South Worcestershire Development Plan Proposed Submission Document Representation Form Please return by 5.00pm on the 22 nd February 2013 to: South Worcestershire Development Plan Team, Orchard House, Farrier Street, Worcester WR1 3BB or contact@swdevelopmentplan.org Ref: (For official use only) Please complete a separate form for each representation you wish to make This form has two parts: Part A: Personal Details Part B: Your representations. Please complete Part B of this form for each representation you wish to make. You do not need to complete Part A more than once, but please ensure you state your name or organisation as applicable at the top of each Part B form you submit. Please refer to the attached guidance notes on making representations so that they address issues of legal compliance and/or soundness. Please note that when representations are submitted only Part B of the form will be published. Contact details on Part A will not be published.
PART A 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 the 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. Part A 1. Personal Details* *If an agent is appointed please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2. 2. Agent s Details (if applicable) Title c/a Agent Mr First Name c/a Agent Philip Last Name Job Title (if applicable) Organisation (if applicable) Address Line 1 Address Line 2 Address Line 3 Green Planning Solutions Rawle Senior Planning & Development Manager Green Planning Solutions Unit D - Lunesdale Upton Magna Business Park Shrewsbury Address Line 4 Postcode Shropshire SY4 4TT
Telephone Number 01743 709364 E-mail address philip.rawle@gpsllp.co.uk
South Worcestershire Development Plan Proposed Submission Document (January 2013) Sites Promotion Document SUBMISSION ON BEHALF OF BOVIS HOMES LTD (SOUTH WEST REGION) 1. Land Adjacent to The Crown, Powick 2. Tempwood, Pershore 3. Land at Wyre Hill, Wyre Piddle 11_453_BOVI1 22 nd February 2013
SWDP Proposed Submission Document 22 nd February 2013 2
Introduction Green Planning Solutions LLP (GPS) is instructed by Bovis Homes Ltd (South West Region) to make representations in respect of the South Worcestershire Development Plan Proposed Submission Document. Bovis Homes Ltd have an interest in a number of sites including: 1. Land Adjacent to The Crown, Powick; 2. Tempwood, Pershore; and 3. Land at Wyre Hill, Wyre Piddle. The Land Adjacent to The Crown, Powick was proposed as a new housing allocation under the Proposed Significant Changes to the 2011 Preferred Options Document (MHPW06). However, this site has not been taken forward into the Proposed Submission Document. This Site Promotion Document supports the re-inclusion of Powick site as a housing allocation site for Powick/Collet s Green in the SWDP and also recommends the inclusion of the Tempwood and Wyre Piddle sites as housing allocation sites in the SWDP. 3
SWDP Proposed Submission Document 22 nd February 2013 4
Powick and Collett s Green as a Category 2 Village Powick / Collett s Green is classified in the Preferred Options document as a Category 2 village in the Malvern Hills District. The village relates very well to both Malvern (4 miles to the north) and Worcester (2 miles to the south) siting directly on the A449 (Worcester Road), which forms a direct link between these two main settlements, and also provides convenient access to Junction 7 of the M5 Motorway, via the A4440. Site Allocations Policies Land Adjacent to The Crown, Powick GPS are promoting the site known as Land Adjacent to The Crown, Powick and support the re-inclusion of this site as a housing allocation site. GPS propose an allocation of 45 dwellings on the site. The village of Powick / Collett s Green has a good level of local services and facilities, which include a Primary School, Village Hall, x2 Public Houses (Crown Inn and Red Lion), a Chinese Restaurant (New Four Seasons), and a garage (Powick Service Station). This was reflected in the Rural Village and Rural Transport Study (March 2010), which was used as the evidence base for the South Worcestershire Development Plan Preferred Options document (as stated in Paragraph 4.6 on page 29). However, GPS does question the status of Powick / Collett s Green as a Category 2 village. According to the Rural Village and Rural Transport Study, Powick / Collett s Green does in fact meet the requirements of a Category 1 village. These requirements being that a Category 1 village needs to score at least 16 points in the Village Facilities Survey. Powick / Collett s Green far exceeds this by scoring 20 points. In addition, Category 1 villages also have to have medium/high levels of public transport including access to all of the daytime bus service types identified in the Rural Transport Study. Table 11 on pages 34 35 of the Rural Village and Rural Transport Study shows the settlements that have access to all such journey types. Powick / Collett s Green is one of these settlements. On this basis, GPS is of the opinion that Powick / Collett s Green warrants a re-classification to a Category 1 village; and regardless, due to Powick / Collett s Green s good sustainability credentials (as reflected in its scores in the Rural Village and Rural Transport Study) it has been demonstrated that it can accommodate further housing development above and beyond that currently proposed in the SWDP. 5
