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Emma Newfield

From:Sent: 08 February 2016 20:19To: Consult PlanningSubject: Comment on BORLP4 NarrativeAttachments: Comment on BORLP4 Narrative.docx

Dear Sir/Madam,   I intended to print and post my comments but that has proved impossible owing to printer malfunction. I hope this attachment is not too big to send.   Yours sincerely,   E.Morris (Ms)   

 

Comment on BORLP4 Narrative 1 Ms E. Morris February 8th 2016

P4 1.3 /p.96 16.1 I acknowledge amount of work by RBC but for non-specialist residents, the process has been repetitive , time-consuming and worrying, compounded by a lack of clarity , e.g. p.9 2.21=? P.15 2.63=? p.66 9.132=? p.75 exiting= existing? P91,no.2=?

P7 Did WYG report say to use ADR now? They said ‘future’ (beyond 2026)

P12 2.40 Gives the idea of ‘fait accompli’

P30-31 6.15 Biodiversity evidence not mentioned!! Details of effective mitigation needed.

P41/94 heritage assets: no mention of Norgrove Ct. Walkers/riders/cyclists can see it as they pass (see photo ); not applicable to Hewell Grange See also p.59

National Trail Monarch’s Way /rear of Norgrove Ct. (L of hedge)

Path passes front of house

New information: Upper Norgrove House, Church Rd, demolished Jan 2016

Comment on BORLP4 Narrative 2

P47 9.28 ‘’ Equestrian use of ADR land but only for grazing’’. Inaccurate. Riding lessons take place and a caravan may still be there, but ‘’change of land use’’ enforcement /monitoring insufficient.

P49 Access to Shopmobility (in centre) important. Flat walking is also important (e.g. Pumphouse Lane). Buses are not ‘readily accessible’ from outer Webheath : long walk to Downsell Rd .

P51 9.49, 9.52 Will ‘planned package of transport measures’ ever materialise?

P57-58 9.83 9.87 ’’explore opportunities…’’ is weak idea when historic landscape is under threat of destruction.

P59 Area 3 has 5 listed buildings.3 are easily seen by walkers/cyclists/riders.

P 60 9.96 Setting assessment Is the ‘’evidence ’’ merely desktop or from real field study?

Heyford Developments and Rockspring Barwood Limited Setting study Wardell Armstrong #4.27 (Norgrove Court)

The rural character and context of the surrounding landscape contribute significantly to its heritage significance with the almost complete absence of modern visual intrusion giving it a sense of tranquillity and remoteness

16.15: Monarch’s Way R to L needs its natural setting , not ‘enhancement’

Comment on BORLP4 Narrative 3

Setting of Norgrove Ct. contd

Monarch’s Way R to L from Crumpfields Lane (1st floor view)

Norgrove in centre

Norgrove Court (in dip, centre)visible to walkers/riders from Bridle Path P61/64 9.104-9.106 weak language re mitigation/surveys etc E.g. p66 9.134 Importance/enjoyment of Monarch’s Way & its setting minimised

Deleted:

Deleted: ¶

Comment on BORLP4 Narrative 4

P68 Not all people have cars to reach surgeries.

P71 9.160 Possible effects on Bow Brook water quality?

P. 74 9.175 (ADR) heritage impact mentioned but not Norgrove Court. Idea of fait accompli as on P12 2.4 ?

P.74 9.175-176 Objectors’ main concerns dismissed as ‘not major determining factors in site selection’

p.74 9.175 / p.97 16.6 Concept of ‘Improvements’ for existing communities is laughable! Demonstrates a lack of common sense/ignores residents’ local knowledge.

P.77 9.189 But Webheath ADR was previously Green belt and important as such for the area.

p.94 para 3 2013 A448 Bromsgrove Highway Housing Development ...on Hewell Grange and many more old buildings/structures does state high level of harm. See table 2

www.hwa.uk.com/.../Appendix-20-Archaeology-Desk-Based-Assessment...

pp.96-7 16.1 Disagree. Again, smacks of ‘fait accompli’.

