Kidderminster Central Area Action Plan Development Plan ......Suggestion that sites allocated for...

Kidderminster Central Area Action Plan DevelopmentPlan Document

Statement of Publication Consultation(Regulation 22 (c) (v) Statement)

October 2012

Wyre Forest District Local Development Framework – Kidderminster Central Area Action Plan DPDStatement of Publication Consultation (Regulation 22 (c) (v) Statement) – October 2012

Contents

1. Purpose of the Report 12. Publication of the Kidderminster Central Area Action Plan DPD 13. Overview of Representations 24. Summary of the Main Issues Received by Representations 25. How the Representations Have Been Addressed 7

Appendix A List of People Notified at Publication Stage 8Appendix B Summary of Representations 14


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1 Purpose of this Report:1.1 This document has been prepared to meet the requirements of

Regulation 22(c) (v) of The Town and Country Planning (LocalPlanning) (England) Regulations 2012. The document will besubmitted alongside the Kidderminster Central Area Action PlanDevelopment Plan Document (DPD). It sets out details of the numberof representations made in response to the publication period and asummary of the main issues raised by those representations.

1.2 Regulation 22 (c) also requires a statement detailing representationsmade at Regulation 18 stage. This requirement was fulfilled by theRegulation 22(c) Statement (July 2012) which was published alongsidethe Pre-Submission Publication Kidderminster Central Area Action PlanDPD.

2 Publication of the Kidderminster Central Area Action Plan DPD:2.1 The Kidderminster Central Area Action Plan DPD was approved by

Council for publication and submission on 20th June 2012. Thisrepresents the final draft of the Kidderminster Central Area Action PlanDPD and is considered by the District Council to be both ‘sound’ and‘legally compliant’.

2.2 The Kidderminster Central Area Action Plan DPD was published for aperiod of eight weeks between 23rd July and 14th September 2012.During this time representations were invited in the following ways:o Notifications were sent by post and e-mail to all of those bodies and

individuals set out at Appendix A. Specific consultees receivedcopies of the documents.

o A statutory notice was placed in the Kidderminster Shuttle on 19th

July 2012 setting out the Statement of Representations Procedureand the Statement of Arrangements for Inspection of theKidderminster Central Area Action Plan DPD and other ProposedSubmission Documents.

o Copies of the Publication Kidderminster Central Area Action PlanDPD, Sustainability Appraisal Report, Statement of Consultation,Statement of Representations Procedure and the Statement ofArrangements for Inspection of the Kidderminster Central AreaAction Plan DPD and other Proposed Submission Documents wereplaced in each of the three libraries and Worcestershire Hubswithin the District. Representations forms and guidance notes fortheir completion were also made available in these locations.

o All of the relevant documents were published on the DistrictCouncil’s web-site and facilities were put in place forrepresentations to be made online.


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3 Overview of Representations:3.1 A total of 142 representations were received from 21 respondents. Of

these representations, 52 were from specific consultees and 90 werefrom general consultees. All responses received were duly made.

4 Summary of Main Issues Raised by Representations:4.1 This section sets out a summary of the main issues raised by those

representations which were duly made. The summary is organised bythe headings used within the Kidderminster Central Area Action PlanDPD. The summary looks to set out themes which can be identifiedfrom the comments received rather than setting out a summary of eachindividual comment and therefore, where an issue has been raised by anumber of respondents, it will only be set out once within the summary.However, due to the small number of representations received,individual comments may form part of the summary.

4.2 Throughout the Kidderminster Central Area Action Plan DPD, a numberof factual inaccuracies and typographical errors have been identifiedand these will be addressed through the schedule of minoramendments. These have been excluded from the summary set outbelow.

General: Western Power Distribution provide advice on consulting them on

development proposals and set out their requirements in terms of relocatingelectricity infrastructure.

Kidderminster Civic Society support the DPD and the approach it setsout to provide economic growth whilst protecting the historicenvironment.

Worcestershire County Council set out details of the work which theyare currently undertaking and the relationship with the DPD.

Worcestershire County Council provide information relating toconformity with the Minerals and Waste planning policies and set outsome suggestions for aligning the document more closely with theWaste Core Strategy.

Worcestershire Wildlife Trust consider that the plan gives appropriateweight to biodiversity and green infrastructure and is sound in thatregard.

Natural England are satisfied with the HRA and Sustainability Appraisalreports and support the DPD.

Wolverley and Cookley Parish Council support the DPD. The Environment Agency raise concern that the Infrastructure Delivery

Plan and Flooding Sequential Testing have not yet been published.

A Sustainable Future: Development Strategy: The fire and police services request a change to the vision to refer to a

safe and crime free environment.


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The Environment Agency consider that the vision should refer o floodrisk.

Environment Agency suggest alternative wording for objective 9. Police and Fire service suggest that objective 12 should include

reference to being crime free.

A Proactive Approach to Sustainable Development: Worcestershire County Council consider that policy KCA.PFSD1 is in

conformity with the NPPF.

A Desirable Place to Live: Support for increasing residential development in Kidderminster. Support for reference to safe environments throughout the policies. Suggestion that infrastructure beyond the sites itself needs full

consideration. Support for Churchfields urban village. Support for mixed use developments. Support for the town centre first approach to retailing. Suggestion that policy KCA.DPL2 should make reference to the

emergency services as a town centre use.

A Good Place to do Business: Suggestion that more D1 Uses should be encouraged within the town

centre where retail units have been vacant for a time. Support for focus on the vitality and viability of the town centre. Suggestion that sites allocated for retail development should be

preferred sites for retail development along with locations within thePrimary Shopping Area of Kidderminster.

Support for focussing retail growth at Weavers Wharf and BromsgroveStreet whilst limiting local centres to small-scale convenience retail.

English Heritage supports the retail dumbbell approach and feels it willhelp wider town centre regeneration.

Suggestion that the Bromsgrove Street retail site should be accessedvia the former Woolworths building.

Support for concentrating retail development in the town centre. Suggestion that the dumbbell would create two separate destinations

and would not help regenerate the town centre. Suggestion that policy KCA.GPB4 should set out whether 250 sq m is

net or gross floorspace. Concern that the sequential approach is not clearly stated. KCA.GPB5 - Environment Agency suggest more detailed text in

relation to ground water protection. KCA.GPB6 – Tourism Development – Police and Fire Service suggest

additional wording which reflects the fact hat such development placesadditional pressure on the emergency services.

KCA.GPB7 – Leisure Development – suggestion that policy is toorestrictive.

KCA.GPB7 – Leisure Development - Suggestion that the enhancementof the town hall should be included within the policy itself.


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KCA.GPB7 – Leisure Development – suggestion that the policyconflicts with KCA.GPB7 and is therefore unsound.

Suggestion that an additional policy should be inserted relating to theevening economy.

Adapting to and Mitigating Against Climate Change: Concern that the DPD does not take account of the fact that rural areas

are reliant on the private car. Worcestershire County Council and the Environment Agency suggest

including an additional policy on flood risk. The Environment Agency suggest additional wording at paragraph 6.6

to refer to safeguarding water quality. Support for approach to sustainable transport. Suggestion that paragraph 6.16 should exclude the Aggborough

section of the ring road which is not suitable for pedestrians andcyclists.

Support for increased pedestrian and cycle use of the canal corridor.

A Unique Place: Suggest that urban design and place making objectives should refer to

minimising opportunities for crime and anti-social behaviour. English Heritage suggest changes to the objectives to strengthen

conformity with the BPPF. Suggestion that paragraph 7.12 should be upgraded to a policy. The Environment Agency support the wording in KCA.UP1 (l) but

suggest alternative wording to strengthen it. Fire and Police Service suggest additional wording to strengthen policy

KCA.UP1. English Heritage support the prominence given to improving the public

realm. The Environment Agency support policy KCA.UP2 (g). Support for improvements to the walking route from the town centre to

the rail station. English Heritage welcome the specific consideration given to St. Mary’s

Church. Suggestion that the Staffordshire and Worcestershire Canal deserves a

higher profile. Support for paragraph 7.50. The Environment Agency support policy KCA.UP5 and propose

amendments to it. Fire and Police Services suggest additional wording for policy

KCA.UP5 relating to safety. The Environment Agency suggest additional wording for policy

KCA.UP6. Worcestershire County Council suggest additional green infrastructure

objectives. Worcestershire County Council suggest additional information is

needed in relation to the role of green infrastructure and its multi-functionality.


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Churchfields: Support for urban village. Suggests parking should be improved within the Horsefair local centre. Suggestion that Blackwell Street should be one-way with on-street

parking. Fire and Police Services welcome the acknowledgement that

Churchfields regeneration will require additional investment in policeinfrastructure including a compensatory police post at Grasmere Close.

Sport England supports the need for compensatory playing fieldprovision as part of policy KCA.Ch4 – Former Sladen School.

Suggestion that a retail impact assessment should be undertaken forall new retail development within Churchfields.

Policy KCA.Ch7 – Crossley Park - Suggestion that walking routesthrough the Crossley Park site should be retained.

Policy KCA.Ch7 – Crossley Park - suggestion that site boundaryshould be adjusted to run alongside the river bank.

The Environment Agency has suggested additional wording relating towater protection for policy KCA.Ch7.

Support for policy KCA.Ch8 – Horsefair.

Eastern Gateway: Support for policy KCA.EG1 – Comberton Hill Area. Suggestion that the Eastern Gateway section is unsound because it is

inappropriate to deal with areas separated by the ring road in the samepart of the document.

Suggestion that the policy KCA.EG1 is unsound because small scalemedical uses should be allowed within the retail frontage and theboundary of the area should be amended to include the HarriersTrading Estate.

Suggestion that policy KCA.EG2 should cover both the rail station andthe Severn Valley Railway station, including extending the boundaryand amending the heading to rail stations.

Support for replacing Comberton Hill subway with surface levelcrossing facilities.

Suggests that Kidderminster does not need any more traffic lights andsuggests a solution which allows pedestrians to be above the trafficwould be more appropriate.

Suggestion that the retail dumb bell will split the town in two. Suggestion that policies KCA.EG5 and KCA.EG6 should be

amalgamated and consideration should be given to including KCA.EG7also.

Suggestion that paragraphs 10.29 and 10.30 are unsound becauseKidderminster does not need another edge of centre supermarket andthe boundary with Worcester Street and Prospect Hill is inappropriate.

Support for the retention of the former Law Courts. Sport England stress the importance of making sure that new leisure

provision is at least as good as the existing provision. Suggestion that the masterplan accompanying policy KCA.EG5 is

inappropriate because it uses decked parking.


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Suggestion that more decked parking could offer the opportunity todevelop comparison retailing alongside a supermarket at BromsgroveStreet.

Western Gateway: Suggestion that the topography makes links to Park Street

unachievable.

Castle Wharf: Suggestion that policy KCA.CW1 is confusing because it includes

limited retailing which could lead to the area becoming an edge of townshopping area.

The Environment Agency suggest alternative wording for policyKCA.CW1 in relation to groundwater protection.

Crossley Park and Mill Street: Concern that the vision is not deliverable because of the dominance of

other retail centres such as Merry Hill and Worcester.

Traditional Town Centre: Support for encouraging investment in the old town.

Heritage Processions Area: Support for new development in these areas being high quality to

complement the existing conservation area. The Environment Agency suggest additional wording relating to water

quality. Alternative wording is suggested which removes specific use sand

instead refers to uses appropriate to the edge-of-centre location. The Environment Agency express concern over the extension to the

Frank Stone building which is built over the River Stour and in theirview should be removed.

Suggestion that the Frank Stone building should be allocated for amixture of residential and commercial uses rather than specific uses.

The Environment Agency suggest additional wording to policiesKCA.HP3 and KCA.HP4 in relation to safeguarding water quality.

Monitoring and Implementation Framework: Worcestershire County Council suggest that delivery agencies should

be included within the framework and that all of the Area ActionPolicies should be cross-referenced to relevant Core Strategy policies.

Policies to be Replaced: Suggests that Site Allocations and Policies DPD should set out the

policies which remain rather than the DPDs setting out the policieswhich are to be replaced.


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Appendix C – Maps: Suggestion that the primary shopping area is amended to include the

Morrisons store at Green Street.

