WORCESTER CIVIC SOCIETY (WCS): SWDPR PREFERRED OPTIONS RESPONSE
The points below represent the views of the Worcester Civic Society in relation to the following key issues within the preferred options document.
1; HOUSING, EMPLOYMENT AND RETAIL AND WORCESTER CITY ALLOCATIONS
Comments in this part of the WCS response relate to the following sections of the SWDPR document: 13 Housing; 15 Resource Management and 18 Worcester City Allocations.
1.1; Section17 Strategic Allocations. WCS broadly supports the change in policy to focus key housing allocations around rail transport hubs, but would stress the need to ensure that these large allocations are supported with the development of infrastructure in advance of housing development and that important community services, are delivered alongside housing growth and that key services such as the hospital are expanded (see Worcester Woods site allocation comment below). In designating these areas it is important that significant gaps are maintained to ensure that settlements do not merge together. WCS believe that current significant gaps should be retained and expanded and that a significant gap allocation is needed in respect of the Rushwick allocation to ensure separation from the city of Worcester (SWDPR 51).
1.2 SWDPR 12 (E i; ii, v & H) Effective Use of Land. Broadly WCS are in support of the housing density policies as ‘broad indications’ in SWDPR 12, however central Worcester is covered with Conservation Areas and so clause E(v) will need to be applied with care. A height of buildings policy for these areas should be prepared to ensure that schemes do not overpower their urban context. This is particularly important in the absence of Appendix Two of the SWDP Design Guide Supplementary Planning Document which is urgently required to be produced to provide a robust character assessment to guide new development. Equally, the capacity of parts of the road network in inner Worcester is very limited and so density standards may need to be lowered within the City until this capacity is suitably raised, or until passenger transport is more fully provided for (see comments on transport below). In relation to clause H on the best and most versatile agricultural land we support this policy but would suggest that development on best quality agricultural land should be wholly exceptional rather than exceptional.
1.3 SWDPR 14 Meeting Affordable Housing Needs. WCS support the 40% target in B(ii) but note that although a recent viability study suggests this target is viable (13.42), we remain concerned that disputes with developers will continue to prevent the target being reached. When the Affordable Housing SPD is revised, more measures to protect the target should be considered, such as special incentives. Equally, more needs to be done to ensure that the nature of the housing is genuinely affordable for local people. More might be done to strengthen clause E to support social housing for rent and the target of 70:30 split between renting and to buy should not be further reduced in respect of affordable socially rented housing.
1.4 SWDPR 17 Residential Space Standards. WCS welcome the adoption of the national standards as a minimum in new development and particularly in applying these to conversions.
1.5 SWDPR 31 Renewable and Low Carbon Energy. This policy includes a welcome uplift to a 20% requirement for renewable energy in new developments. This goes some way to meeting the guidance in para 97 of the NPPF, which is quoted in the recent SPD on renewable energy. With regard to new and refurbished housing in Worcester, there needs to be a stronger policy commitment to incentivise low carbon or Passive House schemes.
1.6 SWDPR 53 Worcester City Allocations
New 5: Shrub Hill Retail Park. These buildings have potentially a long life remaining before redevelopment and could be used for temporary or permanent relocation sites for businesses affected by the redevelopment of the much older Shrub Hill Industrial Estate and adjoining sites. Only when they are not wanted for trading purposes should these be used for housing allocation. (See reference to relocation in Table 8 clause B viii).
New 6: Land at John Comyn Drive. Regrettable loss of land for Park and Ride site, will increase congestion with other planned developments in the area.
New 9. Navigation Road, Diglis. There is a danger, as at Shrub Hill, that businesses that prefer to pay low rents in small old buildings will be pushed out of the City if redevelopment proceeds too quickly and ignores their needs. As soon as the needs of traders on site or seeking relocation are fully satisfied, should we agree to the indicative proposal for up to 495 dwellings on this site.
Lowesmoor Wharf: Lowesmoor itself is hugely congested. The addition of up to 100 new dwellings should only be considered if personal car use is minimised. The site needs to be virtually car free.
