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 4 th March 2016
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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
2
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 3rd 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.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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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.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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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 16th 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.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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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 Management policy “Ensuring development addresses flood risk from all sources, follows the flood risk management hierarchy when planning and designing development, and does not increase the risk of flooding elsewhere. Where inappropriate developments in areas at risk of flooding are necessary after the sequential test is applied, appropriate designs, materials and escape routes that minimise the risk(s) and loss should be incorporated”. See also Hearing Statement XB1/2f Appendix 10 Flood Risk Assessment by WSP dated November 2014 which states that: “.. the drainage strategy must not only consider flood risk but must also aim to achieve the Greenfield run off rates to ensure that conversion from Greenfield to suburban land use does not reduce recharge rates to the aquifer. In addition we will be expecting the recharge to be of high quality and we will expect the highest level of treatment for SUDS schemes”. This issue was also discussed in the Hearing Sessions in June 2015 where it was stated that this issue is addressed in policy. It is a requirement of the NPPF that run off is not increased as a result of new development. b) Area 8 Some respondents were confused about the remarks in the conclusion of The Narrative (Page 100 para 16.19) in relation to Area 8 and the Abbey Stadium. The Councils’ would like to clarify that benefits are identified in The Narrative including the possibility of providing the Bordesley Bypass, the distance to leisure facilities and recreation and its ‘perceived proximity’ to the Town Centre. There are other factors which outweigh these benefits. These benefits/ strengths/opportunities as detailed in the SWOT analysis on page page 143. The reason ‘perceived’ proximity to the Town Centre is listed is because many objectors claim that Bordesley is closer to the Town Centre than other areas. Whilst it is closer than some it is approximately 4.1 km away (beyond what is considered to be a reasonable walking distance). Officers
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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have considered more than purely distance in relation to the Town Centre including accessibility along main roads, legibility and safety. e) Coalescence and Green Belt gap Some respondents did not consider that the Green Belt gap issue and coalescence had been consistently addressed and considered that the development of Area 4 will significantly reduce the Redditch / Bromsgrove gap. Some considered that this Green Belt purpose was of lesser importance than some of the other Green Belt purposes such as sprawl and encroachment into the countryside and suggested the coalescence of Redditch and Studley was acceptable. The Councils’ consider that the NPPF makes no distinction between the importance of the five Green Belt purposes and at para 80 states one of the purposes is to ‘to prevent neighbouring towns merging into one another’. This clearly does not extend to hamlets, any loose arrangement of buildings or names of areas. The HGDS for completeness did however consider this issue at this finer detail. Page 38 of The Narrative also acknowledges the issue of the Green Belt gap/ Strategic Green Belt gap – “…wherever issues arose about the potential reduction of the Green Belt Gap based upon the distance between settlements, the HGDS described the nature of the issue and which settlements are potentially compromised”. The Councils’ consider that, in relation to development at Foxlydiate and Brockhill East, neighbouring towns would not merge into one another. f) Urban Sprawl There appeared to be some confusion in some of the responses over what is meant by the term ‘urban sprawl’. The Councils’ would like to clarify that urban sprawl is defined as ‘the uncontrolled expansion of urban areas.’ It is the Councils’ opinion that as the sites are selected and identified for allocation through the Local Plan process, that this is not urban sprawl but planned development. Land is only able to be removed from the Green Belt through a Green Belt and Local Plan review. By identifying and enhancing strong Green Belt boundaries via this process this will prevent urban sprawl from occurring. g) Access to employment Some respondents did not consider that access to employment was adequately covered in The Narrative. The Councils’ consider that access to employment areas in relation to each Area is covered in the HGDS. It should however be noted that due to the efficiency of the highways network around Redditch Town this makes all
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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employment areas readily accessible. The Narrative discusses this issue in the sense that the Town Centre is accessible from all parts of the Town and further, the Town Centre hosts the bus station and the Train station which supports frequent and easy public transport movements (page 49 paras 9.38-9.39) h) Area 8 Some respondents considered the suggestion that Area 8’s capacity equates to just 1,000 homes is a ‘rabbit out of the hat’, given that plan-making to date (including engagement) has reflected an assumed capacity of 2,451 (see HGDS, p 176). The Councils’ do not consider that this is a ‘rabbit out of the hat’ as this information is contained in the Gallaghers /Pegasus Hearing Statement XB1/14 December 2014: “As set out in representations submitted in relation to the Proposed Submission Local Plan stage in November 2013 the proposals have been developed based on a landscape led approach, leading to a revised allocation boundary and a resulting capacity of a minimum of 1000 dwellings with an element of employment generating uses on part of the site”. Officers are unaware of firm evidence from the developers that in excess of 1000 dwellings can be delivered on Area 8. i) Bordesley By-pass It has been suggested in representations that the potential for the development of a by-pass in Bordesley, means that Area 8 should be considered for development over Areas 4 and 6 or Webheath ADR. It is suggested that the bypass would not only remove traffic from Bordesley but would also improve connections between Redditch, the M42 and the North. Indeed the Councils’ acknowledge, in the conclusions of The Narrative (para16.19) that the development of Area 8 has the possible benefit of the provision of the bypass. The Councils’ raise questions about the potential costs and feasibility of the Bordesley Bypass in the SWOT analysis (page148) of The Narrative. Whilst representations on behalf of the developer have stated that Gallagher Estates control the land required to deliver the Bordesley Bypass and can assist with resolving this longstanding highway capacity issue (Jubb - Transport Assessment for a SUE, 2014), there is no evidence as to the potential costs of the project and how it would be funded and delivered. If a contribution is required from the public purse this has not been specified nor has evidence been produced that the likelihood of receiving funding has been assessed. Planning permission for the Bordesley Bypass that was previously in place in 2004 has since lapsed and the Councils are unaware of any evidence that has been prepared for a fresh application, nor is there any indication from Worcestershire County Council (WCC) that permission would now be granted.