To: Head of Planning, Wychavon District Council
Date: 04.04.2013
From: Natasha Friend, Principal Planner
Subject: Consultation from Wychavon District Council in respect of land
including Gwillams Farm, Ombersley Road, Bevere
Recommendation: that these comments are taken into account in the
determination of this application
Summary of Worcestershire County Council response: In respect of the
departments contributing to this advice (namely Strategic Planning and
Environmental Policy, Waste and Minerals Planning, Education, Worcestershire
Archive & Archaeology Service and Countryside Service), Worcestershire
County Council officers have no objection to this proposal. The comments of
contributing departments referred to below are intended to help improve the
sustainability of the proposal and to direct the applicants towards best practice.
Any departments not included within this response may choose to comment
and/or object separately.
Application No: W/13/00347/OU
Location: Land including Gwillams Farm, Ombersley Road, Bevere
Proposal: Outline application for residential development for up to 230 dwellings
and new farm shop, including public open space, footpaths and associated
works.
Introduction
Thank you for consulting Worcestershire County Council on the application
above. Please find below officer comments made under delegated powers.
To create a more streamlined, joined-up approach to infrastructure, the county
council has developed a protocol for all relevant Worcestershire County Council
(WCC) departments to contribute to a single response in respect of planning
applications and policy consultations.
This single joined-up county council response will:
Natasha Friend
Principal Planner
Business,
Environment and
Community
Directorate
County Hall
Spetchley Road
Worcester
WR5 2NP

set out County Council infrastructure expectations, should the application
be approved.
Tel 01905 766719Fax 01905 766498Minicom (01905) 766399DX 29941 Worcester 2
NFriend@worcestershire.gov.ukwww.worcestershire.gov.uk
Document2
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advise how far the application generally conforms to County Council's
priorities as set out in its strategies and plans, including the Corporate
Plan; and
highlight any specific areas of planning concern/support arising from the
application proposal, such as potential conditions and phasing
requirements.
This response comprises officer only comments from Strategic Planning and
Environmental Policy, Waste and Minerals Planning, Education, Countryside
Service and Worcestershire Archive & Archaeology Service, however, does not
include any comment from WCC's Highways department, who will respond
separately. .
Infrastructure Expectations
Landscape
Most of the site is elevated flat agricultural land on the northern border of
Worcester. It has been identified as Landscape Type Settled Farmlands on River
Terrace by the County Landscape Character Assessment but the landscape of
the site is in a degraded condition with few of the characteristic features
surviving. The site lies adjacent to the Bevere Conservation Area along its
western and northern boundaries. The western part of the site relates visually to
the Conservation Area and the assemblage of buildings and trees related to the
historic park and gardens of Bevere House and Bevere Manor. This is an
important historic designed landscape which also incorporates Bevere Green
and is one of the few intact historic designed landscapes in the immediate
vicinity of the City. It is closely associated with Dr. Nash who lived at Bevere
House and with Anthony Keck who carried out various architectural
improvements in the 18th century. The western part of the site is therefore
particularly sensitive in historical and visual terms. The northern part, bordering
the lane (also Conservation Area) is also sensitive. Although the proposed
development does show open green space along the north-western boundary, it
is not considered sufficient to provide an adequate buffer and landscape screen
to the Bevere Conservation Area. Additionally, the built development is shown as
extending through to Northwick Road along the south-western site boundary.
Although the land on the other side of this lane is not in the Bevere Conservation
Area, it is part of the "bosky" setting that contributes to its character. We
consider that development so close to this road will compromise the setting of
the eastern part of the Conservation Area.
We recommend that the Applicant is requested to increase the open green
space along the western boundary, removing the built development shown
adjoining Northwick Road.
Public Rights of Way
The development currently proposed and illustrated on the Indicative Masterplan
No.B5165 will affect two Public Rights of Ways (PROW) as recorded on the
Definitive Map and Statement for Worcestershire (relevant date 31 March 2005):
Footpath NC-511 passing along the north western boundary and Footpath NC-513
following the north eastern boundary of the development site.
It is understood that there is no intention to disturb these footpaths but to retain them
in their current position and incorporate them within land designated 'green
corridors', a network of pedestrian access and Public Open Space provision, as
illustrated on the Masterplan. Where existing PROWs are incorporated into a
development and also where new ones are proposed, the following principles should
be included in the design stage, to reduce the potential for conflict between path
users and residents:

Ensure routes are direct, well-lit, open and clear of hiding places;

Set routes in a landscaped areas to avoid potential nuisance to neighbouring
properties and if possible keep routes away from sides and rear of
properties;

All routes should be surfaced with appropriate materials and constructed to a
specification sufficient to cope with anticipated levels of public use.