5. How the Representations Have Been Addressed:5.1 The table at Appendix B sets out how each of the representations have

been addressed. A number of minor amendments have been suggestedin order to address the issues raised in some of the representations.Officers will continue to discuss some of the outstanding issues furtherwith respondents and prepare Statements of Common Ground followingthe submission of the DPD.


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Appendix A – List of People Notified at Publication Stage

Specific Consultees

Wyre Forest District Parish/Town CouncilsBewdley Town CouncilBroome Parish CouncilChaddesley Corbett Parish CouncilChurchill and Blakedown Parish CouncilKidderminster Charter TrusteesKidderminster Foreign Parish CouncilRock Parish CouncilRushock Parish CouncilStone Parish CouncilStourport-on-Severn Town CouncilUpper Arley Parish CouncilWolverley & Cookley Parish Council

Adjacent Parish CouncilsAbberley Parish CouncilAstley & Dunley Parish CouncilBayton Parish CouncilBelbroughton Parish CouncilClent Parish CouncilCleobury Mortimer Parish CouncilDodford with Grafton Parish CouncilElmbridge Parish CouncilElmley Lovett Parish CouncilHagley Parish CouncilHartlebury Parish CouncilHighley Parish CouncilKinlet Parish CouncilKinver Parish CouncilMilson & Neen Sollars Parish CouncilPensax Parish CouncilUpton Warren Parish Council

Other Specific ConsulteesBritish TelecomBromsgrove District CouncilCentral NetworksDudley Metropolitan Borough CouncilEnglish HeritageEnvironment AgencyGreater Birmingham and Solihull Local Enterprise PartnershipHereford & Worcester Ambulance ServiceHereford & Worcester Fire & Rescue ServiceHighways AgencyHighways Agency Network Strategy West Midlands GroupHomes & Communities Agency


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Malvern Hills District CouncilMobile Operators AssociationNational GridNatural EnglandNetwork RailOffice of Rail RegulationOil and Pipelines Agency (The)PINS - GOWMSevern Trent Water LtdShropshire CouncilSouth Staffordshire District CouncilSouth Staffordshire Water PlcSouth Worcestershire Development PlanStaffordshire County CouncilStaffordshire Police AuthorityThe Coal AuthorityThe Planning InspectorateTransco West Midlands Local Distribution ZoneWest Mercia ConstabularyWest Midlands Strategic Health AuthorityWorcestershire County CouncilWorcestershire Local Enterprise PartnershipWorcestershire Primary Care TrustWychavon District Council

General Consultees

Act on EnergyAge Concern Wyre ForestAggborough & Spennells Community Action GroupAll Rivers Hydro LimitedArley Area Environmental GroupArts Council West MidlandsASHA Wyre ForestAssociation of Retired and Persons over 50Bewdley Chamber of TradeBewdley Civic SocietyBewdley Development TrustBewdley Town Centre Management ForumBill Wiggin MPBishops Wood CentreBodenham Arboretum & Earth CentreBritish Geological SurveyBritish Horse SocietyBuddhist CommunityBusiness Connections 4 North WorcestershireCampaign for Real Ale Ltd (CAMRA)Campaign to Protect Rural EnglandCanal & Rivers Trust


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Centro- WMPTAChaplaincy for Agricultural & Rural LifeChiltern RailwaysChurch CommissionersCivil Aviation AuthorityCommunity - The Union for LifeCommunity Action Wyre Forest (CAWF)Community FirstCouncil for British Archaeology West MidlandsCouncil for the Protection of Rural England (Wyre Forest District Group)Country Land & Business AssociationCrown Estate CommissionersD & G Coach & Bus LimitedDerbyshire Gypsy Liaison GroupDesign CouncilDIAL North WorcestershireDisability Action Wyre ForestEnglish HeritageFederation of Small Businesses, Herefordshire & WorcestershireFields in TrustFirst Group PlcForestry CommissionFreight by Water Freight Transport AssociationFreight Transport AssociationFriends Families and TravellersFriends of BroadwatersFriends of the Village AssociationFusion Online LtdGarden History SocietyGPU Power UKH.M. Prison ServiceHealth and Safety Executive, Chemical and Hazardous Installations DivisionHelp the AgedHereford and Worcester Gardens TrustHerefordshire & Worcestershire Chamber of CommerceHerefordshire & Worcestershire Earth Heritage TrustHome Builders Federation (Midlands and South West )Home-Start Wyre ForestHorsefair, Broadwaters & Greenhill PartnershipHurcott Village (Management) LtdIndependent Advisory Group for Black & Ethnic Minority IssuesIslamic MosqueJephson Housing AssociationKidderminster & District Scout GroupKidderminster and District Archaeology & Historical SocietyKidderminster Civic SocietyKidderminster ConnexionsKidderminster Cycle Club (Cyclists Touring Club)Kidderminster Horticultural SocietyKidderminster Swan Centre Manager


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Kidderminster Town Centre PartnershipLittle Lakes Leisure LtdLocal Resident and Tenant AssociationsLocal schools and collegesLondon MidlandMADEMarches Energy AgencyMarches Housing Association LtdMark Garnier MPMeeting Deaf CommunityMuseums, Libraries and Archives, West MidlandsNational Farmers UnionNational Farmers Union West Midlands RegionNational Society of Allotment and Leisure GardenersNational Travellers Action GroupNational TrustNERL SafeguardingNexus Housing AssociationNHS EstatesOdell TrustOffmore Comberton Action GroupOldington & Foley Park Community NetworkOther interested parties including:

agents developers land owners local interest groups local residents members of the public

PHAB LtdPipeline Management Land & Wayleaves LtdPlanning Aid EnglandRamblers AssociationRenewable UKRooftop Housing GroupRoyal British LegionRoyal Mail Property HoldingsRoyal Town Planning InstituteRSPB Midlands Regional OfficeRushock Traders AssociationSevern Navigation Restoration TrustSevern Valley RailwaySir Thomas White's CharitySPA Housing AssociationSport EnglandStaffordshire & Worcestershire Canal SocietyStourport Business AssociationStourport Cricket ClubStourport Forward LtdStourport-on-Severn Civic Society


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Stourport-on-Severn Horticultural SocietyStourport Rugby Football ClubStourport-on-Severn Town Centre ForumStrategic Health Authority (Estates - Midlands Division)Sure-Start Wyre ForestSustainability West MidlandsSustransThe Community Housing GroupThe Diocese Board of Finance WorcesterThe Equality and Human Rights CommissionThe Georgian GroupThe Gypsy and Traveller Law Reform CoalitionThe Inland Waterways Association (Birmingham, Black Country &Worcestershire Branch)The Lawn Tennis AssociationThe Showman’s Guild of Great Britain Midland SectionThe Society for the Protection of Ancient BuildingsThe Theatres TrustThe Victorian SocietyThe Wyre Forest AgendaTourism West MidlandsTransition BewdleyTwentieth Century SocietyUkranian ClubWarwickshire Primary Care TrustWest Mercia Probation ServiceWest Midlands Consortium Education Service for Travelling ChildrenWest Midlands Planning Aid ServiceWest Midlands Region RSL Planning ConsortiumWhittles CoachesWolverley Allotment SocietyWorcestershire Acute Hospitals NHS TrustWorcestershire Biodiversity PartnershipWorcestershire County Association of Local CouncilsWorcestershire Girl GuidesWorcestershire GreenpeaceWorcestershire Mental Health Partnership NHS TrustWorcestershire Racial Equality CouncilWorcestershire Wildlife TrustWyre Forest Action Group for Older PeopleWyre Forest AdvocacyWyre Forest Bangladeshi ForumWyre Forest Citizens Advice BureauWyre Forest Cycle ForumWyre Forest Dial A RideWyre Forest Friends of the EarthWyre Forest Lifelong Learning PartnershipWyre Forest Matters LSP ChairWyre Forest Schools PartnershipWyre Forest Society


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Wyre Forest Tourism and Leisure NetworkWyre Forest Women’s AidWyre Forest Youth Strategy Group


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Appendix B – Summary of Representations Received

Respondent/Response Number

Paragraph/Policy Summary of Representation Officer Response

Western PowerDistributionKCAAPP1

Document

Western Power Distribution [may have] [has] anumber of strategic electricity distribution circuits(which can operate at 132,000 Volts, 66,000 Voltsand 33,000 Volts) in some of the area’s beingconsidered for development. These circuits may runboth underground and as overhead lines (on eithertowers/pylons or wood poles). WPD may also haveelectricity substations in these areas.

Generally, Western Power Distribution would expectdevelopers of a site to pay to divert less strategicelectricity circuits operating at 11,000 Volts (11kV)or below. This may include undergrounding some11kV and low voltage overhead lines as necessary.

Western Power Distribution would normally seek toretain the position of electricity circuits operating at132,000 Volts (132kV) and 66,000 Volts (66kV) andin some cases 33,000 Volts (33kV), particularly if thediversion of such circuits placed a financialobligation on Western Power Distribution to eitherdivert or underground them as WPD would not beparty to any planning application and any suchobligation would also go against the statutory andregulatory requirement on Western PowerDistribution to operate an economic and efficient

Comments are noted.


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electricity distribution system. Assuming the requiredminimum statutory clearances can be maintainedand WPD can access its pylons/poles, WPD doesnot generally have any restriction on the type ofdevelopment possible in proximity to its strategicoverhead lines but it would be sensible for planningguidance and layout of developments to take WPD'sposition into account and consider uses compatiblewith the retention of strategic overhead lines, forexample such as parking, estate roads, commercialuses or open space, within their immediateproximity. It is worth noting that any existing circuitscrossing the proposed development areas in thedocument may run both overhead and underground.In any case WPD should be consulted on detail atan early stage and WPD are always keen to discusslarger sites with the local authorities at an earlystage, so that constraints can be taken into accountand sites planned in the most effective way.

Where WPD have substations on land beingconsidered for development, WPD should beconsulted on the detail of proposals in good time toensure that the required access can be maintainedand catered for and that other requirements fordevelopment in the vicinity of substations are takeninto account.

Kidderminster Civic Document The DPDs together provide an excellent proposed Support is welcomed.


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SocietyKCAAPP10

plan for the redevelopment of Kidderminster whilstprotecting its heritage and retaining economicprogress.

WorcestershireWildlife TrustKCAAPP35

Document

General comment - The Kidderminster Central AreaAction Plan appears to give appropriate weight tobiodiversity and Green Infrastructure interests in linewith the adopted Core Strategy and nationalguidance. Accordingly we consider it be sound inthis regard.

Support is noted.

Campaign toProtect RuralEnglandKCAAPP68

Document Paragraph 6.16 is logically part of the justification toUP4, perhaps becoming a general introductoryparagraph to 7.39-47. As indicated in relation toparagraph 6.16, the Aggbrough section of theRingroad would be best kept as a pedestrian andcycle-free road, with a pedestrian and cycle routebeing signed through the "Heritage Processions"Area.

We have no objection to the remainder of the policy.

Comments are noted. However, it isconsidered that the policy as written issufficiently clear and the vision for the ring roadis a long term ambition that should not precludeconsideration of improvements to walking andcycling links, across its entire length.

Wolverley &Cookley ParishCouncilKCAAPP69

Document Wolverley and Cookley Parish Council would like tothank you for the very comprehensive documents.The Council have discussed and reviewed theseand are happy with the contents contained.

Comments are noted and support is welcomed.

Natural EnglandKCAAPP115

Document Considers that both DPDs, the SA reports and theHabitats Regulations Assessment accord with thelegal requirements and guidance and that they are

Support is noted.


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consistent with the NPPF and relevant local policies.

Satisfied that site allocations are evidence basedand that the environmental considerations andconstraints for each site are understood andaddressed adequately.

Supports the proposed development managementpolicies.


Document Satisfied that the Sustainability Appraisal hasprovided a systematic assessment of the Pre-Submission sites in terms of consistency with theprinciples of sustainable development and likelysocial, economic and environmental effects.Considers that sustainability objectives are clear andrelevant and that they have helped to refineemerging policies.

Support is noted.


Document Satisfied that the HRA provides a systematic andappropriately detailed assessment of both DPDs.Consider that the conclusion that the DPDs will nothave a significant effect on European protected sitesis reasonable.

Support is noted.


Document CorrectionThe Jargon Guide refers to Sites of SpecialScientific Interest (SSSI) and suggests these areofficially notified by English Nature. Please note thisresponsibility has passed to Natural England.