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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Indeed the Council is not aware of any pre-application discussions about a bypass application. It is for these reasons that the potential for a bypass at Bordesley has not been considered a significant factor in the site selection process. j) Concerns were expressed that the conclusions of White Young Green (WYG 1 and White Young Green2 (WYG2) were not pursued in their entirety and no explanation has been given for this departure. The WYG1 work was not conclusive as it did not define sites, which is why WYG2 was carried out. However these studies were completed within a different context and with different housing numbers. The Narrative attempts to provide a summary of the process followed in eventually deciding on the preferred sites and a summary of WYG 1 and 2 is included in the Early Stages of Plan making section for completeness. The Narrative explains at para 2.21: “…..many of its key conclusions such as the optimum location for growth and the return of ADRs to Green Belt were not expressly rejected by the Panel, as documented in the Panel Report dated September 2009 [CDR 6.6a] (see below). However, some of the research conducted in this Study does remain valid, for example, in relation to Redditch’s open space”. And at para 2.24 “In light of the findings of WYG2 [CDX1.4], that the ADRs at Brockhill, Webheath and the A435 corridor were not considered suitable for development, the Preferred Draft Core Strategy proposed they should be designated as Green Belt. However, the conclusions of WYG2 were not accepted by the Councils after the independent panel of experts who considered the WMRSS Phase 2 review concluded there was a need to make use of the Redditch ADRs”. The HGDS, published in January 2013, whilst using the boundaries demarked by WYG1, reviewed the site selection process afresh partly as the West Midlands Regional Spatial Strategy (WMRSS) was imminently due to be revoked and new evidence, for example, regarding housing figures had been produced (Page 9 para 3.11). k) West Midlands Combined Authority (WMCA) It is considered by some respondents that Bordesley ( Area 8) is the correct area for growth on the basis that as RBC is part of the West Midlands Combined Authority (WMCA). Bordesley (Area 8) is considered the ideal geographical location to build thousands of new houses, because it is closest to new employment sites at Redditch Eastern Gateway. The Councils’ do not consider that the argument in relation to the West Midlands Combined Authority (WMCA) is cogent. In any case BDC is not part of the WMCA and therefore it does not follow that land for development should be allocated in Bromsgrove District in relation to this issue. Even if BDC were part of the WMCA this relates to the whole of the West Midlands not just Birmingham, so to locate development here rather than other areas around Redditch or elsewhere does not follow.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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l) Heritage Issues 1. Norgorve Court Some respondents considered that the Councils should have given greater consideration to the impact of development on Norgrove Court, being only Grade I listed building in Redditch Borough. The Heritage Asset Setting Assessment carried out by Wardell Armstrong [XB1/2t Statement by Heyford Developments and Rockspring Barwood June 2015 Appendix 2] examined the impact of development at Foxlydiate in relation to this heritage asset. This Assessment has been endorsed by Bromsgrove District Council. It states that: 5.3 The proposed development lies approximately 650m to the north of Norgrove Court, on higher ground to the north of Pumphouse Lane. Pumphouse Lane represents the boundary from which land to the north of Norgrove Court can be experienced when viewed from the footpath immediately to the west of building. There is no view of land within the proposed development area from this location or from those further to the north with only views of intervening vegetation possible. 5.4 The proposed development will involve the development of land to the north for residential use. The proposals will involve the construction of residential units to the north of Pumphouse Lane behind open space. This will serve to preserve the skyline from visual intrusion by built development. The application of sensitive detailed masterplanning through the implementation of design codes will ensure that the sense of isolation and tranquillity which contributes to the significance of Norgrove Court and Old Cottage will be maintained. 2. Hewell Grange Estate It was considered by one respondent that one of the failings identified by the Inspector was that an inconsistent approach was taken to assessing the potential impacts on built heritage assets with respect to Areas 4 and 5. It was felt that the additional assessment had done little to address this imbalance. The Council considers that the report evidenced that development on Area 5 had the potential to impact on the Conservation Area (CA) and the Registered Park and Garden (RPG), while Area 4 had the potential to impact on the Water Tower and the Walled Garden specifically, although it is appreciated that they are located in the CA and RPG. Section 4.1 highlights the very short contiguous boundary between Area 4 and the CA and the RPG, which are in addition separated by the A448, a four lane dual carriageway. The topography combined with views from Hewell Lane across Area 5 towards the CA and
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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RPG, results in any proposed development on Area 5 having the potential to impact greatly on the CA and RPG. In light of the topography, short contiguous boundary and intervening four lane highway between Area 4 and the heritage assets at Hewell Grange, it was considered that the only impact would be on the Walled Garden and the Water Tower. The most recent Setting Assessment therefore considered this impact in detail. Therefore in relation to Hewell Grange it was not required to assess all of Area 4 in the same level of detail as Area 5 as explained above as large parts do not impact on the setting of a heritage asset The setting assessment concludes that to minimise harm to these Heritage Assets (Has), development of the top north west corner of Area 4 should be excluded. This is indicated on the Map in the Setting Assessment. 3. Lanehouse Farm There is a comment that BDC appear to intimate that the mitigation to Lanehouse Farm is not simply a means of minimising harm to a designated heritage asset but also a public benefit. It is suggested that BDC have failed to assess the harm and potential mitigation on this listed building. It is the Council’s opinion in light of the Setting Assessment, that a sufficient part of Area 4 has been excluded from the developable area to minimise the harm of development of Area 4 on Lanehouse Farm. In addition, it is also considered that the reinforcing of existing boundaries, planting of hedgerow and native species trees, with considered planning, will also help to screen some development, and minimise the impact on the rural setting of Lanehouse Farm. It is a public benefit that this harm is minimised. m) SA issues 1. Some respondents considered that an SA on the new scenarios detailed in The Narrative should have been carried out. The Narrative explains at page 75 para 9.180: It has not been judged necessary to conduct any further SA work in respect of the individual Areas, as all of the Areas (including the Areas within Redditch Borough, i.e. ADR component of Area 3 (3R), 3A, 7 and 18) were considered in the HGDS and the HGDS Addendum in both the text and the Assessment Matrices. But what the Inspector did request in his Post-Hearings Note of July 2015 was an update to the original scenarios for looking at Areas in combination (paragraph 10c). It is not considered appropriate to look at all possible combinations of the 7 Areas because these are numerous and clearly the Area selection decision is being made on the basis of most suitable Areas to emerge from the selection process. These are Areas 4, 6, 3R and 18. However, the Inspector wanted the scenarios set out in the original HGDS to be updated and this has been done below and four additional scenarios have been examined.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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In identifying new scenarios it should be noted that available capacity within Redditch in the intervening period between January 2013 and December 2015 has increased but that of the 4 new scenarios identified none of the ‘reasonable alternatives’ are able to exclude the Webheath ADR and still provide the required quantum of development. 2. SA of alternative levels of growth for Redditch not carried out. Higher growth levels were explored through the WMRSS and lower growth levels via the Core Strategy process (Redditch Revised Preferred Draft Core Strategy (January/March 2011) [CDR 1.16]) as well as a ‘no plan’ option all of which have been subject to Sustainability Appraisal. RBC consider that all reasonable alternatives were subject to the SA process. 3. Some respondents are critical of the Councils description of the SA process being a ‘simple and rudimentary process’. The Councils’ consider this issue is clearly justified in The Narrative at para 2.63 it states that: The purpose of the SA is therefore as a tool in the site selection process to inform decision making. Decisions made typically consider the results of the SA process but are not driven by it; other higher level policy objectives may take more prominence in decision making as is illustrated above. The SA therefore has some limitations in terms of the final decision making process due in part to it being of necessity based on a simple and rudimentary scoring system in which it is difficult to properly address some planning judgments such as the degree to which an Area is close to the town centre but physically and lacking good connectivity with the urban area (Area 8) and especially the clear need to use land not in the Green Belt which is suitable for development when most land around Redditch is in the Green Belt (Areas 3R and 18). Therefore whilst the SA process is useful it not sophisticated enough for decisions to be based purely on its outcome.