Where a route is designated a shared pedestrian/cycleway, ensure It is of
sufficient width to accommodate both cycle and pedestrian use in safety.

If it is intended to enclose by fencing, hedging or buildings any part of the
proposed network of routes, it is strongly recommended that the Countryside
Service Access Team is consulted for advice on the width to be retained for
public access. As a general rule, the Countryside Service refers to the
Rights of Way Review Committee Practice Guidance Notes No.6 [Planning
and Public Rights of Way S.1v. para. 8] and so would require a minimum
width 4 metres and with a desired width of 5 metres.

Should it subsequently prove necessary to divert PROWs (or parts of them)
this should be completed before any development affecting them is started.
Application to divert should be made to the planning authority, although
advice and guidance concerning public access, including detailed
specifications and the legal requirements for diverting public rights of way, is
available from the Countryside Service Access Team.
New housing development can often lead to significant additional use of PROW in
the vicinity of the development area. This additional use can cause problems if
PROWs are, for example, unsurfaced and have not historically carried large
volumes of users. In these cases the Countryside Service may assess the impact
of the development on the wider PROW network and may seek financial
contributions from developers to make improvements to accommodate additional
public use.
Flood Risk and Drainage
These comments represent those of Worcestershire County Council as the Lead
Local Flood Authority (as determined by the Flood and Water Management Act
2010) and are officer comments only. Full details of Worcestershire County
Council role as the LLFA can be found in appendix 1.
Summary
In general we support the principle of attenuating run-off onsite and utilising
SuDS measures. We would however welcome further consideration of the
concerns identified below namely the use of surface levels SuDS rather than
geo-cellular storage and the design of ponds to include opportunities for
biodiversity enhancement such as reed beds.
Detailed comments
The principle of achieving nil run - off to surroundings via the use of multiple
source control measures is welcomed. We also welcome inclusion of the
proposed infiltration basin and treatment swale and the opportunities these may
present for improvements in water quality.
While we note in paragraph 3.2.14 that discussion has taken place with the
Highways Authority and the Wychavon District Council Landscape Team. We
note the absence of any evidence of correspondence or pre-application with the
South Worcestershire Drainage Partnership officers or indeed the LLFA.
This omission may be in error however given the roles outlined above we would
welcome further clarification of these discussions.
As part of a multifunctional approach to green infrastructure and opportunities for
biodiversity again and habitat connectivity we would welcome the inclusion of
reed beds and other appropriate habitats as part of the infiltration basins.
With reference to the proposals to drain the roads shown in red to a cellular
storage and infiltration structure located beneath an area of public open space.
Given the significant proposals for open space provision in the north of the site
and through the central spine, we would question the reason and justification for
utilising geo-cellular storage in this location. The provision of SuDS at surface
level could help enhance the provision of green infrastructure and landscape
connectivity whilst also improving the aesthetic value of the public realm. We
would therefore request consideration of introducing a pond or basin feature in
this location.
Paragraph 3.1.3 - states that "the existing farm shop will be retained in its
current position". However, it is our understanding that the existing farm shop is
to be replaced as part of the development proposals as indicated in the
submitted masterplan proposals. We would welcome further clarification on this
matter and any proposals to address drainage and surface water management
related to it.
The South Worcestershire Water Cycle Study identified that "water resources
are scarce within the region. Catchment Abstraction Management Strategies
produced by the Environment Agency show that the surface water and
groundwater in the study area is either being over-abstracted or there is no
water available for further abstractions."
And
"Severn Trent Water predict a net increase of approximately 31Megalitres/day
(Ml/d) in water consumption from 2006 – 2035 in their Severn Water Resource
Zone. The supply/demand balance for the zone became negative in 2006/2007.
The current projected supply/demand shortfall is around 120Ml/d by 2035, taking
into account the effects of climate change. This shortfall will arise if no further
investment was made to leakage reduction, demand management and resource
development."
Whilst we welcome the inclusion of measures to enable infiltration of surface
water and the proposals to introduce water butts on properties. Given, the
findings of the WCS we are disappointed to note the submitted conclusion that
water capture and water recycling are not suitable for the proposed residential
dwellings.
With regards to water management and addressing issues of water stress we
would welcome the identification of opportunities for water capture and recycling
associated with the farm shop.
Waste and Minerals
Minerals
The application site is within an identified aggregate deposit. (See County of
Hereford and Worcester Minerals Local Plan Proposals Map). Saved Policy M.2
of the Worcestershire Structure Plan is therefore relevant to the consideration of
this application.
"Safeguarding Deposits Policy M.2
Known mineral deposits will be safeguarded as far as possible. Proposals for
development which would sterilise them or prevent them being worked will be
resisted unless:
(i) it can be demonstrated that no workable deposit exists; or
(ii) the mineral is extracted prior to the commencement of the proposed
development; or
(iii) extraction is not possible without unacceptable effects on the environment."
The Council is not aware of any information provided by the applicant that
address these points. More information is therefore required to assess whether
this application is in accordance with this policy in the development plan. If you
wish to discuss this further please contact Nick Dean, Minerals and Waste Policy
