Emma Newfield From: Helen Bonham Sent: 14 February 2016 23:03 To: Consult Planning Subject: Consultation on BORLP4 'Narrative' Document Dear Sirs We would like to comment on Redditch Borough Council’s revised document as follows: 1. It is ingenuous to gloss over the Sustainability Analysis of the ADR sites on the basis that this land has been previously “removed from the Green Belt for the express purpose of meeting the future development needs of the town” (Section 9.16). It is clear that in the years since this designation was applied, there have been fundamental changes in levels of car ownership and usage, travel patterns and public transport provision which have significant implications for the sustainability of local development. This implies that the Sustainability Analysis process should have reviewed potential development in these areas in detail and with no pre-conceptions. Indeed, the designation Area of Development Restraint implies that future development should be subject to rigorous review. It is clear that in reality the review in respect of these areas has been cursory and riven with preconception. 2.Recent announcements in respect of Redditch becoming a member of the West Midlands Combined Authority suggest that future development will, and should be, focussed towards the north of the town as Birmingham City Council will be the driving force and it will be more sustainable to build closer to the areas where new jobs will be created. In this context, the Bordesley site is closest to Birmingham and the Redditch Eastern Gateway, whereas Webheath and Foxlydiate are the furthest away. There is therefore no rationale for building in Webheath where there are no local employment sites being developed. The importance of the WMCA initiative is significant: Redditch MP Karen Lumley has stated that “Redditch will soon become full members of this Midlands Engine for Growth ... Business - Industry - Employment - Regeneration – Growth”. It has been estimated that annual government funding 'worth' £40m will unlock £8 billion of investment and 500,000 jobs. HM Government states in 'Fixing the Foundations : Creating a More Prosperous Nation' (page 43): "9.2 An effective land and housing market promotes productivity by enabling the economy to adapt to change, helping firms to locate where they can be most efficient and create jobs, and enabling people to live and own homes close to where they work." (HM Treasury, July 2015). In a similar vein, the Royal Town Planning Institute has made reference to the government 90 page blueprint, 'Fixing the Foundations : Creating a More Prosperous Nation':"On planning and housebuilding, the document will argue that a more effective land and housing market will promote productivity by enabling the economy to adapt to change – helping people to live and own homes close to where they want to work and firms to locate where they can be most efficient and create jobs." (RTPI, 10/07/15). 3. There is a specific issue regarding carbon emissions increasing due to the pumping of sewage for 3,400 houses to Spernal Ash Water Treatment Works, near Alcester. This is not covered in section 9.161 (page 71). However, it is now understood that Severn Trent Water will pump sewage for the 3,400 new dwellings proposed to Spernal Ash and not spend the £3m to £4m necessary to enable gravity feed to Priest Bridge Treatment Works. This increase in carbon emissions would not be compliant with the Paris Climate Change International Agreement 2015. Note that the SWOT analysis for the Webheath ADR (provided within the report appendices) suggest that the “gravity” option is less favourable than the pumping option, whereas it is clearly the preferred option on environmental grounds. 4. In connection with the proposed building of 200 new houses within the Webheath ADR, it has been established (GeoRisk Management Consultants Investigation Report – December 2014) that the land is 1 contaminated with BaP, cadmium, lead and nickel(GeoRisk Management Consultants Ground Investigation Report (December, 2014). The contamination is in respect of a filled in pond containing waste from the needle making industry. It is notable that there are filled in ponds all over the rest of the Webheath ADR and that these are in all probability similarly contaminated. This clearly detracts from the sustainability of development within this area. 5. The SWOT analysis provided within the appendices as an appendix to the report identifies that there is an opportunity to improve the transport infrastructure for the whole of the Webheath Area. This is a clear mis- statement. Public transport arrangements throughout Redditch are currently ineffectual with the incumbent bus operator not providing a reliable service. The reasons for this are various, but a significant factor is the low level of public subsidy available and this situation is not likely to change. The reality is that further development in Webheath will lead to increased car usage, higher pollution levels and more congestion. 6.The Webheath ADR area is an important recreational resource for the people of Redditch as it provides easy access via foot paths and bridleways to scenic, undulating Worcestershire countryside which is also rich in wild life. This area is of better quality and amenity value than other open spaces in the area. In fact it is strikingly beautiful and should be preserved in perpetuity for future generations. Many areas of undeveloped land are unremarkable and their loss to development can be easily reconciled. This is not the case in respect of the land making up the Webheath ADR. Yours faithfully Helen Bonham Tom Bonham 49 Crumpfields Lane Webheath Redditch Worcestershire B97 5PN 2.