XB1.3 Is it clear how development of the Brockhill Urban Extension (BDP policy RCBD1.1) would relate to the development of the adjoining Brockhill East Strategic Site (BORLP4 policy 46)? Is it intended that cross-boundary co-ordination would take place - for example in respect of infrastructure provision? If so, is this clearly provided for in the two Local Plans? 8. The Councils’ have no further comments to add on this issue in addition to
those made in the previous Hearing Statements. XB1.4 Is the scale and location of the Ravensbank Expansion Site (policy BDP5B) adequately justified? 9. The Councils’ have nothing further to add on this issue to the previous
Hearing Statements.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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9. Other issues
Modifications to the Plans
Schedules of Modifications showing all the wording changes proposed by the Councils’ to BORPL4 and the BDP will be submitted to the Examination before the commencement of the Hearing Sessions on 23rd March 2016.
SA minor suggested changes
The Councils’ have given consideration as to whether the information that is now available (notably the new and revised Setting of Heritage Assets Assessments) requires either the most recent BDP or BORLP4 SAs to be amended. For completeness and accuracy it is considered that some minor changes could be made. The suggested changes to the scoring in the SAs are not sufficient to affect the overall planning judgement made in relation to site selection. For information therefore, the suggested changes to the BDC SA May 2015, the HGDS SA and the BORLP4 SA May 2015 are detailed in Appendix 1.
Five Year Housing Land Supply
The housing supply issue is dealt with in detail in Appendix 2.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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Appendix 1 SA minor suggested changes relating to heritage. OED/34
BDC Sustainability Appraisal May 2015 - suggested update March 2016
Suggested change Where update required
RCBD1
Add:
XIII) To ensure the protection of Heritage Assets,
future proposals should be in conformity with
Policy BDP20 and informed by an understanding
of the setting of Heritage Assets set out in the
most recent Setting Assessment(s) produced, or
formally endorsed, by the Council in accordance
with current Historic England guidance on
setting matters.
Page 126
Add
Setting Assessments have been carried out
whereby it has been concluded that there is ‘less
than substantial harm’ to the setting of Heritage
Assets in relation to Area 4/The Foxlydiate
site/Site 1
Page 127 Key Policy Weaknesses
The Setting Assessment referred to above
requires that development is avoided in certain
parts of Site 1 (Area 4/The Foxlydiate site) to
mitigate the adverse impact of development.
Page 127
Recommendations for Mitigation
OED/33a
Redditch SA (update March 2016)
Current wording/score Suggested change Where update required
Likely effects
There are a number of ways that
the Local Plan aims to improve
the quality of the built
environment, for example
through the redevelopment and
regeneration of the New Town
era District Centres, general
protection for elements of the
historic environment, and design
policies. The protection and
enhancement of the Borough’s
historic assets are ensured
through the Historic Assets policy
in the Local Plan which relates to
the Borough’s local
Likely effects
There are a number of ways that
the Local Plan aims to improve
the quality of the built
environment, for example
through the redevelopment and
regeneration of the New Town
era District Centres, general
protection for elements of the
historic environment, and design
policies. The protection and
enhancement of the Borough’s
heritage assets are ensured
through the Historic Environment
policies in the Local Plan which
relate to the Borough’s local
Page xvii (Likely
Sustainability Effects of the
BORLP4 and their
mitigation)Objective 16
Also on page 35
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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OED/33a
Redditch SA (update March 2016)
Current wording/score Suggested change Where update required
distinctiveness. There are some
clusters of Listed Buildings in a
number of cross boundary
locations although the preferred
locations for development help
to achieve this objective.
distinctiveness. There are some
clusters of Listed Buildings in a
number of cross boundary
locations although the preferred
locations for development help to
achieve this objective. Setting
Assessments have been carried
out whereby it has been
concluded that there is ‘less than
substantial harm’ to the setting of
heritage assets in relation to the
proposed cross boundary
development at Area 4
(Foxlydiate).
Proposed mitigation
None identified
Proposed mitigation
The Local Plan includes policies
on the built environment, design
and the historic environment
which aim to improve the quality
of the built environment while
protecting and enhancing any
heritage assets. The Setting
Assessments referred to in ‘likely
effects’ require that development
is avoided in certain parts of Area
4 (Foxlydiate) to mitigate the
adverse impact of development.
