police at pre-app Section 106/CIL contributions this information will be included stage. towards new policing within the Infrastructure infrastructure. WMC request Delivery Plan which will inform Include Emergency Services that RBC and eventual the Delivery Strategy. within the list in Policy SC.7. developers of these sites engage with WMC as early as
262 possible during pre-app stage. 091/134b Policy BE7 – WMC feel that See response 091/134a proposals for these sites must involve Section 106/CIL contributions towards new policing infrastructure. WMC request that RBC and eventual developers of these sites engage with WMC as early as possible during pre-app stage. 091/134c WMC welcomes Policy ES6 See response 091/134a where RBC will seek to maintain and enhance the vitality and viability of Redditch Town Centre through promoting a vibrant and safe evening economy. WMC is of the view that new developments, such as bars and clubs should provide contributions towards new policing infrastructure. 091/134d Policies H1, H3, SC1, and The methodology will be Inform Development Control SC4. WMC request that they looked into when identifying regarding early engagement are invited to be involved as infrastructure costs. with the police at pre-app early as possible in any stage. proposals to advise on the (See response 091/134a) design of developments and to Include Emergency Services determine if new policing within the list in Policy SC.7.
263 infrastructure should be provided. It may not be clear to RBC what the actual policing costs would be directly attributable to a given development and therefore not suitable for contributions however the methodology set out in appendix b of the reps identifies the costs. 091/136 WMC request the following be The respondents comments None added to Policy CS1 ‘provide have been noted however it is obligations to be used to not appropriate to add the text fund/provide policing to policy CS1 as not all infrastructure necessary to development would be subject make development acceptable to planning obligations as set in planning terms’. out in Circular 05/05 091/138 Provisions of Policy SC7 are Noted Include Emergency Services supported by WMC however within the list in Policy SC.7. surprise that the emergency services have been omitted from the current list of recipients. Although the policy contains the provision that the list is not limited to the infrastructure types listed WMC believe that it will be treated as a definitive list by developers and others. Issues and Options
264 identified policing as an essential infrastructure. It is also supported by a number of other documents (listed in rep). 093/503 Reference should be made Biodiversity, including habitat Amend list in SC7 to read; within Policy SC7 for the creation and local Green Infrastructure phasing of sites in accordance environmental improvements is (including biodiversity, with appropriate infrastructure covered within ‘Green habitat creation and local as there could be timing and Infrastructure’ therefore agree environmental cost implications. Clarify with the rep that this is improvements). difference between ‘green somewhat confusing. infrastructure’ and biodiversity including habitat creation and With regards to the issue of Investigate issue of phasing. local environment phasing this may or may not be improvements’. appropriate and will have to be Include the following under the investigated further, with remit of ‘Environmental Further consideration given to advice from a regional level. Infrastructure’ in the list in ‘Environmental Infrastructure’ Policy SC.7; within policy. Suggested the following types of infrastructure Foul Sewage be included in the key Water Supply infrastructure requirements; Surface water drainage Foul Sewage Flood Management Works Water Supply (Defences) Surface water drainage Waste Flood Management Works (Defences) The CIL would cover the whole Waste sewerage network affected by the capacity. Reference is made to the use
265 of a CIL, would this just cover the area of development or the whole sewerage network affected by the increase in capacity? 104/066 Core Strategies are required by The Core Strategy was only To be completed for PPS12 to include an draft and this was not a submission. Infrastructure Plan. Policy SC7 requirement at this stage. does not meet this An Infrastructure Delivery Plan requirement. It does not is currency being worked on represent a spatial strategy for and will inform both the infrastructure planning; it is a delivery strategy and Policy development control based SC.7. This will address the responsive policy that is not issue of cross boundary growth founded upon any evidence. and working with Bromsgrove District Council. The Council should develop an Infrastructure Strategy that supports the Core Strategy that includes working with Bromsgrove Council in order to deliver cross boundary growth.
108/171 Asking what consideration is Noted. Opportunities are given Continue with Infrastructure given to local residents in to residents at a number of Delivery Plan terms of schooling, policing, stages through the core fire and medical service etc strategy process to comment when new builds are proposed. on such issues. The Borough Roads will be congested with Council is currently working
266 lorries carrying building with Infrastructure providers to materials assess additional demand on services as a result of future development. This information will be fed into an Infrastructure Delivery Plan and further feed into any future CIL document and Section 106 Obligations to receive monies/additional works to mitigate impacts on exciting infrastructure. 109/173 Need infrastructure for the Noted. All necessary Continue with Infrastructure Studley By-pass, Bordesley infrastructures will be Delivery Plan By-pass and school sites on investigated and detailed in an the outskirts of town. Infrastructure Delivery Plan to inform the Delivery Strategy. 263/442 Policy SC7 makes no To be investigated – more Email English Heritage. reference to the heritage information required from resources of the Borough – English Heritage whether individual sites or the wider character of important areas such as the boroughs designated Conservation Areas. We recommend a specific reference should be made to Historic Environment assets. 264/456 Support Policy SC7 and Noted. The ‘and’ after criterion Amend the wording of criterion criterion i. The wording of ii should remain as all 3 ii to read
267 criterion ii is somewhat criterions must be met in order ‘its impacts on the existing confusing and could be for proposals to be permitted. infrastructure required to amended to read “its impacts support it are minimised’. on the existing infrastructure Criterion iii will be amended required to support it are however the term ‘local Amend the wording of criterion minimised”. Alternatively infrastructure’ will be replaced iii to read ‘appropriate criterion ii could be deleted as by just ‘infrastructure’. investment is secured in its covered by criterion i. and iii. either in the form of works or financial contributions to The ‘and’ after criterion ii mitigate the cumulative implies that all three criterions impact of the proposed must be met in order for development on local proposals to be permitted. We infrastructure. suggest amending this to ‘or’ which would ensure that only the relevant criterion applies.
The wording of criterion iii should be amended as follows: “appropriate investment is secured in either in the form of works or financial contributions to mitigate the cumulative impact of the proposed development on local infrastructure”.
268 Landscape, open space, nature, pollution, Green Belt
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy BE.3 021/ 080 Policy BE.3 generally accords Noted. None. with published West Midlands Regional Spatial Strategy (WMRSS) Policy QE. 6. Policy BE.5 021/ 081 Policy BE.5 generally accords Noted. None. with published WMRSS Policy QE8B and emerging WMRSS Policy PA15. Policy H.2 021/ 091 Policy H.2 accords with Noted. None. published WMRSS Policies QE. 4, QE. 7 and QE. 8. Policy BE.5 024/ 110 Support for Policy BE.5. Support noted. None Policy BE.5 049/742 Consideration should be given The intention of this policy is to None to new tree planting in regard ensure that where new to existing habitats e.g. development is to occur, the grassland. proposal is sympathetic to the features of the Borough i.e. the abundance of trees. This policy now forms part of the Natural Environment Policy within the Core Strategy.
Item (iv) of Policy should be The key principle of this policy None.
269 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. made clearer as it currently is that trees, woodlands and reads all proposals will be hedgerows in Redditch are expected to involve tree retained and their appropriate planting for timber production; management encouraged, this perhaps change wording to key point has been transferred states ‘for example’ after the to a new Natural Environment word ‘planting’. Policy within the Core Strategy. The remaining points of this policy have been removed as it is considered they are more suitable for a Site Allocations and Policies DPD.
Under point (vi) please refer to Please see above with regard None. the Forestry Woodlands to point (vi) of this Policy. With Mapping Strategy and the regard to using the Forestry Historic Landscape Woodlands Mapping Strategy Characterisation when and the Historic Landscape completed. Characterisation, it is understood that these studies will not be complete until Spring 2011 and therefore too late to feed into the Core Strategy process.
Proposals for planting should A sentence will be included A sentence will be included
270 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. not cause damage to known or within the aspect of the policy within the paragraph of the suspected features of trees sits within which refers to Natural Environment Policy archaeological importance. the need for planting to ensure which states “ Proposals for that damage is not caused to planting should not cause areas of known or suspected damage to known or suspected archaeological importance. features of archaeological importance”. Open Space 049/ 747 A number of open spaces have The importance or some of the None. specific historic interest. This open space areas within the should be used to enhance Borough for historic interest will their character and engender be investigated further through local pride. Further open the production of the Green spaces may also be Infrastructure Strategy. If it is designated for principally considered that some of these historic interest and then areas are important for developed for their amenity historical purposes and open value. space purposes this will be taken on board when the Open Space Needs Assessment is revised, and the open space designated accordingly. 082/ 764 Cannot support Strategy as a Playing Pitch Strategy will form None. Playing Pitch Strategy has not part of the evidence base to been carried out. the Core Strategy.
271 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Evidence for the indoor Facilities Planning Model will None. facilities is highly suspect on be included as part of the pools and halls. Need to run a evidence base to the Core facilities planning model. Strategy. Cannot use the Sports Facility Calculator for predicting demand on its own. Some of the policies in the Preferred Draft Core Strategy are at risk if the above issues are not addressed mainly SP.6 and SP.7. There may also be possible implications for the Green Belt and Employment Land Allocations. These studies are also important for the BSF Programme and other developments affecting schools. It could/ will prejudice S77s if there is not a robust Playing Field Strategy in place. Trees 085/ 525 The Core Strategy should The intention of Policy BE.5 None. encourage the responsible within the Core Strategy is to management of existing trees, ensure that where new woodlands and hedgerows. development is to occur; the
272 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Exception should be made for proposal is sympathetic to the the removal of existing trees, features of the Borough i.e. the woodlands and hedgerows that abundance of trees and to are not healthy or of any ensure this is incorporated into particular merit in terms of their the development proposal. quality, particularly where appropriate mitigation or With regard to existing trees replacement planting is including management, this will proposed. be included as a principle within the new Natural Environment Policy within the Core Strategy. In terms of the removal of trees due to quality, those trees with Tree Preservation Orders would be inspected by the Landscape Officers within the Council and judged on an individual basis. Where removal does occur it is anticipated that the tree would be replaced, however this cannot be enforced. Policy BE. 3 088/ 544 Support the inclusion of this Support noted. None. Policy and the use of the Landscape Character
273 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Assessment for Worcestershire. Policy BE. 5 088/ 546 Welcome the Policy. The Agreed. This aspect of the Text to be amended to read requirement to expand and link policy is now contained within “Particular emphasis should be ancient semi-natural the new Natural Environment placed on expanding and woodlands is particularly Policy within the Core Strategy. linking ancient semi-natural positive; this principle should The text will be amended to woodlands.” be applied to all semi-natural ensure the requirement is and natural habitats, detailed that ancient semi- particularly those which are natural woodland is expanded BAP priorities. and linked.
Recommend that the See response to 049/ 722. See action to 049/ 722. expansion and linking of habitats be considered within the context of green infrastructure in order to secure the delivery of multifunctional benefits.
Consideration should be given There are many benefits to the None. to the role of woodlands in a role of woodlands. However it warming climate, for example, is not considered appropriate the suitability of a species to that all of these benefits are warmer and dryer climate listed in the policy. Rather the
274 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. should be considered when generic principle of extending creating new woodlands. and linking woodlands is Resistance to recreational promoted. pressures may also become a consideration, as the shade woodlands provide may increase their popularity for recreation. Policy H. 2 088/ 555 Underlying confusion in policy The Core Strategy will be None. between green infrastructure restructured and the included and its relationship with open polices will be refocused to space. Policy is labelled ‘open ensure better clarification space’ but incorporates between open space and biodiversity and concludes that biodiversity. This will be consideration of the two refocused with a clear together equates to green emphasis on the role of Green infrastructure. The Core Infrastructure. A Green Strategy should present green Infrastructure Strategy is infrastructure as an currently being prepared which overarching framework within will inform the content of the which open space and Core Strategy. These elements biodiversity sit. Policies on sit within the ‘Green Strategy’ landscape, climate change, of the Core Strategy. flood risk, pollution, trees and sustainable transport should be
275 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. clearly cross- referenced.
A green infrastructure strategy See response to 049/ 722. See action to 049/ 722. should be undertaken, forming part of the evidence base and informing policy direction.
The policy on open space Agreed. The policy directs for a Include sentence in policy to should include a presumption presumption against the read “where open space will be against the development of development of open space by lost the substantial open space, and that where stating that ‘Primary Open enhancement of remaining open space will be lost the Space will therefore be and/or nearby open space will substantial enhancement of protected…’ and ‘proposals be required.” remaining and/ or nearby open involving a loss or partial loss space should be required. of open space will be assessed again the following criteria’. However an additional sentence will be included which states that where open space will be lost the substantial enhancement of remaining and / or nearby open space should be required.
Would welcome the setting of The open space provision None. an open space provision standard is a result of the open
276 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. standard which is comparable space needs assessment to the rest of Redditch within all (March 2009) completed for new developments and Redditch Borough Council. includes reference to Natural Natural England’s Accessible England’s Accessible Natural Natural Greenspace Standards Greenspace Standards have been considered as part (supplied), which should be of the preparation of the open strategically delivered within space needs assessment. With the context of green regard to Natural England’s infrastructure. standards the document concludes that, “on the whole, Redditch Borough performs well for accessing semi-natural open spaces, and also for proximity to green spaces that can be accessed outside the Borough, such as the Lickey Hills and Malvern.” (From the Open Space Needs Assessment, March 2009). Policy BE. 4 088/ 545 Clarification is needed to Officers consider that the Delete policy. ensure the policy achieves its control of pollution is purpose. It is not clear how the adequately covered by ‘acceptability’ of an application Planning Policy Statement 23 in terms of its resulting ‘Planning and Pollution
277 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. pollution will be judged, Control’. Therefore this policy especially considering is likely to be removed from the cumulative impacts. Submission Core Strategy. Consideration should be given to the type of information which may be needed to make informed judgements on applications, and whether the Sustainability Statement currently required under Policy BE.1 could be tailored to meet this requirement. Delete Policy The pollution policy seeks to It is not clear what receptor the work toward achieving a policy applies to. The policies number of objectives both position in the ‘Better environmental and health Environment’ section and its related. The policy is suited to pre-amble indicate that the the Better Environment section, natural environment is the however by implication the receptor, but the symbols used policy does seek to reduce the to indicate the Sustainability impact of new development on Objectives show that the policy health. There are a number of will help to improve health and similar instances in the well-being. Preferred Draft Core Strategy.
278 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 212/ 348 There is no reference to The following documents have Ensure that Planning Policy Planning Policy Statement 9 – been considered when Statement 9 ‘Biodiversity and Biodiversity and Geological preparing the Core Strategy Geological Conservation’, the Conservation. and will be reference in the Worcestershire Geodiversity ‘Green Strategy’ Technical Action Plan and the The Worcestershire Paper. It is not always Worcestershire Biodiversity Geodiversity Action Plan has necessary to reference County, Action Plan are referred to in just been launched and this Regional and National the ‘Green Strategy’ Technical should be referred to in the Planning Policy in the Core Paper where necessary. strategy, alongside the Strategy. It is considered that Worcestershire Biodiversity the Geodiversity Action Plan Action Plan. and the Biodiversity Action Plan do not have any significant implications for the Core Strategy and the main principles of the Actions Plans will be achieved through the Natural Environment Policy. A Better 212/ 352 Paragraph 1 – object to the A definition of the Natural Definition of Natural Environment definition of the natural Environment the Glossary of Environment in Glossary to for Today and environment. The natural the Submission Core Strategy read, “Trees, wildlife corridors, Tomorrow environment includes all will be expanded. rivers, sites of national, aspects of living and non-living regional or local importance nature, including soils, natural and other sites of biodiversity processes and geology. importance including aspects
279 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. of the environment that are living and non-living such as soils, geology and natural processes.” Paragraph 2 – the sentence This section of the introduction beginning “SSSIs are Sites of will be removed from the Remove second paragraph of National Wildlife importance…” Submission Core Strategy. the Introduction to the ‘Better does not make sense. This Environment for Today and should be removed, as it is Tomorrow’ section. repetition (and inaccurate repetition) of the definition later on in the sentence. Please see response to There is no policy with respect 212/351. Please see action to 212/351. to biological or geological conservation within the Borough. Other Core Strategies within Worcestershire appear to cater for this. A policy would be welcomed that stated the role of development proposals in safeguarding and enhancing biodiversity and geodiversity and the suite of designated sites that they contain.
280 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy BE.3 017/ 243 Support for the Reasoned Support noted. The principles None. Justification for the Policy. of this Policy can be contained within a broader Natural Environment Policy within the Submission Core Strategy. Policy BE.5 017/ 244 The introduction to the Policy The principles of this policy Amend term changes to those uses the word ‘should’ three have been retained and can be recommended, where times, these should be merged with the Natural appropriate. replaced with ‘will’, ‘to’ and ‘are Environment policy for the to’ respectively. The word Submission Core Strategy. The ‘must’ should be used at the suggested term changes will beginning of the last paragraph be reflected where appropriate. of the policy. In the Reasoned Justification, the first ‘should’ should be changed to ‘will’ and the last ‘should’ be changed to ‘needs to’.
The term veteran will be Replace veteran with the term The term veteran should be replaced with the term ancient ancient where appropriate. replaced with the term ancient. where appropriate.
Policy H.2 017/ 247 Support for this Policy. Support noted. None. Policy BE.4 093/ 497 This policy focuses solely on This policy is recommended to None.
281 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Air Quality; if this is the be removed from the intention of the Policy it should Submission Core Strategy as be re-titled ‘Air Quality’. Water Officers consider that this is quality issues (pollution) could adequately covered by national be picked up in the water planning policy. management or climate change policy as suggested above and it is noted that soils (contaminated land) has been picked up within Policy SP. 3 on Sustainability Principles.
Policy BE. 5 093/ 498 Wish to see biodiversity Biodiversity forms part of the None. included within a policy in the ‘Green Strategy’ within the document, it is noted that it has Core Strategy and therefore is been picked up in the final referred to throughout the paragraph of this policy, and document. It is considered that would suggest that proposals nothing additional could be should also be looking to achieved through having a enhance biodiversity in the biodiversity policy that is not area through the proposed achieved already. development and potential developer contributions. It is acknowledged that biodiversity has also been picked up in the
282 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. open space policy (H.2). Policy H.2 093/ 500 Recommend that Policy H.2 is The wording that is None. changed to sound more recommended does achieve positive by removing the necessary protection ‘Proposals involving a loss or against loss of open space partial loss of…’ so that the where it would be necessary. policy reads – ‘ The provision of Open Space will be assessed against the following criteria as applicable…’ It is considered that there are None. An additional point could be significant benefits to open added to this policy to consider space, however listing all of its multi-functional use. For these benefits would make the example open space can be policy unduly long. These utilised within a development benefits will be fully detailed in site to control surface water the ‘Green Strategy’ Technical runoff through the provision of Paper. SuDS (i.e. ponds, wetland habitat, swales etc), provide flood storage areas etc. Green 049/ 722 An additional policy on Biodiversity and Green Insert principle in the Natural Infrastructure Biodiversity and Green Infrastructure will be Environment Policy which Infrastructure is recommended incorporated as a principle states, “Protect and enhance as green infrastructure can within the Natural Environment the quality of natural resources
283 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. play a role in reducing flood Policy. and green infrastructure risk, reducing the ‘heat island’ resources in the Borough effect and providing crucial including water, air, land, linkages for habitats. Trees, the habitats and biodiversity.” historic landscape, open spaces are just some of the attributes that make up green infrastructure and these should be included within a policy on green infrastructure.
A Green Infrastructure Study It is considered that this study None. and detailed ecological surveys will be appropriate in advance should be undertaken that feed of the Site Allocations and into Site Allocations/ Master Policies DPD. Plans/ Development Briefs/ Area Action Plans along with PPS 9 compliant Development Control decisions. None. There is a need for ecological Policy B(NE).1 Overarching connectivity between sites Policy on Intent from Local promoting a functional Green Plan No.3 is saved. This policy Infrastructure within the built states that, “where possible and rural environment. This conserve, enhance and link should be addressed in the habitats”.
284 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. document. Policy BE.3 049/ 740 The Policy is welcomed subject The Central Marches Historic None. to the Central Marches Historic Towns Survey has been used Towns Survey being used as a as part of the Core Strategy basis for forward planning. This evidence base. study requires updating and incorporation into the on-going Historic Landscape Characterisation Project. Other information is available from County Historic Environment Record. Policy BE.4 049/ 741 Both the natural and historic It is considered that pollution is None. built environments are adequately covered by PPS 23 susceptible to pollution. It is ‘Planning and Pollution important to consider soil and Control’. water pollution, as well as air, None. in this context. The policy is The Hereford & Worcestershire lacking in this area. The Draft Air Quality Strategy has now Hereford & Worcestershire Air been finalised and concludes Quality Strategy could usefully that there are no areas within inform this section of the Redditch Borough that exceed strategy. the air quality objectives. None. Both of these documents have
285 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Regard should also be had to been considered in the the Water Framework Directive formulation of the Core and River Basin Management Strategy. None. Plans. Both of these documents have The Planning for Soil and been considered in the Water Technical Research formulation of the Core Papers can inform this section Strategy. when preparing the Core Strategy Submission Document. Policy H.2 049/ 752 The introduction to ‘Open The definition provided will be Insert the following definition of space’ recognises that the included within the Glossary to open space within the 1990 Act provides a definition the Core Strategy. Submission Core Strategy. of open space and there is also reference to PPG 17, however it is important to note that within PPG 17 at Annex; Definitions (1) the definition of open space is widened (full definition provided) the Preferred Draft Core Strategy should recognise these wider purposes. The criteria are required to None.
286 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. The general thrust of H.2 is ensure that any loss of open welcomed but there are space is only allowed in certain concerns over how loosely the circumstances and where it criteria are defined for example can be proven that this is not wording could be “in detrimental. exceptional circumstances, proposals resulting in the loss of any part of this primarily open space will only be considered where the developer can satisfactorily ensure …(i) (ii) (iii)” Criteria (i) considers the wider None. environmental and amenity Parts of (i) and (ii) sound very value the site adds to the wider similar and might want to be area, whereas criteria (ii) amended. relates to the specific site and how it can be reserved for alternative uses. These criteria are considered to achieve different things and are worth retaining. Amend wording of criteria (vi) Comment noted. The wording to “ecological connectivity and It is recommended that the will be amended as suggested. features of biological policy wording under criteria importance, such as (vi) is reworded as follows: hedgerows, watercourses and
287 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. “ecological connectivity and other features of biodiversity features of biological importance”. importance, such as hedgerows, watercourses and other features of biodiversity importance”. It is considered that it may be Add wording to the introduction more appropriate to detail the of the open space policy as The policy could mention the benefits of open spaces in the follows, “there are a range of benefits of open space as a introduction to the policy rather benefits of open space flood storage area, perhaps as than in the policy itself. including the use as a flood one of the criteria. storage area.” Each ward has a level of open space, as the boundaries have None. The final paragraph of the been amended this level will Reasoned Justification for change, as previously open Policy H.2 needs to be space that was in one ward explained and made clearer. may now be in another. This Why does a change in ward paragraph will not feature in boundaries affect open space the Submission version of the levels, the policy for which is Core Strategy. applied on a Borough-wide basis? It is considered that it would be Include wording within main appropriate to include this body of the Policy, “The The following text is included in criterion in the policy. Borough Council will consider the Reasoned Justification applications for ancillary (page 87), ‘The Borough development on Primarily
288 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Council will consider Open land that would enhance applications for ancillary the existing open space use.” development on Primarily Open land that would enhance the existing open space use.’ It is questioned whether this text should be included in the Policy wording of H.2. Page 60 102/ 152 Suggest reference to the It is not clear which Forestry None. Policy BE.5 Forestry Woodland Mapping Woodland Mapping Strategy Point (vi) Strategy and the Historic the applicant is referring to. Landscape Characterisation The Historic Landscape when completed. Characterisation is not yet complete. Page 82 Para 102/ 153 A number of existing open Please see response to 049/ Please see proposed action to 2 spaces have specific historic 747. 049/747. interest. This should be used to enhance their character and engender local pride. Further open space may also be designated for principally historic interest and then developed for their amenity value. Page 87 102/ 154 Green Infrastructure Strategies See response to 049/ 722. See action to 049/ 722.
289 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. also includes consideration of the historic environment as an integral element of assessment. Policy BE.3 263/ 439 The general principle of this Agreed. Reference to the A reference to the historic policy is welcomed; however, historic character if the character if the Borough will be there are concerns over the Borough will be included within included within the introduction lack of recognition given to the the introduction to the Natural to the Natural Environment historic character of the Environment Policy. Policy; however this wording Borough’s landscape and the has not yet been finalised. emphasis placed on the County Council’s Landscape Character Assessment.
In assessing the impact of A reference to the importance proposals on the character of The HLC is not anticipated to of the natural landscape will be the landscape, its historic be completed in time to fully incorporated into the Natural dimension must be taken into inform the Core Strategy Environment Policy, however account in order to accord with Policy, however the importance the exact wording has not yet the European Landscape of the natural landscape will be been finalised. Convention. The County incorporated into the Natural Council are progressing a Environment Policy. county wide Historic Landscape Characterisation (HLC). It is recommended that
290 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the implementation of this policy includes a reference to the HLC, and that the County Council are contacted regarding the provision of interim information to inform development proposals. Policy BE.5 263/ 440 Point (vi) should include a This point has been removed None. reference to ‘other information from this policy. Reference to sources, such as the Historic the Worcestershire Landscape Environment Record’. Character Assessment is made within the Natural Environment Policy. With regard to other references that could be incorporated in the Policy, it is considered that only references which fully contribute to directing the actions people could take should be referred to therefore generic references to broad documents such as the Historic Environment Record are avoided. Policy BE.5 264/ 449 It is suggested that the wording It is considered that this None. of this policy is amended as additional wording would
291 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. follows “existing trees, provide an unnecessary woodlands and hedgerows amount of detail. The strategic should be retained where aspirations of the aspect of this practicable and where the trees point are to retain trees, are of good quality/ species to woodland and hedgerows and warrant retention and their ensure appropriate appropriate management management. Detail on encouraged.” whether this may always be practical and the quality of the trees would be detail that would be considered at the application stage by the Officer dealing with the application. Policy BE.5 103/164(a) Policy BE.5 (iii) has no public Criteria (iii) of Policy BE.5 will None. agreement and does not not be continued into the maintain the existing Submission version of the Core distinctiveness created by the Strategy, however one of the Development Corporation. It is key features of the Core resulting in wholesale Strategy is to retain and destruction of most of the trees enhance the trees that are in planted by the Corporation, abundance within the Borough, including beech, hemlock, as this is one of the key spruce etc. Rather than features of the Borough that preserving the landscape, this should be retained and is creating new space that is enhanced. Therefore the
292 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. neither attractive nor desirable general principle of this policy in the public environment. will be contained within the Natural Environment Policy. Green Belt 103/ 164(a) Building on Green Belt The whole Green Belt None. farmland is the present surrounding Redditch Borough intention. Fail to see how was considered for moving the Green Belt will development and it was preserve the openness of this concluded that the preferred resource, and protect the best and most sustainable location agricultural land, or preserve (including preserving the biodiversity interest. openness of the Green Belt) for development to the North of Redditch Borough. None. There should be a strategy for Dealing with waste generated dealing with green waste from new developments is a generated in the timbered parts consideration for the Core of the borough. Once killed, Strategy; however general this material can either be waste processes are a matter allowed to rot on or in the for other Council departments. ground, or burned to create heat and electricity.
293 Miscellaneous
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 017/237; Redditch being designated an Agree. The designation of Reflect Redditch's WMRSS CPRE SSD. Exactly what is meant or Redditch as an SSD was designation in the Core referred to as "significant challenged by Redditch Strategy. development". Some indication Borough Council at the West of what "significant" is essential Midlands Regional Spatial to provide guidance. Strategy Phase Two Examination in Public and this designation was duly removed in the RSS Panel Report. 017/239; Local Distinctiveness The Local Distinctiveness None. CPRE document - not on website. Document will be available in The factual description could due course as part of the be the intro of the final core evidence base for the Core strategy as it contains history Strategy. The Local which precedes the descriptive Distinctiveness Document was portrait. It mentions the cinema fully incorporated when drafting and the Core Strategy doesn’t. the Spatial Portrait for the Core Strategy and all relevant information was included.
017/250; Page 126 Glossary and Noted. The Glossary will be Amend Glossary under CPRE Abbreviations. English Nature amended to ensure that definition to Site of Special now known as Natural England reference is made to Natural Scientific Interest to read
294 England rather than English “Specifically defined areas Nature. where protection is afforded to sites of national wildlife or geological interest. Natural England is responsible for identifying and protecting approximately 4,100 SSSIs in England.” 021/071a RSS Objective (a) to make the Noted None WMRA MUAs of the West Midlands increasingly attractive places where people want to live, work and invest Not Applicable to this Core Strategy. 021/071b RSS Objective (b) to secure Noted. None WMRA the regeneration of the rural areas of the Region The relevant Key Themes and policies, notably Policy SP2 Development Strategy, and BE6 Rural Economy support this objective. 021/071c RSS Objective (c ) to create a Noted. The redraft for the None WMRA joined-up multi-centred vision and objectives will Regional structure where all continue to support this RSS areas/centres have distinct Objective. roles to play The Core Strategy Vision,
295 relevant Key Themes and spatial policies support this Objective 021/071d RSS Objective (d) to retain the Noted. None WMRA Green Belt, but to allow an adjustment of boundaries where this is necessary to support urban regeneration Policy SP2 Development Strategy supports this objective and also the objective as amended in the emerging WMRSS revision 021/071e RSS Objective (e) to support Noted. See responses to Cross None the cities and towns of the Boundary Issues. Region to meet their local and sub-regional development needs. Refer to conformity advice on the cross-boundary issues associated with the growth of Redditch. 021/071f RSS Objective (f) to support Noted. Objective 10 will be None WMRA the diversification and retained and continue to modernisation of the Region’s support this RSS Objective. economy while ensuring that opportunities for growth are linked to meeting
296 needs and reducing social exclusion Strategic Objective 10 and Policies under the Theme ‘Economic Success that is shared by all’ support this objective. 021/071g RSS Objective (g) to ensure Noted. Objectives 1, 4 and 11 None WMRA the quality of the environment will be maintained and continue is conserved and enhanced to support this RSS Objective. across all parts of the Region Strategic objectives 1, 4 and 11 and relevant policies generally support this Objective. 021/071h RSS Objective (h) to improve Noted. None WMRA significantly the Region’s transport systems The relevant policies under the theme Stronger Communities generally support this objective 021/071i RSS Objective (i) to promote Noted. None WMRA the development of a network of strategic centres across the Region. The relevant policies in the Core Strategy relating to Redditch town generally support this objective. 021/071j RSS Objective (j) to promote Noted. None. WMRA Birmingham as a world city
297 Not applicable to this Core Strategy. 029/714; Glossary and Abbreviations: Noted. Reference will be made Make reference to PPS3 in the Tetlow King Welcome reference to to PPS3 in the glossary entry glossary entry for Affordable Government guidance on for Affordable Housing. Housing. affordable housing. A specific reference should be made to PPS3.
Where other guidance and The use of weblinks in the None standards are referred to, Glossary has been specific links should be investigated. However, Officers inserted, indicating where have reservations about this as these may be found to ensure weblinks can move and ease of reference for all. become out of date. 029/716; Throughout the Core Strategy, The submission version of the Take account of changes to the Tetlow King reference is made to the Core Strategy will be published RSS and reflect these in the emerging draft RSS Phase allowing sufficient time to submission version of the Core Two Revision which has not consider the RSS Panel Strategy. yet been tested at examination. Report. This should be closely monitored as changes may be made which will impact on a number of policies within the Core Strategy. Any changes should be taken into account and amendments made to reflect the RSS. 049/724; It is not always very clear how This approach will not be None.
298 Worcs CC the ‘What you told us’ and carried through to the Final ‘What the Sustainability Core Strategy. Appraisal suggests’ has been taken through in to policy. 049/748; Arrow Valley Country Park Noted. This will be changed for Consistently refer to ‘Arrow Worcs CC should be referred to the submission version of the Valley Country Park’ as consistently as such; not Arrow Core Strategy. Reference to opposed to Arrow Valley Park Valley Park or Countryside the Green Flag status of Arrow or Countryside Park. Refer to Park. This is important Valley Country Park will be the Green Flag status of Arrow because Country Parks have a made in Spatial Portrait. Valley Country Park within the particular status which Spatial Portrait. Redditch Borough Council should commit to maintaining - along with Green Flag. The Green Flag Award Scheme is the national standard for quality parks and green spaces and it should be referred to within the Core Strategy. 049/754; Stronger communities section: It is unlikely that the Ensure that the final Core Worcs CC in the third paragraph of the introduction as it is currently Strategy does not suggest that introduction, page 90, the worded will be carried forward the roads are the principal use wording may suggest that to the final Core Strategy. in the hierarchy. roads are the principal use in However, relevant reference the hierarchy. Although this will be made to make it clear issue is clarified in the that it does not mean roads are Transport section, this the principal use in the introduction could be reworded. hierarchy. 049/755; Why has the safeguarding of If there is evidence that None.
299 Worcs CC back gardens not carried development on back gardens through from Issues and should be restricted, a policy Options? No assessment has will be considered but this is been undertaken to say that now considered more areas don’t have special appropriate for a development characteristics which would control style of policy rather justify the protection of back than Core Strategy. gardens from development. Couldn’t proposals be considered on a case-by-case basis to determine specific impact, with a general policy against back garden development? None The initial decision not to If the only reason for not undertake the assessment was developing at different density taken following consultation standards (page 92, 2 nd with English Heritage and paragraph) for each District in advice that there are few Redditch Town is not distinctions between the undertaking an assessment, characters of different Districts why isn’t the assessment being in the Borough. The reasoned undertaken? If there are other justification for policy SC2 reasons for not undertaking the states that the Borough Council assessment, or not developing will apply the densities set out different density standards they in PPS3 as there is no should be made clear. justification for local deviations. In any case this is now considered more appropriate for a development control style
300 of policy rather than Core Strategy. 080/121; Land between the northern end Management o sites is not a None. Bladon of Tunnel Drive and the Core Strategy matter. The southern entrance to the old designation of this area as a railway tunnel should be Conservation Area is not improved and managed by an applicable in-line with National organisation like The Guidance in PPS15. Woodland Trust or Worcs Conservation Trust and developed into a proper conservation area or park. 088/535 It is difficult to tell from the Key As a key diagram is meant to Identify the boundaries of Natural Diagram where the identified be for indicative purposes only, strategic sites in the England Strategic Sites are. An OS map mapping the precise submission version of the Core backdrop or closer scale boundaries of strategic sites on Strategy for inclusion on the diagrams indicating locations the key diagram is not Proposals Map DPD. would be helpful. required. Site boundaries will be identified for the submission version of the Core Strategy in the proposals map DPD. 091/128; Welcome the Objective of Noted. None. West Mercia reducing crime and anti-social Constabulary behaviour and the fear of crime being recognised as relevant to three of the key themes. The recognition by the Council that reducing crime and the means to achieve this, is relevant
301 across its key spatial priorities reflects the approach advocated by PPS1. 101/143 Unable to access document on The Preferred Draft Core None. Bish the website. The whole thing Strategy and associate should be viewable in one documents were available on document as anyone giving the Council’s website for the feedback will want to know all duration of the consultation matters being considered and period 31 st October - 8 th May. can easily scroll down past anything they don’t want to comment on. None Why is the feedback form in a An e-mail address was format that cannot be filled in supplied for comments to be electronically, in order to save submitted electronically. paper? 110/174 Disagree with Core Strategy as Infrastructure requirements None a whole. Redditch in itself has related to the delivery of the inadequate facilities to support Core Strategy are currently the local communities now let being investigated and will be alone future development. included in the final version of Brockhill still has no district the Core Strategy and as part centre, health centre or school. of the Evidence Base to There has been no provision support the demonstration that made for the Brockhill area. it is deliverable.