Comments are noted. The term SSSI is notcurrently included within the KCAAP jargonguide.

Please refer to Minor Amendment KCA -


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MA44

WorcestershireCounty CouncilKCAAPP120

Document WCC is working with partners to develop theframeworks that will assist the fundamental role thatthe economy has in Worcestershire, including theWorcestershire Infrastructure Strategy, GreenInfrastructure Strategy, Renewable Energy Strategyand Worcestershire Local Flood Risk ManagementStrategy.

Wider regeneration of Kidderminster through Re-Wyre initiative provides a long term vision withinwhich many of the sites identified in the DPDs sit.Early delivery of these sites will provide confidencebut will require confidence through public andprivate sector organisations to maximise sustainableeconomic impact.

WCC has significant concerns with regard to theexclusion of waste management which couldusefully and appropriately be located onemployment land. Gives significant concernsregarding conformity with the Waste Core Strategy.Would welcome further discussion of this particularmatter to reconcile current concerns.

Pre-submission documents not currentlyaccompanied by an up to date InfrastructureDelivery Plan, however WCC is happy to support the

These general comments are noted.


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proposed documents on basis of continuedcollaboration in the development of both the WyreForest Infrastructure Delivery Plan and theWorcestershire Infrastructure Strategy.

Would welcome greater recognition of the statutoryrole of WFDC as a Risk Management Authority andparticularly the requirement to have regard to theLocal Flood Risk Management Strategy. Welcomethe inclusion of a policy that is consistent with thisstatutory requirement and identified the need fordevelopment proposals to have regard to theemerging LFRMS.

WCC Archive and Archaeology Service has workedclosely with WFDC in drafting of the historicenvironment content and is supportive of theproposed policies subject to detailed commentsbeing addressed.

WorcestershireCounty Council -EnvironmentalPolicy & StrategicPlanningKCAAPP121

Document The County Council is pleased to support theproposed documents on the basis of continuedcollaboration with Wyre Forest District Council in thedevelopment of both the Wyre Forest InfrastructureDelivery Plan and the Worcestershire InfrastructureStrategy. This continued partnership working willassist in demonstrating the Duty-to-Cooperate.

Comments are noted. Officers are currentlyfinalising a Draft District wide InfrastructureDelivery Plan which will prioritise infrastructure.WCC will play a key role in this particularly withtheir role as Local Transport Authority. WCCOfficers will note that they were responsible forworking up a fully costed scheme for a newstation interchange at Kidderminster in 2010.


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Document Advise that the test of soundness would beimproved and would align more closely with theWorcestershire Waste Core Strategy (now foundsound, adopted November 2012) if WFDC was topropose an additional change so that it referred tothe need for all new development to comply with theWaste Core Policy "Making Provision for waste in allnew development"

These comments are noted and Officers willconsider further minor amendments to theDelivering Sustainable Development Standardssection following discussion with WCC underthe Duty to Co-operate.

EnvironmentAgencyKCAAPP98

Paragraph 1.17

Two of the documents listed are not available forreview and we understand that they are still beingundertaken by the Council to inform the evidencebase.

There appears to be no clear cross reference withthe evidence base as the Sequential Testing(Flooding) document and Infrastructure DeliveryPlan are still being completed. It is difficult tocomment on the soundness of the plan as we havenot seen the contents of these two key evidencebase documents.As the Sequential Testing (Flooding) andInfrastructure Delivery Plan are still being completedit is unclear whether the plan is the most appropriatestrategy, when considered against reasonablealternatives, and whether the plan is deliverableover its period i.e. flood risk, environmentalinfrastructure requirements etc.

Comments are noted. Officers are currentlyfinalising a Draft District wide InfrastructureDelivery Plan which will prioritise infrastructure.This has been used to inform the preparation ofthe Plan. Furthermore, work has beenundertaken in conjunction with the CountyCouncil in terms of infrastructure planning andthese documents are available to view on theCounty Council's website.

The draft sequential test has also been used todevelop the plan, this document has helped tojustify the site selection process.

These documents will be circulated to theEnvironment Agency for their comment.

West Mercia Police Paragraph 1.17 Paragraph 1.17 states that an Infrastructure Delivery Comments are noted. The SIA will be used to


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KCAAPP138 Plan (IDP) supported the site selection processleading to the present KCAAP publication document.

WMP and HWFRS are aware that work by WyreForest District Council on the IDP is taking place inpartnership with Worcestershire County Council’swork on an infrastructure plan for Worcestershire asa whole.

To assist the two councils with respect toemergency service infrastructure planning matters,WMP commissioned consultants WYG to undertakea Strategic Infrastructure Assessment (SIA) toidentify the police infrastructure required to servegrowth and identify where and when thatinfrastructure will be required, based on theproposals in the adopted Wyre Forest CoreStrategy, Pre-submission Site Allocations andPolicies DPD and the Pre-submission KidderminsterCentral Area Action Plan DPD.

help inform the development of both theCounty and the District Infrastructure DeliveryPlans.

Shuttes JKCAAPP37 Paragraph 2.5

Considers that the vision and objectives have failedbecause the construction of the Civic Centre atFinepoint removes an opportunity to draw peopleinto Kidderminster. The site is also remote fromservices and unless a further change of ''use''allocation is approved it fragments the principles ofDistrict development.

Comments are noted.

Environment Paragraph 2.5 We support reference to the River Stour as an Comments are noted and support is


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AgencyKCAAPP111

important natural movement corridor and the greeninfrastructure network.

However, it is disappointing that flood risk has notbeen referred to in the vision, given that a significantpart of the KCAAP area is within the floodplain andin considering the benefits that works to alleviateflood risk can have, in enhancing the water (blueinfrastructure) environment and creatingregeneration opportunities within the town.

welcomed.

Please refer to Minor Amendment KCA -MA1

West Mercia PoliceKCAAPP142 Paragraph 2.5

WMP and HWFRS welcome and support theinclusion of a Vision statement within the KCAAP.This constitutes a significant improvement on thePreferred Options paper and an acceptance of ourprevious representations regarding this particularissue.

Whilst we support the vision of a safe environment,with streets, spaces and buildings designed topromote activity and natural surveillance, we wouldlike to see the wording of the third paragraphexpanded as follows:

‘…The town centre will be a vibrant, attractive , safeand crime free environment in which people wish tospend their time at all times of the day and night…’




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Paragraph 2.6

We support the inclusion of Objective number 6, 7, 8and 9, in protecting and enhancing the waterenvironment. However we would recommendamended wording for objective number 9 on floodrisk and water management.

Recommended wording:"9. Improve the resilience of Kidderminster byreducing and managing flood risk and takingaccount of the impacts of climate change byensuring good water management".




Whilst we are supportive of Strategic Objective 12 inso far as it is currently written, we are veryconcerned that there is no reference to ensuring thatKidderminster is crime free.

This is inconsistent with paragraphs 58 and 69 ofthe National Planning Policy Framework, whichclearly state that planning policies and decisionsshould create safe and accessible environmentswhere crime and disorder, and the fear of crime, donot undermine quality of life or community cohesion.

In view of our comments above, we suggest thatpart 12 of the Strategic Objectives is amended asfollows: -12. Ensure the town is safe , crime free andenjoyable for all users.

Comments are noted.



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PolicyKCA.PFSD1Presumption inFavour ofSustainableDevelopment

Policies SAL.PFSD1 & KCA.PFSD1 are consistentwith the NPPF's requirement for their Presumption inFavour of Sustainable Development.

Comments are noted.

Horsefair TradersPartnershipKCAAPP14

Paragraph 4.2The Kidderminster Central Area Action Plan iscorrect to focus on unlocking residentialdevelopment potential at the heart of Kidderminster.

Noted and support welcomed.


The over use of "mixed use" schemes just out ofcentre could dilute the central core policy in what isa relatively small area in overall terms. Judicioususe of "mixed use" in locations remote from thecentre could be beneficial in ecological and generaltransport terms.

Comments are noted. The mix of use variesbetween town centre sites and those sitesfurther away from the town centre so as not toundermine the town centre first approachtowards general town centre uses whilst stillallowing communities to have access toconvenience retail and local services.

West Mercia PoliceKCAAPP131 Housing

We welcome and support the requirement in thehousing and mixed use development objectives fornew developments to create a safe environmentwhich reduces the opportunities for crime.

We are grateful to the Council for taking into accountour representations to the Preferred Options (May2011) document in this respect.


Shuttes JKCAAPP39 Paragraph 4.8 As with the SAL DPD an emphasis on dwellings,

which are a general district requirement, needs toComments are noted. Strategic transportinfrastructure requirements are set out within


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ensure a wider consideration of infrastructure thanjust the subject area. All types of access and parkingneeds to be considered carefully in relation toproposed and retained uses.

policy CP03 of the Adopted Core Strategy andpolicy SAL.CC3 of the Site Allocations andPolicies DPD.


Paragraph 4.9

The concept of an urban village development onChurchfields would fulfil the objective of blendingbusiness and community interests in the local area.Indeed, a concentration of residential units on theedge of town would also boost the confidence ofbusinesses within the town centre which will help toreinvigorate the town centre economy.

Noted.

Kidderminster CivicSocietyKCAAPP2

Policy KCA.DPL2Mixed UseDevelopment

Supports mixed use developments because they willincrease natural surveillance and attract visitorsthroughout the day.

Support is welcomed.

England & LyleKCAAPP71


Support for Policy KCA.DPL2. The ‘town-centre first'emphasis in the AAP is consistent with the prioritiesin the NPPF for town centre uses and sustainabledevelopment. The town centre has the capacity toaccommodate the growth in comparison andconvenience retail floorspace over the plan period.


West Mercia PoliceKCAAPP133


The policy, as written, makes no reference to theemergency services as one of the uses that cancontribute to supporting the vitality and viability ofthe town centre.

The lack of reference to the emergency services as

Comments are noted.



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part of mixed use developments, which in turncontribute to the vitality and viability of the towncentre, could potentially inhibit partnership workingin relation to such schemes. By creating uncertaintyas to whether the emergency services are alegitimate use within mixed use schemes, this in turncasts doubt on whether other parties should involvethem in negotiations. This could in turn affect thedelivery of community safety, particularly given thatsome of the proposed mixed use developmentsinvolve creating an evening and night-time economyin Kidderminster.

To resolve all of the concerns expressed above, werequest that the following amendment is made toPolicy KCA.DPL2:-

Community uses (including medical and theemergency services )


Paragraph 4.17

The general theme of mixed use development isabsolutely the right approach. A variety of uses forany given site will have significantly more potentialthan to allow an overwhelming single usedevelopment to dominate the area.

Noted.

Shuttes JKCAAPP44 Paragraph 4.17 Feels that more D1 uses should be encouraged

within the retail areas where retail premises areComments are noted. Outside of the primaryshopping area there is greater flexibility over


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vacant for long periods. uses.


Paragraph 5.6

The focus on the vitality and viability of the towncentre is a crucial factor in preserving the role of thetown centre as a primary shopping destination. Aclearly defined strategy highlighting the importanceof the role of the town centre will play an importantpart in attracting investment to the town centre in thefuture.

Noted.

Arrowcroft ServicesLtdKCAAPP12

Policy KCA.GPB1RetailDevelopment

To accord with paragraph 24 of the NPPF (and so toensure that this paragraph is sound), it should alsobe noted that sites which are allocated for retaildevelopment should be preferred locations for retaildevelopment along with locations within the PrimaryShopping Area of Kidderminster.

Comments are noted. However, it isconsidered that Policy KCA.GPB5 is consistentwith the sequential approach to site selectiondetailed in the NPPF, particularly when readwith KCA.GPB4 and Site Allocations & PoliciesDPD Policy SAL.GPB2, which is intended toprovide the detailed guidance on the sequentialapproach. The policy guidance looks for retaildevelopment to be located in the PrimaryShopping Area in the first instance beforelooking to edge-of-centre and out-of-centresites, as per the NPPF.



The balance of targeted retail growth within the towncentre focused on Weavers Wharf and BromsgroveStreet is consistent with a sensible approach toenhance the vitality and viability of the town centre.Limiting retail growth in the local centres atHorsefair, Comberton Hill and the Mill Street mixeduse area to small scale units of no more than

Noted.