16.3-16.7 points made by objectors disregarded.

16.5 heritage: Norgrove Court, grade I, setting accessible on foot/by cycle etc given less prominence than grade II Hewell Grange, which I and many others have never seen.

16.14 ‘Opportunities’ will not necessarily materialise.

16.15 Details of mitigation/how to ‘enhance’ the GI network including Monarch’s Way??

16.16 Webheath ADR not ‘suitable’ merely because removed from green Belt.

Access to full schools? Town centre visits require cars. “No environmental constraints’’ underestimates value to wildlife of grassland for foraging/shelter etc. What exactly would ‘mitigation of heritage issues’ entail? The land itself may hold items of archaeological value. PROWs are popular Bridle Path (ancient Greenway with bluebell) and Monarch’s Way, part of 615-mile National Trail.

16.18…’great weight to be attached to heritage assets….outweighed the public benefits…’ Of what? Again, Hewell Grange is given due importance but is inaccessible to the public, so is it an ‘asset’?

16.19 Surely improvements for walking/cycling would cost less than new roads/junctions?

16.20 WMCA membership pending. Will regenerate area near no.8,so create new jobs. Any community created would not be more isolated than Webheath/Foxlydiate. Planting trees/hedges could create a Green Belt boundary!

16.22 ‘’Evidence is proportionate’’…to what? Much of it is desk-based, by people who are unfamiliar with the area.

Comment on BORLP4 Narrative 5

Appendices

p.112 Sept 2009 ‘’universally recognised that Redditch has limited capacity’’…This is common sense.

‘…would have favoured development between Redditch and Studley on landscape and character grounds alone’’.

Crumpfields Lane/Norgrove Lane Tree on ADR land

p.113 2010 …’produce robust evidence’…again, not just desk-top. Residents’ views / evidence important.

SWOT Analysis

Hardly any ‘threats’ (to infrastructure, biodiversity, etc) mentioned

‘Opportunities’ are just that: but how many will ever be taken? Cannot be given much weight.

p.134 many weaknesses, several threats.

Pp.135-137 How can natural settings of the G.I. network (trees/hedges)be ‘enhanced’ by development which includes removal of some of these?

‘Strengths’ lack common sense or are inaccurate (yes, schools are near, but full)

No ‘threats’ to ADR land? Grasslands destroyed, no habitat for associated fauna/flora, historic area obliterated?

Pp 138-139 many weaknesses ; few threats. New roads ‘threaten’ in many ways: noise, pollution, loss of habitat, danger to animals.

Pp 139-140 Hewell Grange is of similar importance to Norgrove Court, but far less accessible to public view (walking/riding/cycling)

P 143 Area 8’s proximity to more sustainable sewerage system is a big ‘strength’.

E. Morris (Ms) 8th February 2016 94, Crumpfields Lane, Webheath, Redditch B97 5PW

1

Emma Newfield

From:Sent: 12 February 2016 18:06To: Consult PlanningCc:Subject: Additional comments on Narrative on the Site Selection ProcessAttachments: Worcs wildlife 21.docx

12th February 2016   Dear Sir/Madam,   Please find attached my second comment. I would appreciate knowing whether the first one also arrived.   Yours faithfully,   Ms E.Morris     

 

Ms E.Morris    February 12th 2016 

Comments on aspects of  Narrative on the Site Selection process for the Growth Areas at Redditch 

Pp 56‐57, 63‐67  and  SWOT analysis pp 134‐138 

I do not believe sufficient depth of investigation has been given to the biodiversity issues arising 

from the use of green field sites in the Foxlydiate and Webheath areas(3, 3A,4). I attach below some 

WWT material concerning the loss of grasslands and associated species in Worcestershire, and the 

recommendations for the Webheath ADR Pumphouse Lane site made by the former Senior Open 

Spaces officer , Susan Cooper, Bromsgrove. 

