MARCH 2014 Borough of Redditch Local Plan No.4 Regulation 22(1)(c)(v) & (vi) Report Summary of the main issues raised at Proposed Submission stage (30 Sept. to 11 Nov. 2013) Contents 1. Introduction 2. Publication under Regulation 19 of the 2012 Regulations 3. The Representations 4. Bromsgrove Cross Boundary Appendices 1 Consultation letter and Regulation 19 Statement of Representations Procedure 2 Public Notice - Statement of Representations Procedure 3 Consultation Poster 4 List of Representors Abbreviations ADR Area of Development Restraint AQMA Air Quality Management Area BAAG Bentley Area Action Group BCC Birmingham City Council BDC Bromsgrove District Council BDP Bromsgrove District Plan BORLP4 Borough of Redditch Local Plan No.4 CIL Community Infrastructure Levy GB Green Belt GBSLEP Greater Birmingham and Solihull Local Enterprise Partnership HA Highways Authority HGDS Housing Growth Development Study LA Local Authority LWS Local Wildlife Site NPPF National Planning Policy Framework NPPG National Planning Policy Guidance PDL Previously Developed Land PINS Planning Inspectorate RBC Redditch Borough Council SA Sustainability Appraisal SCI Statement of Community Involvement SFRA Strategic Flood Risk Assessment SHLAA Strategic Housing Land Availability Assessment SHMA Strategic Housing Market Assessment SOADC Stratford on Avon District Council SPD Supplementary Planning Document STW Severn Trent Water Ltd WCC Worcestershire County Council WDC Wychavon District Council WFDC Wyre Forest District Council WGT Winyates Green Triangle WMRSS West Midlands Regional Spatial Strategy WYG White Young Green 1. Introduction 1.1 Redditch Borough Council (RBC) submitted the Borough of Redditch Local Plan No.4 (BORLP4) to the Secretary of State for independent examination on 12th March 2014. 1.2 The BORLP4 has been prepared in accordance with the Authority’s Statement of Community Involvement, the Planning and Compulsory Purchase Act 2004 (as amended) and the Town and Country Planning (Local Planning) (England) Regulations 2012 (SI 767/2012). Stages prior to the commencement of the 2012 Regulations were prepared in accordance with appropriate legislation at that time. 1.3 This Statement sets out details of the BORLP4 publication and has been prepared in accordance with Regulation 22(1)(c)(v) & (vi) of the Town and Country Planning (Local Planning) (England) Regulations 2012. It details how the proposed Submission process was undertaken, how many representations were received and the main issues that were raised. Where no issues were raised regarding a certain policy, this has also been indicated. 1.4 The Redditch Borough Council Statement of Consultation sets out the Requirements under Regulation 22(1)(c)(i to iv), which is published alongside this Statement. Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 1 2. Publication under Regulation 19 of the 2012 Regulations 2.1 The Proposed Submission version of BORLP4 was approved by Full Council at a meeting on 9th September 2013 for publication. A six week Representation Period was held between 30th September and 11th November 2013. The BORLP4 Representation Period ran concurrently with the BDP Representation Period due to the inclusion of a cross boundary policy, which impacts on both Plans. 2.2 Consultation Involvement and Engagement Notification of the Representation Period was sent to 1277 bodies and individuals on the Council’s database by post or email. This correspondence set out how copies of the relevant documentation, submission forms and guidance notes could be accessed, how to submit representations, and deadlines for submission. A copy of the letter text and Regulation 19 Statement of Representations Procedure Notice sent to consultees is provided at Appendix 1. 2.3 Statutory Notice A notice was placed in the Redditch Advertiser on 2nd October 2013, setting out the Statement of Representation Procedure (Appendix 2). The contents of the Notice were also displayed on the Council’s website www.redditchbc.gov.uk/localplan 2.4 Drop-in Events The Statutory Notice also highlighted when Planning Officers were available to provide guidance on how to complete the Representation Forms at the Town Hall during the following dates/times: Monday to Friday (30th Sept -11th Nov): 10am to 4pm (Main Reception) Tuesday (8th Oct, 22nd Oct, and 5th Nov): 4pm to 8pm (Committee Rooms) Saturday (12th Oct, 17th Oct and 31st Oct): 9.00am to 11.30am (Committee Rooms) Officers were also available at BDC Council House and/or Customer Service Centre during the following dates/times: Monday to Friday (30th Sept -11th Nov): 9am to 5pm (Main Reception) Tuesday (1st Oct, Conference Room): 4pm to 