Bovis Homes and GPS have undertaken detailed investigations that have informed a current planning application on the site (MH/13/00069/FUL). The Landscape and Visual Impact Assessment prepared for the site, identified a number of constraints and opportunities for the site which have informed the development of the final layout plan proposed. The black hatch in the diagram below indicates a natural plateau within the site that would be the obvious location for development, before the land falls quite dramatically to the south west. Views of the Malvern Hills are available across the site from the north east corner looking in a south westerly direction, this is a key characteristic of the area which is identified in the West Midland National Character Map by Natural England. The layout has been developed around public open space running along this north east to south west axis providing a corridor free of development maintaining and framing these views of the Malvern Hills. Views of the hills will open up as moving through the site and provide a viewpoint that is not currently available to the public. The proposed layout has been developed to work closely with the constraints of the site. The proposed new housing has been located predominantly on the natural plateau, following the existing contours where possible, before the land falls quite dramatically towards the south west corner of the site. The view corridor can be seen in the layout below. More dense development is located along the eastern and southern boundaries that are surrounded by an existing residential estate with more sparse development to the north of the site where it is moving out of the settlement and into the surrounding countryside. It is clearly demonstrated from the proposed layout that 45 dwellings can easily be accommodated on the site. This number of houses provides an appropriate housing density on the site and would be in line with Policy SWDP13: Effective Use of Land. Black hatch indicates potential development area following the contours and taking advantage of the views The Crown Inn Views of the Malvern Hills Existing topography creating a valley within the site Existing development SWDP Proposed Submission Document 22 nd February 2013 6
17 15 PRINCE RUPERT AVE 9 11 18 22 32 13 23 9 23 25 5 7 7 6 4 8 10 4 2 The proposed vehicular access to the site is via Russell Close, which involves the demolition of No.18 Russell Close, a residential property that Bovis Homes also has a controlling interest in. This arrangement has been worked up by the Strategic Engineer at Bovis Homes, and is the third and preferred option investigated. Other alternative access arrangements for the site have been considered through the SHLAA process, including; direct access from the A449 and joining the existing access for The Crown public house. However both of these are considered to be unsatisfactory for new development. Based on detailed investigations and works that have been undertaken, GPS recommends a site boundary to reflect the proposed layout developed in accordance with the sites constraints and opportunities. This revision should include the proposed access via Russell Close, which after reviewing the alternatives is the most appropriate and suitable access solution. GPS recommend that the site can accommodate 45 dwellings, and this is demonstrated in the detailed planning application submitted. This preferred vehicular access, via Russell Close, promotes a traffic calming raised table enabling reduced visibility splays to be promoted while delivering a Minor Access Road to the new site. Initial discussions with Worcestershire County Council have confirmed that the proposed access would be capable of serving a development of 45 dwellings, with an emergency link and pedestrian and cycle link to the A449. Bowling Green Farm Garage 16 1 LB TCB Mast MALVERN ROAD 55.3m A 449 Shelter 56.1m The Crown Inn Apples (PH) 9 11 3 The Brambles Bowling Green Bowling Green 22 19 26 20 RUSSELL CLOSE 2 14 12 14 12 3 11 2 1 3 1 9 (um) 6 18 16 The Seaton 11 12 1 24 2 8 3 6 BYRON CLOSE 26 20 KING CHARLES AVE 15 16 14 12 11 28 10 14 7
SWDP 46: Land at Tempwood, Pershore GPS is promoting the site known as Land at Tempwood, Pershore and therefore the inclusion of this site as a housing allocation for 20 dwellings. The site is a discrete triangular parcel of land formed by the A4014, the B4536 and the River Avon flood plain to the south (all physical features). The site slopes down towards the River Avon in a north to south direction. The site was once a small holding which comprised a house, greenhouse and other associated structures. The house was burnt down in 1998 and since then the site has become overgrown. The site still contains various structures. Policy SWDP2 Development Strategy and Settlement Hierarchy identifies Pershore within the category of Other Towns which is the 3rd tier of the South Worcestershire settlement hierarchy. Table 2 of Policy SWDP2 states that as Pershore is considerably larger and has more available suitable land than the other towns of Upton and Tenbury Wells in this tier, an urban extension is proposed for it. Policy SWDP46 deals with Pershore s urban extension to the north comprising 600 dwellings at Station Road / Wyre Road and 5 hectares of employment land off Wyre Road adjacent to the established Keytec Business Park. In relation to the proposed site, Policy SWDP2 (D) and (E ix) states that infill development will respect the historic form and character of the town, with high design standards and protection of greenspace. SWDP Proposed Submission Document 22 nd February 2013 8