Lack of hospital and leisure The Core Strategy includes None facilities. policies that support the
302 provision of new leisure facilities and new or improved health facilities. 127/199; Mrs Instead of developing new This is not a matter for the None M Shaw housing, it would, in the current Core Strategy. climate, be more cost effective and resident friendly, to purchase some of the houses that should not have been sold off in the first place. The council could buy the houses of people being evicted because they cannot meet mortgage payments and let them to the existing occupants to allow them to stay in their homes. 133/208; Tall buildings, especially in the Based on the views in None. Ceridwen John Town Centre, should be representations received considered as a good way of during the Core Strategy achieving our housing targets Issues and Options without using up more Consultation, it was decided greenfield land than necessary. not to develop a local policy on tall buildings but to rely on National Planning Policy, English Heritage and CABE guidance. 151/261; V The suggested redevelopment Noted. None. Wilcox and regeneration areas seem reasonable.
303 182/303 The number of houses quoted The number of houses required None is excessive for the Redditch/ to be accommodated in Bromsgrove areas, which are Redditch/ Bromsgrove is already built up. Much beautiful allocated by the West Midlands countryside has been lost to Regional Spatial Strategy. provide roads and housing estates. Redditch itself was designed to fit into a compact area which it has now filled. Other, disused land must be sought. 198/320; Sorry to see so many buildings Noted. The number of houses, None. Ridgeway going up in Redditch. All our amount of employment land, green fields will be taken up retail and offices required to be with brick buildings. Many accommodated in Redditch is properties appear to be empty allocated by the West Midlands either for rent or sale. Regional Spatial Strategy. 213/353 Glossary and abbreviations: Noted. Include ‘geodiversity’ in the Earth Heritage An entry defining geodiversity glossary of the Core Strategy Trust would be welcomed. with the meaning: Contraction of “geological diversity”. Geodiversity is the range of rocks, fossils, minerals, soils, landforms and natural processes that make up the Earth's landscape and structure. 263/438 Better Environment section: the Noted. The historic Include historic environment in English environment also includes the environment will be included in descriptions of the Borough’s
304 Heritage historic environment and this descriptions of the Borough’s environment. needs to be underlined in the environment. introduction, particularly with regard to the Borough’s landscape and rural areas. 267/577 The DPD makes reference to It was not within the remit of None Barton the Nathaniel Lichfield and the NLP report to consider the Wilmore Partners Report. Whilst no capacity of Redditch Borough. changes in respect of the This fact is evidenced in other numbers to be provided within RBC evidence base Redditch were proposed, we documents. highlight that there is no suggestion within the NLP Report that there is insufficient land within Redditch to meet the housing targets as set out in the emerging RSS. Given the extensive consultations with LPAs during the preparation of the report, it is fair to assume that any concerns would have been highlighted to the authors of the report at that stage. 267/578 There is no reference within The PDCS describes strategic Include ‘Strategic Sites’ in the Barton the Core Strategy as to what sites as per PPS12 as Glossary Wilmore constitutes a “Strategic Site” locations for strategic and this is not defined by development that are PPS12 either. considered central to the
305 achievement of the Core Strategy. A definition will be provided in the Glossary.
Note that Redditch have None. chosen to identify all proposed The strategic sites identified in allocations as “strategic sites” the PDCS are not all of and query whether all of these Redditch’s allocation, these will sites are “central” to the be identified in the Site achievement of the Core Allocations and Policies DPD. Strategy as set out in PPS12. The Strategic sites are central to the achievement of the Core Strategy Vision, and in particular, some of Redditch’s larger development sites are included because of the limited choices about where development can be located.
Open Space Needs Assessment
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Open Space 180/299 The former playing field at the After analysis of the GIS and Officers to contact respondent Needs rear of No. 96 – 108 (adjacent Open Space Needs for specific plan illustrating
306 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Assessment to Terrys Memorial Field) Assessment Officers are not open space referred to. should be recognised as Open clear on the exact location of Space due to its use by the the open space referred to. local community.
Policy SP.3
Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Policy SP. 3 021/ 074 Policy SP. 3 generally accords Noted. None. with published WMRSS Policies T1, T2, T3 and T5 in particular and other relevant emerging policies.
Policy SP.3 027/ 473 Support for Policy. Support Noted. The principles of None this Policy would still be incorporated in the Core Strategy however they will need to be repackaged. Policy SP.3 049/ 731 Paragraph (iii) of the reasoned A sentence will be included within A sentence will be included within justification should include the use this paragraph that makes the introduction to the Natural of Site Waste Management Plans. reference to the use of Site Waste Environment Policy which states Management Plans. that “The use of Site Waste
307 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Management Plans helps to support the facilitation of waste management processes that are in accordance with the waste hierarchy. Central Government sets out that a SWMP should be used on schemes over £300,000.”
The final sentence of paragraph This Policy has been amended Sentence to be included in the (ii) of the reasoned justification and these requirements now sit introduction to the Natural should be reworded as it fails to within the ‘Natural Environment’ Environment Policy which reads , convey ideas on composting and Policy. A sentence will be “The Borough Council supports recycling. included within the introduction to the ‘Waste Challenge’ initiative this policy which reads; “The which encourages waste Borough Council supports the minimisation by retaining waste at ‘Waste Challenge’ initiative which home through schemes such as encourages waste minimisation recycling and composting ”. by retaining waste at home through schemes such as recycling and composting ”.
The Waste Challenge is an initiative run by Redditch Borough Council, which seeks to reduce the amount of waste in the Borough. More information can be found on the Councils webpage.
308 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Recommend the inclusion of the This principle of Policy SP.3 is Insert sentence “protect and phrase ‘Green Infrastructure’ now contained within the ‘Natural enhance the quality of natural within Point (vi) of the policy Environment’ Policy. A sentence resources and green wording. will be included within this policy. infrastructure resources in the Borough including water, air, land, habitats and biodiversity” in the ‘Natural Environment’ Policy.
Within criteria (viii) the word Comment noted. The word Include the word ‘environment’ ‘environment’ should be included ‘environment’ will be included after the word ‘historic’ where this after the word ‘historic’. after the word ‘historic’ where this is deemed appropriate. is deemed appropriate.
Policy wording in (iv) conflicts with Policy wording in (iv) will be The Natural Environment Policy policy wording in BE.2 B, amended to reflect that in BE. 2 B, will read that “Every new recommended that wording in SP. as this is indeed the correct development will require the 3 (iv) is amended to reflect the wording. This text will be within inclusion of Sustainable Drainage wording in BE.2 B. Also the final the ‘Natural Environment’ Policy, Systems (SUDS).” sentence in paragraph (iv) of the which will replace Policy SP.3. reasoned justification should be The final sentence in paragraph The introduction to this Policy and amended to make clear that other (iv) of the introduction to the the Policy relating to Climate forms of SUDs exist. Natural Environment Policy will Change will state that “SUDS that make it clear that there are other use infiltration techniques are not forms of SUDs techniques suitable in Redditch due to the available. This text will be underlying geology; however included in the ‘Climate Change’ techniques that are appropriate Policy. use detention/ retention methods these include greywater recycling,
309 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. rainwater harvesting, green roofs, permeable surfaces, swales and ponds.”
Part (v) of policy wording should Policy SP.3 has been divided into None. reflect the wording in Policy BE.1 a number of other policies. With Climate Change. regard to the need for renewable energy production, this will be focused in the Climate Change Policy, in which the wording within BE.1 will be used.
Amend wording within paragraph This text has been moved into the Amend wording to reflect that (vi / vii) of the reasoned Introduction to the Natural suggested. The introduction to the justification to “to enhance and Environment Policy, the Natural Environment Policy will maintain statutorily and locally suggested wording will be read “to enhance and maintain designated historic assets incorporated into this. statutorily and locally designated (historic buildings, historic historic assets (historic buildings, landscapes, including historic landscapes, including Conservation Areas, and Conservation Areas, and archaeological sites)”. archaeological sites)”.
Also it is unclear why paragraphs It is considered that points (vi), Points (vi), (vii) of the Reasoned (vi) and (vii) in the reasoned (vii) have been addressed Justification will be considered justification are grouped together. separately within the reasoned separately within the introduction justification but put in the same to the Natural Environment Policy. paragraph. This will be amended in the Submission Core Strategy;
310 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. both points are considered in the Natural Environment Policy.
It is also unclear where point (viii) It is considered that Point (viii) of None. of the policy has been addressed the Policy does not need to be in the reasoned justification. addressed in the Reasoned Justification as there is nothing more to say with regard to this aspect of the policy.
Policy SP. 3 088/ 534a Support the inclusion of defined The principles of the Sustainability None. sustainability principles within the Principles Policy have remained in Core Strategy. the Core Strategy, however these have been repackaged into a number of other policies for example the Climate Change Policy and the Natural Environment Policy.
Policy SP. 3 088/ 534b Recommend reference to existing The Regional Sustainable Ensure the Regional Sustainable sustainability frameworks, Development Framework was Development Framework informs including in particular the considered when preparing the the ‘Green Strategy’ Technical Regional Sustainable policy and has informed the Paper and in turn the content of Development Framework and the technical papers which in turn the policy. West Midland’s Sustainability inform the policy. Checklist. The West Midland’s Sustainability Checklist features more heavily in
311 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Policy BE. 1 Climate Change in which it is required to be considered and does not warrant repeating in Policy SP. 3.
Policy SP. 3 088/ 534c We recommend that point v Sustainable design and None. “incorporate sufficient renewable construction policy has a number energy production facilities and of principles within it which need principles of sustainable design to be applied to new and construction” be amended to developments in Redditch. One of focus solely on energy and these principles focuses on climate change – sustainable renewable energy production. construction is covered under point iii. It is necessary to consider sustainable construction in number of policies, as combating climate change is a key theme within the Core Strategy.
Policy SP. 3 088/ 534d Point v should reflect the energy It is considered that the energy Incorporate the principles of the hierarchy by requiring all hierarchy should be incorporated energy hierarchy into the Climate proposals to reduce energy within the Core Strategy as the Change Policy. demand and incorporate energy energy hierarchy is important to efficiency measures, as well as to reduce energy use first in new include sufficient renewable developments. It is considered energy production. that the Climate Change Policy is the most appropriate location for implementing the energy
312 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. hierarchy. Policy SP. 3 088/ 534e With regard to point iv, due to It would be appropriate to detail Include, in the introduction to the underlying geology of the the techniques of SUDs that are Climate Change Policy techniques Borough, infiltration techniques for appropriate in Redditch. It is of SUDs are appropriate for use in SUDs are impractical. The range considered that the most the Redditch circumstance. For of SUDs is very wide, including appropriate location for this detail exact wording see response to swales, reed beds, permeable will be detailed in the introduction 049/731. paving and green roofs. It would to the Climate Change Policy. be helpful to clarify what types of SUDs may be practical in the given circumstance.
Policy SP. 3 O88/ 534f Point vi reflects the consideration It is considered that it would be Split up water, air and soil as one of Strategic Environmental appropriate to split the issues of point and biodiversity and Assessment, which are water, air and soil and biodiversity landscape as another. Principles welcomed. However, the issues and landscape into two separate in Natural Environment Policy to around the different subjects points to clarify the policy further. read “protect and enhance the within this are likely to vary These principles now come under quality of natural resources significantly. It is recommended the Natural Environment Policy. including water, air and land.” And that the protection and, where “Protect and enhance habitats possible, betterment of water, air and biodiversity.” and soil become one point, with the protection and enhancement of biodiversity and landscape as another
Policy SP. 3 O88/ 534g The justification around It is considered that a full Include a full definition of biodiversity should include definition of Biodiversity will be Biodiversity in the Glossary which
313 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. protected species, BAP priority provided in the Glossary to the reads “The Biodiversity Action habitats and species and Core Strategy and therefore the Plan (1994) defines Biodiversity ‘everyday’ biodiversity, as well as aspects will be considered there. as “the variety of life forms we see designated sites. around us. It encompasses the whole range of mammals, birds, reptiles, amphibians, fish, insects and other invertebrates, plants, fungi, and micro-organisms such as protists, bacteria and viruses”.
The term biodiversity should be The term Biodiversity will be The following will be included in taken to include habitats, and this explained within the glossary. the introduction to the Natural does not have to be repeated. Environment Policy. “There are a Terms such as biodiversity could range of nationally and locally be defined in a glossary to avoid important sites of biodiversity confusion. within Redditch Borough which should be maintained and strengthened through the actions of Local Authorities and other.”
Insert the following definition of biodiversity within the Glossary, “The Biodiversity Action Plan (1994) defines Biodiversity as “the variety of life forms we see around us. It encompasses the whole range of mammals, birds, reptiles, amphibians, fish, insects and
314 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. other invertebrates, plants, fungi, and micro-organisms such as protists, bacteria and viruses”. There are a range of nationally and locally important sites of biodiversity within Redditch Borough which should be maintained and strengthened through the actions of Local Authorities and other.”
Policy SP. 3 088/ 534h Advocate the inclusion of a The importance of the None. requirement to contribute towards components of Green green infrastructure. Infrastructure is a key theme that runs through the Core Strategy, therefore it is considered in a range of policies. Support noted. Policy SP. 3 091/ 131 There is no reference in policy to Policy SP.3 does not exist in this None. providing the general form in the Core Strategy, infrastructure required to support however many of the principles of a development. the policy have remained and are contained within a broader ‘Natural Environment’ Policy; it is considered that it would not be appropriate to refer to infrastructure requirements within this natural environment policy. However, infrastructure is very
315 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. important to the delivery of the Core Strategy and therefore is a key theme that is referred to throughout the document.
There is no reference to the As stated above as this policy None. Sustainable Communities now takes the form of the ‘Natural Strategy theme of ‘Safer Environment’ Policy it is not Communities.’ deemed appropriate to refer to the ‘Safer Communities’ theme, this theme is considered significantly in other areas of the Core Strategy.
Policy SP. 3 212/ 351 Objective vi) (protect and Please see response to 049/ 735. Please see action to 049/ 735. enhance the quality of natural resources) is welcomed; however geodiversity should be listed alongside biodiversity in this context.
The supporting text on page 30 Agreed. Insert principle into the Natural should go further to say that Environment Policy, which states, decisions on development and “All development schemes in the land use will be assessed against Borough will be expected to their integration of and benefits to, integrate with and enhance biodiversity and geodiversity. biodiversity and geodiversity.” Policy SP. 3 262/ 407 Support for Policy. Support noted. The principles of None.
316 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. this Policy are still contained within the Submission Core Strategy however they have been repackaged. A number of the principles are contained within the ‘Green Strategy’ of the Core Strategy, while the remaining principles are contained within the Delivery Strategy. Policy SP.3 093/ 490 Waste Efforts should be made to reverse It is considered that these None. the growth in waste, recover the processes, although sustainable, maximum resource value from the are outside of the remit of the waste produced, and accelerate Core Strategy. progress in delivering increased waste management capacity.
The consideration of commercial It is considered that by requiring None and industrial waste is essential. new development to consider the Waste collection systems which waste hierarchy that the Core aim to minimise waste at source Strategy promotes, as much as should be adopted throughout the possible, the need to minimise Borough. Waste minimisation waste. should also be incorporated.
The WEEE Directive 2002/96/ EC These two directives have been None. and 2003/ 108/ EC should be reviewed and it is considered that included in the list of relevant there are no implications for the
317 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. plans. Core Strategy.
The LDF Framework should be The Scoping Report is reviewed None. regularly updated as more annually. Development Plan information becomes available. Documents are reviewed whenever it is deemed necessary.
Water management
Point iv needs to be amended so Since the production of the None. that the words ‘where possible’ Preferred Draft Core Strategy the are removed to make the Strategic Flood Risk Assessment requirements for SUDS and Level 1 has been finalised, this methods for water efficiency document states that SUDS stronger and that reference is techniques must be used. The made to achieving betterment to document goes on to detail the the flooding regime. Suggested SUDS techniques that would be wording might be ‘not increase suitable for use in Redditch. The the risk of flooding in the site or findings from this document will elsewhere, seeking betterment to be incorporated into the the flooding regime, and Submission Core Strategy. incorporate SUDS and other methods of water efficiency.’
It is acknowledged that overall the The Submission Core Strategy None. underlying geology of the area can make reference to the need may not be conducive for SUDs; for all sites to use SUDs
318 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. however any site brought forward techniques and refer to the for development should have methods of SUDs that are suitable undertaken a more detailed site in Redditch. investigation to inform SUDs techniques, with all appropriate techniques considered.
Contaminated Land
Point Vii should be amended to This Policy will be split up, Amend text to read ‘where read ‘where required’ instead of however where appropriate the required’ instead of ‘where ‘where appropriate’. text will be amended in line with appropriate’. recommendation.
Reference could be made to Any new development or proposal None. Table 2.1 In Annex 2 of PPS23. in the Borough is required to be in accordance with all national planning policy; therefore Table 2.1 in Annex 2 of PPS23 will be required to be considered. Policy SP.3 102/ 148 Criteria (viii) should state to This will be included elsewhere in None. ‘protect and enhance historic the Core Strategy. environment and cultural heritage…’ As one of the definitions of historic environment is that it is not limited by cultural associations.
319 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Policy SP.3 263/ 435 Welcome the inclusion of part Support noted. None. (viii) as part of this policy.
103/164(a) The requirement to improve the The location of the bus routes is None. quality of water, air, soil and water not within the control of the resources would be best achieved Borough Council; it is under the by a complete overhaul of the bus control of private transport routes to reduce congestion. companies, although the Council do advise the Bus Companies on where they think bus routes should be considered.
The construction of two major The need for water infrastructure None. water holding areas adjacent to in the Borough has been the River Arrow, and a facility to considered by a Water Cycle compost waste and add it to the Study and via discussions with the remaining agricultural areas as an water infrastructure providers. alternative to fertiliser. Composting is a sustainable approach to waste management ad is continually promoted by the Waste Management Department within the Council. The Core Strategy cannot require composters to be provided as this is too detailed for the Core Strategy.
320
Procedural
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. 028/104; Concern that the Core Strategy The vision has emerged with Amendments to the vision GOWM does not set out a strategy for eight key strategies, 13 and other miscellaneous the development of Redditch objectives and are these are amendments to the style of but contains a number of carried forward into strategies the relevant policies in the criteria based, development forming the core policies which Core Strategy. control policies, more include: appropriate to old style local • Green Strategy plans, due to the topic based • Enterprise and Skills approach. Recognise that there Strategy are elements of a strategy in • Retail and Centres Strategy some of the policies but they • Sustainable Settlements need to be brought together in Strategy order to provide a coherent • Balance Between Housing approach to delivering the and Employment Strategy vision. • High Quality and Safe Design Strategy • Attractive Facilities Strategy
• Historic Environment
Strategy
• Infrastructure
321 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. The strategies that have been developed incorporate previous draft policy provisions but have been redrafted so that there is a shift away from the development control based policy and so that a coherent approach to delivering the vision is achieved in accordance with PPS12. Prepare Infrastructure The Preferred Draft Core Delivery Plan. A fundamental element of the Strategy included a draft Delivery LDF system is its emphasis on Strategy, and it is the intention of delivery. The Core Strategy Redditch Borough Council to should, therefore, have a restructure this and to positive approach, setting out supplement with information what is proposed for the currently being assembled Borough and how it is to be through a series of detailed implemented in order to infrastructure delivery meetings. achieve the vision. The Delivery Strategy is intended to be accompanied by a comprehensive Infrastructure Delivery Plan (IDP) which will be updated annually and monitored. Review policies to ensure that there is no unnecessary There is a spatial vision which is repetition.
322 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. Concerned that the criteria in locally distinctive, reflects the many policies are simply things that are special about restating regional or national Redditch, implements the spatial policies. Generic DC policies aspects of the SCS and is in may be appropriate in a Core general conformity with the Strategy but they need to be WMRSS and in line with national locally distinctive. policy. The Council will review policies against the WMRSS to ensure that there is no unnecessary repetition. 028/108; There is a significant risk that Officers continue to liaise with Amendments to the vision GOWM proceeding with the document GOWM to overcome these and other miscellaneous in its present form would lead concerns. amendments to the style of to it being found unsound. As a the relevant policies in the minimum, substantial Core Strategy. presentational changes are necessary but there are probably underlying issues which need to be addressed. 042/461; Because of the Council’s RBC has taken a proactive No change Stoneleigh reluctance to address the issue approach in presenting of housing and employment alternatives to the designations of land provision in full, and, in land for housing and employment particular, cross boundary uses based upon the latest growth, real progress in the evidence available; therefore it is
323 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. Core Strategy will be delayed not accepted that there has been until, at the earliest, the any reluctance to address the publication of the EIP Panel issue. Report into the Phase Two Revision. This approach is contrary to the advice set out in PPS12. The short delay is not related to No change. The Core Strategy will not be any inadequacies in the achieved in a timely and approach. The Core Strategy will efficient manner (as stated in respond to the RSS Phase Two PPS12) because of the Panel report issued in September approach currently taken 2009. toward the identification of development land. This will result in unnecessary delay in the delivery of new homes and land for employment and inward investment in new jobs, required to meet both local and sub-regional needs. Agreed that the Core Strategy Redraft cross-boundary should set out how the cross elements of the Core Because there are no boundary growth would be Strategy. arrangements in place to accommodated in broad terms. produce a Joint Core Strategy between the three ‘affected’
324 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. LPAs, the PDCS should, at the very least, set out how the cross-boundary growth of Redditch might be accommodated and delivered. This would be consistent with the advice in PPS12 (para 4.46) which states that Core Strategies should show what ‘alternative’ strategies have been prepared to deal with the uncertainties surrounding the deliverability of the strategy. 042/464; The current LDS anticipates The Core Strategy will respond to No change. Stoneleigh consultation on the Submission the RSS Phase Two Panel report Core Strategy will take place in issued in September 2009. It was October/November 2009. considered timely to consult on However, the PDCS states that the WYG study alongside the the cross boundary Preferred Draft Core Strategy so requirements are to be that comments could be made determined via the EIP into the comprehensively. Phase Two Revision of the RSS with the subsequent published strategy is unlike to emerge before Spring 2010.
325 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. That would delay the Submission Core Strategy by six months notwithstanding that consultation on the recommendations on the WYG study could have been undertaken now with the opportunity to reflect those consultations in responding to the Secretary of State’s proposed changes to the Phase Two Review. 042/465; PPS3 & PPS12 encourage the The site boundaries of any SUE Redraft cross-boundary Stoneleigh consideration of options or were not determined at the time elements of the Core alternatives in the preparation of publishing the PDCS. In terms Strategy once the Panel of LDDs. PPS3 encourages of the scale and range of uses Report for the WMRSS has early dialogue with appropriate for any SUE, an been received (due Sep/Oct stakeholders, developers and indicative figure for residential 09) infrastructure providers about development and associated these options and the most infrastructure as well as potential appropriate strategy for growth. employment land was provided in The Council have the the introductory sections. These opportunity through the Core figures were however based Strategy to do this. The PDCS upon the WMRSS Phase Two does no more than indicate, in Revision requirements in the
326 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. general terms, on the Key Preferred Option Document Diagram the preferred direction (2007) and on the estimated for growth without giving any SHLAA capacity of the Borough. information about the scale of The programme of development development, the range of will be indicated once the precise uses to be included in any implications of a SUE are scheme and the programmed investigated further. development of the site to ensure that the requirements for housing and employment land are met. Procedural 044/118; Shire Policies in the emerging Core Comments noted however this is consulting c/o Strategy or any DPDs must be already an adopted plan policy Barclays Bank founded on a robust and and isn’t within the emerging core credible evidence base strategy policies. (PPS12). Neither the Local Plan nor the background documents to the LDF appear to contain evidence for the choice of percentages for the non-A1 uses specified under the saved policies of the local plan (PPS6) and approach must change. No planning reason to restrict Bank's
327 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. presence at ground floor level in primary shopping frontage. Encourage flexibility to allow changes of use between A1 and A2. Procedural 104/001; (In specific reference to WYG At the time of the Preferred Draft Hold a joint consultation RPS Studies) The evidence base is Core Strategy being prepared period with Bromsgrove incomplete in that it has not and issued for consultation, it District Council on the assessed the full range of was not considered possible to potential locations for cross- strategic development include land within adjoining boundary development. alternatives available. A core Bromsgrove District within strategy based on this study Redditch Borough's SA or Core will be found unsound against Strategy. A joint consultation PPS12; it will have prejudiced period will resolve issues stakeholder interest. associated with these constraints.
Retrospective assessments are Confirmation has been received not appropriate, nor indeed from Natural England that the None permitted in respect of the Habitats Directive has been Habitats Directive. (para 7.10) adhered to and that the Screening identified that a full Appropriate Assessment would not be required. There have been no retrospective assessments.
328 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. The Sustainability Appraisal is The SA process has been extremely weak and not undertaken by strictly applying None. comprehensive enough to be the provisions of guidance considered a SA report. contained in Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents. The Borough Council has taken a practical approach to the SA process, by screening against the SA alongside each Core Strategy stage to give an indication of the likely significant effects associated with different options or approaches and also by taking the further step of attempting locational SA, usually only required as part of EIA of sites. 104/003; Developers and their agents It was important that the No change. RPS were not made aware that the consideration of all possible WYG Phase 2 study had been development options was not commissioned despite previous constrained. This would have involvement in the process. It is been the case had the WYG Joint noted from the project brief for Study considered the site the consultants that no development boundaries of
329 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. consultation was intended on options put forward by this report. Disappointed that prospective WYG did not take up the offer developers/landowners. It is to discuss proposals for North therefore appropriate that the West Redditch. Received WYG study did not consider the advice from WYG that they specific area noted as the North were not opening discussions West Urban Extension in with interested parties in an isolation. Consultation on the effort to remain impartial and to report has been included, despite provide independent advice. it not being required. 104/025 Refers the Council to para 3.31 Respondents have raised an Re-draft cross-boundary RPS of ‘Using evidence in spatial important matter, and it would be elements of the Core planning’ (2007) regarding expedient to respond to Strategy. judging the adequacy of the paragraph 3.31 directly, which evidence base. RPS is of the states "This is unlikely to be a opinion that the Council’s matter that guidance can ever evidence base is demonstrably prescribe exactly. Inspectors’ not significant. reports will provide useful illustration, but this is also a matter for professional judgement. What is clear is that confidence cannot come entirely from answering the question, “Have we enough evidence to proceed to the next stage?”, but
330 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. has also to be informed by looking back and asking “Is there sufficient evidence for the position we are taking?” Evidence cannot be used instead of judgement; it must be used as a knowledge base to inform judgement. It is essential that ‘sufficient’ is considered not just in terms of quantity but in terms of its quality and ability to stand up to rigorous testing." Redditch Borough Council reiterates that at all stages of the development of the Core Strategy that the best available evidence has been used to inform either the range of options or the preferred approach. The evidence from WYG at the time of the preferred draft core strategy being published was the most comprehensive evidence available for informing choices regarding development options. At the time of the issues and
331 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. options the evidence available suggested that the ADRs would be the Borough Council's only alternative development options to make up for the identified shortfall of development found within the urban area. The Council accept that the WYG recommendations contrast with the previous findings in the Analysis of GB Report but having reviewed these and previous findings, the Council concluded that there are cogent reasons for this latest independent assessment and that the recommendations contained in the Stage II Report relating to Bordesley Park can be given significant weight. 104/038 The Council has failed to Alternatives have been assessed None RPS undertake a comprehensive through the Issues and Options and robust approach to stage and in the accompanying identifying and appraising SA Report; when informing the strategic options and preferred options and in the
332 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. alternatives. The current accompanying SA Report and approach is therefore unsound also when evaluating evidence as and a detailed assessment of it becomes available. strategic alternatives should be undertaken prior to the submission of both Core Strategies. 104/039 All reasonable alternatives See response to 104/038 RPS should be subject to full public consultation and a comprehensive SA incorporating SEA. Failure to assess and present this appraisal information to stakeholders along with illustrating by way of a thorough paper trail, the manner in which the preferred option has been selected with regard to alternative options, is unsound. 104/048 The Council is duty bound to Further consultation is planned No change. RPS undertake and additional round for February - March 2010 jointly of consultation on the strategic between Bromsgrove and options for Redditch before Redditch.
333 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. Submission of the Core Strategy in order to achieve the specificity it requires. 200/325 Disappointed and unamazed The Core Strategy Consultation No change. Orme that residents of Hoveton Close has been advertised in a number have not been formally advised of ways including the Local of RBCs plans to deprive Press, Council notice boards and Greenlands residents of Public a cinema advert. The SHLAA Amenity Space and only found document has been available on out by chance. the Council’s website for the duration of the consultation period. A list of all SHLAA sites not in public arena was included in the Spring 2009 edition of the Council Magazine ‘Redditch Matters’. 220/361; Proposals in the SHLAA to the See response to 200/325 No change. Forbes rear of Hoveton Close have not been advertised in the areas where the majority of people will see it. 262/416; The White Young Green Stage SA of background No change. HCA II report is not accompanied by documents/evidence is not an appraisal of the required. The WYG Second sustainability credentials of Stage Report is accompanied by
334 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. each of the growth options for a simple SA matrix which builds Redditch carried out using the upon the draft SA completed for sustainability criteria set out in the Core Strategy. The SA matrix the RSS. accompanying the WYG Report does not purport to be a formal assessment as it does not relate to either a plan or programme. However it was produced to provide a basis for assessing and understanding the sustainability implications of development in different locations. 267/576 The LPA has failed to identify The housing requirements as set Redraft Housing Barton Wilmore sufficient land within its out in the forthcoming WMRSS requirements policy to refer boundary to meet housing will be identified in the Core to the allocation of targets as set out in the Strategy. residential development from emerging RSS. Consider that the WMRSS. the proposed approach is inconsistent with the emerging RSS and therefore does not comply with Sections 19 (2)(b) and 24 (1)(a) of the Planning and Compulsory Purchase Act 2004. This is inevitable given the limited Re-draft cross-boundary
335 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. Suggest that the proposed capacity within the Borough and elements of the Core redistribution of housing figures because of the implication of the Strategy. to outside the Borough Phase Two WMRSS. boundary is not justified by credible evidence and is therefore unsound. RBC has assessed the relevant alternative options in the SA. No change. With reference to Section 19(5) of the Planning and Compulsory Purchase Act 2004, the SA accompanying the Core Strategy fails to provide an adequate or balanced assessment of alternative options. As such there is insufficient evidence to demonstrate that the Preferred directions for growth are more sustainable than the ADRs or any other sites within the Borough boundary. 267/584 The DPD is not backed up by The Green Belt and ADR Study No change. Barton Wilmore robust or convincing evidence. undertaken by the Borough The evidence is contradictory, Council does not pertain to be an with no justification for assessment of suitability; the
336 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. preferring the conclusions of nature of this document differs one document over another. from that of WYG 1 and WYG 2. All evidence will be used to help to justify a preferred option. 267/585 It is clear the document is not It is not clear what aspect of the No change. Barton Wilmore based on fact and that the Core Strategy is factually assumptions made are not incorrect. The policy stances of reasonable or justified, the Preferred Draft Core Strategy particularly in light of a report reflected the most up to date (Green Belt/ADR Study) which evidence base information. The confirms the Council’s Study referred to by the previously held view that land respondent is a review of the at Webheath is suitable for history of relevant sites. development. 267/589 The emerging DPD is contrary The housing requirements as set Redraft Housing Barton Wilmore to PPS3 in that it fails to out in the forthcoming WMRSS requirements policy to refer provide sufficient land to meet will be identified in the Core to the allocation of its housing requirements. The Strategy. residential development from Council has stated that there the WMRSS. are more suitable sites for development within Bromsgrove District, however this does not absolve the Council of its responsibility to meet its housing requirements.
337 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. There are sites within the Borough which meet the tests of paragraph 54 of PPS3 in terms of their suitability for housing and as such these sites should be considered in advance of land outside of the administrative boundary of the Borough. 267/590 The Core Strategy document There is no recognisable flaw in No change. Barton Wilmore as a whole is unsound as it the Core Strategy based upon does not meet any of the tests the tests of PPS12. The Core of PPS12. On the basis that Strategy will be progressed and the development strategy and submitted in confidence that the underlying principles are tests of soundness are met. fundamentally flawed, we do not consider that the Core Strategy can be progressed in its current format. 267/591 Barton Surprised at the weight A decision was made to use No change. Wilmore attributed to the WYG Report WYG conclusions to inform what given its self-evident flaws. was consulted upon in the Preferred Draft Core Strategy as an alternative strategy which was the most up to sate evidence
338 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. available at the time. Weeks before publication of No change. the Core Strategy Redditch Evidence available to Redditch Borough Council advised that Borough Council before the WYG the Webheath ADR would be Report indicated that all of its included as a strategic site. ADR sites would be suitable for development, hence it being presumed so at Core Strategy Issues and Options Stage. The Council have given No change. insufficient time to properly Redditch Borough Council must consider conclusions of WYG take account of the latest and the report and its implications for most comprehensive evidence the wider regional area. available which was the WYG Report. If Redditch Borough Council ignored this evidence and it was not use to inform the Core Strategy, the alternative development scenarios would not have been consulted upon. There is sufficient time to consider all comments, new evidence and the outcomes of the WMRSS Phase Two Panel Report. 267/592 Barton An offer was made to supply all WYG Report was intended to be No change.
339 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representation No. Wilmore relevant information to WYG a completely independent relating to Webheath ADR to comprehensive assessment. Also enable a comprehensive it was important that the review to be undertaken, but consideration of all possible the offer was turned down. development options was not constrained. This would have been the case had the WYG Joint Study considered the site development boundaries of options put forward by prospective developers/landowners. 267/595 Barton WYG Report - There is There are no identified No change. Wilmore inconsistency in approach and inaccuracies in the WYG Report. conclusions inaccurate. Balance towards Bordesley It is accepted that the report No change. Park and Foxlydiate Woods focuses on the Bordesley Park sites suggests the conclusion option as the preferred option has informed the report rather and Foxlydiate Woods as an than the report leading to the alternative option, presumably conclusion. Do not consider because there was certainty over that weight can be attached to these locations being the most the document. It cannot form a preferable after considering the basis for a development constraints on all sites. strategy.
340
Retail
Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action 017/240 CPRE approve of the Noted None following policies - Strategic Sites, Regeneration of Town Centre, Policy SP4 and District Centre Redevelopment, Policy SP5. 021/075 Policies SP4 and SP5 Noted None accord with emerging WMRSS policies PA12A and PA13 respectively. SP4 also aligns with published WMRSS Policy UR3. 021/087 ES5 accords with Noted None emerging WMRSS policies PA1 and PA12B 021/088 ES6 generally accords Agreed Amend Policy ES6 to with emerging WMRSS make clear that the floor Policy PA12A but the space requirements are Core Strategy Policy for the Town Centre should be explicit that which is the preferred
341 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action the Town Centre is the location from; preferred option for this floor space. The Borough Council seeks to plan for approximately 30,000sqm of comparison floorspace for the period up until 2021 and aim to make provision for an additional 20,000sqm floorspace between 2021 and 2026.
to;
The Borough Council seeks to plan for approximately 30,000sqm of comparison floorspace for the period up until 2021 and aim to make provision for an additional 20,000sqm floorspace between
342 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action 2021 and 2026 within the Town Centre.