Page xvii (Likely
Sustainability Effects of the
BORLP4 and their
mitigation) Objective 16
Overall Sustainability
Implications
There is one Conservation Area
within the cross boundary
development locations at Beoley
which would be the only location
to have a negative effect on this
criteria. All other options would
have no effect.
Overall Sustainability
Implications
There is one Conservation Area
within the cross boundary
development locations at Hewell
Grange. A Setting Assessment has
been carried out on the Hewell
Grange Estate and it has been
concluded that development in
the preferred locations would
cause ‘less than substantial harm’
to the setting of heritage assets.
Page 83
Appendix B:Overall
Sustainability Implications
(including cumulative
effects) of the Local Plan.
Objective 16, Guide
Question: Will it enhance
the Borough’s Conservation
Areas?
Comments
Brockhill West/Site 5 and Site 11
significantly adversely affect the
Hewell Grange Conservation
Area. Sites 9 and 10 significantly
adversely affect the Beoley
Conservation Area. Site 4 is
partially adjacent to the Hewell
Comments
Brockhill West/Site 5 and Site 11
significantly adversely affect the
Hewell Grange Conservation
Area. Site 4 is partially adjacent to
the Hewell Grange Conservation
Area but its adverse effects with
mitigation are less than that of
Appendix D
Page 234 (Objective 16,
guide question (ii) Will it
enhance the Borough’s
Conservation Areas?
Page 254 (Objective 16,
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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OED/33a
Redditch SA (update March 2016)
Current wording/score Suggested change Where update required
Grange Conservation Area but its
adverse effects are less than that
of Site 5. Conservation areas will
not be affected by the other sites
as they are not within or
adjoining a Conservation Area.
Site 5 and 11. Sites 9 and 10
significantly adversely affect the
Beoley Conservation Area and
Site 13 would have a significant
adverse effect on Sambourne
Conservation Area. Conservation
areas will not be affected by the
other sites as they are not within
or adjoining a Conservation Area.
guide question (ii) Will it
enhance the Borough’s
Conservation Areas?
Scoring
Site 13
Site not in or adjoining
Conservation Area (+2)
Scoring
Site 13
Significant adverse effect on
Conservation Area (-2)
Appendix D
Page 254 (Objective 16,
guide question (ii) Will it
enhance the Borough’s
Conservation Areas?
Comments
Only four sites (3a, 18, Land to
the rear of the Alexandra
Hospital and Woodrow Strategic
Site) have no Listed Buildings on
the sites or adjacent and will
meet this criteria. Brockhill/Site 6
has opportunities to improve
Listed Buildings within the site as
part of the site development. Site
4 has no predicted effect on its
one listed building. Other sites
have numerous Listed Buildings
which may have an adverse
impact. Site 3 includes Redditch’s
only grade 1 Listed property
although mitigation can be
undertaken.
Comments
Only three sites (Brockhill
Strategic Site/Site 6, Land to the
rear of the Alexandra Hospital
and Woodrow Strategic Site)
have no Listed Buildings on the
sites or adjacent and will meet
this criteria. Setting Assessments
have been carried out whereby it
has been concluded that there is
‘less than substantial harm’ to the
setting of heritage assets in
relation to the proposed cross
boundary development at Area 4
(Foxlydiate). Other sites have
numerous Listed Buildings which
may have an adverse impact. Site
3 includes Redditch’s only grade 1
Listed property although
mitigation can be undertaken.
Appendix D
Page 234 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Page 254 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Scoring
Brockhill Strategic Site (Including
Site 6)
Improve or no effect (+2)
Scoring
Brockhill Strategic Site (Including
Site 6)
Site not Listed or adjacent to
Listed Buildings (+2)
Appendix D
Page 234 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Scoring
A435 (Including Site 18)
Site not Listed or adjacent to
Listed Building(s) (+2)
Scoring
A435 (Including Site 18)
Adverse effect with mitigation (-
1)
Appendix D
Page 234 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Scoring Scoring Appendix D
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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OED/33a
Redditch SA (update March 2016)
Current wording/score Suggested change Where update required
Site 3A
Site not Listed or adjacent to
Listed Building(s) (+2)
Site 3A
Adverse effect with mitigation (-
1)
Page 234 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Scoring
Site 4
Improve or no effect (+2)
Scoring
Site 4
Adverse effect with mitigation (-
1)
Appendix D
Page 234 (Objective 16,
guide question (iii) Will it
help to safeguard the
Borough’s Listed Buildings?
Total Score
A435 (Including Site 18)
48
Total Score
A435 (Including Site 18)
45
Appendix D
Page 239
Total Score
Site 3A
19
Total Score
Site 3A
16
Appendix D
Page 239
Total Score
Site 4
37
Total Score
Site 4
34
Appendix D
Page 239
Total Score
Site 13
13
Total Score
Site 13
9
Appendix D
Page 258
CDB 3.1
Housing Growth SA (update March 2016)
Suggested change Where update required
A Setting Assessment has been carried out
entitled “Hewell Grange Estate setting of
Heritage Assets Assessment December 2015” in
which it has been concluded that there is ‘less
than substantial harm’ to the setting of Heritage
Assets.
Page 30 para 4.67
Page 79 para 5.17
Page 82 para 5.31
Page 87 para 5.55 add change and delete
reference to Area 4 in first sentence)
Page 208- E4
Page 215-E4
“the Setting Assessment requires that
development is avoided in certain parts of Area 4
to mitigate the adverse impact of development
of Foxlydiate”.
Page 30 Para 4.70
Page 33 Para 4.86
Page 80 para 5.19
Page 84 para 5.37
Page 88 para 5.60
Area 4 reduced capacity
This paragraph under key strengths should be
deleted and a new paragraph added under ‘key
weaknesses’ at 4.82 to state the same wording
as above at 4.67
Page 32 Para 4.79
It is stated that as there are no listed buildings
within the area and that this is a key strength.
(Although it is noted that there is one Listed
Building close to the area on Cur Lane).
