South Worcestershire Development Plan Stage 2a Examination: Policy SWDP 45 Directions for Growth Outside the City Administrative Boundary 1.0 Environment Agency (EA) 1.1 EA comments: The EA want the footnote, with respect to foul drainage, as agreed in the 23 February 2015 Statement of Common Ground, to be included. SWC response: The SWC agree with the EA on this matter. 2.0 Highways England (HE) SWDP45/1 2.1 HE comments: HE support the latest text for A(i), A(xi), A(xii) and A(xv). SWC response: Noted. SWDP45/2 2.2 HE comments: HE support the proposed uplift in the proposed number of dwellings to 2,150 (see B(ii)) as it would have the lowest overall additional impact upon the Strategic Road Network. HE also support B(ii) in terms of its reference to the Worcester Transport Strategy and the dualling of the A4440 Southern Link Road and the revised wording with respect to B(xi). SWC response: Noted. SWDP45/5 D(iii) 2.3 HE comments: The HE contend that there should be a requirement for SuDS in order to address the impacts of the development with regard to wider flood risk. SWC response: The Sustainable Drainage Systems policy is set out at SWDP 29. This is consistent with SWDP45/2, 45/3, 45/4 and 45/6. The SWC acknowledge that SuDS are required in SWDP45/1
xv but no specific scheme is set out, so including it here merely repeats policy set out in SWDP 29. SWDP45/6 2.4 HE comments: HE specifically support F(iv). SWC response: Noted. 2.0 David Lock Associates on behalf of Hallam Land Management (HLM) SWDP45 3.1 HLM comments: HLM considers that for reasons of consistency with SWDP45/1 (A(iii) refers), the policy for Temple Laugherne should include a policy diagram showing the broad distribution of land uses and various policy requirements. SWC response: Given the Statement of Common Ground (EX/632) includes a so called Parameters Plan (ref. 4844-L-31, January 2015) it would seem logical and reasonable, for reasons of consistency, to include a diagram in SWDP45/2 B. 3.2 HLM comments: Assuming a policy diagram is included then part of the introductory text, i.e. individual masterplans / delivery plans (to be agreed with the local planning authority) and should be deleted. SWC response: The SWC at the hearing pointed out that this proposed allocation was not as advanced as SWDP45/1 but for consistency with other similar large-scale allocations, the policy reference to master planning could be deleted. Clearly that would address HLM concern about masterplans having to be agreed with the local planning authority. In 3.1 above the SWC have accepted the inclusion of the Parameters Plan as an indicative diagram within the written statement which would provide a possible indication of the disposition of land uses and transport connections within the allocation. The SWC suggest that SWDP45/2 could be amended to include a similar clause to SWDP45/1 iii.
SWDP45 A(i) & B (ii) 3.3 HLM comments: HLM no longer consider the need to revise the policy as it is dealt with in SWDP 4 and SWDP 7. Also, that infrastructure delivery is already factored into the Plan s housing trajectories and monitoring provisions. Second the revised wording reads as a commentary rather than policy. SWC response: With respect to the SWDP 4 and SWDP 7 duplication point, the SWC consider that SWDP45/1 and 45/2, due to their location and size, will have the greatest impact on the highway network and there would be serious implications for traffic congestion if development proceeded in advance of the necessary transport infrastructure to make it sustainable. With regard to the rate of delivery point, the trajectories and monitoring provision are not policy, so given the significant scale of SWDP45/1 and 45/2, the SWC consider specific wording is both appropriate and reasonable. SWDP45 (xi) 3.4 HLM comments: HLM contend that there was broad agreement with the SWC and Worcestershire County Council as the highway authority that a 60 mph spine road along the western edge of the site is not necessary to serve the planned development. Consequently, all references to a spine road should be deleted from the Plan. SWC response: SWDP45/2 currently includes the words the delivery of a spine road within the site between the A44 and the Martley Road. Furthermore, the allocation shown on the Policies Map indicates the broad alignment of a potentially policy compliant road along the western boundary. The SWC acknowledge that the detail of the Policies Map may infer a possible contradiction between it and the broad indications of land uses and transport connections indicated in the Parameters Plan. Further, the SWC accept that progress on discussions between WCC, HLM and Bloor Homes may suggest that the ultimate alignment of the required spine road may be more closely aligned to the Parameters Plan to the Policies Map. This matter however, has not been formally resolved such that the detailed alignment and associated design work is yet to be concluded. The SWC therefore
suggest that the wording of SWDP45/2 xi is subject to the following footnote: The status, alignment and design of the spine road referred to in Policy SWDP45/2 will be subject to the outcome of detailed modelling and design work to be agreed with the Highway Authority, alongside urban design and environmental considerations. In the event that the spine road follows the form identified on the policy diagram for SWDP45/2, the western boundary of the allocation will remain as shown on the Policies Map. The SWC would suggest that with the inclusion of the above footnote, the Policies Map can remain unchanged. SWDP45 (x) & (xi) 3.5 HLM comments: HLM contend that the CIL test, i.e. necessary and fairly and reasonably related in scale and kind to the development should be written into the policy. SWC response: The CIL test wording is now written into SWDP7 C and it is considered unnecessary to repeat that precise test here, particularly as it is clear that the Plan requires proportionate contributions directly related to the development. 3.6 HLM comments: HLM, in their tracked change version of SWDP45/2, agree that B(iii) should be deleted as it duplicates SWDP 15; that the retail parameters should be revised to be consistent with SWDP45/1; that the requirement for a site for Travellers is not justified; that reference to emergency services infrastructure should be deleted; and that the reference to a parking hub should also be deleted. SWC response: B(iii) does not add anything to SWDP 15 so could be deleted as it s duplication. The retail parameters, whilst different to SWDP45/1, are consistent in that 450 more dwellings and 15 ha more employment land is proposed to be allocated there. Further, for Worcester West there is already retail provision at Dines Green, which is easily accessible on foot and bicycle.
