Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1369

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP34 is followed by a passage in italics, as to future policy. Future policy is inevitably unknown, but planning applications are dealt with according to policy at their date of submission, but we see no reason why applicants cannot be required (as policy) to comply with the latest position, whatever it may then happen to be.
Instead add to policy:
6. Applicants will be expected to comply with any new enhanced guidance and scientific evidence on hedgerows that become available during the lifetime of this plan.

Object

Representation ID: 1372

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The threshold of 100 houses is too high. It should be possible to devise simpler systems suitable for smaller developments, down to putting solar panels on the roofs of single new dwellings.
The policy seems to lack any provision requiring (or at least encouraging) solar electricity generation by placing solar panels on roofs (both domestic and commercial), above car parks and on brownfield sites that cannot be used for other purposes. It ought to require such. It is possible that this is implicit in the very generalised expressions used, but if so, it would be better if the supporting text provided examples of what is intended by these expressions; otherwise this policy is effectively gobbledegook.

See CPRE reports on this: https://www.cpre.org.uk/wp-content/uploads/2024/04/CPRE-Report-Lighting-the-way-final-version.pdf and https://www.cpre.org.uk/wp-content/uploads/2023/05/Rooftop-Revolution-Report.pdf
Copies of these reports are sent with this objection

Comment

Representation ID: 1373

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP44.1b seems to be prejudiced against the use even of electric vehicles. With a large proportion of journeys made by car, this is an irrational policy, however desirable less car usage may be.
Similarly, DLP44.1d is hopelessly idealistic for planning in an existing built-up area. Accordingly, it is unsound.

Object

Representation ID: 1374

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DLP45.13 The word easement is being misused, so that the policy as currently drafted is meaningless. The word easement refers to a right of way, drainage, etc, not the land over which it passes (properly called the servient tenement). If the objective is for example to provide a means of access for clearing culverts, clear wording should be used to express that.

DLP45.15 The phrase “ground-truthing strategic datasets” is utter gobbledygook: does this refer to terriers kept by the Council, Environment Agency, and statutory undertakers? Plain English is needed.

12.50 The list appears to omit Withy Brook – or is that the same as Swan Brook? Similarly Black Brook (draining Saltwells Nature Reserve) appears to be omitted, being a tributary of Mouseweet Brook. Once again, the word easement is misused (see objection to DP45.13). It is not clear if the width required is 10m from the centres of the brook or a total of 10m. In any event, a 3m undeveloped strip of land on either side of small brooks should be quite sufficient. Only the river Stour needs more than that, possibly also its tributary Illey Brook.

Comment

Representation ID: 1376

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP47 may be intended to be a counterpart to DLP42. Logically it should follow DLP42, so that the requirements for different kinds of housing and other development are placed together. Even so, there appears to be no provision (as there should be) for discouraging the placing of solar panels on productive agricultural land, including prime pasture (grade 3B) as well as Best and Most Versatile Agricultural Land.

Comment

Representation ID: 1379

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

National Policy provides several specific cases where (exceptionally) development is permissible in the Green Belt. The policy fails to set these out. If the intention is to incorporate the policy of NPPF (which would be welcome), this should be more explicitly stated.

Object

Representation ID: 1382

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DLP54 seems to cover much the same subject as DLP45. The policies should be placed sequentially so as to provide a comprehensive code. Policies appropriate to the river Stour are probably inappropriate for smaller brooks. An undeveloped band 10m from the top of the river bank is probably greater than is needed and probably undeliverable in practice, however desirable in theory.

Comment

Representation ID: 1384

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP63 is welcome but does not go far enough. The default position should be that the open space provided is available to the public generally and maintained at public expense. In recent years, the practice has arisen of developers retaining open space and charging residents a service charge for maintaining it. Since the Council will be collecting Council Tax from the residents, having a service charge as well constitutes a form of double taxation. There may need to be some exceptions to this, such as for blocks of sheltered housing (as provided by McCarthy & Stone and others) where it may be appropriate to have a homogenous enclosed community. If a service charge is imposed, it should be in favour of a company owned by the property owners, not by the developers, at least once the development is completed. This also applies to DLP64.

Object

Representation ID: 1387

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Does not go far enough. The default position should be that the open space provided is available to the public generally and maintained at public expense. In recent years, the practice has arisen of developers retaining open space and charging residents a service charge for maintaining it. Since the Council will be collecting Council Tax from the residents, having a service charge as well constitutes a form of double taxation. There may need to be some exceptions to this, such as for blocks of sheltered housing (as provided by McCarthy & Stone and others) where it may be appropriate to have a homogenous enclosed community. If a service charge is imposed, it should be in favour of a company owned by the property owners, not by the developers, at least once the development is completed.