Examinations of the Bromsgrove District Plan (BDP) and Borough of Redditch Local Plan No.4 (BORLP4) Hearing Statement: Response to Inspector’s Matters, Issues and Questions Matter XB1: Cross-boundary Allocations 5YHLS Joint Statement prepared by Bromsgrove District and Redditch Borough Councils 4th March 2016 Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions Matter XB1 - Cross-boundary Allocations XB1.2 Do the Foxlydiate and Brockhill Urban Extensions represent the most appropriate locations for meeting Redditch’s housing needs within Bromsgrove District, having regard to the provision of the necessary infrastructure, affordable housing and other facilities, and taking account of environmental constraints? Is the methodology for selecting these sites robust and transparent? Has appropriate consideration been given to alternative locations? Have exceptional circumstances been demonstrated to justify the removal of land from the Green Belt? 1. In addition to the previous comments made in the previous Hearing Statements XB1/1a and XB1/1b dated 3 rd December 2014 and 8th June 2015 Bromsgrove District Council (BDC) and Redditch Borough Council (RBC) would like to take the opportunity to re-emphasise and add the following comments. 2. The Councils’ consider that the Foxlydiate and Brockhill East urban extensions represent the most appropriate locations for meeting Redditch’s housing needs within Bromsgrove District. The analysis that informs this view can be found in the Housing Growth Development Study (HGDS) [CDX1.1], and further explanation is found in the more recent Narrative on the Site Selection Process for the Growth Areas at Redditch January 2016 [“The Narrative”] which were completed jointly by BDC and RBC officers. Both set out the process of analysis undertaken to identify appropriate locations to meet Redditch’s unmet housing need. Revised wording to address the amended developable area boundary of Site 1(Foxlydiate / Area 4) will be provided in the Schedule of Modifications. This will be published before the Hearings in March 2016. 3. Both the HGDS and The Narrative emphasise that no area is perfect and that the process boils down to a fine balancing act. The choice that has to be made therefore is on the basis of the area(s) which most suitably deliver the required amount of development and associated infrastructure with the least negative impacts. 4. Both Councils’ consider that the methodology for selecting appropriate sites for development is robust and transparent, as demonstrated in the HGDS and explained in The Narrative and as set out in the previous Hearing Statements. 5. The HGDS, HGDS Sustainability Appraisal (SA) and Addendum documents comprehensively examine all alternative locations around Redditch’s urban area and The Narrative provides further explanation and detail on this process. 6. The previous Hearing Statements explain how exceptional circumstances have been demonstrated. However, the Councils’ have further comments to make on this issue. 2 Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions Paragraph 84 of the National Planning Policy Framework (NPPF) states that; When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. The Councils’ have demonstrated that they have considered the consequences for sustainable development referred to in this paragraph in the following ways: A) Towards urban areas inside the Green Belt boundary: This has been demonstrated by allocating two small Green Belt sites at Brockhill East and land opposite the Foxlydiate Arms, for development within the Borough. It is evidenced via the RBC Strategic Housing Land Availability Assessment (SHLAA) process that no further sites are suitable, available and achievable. B) Towards towns and villages inset within the Green Belt: There are no towns (apart from Redditch) and only one village inset within the Green Belt, namely Astwood Bank, and one smaller village, namely Feckenham, which is washed over by the Green Belt. Astwood Bank is separated from the southern part of Redditch’s main urban area by ribbon development. The village does have some good services and facilities, mainly concentrated around the main Evesham Road A441(“The Ridgeway”). Access to public transport in this area is considered to be poor and it is 6.8km from Redditch Town Centre. Development north of Astwood Bank would result in coalescence between Redditch and Astwood Bank. Feckenham is located further south in a largely rural area and has much fewer services and facilities (as evidenced in the Redditch Accessibility Study and Settlement Hierarchy document [CDR7.12]) and is less accessible in transport terms. Significant investment in highway infrastructure would be required to unlock this area for development, which at the present time, is considered very unsustainable. C) Towards locations beyond the outer Green Belt boundary: There is an area of ‘open countryside’ beyond the outer limits of the Green Belt boundary in the south of the Borough. This area has been examined in terms of providing a new settlement as no existing settlement exists here. The option of having a new settlement in the Green Belt is assessed as an option in the Redditch Sustainability Appraisal Refresh (February 2010 - March 2010) page 208 – 219. The same information (together with other options) is included again in the Sustainability Appraisal Revised Preferred Draft Core Strategy (January 2011 – March 2011) page 292 – 315. There are no existing services and facilities or adequate highway infrastructure serving this area. 3 Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions Whilst there is a section of Feckenham south of the B4090 in the open countyside, similar to B) above significant investment in highway infrastructure, services and facilities would be required to unlock this area for development, which at the present time is considered unsustainable. As set out in Part 2 of the Planning and Compulsory Purchase Act 2004 the achievement of sustainable development is an ongoing duty on Local Planning Authorities (LPA’s). The duty to contribute to sustainable development involves strategic considerations about how best to shape development in an area to ensure that proper provision is made for the future in terms of housing and economic growth and for mitigating the impacts of climate change. Inevitably additional travel and patterns of development are an important consideration in this respect. Therefore, as demonstrated above the lack of sustainable sites outside the Green Belt boundary to meet the identified need for housing in a way that is consistent with the Development Strategy of Borough of Redditch Local Plan No 4 (BORLP4) amounts to exceptional circumstances that justify release of Green Belt land. In accordance with the Redditch Development Strategy that development must be adjacent to the boundary of the Redditch urban area and there are no suitable sites available within the Borough, sites in the Green Belt of Bromsgrove District are therefore proposed Site 1 (Foxlydiate/ Area 4) and Site 2 (Brockhill East/Area 6). Such sites are being brought forward under the legal Duty to Co-operate with Bromsgrove District Council. 7. Consultation was carried out between 31st December 2015 and 16 th February 2016 on the following documents: • Narrative of the Site Selection Process for the Growth Areas at Redditch • Hewell Grange Estate: Setting of Heritage Assets Assessment • Lanehouse Farm: Setting of Heritage Assets Assessment • Heritage Assets Harm Versus Public Benefits Statement • Bromsgrove Updated Five Year Housing Land Supply • Redditch Updated Five Year Housing Land Supply • Gypsy and Traveller Accommodation Assessment Issues were raised by respondents concerning the appropriateness of the sites selected. The Councils’ would like to take the opportunity to comment on some of the key issues raised. a) Flooding Issues Some respondents have concerns that development at Foxlydiate will increase flood risk due to additional run- off, thereby increasing risks of flooding downstream. 4 Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions The Councils’ consider that it should be noted that a Statement of Common Ground (SoCG) has been agreed between Severn Trent Water Limited (STWL), the Environment Agency (EA), RBC and BDC. Furthermore policies in the Bromsgrove District Plan state that: RCBD1.9 VI. (Proposed Modifications underlined) “Flood risk from the Spring Brook on Site 1 Foxlydiate and the Red Ditch on Site 2 Brockhill East should be managed through measures that work with natural processes to improve the local water environment . Any necessary measures to mitigate flood risk are to be implemented and flood modelling will be required, which must be outlined in a site specific Flood Risk Assessment. Surface water runoff must be managed to prevent flooding on, around and downstream of both sites through the use of Sustainable Drainage Systems (SuDS)”. BDP 23.1c) Water