The delivery of a Traveller site at Worcester West is considered necessary given the latest evidence and the fact that it is reasonable and more appropriate to meet such needs on the larger proposed allocations; it is also consistent with the approach for SWDP45/1. The SWC still contend that there is a need for emergency services infrastructure on the largest allocations and that is reflected in the Statement of Common Ground with West Mercia Police and the Herefordshire and Worcestershire Fire and Rescue Service. The SWC agree that there should no longer be a reference to parking hubs in the Plan. 4.0 Savills A(i) 4.1 Savills comments: Savills contend that the viability evidence for this site demonstrates that 40% affordable housing is not deliverable. SWC response: The SWC point to the revised site specific policy, i.e. SWDP45/1 on affordable housing, which now says up to 40% affordable housing. A(iv) 4.2 Savills comments: Savills contend that the maximum limit for retail provision should be 3,000 sq.m. and not 2,500 sq.m. SWC response: The SWC made an earlier change to increase the size of the largest unit to 2,000 sq.m. The 500 sq.m. balance would allow for a parade of approximately 7 retail outlets which is considered appropriate for the proposed Local centre. There is no evidence to suggest that an additional 500 sq.m. is appropriate or justified. A(vii) 4.3 Savills comments: Savills contend that there is no evidence to support / justify a Significant Gap to the east of Norton Road.
SWC response: The SWC maintain that Brockhill Village / Norton Barracks is a settlement in its own right (extant Wychavon District Local Plan and submission SWDP) and is not part of Worcester. The SWC therefore agree with Norton-Juxta-Kempsey Parish Council that this rural settlement should be safeguarded as practically as possible. Given that the 40% Green Infrastructure and Significant Gap are not mutually exclusive, there is clearly capacity to deliver the majority of the proposed allocation on the available land between Norton Road and the A38. The village has only just seen the completion of 74 dwellings next to St. Peter s Garden Centre and there is insufficient justification to warrant further expansion of what is a Category 3 rural settlement (Annex D). Notwithstanding the Significant Gap issue, the SWC contend that where it can be avoided, housing development should not be located immediately adjacent to the motorway. Also, the proposed allocation includes a requirement for formal sports provision and the Significant Gap (SG) land is an appropriate location for this, as indicated on the SWDP45/1 policy diagram. Finally, the proposed urban extension will become part of the city so the proposed SG will serve a similar purpose to the M5 Corridor policy in the extant Worcester City Local Plan. A(xv) Savills comments: Savills do not support the proposed Local Green Network (now referred to as Green Space in the Plan) buffer to the west of Norton Road and that the amenity and distance separation from existing properties should be considered at the detailed design stage. SWC response: The SWC contend that the setting of Brockhill Village / Norton Barracks settlement should be afforded reasonable protection in the Plan. The proposed Green Space buffer will not stop neighbouring communities from integrating, especially given the proposed main cycle / pedestrian link. In any event, the SWC consider that the most important visual connection to be secured in the Plan is that between the proposed urban extension and the city itself.
5.0 Pegasus Group on behalf of Robert Hitchins Ltd (RHL) SWDP45/5(i) 5.1 RHL comments: RHL support the amendment with regard to the affordable housing requirement, i.e. up to 40%. SWC response: The SWC agree that the revised wording is appropriate. SWDP45/5(v) 5.2 RHL comments: RHL contend that, as worded, there is a requirement for and entirely new vehicular access off Swinesherd Way. SWC response: The SWC agree that the word new is superfluous as the important matter is that the principle access is directly off the A4440 and, of course, to the satisfaction of the local highway authority. SWDP45/5(viii) 5.3 RHL comments: RHL contend that, as worded, the policy prioritises certain types of infrastructure over others. SWC response: The SWC disagree that this is the case and by using the word including it is clear that this is not an exhaustive list of infrastructure. As none of the cited infrastructure requirements are unique to this proposed allocation the proposed RHL wording is acceptable. 6.0 Planning Prospects on behalf of St. Modwen Developments (SMD) SWDP45/1(i) 6.1 SMD comments: SMD are concerned that the rate of delivery is dependent upon the implementation of elements of the Worcestershire Transport Strategy (WTS) to the west of the Ketch roundabout.
SWC response: The SWC consider that the wording, as currently drafted, is appropriate. Clearly the more the immediate highway infrastructure is improved the greater the likelihood of increased delivery. Of course the WTS is not simply about roads and other aspects of it need to be implemented in a timely fashion in order for development to be sustainable. SWDP45/1(ii) 6.2 SMD comments: SMD consider this to be unnecessary as it is covered elsewhere in the Plan. SWC response: The SWC agree that SWDP45/1(ii) does not add anything to SWDP 14, or SWDP 15. SWDP45/1(xi) 6.3 SMD comments: SMD contend that the requirement should only refer to part dualling of the A4440. SWC response: The SWC disagree, as the intention is eventually to dual the entire length of the A4440, albeit over several phases, not all of which are necessary in this Plan period. SWDP45/1(xv) 6.4 SMD comments: SMD contend that the requirement for SuDS duplicates SWDP 29. SWC response: The SWC agree. 6.5 SMD comments: SMD contend that the aims of this part of the policy are not cumulative. SWC response: The SWC agree that Green Infrastructure / Green Space can perform multiple functions. South Worcestershire Councils 6 July 2015