To: Head of Planning, Wychavon District Council
Date: 12th April 2011
From: Head of Strategic and Environmental Planning, Worcestershire
County Council
Note: Officer Comments made under delegated powers
Subject: Consultation from Wychavon District Council In Respect Of
Development of three sites at Bevere.
Recommendation: that these comments are taken into account in the
determination of this application
Background
An area of land to the North of Worcester City, off Ombersley Road, Bevere is
currently subject to two planning applications, with a third to cover the remaining
area of land is expected shortly.
The first application is by Bellway (West Midlands) Ltd for:
"Proposed construction of 115 dwellings, new access and associated works" at
Land Adjacent, Firs Farm, Ombersley Road, Bevere.
The second application is by Cala Homes (Midlands) Ltd and Mr & Mrs N.
Gwillam for:
"Outline planning application comprising a residential development of not less
than 209 dwellings (including 77 affordable dwellings0; and public open space;
together with associated roads and parking, drainage, renewable energy, with
main vehicular access from Ombersley Road (all matters apart from access are
reserved)" at Gwillams Farm Site, Ombersley Road, Bevere.
Worcestershire County Council is a formal consultee in the process and is not
engaged in determining the application.
Summary of County Council Comments (detailed comments are included at
appendix 1).
Although the development site has been split into three separate plots, with
proposals being submitted by different developers, Worcestershire County
Council's comments cover the site in its entirety. It is recommended the various
applications should be considered in relation to each other to enable the
development of the whole site be undertaken in a comprehensive, integrated and
holistic manner.
The following paragraphs summarise Worcestershire County Council's response,
detailed comments are included as supplementary material.
Landscape and Biodiversity
There are no landscape objections in principle to the development of the site as,
although elevated, the site is not particularly visually prominent. There are a
number of detailed design issues that could be improved which are outlined in the
detailed comments.
The developers have not demonstrated how they have approached biodiversity in
a consistent manner and in doing so have failed to consider issues of
interconnectivity and movement between plots. As a consequence, the applicants
fall short of opportunities to maintain and enhance biodiversity across the site and
have missed opportunities to work collaboratively to deliver maximum benefit as
promoted by the Government's objectives and principles outlined in PPS9
(including para 12 on Networks).
Archaeology
The proposed development affects a site of archaeological interest and lies within
an area rich in prehistoric and Romano British remains. Worcestershire County
Council therefore request that a Historic Asset Evaluation is provided before the
application is approved (in line with PPS5, policy HE6.1).
Transport
Worcestershire County Council has had pre-application discussions with the
developer of the sites concerning the traffic impact, during which it was
recommended that they use the Worcester Transport Model in order to complete
the Traffic Assessment.
The TAs accompanying both applications do not adequately demonstrate that the
traffic modelling and the strategic impacts of the development have satisfactorily
been completed for the sites. There remains significant missing information on
the impact the development will have on the highway network and a lot more
work is required from the developers to provide the development is deliverable in
a sustainable manner. It is recommended that the developers should liaise with
Worcestershire County Council and the Highways Agency to agree an approach.
Attention needs to be given to how the highway layout between phases can be
better integrated, to enable the comprehensive development of the whole area.
Education
Worcestershire County Council will apply the standard table of charges to the
applications for a financial contribution towards education provision. Claines CE
Primary is the catchment primary school and is full and predicted to continue to
be so. There there is a lack of spaces in other local primary schools. The
Secondary catchment school is Tudor Grange Academy and Bishop Perowne CE
College is not far away. There is less concern about a lack of secondary spaces.
Figures for contributions have previously been submitted to Wychavon DC
directly from the education department of Worcestershire County Council.
Concluding Remarks
Worcestershire County Council does not object to the principle of development in
this location, subject to satisfactory s106 contributions and resolution of the
issues identified. However, it is strongly recommended that the three plots
forming the wider development are more fully integrated in terms of biodiversity,
green networks and transportation. This would enable the more comprehensive
development of the area to be undertaken.
Appendix 1
Detailed Comments
Landscape
This Application is for development on the south-eastern quadrant of a larger site
that is subject to future Application. It should therefore be considered in relation
to the development of the site as a whole and I would recommend that the
various Applications are determined in relation to each other.
Most of the greater site is elevated flat agricultural land on the northern border of
Worcester. Although elevated, the Application site is not particularly visually
prominent except from the adjacent Ombersley Road and Green Lane. 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.
Development on the Application site would relate visually and physically to the
existing urban framework and would not be visually intrusive from the
surrounding countryside or from the Bevere Conservation Area. There are
therefore no landscape objections in principal to development on this site.
Notwithstanding this, there a number of detailed design issues that could be
improved and I would recommend that the developer is required to re-consider
the proposed layout in order to:
a) Improve the spatial arrangement of dwellings and road layouts
b) Improve the play and open space provision
c) Increase the tree planting in shared areas
d) Remove trees planted in back gardens where they will be vulnerable to
removal or neglect and where they will not contribute to public amenity
e) Increase the proportion of local native species in shared areas.
Biodiversity
1. On considering the site as separate blocks the developers are not consistent
with the approach advocated by the Worcestershire Sub-Regional GI steering
group. Biodiversity is one of the key elements of green infrastructure, and should
have been considered as a part of the GI of the whole development sites. The
survey and recommendations as currently undertaken for individual development
plots fails to consider issues of interconnectivity, movement between the plots
and take the advocated whole site approach. As a consequence of this, all the
applicants fall short of opportunities to maintain and enhance biodiversity across
the whole sites (one of the key GI principles) and as such are missing
opportunities to work collaboratively to deliver maximum benefit.