Impact on Character and Appearances On the issue of character, GPS draw very similar comparisons between the proposed site and the approved development for 45 dwellings on the Allesborough Farm site. The Allesborough Farm planning permission was secured by Hannick Homes in May 2012 at appeal (PINS Ref: APP/H1840/A/11/2165772). The SWDP SHLAA Map for Pershore interestingly shows a number of sites along the western boundary of the town. To the north is the Allesborough Farm site (as mentioned above); then below this is the Three Springs Road sites, which Bloor Homes and Bellway Homes are currently building out; and then below this again, we have the proposed site of Tempwood. This site should be viewed as being as favourable as the other sites to the north, all of which have already secured planning permission. It therefore seems logical that Tempwood is allocated in the SWDP as it would complete this development along the western boundary of Pershore. We would recommend the preparation of a Landscape Visual Impact Assessment for any development of this site. We note that Tisdale Associates have been appointed as Landscape Architects on the project. Ecology A Phase 1 Habitat Report has been undertaken by Naturally Wild. The Report concludes that the proposed developments on the Tempwood site, Pershore, will have no significant impact on either protected species or habitats (statutory or nonstatutory) on the site or in the surrounding area, providing a series of mitigation measures are adopted as recommended. This includes an on-site landscaped bio-diversity area in the part of the site that is outside Flood Zone 1. This will also double-up as on-site public open space. A series of mitigation measures, notably through the provision of this on-site landscaped bio-diversity area on part of the site, it is expected will actually provide an ecology benefit to the site, which will be over and above policy requirements. Flooding The majority of the site is located within Flood Zone 1. This is the part of the site that is to be allocated. The rear part of the site (to the south) drops off into the functional flood plain, therefore Flood Zone 3b (according to the South Worcestershire Strategic Flood Risk Assessment Map for Pershore). It is this area that is to be utilised as the on-site landscaped bio-diversity area and open space. Highways Access is to be provided off the Defford Road (B4536). The access is to be positioned to provide visibility splays in accordance with highway requirements. GPS suggests this is assessed via speed tests along the B4536. A footpath entry point will also be taken from the Defford Road and will lead to the on-site landscaped bio-diversity area. The proposed site is accessible to the services and amenities of Pershore, as well as alternative forms of transport to the private car available i.e. access to the bus stop, which is directly opposite the site on the B4536. 9
Land at Wyre Hill, Wyre Piddle GPS are promoting the site known as Land at Wyre Hill, Wyre Piddle and therefore the inclusion of this site as a housing allocation for 35 dwellings. The site comprises a triangular parcel of land formed by the railway to the north; Wyre Hill, the B4083 to the south; and Piddle Brook to the east (all physical features). The site has the appearance of an overgrown small holding, with the property known as Lyncroft sat in the middle. The neighbouring property of Elm Croft is located to the east of the site, and would form a small extension to the south eastern boundary if feasible. The site abuts the western extreme of the established settlement boundary to Wyre Piddle. On the opposite side of Wyre Hill to the appraisal site is the proposed 5 hectare employment site to north Pershore under the Proposed Submission Document of the SWDP. This site is known as SWDP47/2 Land to the north-east of Pershore and fronts onto Wyre Road. This constitutes an extension to the Keytec Business Park, and emphasises the sustainability credentials of this location for development (both employment and residential). Impact on Character and Appearance SWDP Proposed Submission Document 22 nd February 2013 10
The proposed site is not located within any specific landscape designation. The site is a discrete triangular parcel of land formed by the railway to the north; Wyre Hill, the B4083 to the south; and Piddle Brook to the east (all physical features). The proposed site abuts the western extreme of the established settlement boundary to Wyre Piddle; and on the opposite side of Wyre Hill to the site is the proposed 5 hectare employment site to north Pershore under the Proposed Submission Document of the SWDP, which is an extension to the Keytec Business Park. To this end, the proposed site will be flanked by the Keytec Business Park to the west and the village of Wyre Piddle to the east. This will define the character/future character of the area in which the site is to be located. In terms of visual impact, given how well contained the triangular appraisal site is, the only public view of the site is from Wyre Hill itself. Noise The north of the site is defined by the railway line, which is the Cotswold line between Worcester and Oxford. It should be noted that the embankments either side of the railway are designated in the current Wychavon District Local Plan as safeguarded land for transport infrastructure. Given the proximity of the railway to the north of the proposed site, a noise survey will be undertaken to confirm that the presence of the railway will not have an adverse impact on the amenity of the proposed residential properties on the site. If necessary appropriate mitigation measures will need to be incorporated into the proposed development in order to make it policy compliant from an amenity perspective. This is not anticipated to be an issue as residential properties in Wyre Piddle already back onto the railway line at the same proximity to this site. Ecology A Phase 1 Habitat Report has already been undertaken by Naturally Wild. Part of the site next to Piddle Brook is ecologically rich, and any development of the site will respect this. Enhancements to biodiversity could occur in the form of a landscaped bio-diversity area on this part of the site. This will be carefully integrated into the development proposals for the site. Flooding The majority of the site is located in Flood Zone 1. The floodplain of Piddle Brook is located to the east of the site, and therefore the development of the site will respect this. Highways Access is to be provided off Wyre Hill, the B4083. The access is to be positioned to provide visibility splays in accordance with highway requirements. It is suggested this is assessed via speed tests along the B4083. The accessibility of the site is very good as it is within close proximity to the services and amenities of both Wyre Piddle and Pershore (which includes the Keytec Business Park, Pershore High School, and Pershore Railway Station), as well as the alternative forms of transport to the private car available from the site. 11