021/089 ES.7 (A5 uses within Noted. A5 uses within None District Centres) is not of the district centres and regional significance the cumulative impact of these uses are a locally distinctive issue for Redditch and therefore should be monitored through a Core Strategy Policy 024/109 Well written – support for Noted None phasing of development in the Town Centre 044/117 Supports intentions set Comments are noted None out in ‘Economic however there are no Success that is shared policies within the core by all’ however strategy that specifically concerned that the draft relate to the restriction policy approach fails to of A2 Uses within Town reflect the important role Centres. Local Plan played by financial Policy E(TCR).5 does services retailers in not restrict financial promoting vitality, uses completely underpinning Town however merely controls Centres and assisting in the number of uses
343 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action regeneration. Local Plan within the primary retail Policy E(TCR).5 restricts area. financial uses in the town centre however circular 03/2005 states the financial services sector is’ very much a part of the established shopping street scene, and which is expanding and diversifying…..(being)….. uses which the public now expects to find in shopping areas’ Supported by WYG study. This approach should not continue in the core strategy as it goes against government and borough objectives. A2 users can provide a high level of investment in, and maintenance of their premises resulting in attractive and active street frontages that can
344 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action also foster significant footfall and pedestrian activity therefore benefiting the town centre. 080/119 Land at Edward Street The Edward Street Site None would be an ideal site for is currently covered by ‘Redditch Heritage Policy E(EMP).5 in the Museum’ with a small Borough of Redditch urban park and facilities Local Plan No.3 which for coaches. states that the site should continue to be used for employment purposes and where this is not economically viable then housing could come forward. The Retail and Leisure Needs Assessment recommends retail use on the site only if other named sites in the Town are found unsuitable for retail. Therefore using the site as a Heritage Museum would be contrary to current
345 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action planning policy. 085/520 Supports the strategic Whilst the Borough No change vision and objectives Council agrees that this however objective 8 is important, there are should acknowledge the many contributory importance of improving factors that would established retail improve the vitality and facilities within the town viability of the town centre, including the centre which cannot all kingfisher through be referenced in a core investment and strategy objective. complimentary development. The retail needs of the town should be properly understood, WYG study should be supplemented by a market focussed assessment of retail provision in the town, particularly in respect of comparison retailing. 085/521 Recognise that the town Agree with the Seek to implement centre is part inward respondents comments Town Centre Strategy looking and poorly about the Town Centre. priority projects and connected. Long term It is important to note actions. strategic initiatives that the Council has an
346 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action should be explored to adopted Town Centre Revise Town Centre improve connectivity Strategy which broadly policies to take on board between the key areas includes the following; the Town Centre and the prominence of Strategy the retail core. Short to • Analyse recommendations. medium term external information from signage should be the Retail and Revise the vision to take considered and Leisure needs into account the Town improvements to the survey of the Centre Strategy external treatment of the Borough recommendations. shopping centre. • Make recommendation s based on the above survey, having regard to relevant national, regional and local planning policies and guidance as well as emerging Council priorities and Town Centre initiatives • Articulate a vision for the Town Centre and establish a
347 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action common goal which will guide development and growth • Establish an Action Plan to implement the Strategy
The study identified a number of short term ‘wins’ and more long term strategic objectives. More detailed information regarding the above can be found in Section 8.5 Priority Projects and Actions of the Town Centre Strategy. The vision for the Town Centre is therefore well established and this can be reflected in the Core Strategy.
085/523 Supports the principle of Comments are noted None
348 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action identifying strategic however a balance of development sites uses is needed within however the core the town centre, stating strategy should not that all uses could be prescribe limited land allowed would uses for each site within undermine the Centre. the town centre, it should Reference to identifying state that any number of a clear need and town centre uses are demand would be a appropriate. Car park 4 repetition of National is capable of being Planning Policy in developed for a number PPS4. of uses and convenience retailing should be directed there prior to Church Rd/North West Quadrant – areas which are dislocated from the comparison offer. The document should acknowledge that all new retail development should satisfy a clearly identified need and demand. 085/526 It’s considered that the Noted. The amount of None. recession will have a retail to be
349 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action negative affect on future accommodated in retail spending. Consider Redditch is allocated by that the comparison floor the West Midlands space figure identified in Regional Spatial Policy ES6 will Strategy. The evidence overstretch retailing in in support of this the Borough and requirement included a adversely impact on the refresh to the Regional health of the retail core Centres Study which and surrounding centres. took account of current CS should acknowledge economic positive role investment circumstances. The in the Kingfisher centre Hierarchy of Centres can play and the centre promotes the Town should be promoted and Centre as the preferred recognised as an location for main Town appropriate location for Centre uses. further retail development if proven to be appropriate. 088/536 Supports Policy SP4. Noted Amend policy SP.4 Welcomes the promotion from; of accessibility and recommends that priority promote excellent is given to sustainable accessibility by a modes of transport range of transport including walking and modes, incorporating
350 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action cycling. any necessary infrastructure improvements
to;
promote excellent accessibility by a range of sustainable transport modes, incorporating any necessary infrastructure improvements
088/537 Welcomes Policy SP5 Noted however the None however the policy could policy at present be more positively actively promotes the worded to actually regeneration of centres. promote the regeneration of the centres. 088/538 Policy SP6. Welcomes Noted None requirements for sustainable access links and open space provisions. Within the
351 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action context of Green Infrastructure connections to Arrow Valley Park and Local Nature Reserves to the west should be promoted and enhanced as a means of securing multi functional benefits. 088/552 Supports Policy ES5 Noted None 088/553 Supports Policy ES6 Noted None 089/517 Objects to the wording of Comments noted. An Look at the rewording of Policy SP4. The Policy additional policy Policy SP.4 to include should address objective specifically relating to elements of Policy ES.5 6 together with the 4 A5 uses within centres and to reflect objective parcels of land. Suggest is also contained within 8. the elements in Policy the Core Strategy. ES5 Tier 1 associated with Town Centres are reflected in Policy SP4. To reflect objective 8 the policy should also contain a section on evening and night time economy to establish guidelines for a subsequent Area Action
352 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action Plan to improve and manage by controlling location and types of licensed premises and hot food takeaway to ensure harm is not caused to the neighbourhood. 091/132 WMC welcomes part iii Noted None of Policy SP4 regarding safe and well designed places and buildings as it is fully in accordance with the guidance contained in PPS6. 091/133 WMC endorses the Noted None requirement of Policy SP5 that all redevelopment proposals for new town district centres must design out crime and make the district centres feel safer. 093/494 Any consideration of Noted. As part of any Review sites potential development on the development proposal for water and foul Woodrow Strategic Site these issues will be drainage problems in should take account of investigated at the the SFRA Level 2 and
353 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action all the site and Planning Application WCS refresh. immediate proximity in stage. If issues are terms of environmental identified on site infrastructure such as following more detailed water and foul drainage. investigation in the Water Cycle Strategy refresh and Strategic Flood Risk the measures required for mitigation would be detailed in the policy and considered when assessing the deliverability of the strategic site. 099/142 Developing retail These are Town Centre None units/food outlets in the uses appropriate in area of Church Rd/North these Town Centre West Quadrant is not locations. There is a sustainable. People need and demand won’t walk outside the identified for these uses Kingfisher Centre to in these locations. shop and the lack of retail units near to the theatre and Town Hall would appear to confirm Should housing come this. forward on these sites,
354 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action dependent on the size Developments nearer to there will be an element the Town Centre such as of social housing Edward Street and included along with Church Rd should be green architecture to aimed at families who ensure efficiency. cant afford to buy properties such as low cost fuel efficient flats to rent 103/159a RLNA argues that food It is agreed that None. stores should be trading convenience offers company average sales would be preferable at density. If this isn’t the within or adjacent to the case then competition is Town Centre. The study necessary and this has considered the should be located close supermarkets with to the town centre. The extensions and study does not take into mezzanine floors and account Tesco or the fact those with permissions Tesco and Sainsbury’s for such extensions. have had permissions for There is no evidence to mezzanine floors. In suggest that Marks & addition the study does Spencers turnover in not address why M&S comparison to that of has half the turnover of Tesco Express differs, Tesco Express in Lodge indeed it is not within
355 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action Park and why Aldi and the remit of the Retail Lidl stores are not Needs Assessment to fulfilling this perceived detail this. need. Any new retailer would be located in a similar position to these two stores therefore they would have a right to claim the intro of another store would prejudice the current viability of the town centre. 103/159b On page 58 of the RLNA Capacity assessment None no statistical basis given will be updated regularly for the claim that the as new information and growth of internet forecasts are shopping has peaked. issued to ensure low Current financial growth and high growth conditions are likely to scenarios are as increase in internet accurate as possible. shopping in order to get The report also states the best price which that ’e-tailing’ is unlikely would greatly affect the to replace the ‘whole high growth scenario day out’ shopping figure. experience. 103/159c The report claims there It is not the intention of Investigate through Site is a need for 28,000sqm the Retail Need Allocations DPD
356 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action retail floorspace but fails Assessment to to indicate how much of determine the trading this could achieved by capacity of existing redeveloping existing stores, in any case spare capacity. There existing capacity would are a significant number be considered when of retail spaces available making site allocations. within the town centre. The study does not address the question ‘how close are existing retail outlets to capacity trading?’ 104/055 The Council should The policies within the None establish the most core strategy accord appropriate strategy for with the evidence base the Borough that will and are the most provide the retail facilities appropriate strategy for in locations that accord the Borough. with the evidence base. 104/057 Significant that the retail The Core Strategy will Take account of evidence may need to be reflect any changes changes to the RSS and revisited in light of made to the RSS reflect these in the Core additional housing following its Strategy. growth emerging from examination. the RSS. 106/166 Developing retail The development brief None
357 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action units/food outlets in the for Church Rd sites area of Church Rd/North encompasses a number West Quadrant is not of uses including sustainable and would housing and offices not compromise the existing just retail which has centre. Future food been supported by the convenience stores must Retail and Leisure be situated within the needs Assessment. A confines of Redditch balance of uses is Town centre. Fails to see required including how pedestrian links can convenience offer which be achieved from the site is in line with need and to the Town Centre. demand as established Church Rd should be in the Retail and Leisure developed for uses such Needs Assessment. as housing and or offices.
Agree with the redevelopment of Leisure uses within the Smallwood Health site does not Centre however the necessarily mean it will report fails to mention be the same as the how the Bus Depot will Abbey Stadium as there be redeveloped and will are a variety of leisure the adjoining buildings uses. survive – needs clarification? The reports
358 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action also states the site should be used for leisure needs however this will be in direct competition with the Abbey Stadium.
Does not support the Car Park 7 is within removal of car park 7 private ownership and and would like to see it has recently been restored. Demolishing refurbished and brought this would contradict the back into use. council’s recent decision on the Bates Hill application, given approval on the grounds of good parking nearby in the form of car park 7.
Does not agree with Edward Street is a retail development on gateway site to the the Edward Street Site Town Centre and the as it is too far out and Edward Street SPD is would be incompatible still current. The brief with the retention of the does state that if locally listed buildings. employment is not The buildings should be economically viable retained, site tidied up then housing could be
359 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action and possibly used for accommodated on the housing or office. Is the site. The Retail and Edward Street SPD still Leisure Needs current? Assessment states the site could be accommodated for retail should other sites be unable to come forward. Officers will continue to monitor the site and for the locally listed buildings to be retained where ever possible.
Car park 4 is the most These areas of land are sensible option for retail being investigated and development however are also contained the following pockets of within the Redditch land should also be Town Centre Strategy. considered; • Old job centre Market area at the back of Debenhams 112/176 Agrees with the Noted None redevelopment of the Town Centre and New Town District Centres
360 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action 116/181 Disagrees with retail Figures are set by the Commission car parking development on the region for retail and study as identified within Church Rd/NW Quadrant offices. The Retail and the Town Centre site as the Town Centre Leisure Needs Strategy but this is not cannot sustain current Assessment identifies likely to be evidence in retail provision. the sites for retail use. support of the Core Strategy. Adequate car park Car parking study will provision is needed to be commissioned as serve the numerous part of the Town Centre doctor surgeries. Short Strategy to ensure term parking for those adequate parking is in people visiting banks, the right places. Car insurance companies Park 7 has recently and Building Societies been refurbished and etc is needed without brought back into use people having to walk through the Shopping Centre. Reinstate Car Park 7. 133/210 Unsure of proposals to All of the sites stated None regenerate parts of within the respondents Redditch Town Centre comments are within the (Church Rd, Prospect defined boundaries of Hill, and Car Park No.4) the Town Centre. as this will spread the town centre out.
361 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action 135/217 Agrees with the Noted None redevelopment of Church Hill centre 151/263 Retail needs have Noted. The number of None. shrunk considerably in houses, amount of the past year therefore employment land, retail the present provision and offices required to negates the planned be accommodated in increase. Redditch is allocated by the West Midlands Regional Spatial Strategy. The need for additional retail floor space has been clearly identified with the RNLA which demonstrates that provision is needed and can be sustained.
153/513 As public transport Agreed. Travel Plans None infrastructure can will be a requirement of increase the accessibility the delivery strategy of of an area Centro the submission core recommends that strategy. However travel development should be plans will also be a focussed in places that requirement at the are well served by public Development Control
362 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action transport as outlined by stage as part of the the WMRSS Policy T2. A validation checklist Travel Plan should be when an application is produced for new submitted. development to promote sustainable transport. Centro are happy to assist in any cross boundary issues. 160/276 There is no need for Noted. The number of None. additional retail in the houses, amount of Town Centre as too employment land, retail many shops are vacant and offices required to as present. The same be accommodated in applies to offices in Redditch is allocated by Redditch as many are the West Midlands vacant and have been Regional Spatial for several years. Strategy. The RNA states that vacancy rates have dropped in recent years and currant rates do not give rise to any major concerns. 160/278 Agree with Prospect St Figures are set by the None and Edward St as region for offices and strategic sites however retail that need to be they should not be for accommodated
363 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action shops and offices. therefore these uses Redditch needs a would be priority. museum, gallery, open park areas, youth centres and toilets. The public need another reason to come to Redditch other than to Shop 160/279 Shops on the New Town Comments noted Inform DC for when District Centres are redevelopment important and good for applications are the environment whilst submitted. also being sustainable. However they do require public toilet facilities. 185/307 Supports Matchborough Comments noted None. Shopping Centre although some aspects Redevelopment; are not under the remit of planning. • Enclose the shopping centre • Encourage local producers to provide fresh seasonal produce, new shops could
364 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action be hardware, haberdashery etc • Recreate original atmosphere with the pub • Local Schools – supervision lies with school and parents if children are using the centre • Smokers should not be allowed to converge into the public domain to smoke • Landscaping could be improved around the church Access and overflow car parks need to be redesigned to overcome parking issues. 208/344 Noted that Policy ES6 There is no figure for Revise RNA. refers to the need for convenience retail comparison retail development within the floorspace in the WMRSS. In terms of
365 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action Borough although it fails PPS6 Para 2.16 there is the need for no requirements for convenience retail identifying the need for development in the main convenience retail in the centres which is a same way as requirement of PPS6 comparison retail. Since (paragraph 2.16) the PDSC was drafted, PPS4 has indicated that local authorities should identify "any deficiencies in the provision of local convenience shopping and other facilities which serve people’s day-to-day needs". In addition paragraph Therefore officers 2.16 indicates that once suggest that more detail the need for retail is included in the refresh development has been to the RNA. confirmed, LPA’s should identify and allocate sites The Site Allocations and in accordance with the Policies DPD is sequential approach. scheduled in the Local Therefore should a Development Scheme convenience need be to commence identified within the Core production in February Strategy sites should 2010.
366 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action then follow in associates site specific LDF documents. 223/366 Support the identification Edwards Street None of Edward Street as a boundary has already Strategic Site in Policy been established within SP4 but request further the Development Brief. changes. Request that Should a Edward Street is referred comprehensive to as an area of land redevelopment come 1.15 hectares in forward with the accordance with the additional land this landownership on the would be assessed on adjacent site (shown on its merits and through plan). Both sites offer an the Development opportunity for Control Stage. comprehensive redevelopment over the site and to redefine land uses.
Policy SP4 should Development Briefs establish more detailed have been written for criteria for the the strategic sites and redevelopment of the provide further detail to strategic sites as in guide developers. Policy SP7.
367 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action
Request the following This is unnecessary changes to SP4: because there is provision in policy to Each of the four sites allow sites to come should be separated out forward separately. into their own policies.
The policy for the Agreed that more detail Edward Street site can be added to policy should give more following the receipt of detailed guidance on the Town Centre redevelopment criteria Strategy. Health and and mix of uses. Leisure uses would Housing, health and however be leisure uses should also inappropriate uses. be included within the policy text.
Reasoned justification for Total area will be re- Policy SP4 should be calculated. It should be changed and refer to the noted that there may be adjacent site with the consequential revisions total site area being to the reasoned refereed to as 1.15 justification following hectares, suggested restructure to
368 Policy/ Issue/ Para/ Respondent No./ Summary of comment Council’s response Council’s proposed Doc Representation No. action the Core Strategy.
262/408 Policy SP4 promotes the Noted None regeneration of Redditch Town Centre and establishes a list of objectives. The HCA supports the regeneration objectives proposed. 262/409 The HCA supports the Noted None proposals in Policy SP5. The enhancement of district centres can promote stronger communities and can deliver sustainability benefits.
Strategic Housing Land Availability Assessment
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
369 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SHLAA 029/715 1. Objection to manner in 1. Further to the CLG Good 1. None methodology (Tetlow King) which sites have been Practice Guidance (2007), PAS assessed, resulting in a produced an additional number of site groupings guidance note (July 2008) to 2. None being excluded as a result be read in conjunction with the of ‘competing land uses’ CLG Guidance. Para 49 of the and new settlement PAS note states that “whilst the proposals. At odds with the assessment will address purpose of the SHLAA as in whether sites are suitable for CLG Good Practice housing, this should only be Guidance (2007) which taken to mean that they are states that “It should aim to suitable provided they are not identify as many sites with required for other purposes ” housing potential in and [my emphasis]. Para 50 goes around as many on to state that “sites should settlements as possible in not be included in the SHLAA the study area.” All land/ which are not considered planning applications suitable or potentially suitable should be considered for housing. This would present individually on their own confusing messages… merits and not excluded Moreover, their inclusion could solely on conflicting land give unwarranted credibility to use proposals such sites.” Officers consider that the para 6.6 bullet points 2. Considers that para 1.4 of of the SHLAA offer sufficient SHLAA introduction does justification for the exclusion of not need to state that new settlement proposals and SHLAA does not determine sites where conflicting land whether planning uses may be an issue. The
370 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. permission would be SHLAA states that such sites granted as there is no will be investigated at an cause for this reference to appropriate time to establish be used as evidence to whether they might contribute suggest Council support for to the SHLAA if deemed residential development necessary. 2. Officers agree that the SHLAA does not necessarily need to make reference to the fact that the SHLAA is not a decision making document. However, for the purpose of clarity for all its readers, especially those who may not be familiar with the CLG and PAS Guidance Notes, such as local residents, officers consider that the inclusion of this reference does not detract from the methodology and overall purpose of the SHLAA UCS 5.20 – 080/120 Land should be considered for Officers are aware of the Investigate alternative active Land off Lady (Bladon) allotment space current increase in popularity of uses if site deemed unsuitable Harriet’s allotments. This could be an for residential development Lane alternative use to be investigated should there be any reason to discount the site
371 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. as having development potential
SHLAA 104/005/ 013 Concerns relating to the methodology (RPS) Redditch SHLAA, particularly in and specific relation to adherence to sites methodology and specific sites and therefore cannot be considered justified or robust:
1. Does not deliver against CLG Guidance Core Output 1 – there are no plans or 1. The first SHLAA draft (Oct 1. None maps to which cross- 2008) was released for consultation in a broadly references can be made to the tables/matrices. There complete format with respect to methodology and indicative is no geographical context to sites for stakeholders to capacities in order to present provide appropriate as many Core Strategy evidence documents for consultation response consultation as possible with the intention to address any
inconsistencies/ shortcomings in a revised draft as early in the new year as possible. Based
372 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. on the Stage 3 Desktop review of 594 sites, only those sites considered suitable for further assessment (102) have been 2. Does not deliver against mapped CLG Guidance Core Output 2 – SHLAA has not 2. This information was completed an assessment completed and included in the of deliverability and March 2009 SHLAA refresh developability according to
the tables in Appendix 8 and is therefore incomplete
3. Does not deliver against CLG Guidance Core Output 2 – Assessment requires the Council to consider 3. Para 6.26 actually states availability to ensure 2. None housing delivery. The that ownership and availability SHLAA findings are information would only be undermined as para 6.26 collected for sites that were states that “for some sites considered to offer some development potential as costs ownership and availability is unknown and will not be associated with enquiries on all SHLAA determined at this stage”. sites would have been methodology The Council should revise prohibitive for the Council. This and specific 104/005/ 013 the SHLAA and its findings information has been collected (RPS) and included in the March 2009 sites to take full account of site availability as current SHLAA refresh
373 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. capacity considerations are 3. None not considered compliant with the requirements of PPS3 4. Does not deliver against CLG Guidance Core Output 2 – Para 6.26 states that it makes “assumptions about landowners’ attitudes to development”. The Council’s ability and qualification to make such 4. In context, para 6.26 states assumptions is questioned, that assumptions to particularly in the current landowners attitude towards economic climate where development of sites has been ‘attitudes’ are vastly made against sites that were different. The Council submitted for inclusion in the should use quantifiable SHLAA by landowners evidence regarding themselves. This paragraph availability. If ‘landowners has been further extended in attitudes’ are used as a the March 2009 refresh (now proxy, then advice should para 6.29) and states… “For be qualified and sourced those sites that have been appropriately rather than submitted for assessment by assumed landowners, an assumption has been made about those landowners’ attitudes towards development. These sites can
374 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. be considered to be available for development as the landowners are clearly 4. None proactively considering the future development of their sites.” No assumptions were made with respect to attitudes towards development of sites that were identified through other avenues i.e. previous Urban Capacity Study. All landowners of sites which were SHLAA considered to have methodology development potential were and specific contacted and the table at sites 104/005/ 013 Appendix 9 updated 5. Does not deliver against (RPS) accordingly. Two sites remain CLG Guidance Core Output inconclusive with respect to 2 – Concerned over landowners attitudes towards reference in para 7.2 where development and these have the Council has combined subsequently been pushed sites which may have been back in the delivery timescale promoted separately. Land until further information is ownership and assembly is obtained far more complex an issue
than can be addressed by 5. Officers understand the Council arbitrarily concerns regarding this point, combining sites however, para 7.2 has been updated to clarify the position
375 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. in the March 2009 SHLAA refresh through the introduction of a statement justifying the 6. Does not deliver against merging of sites. Merging sites CLG Guidance Core Output predominantly arose through 2 – Para 6.27 states that the previous identification of achievability is assessed smaller adjacent sites in the against market factors, cost previous UCS survey to enable factors and delivery factors a more comprehensive as required by SHLAA assessment of development Guidance. However SHLAA potential refers to none of these in its consideration of sites, it 6. Officers are aware of this merely refers to the ‘credit weakness in the SHLAA and crunch’ and draws a work continues to strengthen negative conclusion with this element of the SHLAA with respect to deliverability. advice and contributions from Achievability should not be the SHLAA Working a generic assessment and Partnership which includes should require site specific members of the development considerations to market, industry who have expert cost and delivery factors. knowledge of economic Reference to the ‘credit viability and delivery of sites for crunch’ is a short term view housing development. In for a plan which extends up addition, the site specific to 2026 considerations noted by the respondent will be developed 7. Does not deliver against as the Borough Council CLG Guidance Core Output commences work on a Site
376 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SHLAA 2 – The Council has Allocations and Policies DPD methodology incorrectly applied the and specific concepts of assessing sites achievability as it incorrectly uses development plan 104/005/ 013 phasing as a proxy. (RPS) Achievability should be undertaken on a site 5. None
specific basis. Phasing references should relate to specific site phasing, build rates and delivery issues not the entire phasing
strategy. Phasing strategy 7. Whilst officers agree that and policy is likely to reduce that SHLAA guidance refers to achievability further by developer’s own phasing with requiring brownfield sites to respect to delivery factors, be favoured over others officers consider that for the purposes of establishing an
appropriate/ approximate timeframe for development, the use of strategic phasing policy
offers a broad analysis of the SHLAA sites and where they fit
into the overall plan time- framework. As the SHLAA is
8. Does not deliver against neither policy nor strategy, the CLG Guidance Core Output ability for sites to proceed
377 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 2 – SHLAA guidance also towards development at a expects sites to be different rate to that suggested considered for market in the SHLAA is not 6. April 2010 refresh of the SHLAA to include more viability against: The incomprehensible. It is Council’s aspirations for anticipated that this information detailed economic viability affordable housing policy to will be supplemented for the assessment of SHLAA sites as determine the levels of April 2010 SHLAA refresh a result of the Working financial contributions likely through involvement of the Partnership contributions to be sought against Housing Market Partnership as particular sites as this will part of their work on housing affect viability; Council’s implementation strategy, in policy/emerging policy on accordance with Housing and planning obligations or CIL; Planning Delivery Grant Council’s policy on requiring guidance and PPS3 renewable energy contributions (testing 8. See response to required to be in 104/005/013(RPS) 6 above SHLAA accordance with Paras 33.1 methodology & 33.2 of PPS on Planning and specific for Climate Change); sites specific issues such as land values, physical constraints,
infrastructure needs and 104/005/ 013 funding requirements. All of (RPS) these are considered best practice elsewhere
9. Does not deliver against CLG Guidance Core Output
378 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 4 & 5 – Constraint information is limited and difficult to assess given that there are no plans or qualified evidence on assumptions made and states in para 6.28 that addressing constraints should be the responsibility of the landowner if they wish to progress their site 7. Improve delivery/ towards development. To achievability assessments of conform to PPS12 para sites through SHLAA Working 4.27, the Council has the Partnership work for 2010 responsibility to work SHLAA refresh proactively with landowners to establish appropriate
rather than reactionary approaches to this issue
10. RBC failed to take into consideration extensive supporting information submitted in relation to the
North West Urban extension to Redditch and defers responsibility to the WYG Study which also 9. Constraint information has failed to consider been detailed on the survey
379 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. supporting information. The sheets in Technical Appendix A Council has failed to (Included sites). Constraints undertake timely, effective would not preclude a site from and conclusive discussion development, but merely on what options for a core highlights any issues. Para SHLAA strategy are deliverable 6.26 was updated in the methodology [PPS12 Para 4.27] SHLAA refresh (March 2009, and specific para 6.33) to reflect the sites Council’s willingness to proactively engage with developers in order to discuss appropriate courses of action. Additional constraint
104/005/ 013 information will be gathered through a landowners (RPS) 11. As the SHLAA fails to deliver on 4 of the 5 Core questionnaire as an action of the Working Partnership outputs it is incomplete. It cannot be considered robust enough to inform the development strategy for the Borough. The Council places significant weight 10. The WYG Study considered, in broad terms, the upon the SHLAA within the Core Strategy and it has development potential of land 8. See action at parcels beyond the Redditch been used to inform the 104/005/013(RPS) 6 above WYG Study. This Borough boundary and its undermines the Core ADRs, to determine the most Strategy, WYG Study and suitable/sustainable direction for future growth. Additional
380 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. any other element of the submitted information such as evidence base which is that relating to the North West based on or uses its Urban Extension to Redditch findings would be more appropriately considered through Core 12. Windfalls - The SHLAA Strategy/ Site Allocation DPD incorrectly and unjustifiably preparation rather than in the includes a windfall SHLAA. However, due to the allowance and should be RSS Panel Report removed from the SHLAA in Recommendations, its entirety consideration of the ADRs to accommodate Redditch’s housing needs will form part of the 2010 refresh
11. Concerns relating to the SHLAA failing to deliver on 4 out of 5 Core Outputs have been addressed in the March
2009 refresh. As the SHLAA is SHLAA a living document, officers methodology consider that its contents and and specific 13. Windfalls – forthcoming actions i.e. sites Misinterpretation of national Housing Market Partnership policy on windfall work and further discussions allowances as RBC sought with landowners, can only to justify inclusion of strengthen the document as it
381 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. windfalls on the basis of and the Core Strategy process past trends (PPG3) rather evolve than new requirements of
104/005/ 013 PPS3, para 59. No (RPS) reference to genuine local circumstances has been made that prevents specific 12. Discussions with the sites from being identified SHLAA Working Partnership
or justification required by concluded that a windfall 9. Collate additional constraint PPS3. The windfall allowance should be excluded information for inclusion in the allowance should be form the first 10 years of the 2010 refresh removed Plan to ensure robustness and conformity with PPS3. This will 14. Cannot understand how the be reflected in the April 2010 Council can acknowledge in SHLAA refresh. Only the SHLAA that that there brownfield historic trends will are ADRs and other sites in be taken into account to avoid Appendix 8 to be assessed an unrealistic expectation for and then seek to claim that greenfield development i.e. there are genuine local barn conversions which form circumstances preventing part of past trends but which sites from being identified may already have been depleted and should rightly be
excluded from future trends analysis
13. See 12 above
382 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
SHLAA 10. Consideration of the ADR methodology capacities to form part of the and specific 2010 refresh sites
15. Concerns that identified supply will not come forward as expected given 14. The reference in Appendix that site suitability, 8 to “sites to be assessed” 104/005/ 013 availability and achievability refers to the initial desktop (RPS) has not been undertaken review of all sites at Stage 3 of the SHLAA process. These 16. Evidence base fails to consider factual information sites were assessed following regarding housing supply the desktop review for their and delivery within the suitability for inclusion in the SHLAA. With respect to the
383 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Borough in the context of ADRs, when preparing the the current market and 2008/09 SHLAA, officers were housing supply. It should minded to consult based on the present sound information conclusions of the WYG2 study regarding the ability of all which was commissioned to sites including strategic establish preferred directions of sites to deliver the required growth for Redditch. WYG1 housing through a Study concluded that whilst comprehensive site specific planning up to its boundaries housing trajectory including only, the ADRs offered suitable start/completion locations for development. rates/trends and future However, the WYG2 Study, projections when considering land beyond the Borough boundary, 17. Objection to RBC deferring considered that there were responsibility of other, more suitable locations 11. None assessment of the ADRs to for development and that the WYG without integrating ADRs were less preferable for back into the SHLAA development than other locations. The WYG2 study was considered by the RSS Panel of Inspectors, who
18. Detailed scrutiny of the concluded that there were no capacity of the urban area good reasons to overturn the is weak. The urban capacity ADR findings in WYG1
is significantly 15. See response to SHLAA challengeable against the 104/005/013(RPS) 6 above methodology requirements of PPS3 and
384 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and specific CLG SHLAA guidance and sites should be re-appraised. WYG should have included
this in its detailed scrutiny of the urban area capacity
19. An increase of 5dph to increase overall capacity is 16. See response to not considered detailed 104/005/013(RPS) 6 above scrutiny
104/005/ 013 12. SHLAA refresh in April (RPS) 2010 to recalculate windfall allowance, excluding any allowance in the first 10 years of the Plan period.
385 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
17. In the March 2009 refresh of the SHLAA, officers did integrate the WYG2 assessment of the ADRs back into the SHLAA. However, with respect to the current status of the ADRs, refer to 104/005/013(RPS) response 13. See 12 above 14 above 18. The WYG brief did not include detailed scrutiny of the SHLAA urban area capacity. The Brief methodology required that they look at the and specific possible urban capacity on sites primarily open space within the urban area. Also, refer to 104/005/013(RPS) response 14 above
19. Refer to 104/005/013(RPS)
386 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. response 18 above 104/005/ 013 (RPS)
14. Officers to consider capacities available within the ADRs to meet the revised RSS
target of around 4000 dwellings up to 2026 and undertake a further consultation period
387 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
SHLAA methodology and specific sites
104/005/ 013 (RPS)
388 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 15. See action at 104/005/013(RPS) 6 above
16. See action at 104/005/013(RPS) 6 above
SHLAA methodology and specific sites
389 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
17. See action at 104/005/013(RPS) 14 above
104/005/ 013 (RPS)
18. See action at 104/005/013(RPS) 14 above
390 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
19. None
391 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SHLAA 104/005/ 013 20. The Council should revert 20. Further to the findings of 20. RBC officers will continue methodology (RPS) back to developing and the RSS Panel of Inspectors to work closely with BDC to expanding upon its existing with respect to the WYG2 develop robust evidence to SHLAA process as part of a Study, officers now have support cross-boundary growth joint assessment clear advice in order to options for Redditch related undertaken with BDC which progress the robustness of needs embraces an open, the Redditch SHLAA transparent and interactive approach to engagement. This will avoid the requirement for the Council to justify its approach for strategic land identification
392 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 3.43 – 124/196 Concerns about possible 1. This site is not designated Officers recommend that this Land east of (Coulson) development of this site having Green Belt site be dropped from the Longfellow an impact on the following: SHLAA as landowner unwilling Close to release land for 1. Further erosion of Green development. In addition, Belt area biodiversity and flooding implications along The 2. Report from the Biodiversity 2. Effects on existing Wharrage Park area Officer raises concerns over hedgerows, trees and loss of habitat and open wildlife feeding areas for possible
bat population. In addition to this, removal of open
land within Wharrage Park will put added pressure on the remainder of the Park in
terms pedestrian use, thus disturbing the integrity of
the whole green corridor
3. Site is not within Environment Agency Flood 3. Increased flood risk Zone. However, the site
is adjacent to the Wharrage Watercourse, which is
designated as Main River and as such, development would not be considered
favourably by the EA.
4. No definitive scheme is in place for this site and the 4. Loss of on-street car parking bay may be parking bay excluded from the 393 development area
5. Headless Cross and 5. Loss of open space with Oakenshaw Ward has an Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 8.10 – 126/198 Concerns about possible This site was previously Officers recommend that this Land at (Shaw) development of this site having identified as a road reserve for site remain in the SHLAA at McDonalds an impact on the following: the Alcester Highway this stage but a full 12 month Island, extension, to connect to the species survey would need to Oakenshaw Studley Bypass. The Bypass be undertaken prior to scheme was subsequently development revoked and the land not needed for transport
development. Therefore development of the site in principle has previously been 1. Loss of green space established
1. Headless Cross and Oakenshaw Ward has an open
space surplus of +1.92 ha per 1. None 1000 population. The overall Borough standard of unrestricted open space is
9.08Ha/1000 population. Comparison with the NPFA
standard (2.4Ha/1000 population) shows that there are 8.6Ha/1000 population of
formal open space, which is considered to be a healthy
figure. In comparison, Redditch Borough has at least 3.1Ha/1000 population more
394 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. open space than any other Worcestershire district. Furthermore, no SHLAA identifications on unrestricted open space would result in 2. Increased traffic congestion approximately 260 additional at roundabout at peak dwellings (8Ha) being allocated periods on Green Belt land
2. Comments from the Highways Engineer conclude 2. None that an increase in traffic generation from 44 units will have some impact on traffic flow at this location, it is UCS 8.10 – considered unlikely however Land at that the increase is likely to be McDonalds significant enough to warrant any improvements to the island Island, Oakenshaw such as traffic signals. Satisfactory junction spacing 126/198 3. Site is higher than (Shaw) can be achieved to allow surrounding development access to the site, and the and new development geometry of Grangers Lane, is would be very prominent on suitable to allow additional this site traffic 3. The topology of this site is not sufficient to exclude it from
395 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the SHLAA. Appropriate development, sympathetic to the surroundings would be a matter to be addressed through the planning application process 3. None
UCS 3.43 – 128/200 Concerns about possible See 124/196 above Land east of (Moore) development of this site having Longfellow an impact on the following: Close 1. What is the boundary of
Wharrage Brook Park? 1. Wharrage Brook open space Would a green corridor be is not specifically designated maintained if development as a park. BORLP3 Policy goes ahead B(NE).3 seeks to protect the
principle of wildlife corridors as a means of transition from one
habitat to another. Development of this site would not impact on the transitional nature of such wildlife 2. History of drainage problems on the estate corridors.
