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From:Sent: 20 November 2014 12:11To:Subject: FW: British Horse Society Response to Proposed South Worcestershire

Development Plan ModificationsAttachments: Main_Consultation_Form Oct2014 - PM95.doc; Supplementary_Consultation_Form

Oct2014 - PM96.doc; Supplementary_Consultation_Form Oct2014 - PM127.doc; Supplementary_Consultation_Form Oct2014 - PM138.doc; Supplementary_Consultation_Form Oct2014 - PM194 (Clifton on Teme bridleways).doc; SWDP Main Consultation Signature Page.pdf

  

From: Bobbie Matulja Sent: 16 November 2014 18:43 To: SWDP Cc: Mark Weston; Richard Jones; Frank Randle; Andrea Jackman; Wendy Harper Subject: British Horse Society Response to Proposed South Worcestershire Development Plan Modifications

November 16th 2014Dear Sirs Please find attached my response on behalf of the British Horse Society to the proposed modifications to the South Worcestershire Development Plan. It has taken me several days to read and assimilate all the information, so I was very grateful for the extension to the consultation deadline until 9 am tomorrow morning. Please find attached below proposed modifications in respect of PM95 (on my Main Consultation Form), plus PM 96, 127, 138 and 194 on Supplementary Consultation Forms. I have scanned and attached the signature sheet for my Main Consultation Response form, which covers them all. I would be grateful if you would confirm safe, legible receipt of the forms in time for the extended deadline - and also that the scanned signature is acceptable. If not, I can always post hard copies. In addition to these specific responses, I have some general concerns about the sites chosen for additional housing allocations where they affect public bridleways and other routes used by equestrians, but there is no means of raising them using the forms you have supplied. It seems I was missed off the list of consultees for the planning application for SWDP 59b) at Clifton on Teme, which affects two bridleways and which I see was approved last year. From cross referencing the site maps with Worcestershire County Council's online Map of Paths, the other sites which affect bridleways are SWDP 59zzi, SWDP 60/5, SWDP 45/1 (both the original and supplementary sites), SWDP 45/2 (ditto), WC004 and WY045, which affects a UUCR. I would be very grateful to be included on the list of consultees for all these sites and and when the planning applications are made. Bobbie Mrs Bobbie Matulja British Horse Society County Access and Bridleways Officer, Worcestershire

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South Worcestershire Development Plan Examination Representation Form Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Please use a separate sheet for each modification response There is an extension form available on the SWDP website that can be downloaded / completed and appended to this form as many times as required. This will enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments must be received by 5.00pm on the November.

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

The South Worcestershire Councils (SWC) are seeking representations on the Proposed Modifications to the SWDP, following stage 1 of the Examination (March 2014). The changes are proposed by the SWC to address issues around the need for an uplift of housing numbers to meet the objectively assessed housing need for the area and we are only able to accept representations on these matters.

. You can access the SWDP documents online and obtain additional copies of this form from the SWDP website ://www.swdevelopmentplan.org/?page_id=5393 Completed forms should be returned either by Email to: @swdevelopmentplan.

Post to: Paul Bayliss, SWDP Project Manager c/o Wychavon District Council Policy Plans Team Civic Centre Queen Elizabeth Drive Pershore Worcestershire WR10 1PT Please note: Unfortunately we are now unable to receive responses sent to the Freepost address previously used. Please ensure that only the address given in this current guidance and associated response forms are used. ALL REPRESENTATIONS MUST BE RECEIVED IN WRITING NO LATER THAN 5.00PM ON NOVEMBER 2014.

(The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

REPRESENTATIONS MUST ONLY RELATE TO THE CURRENT PROPOSED MODIFICATIONS.

Further representations to the submitted SWDP will not be accepted. There is no need to repeat representations that you submitted at the Pre-Submission consultation stage (January/

February 2013).

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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Before completing the response form we would be grateful if you could tell us more about yourself:

1. Personal Details 2. Agent Details (if applicable)

Title Mrs

First Name Bobbie

Last Name Matulja

Job Title (if relevant)

British Horse Society County Access and Bridleways Officer

Organisation (if relevant).

British Horse Society

Address

Postcode

Tel. No.