Unit D Lunesdale, Upton Magna Business Park, Upton Magna, Shrewsbury SY4 4TT Tel: 01743 709 364 Fax: 01743 709 385 Email:philip.rawle@gpsllp.co.uk Email: applications@gpsllp.co.uk Unit 2B The Tack Room Top Barn Business Centre, Worcester Road, Holt Heath, Worcester WR6 6NH Tel: 01905 622 395
South Worcestershire Development Plan Proposed Submission Document (January 2013) Submissions by Green Planning Solutions LLP On behalf of Bovis Homes Ltd (South West Region) 22 nd February 2013 Green Planning Solutions LLP Unit D Lunesdale Upton Magna Business Park Shrewsbury SY4 4TT Tel: 01743 709364 Fax: 01743 709385 Email: admin@gpsllp.co.uk GPS Ref: 11_453_BOVI1 Applicant: Bovis Homes Ltd (South West Region)
CONTENTS: 1. INTRODUCTION... 2 2. REPRESENTATIONS... 4 APPENDICES: 1. HONEYBOURNE APPEAL DECISION (PINS REF: APP/H1840/A/12/2171339) 2. BOVIS HOMES LTD (SOUTH WEST REGION) - SOUTH WORCESTERSHIRE PROPOSED SUBMISSION SITE PROMOTION DOCUMENT
1. INTRODUCTION 1.1. Green Planning Solutions LLP is instructed by Bovis Homes Ltd (South West Region) (to be known as Bovis ) to make representations in respect of the South Worcestershire Development Plan Proposed Submission Document (to be known as the SWDP ). Bovis have land interests in two of South Worcestershire Authorities (Wychavon and Malvern Hills Districts). 1.2. In making these representations Green Planning Solutions has consulted both the recently published Planning Advisory Service s Soundness Self-Assessment Checklist of January 2013, and the National Planning Policy Framework, particularly Paragraphs 150 185 on Plan-making. 1.3. To confirm, Bovis has made representations at every stage of the SWDP plan-making process. These being: SWDP Preferred Options 2011 (published September 2011) SWDP Proposed Significant Changes to the 2011 Preferred Options (August 2012) 1.4. The representations contained herein relate to: SWDP 1 Overarching Sustainable Development Principles SWDP 2 Development Strategy and Settlement Hierarchy SWDP 3 Employment, Housing and Retail Provision Requirement and Delivery SWDP 6 Historic Environment SWDP 7 Infrastructure SWDP 13 Effective Use of Land SWDP 14 Housing Mix SWDP 15 Meeting Affordable Housing Needs SWDP 21 Design SWDP 25 Landscape Character SWDP 26 Telecommunications and Broadband SWDP 27 Renewable Energy and Low Carbon Energy SWDP 60 Category 2 Village Allocations SWDP 46 Pershore Allocations 2
SWDP 61 Category 3 Village Allocations 1.5. These are all discussed in Section 2 Representations. 3
2. REPRESENTATIONS Part B Please use a separate sheet for each representation Name or Organisation Bovis Homes Ltd (South West Region) 3. To which part of the SWDP does this representation relate? Paragraph 81, page 18 Policy Proposals Map If your comment does not relate to a specific part of the document, or it relates to a different document, for example the Sustainability Appraisal, please make this clear in your response. 4. Do you consider the SWDP is legally compliant? YES NO Please give details of why you consider the SWDP is not legally compliant. Please be as precise as possible. 5. Please set out what change/s you consider necessary to make the SWDP legally compliant, having regard to the issue/s you have identified above. You will need to say why this change will make the SWDP legally compliant. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. 6. Do you consider the SWDP to be sound? YES NO If you consider the DPD is unsound is this because it is not: 1. Justified 2. Effective 3. Consistent with national policy 4. Positively prepared 4
7. Please give details of why you consider the DPD is unsound. Please be as precise as possible. If you wish to support the soundness of the DPD, please also use this box to set out your comments. Green Planning Solutions welcomes the SWDP s acknowledgement that the WMRSS Panel Report is evidence. This is confirmed by Paragraph 218 of the NPPF, which states Local Planning Authorities may also continue to draw on evidence that informed the preparation of Regional Strategies to support Local Plan policies, supplemented as needed by up-to-date, robust local evidence. Green Planning Solutions does not agree with the level of weight the SWDP places on the Worcestershire Strategic Housing Market Assessment 2012 (SHMA), the South Worcestershire Demographic Background Paper (February 2012) and the Housing Background Paper (November 2012), because none of these documents have been subject to public consultation, nor have they been tested. Whereas the WMRSS figures have been scrutinised at an Examination in Public. The SWDP now ignores the WMRSS evidence base that the three South Worcestershire Authorities previously accepted (the Preferred Options figures). Green Planning Solutions is also concerned that the SHMA was published at a late stage (February 2012) in the SWDP s production and so may have been too late to inform the strategy s development (SWDP Preferred Option published in September 2011). 8. Please set out what change/s you consider necessary to make the DPD sound, having regard to the test you have identified at 6 above, where this relates to soundness. You will need to say why this change will make the DPD sound. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. The SWDP in its present form does not demonstrate an adequate and realistic deliverable supply of housing. Before the SWDP can proceed to the Submission Stage this evidence base needs to be reviewed in line with the most up to date evidence on future housing needs in the plan area. This being the 2011-Based Sub National Population Projections. Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support / justify the representation on legal compliance and / or soundness and the suggested change(s) necessary to make the plan sound, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submissions will only be made at the request of the Inspector, based on the matters and issues he / she identifies for examination. 9. If your representation is seeking change, do you consider it necessary to participate at the oral part of the examination? NO I do not wish to participate YES I wish to participate at the at the oral examination oral examination 10. If you wish to participate at the examination, please outline why you consider this to be necessary 5
The nature of our representations is strategic and has key implications. Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate in the oral part of the examination Signature Green Planning Solutions LLP Date 22.02.13 6
Part B Please use a separate sheet for each representation Name or Organisation Bovis Homes Ltd (South West Region) 3. To which part of the SWDP does this representation relate? Paragraph Policy SWDP1 D Proposals Map If your comment does not relate to a specific part of the document, or it relates to a different document, for example the Sustainability Appraisal, please make this clear in your response. 4. Do you consider the SWDP is legally compliant? YES NO Please give details of why you consider the SWDP is not legally compliant. Please be as precise as possible. 5. Please set out what change/s you consider necessary to make the SWDP legally compliant, having regard to the issue/s you have identified above. You will need to say why this change will make the SWDP legally compliant. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. 6. Do you consider the SWDP to be sound? YES NO If you consider the DPD is unsound is this because it is not: 1. Justified 2. Effective 3. Consistent with national policy 4. Positively prepared 7. Please give details of why you consider the DPD is unsound. Please be as precise as possible. If you wish to support the soundness of the DPD, please also use this box to set out your comments. 7
We note that Policy SWDP 1 reflects the principles of the presumption in favour of sustainable development, and that it reflects the Planning Inspectorate s model wording for such a policy. However, not all the test outlined at Paragraph 14 of the NPPF it referenced, notably Flootnote 9. 8. Please set out what change/s you consider necessary to make the DPD sound, having regard to the test you have identified at 6 above, where this relates to soundness. You will need to say why this change will make the DPD sound. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. The policy needs to state that the presumption favour test is not applicable in the areas cited in Footnote 9 of the NPPF. For example, those policies relating to sites protected under the Birds and Habitats Directive and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty, designated heritage assets, and locations at risk of flooding. Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support / justify the representation on legal compliance and / or soundness and the suggested change(s) necessary to make the plan sound, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submissions will only be made at the request of the Inspector, based on the matters and issues he / she identifies for examination. 9. If your representation is seeking change, do you consider it necessary to participate at the oral part of the examination? NO I do not wish to participate YES I wish to participate at the at the oral examination oral examination 10. If you wish to participate at the examination, please outline why you consider this to be necessary The nature of our representations is strategic and has key implications. Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate in the oral part of the examination Signature Green Planning Solutions LLP Date 22.02.13 8
Part B Please use a separate sheet for each representation Name or Organisation Bovis Homes Ltd (South West Region) 3. To which part of the SWDP does this representation relate? Paragraph Policy SWDP2 C Proposals Map If your comment does not relate to a specific part of the document, or it relates to a different document, for example the Sustainability Appraisal, please make this clear in your response. 4. Do you consider the SWDP is legally compliant? YES NO Please give details of why you consider the SWDP is not legally compliant. Please be as precise as possible. 5. Please set out what change/s you consider necessary to make the SWDP legally compliant, having regard to the issue/s you have identified above. You will need to say why this change will make the SWDP legally compliant. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. 6. Do you consider the SWDP to be sound? YES NO If you consider the DPD is unsound is this because it is not: 1. Justified 2. Effective 3. Consistent with national policy 4. Positively prepared 7. Please give details of why you consider the DPD is unsound. Please be as precise as possible. If you wish to support the soundness of the DPD, please also use this box to set out your comments. 9