396 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. Drainage at Wharrage 2. & 3. See 124/196 above Brook
4. Would design of new development be in keeping with existing development 4 & 8. Appropriate development, sympathetic to the surroundings would be a 5. Location of vehicular matter to be addressed through access to new development the planning application process 6. Fate of existing footpaths 5. See 124/196 above
6. Indicative scheme indicates 7. Loss of green space and that existing footpaths would recreational use remain untouched as a 8. Possible high density of consequence of development development would affect 7. Noted. Refer to response no. the quality of life in the area 124/196
8. Noted. Quality of life is a very important element of spatial planning. However, striking an appropriate and harmonious balance in Redditch is currently hampered
397 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 3.43 – by the fact that the available Land east of land identified in the SHLAA to Longfellow 128/200 9. Increase in waste meet the Regional Housing (Moore) Close 10. Increase in noise levels Allocation for the Borough falls short of this allocation 9 & 10. Increase in waste and 11. Block views and impact on noise from a maximum of 7 property values dwellings is not considered to have a significant impact 11. Impact on property values and outlook for existing properties is not considered to be a spatial planning matter. UCS 8.10 – 131/204 Objection to development of This site was previously See action at 126/198 above Land at (Troth) this site with respect to: identified as a road reserve for McDonalds the Alcester Highway
Island, extension, to connect to the Oakenshaw Studley Bypass. The Bypass scheme was subsequently revoked and the land not needed for transport
development. Therefore development of the site in principle has previously been UCS 8.10 – 1. Impact on wildlife (bats, established Land at deer, butterflies, McDonalds dragonflies, buzzards, 1. Report by Biodiversity
398 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Island, pheasants) Officer is unclear as to the Oakenshaw presence of protected species 131/204 2. Grangers Lane already (Troth) dangerous due to 2. Comments from the volume/speed of existing Highways Engineer conclude 1. Request full 12 month car users that the issue of speeding species survey for this site traffic is an existing situation that is unlikely to be made worse by development at this 2. None location, in any event, it will be a matter for the police to enforce and is likely to be caused by local traffic WYG03 – 135/218 Objects to development on this 1. Brownfield site, which has None Tanhouse (Smith) site. The trees and shrubs been cleared for future Lane compensate for the housing development. Trees and estate shrubs have been cleared from
the site with the exception of perimeter planting. Noted that Church Hill Ward has an open space deficit of -2.47 ha per 1000 population. The overall
Borough standard of unrestricted open space is 9.08Ha/1000 population. Comparison with the NPFA standard (2.4Ha/1000 population) shows that there
399 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. are 8.6Ha/1000 population of formal open space, which is considered to be a healthy figure. In comparison, Redditch Borough has at least 3.1Ha/1000 population more open space than any other WYG03 – Worcestershire district. Tanhouse Furthermore, no SHLAA Lane identifications on unrestricted 135/218 open space would result in (Smith) approximately 260 additional dwellings (8Ha) being allocated on Green Belt land UCS 3.43 – 136/219 Objects to development of this See 124/196 above Land east of (Wood) site with respect to: Longfellow Close 1. Increased traffic flow through Longfellow Close 1. See 124/196 above 2. Loss of open space and would cut off open aspect of 2. Noted. Refer to response no. the Close 124/196
UCS 3.43 – 137/220 Objects to development of this See 124/196 above Land east of (Batchelor) site with respect to: Longfellow
400 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close 1. Loss of open space/ 1. See 124/196 above recreation land
2. Affect on existing hedgerows, flora and fauna 2. See 124/196 above 3. Increased traffic flow through Close 3. See 124/196 above 4. Concerns of footpath closure 4. Indicative scheme indicates that existing footpaths would remain untouched as a consequence of development UCS 2.16 – 138/221 Objects to development of this Officers recommend that this Land to the (Lawless) site with respect to: site remain in the SHLAA at rear of this stage 1. Loss of residents privacy Sandygate 1. Noted. Unsure how privacy Close will be lost 2. Lack of parking facilities 2. New development would need to meet required parking standards and no existing parking provision would be lost. This would be a consideration at any planning application stage 3. Loss of safe play space
401 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. West Ward has an open space surplus of +4.81 ha per 1000 population. The overall Borough standard of unrestricted open space is 9.08Ha/1000 population. Comparison with the NPFA standard (2.4Ha/1000 population) shows that there are 8.6Ha/1000 population of formal open space, which is considered to be a healthy figure. In comparison, Redditch Borough has at least 3.1Ha/1000 population more open space than any other Worcestershire district. Furthermore, no SHLAA identifications on unrestricted open space would result in approximately 260 additional 4. Implications associated with dwellings (8Ha) being allocated building sites - movement of on Green Belt land construction traffic through congested residential area, 4. Disruption from construction UCS 2.16 – health & safety of residents is a temporary issue. All safety Land to the and visitors, dirt and grime regulations and planning rear of 138/221 conditions to ensure street Sandygate cleanliness etc would be met
402 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close (Lawless) during construction UCS 3.43 – 139/222 (Pioli) Objects to development of this 1 & 2. Noted. Refer to See 124/196 above Land east of site with respect to: response no. 124/196 Longfellow Close 1. Loss of open space 2. Safe area for children to play 3. See 124/196 above 3. Existing high levels of traffic in the Close UCS 3.43 – 140/223 Objects to development of this See 124/196 above Land east of (Brewer) site with respect to: Longfellow Close 1. Access into Longfellow Close inadequate due to 1. See 124/196 above
existing on-street parking
2. Loss of on-street car parking bay 2. No definitive scheme is in place for this site and the 3. Loss of safe area for parking bay may be excluded children to play 3. Noted. Refer to response no. 4. Concerns of footpath 124/196 closure UCS 3.43 – 4. Indicative scheme indicates Land east of 140/223 that existing footpaths would Longfellow remain untouched as a
403 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close (Brewer) consequence of development 5. Disruption to wildlife e.g. 5. See 124/196 above bats in nearby oak trees
6. History of drainage problems near 27 6. See 124/196 above Longfellow Close 7. Increased flood risk 7. See 124/196 above UCS 3.43 – 141/224 Objects to development of this See 124/196 above Land east of (Eacock) site with respect to: Longfellow Close 1. Loss of Green Belt land 1. Not Green Belt land – primarily open space. Refer to response no. 124/196 2. Loss of public right of way 2. Indicative scheme indicates
that existing footpaths would remain untouched as a consequence of development 3. Loss of safe area for children to play 3. Noted – see 1 above
4. History of drainage
problems near 27-29 4. See 124/196 above Longfellow Close
5. Disruption and danger from
404 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. construction traffic 5. Disruption from construction is a temporary issue. All safety regulations and planning conditions to ensure street cleanliness etc would be met during construction 6. Wharrage Brook Park is home to variety of flora and 6. See 124/196 above fauna. Affect on existing TPO oak trees, flora and fauna (sparrows, bats, bluebells) UCS 3.43 – Land east of 7. When estate first built, this Longfellow 141/224 land was identified for Close (Eacock) landscaping but was not completed as builders went 7. The site did not form part of into liquidation the original site for the estate development and there are no plans to indicate that it was to 8. Density concerns be landscaped by developers (File No. NT23 82) 8. Noted UCS 3.43 – 142/225 Concerns about possible See 124/196 above Land east of (Purshall) development of this site having Longfellow an impact on the following: Close 1. Loss of safe play space for children will fuel obesity
405 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. epidemic 1. Noted. Refer to response no. 124/196.
Redditch Health Profile 2008 (Department of Health,
www.healthprofiles.info ) shows that the percentage of physically active children in the Borough is significantly better than the England average
(10% lower). The percentage 2. Increased traffic flow of obese children in the through Close and parking Borough is not significantly different to the England on pavements makes route unsafe for pedestrians average but is 0.2% lower
3. Increased flood risk to 2. See 124/196 above existing properties UCS 3.43 – 4. Loss of vegetation e.g. Land east of hedgerows Longfellow 142/225 Close (Purshall) 3. See 124/196 above
4. Existing hedgerows will remain untouched. One small
406 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. tree may be affected UCS 3.43 – 143/226 Objects to development of this See 124/196 above Land east of (Marshall) site with respect to: Longfellow Close 1. Loss of vital ‘breathing space’ between Housing 1 & 2. Noted. Refer to estates response no. 124/196 2. Loss of recreation space and safe play space for children 3. See 124/196 above 3. Loss of wildlife habitat 4. 56% of sites identified in the 4. Plenty of brownfield sites SHLAA are on brownfield land. elsewhere in Redditch that The search for available and could be used for housing deliverable brownfield sites has been exhausted through this process UCS 3.43 – 144/227 Objects to development of this See 124/196 above Land east of (White) site with respect to: Longfellow Close 1. Increased traffic flow through Close 1 & 2. See 124/196 above
2. Increased congestion due
UCS 3.43 – to existing on-street parking Land east of Longfellow 3. Loss of on-street car
407 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close 144/227 parking bay/ turning area (White) 3. No definitive scheme is in 4. Existing school-run traffic place for this site and the parks opposite Longfellow parking bay may be excluded Close and cars use Close entrance to turn around 4. Noted but not a spatial which is chaotic planning matter 5. Loss of recreation space and safe play space for children
5. Noted. Refer to response no. 124/196 UCS 9.1 – 145/228 Objects to development of this 1. Noted that Lodge Park Ward Officers recommend that this Land to the (Gooding) site with respect to: has an open space deficit of - site be dropped from the rear of 2.72 ha per 1000 population. SHLAA as landowner unwilling Watery Lane 1. Loss of recreation space The overall Borough standard to release land for and safe play space for & of unrestricted open space is development. In addition, Ravensmere children 9.08Ha/1000 population. biodiversity implications and Road Comparison with the NPFA lack of open space provision in standard (2.4Ha/1000 the Lodge Park Ward warrant population) shows that there exclusion. are 8.6Ha/1000 population of formal open space, which is considered to be a healthy figure. In comparison, Redditch
408 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Borough has at least 3.1Ha/1000 population more open space than any other Worcestershire district. Furthermore, no SHLAA identifications on unrestricted open space would result in approximately 260 additional dwellings (8Ha) being allocated on Green Belt land. Only half of the site has been identified as having development potential
UCS 9.1 – Land to the rear of 145/228 Watery Lane (Gooding) & Ravensmere Road UCS 3.43 – 146/229 (Hill & Objects to development of this See 124/196 above Land east of Dunn) site with respect to: Longfellow Close 1. Increased traffic flow through Close 1 & 2. See 124/196 above 2. Increased congestion due to existing on-street parking
409 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. Loss of on-street car parking bay/ turning area
4. Existing school-run traffic 3. No definitive scheme is in parks opposite Longfellow place for this site and the Close and cars use Close parking bay may be excluded entrance to turn around 4. Noted but not a spatial which is chaotic planning matter 5. Loss of recreation space and safe play space for children
5. Noted. Refer to response no. 124/196 UCS 8.10 – 154/266 Concerns about possible This site was previously See action at 126/198 above Land at (Ashfield) development of this site having identified as a road reserve for McDonalds an impact on the following: the Alcester Highway Island, extension, to connect to the
Oakenshaw Studley Bypass. The Bypass scheme was subsequently UCS 8.10 – revoked and the land not Land at needed for transport McDonalds 154/266 development. Therefore Island, (Ashfield) development of the site in Oakenshaw principle has previously been 1. Destroy wildlife habitat,
410 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. trees and bushes established 2. Increased traffic congestion 1. See 131/204 above 1. See 131/204 above at roundabout
3. Increased pollution from higher traffic volume 2 & 3. See 126/198 above 2. & 3. See 126/198 above 4. Lineholt Close protected by trees which form noise buffer from roads
5. Development would impact on property values and 4. Trees alongside Lineholt 4. None destroy outlook for Lineholt Close will not be removed Close
5. Impact on property values and outlook for existing 5. None properties is not considered to be a spatial planning matter
411
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 155/267 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Burgoyne) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space & and safe play space for Ravensmere children Road UCS 9.1 – 156/268 Objects to development of this 1. Comments from the See action at 145/228 above Land to the (Mitchell) site with respect to: Biodiversity officer conclude rear of that it has been reported that Watery Lane 1. Presence of bats bats are regularly seen over
& the field in the evenings. Thus Ravensmere the field acts as an important Road feeding area for bats. The bats might be present within the older trees on the site and also
within the roof spaces of some of the houses surrounding the field. Some residents have bat boxes in gardens which are being used. Development on
feeding areas such as this field will cause problems for all bat species.
The presence of owls has been
412 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. reported. If present, they will also be hunting over the field and adjacent gardens for small mammals.
Reports of amphibians such as frogs, toads and newts present in gardens and within the site. Possible presence of great
crested newts in some ponds.
Surveys for bats and great UCS 9.1 – crested newts would have to Land to the be carried out over a full year 156/268 2. Loss of recreation space for period to ascertain which of rear of children Watery Lane (Mitchell) these species are present on & the site. Ravensmere Road 2. Noted. Refer to response no. 145/228 UCS 9.1 – 157/269 Objects to development of this 1. Comments from the See action at 145/228 above Land to the (Gardner) site with respect to: Highways Engineer conclude rear of that due to the lack of a Watery Lane 1. Increased traffic volume footpath on Watery Lane, the along Watery Lane and & road appears narrow and Ravensmere Ravensmere Road restricted to road users, even
413 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Road though it is of adequate width to accommodate an additional number of units. The main issue however, is that properties currently fronting the lane directly abut the carriageway without the 'buffer' of a footpath; this makes egress, especially on foot, hazardous. This hazard would increase with additional development. In order to alleviate this situation, a footpath would need to be constructed on the south side UCS 9.1 – of Watery Lane and the Land to the carriageway widened on the rear of 157/269 north side to maintain a width Watery Lane (Gardner) 2. Overworked drains would of 5.5m & be more prone to flooding 2. Comments from the Assets Ravensmere Road Maintenance Officer conclude that The surface water will require balancing to green-field run-off, prior to discharge to a public sewer. There is a
public surface water sewer situated within the site, near its southern boundary.
414 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. It's possible that this may dictate layout or require diversion, if feasible 3. Impact on property values and outlook for existing properties is not considered to 3. Loss of outstanding views be a spatial planning matter. from respondents property Quality of life is a very resulting in property important element of spatial devaluation and reduced planning. However, striking an quality of life appropriate and harmonious balance in Redditch is currently hampered by the fact that the available land identified in the SHLAA to meet the Regional Housing Allocation for the Borough falls short of this allocation
4. Site is at the opposite end of the field to respondents 4. Possibility of loss of rear property so no loss of rear access to respondents access is likely property 5. Noted. Refer to response no. 5. Loss of recreation space 145/228
6. The search for available and 6. There are many more deliverable sites has been
415 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. alternative sites on which exhausted through this process to build
UCS 9.1 – Land to the rear of Watery Lane 157/269 & (Gardner) Ravensmere Road UCS 9.1 – 161/280 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 Land to the (Donegan) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space and safe play space for & Ravensmere children Road 2. Waste of taxpayers money 2. Only half of the site has to install play equipment/ been identified as having planting if is to be lost to development potential and development excludes the play area General loss 162/281 1. Retention of open 1. Noted. However there are no Officers recommend that this of open (Arney) countryside/ Green Belt development proposals which site be dropped from the space for south of Elmstone Close affect the Green Belt south of SHLAA as landowner unwilling residential Elmstone Close. Green Belt to to release land for development the south west of the urban development. In addition, there & area was excluded due to are biodiversity and Green Belt sensitivities
416 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 3.23 – highlighted in the Study of contamination issues Land off Hunt Green Belt Land & ADRs within End Lane Redditch 2. Objection to development of General loss UCS 3.23 as it forms a 2. A buffer will be retained of open buffer between residential between incompatible uses if space for and employment uses this site comes forward for residential 162/281 development development (Arney) 3. Site contains hazardous & waste 3. Comments from the Environmental Health Officer UCS 3.23 – conclude that the proposed Land off Hunt residential development is a End Lane sensitive land use and a contaminated land assessment would be required what ever the former land use. The area is situated close to a former factory which has had a variable site history (manufactured cars/vehicles, batteries and tyre storage/ manufacture). The current site uses on the industrial estate can also lead to on this site contamination. On the actual proposed site a tank is depicted what this is unclear. It is likely to be water but could
417 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. also be fuel.
Our current records do not indicate that the site was
subject to a potentially contaminative land use with the exception of the tank. At other battery works in Redditch, contamination has been
encountered some distance from the site; further assessment of the proposed site should therefore be undertaken. In order to understand the likely costs of 4. Loss of well used amenity remediating the site a Phase 1 open space and potentially a Phase 2 investigation is recommended.
General loss 4. Noted that Astwood Bank & of open Feckenham Ward has an open space for space surplus of +4.02 ha per residential 1000 population. The overall development Borough standard of & unrestricted open space is 9.08Ha/1000 population. UCS 3.23 – 162/281 Comparison with the NPFA Land off Hunt standard (2.4Ha/1000
418 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. End Lane (Arney) population) shows that there are 8.6Ha/1000 population of formal open space, which is considered to be a healthy figure. In comparison, Redditch Borough has at least 3.1Ha/1000 population more open space than any other Worcestershire district. Furthermore, no SHLAA identifications on unrestricted open space would result in approximately 260 additional dwellings (8Ha) being allocated on Green Belt land
419 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
General loss of open space for residential development & UCS 3.23 – Land off Hunt End Lane 162/281 (Arney) UCS 9.1 – 163/282 (Boor) Objects to development of this 1. Comments from Leisure See action at 145/228 above Land to the site with respect to: Services conclude that during rear of the public consultations 1. Council assurance in 2004 Watery Lane regarding the new play area & that area would remain for facility Members did give Ravensmere recreational facilities assurance at the NHG that this Road piece of open space would
420 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. remain in situ 2. Loss of recreation space 2. Noted. Refer to 145/228 and safe play space for above children
3. Capacity of Watery Lane to accommodate additional 3. Noted. Refer to 157/269 traffic above UCS 8.10 – 164/283 Objection to development of This site was previously See action at 126/198 above Land at (Mews & this site with respect to: identified as a road reserve for McDonalds Wakefield) the Alcester Highway Island, extension, to connect to the Oakenshaw Studley Bypass. The Bypass
scheme was subsequently revoked and the land not
needed for transport development. Therefore development of the site in
principle has previously been established 1. Increased traffic volume at 1. See 126/198 above UCS 8.10 – roundabout Land at McDonalds 2. Land provides a noise 1. See 126/198 above Island, 164/283 barrier between 2. None
Oakenshaw (Mews & respondents house and the Wakefield) busy roundabout 2. Land mass would not be flattened - no reason why
421 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development on this site should reduce current noise 3. Impact on wildlife (bats, barrier from roundabout traffic deer, foxes) 3. See 131/204 above 3. See 131/204 above 4. Loss of open space for recreational uses such as dog walking would be 4. See 126/198 above limited if land developed 4. Noted. Refer to response no. 126/198 5. Loss of visual amenity whilst driving around the roundabout
6. Development in a desirable 5. Noted. Not considered a 5. None location would negatively spatial planning issue affect property prices 6. Noted. Not considered a 7. Development of terraced spatial planning issue 6. None and semi detached properties would be out of keeping with Oakenshaw South 7. Development would be designed to accommodate 7. None existing topography and would be of a size and type reflective of the identified Redditch housing requirements detailed 8. Negative affect on the area in the Redditch Strategic due to social housing and Housing Market Assessment
422 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. their associated ‘trouble’ 8. Redditch Borough’s target for affordable housing is 141 units to be delivered per annum, as minima. National Planning Policy (PPS3) requires all development of 15 dwellings or more to accommodate a percentage of 8. None UCS 8.10 – affordable housing units. Land at Guidelines for Redditch are set McDonalds out in the SPD on Affordable Housing (January 2008) Island, Oakenshaw
164/283 (Mews & Wakefield) UCS 9.1 – 165/284 Objects to development of this 1 and 2. Noted. Refer to See action at 145/228 above Land to the (Forester) site with respect to: response no. 145/228 rear of Watery Lane 1. Loss of only recreation & space in the Greenlands, Ravensmere Woodrow, Lodge Park and Road Smallwood areas 2. Loss of valuable and well used and safe play space
423 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. for children UCS 9.1 – 166/285 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Cater) site with respect to: 145/228 rear of Watery Lane 1. Loss of play space for & children Ravensmere Road
UCS 9.1 – 167/286 Objects to development of this See action at 145/228 above Land to the (Headley) site with respect to: rear of Watery Lane 1. Detrimental effect on house prices in Hoveton Close 1. Noted but not a spatial & planning matter Ravensmere 2. Spoil outlook of properties Road in Hoveton Close 2. Noted but not a spatial planning matter 3. Loss of play space for children. Problem in 3. Noted. Refer to response no. Hoveton Close of children 145/228 playing ball games in the street. This has been addressed with community police support to encourage children to use the open
424 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. space. UCS 9.1 – 168/287 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Davies) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space & and safe play space for children 2. Only half of the site has Ravensmere been identified as having Road 2. Waste of council tax payers development potential and money to install play excludes the play area equipment/ planting if is to be lost to development UCS 9.1 – 169/288 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Dixon) site with respect to: 145/228 rear of Watery Lane 1. Loss of play space for 2. 56% of sites identified in the & children SHLAA are on brownfield land. The search for available and Ravensmere 2. Green areas should stay Road deliverable brownfield sites has green been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation UCS 9.1 – 170/289 Objects to development of this 1. Noted. To date no title deed See action at 145/228 above Land to the (Street) site with respect to: information has been rear of forthcoming to verify this claim Watery Lane 1. Recreational ground
425 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. & donated by builder of Ravensmere Watery Lane homes and Road protected by King George VI covenant 2. Loss of play space for 2. Noted. Refer to response no. children 145/228
3. & 4. See 157/269 above 3. Watery Lane inadequate to accommodate increased volume of traffic
4. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
5. Inadequate drainage and flooding concerns along Watery Lane 5. See 157/269 above
UCS 9.1 – 171/290 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Horton) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space & and safe play space for Ravensmere children
426 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Road
UCS 3.43 – 172/291 Objects to development of this 1. Footpath falls beyond site See 124/196 above Land east of (George) site with respect to: boundary and should not be Longfellow affected by development Close 1. Safety of footpath use if site developed 2. Flooding issues 2. See response 124/196 downstream of The above Wharrage if site developed UCS 3.23 – 173/292 Objects to development of this See action at 162/281 above Land off Hunt (Backhurst) site with respect to: End Lane 1. Loss of open space 1. Noted. Refer to response no. 162/281 2. Tree Preservation Order on site 2. Noted. Development would need to comply with the TPO restrictions for New Town TPO
3. Impact of wildlife 29
3. Comments from the Biodiversity Officer conclude that this area of land contains a range of habitats, including
scrubland, meadowland, rough grassland, developing native
427 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. woodland plantations, mature trees, veteran trees and some lengths of hedgerow. It is this important mosaic of habitats that make this site good for wildlife as it leads to a great range of plants and animals being found within it. It is likely that bat species will be present on the site and using the grassland and scrubland areas to feed over. It is also likely that the site will be important for amphibians and reptiles, in particular, grass snakes, great UCS 3.23 – 173/292 crested newts and slow worms. Land off Hunt (Backhurst) There are areas of thick scrub End Lane of hawthorn and blackthorn. Foxes and deer are present
within the scrubland area. There is also a distinct possibility of badgers present on the site.
An extensive ecological survey carried out over a full year
would be needed to check for all protected species within the
428 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. site.
The whole site consists of a developing woodland plantation strip of mixed native
species such as Oak and Field Maple at around 30 years of age. Within this plantation are several mature trees and some large veteran trees. Eastwards
from this plantation strip occurs more open land. To the south this is developing scrubland with open areas of wildflowers and rough grassland. To the
north of this scrubland is an area of meadow land. These two habitats are very important for wildlife. They are particularly good for insects,
birds and small mammals. For the past three years, the Redditch Mid-Week Conservation Volunteer Group (Run by RBC) has been
carrying out a series of tasks on the Hunt End Lane Open
429 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Space area, helping to keep paths through the site open and also to manage the UCS 3.23 – meadow area.
Land off Hunt End Lane 173/292 (Backhurst) The possible construction of housing across this site would
thus harm the site greatly with 4. Loss of buffer between the loss predominantly of two incompatible land uses of the most important habitats, the scrubland and the meadow
land. It also reduces the mosaic effect of having several 5. Loss of public footpath interesting habitats adjacent to each other, which is so important for wildlife here.
6. Disruption to public access Leaving isolated fragments of during construction these habitats around the edge of the housing is not a good enough wildlife mitigation measure here 7. Steep, undulating land may 4. A buffer will be retained be cost prohibitive to develop between incompatible uses if this site comes forward for development
8. View of Dunlop Road 5. Public footpath/ access
430 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. industrial estate from new would be maintained properties may effect ability to sell properties 6. Noted. Suggest that arrangements are put in place 9. Traffic noise from Windmill during construction to keep Drive public right of way open
7. Noted. However, Redditch is 10. Disruption, noise and traffic renowned for building on steep, during construction period undulating land due to its would impact on local general topography property prices during this period 8. Noted but not a spatial planning matter 11. Type of properties (4 bed detached) could impact on existing properties if not in- keeping with existing residential development 9. Existing vegetation would continue to act as a sound buffer to residential UCS 3.23 – 12. Loss of visual amenity development Land off Hunt along Hunt End Lane End Lane 10. Disruption from construction is a temporary 173/292 issue (Backhurst) 13. Impact of additional traffic at junction of Hunt End Lane/ Windmill Drive
431 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 11. Development would be of a size and type reflective of the identified Redditch housing requirements detailed in the Redditch Strategic Housing Market Assessment 12. Noted but not a spatial planning matter. Indicative scheme indicates that development would be well screened
13. Comments from the Highways Engineer conclude that Hunt End Lane and the junction with Windmill Drive are considered suitable to accommodate the proposed increase in traffic without the need for improvement
432 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
UCS 3.23 – Land off Hunt End Lane
173/292 (Backhurst) UCS 3.43 – 174/293 Objects to development of this See 124/196 above Land east of (McAuliffe) site with respect to: Longfellow Close 1. Loss of recreation space and safe play space for 1. Noted. Refer to response no. children 124/196 2. Loss of outlook for existing 2. Noted but not a spatial properties planning matter 3. Loss of quality of life of 3. Noted. Quality of life is a existing residents and ‘Park’ very important element of users spatial planning. However, striking an appropriate and
433 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. harmonious balance in Redditch is currently hampered by the fact that the available land identified in the SHLAA to meet the Regional Housing Allocation for the Borough falls short of this allocation 4. There are more suitable 4. 56% of sites identified in the areas for development SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation 5. Increased traffic flow 5 & 6. See 124/196 above through Close
6. Increased congestion due to existing on-street parking 7. Loss of on-street car parking bay/ turning area 7. No definitive scheme is in place for this site and the 8. Suggestion of alternative parking bay may be excluded area of ‘Wharrage Park’ be 8. The remaining land within
434 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. considered as an ‘Wharrage Park’ is not alternative to this site considered suitable for development due to its linear nature and access difficulties UCS 9.1 – 175/294 (Rao) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of 1. Lack of formal notification of Watery Lane 1. The SHLAA forms part of the & proposal to all local residents evidence base to support the Ravensmere Core Strategy. The Core Road Strategy and its supporting evidence documents were available for public consultation between 31 October 2008 and 8 May 2009. This consultation period was publicised in the local press, at neighbourhood groups, on the Council’s web site, in Redditch Matters, in a cinema advert and at a number of drop-in sessions at various locations around the town. Formal notification of the production of a background document to the Core Strategy is not a recognised requirement but the Council considers that more than
435 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sufficient notification/ consultation has been 2. Has Ramblers Association undertaken been notified? 2. Ramblers Association is included on our consultation database and was notified of this consultation period. No response from the Ramblers Association was received
3 , 4 & 6. Noted. Refer to 3. Loss of recreational open response no. 145/228 space
4. Loss of safe play space for children 5. Removal of Open Space is 5. 56% of sites identified in the contrary to Local Plan No.3 SHLAA are on brownfield land. The search for available and 6. Greenlands Ward has a deliverable brownfield sites has poor open space provision been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation. Policy R.1 of Local Plan No.3 states that development will be considered on Primarily Open
436 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Space if it can be demonstrated that the need for development outweighs the value of the land as an open 7. Loss of public footpaths area
7. Public Rights of Way would 8. Increased risk of surface be retained water flooding as there is nowhere for excess water 8. Drainage would form part of to drain to any development proposals 9. Site of old aluminium factory has not been identified for housing 10. Development would 9. The Council has a need to discourage presence of safeguard existing employment bats land for employment uses 11. Development would 10 & 11. See 156/268 above discourage presence of owls who use field for hunting mice UCS 5.20 – 176/295 (Mills) Objects to development of this Officers recommend that this Land off Lady site with respect to: site be dropped from the Harriet’s SHLAA as landowner unwilling Lane 1. Detrimental effect on to release land for respondents property 1. Noted. Not considered a spatial planning issue development as the site is in
437 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 2. Concerns over passing 2 & 3. Comments from the use by Trinity High School space for vehicles travelling Highways Engineer conclude the length of the lane that Lady Harriet’s Lane is considered to be of sufficient 3. Maintenance of unadopted width to accommodate a small land with increased traffic increase in traffic generation of up to 7 units. The visibility at the junction of Easemore Road is also considered suitable due to the new guidelines outlined in Manual for Streets. It will be necessary to improve the lane in line with adoptable construction standards and a dedicated footpath will be necessary, given the current designation as a public right of way. It is considered that this could be accommodated, together with a suitable carriageway within the current 4. Lack of privacy confines of the Lane 4. Noted. Not considered a 5. Consideration of covenants spatial planning issue relating to lane 5. Noted. Extent of ownership boundaries confirmed with Legal team.
438 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 6. Access for maintaining leylandii border tree line 6. Unaware why existing maintenance access should be 7. Light pollution from all affected weather sports pitch effecting proposed 7. Existing boundary planting development should offer screening UCS 3.43 – 177/296 Objects to development of this 1. Noted. Refer to response no. See 124/196 above Land east of (Cooke) site with respect to: 124/196 Longfellow Close 1. Loss of recreation space and safe play space for children UCS 8.10 – 178/297 Objection to development of This site was previously See action at 126/198 above Land at (Lewis) this site with respect to: identified as a road reserve for McDonalds the Alcester Highway Island, 1. Increased traffic volume at extension, to connect to the Oakenshaw roundabout Studley Bypass. The Bypass 2. Concerns over location of scheme was subsequently residential access road for revoked and the land not this site in relation to bend needed for transport of Grangers Lane as car development. Therefore speed is an issue development of the site in principle has previously been established
439 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 1 & 2. See 126/198 and 131/204 above UCS 9.1 – 179/298 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Harris) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space & and safe play space for Ravensmere children Road RB003 - 180/300 Objects to development of this 1. Noted that Central Ward has None Widney (Parry) site with respect to: an open space surplus of House & +6.35 ha per 1000 population. adjoining 1. Open space forms The overall Borough standard important green wedge land, of unrestricted open space is Bromsgrove between large-scale 9.08Ha/1000 population. Road residential areas Comparison with the NPFA standard (2.4Ha/1000 population) shows that there
are 8.6Ha/1000 population of formal open space, which is considered to be a healthy figure. In comparison, Redditch Borough has at least
3.1Ha/1000 population more open space than any other Worcestershire district. Furthermore, no SHLAA
440 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. identifications on unrestricted open space would result in approximately 260 additional dwellings (8Ha) being allocated on Green Belt land
2. Open space forms part of 2. Comments from Leisure RB003 - the current play and sports Services conclude that the Widney provision in the area (junior junior football pitch is in the House & football) ownership of Worcestershire adjoining 180/300 County Council, it does not land, (Parry) form part of the current playing Bromsgrove pitch provision and RBC can Road accommodate all playing pitch requirements within existing formal playing field provision. It is used by Redditch United informally, however, this has no implications for the development of this site 3. Demolition of properties on Bromsgrove Road would be 3. Noted. However, detrimental to the character development of this nature has and layout of the residential been carried out in other parts area of Redditch, therefore precedent already set but would be a matter at planning 4. New access road may application stage create additional road 4. Comments from the
441 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. safety issues Highway Engineer conclude that whilst there is unlikely to be a major issue introducing an additional volume of traffic onto Bromsgrove Road, the volume indicated would require a Transport Assessment to accompany any Planning Application, to identify any potential problem areas in the vicinity of the site, together with any improvements to public transport facilities and the walking/cycling network.