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250sqm will allow those areas to maintain their roleas effective and sustainable neighbourhood centres.This will also promote a vital sense of communitywithin the local area.

English HeritageKCAAPP21


English Heritage welcomes vision for retaildevelopment 'dumbbell' focussed on Weavers Wharfand Bromsgrove Street which should help widerregeneration of town centre.




We accept that sites in the Western and EasternGateways would be the sequentially preferablelocations for new retail development inKidderminster. Support that view that BromsgroveStreet is appropriate for a major supermarketdevelopment, but note that it may also be suitable tomeet comparison goods retail development. Wesupport the policy acceptance of limited retail growthin the Horsefair neighbourhood centre.

Noted and support welcomed. Paragraphs 5.9to 5.13 set out that new retail development inthe Worcester Street/Bromsgrove Streetarea will be encouraged and is not restrictedto either comparison or convenience.


Paragraph 5.10The text should be re-drafted to express apreference for access to the Bromsgrove Street sitevia the former Woolworths unit.

Comments are noted. The policies andguidance contained within the A Unique Placechapter look to create a network of wellconnect streets and spaces and improveaccess and permeability throughout the town.This is further highlighted by Policy KCA.CC2which looks to developments to provide linksthrough sites themselves and create directroutes to aid the ease of movement.


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Paragraph 5.10 in the A Good Place to doBusiness chapter supports this approach andstates that footfall could be encouraged to theBromsgrove Street site " via the formerMagistrate's Court site, Step Entry and/orpremises fronting Worcester Street ." The textdoes not restrict improved access beingprovided through only one of these options butlooks for a number of possible solutions thatcould work in tandem.

In addition to this, the site specific policyKCA.EG6 Worcester Street RetailDevelopment (which covers the formerWoolworths unit) states that any newdevelopment should "create improvedpedestrian links between Worcester Street andBromsgrove Street." The reasoned justificationgoes on to highlight the importance of this sitein improving visual and physical links betweenthese two streets and states the ambition forthe site to provide new 'street' to improveaccess.


Feels that Kidderminster requires a compact towncentre and that further development will take peopleaway from small traders.

Comments are noted, the retail centre hasshifted towards Weavers Wharf and theproposals for Bromsgrove Street aim toencourage shoppers back into the traditionaltown centre.


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Paragraph 5.13

Improving and utilising the Vicar Street, High Street,Worcester Street areas in conjunction with WeaversWharf would benefit the town in the long-term. Concentrating retail development in the townis welcomed as out of centre retail developmentsdamage the traditional town centre.



Feels that the dumbbell effect would create separatedestinations and leave the town centre streetsunoccupied. The topography of the town meansthat a supermarket off the ring road is unlikely togenerate footfall through the town centre.

Comments are noted.


Policy KCA.GPB2Primary andSecondaryShoppingFrontages

The policy is not legally compliant or effective, thefollowing changes are required:

1. Paragraph 5.20 constitutes a policy and shouldappear as such, not as mere justification

2. The policy should be split into two - one relating tothe Primary Shopping Area and the other to theSecondary Shopping Area.

3. The possibility of the use of basements for non-A1 uses (as well as upper floors) should be allowedwhere A2-A5 are allowed.

4. Small medical facilities such as dentists andphysiotherapists should be allowed where A2-A5 is

Comments are noted. Taking each of them inturn:

1. It is considered that the wording inparagraph 5.20 should remain as ReasonedJustification. It helps to explain the policyposition and clarify what is considered to beover-concentration. This approach has beensuccessfully applied in the current AdoptedLocal Plan of 2004.

2. It is considered that the policy is already splitinto the two component parts mention in therepresentation. It is important to note that thispolicy refers to frontage and not the Primary


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permissible Shopping Area.

3. This is not considered to be precluded by thepolicy as currently worded

4. It is considered that this is permissible -within the Secondary Shopping Frontage. It isconsidered important to ensure that thePrimary Frontage is retained for A useclasses. The policy for the Secondary frontageis more flexible to allow these other uses to beimplemented.


The East end of New Road and Oxford Street aretraditional shopping streets and closer infill areasbetween the existing shopping zones/supermarketsand the museum attraction.

Comments are noted.


As stated above good pedestrian links and freeparking make Crossley Park feel less edge of town.However the same can not be said of B&Q which isin a location that is not a natural walking destinationfrom the centre and by the nature of its business isan "in and out" destination more out of town thanedge of town.

Comments are noted. B&Q is restricted tobulky goods retail for this reason.


Policy KCA.GPB4Edge-of-Centreand Out-of-CentreRetailing

The policy does not specify whether 250 sq.m. isgross or net floorspace. The AAP should clarify that250 sq.m. is a net figure. It would also be helpful toclarify that the use of this floorspace figure is


In regard to retail floor space, as per PolicySAL.GPB2 of the Site Allocations & Policies


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effectively a floorspace threshold for retail impactassessments.

The general health of the centre has, in our view,not improved in recent years and, despite theattraction of the large edge-of-centre stores, theretail core area remains at risk from further pressurefor retail development outside the centre. Thispressure should be resisted in order to sustain thevitality and viability of the town centre.

We welcome the support in the AAP for the towncentre to be strengthened through further retaildevelopment and overall improvements in theshopping environment. Policy KCA.GPB4 shouldsafeguard the vitality and viability of the town centrefrom pressures for edge-of-centre and out-of-centredevelopment.

DPD, this is intended to be 250 sq.m. net salesarea. It is agreed that this could be specifiedwithin the policy.

In terms of 250 sq.m. being a locally setthreshold for retail impact assessments, asallowed through the NPPF; it is considered thatthis is achieved through Policy KCA.GPB4which requires any retail development outsideof the Primary Shopping Area (PSA), over 250sq.m. to undertake a sequential test anddemonstrate that there will be no significantadverse impact on vitality and viability of thePSA.

Please refer to Minor Amendments KCA -MA7, KCA - MA8, KCA - MA30, KCA - MA31,KCA - MA37 and KCA - MA40


Policy KCA.GPB4Edge-of-Centreand Out-of-CentreRetailing

1. The sequential approach is not adequatelyexpressed. It would be better to incorporateexpressly or by cross-reference SAL.GBP2. Ourcomments on SALP have suggested that the areacovered by KCAAP should be excluded from theoperation of SAL.GBP2, so that KCAAP standsalone.

2. There should be a clearer statement ofpreference of sites within the ring road or adjoining

Comments are noted. Taking each of these inturn:

1. It is considered that this is explained inparagraph 5.8, which identifies the importanceof considering the sequential policy, as set outin the Site Allocations DPD.

2. It is considered that the policy, as currentlyworded, is suitable and does not require


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Comberton Hill, with a preference for that and thenorthern part of the "Heritage Processions" areabeing regarded as edge-of-centre. Other areasbeyond the Ring Road should be regarded as out-of-centre, irrespective of the distance from its edge.

amendments. This is because it follows theNPPF's definition of edge-of-centre and tofollow a different approach would mean that thedocument was not consistent with NationalPolicy.


It is important that small manufacturing can get afoothold and grow and policy must support smallindustry as part of housing development proposal.The availability of specialist and manual labour ismore obvious in the area and encouragement ofservice based uses will import travelling labour fromoutside the area and further adding to theinfrastructure requirements.

Comments are noted, as well as retainingemployment space within the town centre, theSite Allocations and Policies DPD sets out asupply of employment land to meet theDistrict's requirements.


Paragraph 5.44

We support the inclusion of paragraph 5.44 inconsidering the environment setting of the industrialsites identified within policy KCA.GPB5. Howeverwe would recommend some additional wording inconsidering the justification for this statement asfollows:

"Any new industrial development will need toconsider the potential impact on ground waterprotection in the area. Types of activities,drainage and building design should be in linewith the Environment Agency's GroundwaterProtection Policy and Practice Guidance. Tightercontrols are likely to be required in line with thisguidance, as the sites overlie a principal aquifer




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with a relatively shallow water table. The aquiferis of regional strategic importance in terms ofwater supply and the sites fall within closeproximity (Inner, Outer and Total SourceProtection Zone) of a public water supplysource."


Tourism

Agree that heritage sites should be promoted withKidderminster being the tourist Hub for theDistrict. Recognises importance of tourism in thelocal economy. Supports aim to ''strengthen thetourism offer of the town'' because of its economicbenefits.



Policy KCA.GPB6TourismDevelopment

The Strategic Infrastructure Assessment (SIA)prepared by consultants WYG, submitted in supportof these representations, confirms that tourismrelated development places significant additionaldemands on the police and emergency services.

This is implicitly acknowledged by paragraph 5.57 ofthe KCAAP, which notes that Kidderminsterunfortunately suffers from a negative reputationamongst the canal boating community, due to anti-social behaviour and vandalism.

The absence of an explicit reference to the need tocreate a safe and crime free environment, as part ofthis overarching policy on tourism relateddevelopment, is inconsistent with Policy KCA.GPB7

Comments are noted.

Please refer to Minor Amendment KCA-MA11


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which does implicitly acknowledge these issues.

In view of all of the above, the absence of areference in policy to the need to ensure that touristrelated development is safe, enjoyable and crimefree is unjustified. It is also likely to mean that theKCAAP will be ineffective in delivering genuinelysustainable tourist related development from asocial perspective, as required by paragraph 7 of theNational Planning Policy Framework.

To resolve all our concerns and make the KCAAPsound, we suggest the inclusion of the followingaddition text in Policy KCA.GPB6: -

‘…Within these areas, development which isdemonstrated to create a safe, enjoyable andcrime free environment for the following uses willbe specifically encouraged:…’


Policy KCA.GPB7LeisureDevelopment

Given that D2 leisure and A3 and A4 food and drinkuses are 'town centre uses', the AAP shouldrecognise that such uses may also be acceptable onother sites but without a proviso that these shouldbe "smaller scale". We recognise, however, thatsuch recognition should be subject to there being anappropriate mix of uses on those other sites so thatthe aims of site-specific policies are not prejudiced.

Comment noted.



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The Theatres TrustKCAAPP36


Pleased to see that live performance venues areencouraged but assumes this does not refer totheatres. Supports the enhancement of the TownHall but suggests that the policy should specificallyrefer to this.

Disappointed that the Rose Theatre is not includedand unsure whether it falls outside theboundary. Feels it should be considered at 5.61regardless as it makes a contribution to the culturaland visitor economy.

Comments are noted.

The Rose Theatre is not referenced as it liesoutside of the KCAAP boundary.




Policy- Unsound: not effective:

1. The policy appears to conflict with GBP2. The firstparagraph of GBP7 should be expressed to besubject to the policy of GPB2.

2. References to the Carpet museum as"forthcoming" in 5.47 and 5.61 will need to beupdated before adoption. It is suggested thatsuitable phrases should be placed in squarebrackets with a footnote that they are to be deletedas from the museum's opening.

Comments are noted. Taking these points inturn:

1. It is considered that the approach isacceptable in targeting uses to certain centralareas of the town, furthermore the policy stateselsewhere in the KCAAP proposals will beconsidered favourable subject to them meetingthe objectives of the KCAAP.

2. Comments are noted. Updates will be madeto the plan as and when appropriate, prior toadoption.



There is a need for robust guidance to address theKCAAP specific problems, but also to address thelack of policy in the NPPF covering the evening and

Comments are noted. It is, however,considered that the KCAAP provides a clearstance on the evening economy through the


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night-time economy.

The DPD does not go far enough in terms of:

1. Setting out in a clear and concise way whereand when evening and night-time economyrelated development will be located anddelivered within Kidderminster.

2. Providing sufficient policy and supportingguidance in terms of explaining how the welldocumented negative side effects of eveningand night-time economy related developmentwill be actively managed.

3. Establishing the basis by which public sectoragencies, private companies and otherstakeholders will work together to coordinatethe active management of the evening andnight-time economy in Kidderminster towncentre.