      

                                             Fields near the Greenway/Bridle Path 

Source: Worcs Wildlife 21.5.13 Decline in species

Worcestershire is home to a fifth of the remaining lowland meadows in England and our county’s most threatened habitat is heathland. The national trend for these two habitats combined is a 65% decline of species associated with them.

“It’s not just in the wider countryside that we’re seeing changes. Urban wildlife is declining too – invertebrates are doing poorly as we pave over gardens and ‘deck’ our lawns but it’s the once ubiquitous hedgehog that’s really suffering.“These spiny mammals were once regular visitors to our gardens but as we’ve tidied our gardens and fenced ourselves in there’s nowhere for these gardener’s friends to find food.

Grasslands 2014

A dramatic decline in our remaining wildlife-rich grasslands is highlighted by Worcestershire Wildlife Trust today. The county’s largest conservation charity is reporting that information collated from across the UK tell a story of devastating losses.

Worcestershire is home to approximately 20% of England’s remaining lowland meadows so has an important role to play in their survival. Wildlife-rich grasslands provide great benefits to society and are a vital resource – for bees and other pollinators, for securing soils and enabling landscapes to hold and filter water to help prevent flooding and pollution, and for the abundance of wildlife that depends on wild grasses and flowers – from bees and butterflies to barn owls and bats.

These beautiful and valuable habitats are vanishing and the dazzling array of species that depend on them is under threat.

Colin Raven, Director of Worcestershire Wildlife Trust, explained “Wildlife-rich grasslands have been in trouble for decades but the information that has been recently collated from around the UK shows that the remaining hay meadows and flower-rich pastures are still at risk.

“We’re seeing an insidious and catastrophic decline. The pressures are enormous – from development and changes in agricultural practices to neglect.

“The Government is currently making decisions on how it will implement the greening measures of the Common Agricultural Policy and how it will target grants to farmers in the future. Worcestershire is joining England’s other Wildlife Trusts to call on Ministers to take full account of the value of our remaining wildlife-rich grasslands and the threats they face as they make these decisions.”

Loss of Worcestershire Grassland

Source: Worcs Wildlife Trust

Though the open-field ridge & furrow strips persisted until as late as the 16th century, it was largely through wide-scale events such as the de-population of the countryside during the Black Death and the rise of the wool trade that many of the ridge & furrow fields converted to grassland and the semi-natural and species-rich pasture and meadow swards that we still see today developed. In fact, some of the surviving hay meadows in the Severn-Avon Vales and Forest of Feckenham may have an almost unbroken history of several hundred years.

Traditional grasslands are important wildlife habitats, not just for their diversity of plants but also for their invertebrate, fungal and microbial diversity. They have considerable cultural importance and are more aesthetically pleasing than modern agricultural leys, adding colour and visual diversity to the landscape and contributing to the unique character of our countryside.

Losses continued unabated throughout the 1980s and 1990s. In Worcestershire an estimated 45% of remaining semi-natural grasslands were damaged and 30% completely destroyed between 1975 and 2000, leaving only 25% of remaining unimproved grasslands intact.

Conditions (to building on Webheath ADR Pumphouse Lane site)

Source: Ecological Appraisal Susan Cooper Senior Open Spaces officer Bromsgrove

In addition to the long term impacts resulting from the changes in land use and management, the construction activities themselves have potential to impact protected species if works are not suitably controlled or carried out in an appropriate manner. I have recommended that the Developer is required to sign a legal agreement to ensure that the details of the development and the way in which construction takes place does not damage.