E4- change score to -0.5 Page 92 Table 5 (under column Areas 4 and 6)
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
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Page 201
E4 change score to -1 Page 111
Page 116
Amend sub total score to -2 Page 92 Table 5
Amend grand total score 5.5 Page 92 Table 5
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
18
Appendix 2
Bromsgrove District Plan / Borough of Redditch Local Plan No.4
5 Year Housing Land Supply Topic Paper
4 March 2016
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
19
1. Introduction
1.1 This Topic Paper has been produced in response to the representations on housing matters
which were received during the most recent consultation period. The key issues raised in the
representations have been categorised and will be dealt with in turn in this Paper. The issues
raised affect both the Bromsgrove and Redditch Plans and the responses deal with both
Districts separately. Where the issue relates to only one of the Districts, this has been
articulated within the text.
1.2 The issues raised and addressed in this Paper are:
• Persistent under-delivery and the application of an appropriate buffer
• Lapse Rates and Non-implementation Rates
• Commitments and additional plan flexibility
• Range of commitments and Appropriate lead-in times
• The Five Year Housing Land Supply
1.3 Another issue raised was that of C2 Uses. These are not discussed in detail in this Paper as C2
Uses do not now appear in the five year supply. The Councils could include Extra Care units
in the housing land supply as they are individual residential units, but since both Councils can
demonstrate a five year supply without their inclusion, they have been excluded from the
calculations in this Paper.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
20
2. Persistent under delivery and the application of an appropriate buffer
Introduction
2.1 The issue of persistent under delivery has been raised by respondents to the recent
consultation period. Representations consider that assessing performance against previous
Plan delivery is inappropriate/ irrelevant and that delivery should be tested against the
current housing requirement. Whilst this issue was discussed in detail at previous Hearing
Sessions, both Councils have taken the opportunity to restate their case for the application
of a 5% buffer to the five year housing land supply (5YHLS). This section has been produced
to update the position of both Councils in relation to the Inspector’s original Matter 2
(Housing), and more specifically B2.1(a) and R2.1(a) “Has the Council shown a record of
persistent under-delivery of housing, in the terms of paragraph 47 of the Framework?”, in
light of the publication of updated 5YHLS documents in December 2015 for the purposes of
public consultation. This document responds to comments received during the consultation
period.
2.2 For a number of years it has been necessary for local authorities to maintain a supply of
deliverable sites to ensure that there is a constant supply of new build properties available
to meet identified housing needs. Following the publication of the National Planning Policy
Framework (NPPF) it has become clear that local planning authorities should significantly
boost the supply of housing to address the low levels house building nationally in recent
years. It is considered that increased levels of house building will help to meet unmet need
and demand for both affordable and market housing whilst also stimulating economic
recovery.
2.3 The NPPF (para 47) states that local planning authorities should include an additional buffer
in the 5YHLS figure (moved forward from later in the plan period) to ensure choice and
competition in the market for land. The buffer should be an additional 5%, unless the local
authority had persistently under delivered against its housing target, in which case a 20%
buffer should be added.
2.4 The NPPF provided no further guidance as to how local planning authorities should
determine whether to apply an additional 5% or 20% buffer. However the publication of the
National Planning Practice Guidance (NPPG) in 2014 offered planning practitioners a steer on
this matter. NPPG (ID: 3-035-20140306), states:
“How should local planning authorities deal with past under-supply?
The approach to identifying a record of persistent under delivery of housing involves
questions of judgment for the decision maker in order to determine whether or not a
particular degree of under delivery of housing triggers the requirement to bring forward an
additional supply of housing.
The factors behind persistent under delivery may vary from place to place and, therefore,
there can be no universally applicable test or definition of the term. It is legitimate to
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
21
consider a range of issues, such as the effect of imposed housing moratoriums and the
delivery rate before and after any such moratoriums.
The assessment of a local delivery record is likely to be more robust if a longer term view is
taken, since this is likely to take account of the peaks and troughs of the housing market
cycle…”
2.5 The following sections take NPPG paragraph 35 and apply its steer to underpin the decision to
apply a 5% buffer to the 5YHLS figures for both Bromsgrove District and Redditch Borough.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
22
Appropriate time period for assessing a local delivery record
2.6 NPPG (Para 35) states: “The assessment of a local delivery record is likely to be more robust if
a longer term view is taken, since this is likely to take account of the peaks and troughs of the
housing market cycle.”
2.7 Following its autumn 2014 event on the 5YHLS, the Planning Advisory Service (PAS)
produced some FAQs on its website (http://www.pas.gov.uk/local-planning/-
/journal_content/56/332612/7363780/ARTICLE#16).
Of particular interest is Q14:
14. When does a 5% buffer become 20%? Is it based upon cumulative totals against
the requirement or on a purely annual basis? How far into the past do you go? Is it 5
years, or Plan period, or as far back as possible?
There is no universally applicable test and no consistency about what length of time
should be considered and no exact definition of persistent under-delivery. This is
epitomised by the situation in East Cheshire where 5 different Inspectors applied
different buffers. However, this has now been clarified by the Local Plan Strategy
Inspectors interim views (6 Nov 2014) Inspectors are considering ‘under-delivery'
differently and there are examples of many different approaches. In principle it is about
understanding your track record by comparing your completions against your
requirement over a reasonable time period as evidenced in your AMR. Something is
persistent when it has continued over time. The South Worcestershire Core Strategy
Inspector said that this is a matter of degree and the Judge Lewis in the Cotswold
judgement ([2013] EWHC 3719 (Admin) 27 November 2013) said that ‘it should not be a
‘temporary or short lived fluctuation'.
The Rother Inspector said that despite low levels of completions there had not been
persistent under- delivery. However, in many other cases where delivery has fallen short
on a continuous basis, a 20% buffer is being applied. The Parsons Brinkerhoff housing
supply research for CPRE August 2014 notes that of all appeals for residential
development on greenfield land since the publication of the NPPF two thirds of the time
a 20% buffer has been applied.
While some Inspectors say five years is appropriate in a S78 appeal situation, local plan
inspectors are mindful that a longer period is more appropriate when considering a 15
year plan period. The Practice Guidance recognises that the local delivery record is likely
to be more robust if a longer term view is taken since this has regard to the economic
cycles and market conditions. While the recession should not be used as an excuse for
low delivery, it is suggested that it is useful and appropriate to take a longer term view,
which would probably be at least 10 years.