The existing access is considered unsuitable in its current form to serve the maximum number of dwellings; approximately 50 units are considered to be the maximum from this access point. RB003 - Widney Subject to any additional House & access meeting the relevant design criteria, there would be adjoining land, no objection to this provision to
442 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Bromsgrove further serve the site Road 180/300 (Parry) Webheath 181/301A Site considered suitable for See 104/005/013 (RPS) 14 See action at 104/005/013 ADR – (Lloyd) inclusion in the SHLAA for the above (RPS) 14 above Woodyard following reasons: Garage site 1. Brownfield site in the Green Belt 2. Non-conforming industrial use in an existing residential area 3. Assist the development of the ADR
UCS 3.43 – 182/304 Objects to development of this 1. The path will not be affected See 124/196 above Land east of (Morris) site with respect to: by the development of this site Longfellow Close 1. Loss of safe path provided for school children UCS 8.10 – 183/305 Objects to development of this This site was previously See action at 126/198 above Land at (Cund) site with respect to: identified as a road reserve for McDonalds the Alcester Highway
Island, extension, to connect to the Oakenshaw Studley Bypass. The Bypass
443 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. scheme was subsequently revoked and the land not needed for transport development. Therefore development of the site in principle has previously been 1. Pedestrian safety at established crossing point adjacent to indicative road access 1. Response from the Highways Engineer concluded that there is a reasonable crossing point provided already and additional pedestrian 1. None movements would be sufficient to require an upgraded crossing in this location. Furthermore, there would not be a major issue leaving it in 2. Increased pollution from it's current position, even with a higher traffic volume new residential access
2 & 7. It is considered that traffic congestion will only increase at am & pm peak times as people leave/return a residential area. As such, UCS 8.10 – 3. Lineholt Close footpath congestion and pollution is not Land at protected by trees which currently considered to have a McDonalds form noise buffer from significant impact Island,
444 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Oakenshaw roads 3. Trees alongside Lineholt Close footpath will not be 183/305 4. Impact on wildlife removed 2 & 7. None (Cund) 5. Loss of open space
4. See 131/204 above 6. Increased impact on drainage at Grangers Lane/ 5. Noted. Refer to response no. roundabout junction which 126/198 occasionally floods 6. Report by the Operations 7. Increased impact from air Manager (Assets Maintenance) pollution concludes that he is unaware of any flooding issues in the vicinity although there is 3. None possibly a susceptibility to surface water flooding, possibly due to inadequate or poorly maintained highway drainage – 8. Impact of social housing this is not a valid reason to 4. See 131/204 above exclude the site from the 5. See 126/198 above SHLAA
8. National Planning Policy (PPS3) requires all 6. None development of 15 dwellings or more to accommodate a percentage of affordable housing units. Requirements in
445 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Redditch are set out in the SPD on Affordable Housing (January 2008)
8. None UCS 9.1 – 184/306 Objects to development of this 1. Noted. Redditch has a See action at 145/228 above Land to the (Wilkes) site with respect to: perpetual requirement to rear of provide housing and Watery Lane 1. There has been enough employment to accommodate & development in this area its evolving population and Ravensmere over the last 10 years workforce Road 2. Loss of recreation space for 2. Noted. Refer to response no. children 145/228 UCS 9.1 – 186/308 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Hallahan) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space for
446 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. & children Ravensmere Road 2. Increased traffic congestion 2. Comments from the in the Studley Road vicinity Highways Engineer conclude that the Studley Road junction is capable of accommodating additional traffic, however, it may be necessary to carry out some re-configuration to the service road fronting Studley Road, in order to prevent conflict. There are no further reaching issues on traffic generation in the area. 3. No prior knowledge of consultation period 3. The SHLAA forms part of the evidence base to support the Core Strategy. The Core Strategy and its supporting evidence documents were available for public consultation between 31 October 2008 and 8 May 2009. This consultation period was publicised in the local press, at neighbourhood groups, on the Council’s web site, in Redditch Matters, in a cinema advert and at a number of drop-in sessions at various
447 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. locations around the town UCS 9.1 – 187/309 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Zagwoski) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space for & children Ravensmere Road UCS 9.1 – 188/310 Objects to development of this 1. The SHLAA identifies a See action at 145/228 above Land to the (Reed) site with respect to: capacity ranging from 30 to 50 rear of dwellings per hectare. 1. SHLAA identifies a range of Watery Lane However, guidance suggest & 13-22 dwellings that indicative schemes can Ravensmere give a more realistic capacity Road figure, hence 16 dwellings based on the indicative
scheme, has been used in the final analysis of land with development potential 2. Loss of Primarily Open 2. Respondent is correct in its Space. RBC as landowner interpretation of Policy R.1 may determine the sites criteria with respect to open suitability for development space need being weighed up against Policy R.1 in its own against development need. financial favour to the With respect local authority detriment of the residents ‘conspiracy’ in matters such as this, Estates dept would
448 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. present a case for open space land to be made over for development, the Planning dept would analyse the strength of the case independently as part of the planning application process and the Site Allocations DPD process. Any application made by the Borough Council would automatically be presented to Committee and would therefore 3. Impact on wildlife, in be in the public arena particular, bats. Not aware of existence of detailed 3. See 156/268 above analysis
4. Loss of recreation and play space 5. Vehicle speeds along 4. Noted. Refer to response no. Watery Lane are 145/228 inadequately controlled 5. Comments from the Highway Engineer conclude that the issue of speeding traffic in Watery Lane and Hoveton Close is undoubtedly down to local traffic as there is 6. Position of Watery Lane/ no through route
449 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Studley Road junction is 6. See 186/308 above poorly positioned for current traffic levels 7. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath 7. See 157/269 above 8. Requests that all residents of Watery Lane and Ravensmere Road are notified of the annual SHLAA update 8. Results from actions associated with this site/ consultation period will determine whether it remains in the SHLAA or is removed. If it remains in the SHLAA, notification of any subsequent planning application would be sent to affected residents
450
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 189/311 (Print) Objects to development of this 1. See 157/268 above See action at 145/228 above Land to the site with respect to: rear of 1. Impact of increased traffic Watery Lane & along Watery Lane and Ravensmere Ravensmere Road Road 2. Noted. Refer to response no. 2. Loss of children’s play 145/228 space 3. See 157/269 above 3. Increase drainage/ flooding impact on existing development/ rear gardens (61 Ravensmere Road) 4. Site ‘handed over’ many 4. No title deed information has years ago solely for been forthcoming to date to recreational purposes verify this point 4. Investigate land title deeds with Estates dept UCS 9.1 – 190/312 Objects to development of this See action at 145/228 above Land to the (Taylor) site with respect to: rear of 1. Increased traffic congestion Watery Lane 1. See 186/308 above & in the Studley Road vicinity Ravensmere at what is already considered to be an
451 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Road accident ‘black spot’ 2. Loss of recreation space and safe play space for children 2. Noted. Refer to response no. 145/228 3. Concerns of access between new development 3. Comments from the and Hoveton Close could Highways Engineer conclude cause a ‘rat-run’ through to that the issue of motorcyclists the Studley Road, which is is a police matter for already a problem with enforcement and not will be motorcyclists. Unacceptable exacerbated by this proposal mix of pedestrian and vehicular use
4. Public footpath from Studley Road to Ravensmere Road would become a no go area at 4. Noted. Anti-social behaviour night time which already issues are taken into account suffers from anti-social as part of planning application behaviour consultation with Police and Secured by Design standards UCS 8.10 – 191/313 Objects to development of this This site was previously See action at 126/198 above Land at (Selwood) site with respect to: identified as a road reserve for McDonalds the Alcester Highway Island, extension, to connect to the Oakenshaw Studley Bypass. The Bypass
452 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. scheme was subsequently revoked and the land not needed for transport development. Therefore development of the site in principle has previously been 1. Concerns over social established housing 1. National Planning Policy (PPS3) requires all development of 15 dwellings or more to accommodate a percentage of affordable 1. None housing units. Requirements in Redditch are set out in the SPD on Affordable Housing 2. Pedestrian safety at (January 2008) crossing point adjacent to indicative road access 2. See 183/305 above
3. Footpath provides a safe, straight route to the hospital
4. Land provides a ‘green lung’ to buffer traffic 3. Footpath route should pollution remain unaffected 4 & 7. It is considered that 2. See 183/305 above traffic congestion will only increase at am & pm peak times as people leave/return a
453 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. residential area. As such, noise and pollution are not currently 5. Land provides a noise considered to have a 3. None barrier from the dual significant impact carriageway 5. Land mass would not be 4. & 7. None flattened - no reason why development on this site should reduce current noise 6. Impact on wildlife barrier from roundabout traffic 7. Increased traffic noise and 6. See 131/204 above pollution
5. None
6. See 131/204 above
UCS 9.1 – 192/314 Objects to development of this See action at 145/228 above Land to the (Burgoyne-
454 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. rear of Elvins) site with respect to: Watery Lane & 1. Loss of recreation space 1. Noted. Refer to response no. Ravensmere and safe play space for 145/228 children Road 2. & 3. See 157/269 above 2. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
3. Impact of increased traffic along Watery Lane and Ravensmere Road
4. Impact on wildlife
4. See 156/268 above UCS 9.1 – 193/315 Objects to development of this See action at 145/228 above Land to the (Abbott) site with respect to: rear of Watery Lane 1. Loss of recreation space and safe play space for 1. Noted. Refer to response no. & 145/228 Ravensmere children Road 2. Increased traffic impact/ 2. See 186/308 above safety impact for Hoveton Close residents accessing Studley Road
455 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. New development will ruin the aesthetics and community spirit of the area 3. Aesthetics of a development is a consideration at any planning application stage. Community spirit is unlikely to be affected by 16 new dwellings UCS 9.1 – 194/316 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Street) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space 2. Noted. Refer to response no. & and safe play space for 142/225 for comments on Ravensmere children Redditch Health Profile Road 2. Increase in childhood obesity UCS 9.1 – 195/317 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Sears) site with respect to: 145/228 rear of 1. Loss of recreation space 2. See 157/269 Watery Lane & and safe play space for Ravensmere children Road 2. Impact of increased traffic along Watery Lane and Ravensmere Road UCS 9.1 – 196/318 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above
456 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Land to the (Sears) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space & 2. Increase in drainage/ 2. See 157/269 above Ravensmere flooding impact on existing Road development/ rear gardens (32 Ravensmere Road) 3. Impact of increased traffic along Watery Lane and Ravensmere Road 3. & 4. See 157/269 above 4. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath UCS 9.1 – 197/319 Objects to development of this See action at 145/228 above Land to the (Pearce) site with respect to: rear of 1. Inadequate drainage and Watery Lane 1. See 157/269 above & flooding concerns along Ravensmere Watery Lane and Road Ravensmere Road
2. Impact of increased traffic along Watery Lane and Ravensmere Road 2. See 157/269 above 3. Impact of construction
457 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. related traffic 4. Safety issue of Watery Lane properties fronting directly onto Watery Lane 3. Disruption from construction and lack of footpath is a temporary issue. 5. Loss of recreation space 4. See 157/269 above
5. Noted. Refer to response no. 145/228
UCS 3.43 – 198/598 Objects to development of this 1. See 124/196 above See 124/196 above Land east of (Ridgeway) site with respect to: Longfellow Close 1. Increased traffic flow through Close IN69 – Land 199/322 (Bray) 1. Site excluded from SHLAA. In light of the RSS EiP Panel Investigate contribution this site to the rear of Land should immediately be Report and Redditch’s could make towards the Alexandra designated for housing requirement to find land for housing target for 2010 SHLAA Hospital development around 4000 dwellings within refresh the Borough Boundary, this site will be investigated to determine the contribution it could make towards the housing target
458 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 200/326 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Orme) site with respect to: 145/228. There are no plans to rear of remove the play area Watery Lane 1. Loss of recreation space & and safe play space for 2. Public Rights of Way would Ravensmere children be retained Road 2. Loss of Public Right of Way 3. Comments from Leisure Services confirm that all 3. Section 106 agreements to monies collected far and fund an infant play space allocated to the play area not fully honoured provision have been spent on this facility UCS 3.43 – 201/327 Objects to development of this See 124/196 above Land east of (Poole) site with respect to: Longfellow Close 1. Loss of open space/ recreation land 1. Noted. Refer to response no. 124/196 2. Effect on existing hedgerows, flora and fauna 2. See 124/196 above 3. Increased traffic flow through Close 3. See 124/196 above 4. Loss of on-street car parking bay 4. No definitive scheme is in place for this site and the 5. Other more suitable sites
459 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. than this are available for parking bay may be excluded development 5. 56% of sites identified in the SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation SHLAA 202/334 Objection to the manner in Further to the CLG Good None methodology (Tetlow King) which sites have been Practice Guidance (2007), PAS assessed, resulting in a produced an additional number of site groupings being guidance note (July 2008) to excluded as ‘competing land be read in conjunction with the uses’. At odds with the purpose CLG Guidance. Para 49 of the of the SHLAA. Approach PAS note states that “whilst the dismisses consideration of a assessment will address range of sites which has whether sites are suitable for resulted in a reduced overall housing, this should only be dwelling figure taken to mean that they are suitable provided they are not required for other purposes ” [my emphasis]. Para 50 goes on to state that “sites should not be included in the SHLAA which are not considered
460 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SHLAA 202/334 suitable or potentially suitable methodology (Tetlow King) for housing. This would present confusing messages… Moreover, their inclusion could give unwarranted credibility to such sites.” Officers consider that the para 6.6 bullet points of the SHLAA offer sufficient justification for the exclusion of sites where conflicting land uses may be an issue. The SHLAA states that such sites will be investigated at an appropriate time to establish whether they might contribute to the SHLAA if deemed necessary UCS 9.1 – 203/460 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Tabor) site with respect to: 145/228 rear of 1. Loss of recreation space / 2. Noted. Refer to response no. Watery Lane & play space for children 142/225 for comments on Redditch Health Profile Ravensmere 2. Increase in childhood Road obesity 3. The Council has a need to safeguard existing employment 3. Recent factory closures land for employment uses. would make brownfield 56% of sites identified in the sites more appropriate for SHLAA are on brownfield land.
461 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development The search for available and deliverable brownfield sites has 4. Drainage/ sewage problems been exhausted through this in this area process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation 4. See 157/269 above UCS 9.1 – 204/339 Objects to development of this See action at 145/228 above Land to the (Luckman) site with respect to: rear of 1. Impact of increased traffic Watery Lane 1. See 157/269 above & and emergency service Ravensmere access along Watery Lane Road 2. Anti social behaviour outside 1 Hoveton Close including excessive 2. Noted, however this is not a pedestrians (100 a day at spatial planning issue weekends), dropped litter, late night noise from people leaving taxis, around 50 cars a day turning round in Close. Fear that more houses will increase this problem 3. Impact on infrastructure in
462 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Watery Lane 4. Loss of recreation space
3. See 157/269 above 5. Access to Arrow Valley Lake from Hoveton Close needs blocking off as 4. Noted. Refer to response no. unsafe walking route and 145/228 would reduce foot traffic through Hoveton Close 5. Not a spatial planning issue and unlikely that a public right 6. Council should buy some of of way would be closed the unsold houses in Redditch to get the housing market moving again
6. Buying unsold houses would not eradicate the need for the Core Strategy to address Redditch’s growing population needs up to 2026 and make provision for additional homes UCS 9.1 – 205/340 Objects to development of this See action at 145/228 above Land to the (Gorton) site with respect to: rear of Watery Lane 1. Loss of recreation space / play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere
463 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Road 2. Impact of increased traffic 2. & 3. See 157/269 above along Watery Lane and Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath 4. Impact of development on Watery Lane/ Studley Road junction 4. See 186/308 UCS 9.1 – 207/342 (Fry) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of Watery Lane 1. Loss of recreation space / safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Why are more houses Road needed in Greenlands? 2. Credit crunch/ recession is Credit crunch/recession not a spatial planning issue. would make them The allocation of land for unaffordable and be a dwellings is to meet the waste of time building them growing population needs of Redditch up to 2026 and is necessary irrespective of economic climate 3. Increased traffic congestion 3. See 186/308 above.
464 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. in the Studley Road vicinity Furthermore, crossing points at what is already are provided on Studley Road considered to be an adjacent to Hoveton Close and accident ‘black spot’ at the Barlich Way junction, both are considered to be in the optimum position for school access. The siting of Bus stops is in line with government recommendations
4. Noted. Refer to response no. 4. Increase in childhood 142/225 for comments on obesity Redditch Health Profile
UCS 9.1 – 209/345 Objects to development of this 1 & 2. Noted. Refer to See action at 145/228 above Land to the (Harris) site with respect to: response no. 145/228 rear of Watery Lane 1. Loss of recreation space / 3. Noted. Natural surveillance & safe play space for children issues are taken into account as part of planning application Ravensmere 2. Facility contributes to Road consultation with Police and community cohesion Secured by Design standards 3. Loss of natural surveillance of play area and noise nuisance for new properties from existing play area
465 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 211/347 Objects to development of this See action at 145/228 above Land to the (Wood) site with respect to: rear of Watery Lane 1. Loss of recreation space / safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Children play on road in Road Hoveton Close. Speed of 2. See 207/342 above traffic along Hoveton Close is a danger UCS 9.1 – 213/354 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Davies) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space / & safe play space for children Ravensmere Road UCS 9.1 – 214/355 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Ridge) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space / & safe play space for children Ravensmere Road UCS 5.20 – 215/356 Objects to development of this See action at 176/295 above Land off Lady (Whitfield) site with respect to: Harriet’s 1. SHLAA analysis form states
466 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Lane that there is no Public Right 1. Noted. Officer considers that of Way on site. ‘Leafields’ the analysis form is correct in has private right of way stating that no Public Right of access Way exists 2. Each property boundary 2. Noted. Extent of ownership along Lady Harriet’s Lane boundaries confirmed with runs along the centre line of Legal team. the Lane. Access to site would require crossing private land. Restrictive covenants to prevent nuisance and damage nuisance may result in compensation claims 3. Concerns over passing space for vehicles accessing the single track lane 3, 4 & 5. See 176/295 4. Pedestrian safety as there is no pavement
5. Impact of increased traffic on junction of Lady Harriet’s Lane/ Easemore Road 6. Light pollution from all weather sports pitch
467 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. effecting proposed development
7. Impact on wildlife (bats, foxes, birds) 6. Existing boundary planting should offer screening 8. Site has historical significance 7. Biodiversity unable to gain access to the site as gated and locked and in school ownership
8. Historic Environment Records (HER) at Worcestershire County Council was contacted to investigate this claim further. HER investigation reveals that there was a small building on the site in 1886 but it does not appear on the earlier 1813 map but it may have been too small to have been drawn. This is the only finding within the site. The field pattern suggests 9. Effect on current public Parliamentary Enclosure but utilities (low water pressure, there is no further information drain blockages) to suggest historic significance. This information alone would
468 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. not preclude development of this site
9. Comments from the Assets Maintenance Officer conclude that there maybe, subject to STW approval, capacity for additional foul drainage to the existing public sewer network. Surface water will require balancing to green-field run-off, prior to discharge. Connections to the public foul sewer may be possible require relatively short, off-site works. However, the existing foul sewer is only 100mm diameter and there is no surface water sewer - nearest available, subject to levels, is situated within 10. Disruption to existing Easemore Road. If water residents if services need pressure is already a problem, upgrading then additional dwellings would certainly make matters worse. 11. Loss of privacy and light to Again, due to probable ‘Cropthorne’ inadequate size, the existing foul drain problems are likely to get worse although it could be
469 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. due to lack of flow 10. Disruption from such work is a temporary issue
11. Issues such as overlooking and loss of light are considered as part of the planning application process UCS 8.10 – 216/357 Objection to proposed building Noted See action at 126/198 above Land at (Prevett) of around 30 dwellings as McDonalds outlined in Redditch Matters Island, Oakenshaw UCS 9.1 – 218/359 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Turner) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space / & safe play space for children Ravensmere Road
UCS 9.1 – 219/360 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the
470 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. rear of (Turner) site with respect to: 145/228 Watery Lane & 1. Loss of recreation space / Ravensmere safe play space for children Road UCS 9.1 – 220/362 Objects to development of this See action at 145/228 above Land to the (Forbes) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Increase in childhood Road obesity 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile 3. Use brownfield sites in 3. The Council has a need to Redditch such as Alcan and safeguard existing employment land by Redditch Station land for employment uses and other land for essential uses such as town centre functions. 56% of sites identified in the SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the
471 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Borough’s housing allocation
UCS 9.1 – 221/363 Objects to development of this See action at 145/228 above Land to the (Buck) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Existing flooding issues in Road the local area would be 2. See 157/269 above exacerbated 3. Use other, more run down sites for housing rather than green areas 3. 56% of sites identified in the SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the Borough’s housing allocation
472
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 222/364 Objects to development of this See action at 145/228 above Land to the (Norton) site with respect to: rear of Watery Lane 1. Loss of Primarily Open Space which is used by 1. Noted. Refer to response no. & 145/228 Ravensmere residents in Greenlands & Road Lodge Park Wards which have an under-provision of open space 2. No direct access to the site from Studley Road. Only accessible from Watery 2. Noted but access from Lane which would be a very Studley Road is not a necessity indirect route to reach new houses
3. Width of Watery Lane for increased traffic and access for construction traffic 3. & 5. See 157/269 above 4. Impact on Watery Lane/ Studley Road junction from construction traffic causing congestion 4. See 186/308 above. 5. Impact of emergency However, disruption from service access along construction traffic is temporary Ravensmere Road
473 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 6. Inadequate drainage and flooding concerns along Watery Lane and Ravensmere Road. Marked as ‘Historic Flooding Site 88’ in Strategic Flood Risk Assessment (SFRA) 6. See 157/269 above. Furthermore, the site is not within the Environment Agency Flood Zones 2 or 3. Historic flooding records (SFRA) states that approximately 7 dwellings 7. Core Strategy, when flooded in July 2007 due to adopted will include policy mechanical, structural or H.2 which states the operational failure and importance of protecting localised surface water and enhancing open space. flooding. This , unlike other 4 of the 6 policy criteria are historic listings is not listed as a extremely relevant to the repeated incident protection of this site against development. 7. Policy H.2 in the Preferred Draft Core Strategy is derived from the existing BORLP 3 Policy R.1. The criteria are used to assess the open space need weighed up against development need. Developers would present a case for open
474 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. space land to be made over for development, the Planning dept would analyse the strength of the case independently as part of the planning application process and the Site Allocations DPD process UCS 9.1 – 225/368 (May) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact on wildlife Road 2. See 156/268 above 3. Impact on Watery Lane/ Studley Road junction as 3. See 186/308 above Studley Road is busy and fast UCS 9.1 – 226/369 (Stait) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of Watery Lane 1. Loss of recreation space/ play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. & 3. See 157/269 above
475 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath 4. Increase in childhood obesity
4. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile
UCS 9.1 – 227/370 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Morgan) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & play space for children Ravensmere Road UCS 9.1 – 228/371 Objects to development of this See action at 145/228 above Land to the (Ingles) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere
476 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Road 2. Impact of increased traffic 2. & 3. See 157/269 above along Watery Lane and Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath UCS 9.1 – 229/372 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Farley) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & safe play space for children Ravensmere Road UCS 9.1 – 230/373 Objects to development of this See action at 145/228 above Land to the (Ullah) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. & 3. See 157/269 above Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane
477 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. and lack of footpath 4. Inadequate drainage and flooding concerns along Watery Lane 5. Increase drainage/ flooding 4. See 157/269 above impact on existing development/ rear gardens (Ravensmere Road) 6. Significant impact on 5. See 157/269 above property values
6. Noted but not a spatial planning matter UCS 3.43 – 231/374 Objects to development of this 1 & 2. Noted. Refer to See 124/196 above Land east of (Lewis) site with respect to: response no. 124/196. Policy Longfellow R.1 in BORLP 3 has criteria Close 1. Loss of open space/ safe which are used to assess the recreation land. Council’s open space need weighed up Culture & Recreation against development need. chapter of Local Plan No.3 Developers would present a states that it is important to case for open space land to be protect and enhance open made over for development, space so why destroy it
478 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the Planning dept would analyse the strength of the case independently as part of the planning application process and the Site 2. Access to open space Allocations DPD process. reduces health risks and crime related offences 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile.
Contextual information indicates that the perception of crime appears high. However, the Redditch Scoping Report (April 2009) shows that the recorded crime change 2006/07-2007/08 decreased by 4% in Redditch compared to 3. Increased traffic flow 3% in West Mercia. ‘Places through Close and Spaces’ policy in the Core Strategy would address such 4. Existing school-run traffic issues parks opposite Longfellow Close 3. See 124/196 above 5. Effect on existing wildlife 4. Noted but not a spatial
479 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 6. Development will be on a planning matter flood plain. Strategic Flood Risk Assessment (SRFA) states that Wharrage Brook 5. See 124/196 above is classed as a flood risk 6. See 124/196 above UCS 9.1 – 232/375 Objects to development of this See action at 145/228 above Land to the (Orange) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road 2. See 157/269 above 3. Ravensmere Road suffers with drainage issues 3. See 157/269 above UCS 9.1 – 233/376 Objects to development of this See action at 145/228 above Land to the (Taylor) site with respect to: rear of Watery Lane 1. Loss of recreation space/ play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact on Watery Lane/ Road Studley Road junction as 2. See 186/308 & 207/342 Studley Road is busy and above fast. Many parked cars on Studley Road at school drop off/collection times.
480 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Bus stop in this vicinity 3. Anti social behaviour is uncontrolled and bus stops are continually smashed
3. Noted. Anti-social behaviour issues are taken into account 4. Concerns of access as part of planning application between new development consultation with Police and and Hoveton Close could Secured by Design standards cause a ‘rat-run’ through to the Studley Road, which is 4. See 190/312 above. already a problem with However, not a spatial planning motorcyclists. Unacceptable matter mix of pedestrian and vehicular use UCS 9.1 – 234/377 Objects to development of this See action at 145/228 above Land to the (Anderson) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. & 3. See 157/269 above Ravensmere Road 3. Safety issue of Watery
481 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Lane properties fronting directly onto Watery Lane and lack of footpath UCS 9.1 – 235/378 Objects to development of this See action at 145/228 above Land to the (Deaves) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of childhood obesity Road 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile 3. Impact on wildlife (bats) 3. See 156/268 above 4. Impact of increased traffic along Watery Lane and 4. & 5. See 157/269 above Ravensmere Road 5. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
6. Inadequate drainage and flooding concerns along Watery Lane 7. Impact on Watery Lane/ 6. See 157/269 above Studley Road junction as
482 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Studley Road is busy and fast. Many parked cars on Studley Road at school drop off/collection times 7. See 186/308 above UCS 9.1 – 236/379 Objects to development of this See action at 145/228 above Land to the (Perkins) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Loss of facility may Road increase anti social 2. Noted. Anti-social behaviour issues are taken into account behaviour as part of planning application consultation with Police and Secured by Design standards
3. Impact of childhood obesity 3. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile
4. & 5. See 157/269 above 4. Impact of increased traffic along Watery Lane and Ravensmere Road
5. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
483 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 6. Ravensmere Road is a cul- de-sac, making it a thoroughfare would be detrimental to the area 6. Indicative scheme suggests that Ravensmere Road would 7. Impact on existing flooding issues in the vicinity remain a cul-de-sac if development were to take 8. 16 houses wont make any place difference to the current housing issues. Build on 7. See 157/269 above
larger areas such as Windsor Road development. There are 8. Any size site will make a empty offices and old contribution to the Borough’s factory sites in Redditch housing allocation. The Council which could easily has a need to safeguard accommodate more than 16 existing employment land for houses employment uses and other land for essential uses such as town centre functions. 56% of sites identified in the SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the
484 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – Borough’s housing allocation Land to the rear of 236/379 Watery Lane (Perkins) & Ravensmere Road UCS 9.1 – 237/380 (Kite) Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & safe play space for children Ravensmere Road UCS 9.1 – 238/381 Objects to development of this See action at 145/228 above Land to the (Kondola) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Pedestrians at greater risk Road from traffic when accessing 2. Highway and footpath path across playing field standards and safe access to public rights of way would be a consideration at planning application stage 3. Impact of increased traffic along Watery Lane and 3. & 4. See 157/269 above
485 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Ravensmere Road 4. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath 5. Impact on existing flooding issues in the vicinity
5. See 157/269 above
UCS 9.1 – 239/382 (Gee) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of childhood obesity Road 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile
3. See 157/269 above 3. Impact of increased traffic on already overcrowded roads UCS 9.1 – 240/383 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above
486 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Land to the (Dicker) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & safe play space for children Ravensmere Road UCS 9.1 – 241/384 Objects to development of this See action at 145/228 above Land to the (Smith) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. & 3. See 157/269 above Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
4. Impact on childhood obesity
5. Impact on existing flooding 4. Noted. Refer to response no. issues in the vicinity 142/225 for comments on Redditch Health Profile
487 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 5. See 157/269 above UCS 9.1 – 242/385 (Ray) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact on existing flooding Road and sewage issues in the 2. See 157/269 above vicinity 3. Impact of increased traffic along Watery Lane and Ravensmere Road 3. See 157/269 above 4. Many parked cars on Studley Road at school drop off/collection times add to traffic congestion 4. See 186/308 and 207/342 5. Playing field acts as a above rainwater soakaway
5. See 157/269 above. Other issues have been raised regarding rear garden flooding 6. Impact on wildlife from rainwater along Ravensmere Road so it is
488 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 7. Loss of quality of life questionable whether the playing field is sufficient as a soak away 6. See 156/268 above 7. Noted. Quality of life is a very important element of spatial planning. However, striking an appropriate and harmonious balance in Redditch is currently hampered by the fact that the available land identified in the SHLAA to meet the Regional Housing Allocation for the Borough falls short of this allocation UCS 9.1 – 243/386 Objects to development of this See action at 145/228 above Land to the (Watkins) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Detrimental effect on Road property values 2. Impact on property values is not considered to be a spatial planning matter 3. Impact of increased traffic along Watery Lane and 3. See 157/269 above
489 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Ravensmere Road 4. Impact on existing flooding issues of Ravensmere Road gardens 4. See 157/269 above
490
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 244/387 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Towler) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & safe play space for children Ravensmere Road UCS 9.1 – 245/388 Objects to development of this See action at 145/228 above Land to the (Arnott) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Additional congestion on Road Studley Road 2. See 186/308 above 3. More suitable sites in Redditch for development 3. The Council has a need to such as derelict factory safeguard existing employment units land for employment uses and other land for essential uses such as town centre functions. 56% of sites identified in the SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of
491 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. greenfield land has had to be considered to meet the Borough’s housing allocation
UCS 9.1 – 246/389 Objects to development of this 1. Noted. Refer to response no. See action at 145/228 above Land to the (Mellor) site with respect to: 145/228 rear of Watery Lane 1. Loss of recreation space/ & safe play space for children Ravensmere Road UCS 9.1 – 247/390 Objects to development of this See action at 145/228 above Land to the (Russo) site with respect to: rear of 1. Impact on existing flooding Watery Lane 1. See 157/269 above & issues in the vicinity of Ravensmere Studley Road Road UCS 9.1 – 248/391 Objects to development of this See action at 145/228 above Land to the (Carroll) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. See 157/269 above
492 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Ravensmere Road 3. Detrimental effect on property prices 3. Impact on property values is not considered to be a spatial planning matter UCS 9.1 – 249/392 Objects to development of this See action at 145/228 above Land to the (Smith) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road 2. See 157/269 above along Watery Lane and Ravensmere Road
3. Recreational ground donated by builder of Watery Lane homes 3. Title deed information indicates that the land was purchased by Redditch Urban District Council in 1957 from Reginald Charles Martin. There is no indication that this land was to remain in recreation use UCS 9.1 – 250/393 (Peel) Objects to development of this See action at 145/228 above Land to the site with respect to: rear of
493 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Watery Lane 1. Loss of recreation space/ 1. Noted. Refer to response no. & safe play space for children 145/228 Ravensmere Road 2. Impact of increased traffic 2. See 157/269 above along Watery Lane and Ravensmere Road 3. Recreational ground donated by builder of 3. See 249/392 above Watery Lane homes
UCS 9.1 – 251/394 Objects to development of this See action at 145/228 above Land to the (Shelton) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Recreational ground left to Road residents in a will 2. See 249/392 above 3. Impact of increased traffic along Watery Lane and 3. & 4. See 157/269 above Ravensmere Road
4. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath UCS 9.1 – 252/395 Objects to development of this See action at 145/228 above
494 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Land to the (Laight) site with respect to: rear of Watery Lane 1. Loss of recreation space/ 1. Noted. Refer to response no. & safe play space for children 145/228 Ravensmere 2. Recreational ground left to 2. See 249/392 above Road residents in a will
3. Impact of childhood obesity 3. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile 4. Impact of increased traffic along Watery Lane and 4. & 5. See 157/269 above Ravensmere Road 5. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
6. Detrimental effect on property prices
6. Impact on property values is not considered to be a spatial planning matter UCS 9.1 – 253/396 Objects to development of this See action at 145/228 above Land to the
495 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. rear of (Gough) site with respect to: Watery Lane & 1. Loss of recreation space/ 1. Noted. Refer to response no. Ravensmere safe play space for children 145/228 Road 2. Impact of childhood obesity 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile 3. Road running right through 3. There are no plans for the field would make remaining road to extend beyond the area field unsafe identified as having housing potential 4. Impact of increased traffic 4. & 5. See 157/269 above along Watery Lane and Ravensmere Road 5. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath 6. Detrimental effect on property prices
6. Impact on property values is not considered to be a spatial planning matter
496 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. UCS 9.1 – 254/397 Objects to development of this See action at 145/228 above Land to the (Bradbury) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. See 157/269 above Ravensmere Road 3. Existing sewage system prone to flooding 3. See 157/269 above 4. Impact on well established community 4. Community spirit is unlikely to be affected by 16 new dwellings UCS 9.1 – 255/398 Objects to development of this See action at 145/228 above Land to the (Mason) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1 & 9. Noted. Refer to & response no. 145/228 Ravensmere 2. Impact on health/obesity Road 2. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile
497 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 3. Impact of increased traffic 3. See 157/269 above along Watery Lane and Ravensmere Road 4. Existing sewage system prone to flooding 4. See 157/269 above 5. Reduction in quality of life of existing residents 5. Noted. Quality of life is a very important element of spatial planning. However, striking an appropriate and harmonious balance in Redditch is currently hampered by the fact that the available land identified in the SHLAA to meet the Regional Housing Allocation for the Borough falls 6. Impact on Watery Lane/ short of this allocation Studley Road junction which bottlenecks at peak 6. See 186/308 above times
7. Impact on wildlife (including bats) 8. Watery Lane and 7. See 156/268 above Ravensmere Road prone to flooding
498 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 9. OSNA states that 8. See 157/269 above Greenlands is poorly provided for in terms of open space UCS 9.1 – 256/399 Objects to development of this See action at 145/228 above Land to the (Whitcombe) site with respect to: rear of Watery Lane 1. Loss of recreation space/ play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. See 157/269 above Ravensmere Road UCS 9.1 – 257/400 Objects to development of this See action at 145/228 above Land to the (Cooke) site with respect to: rear of Watery Lane 1. Moved here for peaceful location 1. Noted but not a spatial & planning issue Ravensmere 2. Loss of recreation space/ Road safe play space for children 2. Noted. Refer to response no. 145/228 3. Impact of increased traffic along Watery Lane and 3. See 157/269 above Ravensmere Road 4. Area already prone to flooding
499 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 5. Detrimental effect on 4. See 157/269 above property prices 5. Impact on property values is not considered to be a spatial planning matter
UCS 2.16 – 258/401 (Friar) Objects to development of this 1. Comments from the See action at 138/221 above Land to the site with respect to: Biodiversity Officer conclude rear of that wildlife interest comes in 1. Impact on wildlife Sandygate the form of a thick hedge/ Close shrub area, with mature trees contained within it, which runs around the edge of the site. There are three or four large
ash trees and a smaller oak tree. There are also several other smaller trees of different species present as well. The size of these trees means that
they will have roots which will obviously run for several metres under the open space land. Any disturbance of the open space area would have a
500 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. very detrimental effect on the trees located around the edge of the open space site. The thick hedge and the trees will provide nesting sites for birds. It is also likely that bats will certainly be flying over and feeding here. They may be present actually in the mature trees, although unable to get close to the trees to inspect them, due to some very thick shrubs in front of them. An ecological survey to test for the presence of bats will be needed for this site.