2. There are significant differences in the survey effort between the two
applications. The ecological survey submitted by Bellway represents minimal
survey effort and there are significant issues which have not been addressed.
a. The extended phase 1 survey was undertaken in January 2011. It is
acknowledged within the documentation that this is a sub-optimal time of
year for survey, and will have meat that they have relied of vegetative
species identification. Depending upon the skills of their surveyor, there is
a high likelihood of important grassland species being missed or
overlooked with this method. This should be supplemented by a survey at
the appropriate time of year, to judge more accurately the quality of the
grassland.
b. A Bat survey was undertaken in January, looking for signs of roosts and
assessing the potential of the trees to support bats and their roosts. This
is not supported by any proposals to undertake any bat transects, to
understand the potential movement patterns across the site of foraging or
commuting bats which would be expected as a part of this applications.
Without this information it is not possible to assess the impact of the
proposals on the biodiversity of the sites or impact of, for example,
hedgerow removal.
c. No reptile surveys were undertaken. Worcester City is known hotspot for
slow worms and a reptile survey would be expected to confirm their
presence / absence on this site.
3. Badgers are present across both of the development sites, which represents
licensable activity to temporarily or permanently close a badger site.
4. CALA homes have undertaken a more comprehensive ecological survey,
including habitat surveys at the correct time of year, bat transects and hedgerow
classifications. This does need to be supported by an Ecological / Conservation
management plan, which outlines the long term management of the
greenspaces areas on the site including their proposals to create areas of
species rich grassland. We welcome proposals to maintain the majority of the
hedgerow network on the site, as apart of the design and landscaping. .
5. Although reptile surveys have been undertaken on the CALA sites and no slow
worms were found, we would recommend that a precautionary approach is taken
with regard to their presence, and that proposals for mitigation are considered,
as slow worms are frequently under recorded and missed in surveys. In a similar
way we would also recommend a pre-cautionary approach to the presence of
great crested news, given the proximity of ponds to the site, the HIS score of one
within 200m and the potential for newts to be using the hedges etc on site for
foraging etc.
6. We welcome the use of SUDS on the CALA homes site, but would like to see
consideration of this for biodiversity. We would also recommend that the SUDS
system is considered as a part of the wider green infrastructure for the site,
potential to contribute to a wildlife corridor between site and the surrounding
landscape. This could also have a recreational function, in which case
consideration needs to be given to ensuring that suitable buffers and widths are
maintained to ensure multi-functionality.
Archaeology
I have checked the County Historic Environment Record and this application affects a
site of archaeological interest (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 above-ground evidence including buildings
of historic and architectural interest, whether designated or not.
The Planning Advisory Section have been liasing with the developer via their
archaeological consultants regarding this proposed development. Given that the
intention was to submit an outline application, it was agreed that the desk based
assessment would suffice as providing sufficient information at this stage. However
this outline application is now accompanied by a detailed master plan upon which the
application will be based. Therefore while the detail may be left as reserved matters,
the layout appears to be up for determination at this stage.
Therefore it would be inappropriate to undertake the field evaluation as condition of
outline consent as this would negate the concept of preservation in situ. Therefore,
given the known occurrence of archaeological remains on site I advise that prior to
determination a programme of archaeological field evaluation should be carried out.
In line with government policy given in Planning Policy Statement 5: Planning for
the Historic Environment (Policy HE6 – HE9), it has been demonstrated that
further information on the nature, extent and significance of the heritage asset or
potential asset, is required. Therefore a Historic Asset Evaluation, as required under
HE6.1 of the above document, should be provided before this application can be
approved.
Please Note: From January 1st 2011, fees 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 the officer
below to arrange provision of the brief as soon as possible.
As a guide the following table shows the breakdown of fees payable
Task
Large Dev
Provision of Archaeological Brief
Assessment of WSI
Assessment/approval of Archaeological Mitigation Report
£120.00
£30.00
£120.00
Total Cost
£270.00
Addition cost if site meeting required (per hour)
£60
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.
Transport
The Network Control Manager, on behalf of the County Council, under Article 10 of
the Town and Country Planning (General Development Procedure) Order, 1995:Recommends that the permission be deferred so that the developer can address the
following issues;We have had pre-applications discussions with the developer concerning the traffic
impact the development will have on the wider Highway network and had
recommended that they use the Worcester Transport Model (WTM) in order to
complete the assessment.
The TA accompanying the application does not adequately demonstrate that the
traffic modelling and the strategic impacts of the development have satisfactorily
been completed for the site, evidence of mitigation measures have also not been
identified. Furthermore, the TA does not include a sufficiently evidenced accessibility
assessment of how mode shares can be achieved.
Having undertaken our own assessment of development impacts on the highway
network it is obvious that there remains a significant piece of the "TA Jig-saw"
missing, with a lot more work required from the developer to prove that this
development is deliverable sustainably and with nil detriment on an already
congestion local and strategic highway network.
It is recommended that the developer should now liaise with WCC and Highways
Agency to agree further assessment requirements including both a WTM assessment
and an Accessibility assessment.
The developer should also investigate methods of increasing the mode shares of
walk, cycle and passenger transport. This will include methods of further improving
the accessibility and journey time and cost competiveness of these modes of
transport. There is also a need to consider additional priority measures outside of the
development to further improve journey times and reliability.
Detailed discussions should also be held to ensure that an effective travel plan is
agreed once the outputs of the strategic assessments have been reviewed. Should
the developer fail to satisfactorily completed these assessments, then the Highway
Authority will recommend this application be refused on grounds that the traffic
generated by the proposals have not been proved to be non-detrimental to the local
and strategic highway network.
Furthermore, the proposed highway layout does not allow the best access options for
the adjacent phase, and should therefore be re-designed in consultation with the
Highway Authority to allow better integration between the two phases and the
subsequent phase, to enable a comprehensive development of the whole area to be
undertaken.