Comment

Representation ID: 170

Received: 21/12/2023

Respondent: Dr Kevin James

I welcome policy DLP54 especially paragraph's 2a and 2b. The Stourbridge / Wollescote / Cradley area had numerous streams, including the following tributaries of the river Stour: • Mouse Sweet Brook • Ravensitch • Audnam Brook • Wordsley Brook • Coalbourne Brook • Dividale / Covern Brook • Withibrook (and its numerous tributaries) • Catherwell Brook • Swinford Brook • Shepherd's Brook, and its tributaries, i.e. Ludgbridge Brook and Kowback (more properly Robache)[1] • Salt Brook (and its two tributaries) • Lutley Gutter

Although many of these watercourses were of historic importance — e.g. demarcating administrative and property boundaries, determining the locations of roads, tracks, fords and mills — most of them are now almost entirely culverted and forgotten. Re-exposing at least some of these watercourses would, with appropriate landscaping and protection, enhance the human environment, afford opportunities for recreation, and provide much needed wildlife habitats / corridors.

REFERENCES 1. K. James, The Kowback: Stourbridge's Misplaced Brook (2016)

Object

Representation ID: 456

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP54 River Stour and its Tributaries
Policy DLP54 puts in place a series of criteria that the local authority expect applicants to comply with an preparing proposals for development within the vicinity of the River Stour.
These relate to ecological matters, green infrastructure provision and general riverside improvements. These works all have the potential for significant development costs. In such circumstances a balance will need to be struck between the provision of these infrastructure requirements and more general infrastructure requirements to ensure schemes remain viable.
This should be recognised in the policy. Part C of the policy makes reference to the need to provide a green infrastructure corridor of at least 10 metres in width from each riverbank top, unless it can be satisfactorily demonstrated to be unfeasible or unviable or in conflict with the Local Plan polices. Whilst there is some flexibility with this standard it is not clear where the 10 metre stand off distance is derived from. The plan making process should be evidence base driven. We are not aware of any evidence to support a 10 metre stand off.
Part D of the policy makes reference to development proposals contributing towards making existing river bridges structurally sound and potentially the delivery ofr new river bridges. We have a number of concerns with this proposal. Firstly, not all river bridges are in the ownership of the Council or an applicant. Where bridges are owned by a third party it is in their gift whether they will allow for them to be repaired, upgraded or public access secured. This should be acknowledged in the policy. In addition, in terms of the provision of new river crossings this has the potential to be extremely expensive. It will also be necessary for land to be controlled on either side of the river to create such a crossing, and for appropriate onward connections from the crossing points. We are concerned that this is not realistic, achievable and will make developments unviable.

Paragraph 3.12 – Bridge provision
Paragraph 3.12 makes reference developments within areas such as Bradley Road East and Bradley Road West incorporate the development of new bridges to provide access to the surrounding areas and to provide connections to residents on both sides of the canal. We fundamentally disagree with this suggestion. Firstly, it has not been viability tested and significant infrastructure requirements such as the provision of new bridges cannot be included
in the plan unless it is demonstrated that they are financially viable.

Secondly, bridge connections may not be deliverable. In order for a bridge connection to be provided land either side of the river or canal must be in either the control of the applicant or the developer and agreement is needed to cross the watercourse itself. There are no evidence based documents accompanying the Plan to demonstrate that this is a deliverable policy aspiration.

Thirdly, we are not aware of any evidence base documents that demonstrate that there is a
need for such additional bridge crossings to deliver sustainable modes of transport. These provisions are entirely unfounded and without evidence.

Comment

Representation ID: 602

Received: 18/01/2024

Respondent: Environment Agency

We support the requirements in this policy, particularly, sections 2a b and c (restoration of riverbank habitat, of in-channel habitat including removal of culverts, improving the water quality of discharges, and retaining or creating at least 10 metres Green Infrastructure either side of the Stour and its tributaries).

We would like to see the ‘removal of weirs’ including within this policy as part of 2b. Weirs within rivers are often no longer needed and their removal would greatly improve ecological connectivity.

Support

Representation ID: 667

Received: 22/12/2023

Respondent: Natural England

NE welcomes the inclusion of this policy

Comment

Representation ID: 754

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests that section 1 of Policy DLP54 River Stour and its Tributaries, should read ‘Canal and River Trust’. Furthermore, we advise that whilst the River Stour is not one of the Trust’s assets we remain willing to engage in partnership working to identify and mitigate consequential flood risk issues arising from it to our network. (ACTION REQUEST)