Furthermore, the site appears to have an important function in acting as area which allows
rainwater to soak away. Apparently for much of the year the ground which rises to the east is very wet and quite 2. Loss of residents privacy boggy. There may also be UCS 2.16 – small springs which can Land to the 3. Webheath has had more suddenly appear at times of
501 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. rear of 258/401 (Friar) than its share of housing heavy rainfall Sandygate development Close 2. Noted. Unsure how privacy will be lost 4. Implications for flooding 3. The SHLAA has investigated the whole of Redditch’s urban area in an effort to find sites which contribute towards its housing allocation 4. Comments from the Assets Maintenance Officer conclude that there maybe, subject to STW approval, capacity for additional foul and surface water drainage to the existing public sewer network. Surface water will require balancing to green-field run-off, prior to discharge to a public sewer. Not aware of any flooding issues in the vicinity. Discharge limits are likely with approved measures to achieve such criteria. UCS 3.43 – 259/402 Objects to development of this 1. Noted. Refer to response no. See 124/196 above Land east of (Wright) site with respect to: 124/196 Longfellow
502 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close 1. Loss of open space 2. Impact on wildlife 2. See 124/196 above 3. Originally a water 3. See 124/196 above catchment area and should not be built upon UCS 9.1 – 260/403 Objects to development of this See action at 145/228 above Land to the (Edmonds) site with respect to: rear of Watery Lane 1. Loss of recreation space/ play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Against government Road campaign to encourage 2. Noted. Refer to response no. people to be more active 142/225 for comments on Redditch Health Profile 3. Impact of increased traffic along Watery Lane and 3. & 4. See 157/269 above Ravensmere Road 4. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
5. Area already prone to flooding 6. Detrimental effect on
503 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. property prices 5. See 157/269 above 6. Impact on property values is not considered to be a spatial planning matter Mettis 264/446/458 The Mettis Aerospace site was The Employment Land Review, None Aerospace (CB Richard previously submitted for Stage 3 (March 2009) Ellis) consideration for inclusion in concludes that this site should the SHLAA in March 2008. The be maintained for employment site was eliminated from uses (p. 89). There is no need detailed consideration stating to consider this site further for that its requirement for inclusion in the SHLAA employment uses was to be reviewed in the first instance in the ELR. The site may become unsuitable or unviable within its current employment use in the medium term. ON-site constraints such as flood risk and a watercourse could only be mitigated against if there was a high-value end-use such as housing. This site should be reconsidered by the SHLAA for residential use UCS 3.43 – 266/459 Objects to development of this 1 & 2. Indicative scheme See 124/196 above Land east of (O’Toole) site with respect to: indicates that existing footpaths Longfellow would remain untouched as a
504 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Close 1. Pathway would be moved consequence of development. Children will still have access 2. Children cross the field to to school school 3. See 124/196 above 3. Increased traffic flow through 4. No definitive scheme is in Longfellow Close place for this site and the parking bay may be excluded 4. Loss of on-street car parking bay 5. See 124/196 above
6. See 124/196 above 5. Impact on wildlife (bats) 6. Loss of open space 267/573/579 Notes that WYG considers the In light of the RSS EiP Panel Officers to identify sufficient (Barton Council’s assumptions in Report, and Redditch’s land to meet the RSS housing Willmore) respect of dwellings to be requirement to find land for target for Redditch of 4000 delivered through SHLAA to be 4000 dwellings within the dwellings unambitious and identify a Borough boundary, officers potential capacity across the need to identify sufficient land Borough for a further 187 to meet its housing target dwellings L4L01 – Land 268/596 Unsure of location of potential 1. Comments from Highways Scheme revision takes this off Banners (Richardson) site but has concerns Engineer conclude that there capacity below the SHLAA Lane regarding: are no highway implications threshold and should therefore
505 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 1. Increased traffic along associated with the be removed from the SHLAA Banners Lane construction of five dwellings in this location. The capacity of 2. Lack of parking Banners Lane is sufficient to accommodate the additional traffic without the need for improvement 2. Parking spaces for additional dwellings would be provided as part of a development scheme UCS 9.1 – 269/230 Objects to development of this See action at 145/228 above Land to the (Grant) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact of increased traffic Road along Watery Lane and 2. & 3. See 157/269 above Ravensmere Road 3. Safety issue of Watery Lane properties fronting directly onto Watery Lane and lack of footpath
4. Inadequate drainage and flooding concerns along Watery Lane
506 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 5. Increase drainage/ flooding 4. & 5. See 157/269 above impact on existing development/ rear gardens (Ravensmere Road) 6. Significant impact on property values
6. Noted but not a spatial planning matter UCS 9.1 – 270/765 Objects to development of this See action at 145/228 above Land to the (Coward) site with respect to: rear of Watery Lane 1. Loss of recreation space/ safe play space for children 1. Noted. Refer to response no. & 145/228 Ravensmere 2. Impact on Studley Road Road due to increased traffic, 2. See 186/308 and 207/342 poorly sighted bus stops above and no safe crossing area for school children
3. There are other more suitable sites in Redditch for new housing 3. 56% of sites identified in the
507 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SHLAA are on brownfield land. The search for available and deliverable brownfield sites has been exhausted through this process and the inclusion of greenfield land has had to be considered to meet the 4. Impact on well being of Borough’s housing allocation local residents 4. Noted. Quality of life is a very important element of spatial planning. However, striking an appropriate and harmonious balance in Redditch is currently hampered by the fact that the available land identified in the SHLAA to meet the Regional Housing Allocation for the Borough falls 5. Impact of childhood obesity short of this allocation 5. Noted. Refer to response no. 142/225 for comments on Redditch Health Profile UCS 8.10 – 271/766 Concerns about possible This site was previously See action at 126/198 above Land at (Tipper) development of this site having identified as a road reserve for McDonalds an impact on the following: the Alcester Highway Island, extension, to connect to the 1. Increased traffic congestion Studley Bypass. The Bypass
508 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Oakenshaw at roundabout especially at scheme was subsequently peak periods – roundabout revoked and the land not would need traffic lights needed for transport development. Therefore 2. Loss of green space and development of the site in footpaths principle has previously been established 1. See 126/198 above 2. Noted. Refer to response no. 126/198. No footpaths are expected to be lost as a result of this development RB003 - 272/1000 Objection to inclusion of site in Widney (Clack) the SHLAA and query of House & accuracy of survey information adjoining with respect to: land, Bromsgrove 1. ‘Current Land Use: 1. & 2. Land between Widney 1. & 2. None Road Industrial & part Works and the sports pitch is unused/vacant’ – no unused scrub land unused land included
2. There is no scrub land, only a sports field that is not mown 3. Noted and agreed 3. Part of the site is a sports 3. SHLAA refresh in April 2010 field and should count as a
509 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. greenfield site will acknowledge that the site is brownfield and greenfield 4. Removal of a sports pitch in an area already short of 4. None provision should count as 4. Comments from Leisure an adverse impact Services conclude that the playing field does not form part of the current playing pitch provision and is used by Redditch United informally, all playing pitch requirements can be accommodated within existing formal playing field provision adjacent to the site in question RB003 - 273/1001 Objection to inclusion of site in 1. Comments from the 1. None Widney (Bonham) the SHLAA and query of Highways Engineer conclude House & accuracy of survey information that whilst there is unlikely to 2. None adjoining with respect to: be a major issue introducing an land, additional volume of traffic onto Bromsgrove 1. Location of new access point Bromsgrove Road, the volume Road for the site between Vicarage indicated would require a Crescent and respondents Transport Assessment to house would increase accompany any Planning congestion and would form a Application, to identify any staggered crossroad potential problem areas in the 2. Loss of sports land in this vicinity of the site, together with area any improvements to public transport facilities and the
510 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. walking/cycling network. The existing access is considered unsuitable in its current form to serve the maximum number of dwellings; approximately 50 units are considered to be the maximum from this access point. Subject to any additional access meeting the relevant design criteria, there would be no objection to this provision to further serve the site 2. See 272/1000 above
Sustainability Appraisal
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Sustainability 088/529; Support inclusion of an HRA Noted. Reference to the Add the following to the SA Appraisal Natural Screening Assessment within response from Natural England Habitats Assessment Section
511 England the SA. The distance to the site will be made in the SA Report. of the SA "Natural England provides further evidence that responded to the a full HRA is not necessary and consultation on the Preferred should be stated in the report. Draft Core Strategy confirming that full HRA would not be required due to the distance between the Borough and Bredon Hill SAC." Sustainability 104/023; The SA process has not The SA process is fully SEA No change. Appraisal RPS complied with the requirements compliant and has been for SA under the Town and prepared in line with the Country Planning Act and the guidance for Regional Planning associated regulations, nor has Bodies and Local Planning it complied with the Authorities 'Sustainability SEA/Directive or Habitats Appraisal of Regional Spatial Directive. Because it does not Strategies and Local appraise realistic alternatives Development Documents' to the approach set out in the (November 2005). RBC had to Core Strategy, in addition to assess the implications of the not appraising the Core WYG Stage I and II findings to Strategy itself. The SA Core be able to consider all Strategy report has not alternative options. With responded to consultation regards to assessment of the representations from RPS SUE proposed by RPS, the promoting an urban extension, Borough Council undertook a nor has it considered more full SA of the WYG significantly the wider development areas and the five significance of appraising options in WYG, which include options for sustainable urban the area in question. This can
512 extensions. RPS expects be seen in the Sustainability detailed SA of all strategic Appraisal refresh (Consultation options and alternatives. 1 February 2010 - 15 March No change. 2010).
Question whether the current See Table 2: 'Matrix testing the SA report appraises the compatibility of the significance of the effects sustainability appraisal associated with the Core objectives and the draft DPD Strategy. objectives and assessing the cumulative effects of the DPD Objectives'. Objectives have been assessed to determine where significant effects are predicted from implementing more than one of the Objectives, and see also 'Cumulative impacts from the matrix testing the compatibility of the SA Objectives and the draft DPD Objectives.' The Options Appraisal of each issue and options also appraises the significance of each option being implemented in terms of their magnitude, their geographical scale, the time period over which they will occur, whether they are permanent or temporary,
513 positive or negative, probable or improbable, frequent or rare, and whether or not there are cumulative and/or synergistic effects. Sustainability 262/416; The WYG Stage II Report The Borough Council No change. Appraisal Homes & considers growth options for undertook a full SA of the WYG Communities Redditch in general terms. development areas and the five Agency However, it is not accompanied WYG options, tested against by an appraisal of the Redditch's SA Framework. SA sustainability credentials of of the options in and around each of the growth options for Redditch Borough should not Redditch carried out using the be assessed against the sustainability criteria set out in Regional Sustainable the RSS. Development Framework as this would not be meaningful. The RSDF did however influence the SA Framework against which the options are assessed. Sustainability 267/586; SA does not have an audit trail Further evidence in support of Production of series of Appraisal Barton demonstrating how the the preferred options will be Technical Papers are part of Wilmore c/o preferred option has been provided in the Technical the Core Strategy Evidence Barratt Homes arrived at and there is no Papers to be completed as part Base and consider where more and Taylor evidence to demonstrate how of the evidence base for the clarity over options selected as Wimpey the different options perform. Core Strategy. In addition, the Preferred options have been SA appraisal of options for arrived at. each issue includes a summary explaining what the SA
514 determines to be the most appropriate options for consideration as the preferred option for the Core Strategy. More clarity can also be provided in the SA. The SA is not specific to the assessment of the existing The Borough Council None. ADR sites. undertook a full SA of the WYG development areas and the final five options, tested against Redditch's SA Framework. This can be seen in the Sustainability Appraisal refresh. Specific site appraisals may be more appropriate for EIA of the site. Sustainability 267/594; Reduce the impacts of climate There are other considerations No change. Appraisal Barton change / encourage renewable such as the distance of the Wilmore c/o energy provision - Bordesley options from the Town Centre, Barratt Homes Park secures a positive rating which influence this score. The and Taylor here as opposed to all other proximity of Bordesley Park to Wimpey sites which score negatively, the Town Centre means it on the basis of economies of would have less of an impact scale and potential to introduce on carbon emissions than most low carbon technology. Policy other sites as there is likely to B(BE).1 requires all be lower emissions from development to include 10% transportation, greater renewable energy provision so accessibility and all should achieve the same encouragement for modal
515 standards. shifts. No change. Opportunities for sustainable modes of travel - same scoring Similar to above, this appraisal as above for the same has been assessed taking into reasons. All sites under account proximity of options to construction are of a sufficient the town centre and which size and scale to achieve some option has the greatest form of modal shift. Webheath accessibility to sustainable ADR should be positively transport. Compared with some scored (see submitted other options the Webheath accessibility strategy). ADR has not been judged to be as accessible to the town centre, so the scoring is Amend The matrix on Page reasonable. 142 of the Sustainability Will it support tourism - No Appraisal refresh (Consultation justification for Bordesley Park This judgement is only based 27 March - 8 May 2009). scoring positive and others upon the closer proximity and Option 1 and 2 should be 'Yes' negative. ease of access from this option and Option 3 and 5 should be to the major tourist attractions 'To a small extent'. in Redditch Borough, e.g. the Town Centre, Bordesley Abbey, Forge Mill museum. The matrix on Page 142 of the Sustainability Appraisal refresh should be amended to reflect this on both Options 1 and 2 for Bordesley Park as well as Option 3 and Option 5 being amended to read 'To a small
516 extent' because of the location No change. Provision of local services and of the Brockhill ADR. facilities - Only Bordesley Park and Foxlydiate Woods are This judgement is based on the deemed to achieve this. proximity of existing facilities Webheath ADR proposals that could be enhanced as well include a local centre, doctors as potential for further and/or dental surgery. provision. In addition, developing on all smaller sites will result in fewer opportunities No change. Accessibility by public transport to provide local services and - Refer to accessibility strategy facilities. submitted with representation. There is existing and proposed Judgement based upon the public transport provision to conclusion that development enhance provision for existing closest to the town centre Webheath residents also. offers the maximum potential to improve and integrate public No change. Safeguard and strengthen transport links. landscape - Bordesley Park secures a positive rating here and Webheath ADR negative Judgement has been based despite Bordesley being in the upon WYG assessment of Green Belt adjoining an Area of landscape value as set out in Great Landscape Value and WYG Stage II report. Landscape protection area. Webheath ADR has no landscape designations.
517 Sustainable Developments Strategy
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.1 – 005/484 Recognises the importance of Officers acknowledge that the Alter final paragraph of Policy Housing (William Davis providing lifetime homes in the requirement for lifetime homes SC.1 to encourage voluntary Provision Ltd) future but does not consider it is not expected in advance of private sector take-up of the necessary to establish such a 2013. However, para 20 of lifetime homes concept prior to requirement in advance of ‘Lifetime Homes: Lifetime its mandatory status in 2013. 2013 (National Guidance – Neighbourhoods’ states that Encourage RSLs to build to Lifetime Homes: Lifetime voluntary take-up of the Lifetime Homes Standards Neighbourhoods). Objection to concept by the building from adoption of the CS final paragraph of Policy SC.1 industry would be encouraged/ which looks to introduce a supported with a review of Lifetime Homes Standard on take-up in 2010 to assess adoption of the Core Strategy matched market needs/ which is likely to be in advance expectations. Chapter 7: of 2013 Lifetime Homes (summary panel) states that all public sector funded housing should be built to Lifetime Homes Standards by 2011, which is when the Core Strategy is anticipated for adoption. Policy SC.2 – 005/485 Objection to criteria (ii) of Officers consider that the None Efficient Use (William Davis Policy SC.2. Consider that the density levels in Policy SC.2 of Land Ltd) densities are too high and are specific to the Redditch would limit the quality and type local area as they carry forward of housing delivered. Any achieved density levels from
518 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. density requirement above the Borough of Redditch Local 35dph is unlikely to be Plan No.3 and encourage achieved without a high higher density levels on sites proportion of flats which would within and adjacent to the not reflect market demands. Borough’s Town and District Housing density requirement centres. Further to this, criteria should be flexible on a site by iii of the policy also makes site basis to allow for provision for density flexibility. consideration of local trends The policy is therefore and character. Flexibility would considered to be in conformity allow for higher quality with the WMRSS Policy CF6 – developments and reduce the Making efficient use of land need for flats in a limited market Policy SC.3 – 005/486 Objection to the 40% 1, 2 & 3. The provision of 40% 1, 2 & 3. Officers to investigate Affordable (William Davis affordable housing requirement affordable housing requirement the viability of alternative Housing Ltd) for residential development in has been established through affordable housing provision criteria (i) of Policy SC.3 with the findings of the ‘Strategic including a sliding scale of respect to: Housing Market Assessment financial contributions and for the South Housing Market lower levels of on-site provision 1. Requirement is far too high Area of the West Midlands should a threshold of 40% and contrary to national Region’ (April 2007). prove too constraining planning policy Paragraph 29 of PPS3 –
2. A 40% requirement will be Housing states that LPAs extremely constraining on should set an overall (i.e. plan- residential development wide) target for the amount of and render a significant affordable housing to be proportion of potential provided… taking into account
519 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. residential developments information from the Strategic unviable and undeliverable Housing market Assessment. The 40% affordable housing 3. This will in turn endanger provision is also a threshold the ability of the council to which has been established in deliver regional targets and adopted SPD (January 2008). is particularly relevant in the Prior to revising the SPD, current economic climate previous SPG (March 2004) where viability of sites is expected a provision of ‘at particularly vulnerable. least 39% (para 6.3), based Even modest requirements upon findings in the Housing are unviable in the current Needs Assessment (December economic climate and this 2003). Officers consider that will be the case for the this is a well established and demanding requirements of relatively consistent threshold Policy SC.3 for Redditch based in the findings of successive studies. 4. PPS3, para 29 indicates that LPAs will need to However, officers consider that undertake an informed should the 40% threshold assessment of economic prove unviable, investigation of viability of any thresholds a sliding scale of financial contributions coupled with Policy SC.3 – 005/486 and proportions of affordable housing and their lower levels of on-site provision Affordable (William Davis may provide a more viable Housing Ltd) likely impact on levels of housing delivery. Unaware option
of any affordable housing viability assessment being carried out to support Policy 4 & 5. Noted and agreed
520 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. SC.3 and consequently, Policy SC.3 is contrary to national policy 5. The Council should undertake a viability assessment as stipulated by national policy and any future requirements are guided by the results of the assessment
4 & 5. The Council will undertake a local level Housing
521 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Market Assessment which will include the economic viability assessment regarding affordable housing
Policy SC.1 – 017/248 1. Consider PDL as being the 1. Policy SP.2 – Development 1. None Housing (CPRE) first option for new Strategy addresses this point Provision development
2. There should be a specific 2. This issue is addressed in policy relating to the 2. None protection of back gardens BORLP3 Policy B(HSG).6 – Development within or adjacent to the Curtilage of an Existing Dwelling. This policy has been saved indefinitely until such time that it is replaced/ superseded and should therefore be relied upon when proposed development in these circumstances arises Policy SP.1 – 021/072 Policy accords with emerging Noted None
522 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Settlement (WMRA) WMRSS Policy CF2 (Housing Hierarchy beyond the Major Urban Areas) and also the published WMRSS version of this policy Policy BE.7 – 021/082 Policy accords with emerging Noted None Exceptions (WMRA) WMRSS Policy CF7C Housing at (Delivering Affordable Housing) Astwood Bank and Feckenham Policy SC.1 – 021/093 Policy is contrary to emerging It is evidenced in previous Consider future use of ADRs Housing (WMRA) WMRSS Policy CF3 (Level and planning documentation and other options to meet the Provision Distribution of New Housing relating to the Borough of revised EiP Panel Development) and part e of the Redditch Local Plans 2 & 3 that recommendation for the footnotes to the policy. Policy the three ADRs had potential housing target of 4000 SC.1 proposes to make for development. It should be dwellings within Redditch provision for 2243 dwellings up noted that during previous plan Borough to 2026 which is 1057 short of preparation, officers were the Borough’s required housing restricted to searching for provision set out in Policy CF3. appropriate and suitable land Update Key Diagram to show If pursued, the CS would be for development within the the broad location of the SUE out of conformity with the Borough’s administrative boundary to be determined in emerging WMRSS Phase 2 boundary only. The three collaboration with Bromsgrove Revision ADRs offered the most District Council appropriate locations for development at that time. Changes to the planning
523 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. system have allowed for cross- boundary investigation for sustainable locations for Redditch related development. WYG1 dismissed Redditch’s rural south west as unsuitable for development and WYG2 concluded that land beyond the Borough Boundary offered more sustainable locations for development than the three ADRs.
Following receipt of the EiP Panel Report, the Bordesley Park identification in the WYG 2 Report was regarded as too inflexible to deliver Redditch related growth in Bromsgrove District and greater flexibility in terms of achieving and maintaining housing output could be provided through parallel pursuit of a number of development options. The Panel recommended that land for 4000 dwellings should be
524 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. identified within the Borough boundary. As such, joint consultation between Redditch Borough and Bromsgrove District Councils will take place early in 2010 to consider development options for Redditch related growth and the contribution of other sites, including the ADRs within Redditch Borough Policy SC.3 – 021/095 Policy accords with emerging Noted None Affordable (WMRA) WMRSS Policy CF7 Housing (Delivering Affordable Housing) Policy SC.3 – 028/107 Support for addressing issue of Noted None Affordable (GOWM) housing affordability Housing Policy SP.1 – 029/704 1. Object to policy as it fails to 1. Officers consider that with 1. Include reference in the Settlement (Tetlow King) take account of local needs respect to the settlement Settlements Strategy preamble Hierarchy in rural areas throughout hierarchy, Redditch Borough to rural exceptions sites Redditch Borough. Policy only has three distinctively providing 100% affordable should make clear sized settlements to which this housing reference to the need for policy applies, two of which are 100% affordable housing within Redditch’s rural area. developments on rural BORLP3 Policy B(RA).10 exception sites where local makes reference to exception need is demonstrated. This housing in rural settlements
525 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. should be taken into being for 100% affordable account within the uses. This policy has been Settlement Hierarchy retained, however, officers consider that some reference to 100% affordable uses on exceptions housing sites could be made in the Settlements Strategy preamble Policy SP.2 – 029/705 2. Object to the rigid phasing 2. Officers consider that the 2. Consider wording of Policy Development (Tetlow King) of policy as it fails to take policy is in conformity with the SP.2 to allow for development Strategy into account the current emerging WMRSS Policy CF4 to come forward on sites economic circumstances – Phasing of new development. currently designated as Green and the difficulty of bringing The Council’s five year housing Belt in a manner which will not forward sites in a strictly land supply document will be to the detriment of phased manner. Suggested inform whether there is a development in the urban area alteration to policy wording: sufficient supply of brownfield on brownfield and greenfield “In exceptional land available to meet the sites circumstances, where there trajectory and whether exists a clear development greenfield sites need to be need and when the options made available for locating development set out above cannot be achieved , consideration of With respect to the suggested locations adjacent to the policy wording to consider Redditch urban area on development on Green Belt land currently designated land, officers consider that the as Green belt will be Green Belt boundaries will be rolled back to accommodate
526 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. acceptable.” the level of development allocated for Redditch’s growth needs prior to CS submission. Therefore, development on Green Belt land will not be an issue in the CS once adopted
Officers recognise that the level of development likely to be required on land currently designated as Green Belt will need to be phased sooner in the plan period to enable development to continue to come forward in a satisfactory manner without compromise to development in Redditch’s urban area. This should be addressed through a revision to Policy SP.2 but not necessarily the respondents suggested wording Policy SP.6 – 029/707 3. Support for policy. 3. Noted 3. None Woodrow (Tetlow King) Demonstrates Council’s Strategic Site commitment to providing high quality affordable housing of an appropriate
527 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. mix to meet local needs Policy BE.7 – 029/709 4. Support for policy. 4. Officers consider that some 4. Include reference in the Exceptions (Tetlow King) Recommend that ‘local clarification of ‘local need’ Settlements Strategy preamble Housing at need’ is qualified through could be made in the to clarification of ‘local need’ Astwood use of a clear set of Settlements Strategy preamble Bank and potential need parameters.
Feckenham List should not be exhaustive but provide a clear indication by which local need may be assessed externally
5. Statement that settlement boundaries will not be 5. Officers disagree that revised to accommodate reference to settlement 5. None affordable housing boundaries not being revised to developments should be accommodate affordable removed as it is restrictive housing is restrictive. The RJ clearly states that exceptions housing will be considered beyond settlement boundaries and does not necessitate boundary reviews Policy SC.1 – 029/711 6. Exact figure relating to 6. Core Strategy will reflect the 6. Alter housing provision Housing (Tetlow King) housing provision should be appropriate target at the time of target in the CS to reflect that Provision removed as it is subject to its submission but it would not in the WMRSS prior to
528 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. further approval and be necessary to remove submission change following WMRSS reference to the requirements EiP. Opening sentence
should instead make reference to sufficient provision being made to meet local needs and demand in line with PPS3
and RSS figures when published
7. Advise that CS provide an indicative tenure split for affordable housing. 7. Officers consider that there WMRSS Policy CF7 is no need to indicate a tenure indicates that separate split for affordable housing in 7. None targets should set for the policy. Reliance should be social-rented and had to the SHMA which is intermediate housing to updated periodically throughout ensure that these are in the plan period. Any specified broad accordance with the tenure split in policy may not findings of an up-to-date reflect the needs of the SHMA Borough as the SHMA is updated
529 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.2 – 029/712 8. Support for policy. Target 8. Agreed and noted 8. None Efficient Use (Tetlow King) figure for housing of Land development on PDL reflects a realistic housing strategy and takes account of economic viability. This figure should be retained as a target Policy SC.3 – 029/713 9. Justification should be 9. Officers are aware that this 9. Revise affordable housing Affordable (Tetlow King) made for the minima target figure may alter upon figure if appropriate when Housing of 141 affordable dwellings publication of the WMRSS WMRSS Phase 2 Revision per annum to improve Phase 2 Revision and will publishes revised housing clarity in the policy. clarify the point when revised figures. Policy should be Supports the intention to housing requirements have sufficiently flexible to reflect the review this figure when new been set for Redditch growth. findings of the most up to date evidence indicates this is Aspects of the HNA have been SHMA appropriate. Support superseded by SHMA which is remainder of policy. reviewed annually throughout Recommend regular the plan period. Policy should The Council will undertake a monitoring and review of be sufficiently flexible to reflect local level Housing Market Housing Needs the findings of the most up to Assessment which will include Assessment date SHMA the economic viability assessment regarding affordable housing Strategy 029/717 10. Consider that the following 10. Officers consider that CS 10. Ongoing policy (Tetlow King) be addressed in the CS: policies address these points development prior to and continued work to fine-tune
530 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. i. Affordable housing be policies for CS submission will submission given sufficient weight and serve to enhance these issues status ii. Full range of special needs housing including provision of lifetime homes and appropriate provision for the elderly iii. Flexibility regarding design and development control standards, densities etc to assist in achieving affordable housing iv. Provision of affordable housing should be viewed within the context of achieving balanced communities and within the wider social exclusion and housing plus agendas v. Recognition should be given to the advantage of working with RSLs and a suitably flexible approach should be adopted towards
531 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. S106 agreements vi. Include policies that maximise the reuse of empty properties for affordable housing
532 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy BE.7 – 049/744 1. Policy would be better 1. The layout and headings of 1. None Exceptions (WCC) placed within the Housing the CS will be changed prior to Housing at section of ‘Stronger submission and policies will be Astwood Communities’ rather than moved to appropriate locations Bank and with the environmental under the new strategy Feckenham policies headings 2. Policy should explicitly refer 2. Noted to affordable housing in the title and first paragraph 2. Consider more prominent reference to affordable housing 3. First para of RJ could be within the policy title made clearer by explaining 3. Due to a revised layout of that the exceptions policy 3. Ensure all issues are the CS, RJs will cease to exist covered in the new strategy allows for affordable and will be replaced with housing to be provided on introductions. Include reference introductory text which will to exceptions housing being small sites that would not encompass the purpose of the normally be used for provided on sites not normally individual strategies. Officers used for housing could be housing consider that reference to incorporated in the new exceptions housing being Strategy pre-amble provided on sites not normally used for housing could be incorporated in the new Strategy pre-amble 4. RJ states that housing will be required to remain affordable in perpetuity but 4. Noted. Policies may be this may be better included expanded as text is removed in policy from deleted RJs 4. Ongoing policy development for new CS structure following commissioning of Redditch Housing Market Assessment 533 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.1 – 049/756 1. Due to reliance on the 1, 2, 3, 4 & 5. See 021/093 1, 2, 3, 4 & 5. See 021/093 Housing (WCC) findings of WYG2, the above above Provision PDCS does not make sufficient provision within
Redditch for the level of housing growth required by WMRSS Preferred Option
2. Whilst the PDCS makes reference to adjoining authorities making up the
shortfall in allocation, neither of the draft CS for Bromsgrove or Stratford on Avon Districts make provision to meet this
shortfall
3. The level of growth to be accommodated within Redditch may alter as a consequence of the WMRSS EiP
4. RBC needs to be aware
that a significant under provision in the housing allocation is not in conformity with WMRSS Phase 2 Revision
534
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.1 – 049/756 5. Final submission will need 5. Noted. See 1 above Housing (WCC) to consider and respond to Provision any future
recommendations that emerge from the EiP Panel which may affect the level of housing growth to be accommodated within Redditch Borough 6. Unclear what proportion of homes would be expected to comply with the Lifetime Home Standard. Pg 92 states ‘a proportion of 6. Noted. Officers acknowledge 6. Clarify the proportion of homes’ whilst Policy SC.1 that the requirement lifetimes homes provision in states ‘all new residential policy. Alter final paragraph of for lifetime homes is not Policy SC.1 to encourage development’. This issue expected in advance of 2013. should be clarified voluntary private sector take-up However, para 20 of ‘Lifetime of the lifetime homes concept Homes: Lifetime prior to its mandatory status in Neighbourhoods’ states that 2013. Encourage RSLs to build voluntary take-up of the to Lifetime Homes Standards concept by the building from adoption of the CS industry would be encouraged/ supported with a review of take-up in 2010 to assess matched market needs/ expectations. Chapter 7: Lifetime Homes (summary
535 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. panel) states that all public sector funded housing should be built to Lifetime Homes Standards by 2011 Policy SC.3 – 049/757 1. Policy does not recognise 1. Officers consider that under 1. Investigate the option of Affordable (WCC) or address particular the revised structure for the more closely aligned or merged Housing difficulties in delivering CS, there may be an policies for affordable housing affordable housing within opportunity to combine or more smaller settlements such as closely align the affordable Feckenham or rural areas. housing policy and the rural More explicit guidance exceptions policy should be given in the policy itself with respect to lower thresholds/ 100% affordable housing sites (WMRSS CF7) and RBC’s Affordable Housing SPD Policy SP.1 – 085/522a & b 1. Supports categorisation of 1. Noted 1. None Settlement (Turley Redditch at the top of the Hierarchy Associates) settlement hierarchy as the ‘Main settlement’. 2. Agrees that Redditch is the key service centre for the Borough. 2. Noted 2. None 3. CS should recognise the important contribution the
536 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Kingfisher Shopping Centre can make to enhancing Redditch’s ability to function 3. Not relevant within Policy 3. Consider amendment to as the main settlement SP.1. This issue is covered in Spatial Portrait to reflect the the Spatial Portrait. important contribution the Kingfisher Shopping Centre can make to enhancing Redditch’s ability to function as the main settlement
537 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Stronger 085/528 4. In order to strengthen 4. There are sites within the 4. None Communities (Turley Redditch’s role as the main town centre which may be Associates) settlement, the CS should suitable for a mix of uses. At seek to direct the this point in time, they do not development of additional specifically appear in the housing to suitable and SHLAA until the mix of available sites within the development has been Town Centre which will determined and the enhance its vitality and approximate provision viability, and to the urban remaining which may have area housing potential has been established. At that point in time, such sites will be included in the SHLAA with a provisional density appropriate with development in a town centre location
5. The identification of SHLAA 5. In locating new housing sites takes into consideration development, consideration sustainability issues such as should be given to the access to services and desirability of promoting distances to retail and health sustainable development facilities et al. Although the and connectivity to the town SHLAA sites are not ranked, 5. None centre to encourage the use their location to such facilities of existing shopping can be scrutinised in the facilities and enhance their SHLAA. The majority of long-term viability SHLAA sites in the urban area are within a reasonable walking distance of local retail facilities 538 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.1 – 088/532 Settlement hierarchy seems 1. & 2. The Settlement 1. & 2. None Settlement (Natural appropriate but reiterates the Hierarchy was duly considered Hierarchy England) following points: in the CS Sustainability Appraisal (pp. 112-113) 1. The most sustainable location may not always be the settlement with the most existing services – The Accessibility Study justifies sustainability goes beyond the Settlement Hierarchy set this out in the CS and identifies which settlements in the 2. Each location should be Borough are the most judged on its merits with sustainable. It concludes that decisions informed by a Redditch as a town, is robust evidence base considered to be the most sustainable of all the settlements in the Borough, Astwood Bank is considered to be a sustainable rural settlement and Feckenham is classified as an unsustainable rural settlement Policy SC.1 – 088/556 1. Mostly this policy seems 1. Lifetime Homes, Lifetime 1 & 2. Clarify the proportion of Housing (Natural appropriate however a Neighbourhoods (2008, p.90) lifetimes homes provision in Provision England) blanket requirement for all states that all public sector policy new developments to funded housing should be built comply with Lifetime Homes to Lifetime Homes Standards Standards may be from 2011. Furthermore, it excessive – particularly for aspires to build all new homes
539 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. flats to Lifetime Homes Standards by 2013. There is no caveat in 2. Elsewhere in the County, a the document for certain types proportion of homes of properties i.e. flats, to be meeting Lifetime Homes excluded from meeting the Standards has been Lifetime Homes Standards required
540 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.2 – 088/557 1. Policy places onus on 1. Officers consider that 1. None Efficient Use (Natural developer to prove that developers should provide of Land England) lower than required justification if proposals fall densities would result in short of density requirements. detrimental impacts. Reality Past trends show that some is that majority of proposals attempt to come in developers would wish to under the density requirements build as many units as in order to avoid the provision possible to maximise profits of affordable housing units. This policy criteria affords some protection to the affordable housing provision allocated to the Borough if sites should be contributing to meeting this provision
Policy SC.2 – 088/557 2. Suggest a change of policy 2. Sites which fall into these 2. Include in Policy, text Efficient Use (Natural emphasis in order to protect categories may have already relating to consideration of of Land England) brownfield/marginal land been dismissed from inclusion other functions outweighing the which has value for in the SHLAA. However, need for development for amenity, character and gardens have not been subject brownfield sites which may
541 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. environmental quality of an to SHLAA scrutiny due to have value in terms of area. Council should threshold sizes. If land biodiversity interests, their identify brownfield land and proposed for development has function as a wildlife corridor, gardens which have value not been the subject of SHLAA landscape and townscape in terms of biodiversity scrutiny, it is anticipated that amenity and formal and interests, their function as a consideration of other functions informal recreation in wildlife corridor, landscape outweighing the need for preference to development and townscape amenity and development would form part formal and informal of the development control recreation. These should be process protected from inappropriate development and proposed lower, more suitable densities as appropriate 3. Support the promotion of higher densities in locations close to public transport 3. Noted interchanges 3. None
542
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SP.1 – 091/129 Proposed settlement hierarchy Noted None Settlement (Atisreal) is welcomed and officers Hierarchy comments that a large number of development sites would not be a sustainable approach is endorsed Policy SC.2 – 093/ 501 Density of housing Noted. Officers consider that if None Efficient Use (Environment development on PDL will be alternative uses to housing or of Land Agency) subject to environmental lower density housing may be infrastructure/ constraints. E.g. more suitable on PDL sites in the regeneration of some residential areas, then brownfield sites may be more justification for this would be suitable to a commercial/ less required as part of any vulnerable use if there were planning application. Preferred flood risk constraints or to Draft Core Strategy Policy lower levels of housing density SC.2 Criterion iii provides the to achieve flood risk betterment policy detail for this consideration. The type of development proposed on any land, whether PDL or not, would be judged on its appropriateness within its surroundings during the planning application process Housing 103/160 1. Actual Redditch population 1. The need for new dwellings 1. None (Anderson) not growing at rate in does not solely come from