The reference to development in the open countryside needs to reflect the special circumstances in the NPPF at Paragraph 55, which it should be noted are not exhaustive by the manner in which the paragraph has been drafted. 8. Please set out what change/s you consider necessary to make the DPD sound, having regard to the test you have identified at 6 above, where this relates to soundness. You will need to say why this change will make the DPD sound. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. Paragraph 55 of the NPPF states that Local Planning Authorities should avoid new isolated homes in the countryside unless there are special circumstances such as: The essential need for a rural worker to live permanently at or near their place of work in the countryside; or Where such development would represent the optimal viable use of a heritage asset or would be appropriate enabling development to secure the future of heritage assets; or Where the development would re-use redundant or disused buildings and lead to an enhancement to the immediate setting; or The exceptional quality or innovative nature of the design of the dwelling. Such a design should: - Be truly outstanding or innovative, helping to raise standards of design more generally in rural areas; - Reflect the highest standards in architecture; - Significantly enhance its immediate setting; and - Be sensitive to the defining characteristics of the local area. As mentioned above, the manner in which Paragraph 55 of the NPPF is written, this is not an exhaustive list. Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support / justify the representation on legal compliance and / or soundness and the suggested change(s) necessary to make the plan sound, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submissions will only be made at the request of the Inspector, based on the matters and issues he / she identifies for examination. 9. If your representation is seeking change, do you consider it necessary to participate at the oral part of the examination? NO I do not wish to participate YES I wish to participate at the at the oral examination oral examination 10. If you wish to participate at the examination, please outline why you consider this to be necessary 10
The nature of our representations has key implications. Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate in the oral part of the examination Signature Green Planning Solutions LLP Date 22.02.13 11
Part B Please use a separate sheet for each representation Name or Organisation Bovis Homes Ltd (South West Region) 3. To which part of the SWDP does this representation relate? Paragraph Table 4b & 4c, and Paragraphs 2 7 on Pages 37 & 38 Policy SWDP 3 Proposals Map If your comment does not relate to a specific part of the document, or it relates to a different document, for example the Sustainability Appraisal, please make this clear in your response. 4. Do you consider the SWDP is legally compliant? YES NO Please give details of why you consider the SWDP is not legally compliant. Please be as precise as possible. 5. Please set out what change/s you consider necessary to make the SWDP legally compliant, having regard to the issue/s you have identified above. You will need to say why this change will make the SWDP legally compliant. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. 6. Do you consider the SWDP to be sound? YES NO If you consider the DPD is unsound is this because it is not: 1. Justified 2. Effective 3. Consistent with national policy 4. Positively prepared 12
7. Please give details of why you consider the DPD is unsound. Please be as precise as possible. If you wish to support the soundness of the DPD, please also use this box to set out your comments. Green Planning Solutions (GPS) is pleased to see that the South Worcestershire Development Plan recognises that it needs to provide for more housing than was originally outlined at the Preferred Options stage. However, as will be seen from the comments below, GPS has concerns on the evidence base that is being relied upon to justify this revised housing need i.e. the SHMA, and that the level of provision being proposed is still not sufficient to meet the required housing need in South Worcestershire up until 2030. The Worcestershire Strategic Housing Market Assessment (SHMA) was published in February 2012. The document considers a great deal of background information relating to housing and population within the area, including projections for households. There are a number of detailed concerns with this document in respect of the work that has been undertaken in respect of household projections, not least because of its significant divergence with the demographic projections utilised by ONS and the corruption of the ONS data. This will have to be explored at the SWDP EiP. It has not been subject to public consultation, and it is inevitable that there will be considerable debate over the appropriateness of the projections at the subsequent EiP into the SWDP. Given the significant shift from the 2008 household projections, no information is given as to where the households that are not provided for will go if they are not provided in South Worcestershire, a particular difficulty given the reduced figures being proposed in Birmingham, Solihull and Stratford. An example of the difficulty of the SHMA can be seen by comparing the projected increase in population that the SHMA projection suggests with the actual 2010 based ONS population projections. Figure 3.2 of Appendix 6 of the SHMA shows a projected increase in Wychavon from 2006 to 2030 to 4,020 people. This is compared to the recent ONS projection which puts the figure at 15,000 people, which is in itself an increase over the 2008 based population projection. The same can be seen for Malvern Hills and Worcester City. Figure 3.2 of Appendix 3 of the SHMA shows a projected increase in Malvern Hills from 2006 to 2030 to 6,020 people. This is compared to the recent ONS projection which puts the figure at 8,000 people. Figure 3.2 of Appendix 5 of the SHMA shows a projected increase in Worcester City from 2006 to 2030 to 10,420 people. This is compared to the recent ONS population which puts the figure at 12,400 people. Green Planning Solutions is of the opinion that the South