Mr. Neil Pearce
Planning Officer
Wychavon District Council
Civic Centre
Queen Elizabeth Drive
Pershore
WR10 1PT
Dear Sir
APP REF: 13/00347 – PROPOSED DEVELOPMENT AT LAND OFF OMBERSLEY ROAD,
BEVERE
I write in connection with the above planning application, which we understand is
currently being determined.
I wish to register a strong objection to the application for the following main reasons:
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The application contains too many new homes in this location and the application
has not taken adequate account of the sensitivity of the site surroundings.
The masterplan is not coordinated, simply submitting an application jointly has
ultimately not resulted in a holistic design.
The application has been made at a time when we believe Wychavon are close to
having a 5 year housing land supply and therefore should not need to approve
such a strategic proposal prematurely, and certainly not before the SWDP is
examined in public this summer.
The context set by conservation and heritage issues associated with the Bevere
Conservation Area and a number of key Listed Buildings within it have still not
been properly considered.
I feel that the proposals are therefore unsustainable and not in accordance with Paragraph
14 of the NPPF.
1.
Too many new homes
The application seeks to provide 228 new homes on this site which is considered to be
disproportionate in this location. Previous submissions to the emerging SWDP show that there is
a strong case for a smaller development, with numbers at around 68 units. This work was
undertaken at the request of the local community group, Bevere Development Opposition Group
(BDOG), by professional advisors, Paul Walshe Associates, and proposes a balanced approach to
the development of the site taking into account the specific constraints of the site.
I also feel that the application has not taken full account of the utilities constraints, such as
overhead electricity pylons and underground gas pipes which cross the site and require zones
within which no development can take place.
2.
Uncoordinated masterplan
The application still relates to two sites in disparate ownership as a grouping of sites. The two
areas do not even share a contiguous boundary and the proposals still feel like a ‘square peg in a
round hole. I still feel, having made this point repeatedly beforehand, that the application is very
uncoordinated and has failed to achieve a holistic approach by the developers and landowners
working together. Essentially, the masterplan reflects existing land ownerships and fails to
integrate the proposed development with good connections from all parts of the development to,
for instance, the different areas of public open space and proposed play areas. Because of this lack
of connectivity, the masterplan does not provide a coherent green infrastructure plan, is not
permeable and segregates the developments into two distinct parts, for no good reason.
As the third landowner is not part of the consortium, the large area of land outside of the scheme
further jars with the proposals, leading to a horseshoe development, which again does not connect.
This area presents significant unknown elements in terms of quantity of proposed development
and it is unclear how the proposals might integrate this area successfully. It would have been
useful for the consortium to have at least shown an indicative layout for this area, integrating with
the rest of the proposals. Again, because of this, the scheme could consist of a series of missed
opportunities because of the piecemeal nature of the proposals.
The application has failed to provide both pedestrian and vehicular linkages within the site to
connect both pieces of land which are to be developed by Cala Homes and Bellway Homes. Each of
the separate sites provides differing access points which further adds to the disjointed and
disconnected flow of proposed development.
The application lacks a proper awareness of its context and fails to contribute positively to its
immediate surroundings. The indicative layout could be for any housing estate anywhere in the
country. Important vista lines do not run through the site, due to the differing areas of ownership
and the buffer zones to existing properties being inadequate.
3.
Five year housing land supply
Wychavon are close to achieving a five year housing land supply (plus 20%) given the amount of
development which has recently been approved within the District. I therefore consider that the
application is now premature, in that no decision has yet been taken on whether there should be
development on this site. Indeed, the South Worcestershire Development Plan (SWDP) is still to
go through the examination stage this summer. Given the progress of the plan since the last
planning application on this site and the progress made by the emerging SWDP plan, I see no
reason why a strategic site such as this should be required by Wychavon to meet housing numbers
that would in any case not be forthcoming for some time - the application is outline, a further
reserved matters application would be required along with a signed S106 before development
could commence.
In the planning statement the applicant’s agent states that there is a continued 5 year housing land
supply issue in Wychavon. In response to this situation the District Council has, over the last 9
months, granted a significant number of planning permissions for new residential development
throughout the District, which I believe has made a significant difference to the 5 year housing
land supply for the District.