4. Providing sufficient encouragement fordevelopment proposals relating to theevening and night-time economy to: -

Locate in preferred locations for this type ofdevelopment

Positively integrate with surrounding uses Provide a high quality, safe and secure

public realm

inclusion of Policy KCA.GPB7 and itsassociated Reasoned Justification. The policyprioritises the location of potential new nighttime activity into certain central locations. Italso makes clear that any proposals for thistype of development should have regard toneighbouring uses and should not causeunacceptable disturbance. This is furthersupplemented by other policies in the plan,specifically in relation to design. Policy UP1which requires, in Criteria J, for developmentsto "create a safe and secure environment thatminimises the opportunity for crime and anti-social behaviour incorporating Secured byDesign Principles." ensures that crime and anti-social behaviour considerations are keyaspects of all new development - includingproposals that will enhance the night timeeconomy.

Officers have reviewed the Policy wordingcontained within the Telford Central AreaAction Plan and it is considered that PolicyKCA.GPB7, whilst not as detailed, provides asimilar policy approach to considering the nighttime economy. This, coupled with theReasoned Justification in paragraphs 5.66 -5.70, is considered to set out a robust policyframework to enable the consideration of


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It would be preferable if the KCAAP includedspecific policy and detailed supporting guidance inrelation to the evening and night-time economy.

As stated in our representations to the PreferredOptions (May 2011), we would ideally like to see theKCAAP include planning policies and supportingguidance on the evening and night-time economy tothe same level of detail as that included on pages 80– 83 of the Central Telford Area Action Plan(adopted March 2011), prepared by Telford &Wrekin Council.

We would be very willing to actively collaborate withthe Council in the preparation of such guidance inthe lead up to the KCAAP public examination and/orduring.

proposals for the night time economy.

Notwithstanding the above, the Councilconsider it to be useful to discuss the policywording further with West Mercia with the aimof coming to a mutually agreeable position priorto examination.

Shuttes JKCAAPP50

Adapting to andMitigating AgainstClimate Change

Concern that sustainable transport takes no accountof reliance on the private car to get around theDistrict. Suggests that alternative out of centreshopping points are also required to allow people towalk to shops.

Tourism will by its nature rely on private transportand therefore the objectives need revisiting.

WorcestershireCounty Council -

Adapting to andMitigating Against

Emphasis of Policy SAL.CC7 very much supported.However, Planning authorities should take

These comments are noted and it isconsidered that they should be subject to


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EnvironmentalPolicy & StrategicPlanningKCAAPP125

Climate Change necessary regard of not just the statutory planningframework and the National FCERM Strategy, butalso the Local Flood Risk Management Strategy. Inso doing, future developments proposals will need togive proper regard to the local flood riskmanagement strategy including the risk of floodingfrom surface water, groundwater and ordinarywatercourses.We would welcome the inclusion of a policy that isconsistent with the above statutory requirement andidentifies the need for development proposals tohave regard to the emerging strategy. This wouldalso assist in demonstrating the Duty to Co-operate.

discussion under a Statement of CommonGround.


Paragraph 6.4

We acknowledge the aspirations of the Council toregeneration the KCAAP area with mixed usedevelopment. However, a flood risk policy isconsidered necessary for the following reasons:

-The majority of the KCAAP area lies within an areaat risk of flooding from the River Stour.

- Although flood risk within the area has beenreduced by the Kidderminster Flood AlleviationScheme (FAS), should the FAS be breached or itsdesign capacity exceeded then the flood hazard islikely to be significant, due to the low lying nature ofthe town and the proximity of parts of the KCAAParea (proposed allocations) to the FAS reservoir

Comments are noted. A meeting will be heldwith the Environment Agency to discuss theinclusion of a flood risk policy within theKCAAP area through a Statement of CommonGround. This will build on the informationprovided in this representation.


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area. The Level 2 Strategic Flood Risk Assessment(SFRA) by Royal Haskoning (dated February 2010)undertook breach and overtopping scenarios toconfirm the above. The report (section 7, page 53)concluded ‘it is essential that this residual risk isappreciated and sufficiently mitigated against...'

- The Water Management Policy (CP02) in theCouncil's adopted Core Strategy includes a generalflood risk policy for the District area. It does notaddress the specific flood risk (identified above) forthe KCAAP area.

The policy should be relevant to the KCAAP areaand address:

- safe development (design and layout)requirements to mitigate for actual and residual riskfrom the towns flood defences and reservoirovertopping or failing;

-the importance of adequate emergency planning tocater for new development, particularly higher floodrisk uses;

-opportunities offered through new development tomanage and reduce flood risk i.e. though provisionor maintenance/improvement of flood risk


41



management structures (some of these measureswould need to be delivered strategically, workingwith other partners and development sites);

-the amount of surface water run-off from the towncentre/opportunities for retro fitting SuDS (weunderstand that a Surface Water Management Planis in progress for the Wyre Forest District, beingundertaken by the Lead Local Flood Authority, thatcould link into this policy).

We would be happy to meet with your Council toassist with the specific wording of a flood risk policy.


Paragraph 6.6

We support the inclusion of a paragraph oncontaminated land. However, we would recommendit is reworded as follows, in fully explaining itscontext and importance in relation to the District:

Paragraph 6.6:- The former industrial nature of partsof the town centre means that there is high potentialfor contamination issues to arise. Disturbance ofany such contamination during re-developmentcan mobilise pollutants and adversely impact onthe groundwater and the wider waterenvironment including the rivers, canals andwetlands. The KCAAP area overlies a principalaquifer which is of strategic importance forwater supply and the area falls within the Source




42



Protection Zone of a public water supplyborehole. The water table is relatively shallow,particularly within the Stour valley. It is thereforeessential that ground and water contaminationmust be addressed as part of any redevelopmentand suitable remediation measures taken. Part B ofthis document identifies sites where this risk isknown to be particularly apparent; however a deskstudy will be required for most sites to assessthis potential . New development should be in linewith the Environment Agency's GroundwaterProtection Policy and Practice Guidance (GP3).


SustainableTransport

Welcome inclusion of supporting mixed usedevelopments and the policies to improvepedestrian connectivity through the area. Supportthe objectives contained within Section 6,Sustainable Transport. This work will be achievedthrough our ongoing LTP3 Kidderminster TownCentre Strategy Package works which are currentlyunderway.



Policy KCA.CC1SustainableTransport

We would question the wisdom of any policy ofchanging the status of the Aggborough section ofthe Ringroad, which is completely unsuitable forpedestrians and cyclists. Green Street and NewRoad are far more suitable as routes for them. Itmight even be possible to provide a northboundcycle lane in Green Street. This is a shorter route

Comments are noted. However, it is notconsidered that this policy cause confusion inrespect of UP4. Paragraph 6.16 talks about thering road generally and paragraph 6.17signposts readers to the relevant policy inSection 7 (UP4). it is not considered,therefore, that a change is necessary in thisregard.


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than the Ringroad.

Proposals for that section are dealt with at length inpolicy UP4 and their reappearance here isunnecessary and liable to cause confusion. Thepolicy is appropriate (and sound) in respect of therest of the Ring Road.

6.16 should be expressed to exclude theAggborough section of the Ring Road.

Canal & River TrustKCAAPP54 Paragraph 6.20

Canal & River Trust welcome the references toopportunities for linkages to the canal corridors forpedestrians and cyclists.



Suggests walking should be replaced by browsingas tourists will not walk a long way but will strollbetween shopping points and attractions. Park andride should be considered from more than onelocation.

Comments are noted however, it is felt thatwalkable town is the most appropriate term.


The current Urban Design and Place MakingObjectives currently make no reference tominimising the opportunities for crime and antisocialbehaviour.

If left unaddressed, this issue will affect the resultingeffectiveness of the KCAAP once it has beenadopted by the Council.

Comments are noted.

Please refer to Minor Amendment KCA - MA16


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To fully resolve the consistency and effectivenessissue, we suggest the following additional bulletpoint is inserted into the Urban Design and PlaceMaking Objectives: -

Create a safe and secure environment whichreduces opportunities for crime and anti-social behaviour.


Policy KCA.UP1Urban DesignKey Principles

Generally support for urban design key principlesand commitment to prepare Town Centre DesignFramework. Suggest amendments to points (i) and(l) to strengthen consistency with NPPF para.58.

Comments are noted.




Paragraph 7.12 is acceptable in principle, but needsto be upgraded to a policy.

A large number of visitors are likely to cometo the town by car. The retention of sufficientcar parking is thus vital to the town's viabilityas a retail centre.

Provision is also needed to ensure thatcommuters and other all-day visitors canpark in more peripheral locations. Failure toprovide such is liable to lead to commutersand other all-day visitors parking inresidential side streets to the annoyance ofresidents. This requires a policy, not merely

Comments are noted. However, it isconsidered that this issue is dealt withsufficiently under Policy UP1 and criteria k.


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explanation. We consider the rest of policy UP1 to be

sound.



We support the inclusion of core design principle (I.)relating to blue and green infrastructure of the towncentre, in particular the River Stour. We wouldsuggest a minor change to the wording:

The word enhance could be added i.e. ‘respect andenhance the blue and green infrastructure of thetown centre...'

Comments are noted and support is welcome.




We commend the Council on the inclusion of part (j)in Policy KCA.UP1, which requires developmentproposals to create a safe and secure environmentthat minimises opportunities for crime and antisocialbehaviour, through the incorporation of Secured byDesign principles. We also commend the Council forthe inclusion of parts (b) and (e) in Policy KCA.UP1,which promote the creation of safe environmentssubject to natural surveillance.

We are grateful to the Council for taking into accountour previous representations to the PreferredOptions (May 2011) document on this matter. Theinclusion of part (j) particularly in Policy KCA.UP1will ensure that new developments comply with a

Comments are noted and support is welcomed.However, it is considered that the proposedchanges to the policy are not required. Theseissues are considered to be picked up by PartB of the Building Regulations. Reference isalso made to the changes introduced in Wales,but these were contentious and enforcednationally and not on a local scale.


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nationally recognised consistent standard, which inturn will mean they contribute to the achievement ofGovernment’s objectives set out in paragraphs 58and 69 of the National Planning Policy Framework.

We are, however, of the view that Policy KCA.UP1should also require new development schemes toincorporate the following: -

Automatic water suppression systems Adequate water supplies for fire fighting Effective and efficient access for emergency

vehicles

The Chief Fire Officers’ Association (CFOA),HWFRS and WMP strongly advocate the installationof automatic water suppression systems in all newhousing and other developments.

We will expect developers to install hydrantsattached to the mains suitable for the purposes offire fighting at their own expense, and to providefunds for their on going maintenance. Locations ofhydrants should be approved in consultation withHWFRS. Where hydrants are not feasible suitablealternative water sources, such as gravity tanks,should be installed.


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Finally, the design of new housing and otherdevelopments must ensure that the emergencyservices can access all areas and buildings. It isimportant to remember in this respect that eachspecific development will have implications for WMPand HWFRS e.g. the need to ensure that WMPpersonnel can attend quickly in the event of adomestic incident, or ensuring that HWFRSpersonnel can attend rapidly in the event of a fire.

To resolve all our concerns expressed in theserepresentations, we suggest the inclusion of thefollowing additional design principle in PolicyKCA.UP1: -

(?) Include automatic water suppression systems,provide adequate water supplies for fire fighting andensure effective and efficient access for emergencyservice vehicles.


Policy KCA.UP2Public Realm

Supports prominence given to improving publicrealm. Will contribute to delivery of tourism,sustainable transport and economic vitality.



Policy KCA.UP2Public Realm

We support the inclusion of part g. of this policy fornew and/or improved public streets and spaces toincorporate SuDS to improve surface waterdrainage. Carefully designed SuDS can improvewater quality and biodiversity in addition to



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managing and improving surface water run-off, inline with the objectives of the Water FrameworkDirective.


Paragraph 7.24Agree that pedestrian route from rail station to towncentre needs to be improved and that signage ispoor and subways are not visitor friendly.

Comments are noted.


Policy KCA.UP3Ring RoadFramework

In principle support given for ambitions for ring road.Strategy is positive and proactive. Support is welcomed.


Policy KCA.UP4Ring RoadCharacter Areas

Welcomes specific consideration given to St. Mary'sChurch. Support is welcomed.


Paragraph 7.50Argues Staffordshire and Worcestershire Canaldeserves a higher profile and that developmentalong the canal should be of high quality.

Comments are noted. However, the KCAAPseeks to improve the design of developmentthroughout the entire central area. Therefore, itis considered that further wording is notrequired specifically for the design ofdevelopment adjacent to the Canal.


Canal & River Trust welcome the additional wordingat paragraph 7.50 highlighting the multifunctionalnature of the waterways.