There are two methods which can be used, either using a straight comparison of annual
rates and measuring the frequency of under delivery over a number of years, or
alternatively considering the cumulative completions. The Inspector in the Broughton
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
23
Appeal in Kettering (APP/L2820/A/13/2204628) agreed with the Council that ‘since 2001
cumulative completions have exceeded the cumulative requirement in all but the last
few years since 2010', agreeing that this was due to the economic recession rather than
a failing by the Council. However the Inspector in the Tetbury appeal rightly recognised
that economic circumstances form no part of national policy under paragraph 47 of the
NPPF.
It is possible to have a 5% buffer and a shortfall and is the circumstance in which both
Kettering and Rother are in. They have been able to successfully argue that their under
delivery is not ‘persistent'. - See more at: http://www.pas.gov.uk/local-planning/-
/journal_content/56/332612/7363780/ARTICLE#16. Do persistent under delivery, and
the 20% trigger relate specifically to delivery against adopted housing targets (even
based on Regional Strategy) or is it appropriate to use the latest household projections,
in advance of submission of a new local plan?
Based on the above Guidance and PAS advice, both Councils have adopted the approach of
considering cumulative completions over a Plan period, which offers a longer term view for
consideration in respect of a local plan .
2.8 The adopted development plan comprises the Councils’ adopted Local Plan, and until their
revocation on 20 May 2013, the Worcestershire County Structure Plan (June 2001) and the
Regional Spatial Strategy for the West Midlands (January 2008). Therefore, it is considered
appropriate to test housing delivery performance against the targets embedded within these
Plans and the timeframes they represent. Assessment across a longer-term Plan period is
considered to offer the longer term view advocated in the NPPG, and is considered to be
representative of the fluctuations within a housing market cycle.
2.9 The Worcestershire County Structure Plan (June 2001) set out housing targets for each
Worcestershire District in the 15 year period between 1996 and 2011. This period runs
consecutively with the current Plan period and presents a strong dataset against which to
assess consistent delivery against the housing requirement. This equated to 3950 dwellings
and 4504 dwellings for Bromsgrove District and Redditch Borough respectively.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
77
Bromsgrove 5YHLS – Sites with Resolution to Grant Planning Permission, subject to Section 106 Legal Agreement at 1st
March 2016
Status App Type App No Address Settlement Description Gross units Net units C2 Use? Comment
Application
Subject to
S.106 REM 15/0996
Land At Norton
Farm, Birmingham
Road, Bromsgrove, Bromsgrove
Reserved Matters Application
including appearance, landscaping,
layout and scale, following outline
planning approval ref. no. 12/0709.
Residential development comprising
316 dwellings 316 316 No
New for 1st
March 2016
5YHLS
calculation. This
is a reserved
matters
application
submitted on
20/11/2015 that
supersedes the
outline app
12/0709.
Application
Subject to
S.106 OUT 14/0408
Land Rear Algoa
House, Western
Road, Hagley,
Worcestershire Hagley
Residential development comprising
the erection of 26 dwellings. 26 26 No
Included in 1st
Nov 2015 and
1st March 2016
5YHLS
calculations.
Application
Subject to
S.106 FUL 14/0821
Land at Recreation
Road, Bromsgrove,
B61 8DT Catshill
Demolition of existing structures and
the erection of 81 bed care home and
66 bed extra-care apartments for
older persons and 26 affordable
apartments for older persons, with
supporting facilities, parking and
access 173 26
Yes
(Extra
Care =
37 units
but not
included
in
5YHLS)
Included in 1st
Nov 2015 and
1st March 2016
5YHLS
calculations.
Totals: 515 368
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
78
Bromsgrove 5YHLS – Deliverable SHLAA Sites (10+ units) included within 5 Year Land Supply at 1st
November 2015
SHLAA Ref Site Location Site Status at 1st
Nov 2015 Nov 15 –
Mar 16 (5
months)
2016-17 2017-18 2018-19 2019-
20
Apr 20 – Oct
20
(7 months)
Total
with 5
years
Total
site
capacity
BDC20 Perryfields Road, Bromsgrove
(Market and Affordable)
• BDP Allocation site BROM2
• Detailed pre-application discussions held
• Outline Application due to be submitted
January 2016
• Indicative Master plan submitted as part
of BDP Examination, details phasing
(1300 housing units SoCG5)
• Taylor Wimpey BDP Examination
Submission/Letter validates build out
rates6
0 0 40 210 325 162 737 1300
BDC80 Whitford Road, Bromsgrove • BDP Allocation site BROM3
• 13/0479 OUT for 490 units refused by
Planning Committee on highways
grounds on 14.08.2014
• Appeal lodged to PINS on 08.10.2014
(APP/P1805/A/14/2225584).
• Reserved Matters discussions had
previously commenced
• Site pushed back by 5YHLS to reflect
recent refusal and appeal . No. of units
within 5YHLS reduced accordingly.
0 0 50 120 120 70 360 490
BDC95 Rear of 50, 52 & 54 Red Lion • Site being progressed to planning 0 0 0 0 10 0 10 10
5 BDC Core Document CDB14.7 Statement of Common Ground between BDC and Taylor Wimpey (November 2014)
6 BDP Examination Statement by Savills on behalf of Taylor Wimpey – Taylor Wimpey UK Delivery Rates letter (4 March 2016) – see letter shown at the end
of this hearing statement.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
79
SHLAA Ref Site Location Site Status at 1st
Nov 2015 Nov 15 –
Mar 16 (5
months)
2016-17 2017-18 2018-19 2019-
20
Apr 20 – Oct
20
(7 months)
Total
with 5
years
Total
site
capacity
Street, Alvechurch application following SHLAA submission.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
80
Bromsgrove 5YHLS – Deliverable SHLAA Sites (10+ units) included within 5 Year Land Supply at 1st
March 2016
SHLAA Ref Site Location Site Status at 1st
March 2016 Mar 16 –
Apr 16 (1
month)
2016-17 2017-18 2018-19 2019-
20
Apr 20 –
Mar 21
(11 months)
Total
with 5
years
Total
site
capacity
BDC20 Perryfields Road, Bromsgrove
(Market and Affordable)
• BDP Allocation site BROM2
• Detailed pre-application discussions held
• Outline Application due to be submitted
January 2016
• Indicative Master plan submitted as part
of BDP Examination, details phasing
(1300 housing units (see SoCG7)
• Taylor Wimpey BDP Examination
Submission/Letter validates build out
rates8
0 0 40 210 325 247 822 1300
BDC80 Whitford Road, Bromsgrove • BDP Allocation site BROM3
• 13/0479 OUT for 490 units refused by
Planning Committee on highways
grounds on 14.08.2014
• Appeal lodged to PINS on 08.10.2014
(APP/P1805/A/14/2225584).