Email

HOW WE WILL USE YOUR DETAILS The personal information you provide on this form will be processed in accordance with the requirements of the Data Protection Act 1998. It will be used only for the preparation of local development documents or any subsequent statutory replacement. However, your name and representations will be made publicly available when displaying and reporting the outcome of the consultation stage, and cannot be treated as confidential. OTHER DETAILS, INCLUDING YOUR ADDRESS AND SIGNATURE, WILL BE TREATED AS CONFIDENTIAL. In agreeing to the holding of your information you are giving permission for your details, held on the database, to be shared between the three local authorities. If you have any concerns or queries relating to this process, please contact 01905 722233. I agree that contact details and any related responses can be held by the planning service departments of the three South Worcestershire local authorities. I understand that they will only be used in relation to the plan making process as required by the Planning and Compulsory Purchase Act 2004 and other planning-related legislation. Signed: Date: 16th Nov 2014

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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3. Are you attaching any additional sheets that relate to this representation?

Yes No X Number of sheets

4. Which Proposed Modification does your representation relate to?

Modification Number PM 95

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment x

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared

Effective X

Justified x Consistent with National Policy

As also set out in the accompanying guidance note (paragraph C, page 2 of GUIDANCE NOTE – How to Respond to the Proposed Modifications), these are the tests of soundness to which your comment(s) should relate:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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Part A

Please use a separate sheet for each modification response – there is an additional document available on the SWDP website that can be completed and appended to this form as many times as required. This will enable the Inspector to consider your comments on each modification as promptly as possible.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

Walkers and cyclists needs are catered for - but there is no mention of horse riders’ needs in relation to the provision of infrastructure and services associated with the development of the A38 and A4440 transport links - nor is there any mention of riders’ needs being accommodated in the new “grade separated” crossings of these roads. This is disappointing given a) that many horses are kept and ridden in the area around Worcester’s urban fringe, and also b) that cyclists off-road provision often depends on the availability of public bridleways.

Expand box / use additional page as necessary

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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Part B Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Your representation should relate only to the current Proposed Modifications. Viii -Strike out “non-car modes” and replace with provision for “horse riders and other vulnerable road users”.

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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7. If your representation is seeking a change to the Proposed Modification, are you content for it to be considered by written representations, or do you consider it necessary to participate in person at an examination hearing?

Written representations X Participate at an examination hearing

8a. If you wish to participate at an examination hearing, please outline why you consider this to be necessary:

8b. Where there are a large number of identical or very similar responses to a particular modification, it would assist the Inspector if individuals could work together on presenting a joint case at the hearing. If you are able to do this, please indicate below who will be representing you. Your individual comments will still be considered by the Inspector.

Thank you for taking the time to complete this representation.

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South Worcestershire Development Plan Examination Representation Form – Additional Pages Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Additional sheet(s) for responses to individual modifications – to be appended to main form as required Please use a separate sheet for each modification response to enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments should be received by 5.00pm on the November. (The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

SWCs: October 2014

Additional sheet for responses to individual modifications – to be appended to main form as required

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

Please use a separate sheet for each modification number.

4. Which Proposed Modification does your representation relate to?

Modification No. PM 96

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment X

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared Effective X

Justified X Consistent with National Policy

As mentioned above, these are the tests of soundness to which your comment(s) should relate:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Your Name / Organisation Name (if relevant) (for tracking purposes only)

Mrs Bobbie Matulja, British Horse Society

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part A Please use a separate sheet for each reference number.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

Once again there is no mention of horse riders, which gives the impression than only walkers’ and cyclists’ needs will be catered for via the provision of bridges over the new dualled sections of the A4440.

Many horses are kept and ridden in the area around Worcester’s urban fringe who make a significant contribution to the local economy, and the widening of major roads often leads to the loss of crossing points used by riders to access adjacent public bridleways and quiet lanes. The provision of off-road routes for cyclists often depends on the availability of public bridleways, which should be promoted as shared multi-use tracks.

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part B

Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Your representation should relate only to the current Proposed Modifications.

The statement could be made more accurate and inclusive if the wording were changed to replace the words “pedestrian and cycle bridges” to “shared use bridges which will accommodate the needs of pedestrians, cyclists and horse riders”.

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South Worcestershire Development Plan Examination Representation Form – Additional Pages Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Additional sheet(s) for responses to individual modifications – to be appended to main form as required Please use a separate sheet for each modification response to enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments should be received by 5.00pm on the November. (The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

SWCs: October 2014

Additional sheet for responses to individual modifications – to be appended to main form as required

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

Please use a separate sheet for each modification number.