Policy KCA.UP5Staffordshire andWorcestershireCanal

Support positive policy framework for the canalwhich will encourage and promote its sustainableuse and full integration into the town centre.



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We support the reference to enhancing the canal'srole as part of the green infrastructure andbiodiversity network in point viii. However, we wouldrecommend that this point also includes a referenceto the canal's water environment, in ensuring thatnew development contributes to the objectives of theWater Framework Directive.

Recommended wording:"viii. Where appropriate, enhance the canal's waterenvironment and role as part of the greeninfrastructure and biodiversity network."





As the KCAAP acknowledges in paragraphs 5.57and 7.51, there are unfortunately continuingproblems of crime and antisocial behaviour alongthe Staffordshire and Worcestershire Canal.

Whilst we support the assertion that increasingnatural surveillance and active frontages along thecanal will help deter crime and antisocial behaviour,the current wording implies that this is all that isrequired. If the policy is implemented as currentlywritten, it will not achieve its objective of significantlyreducing crime and antisocial behaviour along theStaffordshire and Worcestershire Canal.

To resolve the issues highlighted above, we suggestthe insertion of the following bullet point in place of

Comments are noted.



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the existing part (i) of Policy KCA.UP5:-

(i) Create a safe, secure and crime freeenvironment through providing active frontages,natural surveillance, incorporation of Secured byDesign principles and supporting securityinfrastructure where necessary.


Canal & River Trust welcome the additional bulletpoints within the policy and additional wording atparagraph 7.53. Individual waterways and waterspaces need to be viewed as an integral part of awider network, and not in isolation. Waterwaysthemselves should be the starting point forconsideration of the development and use of thewater and waterside land – look from the wateroutwards, as well as from the land to the water. It isimportant that building design optimise views of thewater, generate natural surveillance of water space,and encourage and improve access to, along andfrom the water.



In regards to the additional paragraph 7.57 Canal &River Trust consider Green infrastructure is thenetwork of multi-functional open spaces and naturalassets. However, the canals within Worcestershireare multifunctional, therefore operating asgreen/blue infrastructure in only one of theirfunctions.

Noted.


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In regard to paragraph 7.58 Canal & River Trustconsider the waterways should not be viewed purelyas environmental assets. It is crucial that the natureof inland waterways as multifunctional spaces andarteries is fully recognised and supported withinplanning policy.

Noted and agreed. The River andCanal section within Chapter 7 Unique Placesupports the greater utilisation of the canal andits potential to contribute to the regeneration ofthe town. The section recognises thedevelopment potential of sites adjacent to thecanal and the opportunity for these to improveand promote greater activity alongside thewaterway.


Policy KCA.UP6River Stour

We support the inclusion of a policy on the RiverStour. However, we would suggest the followingchanges to the wording in strengthening the policy:

New developments adjacent to the River Stourshould contribute to the improvement of thewater environment by :

i. Providing a positive relationship to the water'sedge.

ii. Making on-site improvements to the greeninfrastructure links.

iii. Enhancing the biodiversity value of the river andriverside areas as part of a wildlife corridor.

iv. Improving the morphology of modifiedsections of the river, where appropriate, to




52



recreate more natural conditions and betterhabitat (i.e. de-culverting, re-profiling and bufferstrips).

v. Putting in place measures to protect andimprove water quality (including groundwater).

vi. Providing flood risk betterment wherepractical.

vii. Providing opportunities for promenading andinteraction with the environment of the River Stour.


Policy KCA.UP7GreenInfrastructure

The listed objectives for Green Infrastructure arelimited. Climate change adaptation and floodattenuation is not referred to. Even within the towncentre there are opportunities to deliver a range ofGI objectives. Considers policy should be expanded.

Comments are noted.



Paragraph 7.68

References are made to a green links between anumber of sites. These need some greaterexplanation; as to its purpose and function; i.e.recreational links, biodiversity, landscape etc.Without this, there is a danger of a link beingcreated which is inappropriate to the sites, whichdoes not enhance any GI functions.

Comments are noted however it is felt that thebiodiversity and recreational opportunitiespresented by the Stour Valley corridor are setout within paragraphs 7.67-7.69.


Paragraph 7.70Support the potential use of street trees, green roofsand SuDs, but their functionality needs to be furtherexplained given this document's current focus on GI

Comments are noted.



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to deliver biodiversity. MA23


Paragraph 7.71

Functions of the parks and open spaces are greaterthan biodiversity enhancement which is just onefunction. Within the urban setting there may be theopportunity to link these spaces together through"greened" routes, explore walking, cycling routes,create good quality public realm etc.

Comments are noted.


English HeritageKCAAPP27 Paragraph 7.73

We support in principle the ambitions for the area'shistoric environment and heritage assets as set outin the text. Consider that plan provides positive andproactive strategy for Kidderminster's historicenvironment and heritage assets. Consider it usefulto strengthen links between this section and urbandesign, place-making and public realm. Also helpfulto establish clear link with proposed Town CentreDesign Framework and how this will take account ofand promote surviving historic character of thetownscape.

Comments are noted.



Canal & River Trust welcome the additional wordingin paragraph 7.79. The built environment of thewaterways represents a unique working heritage.However, the protection and enhancement of theheritage and character of the canals should notinclude measures which would prevent thewaterways potential for being fully unlocked ordiscourage the use of the waterway network.

Support is noted.


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Paragraph 8.1

This is essentially a drafting point. There arereferences throughout KCAAP to particular areas.Nothing on the map is objectionable in principle, butthe map should refer to the whole document notmerely Part B.

Place this map as a foldout map in section C,amalgamating it with the map currently there.

Comments are noted.



Paragraph 9.2

The Council is right to be focusing on an urbanvillage concept for regeneration of this area. Westrongly concur with the policy of limiting the size ofany new retail business to a maximum of 250sqm.

Noted.


Paragraph 9.5We support this approach in its ability to deliver aclearly defined 'road map' for regeneration of thearea.

Noted.

Hussain SKCAAPP40 Paragraph 9.7 I fully support the approach that was taken. Noted.


Paragraph 9.11

We support the policy of a mixed use developmentfor the Churchfields area. A variety of different usesanchored by housing will create a strong sense ofcommunity aligning the interests of local residentsand businesses.

The policy will also hugely benefit the town centrearea by creating a complimentary dimension withinthe central district of Kidderminster.

Noted.


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Sidhu AKCAAPP61 Paragraph 9.11

I support the mixed use redevelopment ofChurchfields with a big focus housing. This will bevery good for Kidderminster town centre.

Noted.


I would like to register my support and agreementwith the emerging vision for the Churchfields site. Aparallel focus on offices, community facilities andfood and drink premises would significantly enhancelocal employment prospects.

Noted.


Paragraph 9.12

We consider it to be imperative to protect andenhance car parking provision in the Horsefair localcentre. The policy should highlight the needmaintain the existing car parking provision of 5 shortterm car parking spaces (adjacent to the public arthorse statue) in the Horsefair local centre. Inaddition, it should be made clear that a designationof Blackwell Street as one way must includeenhanced on street short term car parking.

The importance of car parking provision in theHorsefair is noted. Policy KCA.Ch1Churchfields Masterplan sets out that newdevelopment in the Churchfields area will beexpected to conform to the overall aims of theChurchfields Masterplan SupplementaryPlanning Document (SPD). Within the SPD theChurchfields Historic Quadrant section sets outthat a new one way link along BlackwellStreetis to include pavement widening and on-street parking.Also stated is the intention for anew public car park to be provided in the centreof the area.


Hussain SKCAAPP41 Paragraph 9.12

A sustainable local centre will only be possible if thecar parking provision able to meet the needs of localbusinesses.

The importance of car parking provision in theHorsefair is noted. Policy KCA.Ch1Churchfields Masterplan sets out that new


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development in the Churchfields area will beexpected to conform to the overall aims of theChurchfields Masterplan SupplementaryPlanning Document (SPD). Within the SPD theChurchfields Historic Quadrant section sets outthat a new one way link along Blackwell Streetis to include pavement widening and on-streetparking. Also stated is the intention for a newpublic car park to be provided in the centre ofthe area.


Blackwell Street should be safeguarded againsttruncation.

The designation of Blackwell Street as one wayshould be combined with an effective scheme oflocal car parking provision to serve the Horsefairlocal centre.

Noted, the importance of the traffic flow alongBlackwell Street to traders is recognised.Despite this, it would be beyond the scope ofthe DPD to safeguard Blackwell Street fromany future truncation.

However, Policy KCA.Ch1 ChurchfieldsMasterplan states that any new developmentwill be expected to conform to the overall aimsof the Churchfields Masterplan SupplementaryPlanning Document. In the supporting text inpoint 9.12 and 9.13 it states that the proposedhighway changes contained in the masterplanhave been worked up using specialist transportadvice and are considered to be the preferredoption. This layout is the starting point and anyproposals that deviate from this would need tobe fully justified to the satisfaction of the District


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Council. This would be the case if any proposalto truncate Blackwell Street were put forward.

Similarly, within the SPD the ChurchfieldsHistoric Quadrant section sets out that a newone way link along Blackwell Street is toinclude pavement widening and on-streetparking. Also stated is the intention for a newpublic car park to be provided in the centre ofthe area.



Paragraph 9.13

The truncation of Blackwell Street should be formallydiscounted due its potential for adversely affectingthe vitality and viability of the Horsefair local centre.

The policy wording should be amended to includeprovision to safeguard Blackwell Street fromtruncation as part of any future proposed highwaychanges.


However, Policy KCA.Ch1 ChurchfieldsMasterplan states that any new developmentwill be expected to conform to the overall aimsof the Churchfields Masterplan SupplementaryPlanning Document. In the supporting text inpoint 9.12 and 9.13 it states that the proposedhighway changes contained in the masterplanhave been worked up using specialist transportadvice and are considered to be the preferred


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option. This layout is the starting point and anyproposals that deviate from this would need tobe fully justified to the satisfaction of the DistrictCouncil. This would be the case if any proposalto truncate Blackwell Street were put forward.


We welcome and support the confirmation inparagraph 9.16 of the KCAAP that the regenerationof the Churchfields area will require furtherinvestment in emergency service facilities. We aregrateful to the Council for taking into account ourprevious representations to the Preferred Options(May 2011) document in this respect.

Under the terms of Policy KCA.Ch2, the three highrise tower blocks will be demolished to make way for100 dwellings. Whilst WMP and HWFRS do notoppose the redevelopment, it will result in the loss ofa Police Post that delivers policing services to theentire Churchfields area. We therefore respectfullyrequest that compensatory provision of a new PolicePost is provided either within Grasmere Close or inanother, mutually acceptable, part of theregeneration scheme

The Council should also be aware that a successfulregeneration scheme will require the incorporation ofmeasures to prevent and contain fires alongside

Comments are noted and support is welcomed.Officers have considered the responses andhave suggested a minor amendment to theplan to refer to community facilities as a whole,as this will protect all uses of this type and notspecifically refer to a particular type, asproposed through this representation.



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emergency services infrastructure.

Unless there is acknowledgment in the KCAAP thatthe above measures may be required, they will mostlikely not be incorporated at all to the detriment ofthe safety of those living and working there. This willin turn harm the effectiveness of the KCAAP infacilitating a successful regeneration scheme.

To resolve the issues highlighted in Part 6 of theserepresentations, we request that the followingadditional text is inserted into paragraph 9.16 of theKCAAP: -

‘The Churchfields Masterplan sets out the priorityareas for development contributions which includesoff-site highways works, public transport andaffordable housing. However, contributions will alsobe sought for other important infrastructure includingeducation, drainage, infrastructure , emergencyservices (compensatory provision of a PolicePost) and water suppression systems.’


Policy KCA.Ch2Phase 1 -Grasmere Close

Whilst WMP and HWFRS do not oppose theredevelopment, it will result in the loss of a PolicePost that delivers policing services to the entireChurchfields area. We therefore respectfully requestthat compensatory provision of a new Police Post isprovided either within Grasmere Close or in another,

Comments are noted. A Minor Amendment hasbeen suggested to the plan but with slightlydifferent wording to that proposed through thisrepresentation.



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mutually acceptable, part of the Churchfieldsregeneration scheme.