• Reserved Matters discussions had
previously commenced
• Site pushed back by 5YHLS to reflect
recent refusal and appeal . No. of units
within 5YHLS reduced accordingly.
0 0 50 120 120 110 400 490
BDC95 Rear of 50, 52 & 54 Red Lion • Site being progressed to planning 0 0 0 0 10 0 10 10
7 BDC Core Document CDB14.7 Statement of Common Ground between BDC and Taylor Wimpey (November 2014)
8 BDP Examination Statement by Savills on behalf of Taylor Wimpey – Taylor Wimpey UK Delivery Rates letter (4 March 2016) – see letter shown at the end
of this hearing statement.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, issues and Questions
81
SHLAA Ref Site Location Site Status at 1st
March 2016 Mar 16 –
Apr 16 (1
month)
2016-17 2017-18 2018-19 2019-
20
Apr 20 –
Mar 21
(11 months)
Total
with 5
years
Total
site
capacity
Street, Alvechurch application following SHLAA submission.
14/336 Adj. St Georges Court, Winyates Way 2 2 0 B
14/367 Adj. 55 Weatheroak Close, Webheath 1 1 0 G
14/371 171 Mount Pleasant, Southcrest 1 1 0 B
14/1515 5 Mount Pleasant, Southcrest 1 1 0 B
15/012 70 Maisemore Close, Church Hill North 1 1 0 B
15/049 78 Ash Tree Road, Batchley 1 1 0 B
15/056 Grand View, Sambourne Lane, AB 1 0 1 G
15/065 British Mills, Prospect Hill 1 1 0 B
15/086 Adj. Carantac, The Mayfields, Southcrest 1 1 0 G
15/097 RO 173 Mount Pleasant, Southcrest 1 1 0 B
15/108 42 Dagtail Lane, Astwood Bank 1 1 0 G
15/119 RO 52 Bromsgrove Road 2 2 0 G
15/123 10 Market Place 1 1 0 B
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
4
15/131 Field House, Feckenham Road, Hunt End 1 0 1 G
15/133 Adj. Grand View, Sambourne Lane, AB 1 0 1 G
SUB TOTAL 51 36 15
No. Site Name Capacity for Completions at
1.3.2016
Not Started Under Construction
Brownfield/ Greenfield
15/137 RO 123-127 The Meadway, Headless Cross 4 4 0 G
15/167 27 Cranham Close 1 1 0 G
15/178 Adj. 17 Crumpfields Lane, Webheath 1 1 0 G
15/196 Black Horse PH, 7-9 Mt Pleasant 2 2 0 B
15/261 Victoria House, Feckenham Road, AB 4 4 0 B
15/274 Adj. 35 Hazel Road, Batchley 1 1 0 G
15/280 Papermill Barn, Brooklands Lane 1 1 0 G
15/288 Green Acres, Crofts Lane 1 0 1 G
15/294 Adj. 10 Foxlydiate Crescent, Batchley 1 1 0 B
15/302 Above Simply Local, Dilwyn Close 1 1 0 B
15/324 Adj. Doebank House, Astwood Bank 1 1 0 G
15/361 51 Mount Pleasant, Southcrest 1 1 0 B
16/009 Vauns Oaks, 13 Icknield Street 2 2 0 G
TOTAL 72 56 16
∆ Application pending Grey highlight = new commitments since 1 November 2015
Small site commitments = 72 dwellings
Small Site Windfall Allowance
Small site windfall allowance on sites less than 5 dwellings = 32 dwellings
Cross Boundary contributions
No. Site Name Capacity for
Completions (2016-21)
Brownfield/ Greenfield
Not Started
Under Construction
Site 1 Foxlydiate 671 G 671 0
TOTAL 671 671 0
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
5
Delivery Schedule
Site Nov 15/16 2016/17 2017/18 2018/19 2019/20 1 Mar 21
Mayfields Works 5 18
Castleditch Lane/ Pheasant Lane 0 0 5 11
Land at Millfields, adjacent the Fire Station 0 0 0 30
South of Scout Hut 21
Former Dingleside Middle School 15 51 0 20
Loxley Close 0 0 0 10
Clifton Close 0 0 0 6
Prospect Hill 14 0 14 43
RO Alexandra Hospital 0 0 45 50 50
A435 ADR 0 0 0 30 50 46
Brockhill East (ADR) 0 16 65 65 65 60
Brockhill East (Weights Lane) 0 38 45 45 45 25
Webheath ADR 0 20 75 75 75 65
Land adjacent to Sandycroft 0 0 6
Birchfield Road (GB) 6 12 11
Former Hewell Road swimming baths 0 30
RO Windsor Road Gas Works 0 10 34
Studley Road/ Green Lane 0 4 6
Park House 0 6 8
The Elms 7
Conwil, Dagnell End Lane 0 0 6
Former ambulance station, Cedar Park Road 0 14
Former Jolly Farmer PH, Woodrow 0 4 10
Former Youth Centre, Ipsley Street 0 0 10
St Stephens House, Town Centre 0 54
Oak House, Herbert Street 0 9
Adj. Lower Tookey’s Farm, Astwood Bank 0 0 1
Threadneedle House 0 46
Land at Moons Moat Drive 0 4 10
The Paddocks 0 0 6
Suntrap, Edgioak Lane 2
Headless Cross Methodist Church 0 2 7
Former night club, Church Road 0 27
White Lion PH, Astwood Bank 0 7
132 Oakly Road 4 5
Ludlow Road 0 6
Springfield Farm 0 1
Millsborough House 0 14
Ashleigh Works, Bromsgrove Rd 0 5 5
Redditch Trades & Labour Club 0 14 14
Paper Mill Drive, Church Hill South 0 0 20 16
Wirehill Drive 0 4 8
3 Plymouth Road 0 0 6
Ipsley Court, Berrington Close 0 5
20 Bromsgrove Road 0 3
5 Alcester Street 4
1240 Evesham Road, Astwood Bank 0 10
Church Hill Medical Centre 0 0 16
Clive Road/ Prospect Hill 0 0 10 30
Millsborough House Ph2 0 0 15 15 10
Matchborough District Centre 0 0 0 35 35
Winyates District Centre 0 0 0 5 30
Former Holyoaks Field First School 0 0 0 0 20
Merry Oak Farm, Moors Lane 0 0 1
XBDY - Site 1 Foxlydiate 0 0 83 169 209 210
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
6
Sub Total 78 439 542 655 589 406
Small site completions (windfalls) 18 25 23 17 11 10
Total 96 464 565 672 600 416
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
7