Worcestershire Development Plan process has failed to consider the housing figures that were relied upon in the Phase 2 Revision Draft of the West Midlands RSS (WMRSS), which before the advent of the Coalition Government in 2010 were accepted. However, ever since the announcement that the Secretary of State s intention was to abolish the RSSs there has been an on-going attempt from the South Worcestershire Authorities to distance themselves from them. Green Planning Solutions agrees with the comments made by the Planning Inspector in the appeal decision on land between Station Road and Dudley Road, Honeybourne (PINS Ref: APP/H1840/A/12/2171339). In which the Inspector at Paragraph 20 states that the Phase 2 Revision Draft of the WMRSS is given the stage it reached (Panel Report) of substantial weight, particularly because it has already undergone an EIP and the housing figures are more up to date and have been properly examined. The Inspector goes onto say at Paragraph 33 of his appeal decision that In my view the target should be guided by the WMRSS Panel Report.. This remains a reliable evidence base, consistent with the NPPF. 13
The consistency with the NPPF is seen at Paragraph 218: Where it would be appropriate and assist the process of preparing or amending Local Plan, regional strategy policies can be reflected in Local Plans by undertaking a partial review focussing on specific issues involved. Local planning authorities may also continue to draw on evidence that informed the preparation of regional strategies to support Local Plan policies, supplemented as needed by up-to-date, robust local evidence. The Phase 2 Revision Draft as amended by the Panel seeks the provision of an annual average of 1,275 dwellings per annum (dpa) in South Worcestershire as a whole in the period of 2006 to 2026, a total of 25,500 dwellings. The Inspector concludes by stating that the figures contained within the Panel Report remain the most recent objectively assessed figures available, although these have been more recent households and population projections since these were published. At a completion rate of 1,225 to 1,275 dwellings per year, the scale of housing provision for South Worcestershire set out in the Phase 2 Revision Draft of the WMRSS Preferred Option and Panel Report would equate to about 29,400 to 30,600 respectively over the plan period 2006 to 2030. The position taken in this very recent appeal decision is contrary to what the South Worcestershire Authorities say at Paragraph 3.3 of the Housing Background Paper 2012: The RSS Panel s recommendations were not considered by the Secretary of State and there was no opportunity for the South Worcestershire Councils to object to the recommended levels of growth. At a practical level there is no prospect at this time of the Phase 2 Partial Review being progressed any further during the period in which the SWDP is being prepared. In light of the Honeybourne appeal decision the justification provided at Paragraph 3.3 must be considered to be the wrong conclusion to draw on the Phase 2 Revision Draft of the WMRSS. As stated at Paragraph 33 of the Honeybourne appeal decision, more up to date information is available in the CLG 2008 Household Projections and the 2010 population figures adjusted by using the Chelmer Model are now available and relevant. The NPPF at Paragraph 159 supports this approach, by stating that any SHMA that is produced needs to meet household and population projections, taking account of migration and demographic change. To this end, Green Planning Solutions has been privy to several Reports that have assessed the needs and demands of the population based upon projections generated by the Chelmer Housing and Population Model, which uses a demographic methodology to determine future housing provision. As discussed above, the policy context requires that up to date evidence is used to determine current and future needs and demands for housing, taking into consideration migration and demographic change. The 2010 Based SNPP run of the Chelmer Model projects that a total of 26,427 dwellings are required between 2006 and 2030, and the 2008 Based SNPP run projects that a total of 23,743 dwellings are required between 2006 and 2030 to provide for both indigenous population and forecast migration levels. Taking migration out of the equation, the zero net migration run reduces the dwelling requirement to 12,278 dwellings between 2006 and 2030. When reviewing a dwelling led scenario to test sensitivity of providing for the level of housing growth set out within the emerging SWDP, it is clear that there are adverse social and economic consequences of under providing dwellings to meet with rising needs and demands. The Chelmer Model projection based on the most up to date evidence is the run derived from the ONS 2010-based Sub-National Population Projections. In our view this represents an objective assessment of housing needs based on population projections. It does not however 14