The Legal Agreement should contain the following conditions:

1. Before any works start the Developer will need to agree; A Landscape and Ecological Design plan which includes the following;

1. Creation of native species rich grassland in public open space within development using seed of local provenance

2. Creation of wildlife habitat in and around attenuation ponds using plants and seeds of local provenance

3. Retention of woodland area

4. Retention of hedgerow and hedgerow trees, gapping up and creation of replacement hedgerows along the frontage to Church Road using native species of local provenance

5. Retention of ditches and streams 6. Retention of dead wood in situ unless it is necessary to fell for health and safety

reasons, where dead wood will be left as close as possible on site. 7. Retention of tall ruderal and scrub areas and badger sett 8. Enhancement of opportunities for wildlife e.g. bird and bat boxes, log pile refugia. 9. Public paths with open space including details of materials and construction and

signage. 10. Design of fencing to restrict access to attenuation ponds

a) A Construction Ecological Management Plan which includes;

1. A Timetable for site clearance and groundworks. 2. Method statements are required to be included for the following activities;

a. Protection of streams and ditches and measures to prevent sediment or materials hazardous to wildlife entering ditches and brooks

b. Protection of hedgerows and trees and woodland c. Protection of outlying badger sett and buffer area d. Building demolition – to protect nesting birds and bats e. Soil handling, movement and management to include the retention of topsoil

from fields F8 and F9 for use in reinstating species rich grassland around water attenuation areas and hedgerow margins.

f. Control of Himalayan Balsam and Spear Thistle to prevent spread to species rich grassland and amenity grassland.

b) A Drainage and flood attenuation scheme designed in detail in consultation with an experienced ecologist and incorporating features for protected species.

c) A lighting design scheme to be submitted designed in consultation with an experienced ecologist which prevents disturbance to bats.

d) A Landscape and Ecological Management Plan to initially cover management for 5 years following completion of the development and how this will be delivered. The plan to be reviewed and updated every 5 years and resubmitted to the LPA for approval. The plan should cover management of public landscape areas for recreation, amenity and biodiversity and also include plans to promote the biodiversity value of habitat in private space. Detailed prescriptions are required to cover

1. Management of grassland to establish and maintain species rich sward 2. Management of woodland area and hedgerows and dead wood 3. Management of attenuation areas and balancing pond 4. Management of stream and ditches 5. Promotion of the biodiversity value of habitat retained and developed 6. Monitoring and ongoing survey of biodiversity on the site and in the locality to

demonstrate effectiveness of mitigation and enhancements.

The Developer should also be required to agree to the following conditions:

1. No removal of hedgerows, trees or shrubs or demolition of buildings or structures that may be used by breeding birds shall take place between 1st March and 31st August inclusive, unless a recent survey has been undertaken by a competent ecologist to check for the presence of roosts and details of measures to protect the nesting bird interest on the site, have first been submitted to and approved in writing by the local planning authority and then implemented as approved.

2. No removal of trees or demolition of buildings or structures that may be used by bats shall take place unless a recent tree climbing/building survey has been undertaken by a competent ecologist to check for presence of roosts and results have been submitted to and approved by the LPA.

4. No ground works or vegetation removal shall take place unless a recent badger survey has been undertaken by a competent ecologist to assess badger activity on the site and adjoining areas and results submitted to and approved by the LPA.

5. No site clearance, demolition or construction works shall take place which are likely to result in an offence under Regulation 41 of the Habitat and Species Regulations 2010 against a protected species unless a licence to affect the protected species has been granted by Natural England a copy submitted to the local planning authority.

6. An ecological Clerk of Works to be appointed during site clearance and groundworks

7. Site operatives are to receive training to enable them to identify protected species, be familiar with biodiversity method statements and implement these correctly, and know how to deal with situations where protected species are encountered.

8. If development has not started by May 2014 then full ecological survey of the site and buildings will be required to be submitted and approved prior to works beginning. 9. If development has not started by March 2014 then a Great Crested New survey will be required to be submitted and approved before works begin As it is now mid-February, 2016, I believe accurate repeat surveys (for the Pumphouse Lane site) should have been mentioned in the Narrative and that far more weight should be given to Biodiversity matters in the document and process as a whole.

Historic grassland

Elizabeth Morris 94,Crumpfields Lane Redditch 12.2.2016