Dear Sir / Madam RE: Bromsgrove and Redditch Local Plans - Examination in Public Further to my letter of 16 February, I am pleased to provide an update on the proposed phasing and delivery rates for the Perryfields site. As noted in our previous correspondence, the site is in the control of Taylor Wimpey, a major national house builder with an established track record in the delivery of large scale, high quality residential developments across the country. Extensive pre-application discussions on Taylor Wimpey’s outline application proposals for Perryfields have taken place to date and we continue to be in regular discussions with the District Council. All of the relevant technical and environmental issues have considered in detail with the planning authority and engagement has been underway with the relevant consultees. The phasing and delivery rates set out below reflect Taylor Wimpey’s latest forecasts based on feasibility studies and financial modelling that have been undertaken prior to the submission of the planning application. The phasing and delivery rates will be included in the planning application for Perryfields, which has been prepared and is awaiting final sign-off prior to submission to Bromsgrove District Council. We anticipate the application will be submitted later this month. The phasing strategy for the development proposes 6 phases for bringing development forward over an 8 to 10 year period. The development strategy is coordinated with the provision of open space, infrastructure and local facilities, alongside land ownership considerations. The table below illustrates the potential timing of each phase. It is envisaged that there will be some overlap between the completion of each phase and the start of the next phase. Perryfields Phasing
Phase Construction Period
Residential Dwelling Construction (Circa.)
Phase 1 2016 – 2020 425
Phase 2 2018 – 2020 225
Phase 3 2019 – 2019 40
4 March 2016 Lt BDC Perryfields delivery rates 04.03.16
Bromsgrove and Redditch Planning Policy Teams Town Hall Walter Stranz Square Redditch B98 8AH By email only
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
8
Phase 4 2019 – 2022 300
Phase 5 2021 – 2022 160
Phase 6 2022 – 2024 150
TOTAL 2016 – 2024 1300
A plan showing the proposed phasing for the site is attached to this letter. The phasing is described as follows: PHASE 1 (2016 - 2020) The first phase of development will be in the south. This will be linked to the delivery of the new roundabout junction from Kidderminster Road and the closure of the Perryfields Road/ Kidderminster Road junction. Circa. 425 residential units will be provided alongside the connecting spine road between the roundabout and Perryfields Road. The mixed use area located in this phase will be made available to the market. Green infrastructure will be delivered concurrently with each phase, in line with the Green Infrastructure delivery plan. It is also envisaged that during the later stages of this phase the new junction from Stourbridge Road to the north of the site will be commenced and a spine road spur provided in order to support the delivery of dwellings in Phase 2. PHASE 2 (2018 - 2020) Using the new Stourbridge Road junction to the north of the Site, circa 225 dwellings will be delivered. Works to the Battlefield Brook, landscape enhancements and preparation works for the recreation ground will be underway during this phase. The recreation ground will be completed or available for use by the completion of phase 3, at which time the proposed sports pavilion and pedestrian link from King George’s recreation ground should be available for use. PHASE 3 (2019 - 2019) This phase is relatively small when compared with other phases. This phase will deliver circa. 40 residential dwellings, alongside the provision of the sports pavilion and the formal park component of the wider open space and parkland provision. On completion of the pavilion and formal park including pedestrian links from the King George recreation ground, the parkland will be open to public use. This phase also delivers the remaining section of the new spine road link and enables all of the proposed alterations to Perryfields Road to be completed. PHASE 4 (2019 - 2022) Located centrally within the site; served directly from the existing Perryfields Road; and within the ownership/ control of one land owner, the County Council, this phase of development is likely to overlap with other phases of development. Circa 300 dwellings will be delivered in this phase, alongside strategic open space components.
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions
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This phase is self-sufficient in terms of surface water drainage and connections to outfalls. Informal landscape elements will be included with this phase of development. The existing SUSTRANs route, and PROW/ Bridleways will remain operational, although temporary diversions may be necessary to facilitate safe development or enhancements to the routes. PHASE 5 (2021 - 2022) Phase 5 is located to the west of the Perryfields Road and situated on the proposed spine road route. This phase comprises additional mixed uses which are intended to accommodate the local centre and extra care facilities. These are to be co-located with the existing Sidemoor First School to create and support a viable local centre. In addition further employment land will be made available to the market during this phase. The local centre will be advanced and expanded in this phase as a critical mass of new population will be in place to support the operation and therefore success of the local centre. In addition to the mixed uses, circa 160 dwellings will be delivered. PHASE 6 (2022 - 2024) Phase 6 is the final phase of development, delivering the remaining components of the scheme which includes circa 150 dwellings. I trust this information is of assistance in progressing the Local Plan. Please do not hesitate to contact me should you have any queries. Yours sincerely
Tim Hoskinson
Associate Director Encl Perryfields Phasing Plan
Bromsgrove District Council and Redditch Borough Council Response to the Inspector’s Matters, Issues and Questions