543 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. predicted population population growth. Other projections despite some trends such as divorcing 3000 new dwellings (over couples, children growing up the last 10 years) and leaving home, amongst others, all contribute to the increased demand for housing
2. Under-occupation may be an issue that can be resolved for Council rented properties 2. Change in housing stock in through suitable property projection is important. exchange mechanisms but this Greatest increase is in is not an issue that can be 2. None single person dwellings. tackled in the private housing Historically, New Town market development concentrated on family homes. As population has aged, these family homes are becoming more under-occupied and are considered to house retired couples or single people. The need to increase densities in new development adds to the problem of larger families living in more cramped
544 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. conditions
3. Encouraging the population to settle in new SUE’s will add to the cost of providing schooling. Each community will only need significant 3. The Worcestershire County school provision for first Council’s Infrastructure Report, twenty five years as identifies all infrastructure demand will fall due to requirements needed to people remaining in their achieve the allocations set out homes and offspring in the WMRSS to 2026. School forming new families in provision has been assessed other parts of the town. and it has been identified that 2 Waste of resources as primary schools will be needed 3. None schools close to serve additional development in Redditch despite steps to reduce the high level of surplus spaces in all three tiers of the education system (p.80)
545 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Housing 103/160 4. New building should be 4. New dwellings will take into 4. None at this stage. Revisit (Anderson) concentrated on the needs consideration the ‘Lifetime this issue during Site of the older population, Homes’ Strategy. Redditch Allocations DPD preparation reflecting modern Borough Council’s draft aspirations (separate living Strategy for the Housing and and sleeping rooms and Support of Older People communal assembly acknowledges that retirement rooms). Large communities villages can contribute to the supported by a resident range of housing and are warden will attract sufficient options available to our aging numbers of the population population, However, the to free up larger dwellings Strategy does not identify a for families to meet specific need for this type of predicted demand. Such accommodation. The SHMA communities could easily identifies what types of be developed at higher residential properties are densities, reducing the needed in Redditch and demand on Green Belt applications for ‘super land. Such ‘super community’ type development communities’ should be would be considered via the
546 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. identified and designated as planning application process strategic sites before on their individual merits. If selecting sites to meet the additional work on the balance of needs emerging Older Persons Strategy identifies a specific need/amount of accommodation which is demonstrated to need to be met through a specifically identified retirement village, it would be possible to include appropriate site allocation at a later date during the Site Allocations DPD preparation Housing 103/164d 5. Requirement to improve 5 & 6. See response to 4 5 & 6. See 4 above (Anderson) access to services for all above must recognise Govt’s
requirements for supporting people in their homes for as long as possible and the steadily aging population
6. Much of the increase in single status is due to
marriage break-up and the loss of a partner. The DPD needs to recognise this and 6 & 7. None concentrate on its 6 & 7. Reliance should be had
547 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. implications rather than to the SHMA and the HNA continue to build 3 & 4 which are updated periodically bedroomed houses. Under throughout the plan period. Any occupancy leads to poor specified housing size/type use of materials and preference in policy may not resources and an increased reflect the needs of the use of services. Building Borough as the SHMA is super centres is one updated as the Plan period solution, but other actions progresses should be planned, such as designating special facilities for the support and social inclusion of the older members of society 7. The most sustainable objective should be to measure the type and quantity of dwellings needed by the population, and match supply to demand Policy SP.1 – 104/050 (RPS) Support for Redditch as the Noted None Settlement principle settlement within the Hierarchy CS settlement hierarchy Policy SP.2 – 104/051 (RPS) 1. Supports the approach to 1. Officers agree that the level 1. Consult on revised policy Development facilitate early delivery of of development likely to be wording early 2010 housing through strategic required on land currently
548 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Strategy sites. Correct to identify that designated as Green Belt will general priority is for need to be phased sooner in brownfield land over the plan period to enable greenfield land, however it development to continue to should not wait until come forward in a satisfactory locations have been manner without compromise to exhausted before accepting development in Redditch’s proposals on Green Belt urban area. This should be land addressed through a revision to Policy SP.2
2. Should not prioritise brownfield land over greenfield land where it 2. Officers consider that may exist in unsustainable brownfield sites within locations settlements are in sustainable locations given the nature of 3. Ensure that there is a Redditch Borough 2. None continuous supply of housing in accordance with PPS3 and plan proactively 3. The Council’s five year for the delivery of housing housing land supply document in the most appropriate will inform whether there is a locations sufficient supply to meet the trajectory. PPS3 stresses that LPAs should set out a housing 3. Work to commence on implementation strategy to deal Implementation Strategy with with the managed delivery of key stakeholders autumn 2009 housing. Work with relevant
549 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. stakeholders will begin on this in autumn 2009 Policy SC.3 – 104/065 (RPS) 1. RBC has presented no 1. The provision of 40% 1. Commission Redditch HMA Affordable evidence that a target of affordable housing requirement as supporting evidence for Housing 40% affordable housing is has been established through policy development viable and been tested the findings of the ‘Strategic against risk to housing Housing Market Assessment delivery through a housing for the South Housing Market trajectory as required in Area of the West Midlands PPS3 para 29.1 Region’. Officers consider that this policy is conformity with both PPS3 and WMRSS Policy CF7 – Delivering affordable housing
Officers consider that the SHMA does not deliver housing requirements at a significantly local level. The 40% target needs to be tested for viability and whether additional contributions for affordable units should be sought on smaller sites
2. Not clear how RBC is
550 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. seeking 40% affordable 2. Following receipt of the EiP housing from a housing Panel Report, the Bordesley provision that is Park identification in the WYG substantially lower than 2 Report was regarded as too WMRSS requirements, inflexible to deliver Redditch further exacerbating the related growth in Bromsgrove viability of delivery. Policy District and greater flexibility in SC.1 sets out a requirement terms of achieving and of 2243 dwellings to be maintaining housing output 2. Officers to consider delivered 2006-2026 which could be provided through capacities available within the equate to 112 dpa. Policy parallel pursuit of a number of ADRs and Green Belt to meet SC.3 states that target for development options. The the revised RSS target of affordable housing Panel recommended that land around 4000 dwellings up to provision is 141 dpa, some for 4000 dwellings should be 2026 and undertake a further 29 dwellings higher than identified within the Borough consultation period current annual provision boundary. As such, joint rate. Therefore policy is consultation between Redditch unsound. RBC should Borough and Bromsgrove undertake viability appraisal District Councils will take place Update Key Diagram to show of affordable housing early in 2010 to consider cross- the broad location of a targets boundary locations for SUE/SUEs boundary to be Redditch related growth and determined in collaboration 3. RBC should plan the contribution of other sites, with Bromsgrove District proactively with including the ADRs within Council Bromsgrove DC for a North Redditch Borough West Urban Extension, in a manner in which such a development could provide comprehensive 3. See 021/093 above
551 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. development solutions to issues such as affordable housing that is realistically nearer its targets 4. Policy should also make 4. Should the 40% threshold provision for flexibility prove unviable, criteria ii offers where such requirements flexibility for meeting the 3. See 021/093 above results in a scheme being affordable housing provision. unviable and threatens Officers consider that this deliverability policy is conformity with both PPS3 and WMRSS Policy CF7 – Delivering affordable housing
Officers consider that the SHMA does not deliver housing requirements at a significantly local level. The 40% target needs to be tested for viability and whether additional contributions for 4. Commission Redditch HMA affordable units should be as supporting evidence for sought on smaller sites policy development
109/172 People need housing, Noted None especially social housing and
552 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. (Wareing) affordable housing to purchase. Local government funds from the sale of council houses should be utilised to house people 153/514 1. Development should be 1. Noted 1. None (Centro) focussed in areas that are well served by public transport as outlined in WMRSS Policy T2
2. A travel plan should be produced for new 2. Noted. With respect to the 2. None developments to promote large areas of development sustainable transport to and likely to come forward to meet from the development the growth needs of Redditch, a travel plan would form a part of a comprehensive planning application submission. Although not specifically referred to in a specific Core Strategy policy, travel plans are referenced in appropriate Core Strategy Strategic Site policies. Policy BE.7 – 202/332 Support for policy. Officers acknowledge that Include reference to local Exceptions (Tetlow King) Recommend that ‘local need’ is there are much smaller needs housing in rural Housing at qualified through use of a clear ‘settlements’ within Redditch’s locations beyond the village Astwood set of potential need rural area, beyond existing boundaries of Astwood Bank
553 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Bank and parameters. List should not be settlement boundaries; such as and Feckenham Feckenham exhaustive but provide a clear Ham Green and Elcocks indication by which local need Brook. In order not to overlook may be assessed externally. local needs housing provision Statement that settlement in such small ‘settlements’, it is boundaries will not be revised considered that some to accommodate affordable reference to local needs housing developments should housing in rural areas beyond be removed as it is restrictive the confines of Feckenham and Astwood Bank is needed in this policy. See same comments for rep 029 Policy SC.1 – 202/333 Object to policy as it grossly See 021/093 above See 021/093 above Housing (Tetlow King) under provides for the WMRSS Provision draft target of 3300 dwellings to be provided in the Borough Policy SC.3 – 202/337 Explanation should make it Officers are aware that this Revise affordable housing Affordable (Tetlow King) clear that the 141 affordable figure may alter upon figure if appropriate when Housing dwellings per annum is derived publication of the WMRSS WMRSS Phase 2 Revision from the Strategic Housing Phase 2 Revision and will publishes revised housing Market Area Assessment. clarify the point when revised figures. Policy should be Supports the intention to housing allocations have been sufficiently flexible to reflect the review this figure when new set for Redditch growth. HNA findings of the most up to date evidence indicates this is has been superseded by SHMA appropriate. Recommend SHMA which is reviewed regular monitoring and review annually throughout the plan of Housing Needs Assessment period. Policy should be
554 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sufficiently flexible to reflect the findings of the most up to date SHMA. See comments to 029/713(9) Strategy 202/338 Consider that the following be 1. Affordable housing needs 1. None (Tetlow King) addressed in the CS: are addressed through policy and reference is made in policy 1. Affordable housing be given that affordable housing should sufficient weight and status reflect the most up to date SHMA. Officers consider that this gives sufficient weight and status to affordable housing needs within the Borough
2. Full range of special needs 2. Policy SC.1 – Housing housing including provision Provision makes specific of lifetime homes and reference to the provision of appropriate provision for the dwellings to Lifetime Homes elderly Standards. In addition to this, Redditch Borough Council’s 2. If additional work on the draft Strategy for the Housing emerging Older Persons and Support of Older People Strategy and/or the SHMA acknowledges the range of identifies a specific housing provision which is need/amount of available to our aging accommodation which is population. However, the demonstrated to need to be Strategy does not identify a
555 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. specific need for this type of met specifically through new new accommodation. The development, it would be SHMA does not identify a possible to include an specific quantity of dwellings appropriate site allocation at a needed over the plan period to later date during the Site meet the needs of our aging Allocations DPD preparation population 3. Flexibility regarding design and development control standards, densities etc to 3. Officers are reluctant to assist in achieving affordable housing accept that there should be a compromise when it comes to design; there are national standards for design of affordable housing (housing
corp) and lowering / altering these standards wouldn’t be 4. Provision of affordable necessary at the local level housing should be viewed 3. None within the context of
achieving balanced 4. Officers consider that the CS communities and within the policy does indeed consider wider social exclusion and the need for affordable housing housing plus agendas provision in the context of
balanced communities. The 5. Recognition should be Policy is further supported by given to the advantage of adopted SPD working with RSLs and a
556 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. suitably flexible approach 5. RSLs have been to meetings should be adopted towards on delivery. 106 agreements S106 agreements including those appropriate to affordable housing will be reviewed 6. Include policies that maximise the reuse of empty properties for 4. None affordable housing
6. Officers have little control over reuse of empty properties within the private sector. However, with respect to empty public sector properties, the Council has a good turn around record for re-letting these properties. Officers consider that whilst some district authorities may have a burdening empty homes issue, this is not the case in Redditch 5. Continue working closely and does not justify inclusion in with RSLs. Review of 106 policy agreements re: affordable housing provision be incorporated as appropriate in SPD revisions
557 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
6. None
Policy SP.1 – 262/405 (HCA) Support for this policy and Noted None Settlement acknowledgement that Hierarchy Redditch is the largest settlement in the Borough Policy SC.1 – 262/411 (HCA) 1. Support for Council’s 1. Noted 1. None Housing objective to ensure new Provision housing meets needs identified in Strategic Housing Area Assessment
2. Welcomes the proposals to ensure new dwellings 2. Noted 2. None comply with Lifetime Home
558 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Standards 3. Concerns that policy proposes significantly fewer dwellings in the Redditch 3. See 021/093 above 3. See 021/093 above urban area that the current WMRSS Preferred option target of 3300 Policy SC.2 – 262/418 (HCA) Support for this policy Noted None Efficient Use of Land Policy SC.3 – 262/419 (HCA) Support for the deliverability of Noted None Affordable social and affordable housing Housing Policy SP.1 – 263/433 Agree that the main focus for Noted None Settlement (English development should be Hierarchy Heritage) Redditch given its role as the main service centre Policy SP.1 – 264/444 (CB Support for Redditch as main Noted None Settlement Richard Ellis) settlement where development Hierarchy should be focussed Policy SC.1 – 264/452 (CB Suggest policy amended to Policy SP.2 – Development None Housing Richard Ellis) include the preference of the Strategy, deals with the Provision re-use of sustainably located phasing of land to come brownfield land within the forward for development urban area for residential use
559 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. over and above the use of greenfield land Policy SC.2 – 264/453 (CB 1. Support the efficient use of 1. Noted 1. None Efficient Use Richard Ellis) land and criterion (i) which of Land priorities reuse and regeneration of PDL 2. Use of targets for PDL reuse is encouraged 2. Noted 2. None 3. Target of 25% in Redditch could be increased in line with the Structure Plan which anticipated that the 3. 25% of development on PDL 3. On receipt of Panel Report percentage of housing is realistic, based on the into WMRSS Phase 2 development on PDL would findings of the SHLAA. Officers Revision, check targets are have risen to 50% by 2011 will revisit this target when the appropriate for Redditch Panel Report into the WMRSS
Phase 2 Revision is available and a more definite set of 4. Policy should encourage housing figures is available to the use of PDL in work with prior to CS preference to greenfield submission land use 4. Policy SP.2 deals with this 5. Densities included in matter criterion (ii) of between 30- 4. None 50 dph should not imply a maximum density limit. 5. Officers consider that the
560 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Density should be assessed density levels in Policy SC.2 on a site by site basis are specific to the Redditch local area as they carry forward 5. Consider alteration to achieved density levels from criterion iii of policy to allow for the Borough of Redditch Local higher density levels if it can be Plan No.3 and encourage demonstrated that there will be higher density levels on sites no detrimental impacts within and adjacent to the Borough’s strategic shopping centres. The policy is therefore considered to be in conformity with the WMRSS Policy CF6 – Making efficient use of land. However, officers will give consideration to amending SC.2 criterion iii to state that higher densities than those in ii may be applicable for the same reasons as lower densities may be accepted Policy SC.3 – 264/454 CB The level of affordable housing The provision of 40% None Affordable Richard Ellis) should be dependent on the affordable housing requirement Housing individual site and the viability has been established through of the development scheme the findings of the ‘Strategic Housing Market Assessment for the South Housing Market Area of the West Midlands Region’. Officers consider that
561 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. this policy is conformity with both PPS3 and WMRSS Policy CF7 – Delivering affordable housing. Refer to SC.2 criteria iii Policy SP.2 – 267/574 1. Development Strategy 1. See 021/093 above 1 . See 021/093 above Development (Barton proposes delivery of only Strategy & Willmore) 2243 dwellings within Policy SC.1 – Redditch which is 1057 Housing short of the emerging Provision requirement for the Borough
2. 2006 base projections increases the requirement for dwellings in Redditch to 2. See 021/093 above 2. See 021/093 above 8000. As a former New Town, Redditch should continue to fulfil such a function in the North Worcestershire area and as merited by its proposed status as SSD in the emerging WMRSS
3. Development and investment should be directed towards the town
562 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. 4. An increase in the number of dwellings to be provided within the Borough will ensure Redditch can meet 3. Policy SP.1 deals with this 3. None its own local housing needs matter
5. Strategy is flawed and unsound. Strategy requires the agreement of the 4. See 021/093 above adjoining authority 4. See 021/093 above
6. There are no significant environmental or physical constraints to the achievement of the WMRSS Preferred option 5. See 021/093 above figure of 3300 dwellings to 5. See 021/093 above be delivered within Redditch
7. Disagree with the conclusions of WYG2 on
the suitability of using safeguarded land to meet 6 & 7. See 021/093 above this target 6 & 7. See 021/093 above Policy SC.3 – 267/583 1. The requirement for 40% 1. & 2. See 104/065 above 1. & 2. See 104/065 above Affordable (Barton affordable housing
563 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Housing Willmore) provision should be expressed as a target percentage to ensure flexibility for those schemes where it is not financially viable to achieve 40% provision. Policy needs to include provision for the submission of financial viability information in such circumstances
2. Unaware of any evidence to demonstrate the extent to which the affordable housing target for the plan area and the site thresholds reflect an assessment of the economic viability of land for housing in the Borough. In the absence of such evidence, Policy SC.3 cannot be found sound
564 Sustainable Transport
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC. 4 021/ 096 Policy SC.4 accords with Noted. None. emerging WMRSS Policy SR2 part F and also adopted WMRSS Policies T2 and T3. Policy SC. 5 021/ 097 Policy SC.5 is in line with the Noted. None. emerging and adopted version of WMRSS Policy T9. Transport 024/ 113 Accessibility and Transport Transport and Accessibility is Ensure transport and should be continuously considered as a key issue for accessibility is a key concern mentioned in the Core Strategy the Core Strategy and will for the Submission Core as this is an important issue. continue to be so in the Strategy. Redditch is an area where Submission Core Strategy. public transport should be encouraged. Policy SC.4 027/477 This Policy should be Agree, this will be detailed in None. underpinned by a robust the "Green" Technical Paper. evidence base that demonstrates that the measures and improvements are deliverable. A sentence will be included Insert additional criteria into Transport Assessments (as within the Sustainable Travel Sustainable Travel and mentioned in the Reasoned and Accessibility Policy which Accessibility Policy which
565 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Justification) should be requires Transport states, “Transport provided for all development Assessments to be provided Assessments will be required proposals with significant for significant developments. for all development proposals transport implications. with significant transport implications.” Policy SC.5 027/478 Road hierarchy as set out in The principle of retaining the Insert, as a sixth criterion to the this policy may assist in unique road hierarchy will be Sustainable Travel and managing congestion, however incorporated in the Sustainable Accessibility’ Policy the care should be taken that this Travel and Accessibility as an following text, “The Borough does not impact upon the additional criterion. This policy Council will continue to ability of routes to promotes pedestrianisation and endorse and pursue the accommodate pedestrians and routes for cyclists. principles of a structured road cyclists safely and that routes hierarchy and will seek to continue to encourage these as extend such principles in any primary modes of travel. proposal.” 049/ 726 The Core Strategy Submission The Worcestershire Integrated None. document should reference the Passenger Transport Strategy Worcestershire Integrated (IPTS) has been considered Passenger Transport Strategy when preparing the Core and sub-strategies. Strategy and it is considered that there would be no merit in directly referencing this document within the Submission Core Strategy. The IPTS will be incorporated into
566 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the ‘Green Strategy’ Technical Paper, as part of the background research informing the Transport Policy. Policy SC. 4 088/ 558 Support Policy. Where All opportunities to enhance None. possible, cycle and pedestrian green infrastructure would be links should be delivered within promoted through the Natural the context of green Environment Policy. infrastructure. ‘Green’ links are likely to be more pleasant and are perceived as safer than routes along roads, and so likely to be used. Transport 098/ 141 The document ‘Vision for The ‘Vision for Alcester 2020’ None. Alcester 2020’ proposes the is a document produced by reopening of the railway Stratford–On–Avon District between Alcester, Studley and Council, their aims and Redditch to enable trains to aspirations can vary from those operate from Alcester to of neighbouring authorities. Redditch and Birmingham. Communication with Stratford– However, no provision has On–Avon has confirmed there been made for the protection of are no plans to progress this a route for the railway for the idea by Stratford–On–Avon as reopening of stations in Studley it is unfeasible to reopen the and Alcester, in Warwickshire, lines.
567 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. or possibly in the large built up area to the south of Redditch Station. The proposal is particularly relevant within the heavy traffic congestion on the A435 and as an alternative to a Studley by-pass. Redditch Borough Council should liaise with Stratford – On – Avon District Council and Warwickshire and Worcestershire County Council for the protection of a route for the railway, including possible sites for new stations. Transport 101/ 144 Public transport should run on The source of power of public None. solar power, probably trams on transport is too detailed for the bus routes and no private inclusion as an aspiration in the cars within the tram transport Core Strategy. With regard to area, walking and bicycles trams on this bus routes, this is would be acceptable. not possible in some parts of the older town of Redditch, as many routes are already shared with private cars. It is considered that as the bus
568 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. services are not operating at full capacity within the town, there is little requirement for addition public transport that follows the same route. Transport 106/ 167 Why is Redditch the terminus See response of 098/141. None. of the railway? The Draft Core Strategy fails to consider the use of rail to any great detail. In its vision for 2020 Warwickshire County Council sees a future where a rail link between Redditch and Alcester is restored. A full connection back to Evesham would be the ideal – but would be difficult and costly. Transport 110/ 600 Public transport is an issue in A Transport Assessment will None. Redditch, both bus and train be commissioned as part of the services. These need to be evidence base for the Core addressed to accommodate Strategy. This study will another 2243 dwellings. analyse what is required to be done in Redditch, in terms of transport infrastructure to accommodate future growth.
569 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Transport 113/ 178 Currently no bus service from The provision of bus services None. Hither Green Lane into cannot be controlled by the Redditch. A local service is Core Strategy. needed. Junction improvements can be None. Difficult to cross the junction of incorporated into the Area A441 and Dagnell End Road. Action Plan that will cover the new growth area. Transport 123/ 194 The most sustainable location The Core Strategy promotes None. for development within the the sustainable location of new Borough is within the existing development through the urban area of Redditch, either Settlement Hierarchy Policy on established public transport and the Distribution of routes or close to public Development Policy. transport interchanges. The frequency of the service of None. Frequency of services on the the cross city line is scheduled cross-city line between to be increased; this project is Redditch, Birmingham New detailed within Network Rails Street and Lichfield be Strategic Business Plan. increased from 2- 3 services per hour. Policy SC.4 017/ 249 The Reasoned Justification Is not appropriate for Quite None. mentions the Quite Lane lanes to be designated through Initiative – neither the policy the Core Strategy as these are
570 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. nor the justification deals with very specific. It is considered this issue. There are that Quiet Lanes can be opportunities for Quiet Lanes in designated through a process Redditch further consideration outside of the Core Strategy could be had in an SPD for the process and would involve LDF. discussions with the Highways Agency and other Council Departments. Transport 027/ 471 Development in Redditch has The SRN has been considered None the potential to impact upon the when developing a preferred SRN especially given the location for future growth. The proximity of the district to the Study into the Future Growth motorway network and the Implications of Redditch’ First regional centre. It is Stage and Second Stage encouraged that the SRN Report considered traffic remains a key determinant implications when determining when the Council is developing the appropriateness of each options for the scale and location. The SRN will continue location of development in the to be given due regard when district. The need for a model considering the appropriate to test the impact of location for future development around Redditch development, in particular large upon Junction 3 of the M42 will growth areas. be kept under review.
571 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Transport 049/758 Passenger Transport routes The ‘Green Strategy’ Technical None. should not be opened up to Paper will justify the reasons general traffic, as suggested on behind the policy direction to pages 96 and 97. This is give priority to buses but allow inconsistent with other areas general traffic to access small within the Draft Core Strategy sections of the route. and a rational, technical explanation has already been given to justify why this should not be included during the Issues and Options Consultation. Transport 049/ 759 The requirement for each new Worcestershire’s County None. development to provide a Council guidance on Transport Transport Assessment is very Assessments will be welcome. Worcestershire considered through the ‘Green County Councils guidance for Strategy’ Technical Paper. It is Transport Assessments and not considered appropriate to Statements should be referred detail specific documents such to when compiling and as this within the Core Transport Assessment or Strategy. However Statement and should be Development Control Officers passed to County. This will be aware of this guidance guidance should be referred to when considering submitted in the Strategy. Transport Assessment and
572 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. when requesting Transport Assessment from applicants. None. A Developer Transport Brief As above it is not considered (submitted with comments) appropriate to detail every best should be utilised by potential practice document within the developers for sites within Core Strategy. However Redditch Borough. The brief Development Control Officers outlines the steps the will be aware of this guidance developer should take towards when considering submitted creating sustainable Transport Assessment and development in transport when requesting Transport terms. This should help meet Assessment from applicants the strategies objectives and should be referred to. Transport 049/ 760 Agree with the proposal for the Support noted. None. Arrow Valley Countryside Park to be used as a coach way (page 97). This offers a sustainable solution by utilising an existing facility that could be integrated with improved passenger transport access to the park. It also offers the opportunity for improved
573 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. transport infrastructure. Transport 103/ 162 Frequently, footpaths do not It is a requirement of the None. lead to destinations, and Sustainable Travel and require users to follow complex Accessibility Policy to ensure routes. there is “comprehensive network of routes for pedestrians” delivered as part of any new development, this should help to ensure the footpath network is improved.
There is a High Quality and None. Many developments are Safe Environment Policy designed as blind alleys off the contained within the Core distributor roads, making it Strategy which will guide future difficult for a bus to go into their development, this will help to centres. work towards high quality design that prevents obstructed views. None. Bus routes are under the Industrial routes are not served control of private bus providers; by the bus routes, either in this is outside of the Core terms of time or, in many Strategy remit. cases, adjacent routes. None.
574 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No.
Policy SC.4 needs to refer to The need for infrastructure an overall plan and require within the Borough is being contributions from all developed via regular meetings construction to a fund that pays with infrastructure providers. for the construction of links and This will form the basis of the interchanges that would enable Infrastructure Delivery Plan to new orbital routes to run round demonstrate delivery. both the central and western residential areas and link in to areas of employment. This would prevent people needing to cross the town, it is unusually necessary to go to the town centre and get another bus to your destination. It is more important to get funds for this requires than to demand cycle routes which are used by only a minute portion of the community. Transport 153/ 506 It is recommended that the Noted. None. Draft Core Strategy acknowledges the role
575 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. sustainable transport can play in the strategic development of the district and wider area. Support noted. None. Support that the document has recognised the importance of accessibility by a range of transport modes and is referenced in multiple policies throughout the document. It is considered that the None. Public transport should be a promotion of public transport is key theme running throughout included within the Core the document and the plan Strategy, through the should also take cross sustainable travel and boundary issues into account. accessibility policy. It is anticipated that a cross- boundary transport assessment will be completed as part of the evidence base of the Core Strategy. Transport 153/ 507 Transport and in particular See response to 153/ 506. See action to 153/ 506. public transport should be a key theme throughout the document, as this will help to
576 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. promote accessible developments and sustainable regeneration. Transport 153/ 509 It is disappointing that rail does Agree. Incorporate the vision for rail not feature greatly in the within the Sustainable Travel Transport Section of this and Accessibility Policy. An document. Rail is an important additional point will be inserted mode of transport within the within the policy, which states, Borough with an annual footfall “increasing services levels to of over 775,000 users. Rail and from Redditch Railway should therefore be a Station.” consistent theme within the document. The Cross City South Redditch Branch line has been earmarked for enhancements in the capacity of the line, which will bring about an improved frequency of rail services to the Borough. Transport 153/ 510 Welcome the recognition that Agreed. This information will be spatial planning can help to incorporated into the minimise the frequency and introduction to the Sustainable distance of journeys that Travel and Accessibility Policy. people need to undertake. It is recommended that private car
577 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. transport is highlighted as contributing to CO 2 emissions and that encouraging modal shift to a more sustainable high quality public transport product will help to contribute towards lower CO 2 emissions. Transport 153/ 511 It is recommended that There are a number of policies None. development should be within the Preferred Draft Core focused in places that are well Strategy that ensure new served by public transport development is located in the outlined by Regional Spatial most sustainable location. Strategy Policy T2. If this is not Policies include SP. 1 possible new infrastructure will ‘Settlement Hierarchy’, ES.1 be required from the outset to ‘Location of new employment’, encourage sustainable travel. ES.2 ‘Office development’, ES.6 ‘Retail’, H.1 ‘Leisure and Tourism’, H.3 ‘Health’, SC.2 ‘Efficient use of land’ and SC.4 ‘Sustainable Travel and Accessibility’. It is considered that the majority of these policies will be carried forward into the Submission Core Strategy; however this is still
578 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. being considered. Consideration should also be None. given to strategic park and ride A Strategic Park & Ride facility sites. for Redditch has not been identified by Draft Policy T6 of Some residents, in particular, the WMRSS. None. elderly residents in Redditch are likely to require special Noted. consideration in terms of travel and accessibility. Access to a frequent and convenient public transport can assist in greater accessibility for the elderly people, especially as from April 2008 people aged 60+ are entitled to a free bus travel anywhere across England.
Public transport can provide None. people within areas of deprivation the means to Noted. access employment and education opportunities, which can allow them to improve their quality of life.
579 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Policy SC.4 264/ 455 Support for the section of this Support Noted. None. Policy which states that “transport will be co-ordinated to improve accessibility and mobility, so that sustainable means of travel, reducing the need to travel by car and increasing public transport use, cycling and walking should be implemented.” Support Noted. None. Support for criterion (i) and suggest that this can be achieved through an appropriate mix of housing and employment uses in Redditch, providing opportunities for people to live close to their place of work. The new process for None. contributions is to collect Criterion (iii) seeks to ensure money via a Community that infrastructure for Infrastructure Levy. This Levy pedestrians and cyclists is ensures that money is spent on provided and that it facilitates the most necessary and walking, cycling and public suitable infrastructure. transport. It is suggested that Therefore this comment is not
580 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. the wording of criterion (iii) is applicable. amended to state, “where appropriate, and relevant to the development proposals , the provision or improvement of off-site cycle routes, footpath links and related infrastructure will be sought. 103/164(a) In order to reduce the need to Bus routes are under the None. travel and move to more control of private bus providers; sustainable travel patterns this is outside of the Core there should be an Strategy function. improvement in the bus network and communities should be concentrated within existing boundaries, rather than take up more Green Belt land.
581
Vision and Objectives
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Objectives 005/482; Objective 2 inconsistent with Agree with the respondents Amend Objective 2 as follows: William Davis national policy. Carbon neutral comments regarding the "To ensure that all new Ltd target is set for 2016 for targets for carbon neutral development in Redditch residential and 2019 for other development and at this stage Borough will work towards development. Objective would it is not the intention of the the achievement of being be adopted in advance of the Borough Council to evidence carbon neutral in line with target and would be highly any deviations from national the Code for Sustainable constraining on development, policy. The objective can be Homes." especially in the current reworded to clarify the economic climate which can intentions. endanger housing delivery. Objectives 021/071k; West Objective 4 should include the Agree. Amend Objective 4 as follows: Midlands historic environment as well as "To protect, promote and Regional the rural and built environment. where possible enhance the Assembly quality of the Boroughs natural, rural and historic environment and its best distinctive features"
582 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Vision 027/472; Pleased that the Core Strategy Agree. Addition to the Vision as Highways recognises the need to follows: Agency accommodate growth in a "Sustainable modes of sustainable way, reducing the transport will be supported carbon footprint of communities and delivered as well as the and increasing accessibility. infrastructure needed to Vision would be strengthened support planned by reference to sustainable development." modes of transport. Vision & 028/103; Commends relationship with Agree. Amendments to the Revise the vision to re-focus on Objectives GOWM the SCS Vision. However, vision can be made to make it key strategy areas which are whilst the Vision of the Core more locally distinctive, whilst important for Redditch to Strategy outlines an ambition referring back to elements of achieve: - Green; Sustainable for the Borough, this should be the spatial portrait. Revise the Settlements; Enterprise and regarded as a work in progress vision to re-focus on key Skills; Retail; Balance between and should be made more strategy areas which are housing and employment; High locally distinctive. Suggests important for Redditch to quality and safe design; referring back to the Spatial achieve. Historic Environment; and Portrait and introductory Attractive facilities. paragraphs can help to make the Vision locally distinctive for the Borough. Vision 029/702; Tetlow Support vision but reword to Agree. Amend the vision as follows: King c/o read: 'All new residential areas " All new development WMRSL in Redditch will be of a high including residential areas in
583 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. quality and safe design and Redditch will be of a high contribute towards creating quality and safe design and distinctive, sustainable places contribute towards creating and communities that reflect distinctive, sustainable the local character and are places and communities that tailored to the needs of the reflect the local character people that live in the and are tailored to the needs Borough.' This will emphasise of the people that live in the the Council's commitment to Borough." creating sustainable communities, as envisioned in the SCS. Objectives 029/703; Tetlow Fully support Objective 9. Note support. It is not No change. King c/o Ensure it is prioritised as the appropriate to prioritise WMRSL requirement for existing and objectives, all are equally future housing to meet all local important to ensure the vision needs is imperative to the for Redditch is realised. success of any community. Objectives 042/467; Objective 9 should refer to Objective 9 refers to having No change. Stoneleigh completion of sufficient homes sufficient homes to meet needs Planning c/o to meet the scale of new and this refers to the 4000 Gallagher housing provision for Redditch dwellings related to meeting Estates as per the phase two revision. Redditch's requirements. The This should include a mix and objective already refers to type at a number of locations. provision for a range, mix and
584 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. type in the best locations.
Reference should also be It is agreed that reference to Include a new objective (12) on made to part of the provision the SUE or SUEs would be the provision of new homes in being met on a strategic appropriate in a separate a SUE as follows: development site at Bordesley objective, once the broad "To work closely with Green and Bordesley Park to location or locations have been neighbouring authorities to the north of Redditch in determined. deliver a Sustainable Urban Bromsgrove District. Extension to the North of Redditch's urban area within Bromsgrove District and a Diversification Park at Winyates Green in Stratford on Avon District." Vision 049/728; First sentence of vision needs Agree. Reference to heritage will be Worcestershire to be amended. The word replaced with historic County Council 'heritage' needs replacing with environment in the vision. 'environment'.