account for any back-log or unmet housing needs identified in an appropriate assessment of local housing needs. Clearly, back-log and unmet need also needs to be factored in to any future housing requirements going forward, and this is dealt with elsewhere in these representations (on Paragraph 4 of SWDP 3). In addition, the figure of 26,427 dwellings over the period 2006 2030 will result in a decline in the labour force of 4,363 persons. The negative implications of this should be carefully considered in arriving at a housing requirement for South Worcestershire over the plan period. Outlined below is a summary of the scenarios run for all three South Worcestershire Authorities (Malvern Hills District, Worcester City and Wychavon District), and then South Worcestershire as a whole: Table 22: Chelmer Population and Household Forecast (2006 to 2030): Summary of Scenarios for Malvern Hills District 2006-2030 Population Total Labour Force Total Households Total Dwellings 2010 SNPP 7620-4363 6119 6374 2008 SNPP 9140-3506 7088 7383 Zero Net Migration -3709-8262 -278-290 Dwelling Led (emerging SWDP) -192-7215 4704 4900 Table 23: Chelmer Population and Household Forecast (2006 to 2030): Summary of Scenarios for Worcester City 2006-2030 Population Total Labour Force Total Households Total Dwellings 2010 SNPP 11380-2383 8606 8747 2008 SNPP 6800-5196 6285 6388 Zero Net Migration 11029-5297 9132 9282 Dwelling Led (emerging SWDP) 14159-1038 9248 9400 Table 24: Chelmer Population and Household Forecast (2006 to 2030): Summary of Scenarios for Wychavon District 2006-2030 Population Total Labour Force Total Households Total Dwellings 2010 SNPP 15060 2721 10966 11306 2008 SNPP 11860 275 9673 9972 Zero Net Migration -64-6162 3188 3286 Dwelling Led (emerging SWDP) 8226-3563 8633 8900 Table 25: Chelmer Population and Household Forecast (2006 to 2030): Summary of Scenarios for South Worcestershire 2006-2030 Population Total Labour Force Total Households Total Dwellings 2010 SNPP 34,060-4,025 25,691 26,427 2008 SNPP 27,800-8,427 23,046 23,743 Zero Net Migration 7,256-19,721 12,042 12,278 Dwelling Led (emerging SWDP) 22,193-11,816 22,585 23,200 15
The crux to the current justification for the housing figures adopted in the SWDP of 23,200, as opposed to the higher figure of approximately 26,500 taken from the 2010-Based SNPP (plus current backlog and unmet need), is that the SWDP is relying upon the working population of South Worcestershire working longer and older to compensate for the significant decline in the area s labour force off the back of these lower housing figures. The Review Paper clarifies that based on the current SWDP housing figures the decline in the labour force would equate to 11,816 persons. On the other hand, the 2010-Based SNPP figures of approximately 26,500 dwellings would result in a decline in the labour force of 4,363 persons. Green Planning Solutions is of the opinion that it is wholly unrealistic to compensate for the reduction in the labour force by 11,816 persons by relying on the current working people working longer and older. On the other hand, Green Planning Solutions, is of the opinion that it is perhaps more realistic that a reduction in the labour force by 4,363 persons can be compensated for by the current working people working longer and older, especially when the housing need figures factor in backlog and unmet need, which will increase them further and subsequently reduce the decline in labour force figure further. The SWDP s prediction, which is somewhat like gazing into a crystal ball, is that the current work force they are predicting to work longer and older is that of the so called golden generation, a generation of baby boomers whom have the benefit of those final salary pensions and high levels of equity in houses that are mortgage free. As a result there is no financial need for these people to work longer and older. It should also be noted that Districts like Malvern Hills attract an in migration of people looking to retire, therefore a proportion of the population is not available to work longer and older, because of the life-style choice they have made by living in the area they do. All of which leads to the compelling conclusion that based upon independent evidence the dwelling requirement of 23,200 is inadequate based on the most up to date population projections available. It is considered that an increased dwelling target should be provided in order to ensure that South Worcestershire is in the best position to meet arising needs and demands for the projected population. In terms of this dwelling target, Green Planning Solutions suggested the following figures as a minimum requirements for the South Worcestershire area: 26,500 dwellings (taken from the 2010-Based SNPP) + 1,814 dwellings (unmet need / back-log taken from Figure 7.3 on Page 181 of SHMA) + 111 dwellings (National figure of 1.1% from the NHPAU) = 28,625 dwellings (29,000 dwellings should form the minimum housing requirement for South Worcestershire over the plan period of 2006 2030). 8. Please set out what change/s you consider necessary to make the DPD sound, having regard to the test you have identified at 6 above, where this relates to soundness. You will need to say why this change will make the DPD sound. It will be helpful if you are able to put forward your suggested revised working of any policy or text. Please be as precise as possible. 16
The SWDP in its present form does not demonstrate an adequate and realistic deliverable supply of housing. Before the SWDP can proceed to the Submission Stage this evidence base needs to be reviewed in line with the most up to date evidence on future housing needs in the plan area. This being the 2011-Based Sub National Population Projections, as discussed and evidenced above. Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support / justify the representation on legal compliance and / or soundness and the suggested change(s) necessary to make the plan sound, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submissions will only be made at the request of the Inspector, based on the matters and issues he / she identifies for examination. 9. If your representation is seeking change, do you consider it necessary to participate at the oral part of the examination? NO I do not wish to participate YES I wish to participate at the at the oral examination oral examination 10. If you wish to participate at the examination, please outline why you consider this to be necessary The nature of our representations is strategic and has key implications. Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate in the oral part of the examination Signature Green Planning Solutions LLP Date 22.02.13 17