The applicant argues that notwithstanding the 5 year housing land supply situation in Wychavon,
the global housing figures for each of the SWDP districts should be revised upwards anyway. This
is not relevant to the determination of this application. It is clear, regardless of how many new
homes need to be provided in the District to 2030, that this particular site cannot accommodate
over 200 new units, as proposed, because of the context within which those development
proposals are set.
The applicant does not make any comment about the additional pressure that has already been
put into Worcester and Wychavon by Malvern Hills DC, where they have chosen to deflect a third
of their housing target into the neighbouring districts. It may have assisted Wychavon somewhat,
if they were not having to take some of this requirement, thereby putting pressure on sites such as
the land at Gwillams Farm to deliver numbers that were well in excess of realistic site capacity.
Given the question marks over global housing numbers and whether or not Wychavon remain
overly exposed in planning terms with a lack of 5 year housing land supply, I would urge officers
to delay making a decision on this application until receipt of the Inspector’s report into the SWDP
is released. This would at least give an opportunity for the proposals to be examined within a
wider context and establish the true capacity of the site, based on evidence from all parties, not
just that of the applicants.
If the applicants were to appeal on non-determination grounds, I suspect that any appeal outcome
would not be forthcoming until after the examination of the SWDP in any case.
4.
Conservation and Heritage issues
The application presumes that any development here will be an urban extension to Worcester.
However the nature of the development, in terms of whether it should be seen as a new rural
settlement set down in the countryside surrounding Worcester or an urban extension of
Worcester, is still to be agreed.
The application has failed to recognise that the two existing properties in the middle of the
proposed development need to be provided with a buffer zone. Furthermore, the buffer zone
between the proposed development and the Conservation Area of Bevere is too small and does not
even align with the building line on the adjacent Northwick Lane.
The application’s intention of treating the buffer zone between the proposed development and
Bevere Conservation Area as a semi-urban park is unacceptable as this will create an urban link
between the development and Bevere and in effect bring Bevere within an urban extension to the
City of Worcester, damaging it. It is clear that the buffer zone between Bevere and any
development on the Gwillams Farm site should remain in agricultural use (and therefore be of an
economically viable size) in order to retain the distinctive rural setting of Bevere as a ‘rural
settlement’; and agricultural land classified as Grade 2 that SWDP policies seek to preserve.
The proposed development does not ensure that the two public footpaths on Gwillams Farm site
linking north and south Bevere and Bevere to Claines remain a rural experience with views of the
two Conservation Areas and of the Malvern Hills. The application further needs to recognise that
the site borders the A449, which is the northern gateway to the city, where the view through to the
Malvern Hills is considered important.
I consider that the application fails to respect and retain the historic visual corridor between
Bevere and Claines. In addition, the application needs to show greater regard for the site’s historic
assets including the characteristic holly hedge which form visually distinctive boundaries to, and
within, the site.
Summary
In summary, I wish to lodge a strong objection to the proposed development. The application has
not adopted a holistic and coordinated approach to producing a masterplan for this proposed
development and that the proposals are for too many new homes within this sensitive location.
The approach has been entirely dictated by land ownership boundaries and the masterplan does
not show linkages for pedestrians or vehicles across the site. The third landowner’s lack of
participation in this application demonstrates the fact that the coordination of the delivery of this
site will be difficult. The masterplan has been developed for some of the proposed site, but misses
out on the land in its centre, creating a strange horseshoe shape, which makes very little sense in
urban design terms.
Wychavon are close to achieving a five year housing land supply (plus 20%) and as such the
determination of the application is premature particularly given that it is a strategic site which
should be considered once the SWDP has gone through the examination process. Arguing that
more housing should be provided within the District as a whole is irrelevant as this site can only
accommodate so much development.
The developers have not fully considered or assessed the historic or heritage assets which
surround the site. The local community group, BDOG, have gone to great lengths to explain the
constraints on this site and the need to retain a rural feel to any development proposed in this area
as a result. This appears to have been ignored by the applicants.
I am opposed to the development of this site. However, if the Council are minded to grant the
application, it must seek to conserve the site’s rural nature and be planned as a new rural
settlement physically separate from the northern edge of Worcester.
I trust that these comments will be taken into account accordingly when deciding the application.
Yours Faithfully,
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