Responses to the South Worcestershire Development Plan Review (SWDPR)

Worcester Civic Society has responded at each key stage of the South Worcestershire Development Plan Review. Our aim throughout has been to support sustainable growth while protecting Worcester’s character, historic environment, and overall vitality, and ensuring that infrastructure and services keep pace with development.

This page sets out our responses chronologically, explains what each stage means, and summarises our key issues.

1) Preferred Options Stage (December 2019)

What this stage means

“Preferred Options” is an early (pre-submission) stage where councils set out the direction of travel: the emerging strategy, draft policies, and potential site options. This is when it is easiest to influence the Plan’s approach before it becomes fixed.

Our key messages at this stage (WCS response dated 16.12.19)

You raised four main topic areas:

A. Housing, employment, retail and Worcester allocations

• Support for focusing major housing around rail hubs, but only if infrastructure and services are delivered early, including community facilities and hospital capacity.
• Strong emphasis on maintaining settlement separation (avoiding places merging), including the need for a defined “significant gap” around Rushwick.
• Support for higher densities in principle, but warning that Conservation Areas and limited road capacity mean density policies must be applied carefully.
• Support for 40% affordable housing, but concern about delivery/viability disputes and a push for stronger mechanisms to secure genuinely affordable homes.
• Support for national space standards and higher renewable energy requirements, with a call for stronger support for low-carbon / Passivhaus approaches.
• Site-based concerns included:
  • Shrub Hill Retail Park: should be retained for relocation needs before housing.
  • John Comyn Drive: loss of Park & Ride land likely worsens congestion.
  • Diglis / Navigation Road: redevelopment must not displace low-rent businesses without relocation solutions.
  • Lowesmoor Wharf: additional homes only if car use is heavily constrained.
  • Shrub Hill Opportunity Zone: major design/transport complexity; need landscaping, strong station approach, public transport integration.
  • Worcester Woods/Newtown Road: argument that land should be safeguarded for hospital expansion/parking rather than employment use.

B. Transport

• Strong concern that the Plan underestimated the severity of Worcester congestion and the knock-on impacts on business, visitors, and city centre vitality.
• Call for a clearer shift away from car dependency: travel behaviour change, hubs, parking management, improved buses, cycle networks, and 20mph measures.
• Concern that investment focus remained too road-heavy; support for multi-modal approaches but not limited to individual sites.

C. Open/green spaces and “significant gaps”

• Opposition to reducing significant gaps based on a narrow definition of open land.
• Call to maintain gaps along the M5 corridor and around growth areas (including Rushwick) and protect key views (including towards the Malverns).
• Suggestion to introduce a concept like Strategic Open Land for stronger protection of key open spaces.

D. Environmental enhancement and historic environment

• Stronger policy needed on views, skylines and building heights, especially city centre spires and historic skyline.
• Need for supplementary guidance (including shopfront guidance).
• Concern for “roadside heritage assets” (e.g., milestones) at increased risk from roadworks and construction traffic

2) Regulation 19 Publication Consultation (November 2022)

What this stage means

Regulation 19 is the formal publication stage. Responses must focus on whether the Plan is legally compliant and “sound” (positively prepared, justified, effective, consistent with national policy). These are the comments that go forward to the Planning Inspector.

Our responses at Regulation 19 (high-level summary)

A. Transport – parking policy needed to support sustainable travel
WCS objected to the approach in SWDPR 06 (Transport), arguing the parking wording risked baking-in car dependency. We proposed a criteria-based approach including accessibility, local car ownership, housing mix, car clubs, and cycle parking priority.

B. Town centres and retail hierarchy – avoid weakening Worcester City Centre
WCS warned that wording suggesting new centres would “eventually” join the hierarchy could create ambiguity and increase risk of drawing anchor tenants/footfall away from Worcester City Centre. We argued new centres should be clearly placed in the hierarchy now, with floorspace/threshold controls to prevent harmful diversion.

C. HMOs – support, but strengthen for balance and amenity
WCS supported SWDPR 17 as sound, but suggested it should go further with more explicit criteria around over-concentration, family housing loss, amenity, compatibility, and restrictions in high-concentration areas.

D. Design – push for stronger quality/character outcomes and shopfront guidance
WCS objected to aspects of SWDPR 26, including the justification for encouraging “new and contemporary designs”, and proposed more explicit character-led criteria, including historic grain, proportions, materials, and detailed shopfront principles.

E. Historic environment – safeguards around demolition and “grain” of historic places
WCS proposed additional policy wording so that if demolition is approved, removal should not occur until replacement delivery is proven, and highlighted the importance of street pattern and “grain” in historic areas.

3) Local Plan Examination: Hearing Statements (February 2025)

What this stage means

After submission, an independent Planning Inspector examines the Plan. “Matters” are the Inspector’s structured topics/questions used to test soundness and legal compliance. Hearing Statements are an opportunity to answer those questions clearly and propose Modifications.

Our Hearing Statements (11.02.25)

Matter 1 – Legal/procedural: footnotes and heritage evidence
WCS said footnotes can work, but argued a key heritage footnote should explicitly reference Conservation Area Appraisals / Management Plans and heritage strategies, and urged prioritising completion of those documents alongside main modifications.

Matter 4 – Housing provision: retail requirement missing from strategy
WCS argued that retail requirements should be explicitly addressed in the strategic policy (SWDPR 02), reflecting evidence of limited floorspace capacity and reinforcing the “town centres first” approach.

Matter 6 – HMOs: define “over-concentration” and “loss of family housing”
WCS pointed to Worcester’s adopted HMO SPD approach (including a threshold-based method) and suggested aligning SWDPR 17 wording with that framework for clarity and effectiveness.

Matter 8 – Economic growth and centres: clarify hierarchy and thresholds
WCS reiterated that the “eventual inclusion” of new settlement centres is unclear and risks undermining Worcester City Centre. You argued the sustainability appraisal did not properly test impacts of new settlement centres, and proposed clearer hierarchy/threshold controls.

Matter 15 – Design: clarify when evidence requirements apply; tighten wording
WCS argued parts of SWDPR 26 should apply to major applications (not every application), and raised concerns about the policy’s broad encouragement of “new and contemporary designs”. You also suggested referencing CPTED principles in place of relying on “Secured by Design” wording.

Main Modifications (February 2026)

What this stage means.

The Main Modifications stage is the point in the local plan process (after the plan has been submitted for examination) where the Council publishes the specific changes that the Planning Inspector considers necessary to make the plan “sound” and legally compliant, and then runs a time-limited public consultation on those proposed changes. The comments received are sent to the Inspectors to inform their final report; if the Inspectors then conclude the plan is sound subject to those modifications, it can move to adoption by the councils.

WCS is currently drafting a response to the Main Modifications consultation that has launched in Q1 2026. Once these have been agreed at our Executive Committee, these will be uploaded here.

WCS has been consistent across all stages

Across 2019 → 2022 → 2025 → 2026, our position has been consistent:

• Infrastructure first (transport, health services, community facilities) alongside growth
• Sustainable transport, not just road capacity: behaviour change + hubs + better buses/cycling/walking
• Protect Worcester City Centre vitality, including careful handling of new settlement centres and retail hierarchy
• Protect historic character: grain, views, skylines, and strong supporting guidance
• Protect green infrastructure and separation: significant gaps, key open spaces, key views
• Clarity and enforceability in policy wording (so the Plan can actually deliver what it says)