Manager (01905) 766374.
Waste
It is noted that Section 5 of the Planning Statement outlines the development
plan but makes no reference to the Waste Core Strategy which is part of the
adopted development plan in Worcestershire. Policy WCS 17 is relevant to the
consideration of this application.
"Policy WCS 17: Making provision for waste in all new development
Proposals for new development will be permitted where:
a) they incorporate facilities into the design that allow occupiers to separate and
store waste for recycling and recovery; or
b) developer contributions are made, for proposals where this is more
appropriate than provision of on-site facilities; or
c) the existing provision is adequate."
The reference to "Provide facilities to recycle and compost household waste,
reducing the amount of household waste sent to landfill" and to "Implement an
element of construction waste reduction or recycling" in the Sustainability section
of the Design and Access Statement is welcomed.
The Design and Access Statement states that "Each dwelling will have access
for wheelie bins to be collected from driveways via the adopted road. In
courtyards, shared surfaces and some private drives or lanes, wheelie bin
collection points are built into the streetscape within 30m of dwellings. Collection
points will be located so that they are within 25m of the waste collection vehicle".
If this includes facilities for the separate storage of waste for recycling this would
be considered to be accordance with policy WCS17, however further information
should be sought to clarify if this provision will be made.
Archives and Archaeology
The County Historic Environment Record shows that this application affects or may
effect a heritage asset or area of archaeological potential (WSM11379). The 'historic
environment' encompasses all those material remains that our ancestors have
created in the landscapes of town and countryside. It includes all below and aboveground evidence including buildings of historic and architectural interest.
In line with comments made for the previous (withdrawn) application, we advise that
further information in the form of an archaeological field evaluation is required. The
site contains known buried archaeological remains, the significance of which have
yet to be established. We advise that either a total area geophysical survey
augmented with targeted evaluation trenching, or a 4% grid array of evaluation
trenching be undertaken in order to provide sufficient information to be able to
determine the outline application.
In line with government policy given in the National Planning Policy Framework,
(paragraph 128), it has been demonstrated that the proposed development area will
affect a known heritage asset and that further information on the nature, extent and
significance of any of that asset, and the potential impact of the proposed
development on said asset is required before this application can be determined.
"Where a site on which development is proposed includes or has the potential to
include heritage assets with archaeological interest, local planning authorities
should require developers to submit an appropriate desk-based assessment
and, where necessary, a field evaluation."
In this instance it is advised that a field evaluation, as required under paragraph
128 of the NPPF, should be provided before this application can be determined.
Please Note: A fee will be charged to the applicant for the formal provision of
archaeological briefs, and for the checking and acceptance of Written Schemes of
Investigation and Archaeological reports required by the local planning authority.
The applicant or their successor in title must contact Worcestershire Archive &
Archaeology Service to arrange provision of the brief as soon as possible.
Worcestershire Archive & Archaeology Service will be able to provide details of the
fees payable. It will be the applicant’s (or their successor in title) responsibility to
contract an appropriate archaeological organisation to undertake the programme of
works as detailed in the brief.
Education
Children's Services will be seeking an education contribution in line with our
current policy. The contribution will be calculated on the basis of the following
cost per dwelling from the 2012/13 table of charges:
Primary
School
Claines
CE
Primary
Middle
School
High
School
Tudor
Grange
Academy
1-bed
contribution
£0
2-bed
contribution
3-bed
contribution
4+-bed
contribution
Flats
Social
Housing
£2,119
£2,119
£3,179
£848
£0
The contribution will be used to fund capital projects in schools local to the
development.
Concluding Remarks
WCC does not object to the principle of development in this location, subject to
acceptable resolution of the issues identified above, namely that more
information is required. It is worth noting, once again, this response is officer
only comments and does not include any comment from WCC's Highways
department, who will respond separately.
Yours sincerely
Natasha Friend
Principal Planner
Appendix 1
The Flood and Water Management Act (FWMA) delegated upper-tier and unitary
authorities as Lead Local Flood Authorities (LLFA) with responsibility for their
respective area's Local Flood Risk Management. Worcestershire County Council
is therefore the LLFA for Worcestershire. This role currently relates to ordinary
watercourses, surface water and groundwater flooding (fluvial flooding from main
tributaries is still currently the responsibility of the Environment Agency).
As LLFA for Worcestershire, the County Council needs to ‘develop, maintain,
apply and monitor’ a Local Flood Risk Management Strategy (LFRMS). The
Strategy will focus on local flood risk due to flooding from surface water,
groundwater and ordinary watercourses and must be consistent with the
Environment Agency’s National Flood Risk Management Strategy for England.
Work is currently ongoing by the County Council and partners in developing the
Worcestershire Local Flood Risk Management Strategy.
There are a number of organisations with statutory roles and others with an
interest in local flood risk management. Relevant organisations are required "to
act consistently with and/or have due regard for the strategy" and have "a
duty to exercise their flood risk management functions in a manner
consistent with local and national strategies, and to have regard to those
strategies in their other functions".
The Act defines various bodies as Risk Management Authorities (RMAs):