4. Which Proposed Modification does your representation relate to?

Modification No. PM 127

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment X

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared Effective X

Justified X Consistent with National Policy

As mentioned above, these are the tests of soundness to which your comment(s) should relate:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Your Name / Organisation Name (if relevant) (for tracking purposes only)

Mrs Bobbie Matulja, British Horse Society

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part A Please use a separate sheet for each reference number.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

Once again there is no mention of horse riders, which gives the impression than only walkers’ and cyclists’ needs will be catered for in the major housing developments proposed by SWDP 45. The sites covered by SWDP45 1 and 2 both are crossed by several public bridleways, and the local British Horse Society Access were also consulted at the design stages, which makes it difficult to justify the omission of provision for horse riders.

Many horses are kept and ridden in the area around Worcester’s urban fringe who make a significant contribution to the local economy, and it is likely that these developments will have adverse impacts on local equestrian businesses as well riders who keep their horses privately in the surrounding area.

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part B

Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Your representation should relate only to the current Proposed Modifications.

Change the wording from “… provision of improved pedestrian / cycle and …” to “…provision of shared use routes for walkers, cyclists and horse riders.”

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South Worcestershire Development Plan Examination Representation Form – Additional Pages Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Additional sheet(s) for responses to individual modifications – to be appended to main form as required Please use a separate sheet for each modification response to enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments should be received by 5.00pm on the November. (The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

SWCs: October 2014

Additional sheet for responses to individual modifications – to be appended to main form as required

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

Please use a separate sheet for each modification number.

4. Which Proposed Modification does your representation relate to?

Modification No. PM 138

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment X

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared Effective X

Justified X Consistent with National Policy

As mentioned above, these are the tests of soundness to which your comment(s) should relate:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Your Name / Organisation Name (if relevant) (for tracking purposes only)

Mrs Bobbie Matulja, British Horse Society

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part A Please use a separate sheet for each reference number.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

Once again there is no mention of horse riders, which gives the impression than only walkers’ and cyclists’ needs will be catered for in the infrastructure associated with the new housing development at Norton Barracks. As the local British Horse Society County Access and Bridleways Officer, I was involved in the original planning consultation, and am disappointed to see that the needs of the user group I represent have once again been omitted.

Many horses are kept and ridden in the area around Worcester’s urban fringe who make a significant contribution to the local economy, and it is likely that these developments will have adverse impacts on local equestrian businesses as well riders who keep their horses privately in the surrounding area. The whole point is that the new transport infrastructure proposed for this development should not create barriers which prevent walkers, cyclists or horse riders from moving through the site and/or accessing adjacent quiet lanes and bridleways.

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part B

Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Your representation should relate only to the current Proposed Modifications.

The original wording, with the addition of “horse riders” would be preferable to the proposed change. As I have already said in Part A, the whole point is that the new infrastructure proposed in the new Norton Barracks development should not create barriers which prevent walkers, cyclists or horse riders from moving through the site and/or accessing adjacent quiet lanes and bridleways.

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South Worcestershire Development Plan Examination Representation Form – Additional Pages Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Additional sheet(s) for responses to individual modifications – to be appended to main form as required Please use a separate sheet for each modification response to enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments should be received by 5.00pm on the November. (The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

SWCs: October 2014

Additional sheet for responses to individual modifications – to be appended to main form as required

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

Please use a separate sheet for each modification number.

4. Which Proposed Modification does your representation relate to?

Modification No. PM 194

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment X

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared Effective X

Justified X Consistent with National Policy

As mentioned above, these are the tests of soundness to which your comment(s) should relate:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Your Name / Organisation Name (if relevant) (for tracking purposes only)

Mrs Bobbie Matulja, British Horse Society

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part A Please use a separate sheet for each reference number.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

I have concerns about several of the additional housing allocations in the Malvern Hills area which affect public bridleways - notably SWDP59b at Clifton on Teme, which has public bridleways CT635 and 636 running through the site.

As the British Horse Society’s County Access and Bridleways Officer, I should have been a consultee when the planning application was made in 2013. I have been in post for the last 9 years, and don’t remember being included in the pre-application process. Given that permission has already been granted, there is little I can do retrospectively, although I would support any measures which protect these bridleways, which form part of our promoted Sabrina Way long distance bridle-route. There are no other public bridleways in the area that can be used as an alternative.

I therefore support the measures aimed at reducing the site area and the number of houses in the development outlined in the “reasons for change”.

Additional sheet for responses to individual modifications – to be appended to main form as required

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Part B

Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Your representation should relate only to the current Proposed Modifications.