We therefore suggest the following amendments toPolicy KCA.Ch2: -

Policy KCA.CH2Phase 1 – Grasmere Close

The redevelopment of this area will be expected toinclude:

C3 Dwelling House Community Uses (D1, including Police

Post)

Any new development on this site should:

1. Provide a strong frontage along StourbridgeRoad and Hurcott Road.

2. Provide active frontages and sense ofenclosure to all roads within the site.

3. Ensure that compensatory provision isprovided for the existing Police Post, ifthis is not to be retained on site, beforeconsidering any future redevelopment.

MA27


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Reasoned Justification

9.21 The Community Housing Group owns the site,which currently consists of maisonette blocksand a Police Post. It is proposed to redevelopthe site with a scheme for more traditional houses.The redevelopment of this site will provide up to 100dwellings and will provide a more attractiveenvironment.

Sport EnglandKCAAPP33

Policy KCA.Ch4Phase 2b -Former SladenSchool

Re-iterates that Sport England is a statutoryconsultee for applications affecting areas of playingfields. Draws attention to Sport England's PlayingFields Policy which provides guidance on how SportEngland assesses applications and whethercompensatory provision is acceptable. Identifiesthat the Wyre Forest Playing Pitch Strategyidentifies the need for replacement playing fieldswhere there is any loss which is consistent with theapproach in this policy.

Comments are noted.


Policy KCA.Ch5Phase 3a -ChurchfieldsBusiness Park

A clear statement to safeguard the town centre andHorsefair local centre from an adverse impact byany new retail development.

New retail development, particularly in the A1classification should be made conditional upon asatisfactory retail impact assessment report.

The Reasoned Justification for Policy KCA.Ch8states the ambition to maintain and enhancethe Horsefair's role as a local service centre,and to also not allow development that wouldhave a negative affect on the viability of thetown centre.

The National Planning Policy


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Framework states that when assessingapplications for retail development that localplanning authorities should require an impactassessment if development is over aproportionate, locally set threshold. If there isno threshold the default is 2,500 sq. m. TheDistrict Council considers that a threshold of250 sq. m. is proportionate for the Horsefair tosupport and enhance its role as aNeighbourhood Centre. It is not considered thata requirement for any new retail developmentto produce an impact assessment would bedeemed to be proportionate and could restrictthe ambitions to enhance the retail area.

Sidhu AKCAAPP77

Policy KCA.Ch5Phase 3a -ChurchfieldsBusiness Park

Any new retail development of Churchfields shouldbe subject to a retail impact assessment to ensurethat it does not adversely affect the vitality or viabilityof the town centre or Horsefair local centre.

The National Planning Policy Framework statesthat when assessing applications for retaildevelopment that local planning authoritiesshould require an impact assessment ifdevelopment is over a proportionate, locally setthreshold. If there is no threshold the default is2,500 sq. m. The District Council considers thata threshold of 250 sq. m. is proportionate forthe Horsefair to support and enhance its roleas a Neighbourhood Centre. It is notconsidered that a requirement for any newretail development to produce an impactassessment would be deemed to beproportionate and could restrict the ambitions


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to enhance the retail area.


I support the policy to limit any new retaildevelopment to units of no larger than 250sqm. Thiswill go some way to preventing any adverse impacton the town centre and Horsefair local centre.

Noted.


Policy KCA.Ch6Phase 3b -Limekiln Bridge

I fully support this policy and recognise the hugepotential to capitalise on the appeal of canalsideliving. There is great potential for a housingdevelopment on this site to create a sense ofescape from the conventional, urban style of living.

Noted.


Paragraph 9.35 I would support these proposals for Crossley Park. Noted.


Policy KCA.Ch7Phase 4 -Crossley Park

The policy should additionally require the retentionof these links, preferably with an active frontage tothem. This should not prevent minor footpathdiversions. The site boundary should be the riverbank, to ensure that a small area of land is not leftisolated between the site boundary and the river.

Add a further paragraph iv:

iv. Enjoy a positive relationship, preferably with anactive frontage, to the paths at the northern end ofthe site.

Comments are noted. However, as pointed outin the representations, the paths in questionare not registered public footpaths andtherefore their retention through policy is notconsidered to be appropriate. The boundary isconsidered to be appropriate and wouldconstitute the area where potentialdevelopment could be located, which would notbe immediately adjacent to the river bank.

Environment Policy KCA.Ch7 The Sequential Testing (Flooding) report should be The draft sequential test has also been used to


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AgencyKCAAPP100

Phase 4 -Crossley Park

finalised and published so that it can be viewed andcommented on. It should be clear how the reporthas been used to inform and support the policy, siteallocations (Sequential Approach) and deliverabilityof the plan, providing transparency and a clear linkto the evidence base. The flood risk sequentialapproach must be fully utilised in selecting sites fordevelopment and the appropriate type ofdevelopment in considering flood risk vulnerability.Upon receipt of this document we would be able tocomment further and update our position.

Subject to the above, the inclusion of policy wordingon flood risk should be detailed within policyKCA.Ch7, and/or the site boundary altered, so that itis clear that only a small area of the site is likely tobe developable.

In relation to contaminated land and theenvironmental constraints associated with this site,as a minimum the following policy wording isrecommended for KCA.Ch7:

‘New development should demonstrateappropriate remediation, building and drainagedesign in order to deal with any contaminatedland and to protect the water environment.'

develop the plan; this document has helped tojustify the site selection process.

These documents will be circulated to theEnvironment Agency for their comment.


Horsefair Traders Paragraph 9.44 We support this approach to highlight the Noted.


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PartnershipKCAAPP63

significance of the Horsefair as an historic gatewayto Kidderminster.

Hussain SKCAAPP42 Paragraph 9.45

I fully support the renovation/refurbishment ofproperties in the Horsefair to improve the overallappearance of this vital local centre.

Noted.

Hussain SKCAAPP43

Policy KCA.Ch8Horsefair I support every aspect of this policy. Noted.

Sidhu AKCAAPP60

Policy KCA.Ch8Horsefair I fully support all aspects of this policy directive. Noted.


Policy KCA.Ch8Horsefair

Blackwell Street should be protected from any formof truncation.

If Blackwell Street is designated as one-way thenshort stay, on street car park provision must bemade along Blackwell Street and Horsefair. Theexisting car parking provision of 5 short stay parkingspaces on the Horsefair triangle (adjacent to publicart horse statue) should be retained


However, Policy KCA.Ch1 ChurchfieldsMasterplan states that any new developmentwill be expected to conform to the overall aimsof the Churchfields Masterplan SupplementaryPlanning Document. In the supporting text inpoint 9.12 and 9.13 it states that the proposedhighway changes contained in the masterplanhave been worked up using specialist transportadvice and are considered to be the preferredoption. This layout is the starting point and anyproposals that deviate from this would need to


66



be fully justified to the satisfaction of the DistrictCouncil. This would be the case if any proposalto truncate Blackwell Street were put forward.

Similarly, within the SPD the ChurchfieldsHistoric Quadrant section sets out that a newone way link along Blackwell Street is toinclude pavement widening and on-streetparking. Also stated is the intention for a newpublic car park to be provided in the centre ofthe area.



Policy KCA.Ch8Horsefair

We support this policy and in particular the proposalto limit new retail development to a maximum of 250sq.m. (net) per unit.

We support the views of the Horsefair TradersPartnership that it is important to retain the existingprovision of 5 short term car parking spaces on theHorsefair triangle area. Also, if Blackwell Street is tobe designated as one-way then some form of shortterm on-street car parking provision along BlackwellStreet and Horsefair must be incorporated withinany such scheme.


Sidhu A Policy KCA.Ch8 I would like to support the policy approach to toward Noted.


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KCAAPP79 Horsefair the Horsefair local centre. The Horsefair has greatpotential to become a shopping destination not onlyfor local residents but also for people who liveoutside the local area.


Policy KCA.EG1Comberton HillArea

Policy EG section is unsound in its overall structure.Since they are separated by the Ring Road, it isunsatisfactory to deal with Comberton Hill and therest of the Eastern Gateway as a single area; theyare essentially disparate, and so should not becovered together. Comberton Hill is a secondaryRetail Area with other adjacent uses. The intra RingRoad area is a town centre fringe area.

Split out Policies EG1-4 into a Comberton HillSection, so that only the EG5-8 form the EasternGateway section.

Comments are noted. However, it isconsidered that this section looks at theEastern Gateway in a holistic sense and theconnections between Comberton Hill andBromsgrove Street and considered to beimportant for the future development of thetown; especially as the two could linkpassengers from the Railway Station into thetown. The sites are subsequently split intoindividual policies and it is considered that thisapproach is appropriate.



Policy: unsound: not effective or not positive enough

1. Small scale medical uses (such as doctors,dentists, and physiotherapists) should bepermissible both within and beyond the retailfrontage.

2. The boundary of the area should be altered tobring the Harriers Industrial Estate within it. Itsexclusion from area EG1 and KCAAP generally

Comments are noted. Taking each of these inturn:

1. It is considered tha the policy allows forthese uses to be brought forward, as identifiedby criteria v.

2. The Harriers Industrial Estate is zoned forresidential use and has received planningpermission for this use, it is anticipated that thissite will come forward for development and is


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seems illogical. not considered necessary to be included withinthe KCAAP.

Sidhu AKCAAPP80


I support this policy and I believe it is the best wayforward to improve the Comberton Hill area in thefuture.

Noted.


Policy KCA.EG2KidderminsterRailway Station

Since the policy is encouraging links between theNetwork Rail and SVR systems, it would be better tohave one policy covering both stations.

1. Mainly a boundary change, so that theboundary covers both stations, theirassociated car parks and what appear to bethe Severn Valley Railway engine sheds.Furthermore, it is probably desirable toinclude the adjacent railway tracks, so thatthe present edge of the platform is not anartificial barrier.

2. The heading should have "stations" (plural),since there are two of them.

Comments are noted. However, this policy isspecifically to cover the mainline station. Thisis because it is anticipated that redevelopmentof the station will occur over the lifetime of theplan. The reference to linking to the SVR is avalid consideration for any redevelopment ofthe mainline station, and this is why it isincluded in the policy. As indicated at 10.12,other policies cover the protection anddevelopment of the SVR and therefore it isconsidered appropriate to retain the boundaryas currently drawn.

Kidderminster CivicSocietyKCAAPP7 Policy KCA.EG4

Supports the replacement of subways with surfacelevel crossings because it would greatly improve theEastern Gateway and provide a user friendlyentrance to the town.


Wilcox N Supports improving pedestrian access to the town Comments are noted. Any detailed design of a


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KCAAPP11Policy KCA.EG4

centre and reducing subways however feels thatKidderminster does not need any more trafficlights. Suggests a solution which allows pedestriansto be above the traffic and cites Paradise Circus,Birmingham as an example of this.

scheme to replace the subways with anotheralternative will need to take into account costas well as traffic flow. Examples from otherareas are always worth considering. Moredetailed consideration of this aspect of the planwill be assessed through work on theKidderminster Town Centre DesignFramework


The propsals in this element of the Policy has thepropbability of splitting the town in two. Thetopography does not encourage walking betweenthe West side and this location across the traditionalshopping street. These traditional locations willsuffer as the new larger retail locations will overpower the smaller traders leaving a no mans land.This also conflicts with the master plan for asupermarket in clause 10.30 that has been pushedhard by the Politicians.

Comments are noted. Paragraphs 10.20 and10.30 refer to the same site where it is possibleto accommodate a large supermarket. As partof these proposals the links between this siteand the traditional town centre would need tobe significantly improved to attract people tomake the journey into the town centre.


Policy KCA.EG5Phase 1:BromsgroveStreet Area

Proposals KCA.EG5 and KCA.EG6 should beamalgamated, and consideration should also begiven to including proposals KCA.EG7.

The wider Eastern Gateway area contains anumber of distinct development opportunitiescovered by policies EG.1 to EG.8. Whilst therewill inevitably be an interplay between thevarious elements, it is considered that thedistinct areas can be delivered separately. Thiscan be achieved in a way that ensures eachdevelopment is complementary withoutrequiring wholesale comprehensiveredevelopment. That [comprehensive


70



redevelopment] would itself be likely toundermine the certainty and deliverability of theplan within reasonable timescales. The LPAconsiders it would likely do this by increasingthe complexity and potentially harming theviability of development proposals in the short/medium term. As worded the Plan seeks toencourage a phased programme approachwhich ensures a delivery focus



Paragraphs 10.29-30 Unsound: not effective

1. Kidderminster already has at least threeedge-of-centre supermarkets. We cannotbelieve another is needed, unless onerelatively remote from the town centre is tobe relocated to this site.