The Lead Local Flood Authority;
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The Environment Agency;
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District or Borough councils;
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Internal drainage board;

Water companies;

The Highway Authority.
The FWMA has also delegated a number of other statutory powers and duties
extending their previous responsibilities for flood risk management, including:

Powers to request information from any person in connection with the
authority's flood and coastal erosion risk management functions;

A duty to investigate and publish reports on flooding incidents in its area
(where appropriate or necessary) to identify which authorities have
relevant flood risk management functions and what they have done or
intend to do;

A duty to maintain a register of structures or features which have a
significant effect on flood risk in their area, in the view of the lead local
flood authority;

Power to do works to manage flood risk from surface runoff or
groundwater;

Power to designate structures and features that could affect flooding and
are considered to be significant when assessing local flood risk;

A duty to establish a Sustainable Drainage Systems (SuDS) Approving
Body (SAB) with responsibility for approval of all drainage plans and the
adoption and maintenance of SuDS that serve more than one property in
new developments (implementation expected by October 2013);

Following commencement of paragraphs 32-34 of Schedule 2 of the
FWMA on 6th April 2012 transfer has been made of the regulatory powers
(consenting and enforcement) on Ordinary Watercourses from the
Environment Agency to LLFAs (internal drainage boards will still have this
role on ordinary watercourses in their system). As permitted by the
FWMA, a number of statutory functions of the LLFA have been delegated
to the District Drainage authorities. For South Worcestershire this is the
South Worcestershire Drainage Partnership. This currently includes the
ordinary watercourse consenting function.
Applicants are advised to enter into pre-application discussions with the LLFA
and (in this instance) the South Worcestershire Water Drainage Partnership to
discuss any localised flooding issues.