The wording for all Agree. Addition to the vision as development making a 'positive follows: contribution to climate change' "Also, new and existing low should be clearly expressed to carbon communities will be state that all development will highly accessible and make a positive contribution to attractive, making the most
585 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. mitigating and adapting to the minimal contribution effects of climate change. possible to the effects and impacts of climate change." It is also overly-optimistic - This is not a requirement of the development should minimise vision. No change. its contribution to climate change because providing a net benefit is extremely challenging. Objectives 049/729; Biodiversity is not picked up in It is agreed that the objectives Amend Objective 1 as follows: Worcestershire the objectives. Reword the first can be amended broadly as "To have high quality open County Council objective as suggested: ' To suggested; however for clarity, spaces and Green have high quality open spaces biodiversity and wildlife should Infrastructure which and Green Infrastructure which be included in the same maximises opportunities for have biodiversity value and objective. Revisions to biodiversity value, wildlife ecological connectivity'. Add Objective 1 as suggested by and ecological connectivity". the following wording to the the respondent can be included end of the second objective: in addition to reference to the 'and maximise opportunities for change to objective 2. wildlife'. Agreed. The objective can be Amend Objective 2 as follows: It is unclear in objective 2 what reworded to clarify the "To ensure that all new the term 'carbon neutral' intentions. Glossary to the development in Redditch covers. Core Strategy explains the Borough will work towards definition of 'carbon neutral'. the achievement of being
586 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. carbon neutral in line with the Code for Sustainable Homes." This detail is more appropriate for policy rather than vision/ No change. Recommend an additional objectives. objective which should include the pursuit and routine incorporation of ecologically advantageous building technologies as an integral part of promoting Green Infrastructure e.g. green and brown roofs, living walls and Agree. opportunities for breeding bats. Amend Objective 4 as follows: "To protect, promote and Amend Objective 4 to read where possible enhance the 'rural and historic environment'. quality of the Boroughs 'Historic environment' is the natural, rural and historic preferred national terms to environment and its best encompass historic buildings, distinctive features" landscapes and archaeological It is considered that many of sites rather than 'built' the Core Strategy objectives environment. will achieve multiple key Remove Key Theme/Objective themes. This has meant that table on PDCS Page 22. Objective 11 on page 21 does the purpose of the
587 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. not appear on page 22 under demonstration of which the better environment Key objectives achieve the key Theme. themes is now superfluous. Vision & 085/520; Turley SWIP supports and welcomes Whilst the Borough Council No change. Objectives Associates c/o the vision and objectives. agrees that this is important, Scottish Widows However the commitment to there are many contributory improving the vitality and factors that would improve the viability of the town and district vitality and viability of the town centres in Objective 9 should centre which cannot all be acknowledge the importance of referenced in a core strategy improving established retail objective. facilities through investment and complementary development. Vision 088/530; Fully support 'green' focus for The ambition to be ecologically Amend Objective 1 as follows: Natural England the vision. Intention to preserve rich was difficult to quantify and "To have high quality open and enhance biodiversity, monitor. Amendments to spaces and Green landscape and historic heritage Objective 1 are suggested. Infrastructure which is welcomed and will ensure maximises opportunities for new development is locally biodiversity value, wildlife distinctive. Disappointing that and ecological connectivity". the ambition to be 'ecologically rich' is removed. Agreed that reference to low No change. Endorse the vision for low carbon communities and
588 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. carbon communities and for all sustainable modes of transport development to make a should be maintained in the positive contribution towards vision. the effects of climate change. Recommend recognition of the role of green transport in achieving this end. Agree. Addition to the vision as follows: The vision should recognise "Also, new and existing low the need for climate change carbon communities will be adaptation as well as mitigation highly accessible and - all new development must be attractive, making the most 'future proofed' i.e. built with minimal contribution future climates in mind. possible to the effects and impacts of climate change." Objectives 088/531; Support Objectives particularly Noted. No change. Natural England 1,2,3,4,5 and 11 Objectives 089/516; Support objective 6 and Noted. No change. Theatres Trust objective 8 as these two are directly linked. Vision 091/126 Atisreal Welcomes the aims and Agreed that appropriate Addition to the vision as c/o West Mercia objectives but no reference reference can be made in the follows: Constabulary made to ensuring Redditch has revised vision. "Finally Redditch Borough sufficient infrastructure to meet will contain excellent public future development services and infrastructure
589 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. requirements. Amend to read ' to support its communities." It will be an enterprising Borough containing diverse employment areas, a skilled workforce, vibrant centres, excellent public services and infrastructure and attractive facilities.' Objectives 091/127 Atisreal Endorses Objective of Although it is recognised that Changes to delivery strategy to c/o West Mercia 'Reducing crime and anti social police are valuable key be confirmed following Constabulary behaviour and the fear of partners in terms of delivery infrastructure delivery crime'. However there is no and preparation of community meetings. reference to policing. Previous strategies, the objectives for a response from Borough Core Strategy are not the Council was that this is not a correct place for reference to spatial planning function. This specific services. PPS12 is incorrect because police are advocates that objectives key partners in the preparation should focus on the key issues of the sustainable community to be addressed and that it is strategy and this needs to be the delivery strategy which reflected in the core strategy. achieves these objectives. Where relevant the delivery strategy would be the most appropriate location for such references.
590 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Vision 093/487; Reference should be made in Agree. Amend the vision as follows: Environment the vision to the water "To achieve this green Agency environment as follows: 'Its strategy, Redditch's character, biodiversity, water character, biodiversity, water environment, landscape and environment, open space historic heritage will have been and landscape will have preserved and enhanced. been preserved and enhanced." Objectives 093/488; Suggest that flood risk be a Agree. Amend Objective 3 as follows: Environment separate objective to climate "To reduce the causes of, Agency change. There is no reference minimise the impacts of and to protecting and enhancing adapt to climate change water, air and soil. especially fl ood risk "
Additional Objective (13) as follows: "To protect and enhance water, air and soil and minimise flood risk".
The need to protect and Agreed. Amendments to Amend Objective 1 as follows: enhance biodiversity has not Objective 1 may satisfy the "To have high quality open specifically been included. respondent. spaces and Green Infrastructure which maximises opportunities for
591 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. biodiversity value, wildlife and ecological connectivity". Vision 102/146; Page 20, paragraph 6 Agree. Change reference from 'historic Worcestershire 'character, biodiversity, heritage' to 'historic County Council landscape and historic environment'. Archaeology environment' for consistency. Unit Objectives 102/147; Page 21 Objective 4 change to Agree. Amend Objective 4 as follows: Worcestershire '…rural and historic "To protect, promote and County Council environment'. Historic where possible enhance the Archaeology environment is the preferred quality of the Boroughs Unit national term to encompass natural, rural and historic historic buildings, landscapes environment and its best and archaeological sites. distinctive features; Vision & 104/029; Suggests that in neither Core Agree. Redditch Borough Add to the vision to include Objectives RPS Strategy for Redditch or Council remains committed to reference to the delivery of Bromsgrove does the Spatial delivery of sufficient residential Cross Boundary development Vision refer to a Sustainable and associated development to in Bromsgrove and Stratford- Urban Extension to Redditch. meet its needs as set down in on-Avon Districts as follows: Given that the emerging RSS the WMRSS; therefore "A Sustainable Urban requires at least 3,300 elements of the suggested Extension to the north of dwellings on the periphery of addition would be appropriate Redditch Borough will be Redditch, it is recommended for inclusion in the vision. developed whilst working that both Core Strategy Visions closely with neighbouring incorporate reference to the Bromsgrove District Council.
592 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. extension. In terms of It will be well integrated and Redditch’s Core Strategy, in provide high quality new line with PPS12, the following housing, employment, retail statement is recommended: and communities facilities to ‘After the town centre, the meet the needs and focus of growth will be a demands of Redditch along Sustainable Urban Extension with assisting the urban (SUE) adjacent to the North regeneration of the town. A West of Redditch, partly within Diversification Park the administrative boundary of adjoining Redditch but in Bromsgrove District Council. Stratford-on-Avon District This will comprise at least will be delivered". 3,300 dwellings and complementary uses adjacent to the existing town. It will be well integrated and provide high quality new housing, employment, retail and communities facilities to meet the needs and demands of Redditch along with assisting the urban regeneration of the town. It will provide sustainable transport and accessibility opportunities and greatly enhance the natural and built
593 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. environment in the North West area of Redditch’. Vision & 104/030; The strategic planning policies In relation to the objective for No change. Objectives RPS contained within the Core new homes being delivered Strategy do not adequately and its coverage in subsequent deliver the objective for the policy, it is assumed that this provision of new homes. relates to the draft Core Strategy referring to the SHLAA estimated capacity being below the draft RSS housing requirements for Redditch. Since the PDCS the Phase Two Revision RSS has designated revised targets to each Local Authority, Redditch Borough Council now has sufficient clarity to refer to its housing requirements in policy. However this is not a matter which necessitates amendments to the vision or objectives. Recommend that more Include a new objective (12) on commonality is contained Objective 9 refers to having the provision of new homes in within the objectives of both sufficient homes to meet needs a SUE as follows:
594 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Redditch and Bromsgrove and this refers to the 4000 "To work closely with Core Strategies in order to dwellings related to meeting neighbouring authorities to demonstrate a clearer Redditch's requirements. It is deliver a Sustainable Urban correlation between Strategic agreed that reference to the Extension to the North of Vision, Objective and Policy SUE would be appropriate in a Redditch's urban area within where the urban extension is separate objective. Bromsgrove District and a concerned. It is suggested that Diversification Park at a new objective 12 be added or Winyates Green in Stratford objective 9 be amended to on Avon District." include clear reference to delivering a SUE adjacent to Redditch. Vision & 133/206; The comment ‘All development Agree. Change the vision to state: Objectives Miss C John will make a positive "new and existing low (RBC) contribution to the effects of carbon communities will be climate change’ needs to be highly accessible and reworded. attractive, making the most minimal contribution possible to the effects and impacts of climate change." Whilst it is agreed that there is Whilst the vision for all new no justification for carbon Amend Objective 2 to read, "To developments in the Borough neutral development at this ensure that all new to be carbon-neutral is positive, time, requirements for carbon development in Redditch it is deemed somewhat neutral developments must be Borough will work towards
595 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. ambitious. There needs to be a based upon National and the achievement of being clear idea of how this target will Regional requirements and the carbon neutral in line with be achieved and enforced. objectives can be amended to the Code for Sustainable Does it, for instance, refer only reflect this; however during this Homes." to domestic properties, or to all plan period up to 2026, the development? Similarly, if the national target in the CFSH Abbey Stadium project is (Level 6) for carbon neutral carried out, how can it be developments remain ensured that it will be carbon- appropriate for inclusion. The neutral? details regarding the application of the Code for Sustainable Homes is included in the relevant policies and delivery strategy.
Suggests the need to build The vision in the PDCS stated No change. energy-efficient and green new that "…new growth will have commercial space to support been achieved in a sustainable the Economic Development way giving rise to high quality, objectives of encouraging low carbon communities". This green economy/green jobs. statement intentionally does not preclude any forms of development including commercial, and it would be too detailed for a vision to be
596 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. specific on the application of energy efficient standards; however the suggestion would be appropriate for consideration in the Green Strategy. Vision & 153/505; Centro Welcomes overall vision and Noted. No change. Objectives objectives. It is important that there are strong correlations between RSS objectives, Policy T1-T12 of the Regional Transport Strategy and WMLTP. Objectives 202/328; Tetlow Support Objective 9, Ensure it Note support and agree with No change. King c/o is prioritised as the requirement the respondent regarding the Bromsgrove for existing and future housing importance of meeting housing District Housing to meet all local needs is need. However it is not Trust and West imperative to the success of appropriate to prioritise Mercia Housing any community. objectives, all are equally Group important to ensure the vision for Redditch is realised. Objectives 212/350; Objective 4 "To protect, Noted No change. Herefordshire promote and where possible and enhance…natural, rural and Worcestershire built environment…" is
597 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. Earth Heritage welcomed and supported. All Trust objectives under A Better Environment for Today and Tomorrow are welcomed and supported. Vision 223/365; Harris Support vision which identified Noted. No change. Lamb c/o James the objective to regenerate the Smith & Son town centre; a key element of and Smithers that regeneration will be Oasis Ltd through the redevelopment of strategic sites which will help improve connections to the town centre Vision 263/431; In most areas the historic Agree. The vision can be Amend the vision as follows: English Heritage environment will be a defining strengthened with specific "In particular, the regeneration characteristic of the plan area. reference to redevelopment of of the Town Centre will The vision should therefore the town centre. improve connectivity between include reference to the long- key sites and will have term aspirations for it and how respected the distinctive its future management might characteristics of the historic contribute towards social, environment." economic and environment aspects of the strategy e.g. conservation led initiatives. Make reference to
598 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. safeguarding/reinforcing the distinctive character of the various parts of the plan area.
In the case of Redditch due to It should be noted that the its local circumstances and reference to preserving and Reference to heritage will be recent planning history as a enhancing historic heritage is replaced with 'historic New Town, the vision achieves proposed to be changed to environment'. acceptable integration of the 'historic environment'. historic environment in terms of a specific reference to preserving and enhancing its historic heritage which should be retained. Objectives 263/432; Include specific objective for It is considered that Amend Objective 4 as follows: English Heritage the historic environment or one amendments to Objective 4 "To protect, promote and that refers to historic would satisfy the respondent. where possible enhance the environment as part of a quality of the Boroughs broader environmental natural, rural and historic objective or objective environment and its best promoting local distinctiveness. distinctive features." It should not repeat national guidance. Amend Objective 4 to include reference to historic environment as follows '…the
599 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. quality of the Borough's natural, rural, historic and built environment' Agree. Amend Objective 11 as follows: Welcome general thrust of "To maintain and support Objective 11 but underline the local landscape character importance of encompassing and distinctiveness in both the contribution of the historic urban and rural areas." environment to landscape character and distinctiveness in both urban and rural environments. Objectives 264/443; CBRE Support Objective 9. Suggest The previous objective 5 was No change. c/o Mettis inclusion of Objective 5 from not considered to be distinctive Aerospace the Issues and Options paper enough for Redditch however to ensure efficient use and re- the Borough Council remains use of land. Objective 9 and 5 committed to the national should then be prioritised. requirement to ensure efficient use and re-use of land, which is also echoed in the WMRSS, which forms part of the Development Plan for Redditch. It is not appropriate to prioritise objectives, all are equally important to ensure the
600 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ No./ Para/ Doc Representation No. vision for Redditch is realised.
Waste
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Waste 049/ 745 The Core Strategy must ensure The Core Strategy does not Consider reference to waste it has taken account of waste make reference to the management in the Enterprise development within the overall exclusion of waste and Skills Strategy of the Core provision for employment land management from future Strategy. as specifically noted within the employment land provision. West Midlands Regional The Employment Land Review, Spatial Strategy. The Waste which contains the detail on Core Strategy Issues and potential future employment Options Consultation proposed site allocations, simply sets out that 17.7% of the County’s new the most suitable type of land waste management capacity, use class for that site, but does up to 2027, should be in not make specific reference to Redditch District. any particular facilities. In relation to waste management falling under different use classes, Officers would point
601 Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. out that the omission of end uses in the Core Strategy will not prohibit the implementation of required facilities. If a site is required to be identified and is backed up by evidence then a site will be identified through the Site Allocations and Policies DPD but reference can be made to waste management facilities in the employment policies.
Water and Flooding
Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Policy BE. 2 021/ 079 Policy BE.2 generally accords Noted. None. with the relevant parts of emerging West Midlands Regional Spatial Strategy Policies SR1, SR2 and SR3.
602 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Policy BE.2 049/ 725 Although the document contains a Since consultation on the Ensure the outcomes of the Policy on Flood Risk and Water Preferred Draft Core Strategy the updates to the Flood Risk Management, insufficient Flood Risk Assessment and Assessment, and Strategic Flood attention is given to issues of Water Cycle Strategy has been Risk Assessment Level 2 (when water infrastructure/ resources updated. These documents now completed) and Water Cycle and water quality. give more scope to the tools the Strategy are considered when Core Strategy can use to ensure preparing the Submission Core flood risk is minimised and water Strategy. management is a high priority. A Strategic Flood Risk Assessment Level 2 will be commissioned which will also influence the Core Strategy. Recent advice states that policies should not be in a Core Strategy that do not relate to significant locally distinctive issues. It is considered that flooding in Redditch does not frequently cause severe problems and therefore does not require a policy in the Core Strategy; therefore it is unlikely that the Submission Core Strategy will contain a policy relating to flood risk. Water quality and resources have been a main issue for the Sustainability Appraisal. BE.2 049/739a Focus of policy is primarily on Pollution has been incorporated None.
603 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. flood risk and the use of SUDs as into the new Natural Resources a means of reducing flood risk. Policy. The intention of this aspect Pollution has not been addressed of the Policy is to ensure pollution in this policy and as a minimum from new development is should be cross-referenced to reduced. It was not considered Policy BE.4 Pollution. appropriate to include pollution in the Flood Risk and Water Management Policy because although pollution is considered to have a strong link to water issues, pollution also has links to air and land and therefore it would be inappropriate to link it to just one. A reference could be made between the Natural Environment Policy, however it is considered that all policies should be used it conjunction and the Core Strategy would be made very lengthy making overly exhaustive links. BE.2 A 049/739b How will SFRA Level 2 inform this The SFRA Level 2 will inform the None. Core Strategy? Core Strategy by detailing any strategic issues relating to flood risk management and defence infrastructure, in particular informing the Infrastructure Delivery Plan which ensures the Core Strategy is deliverable.
604 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No.
The SFRA Level 2 will feed into the Proposals Map by identifying and mapping the functional floodplain.
The SFRA Level 2 will also provide guidance on appropriate polices that could be used for specific sites and would also consider strategic sites. BE.2A 049/739c Item i and ii are taken from PPS 25 ‘Development and Flood None. PPS25 and do not need to be Risk’ requires that a flood risk repeated. Instead the Policy could policy is included within the Core reflect the Governments response Strategy. A surface water to the Pitt review on flooding, management plan is currently which recommends Local being prepared by Redditch Authorities undertake a Surface Borough Council. Water Management Plan. BE. 2A 049/739d Text should be amended to reflect Recent advice states that policies None. national policy which states, should not be in a Core Strategy ‘policy aims to make safe without that do not relate to significant increasing flood risk overall’ rather locally distinctive issues. It is than ‘flood protection has been considered that flooding in incorporated and that effects Redditch does not frequently elsewhere have been fully cause severe problems and assessed and mitigated against.’ therefore does not require a policy But text should not repeat national in the Core Strategy; therefore it is
605 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. policy. unlikely that the Submission Core Strategy will contain a policy relating to flood risk. BE. 2A 049/739e Should have regard to the The information contained within None. Redditch Policy Unit 9, as set out this document has been in the Severn Catchment Flood considered. The document notes Management Plan produced by that the appropriate policy the Environment Agency. approach for Redditch is to continue with existing or alternative actions, and flood risk is currently being managed appropriately. The document also suggests that a number of actions are outside of the control of the Development Plans system and should therefore be enforced by other bodies. BE. 2A 049/739f Supporting text may include Retro-fitting of properties could be None. reference to retro-fitting of existing completed as a corporate project. properties that are at risk of flooding or have flooded to cope with further flooding events.
The main policy should include It is considered that the Core Ensure the ‘Green Strategy’ reference to making properties Strategy ensures that future Technical Paper refers to resilient to the effects of climate properties developed in the properties being resilient to the change i.e. flooding. Borough are resilient to the effects effects of climate change. of climate change.
606 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No.
This section could mention the Warning systems have been None. need for evacuation routes to be analysed through the SFRA Level planned into those developments 1 Report demonstrating there are in flood risk areas. not any areas in Redditch that are at a significant risk where evacuation routes would need to be planned. BE. 2A 049/ 739g The section on flood risk and It is considered that it may be None. water management should appropriate to incorporate highlight the links between green reference to links between green infrastructure, wetlands and wet infrastructure, wetlands and wet wood lands and management of wood lands and management of flood risk. flood risk within the Core Strategy.
The policy should be amended to The Strategic Flood Risk None. reflect the need to safeguard and Assessment for Redditch has where possible, restore the considered the impact of each capacity of the floodplain thus proposed development site on the reducing the risk of flooding. loss of floodplain storage area. Following this it is considered that there does not need to be any other form of protection for the flood plain as the impact of future development has been considered. It is considered that flooding in Redditch does not frequently cause severe problems
607 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. and therefore does not require a policy in the Core Strategy; therefore it is unlikely that the Submission Core Strategy will contain a policy relating to flood risk. BE. 2B 049/739h First section of the text would fit It is considered that specific types Update Policy to include reference better in the reasoned justification of SUD techniques that could be to the specific SUD techniques and instead policy could provide used will be included in the Policy that can be used in Redditch. examples of types of water demand management techniques that could be used.
The policy could also make It is considered that reference to None. reference to the Code for the Code for Sustainable Homes Sustainable Homes and BREEAM and BREEAM is sufficiently standards. covered elsewhere in the document and another reference in this policy would not achieve anything. BE.2B 049/739i Water supply and waste water Water supply and waste water None. infrastructure have not been issues will be addressed addressed in this policy and only elsewhere in the Core Strategy. briefly in infrastructure Policy SC.7.
The Core Strategy should have These documents have been None. regard to the relevant Catchment considered and reviewed as part
608 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. Abstraction Management of the Sustainability Appraisal Strategies (CAMS) and ‘West Scoping Report. Midlands Regional Spatial Strategy (RSS 11) The Impact of Housing Growth on Water Quality and Waste Water Infrastructure’.
It is important to ensure adequate Agree. Officers continue to liaise None. sewerage treatment works are in with relevant infrastructure place to cope with the houses that providers to determine what are built. needs to be provided. BE. 2B 049/ 739j The policy should make clear that The Policy will be amended to Ensure that SUDs techniques that infiltration based SUD techniques clarify which SUDs techniques are are suitable in Redditch are will not be suitable. suitable in Redditch Borough. detailed within the Submission Core Strategy. Policy BE. 2 088/ 543 Welcome section on water A list of SUDS techniques that are Ensure that SUDs techniques that management. It would be helpful appropriate in the Redditch are suitable in Redditch are to list within the reasoned situation will be provided in the detailed within the Submission justification the types of SUDS introduction to this policy. Core Strategy. which might be possible where infiltration SUDS are not.
In addition, new developments It is not within the capacity of the None. should be required to have water Core Strategy to require all new meters installed in order to development to have water encourage efficiency of use. meters installed; this would remain the responsibility of the water regulator.
609 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. BE. 2 104/ 060 The SFRA fails to consider the The Strategic Flood Risk None. strategic planning issues Assessment Level 2 will consider associated within major urban the flood risk issues associated extension adjacent to Redditch. with the major urban extension There are no flood risk or water adjacent to Redditch. issues identified for the area that will comprise a North West Urban Extension.
The Policy should seek It is considered that any scheme None. comprehensive solutions to would need to address all flooding addressing flooding and water and water issues, any scheme issues as part of development that proposes solutions to existing schemes, where they can deliver issues would be appraised wider solutions to existing issues. favourably against the Sustainability Appraisal Framework. 130/ 203 Concern that significant new A Strategic Flood Risk None. development proposals may alter Assessment has been prepared the flow characteristics of the which considered the impact of River Arrow. In the design of new proposed development areas on development, drainage measures flooding. The recommendations should be put in place in order from this have been considered that at times of extreme rainfall in and incorporated into the strategy. the Redditch area the flow into the No issues have been raised to River Arrow heading southwards suggest that the flow towards Alcester will be no worse characteristics of the River Arrow than it would have been without would be altered. It is considered
610 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. the new development. that more detailed assessment may be done during planning application stages. 133/ 207 Greywater recycling, rainwater Greywater recycling, rainwater Include the principle of a harvesting and green roofs should harvesting and green roofs are a Greywater recycling, rainwater be encouraged strongly. Water means of reducing Redditch’s harvesting and green roofs within harvesting can reduce the amount water use and reduce the amount the ‘Flood Risk and Water of energy needed to treat and of water entering the sewer Management’ Policy in the process water. system. These methods are very Submission Core Strategy. important in working towards the ‘Green Strategy’ within the Core Strategy and therefore a separate policy will be included within the Core Strategy. Strategic Sites 093/ 491 With regard to Strategic Sites no The SFRA and Water Cycle None. / Flooding reference has been made to the Strategy have been considered water cycle study for Bromsgrove when compiling Strategic Sites and Redditch (draft) and the Level and it was deemed there was 1 SFRA for Bromsgrove and nothing significant to prevent Redditch. It is expected that the these sites coming forward for sequential testing and phasing of development. sites have been undertaken based on all sources of flood risk (including zones and depths of flooding) and appropriate policy to require the use of SuDS; flood risk reduction and enhancement.
611 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. It is noted that within the ‘SA Agreed. None. assessment of large and strategic sites’ under the decision making criteria ‘no’ has been ticked for all of the sites except the Abbey Stadium for the criteria ‘does it take account of all types of flooding?’
The availability and provision of Agreed. None. appropriate infrastructure (foul/ surface water drainage, water supply) will inform the allocation and phasing of sites and may have financial implications. It therefore must be considered early on in the process.
References made to infrastructure Although there is an emphasis on None. within the spatial policies (i.e. the need for transport regeneration for the town centre, infrastructure within the Preferred district centre redevelopment and Draft Core Strategy, the Woodrow strategic site) appear to Infrastructure Delivery Plan will be towards transport only. explicitly detail all of the forms of However previously commenting infrastructure that each site will on a proposed town centre require before they can be strategy (20.3.2009) highlighted developed, including water that part of the area is identified infrastructure. The Infrastructure
612 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. as requiring a minor infrastructure Delivery Plan is currently being upgrade, based on the draft water progressed. cycle strategy document. Flood Risk 093/ 496 This section could be titled ‘Flood Noted. This amendment will be Re-title the Flood Risk section to Risk and Water Management’. made to reflect the contents of the ‘Flood Risk and Water section. Management’. Under A. Flood Risk
For Policy BE.2 it should be noted Noted. This change will be made Amend policy to ensure a FRA is that a Flood Risk Assessment to identify what is requested required for development (FRA) is also required for nationally. Can this response be proposals in Flood Zone 2, 3a and development proposals in Flood reworded so that it doesn’t look as 3b. Zone 3b (‘functional floodplain’). obvious that we are copying national policy.
Reference should be made in the It is not considered appropriate to None. Policy to the SFRA to make it make reference to specific more locally distinctive. documents within the policy as these documents are used to form the overall direction and content of the policy. It would only be considered appropriate to reference the document within the policy if it was specifically relevant to the policy.
The Policy is generally supported It is considered that these are None. however it could expand on areas very specific issues that would be
613 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. which are considered in less considered at the planning detail within PPS 25 such as application stage and that it is not achieving flood risk betterment; necessary to detail this in a Core safe development requirements; Strategy. other areas of flood risk; and protection and enhancement of watercourses (detailed options are presented under each theme that could be contained within the Policy).
Under B. Water Management
Support the reference to the water Support noted. None. cycle study and the requirement for new development to include SuDS techniques. Support developments incorporating rainwater harvesting and grey water recycling.
It is suggested that reference is Agree. Include reference to water quality made to water quality within this in Policy. policy and / or the policy on climate change. The outcomes of the final Water Cycle Study may inform this further. Water 103/ 161 The use of SUDS is not There are a range of SUDS A full list of SUDS techniques that
614 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. applicable in Redditch due to non techniques that are appropriate in are applicable in Redditch will be permeable clay. Redditch, a list of these will be incorporated into the Policy in the provided in the introduction to the Submission Core Strategy. ‘Climate Change Policy’.
There are problems with the The SFRA and WCS has None. system that collects surface water identified flooding or water separately from the sewerage and management issues within the puts it into the nearest Borough. The SFRA Level 2 will watercourse; this has resulted in identify mitigate measures for any significant increases in flows in areas in need of attention, this will both the streams and rivers. This be fed into the Core Strategy. causes flooding further downstream at Studley, Alcester, Evesham, Pershore and Tewkesbury. This also has a scouring effect on many rivers and streams including the River Arrow which dropped 15 – 20 cm after the 2007 floods.
Most of the rivers in the area will This is too detailed for the Core None. not sustain additional extraction in Strategy but could be undertaken summer months. Water should be as a corporate activity to address stored in the winter for use in the flood risk and water management summer. in the Borough.
615 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. In areas where there is a risk of This is taken into account before None. flooding, the policy should any designations of land for future recognise that, rather than avoid development. Areas of land that building on large sections of land, are at risk of flooding are not artificially isolating communities permitted for development unless and utilising more Green Belt than full mitigation measures are is necessary. implemented.
The river should be straightened Flood risk mitigation measures None. and controlled with weirs, with low are in the SFRA and will also be level paths by the river, and considered in the SFRA Level 2. It protected banks set some five is considered that a range of meters away from the channel to these measures will be allow for wildlife movements along implemented corporately but are the river. not appropriate for inclusion within the Core Strategy.
The requirements to use grey This is outside of the remit of the water recycling and rainwater Core Strategy. National planning None. harvesting should be discarded in policy continues to support all but large commercial sites due greywater recycling and rainwater to health and safety hazards harvesting. There has been no posed by storing and using water. national announcement or research to suggest that greywater recycling and rainwater harvesting is a danger to health and therefore this will still be promoted as a sustainable
616 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. method of water management.
The Arrow Valley lake should be This form of water management is None. used to hold an additional two too detailed for inclusion within meters of water, this would allow the Core Strategy. excess water to be diverted from the river and either stored for the summer, or released through a turbine. It should be a condition on all new development above the lake to contribute towards the construction of such a scheme.
Policy BE.2 264/ 448 This Policy accords with the It is considered that the proposed Amend wording to read “The guidance contained within PPS wording is appropriate and that Borough Council will seek 25. The following amendment flood management schemes opportunities to use developer should be made to the wording of should only be requested where contributions to fund flood risk this policy “The Borough Council they are directly related to the management schemes where will seek opportunities to use development. these are not provided directly by developer contributions to fund the developer and are directly flood risk management schemes related to the proposed where these are not provided development .” directly by the developer and are directly related to the proposed development .”
129/201 With reference to Executive These factors will be considered None. Clive Wilson Summary, items 1.17 & 1.18 are through the SFRA Level 2.
617 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. entirely erroneous.
There are 2 main constraints on Foul Drainage: - 1. The ridge between the Spernal and Priest Bridge sewage treatment works catchments NOT "west of River Arrow" is the significant factor. 2. A lack of capacity in both Old Town and New Town/Duplication sewers between Hewell Road/Windsor Road and Ipsley Church Lane/Arrow Valley Park (Central) These are based upon extensive observations and close working knowledge. Either pumping and/or considerable investment in off-site sewerage infrastructure would be required.
Flooding 103/ 164(a) The requirement to avoid flood This is a mitigation measure that None. zones and not contribute to may be permitted though an surface water flooding in other exceptions test. However in the
618 Policy/ Issue/ Respondent Summary of comment Council’s response Council’s proposed action Para/ Doc No./ Representation No. areas would be met by the first instance development should construction of water retaining be avoided in flood risk areas. areas and by treatment of the key water courses in such a way that they can cope with excessive flow without permanently damaging the habitat of the local flora and fauna.
Avoiding building close to rivers is Again, this is a mitigation measure None. also unattractive in that it puts that may be permitted though an pressure on good agricultural land exceptions test. However in the rather than utilising the poorer first instance development should areas; reworking the river bed is a be avoided in flood risk areas. much more attractive option, especially given the fall levels through the Borough.
Winyates Green Triangle
Policy/ Respondent Summary of comment Council’s response Council’s proposed action Issue/ Para/ No./ Doc Representatio n No. Winyates 017/236; Identified for employment or It should be noted that the No change
619 Green CPRE housing. Does not belong to Winyates Green Triangle is Triangle A435 ADR as part of Reserved within the administrative area Linear Strip. of Stratford-on-Avon District Council. This district has the benefit of No change this natural reserve but no The Key Diagram contained public or primarily open space. within the Redditch Borough Residents for many years have Council Preferred Draft Core enjoyed Winyates Green Strategy indicates the area to Triangle as their be an area for future growth public/primarily open space – and it should also be noted that to lose this site would be this is one of few peripheral sacrilege. Another 300 areas around the Borough of households would densely Redditch which is not included urbanise the district contrary to in the designated Green Belt. the vision for Redditch in the The Winyates ward which draft Core Strategy. adjoins the Winyates Green Triangle has an informal unrestricted open space provision level of 4.29ha/1000 population, although below the Borough average, there is clearly a level of open space that can be used by the No change. inhabitants of the ward. As a ‘local nature reserve’, there is evidence of quality of Notwithstanding the references small meadows, importance of by the respondent to the earlier special hedgerows dividing White Young Green Report, these and also along Drovers the Second Stage Report of
620 Road containing some rare the Study into Future Growth flora and fauna. With streams Implications of Redditch also and ponds at every hedgerow, prepared by White Young the meadows are constantly Green (WYG Stage II) wet. Winyates Green Triangle examines the Winyates Green has to be a Local Nature Triangle in greater depth. Reserve - Stratford’s efforts to get the site identified as a Local Nature Reserve was discounted by Inspector and No change English Partnerships.
Wooded area south of Winyates Green Triangle – Paragraph 5.28 of WYG Stage much ground water comes off II comments that the Winyates the A435 and the area has Green Triangle is an area of several large ponds and an ‘white land’ within Stratford-on- open culvert. The flooding Avon District Council’s aspect referred to by WYG is administrative area and that paramount and will definitely the site was included in the serve as a constraint. Stage I Report as being suitable for residential No change. development and could contribute an estimated 300 units to the assessment. Winyates Green is a residential district. To have this site built Paragraph 5.29 continues by as industry will ‘enclose’ the stating that the site relates to northern section of Winyates Redditch and unlike much of Green District. The Triangle is the A435 ADR land to the
621 enclosed by roads and Far south, WYG felt that the site Moor Lane is not suitable for could be developed without HGV traffic from abroad. All detriment to the surrounding existing empty and unused area. Further investigations No change employment sites need to be in regarding access will be full use before new sites are undertaken as well as a released. Transport Assessment.
Constraints: - 1 Flooding; Para 5.30 of the WYG Report 2 Two historic monuments; commented that the site has 3 Prospective Local Nature elevated roads to the north and Reserve and wooded area; may cause a noise nuisance. 4 Lack of Public/Primarily Open Whilst Redditch appears to Space. have an adequate stock of B2 and B8 premises on Outcomes if land built on: - established industrial estates, 1 Developing industry in a they perceived that there was a residential area; shortage of quality B1 On receipt of the WMRSS EiP 2 Dense urbanisation of accommodation and given the Panel Report (Autumn 2009), Winyates Green contrary to need to identify additional officers will consider whether draft Core Strategy. employment land, this site sufficient potential supply has would be more suited to B1 been identified in the SHLAA to Potential issues relating to rather than residential meet Redditch’s housing coalescence between Redditch development. allocation within the Borough, and Mappleborough Green. or whether further The Stratford-on-Avon District consideration will need to be Council Draft Core Strategy given to contributions which comments that they are faced could be made by the ADRs with two significant
622 development issues that have major implications for certain parts of its own area but has involved close working with neighbouring authorities because of geographical position. Accordingly, Policy CS6 makes provision for approximately 11.7 hectares of land at Winyates Green Triangle to be released for employment development to meet the needs of Redditch. Policy CS6 also makes No change. provision for the extension of the Green Belt elsewhere to include land between the A435 and the boundary with Redditch, however further investigations into the status of Redditch's ADR will be undertaken.
The comments regarding the use of the land as open space are noted. However, the Council contend that there is adequate designated Primarily Open Space off Alders Drive in close proximity to the existing
623 housing development off Far Moor Lane. In the consideration of any future development of the Winyates Green Triangle, the Council are fully aware of the designated Special Wildlife Site off Far Moor Lane which will be given careful consideration. Draft Core 147/233; No objection to overall RBC has no disagreement with Proposals for resolution of Strategy – Stratford-on- approach. concerns relating to traffic traffic impact around Winyates Cross Avon District impact. RBC is currently Green Triangle to be included boundary Council Developing Winyates Green developing a policy for the in new policy for adoption in Issues / Triangle could increase traffic Winyates Green Triangle in Stratford-on-Avon Core Winyates on A435 – need for a bypass to collaboration with stakeholders Strategy and RBC Core Green Studley has been argued even for adoption by Stratford-on- Strategy, if appropriate. Triangle without this allocation. Avon District Council in their Although bypass no longer Core Strategy. In developing committed, traffic impacts need this Policy, provision will be to be fully assessed to see if made for investigation and the bypass is justified. Officer resolution of traffic issues and group should investigate a transport assessment will be further – outcome should undertaken. inform Core Strategies of both Redditch and Stratford Districts
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