2. The boundary adjoining Worcester Streetand Prospect Hill is unduly sinuous. Wordingshould be added to allow adjustments to theprecise site boundaries.

3. We have no objection to the rest of thepolicy.

Comments are noted. With regard to the 'need'for another supermarket within Kidderminster,this test no longer applies in planningpolicy. An operator is not required todemonstrate need, but instead must passsequential and impact tests. In terms of theboundary, it is considered appropriate toremain as currently drafted, as the sitesidentified are where new development is likelyto occur. Links from the site to other areas willbe an important consideration and thesedesign principles are picked up in the Part Apolicies of the KCAAP.



Would like to see the retention of the former LawCourts, Worcester Street and provides some historyrelating to the building. Accepts that the retention ofthe frontage as per the policy is an acceptable

Comments are noted.


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solution.

Sport EnglandKCAAPP34 Paragraph 10.28

The above paragraph refers to the intended closureof the Glades Leisure Centre.

Sport England wishes to stress the importance ofensuring that any replacement leisure centre is asgood as or better than the existing centre and mustbe provided before the existing centre is closed.This requirement is reinforced by the policy set outin paragraph 74 of the National Planning PolicyFramework.

Comments are noted. The District Council is inthe process of securing improved provision toreplace current facilities at Wyre ForestGlades.


Fells that the masterplan is inappropriate becausedecked parking does not work in terms of makingthe store look busy without making it look difficult tofind a parking space. Concern that if the store has anon-food area and a filling station it will become adestination in itself detracting from the town centre.

Comments are noted however, there is a needfor parking at the site to be decked in order tomaximise the availalble space and otherexamples of town centre supermarkets use thismodel.

England & LyleKCAAPP74 Paragraph 10.30

Although the AAP suggests how a majorsupermarket development could be accommodatedon the Bromsgrove Street site, with adjacent surfacecar parking, a more intensive layout with multi-levelparking could provide the opportunity forredevelopment for comparison retail floorspace inaddition to a major supermarket.

Noted. The Supermarket Feasibility Study wasundertaken as an exercise into whether asupermarket development could feasibly bedelivered on the site. It was not intended toprovide the definitive layout of any futuredevelopment. Further negotiations with anyprospective developers will help to determinethe future arrangement.

Shuttes J Western Gateway The proposed link to Park Street is creditable. The Comments are noted. The 3D illustration is


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KCAAPP65 potential as a "specialist area" with the possible linksseems to work. Unfortunately the 3D illustrativescheme does the proposal no service as it showsfeatures that the topography will make difficultparticularly on the West side of Park Street. Theland behind Rock Works is significantly above ParkStreet.

indicative only.


Policy KCA.WG3Weavers Wharf

In general we support the policy. Our only concern iswith the relationship between Weavers Wharf andthe canal, which the Council should take anyopportunity to enhance, not merely that of "newdevelopment".

The solution is for the Council to negotiate theopening of gateways from adjoining land on to thetowing path to make it a natural route between retailsites near the canal.

Additional wording is required, encouraging theopening accesses between the canal and the retailarea. This ought to be able to provide an alternativepedestrian and cycle route to these recent retaildevelopments and the town centre generally.

Comments are noted. However, it isconsidered that the wording included at criteriai, vi, ix and x all seek to achieve thisaim. Further detail on potential developmentwould need to be considered at a planningapplication stage.

Shuttes JKCAAPP66 Castle Wharf

This section seems to confuse particularly whenread with parts of section 15 as it talks ofregeneration introducing limited shopping. Thiscould, due to its location in the road system, become

Comments are noted. Retail would be limitedto small scale specialist retailing fitting thenature of the manufacturing and sales currentlyin the area.


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an edge of town shopping destination on its ownparticularly when read as part of the potentialcomplex outlined in clauses 15.7 to 10.


Policy KCA.CW1Castle Wharf

The location and industrial history of the area meansthat there is a high potential for ground/watercontamination issues that will need to be consideredand addressed. We welcome the reference to this inparagraph 12.4. There is a typo in the last sentenceof paragraph 12.4 which refers to our G3 guidance -this should be GP3. We welcome the reference tothis document.

Notwithstanding the above, there is currently limitedreference to the areas sensitive hydrogeologicalsetting. There are likely to be restrictions for newdevelopment on the drainage, building designs(foundations) and land uses. The level of deskstudy, and if necessary, site investigation andremediation will be high.

We would recommend that wording is added topolicy KCA.CW1 as follows:

x. Take full account of the Groundwater SourceProtection Zone that exists within this area, insafeguarding groundwater supply.

Reasoned Justification:

Comments are noted.



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The site sits on a Groundwater Source ProtectionArea (SPZ1 and 2). SPZ1 is the inner zone and ishighly sensitive to land use / contamination.Therefore the type of development and activities thatcan take place within this zone need to have fullregard to the Environment Agency's GroundwaterProtection: Policy and Practice (GP3) document. Inaddition to control of land use, drainage and buildingdesign (i.e. foundations), tight control of theinvestigation and remediation of any landcontamination issues would also be required withinthis location.

Shuttes JKCAAPP67

Crossley Parkand Mill Street

Concern that the vision will not be achievablebecause of the dominance of other retail centressuch as Merry Hill and Worcester. The centreneeds to be more vibrant and more easilyaccessible. Ludlow and Malvern are currently takingshoppers from Kidderminster because of theirenvironments.

In conclusion this document needs I feel a thoroughreview as time has overtaken the authors ideas andthe piecemeal updating is showing in some level ofcontradiction.

Comments are noted however it is consideredthat the vision and development sites set outare deliverable.


Traditional TownCentre

Supports section 14, the old town needs investmentto make it more attractive to residents ad visitorsand improve its viability. New development shouldbe high quality to enhance the conservation areas

Support is noted.


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and listed buildings.


Policy KCA.HP1HeritageProcessions Area

Supports the protection of Green Street, New Roadand Dixon Street and the requirement for newdevelopment in these areas to be high quality tocomplement the existing conservation area.




We support the inclusion of paragraph 15.4,acknowledging the area's industrial history and thehigh potential for ground/water contaminationissues. In light of this, we would recommend theinclusion of a reference within the policy wording asfollows:

‘New development should incorporateappropriate remediation, building and drainagedesign in order to deal with any contaminatedland and to protect the water environment.'

There is a typo in the last sentence of paragraph15.4 which refers to our G3 guidance - this shouldbe GP3. We welcome the reference to thisdocument.



WM MorrisonSupermarkets PlcKCAAPP113


We therefore suggest that the following text isdeleted:

"A mix of uses in this area will be promoted,including:

This list of uses is not exhaustive but suggestsa number of suitable uses based of policiescontained within Part A of the document suchas KCA.DPL1 Sites for Housing andKCA.GPB5 Employment Development.Additional uses may be acceptable providing


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C1 Hotel C2 Residential Institutions C3 Residential B1 (a) Office B1(c) Light industrial D1 Non-residential Institutions"

And replaced with the following:"A mix of uses will be promoted in this areaappropriate to the edge-of-centre location".

they meet all other relevant Local DevelopmentFramework policies.


Policy KCA.HP2Frank Stone

We support the inclusion of point ii of policyKCA.HP2 and paragraph 15.13 for newdevelopment to contribute to the improvement of theriverside environment and enhancement of thegreen infrastructure.

We acknowledge that the policy looks to retain theexisting building frontage. There is an extensionstructure, which does not appear to be in keepingwith the adjacent façade, built over the bank of theRiver Stour on the site. We would wish to see thisstructure removed and any new development to beset further back from the bank of the River Stour, inline with policy KCA.UP6 (River Stour). We wouldwelcome the inclusion of a specific reference to theabove in paragraph 15.13.

Comments are noted. It is the ambition of thepolicy only to retain the facade of the buildingand it is agreed that the extensions to the rearshould be removed as part of anyredevelopment.


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Policy KCA.HP2Frank Stone

We therefore suggest that the following is deleted :

"On the Frank Stone site the following uses will beacceptable:

C3 Residential B1a Office B1c Light Industrial D1 Non-residential Institutions"

And replaced with the following:"The Frank Stone site will be suitable for a rangeof commercial or residential uses".

This list of uses us not exhaustive, however,any proposal will be expected to meet all otherrelevant Local Development Frameworkpolicies.


Policy KCA.HP3Green StreetDepot

We fully support the inclusion of point vi. in thispolicy, for any redevelopment of the site to take fullaccount of the groundwater Source Protection Zone,and welcome the explanation provided in paragraph15.18 of the reasoned justification, in safeguardingthe water environment. We would suggest minoradditions to the wording as follows (shown in bold),in providing further clarification:

Policy:vi. Take full account of the Groundwater SourceProtection Zone that exists within this area, insafeguarding groundwater supply.

Paragraph 15.18:

Comments are noted and support is welcome.



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In addition to control of land use, drainage andbuilding design (i.e. foundations), tight control ofthe investigation...


Policy KCA.HP4Bus Depot

The Bus Depot site is located within a similarenvironmental setting to the Green Street Depot site(policy KCA.HP3). These sites are located in veryclose proximity to a public water supply pumpingstation, within the inner Source Protection Zone andare therefore located in an extremely sensitivelocation.

The above matter is covered within the policy forGreen Street Depot but not for the Bus Depot site.Therefore we would recommend that similar wordingis added to policy KCA.HP4 as follows:

Policy:iv . Take full account of the Groundwater SourceProtection Zone that exists within this area, insafeguarding groundwater supply.Reasoned Justification:The site sits on a Groundwater Source ProtectionArea (SPZ1 and 2). SPZ1 is the inner zone and ishighly sensitive to land use / contamination.Therefore the type of development and activities thatcan take place within this zone need to have fullregard to the Environment Agency's GroundwaterProtection: Policy and Practice (GP3) document. In

Comments are noted.



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addition to control of land use, drainage and buildingdesign (i.e. foundations), tight control of theinvestigation and remediation of any landcontamination issues would also be required withinthis location.


Monitoring andImplementationFramework

No identification of delivery agencies in theMonitoring & Implementation section, however theyare identified within the Core Strategy.

Suggests incorporating table 16.6 from the KCAAPinto the Monitoring and Implementation section.

Not clear why all KCAAP policies have not beenincluded under the table entitled relevant corestrategy policies as they are relevant.

These comments are noted.

Details of delivery agencies are set out withinthe Adopted Core Strategy and are notrepeated within either the KCAAP or SiteAllocations and Policies DPDs.

Table 16.6 already falls within the Monitoringand Implementation section.

Expand 'Relevant Core Strategy Policies' tableand 'Relevant policies from Site Allocations andPolicies DPD' table to incorporate all KCAAPpolicies.



Policies to beReplaced

The same objection relates to both Appendix B ofSALP and Appendix B of KCAAP Will the adoptionof WFCS and both documents result in all policies inthe 2004 Local Plan and WCSP being replaced withthe possible exception of the Mineral and Waste

Comments are noted. Although the intention ofthe representation is agreed with, it isconsidered that the schedule remains asdrafted. This is because the Adopted LocalPlan has been replaced by a suite of


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provisions (where the County is the PlanningAuthority)? If so, they should say so. If not, SALPshould contain a schedule of policies which willsurvive.

documents and not a singular plan. Therefore,the schedule identifies what elements havebeen replaced, in the same way the AdoptedCore Strategy has.


MapsWe suggest that the boundary of the PrimaryShopping Area is amended to include the Morrisonsstore at Green Street.

The Primary Shopping Area has been definedin order to concentrate retail activity and footfalland contribute to creating a more viable towncentre. It is not intended to stretch the PSA toowide and thus risk diluting retail activity in thetown and undermining the centre. The DistrictCouncil considers that the site of the Morrisonsstore be appropriate as an edge-of-centrelocation.

Kidderminster Central Area Action Plan Development Plan ......Suggestion that sites allocated for...

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Transcript of Kidderminster Central Area Action Plan Development Plan ......Suggestion that sites allocated for...