8pm and Thursday (17th Oct and 31st Oct, Committee Room): 4pm to 8pm Saturday (5th Oct, 19th Oct, and 2nd Nov): 9.00am to 11.30am (Customer Service Centre/Dolphin Centre) Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 2 2.5 Document Availability The Proposed Submission version of BORLP4, Draft Policies Map and Inset Maps, supporting documentation, together with Representation Forms and Guidance Notes for their completion, were made available for inspection during the Representation Period at the following locations: Main Reception, Redditch Town Hall Former Planning Reception, Redditch Town Hall Redditch Library Mobile Library Woodrow Library Redditch One Stop Shops Additionally, all documents were placed on the RBC web site www.redditchbc.gov.uk/localplan 2.6 Posters A4 posters were placed on all Council noticeboards during the Representation Period. A copy of the poster can be seen at Appendix 3. Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 3 3. The Representations 3.1 The Number of Representations received: 13451 bodies or individuals made representations on BORLP4 (Appendix 4). Additional representations were received relating to the cross boundary element of the Plan which has been prepared in conjunction with BDC. These representations have been analysed separately. Of the 1346 BORLP4 Representors, 1235 requested that their Part A information was linked to Action Group representations, 111 made separate representations or individual comments. Some representors did not use the representation forms and these representors tended not to indicate whether they considered the Proposed Submission Document to be legally compliant, sound, or if they wished to attend the Examination Hearings. 3.2 The Representors: Although it is difficult to categorise the responses, the following breakdown gives a general indication of the profile of the Representors. 1235 Representors requested to be linked to Action Group representations o 950 – Keep Our Green Campaign o 94 – Mappleborough Green Residents Association o 191 – Webheath Action Group 62 Representors were individuals 1 Representor was a community/ social group (Redditch Golf Club) 14 Representors were developers, landowners and businesses 9 Representors were Parish Councils, Ward Councillors, MPs 17 Representors were interest groups/ organisations/ Statutory agencies 7 Representors were other Councils/ Council departments Linked to an Action Group Individuals Community/ Social Group Developers/ Landowners/ Businesses Parish Councils/ Ward Councillors/ MPs 34 or 2.5% of Representors indicated that they wished to participate at the Hearing Sessions of the Examination 1 The database contains 1353 Representor entries, which includes 8 deleted records which arose through duplication Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 4 3.3 Legal Compliance Of the 3872 individual Representations: 79 Representations stated that they found the Plan to be legally compliant 71 Representations stated that they did not find the Plan to be legally compliant 238 Representations did not state whether they considered the Plan to be legally compliant or not Legal Compliance 21% Representations that considered the Plan to be legally compliant Representations that did not consider the Plan to be legally compliant 18% 61% Representations that did not state whether they considered the Plan to be legally compliant or not 2 The database contains 396 Representation entries, which includes 9 deleted records which arose through duplication Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 5 3.4 Tests of Soundness Of the 387 individual Representations: 52 Representations stated that they considered the Plan sound 207 Representations stated that they considered the Plan unsound 128 Representations did not state whether they considered the Plan sound or not Tests of Soundness 14% 33% Representations that considered the Plan to be sound Representations that did not consider the Plan to be sound Representations that did not state whether they considered the Plan to be sound or not 53% Borough of Redditch Local Plan No.4 – Regulation 22(1)(c)(v) & (vi) Report – March 2014 6 3.5 Breakdown of the Tests of Soundness Of the 207 individual Representations that considered the Plan unsound: 179 found the Plan content to be not Justified 132 found the Plan content to be not Effective 74 found the Plan content to be not Consistent with national policy 112 found the Plan content to be not Positively prepared Breakdown of the Tests of Soundness Representations that 22% considered the Plan unsound because it is 36% not: Justified Effective Consistent with national policy 15% Postively prepared