Trinity House, Cornmarket: In view of the decline in demand for retail space in the city centre, Living over the Shop conversion or redevelopment on this site should be promoted, although with careful consideration of height, density and design of this key site. A residential company could take the lead on this but a broader development option is preferable.
Shrub Hill Opportunity Zone: Most of the allocation for residential (550 units) is sited on Sherriff Street. The detailed design of the road improvements, public transport and active travel network will be challenging within this dense mixed-use scheme. Ideally the housing areas should be softened by landscaping both within the site and possibly on surplus rail land adjoining. The remaining 200 unit allocation should preferably by sited on both sides of the canal. Most of the industrial estate needs to be redeveloped to attract new offices near the station, eventually to replace Elgar House, and new or relocated trading businesses on Shrub Hill Road. Special attention needs to be given to the station approach and a possible bus interchange on the oval, also to the appropriate improvement of the listed Engine House and the modernisation of Isaac Maddocks House (see also comments re Transport and Shrub Hill Retail Park).
Warndon Woods Business Park, Newtown Road (Table 10: SWDP Employment Reallocations). It is acknowledged in the South Worcestershire Infrastructure Study Update (2019) that “both Emergency Departments in Worcestershire are operating near or at capacity, daily, despite the expansion of capacity in Worcestershire Royal Hospital’s department in 2016. Demand for in-patient treatment in Worcestershire is also increasing, evidenced by growing waiting lists and high bed occupancy (frequently occupancy rates exceed 100%). The bed increase scheme completed in 2019 has yet to become fully operational and its benefits are expected to improve current operating constraints rather than to provide “growing room”.”
WCS believe there is a need for a corresponding Health/Medical infrastructure plan to be drawn up to cover the same time period as the 20 years of the SWDPR. This should show more detailed projections of use of the hospital, ambulance service and associated facilities over that time-scale commensurate with the planned population demographics. Hoping for health centres and GP surgeries to develop organically and depending on ‘roving GPs’ etc. is no enough to meet the projected growth without putting further serious strain on services.
It is expected that further housing growth in South Worcestershire will continue to put pressure on hospital services and their parking facilities. WCS considers that the Worcester City Site allocation at Worcester Woods Business Park, Newtown Road (SWDP REALLOCATE 17/ SWDP 43/15) could be designated for future expansion of the Hospital services and/or parking rather than employment use. The NHS and Worcestershire Royal Hospital is one of the largest employers in the area. Using this allocation for improving this vital community facility would be supported by WCS as it would bring about multiple benefits to the community through employment, improved healthcare provision ad potentially increased parking capacity which is a major problem within the existing hospital site and nearby residential areas. WCS considers that site SWDP 43/15 should be amended to be allocated for this vital community use.
Crowngate reallocation (SWDPR 44/2) – there is a lack of clarity in the document as to the scope of the proposed redevelopment area here. This needs to be clearly set out and should not include the wider development options outlined in the City Masterplan for the Crowngate/Angel Place area as the are buildings of value here that should not be removed and the current shopping centre has opportunities for refurbishment before comprehensive redevelopment.
Riverside (SWDP 44/7) – Paragraph 3.6: The Vision statement for 2041 includes reference to a thriving tourism market being ‘underpinned by a high quality natural and built environment’. It then goes on to list the major area wide assets such as the Malvern Hills AONB and the historic cores of the towns and villages. But it lists Worcester Cathedral in isolation. WCS suggests that it is the Riverside setting which provides the most iconic views of the Cathedral for visitors, as well as a high-quality landscape and natural environment close to the historic core. The paragraph should therefore include: Worcester Cathedral and Riverside.
WCS wishes to emphasise the wording in clauses 18.39-18.41 which indicates that this area should be the focus for recreational and community space and suggest some alternative wording below to reinforce the importance of this area. The riverside should not be the subject of intensive commercial development, as suggested in some proposals within the Masterplan. WCS believe that the green and open nature of the riverside must be protected – it is an important open and green space – this is in the CA appraisal for the Riverside. Tall buildings would dominate.
Table 8 Mixed Use Reallocations, 44/7 Riverside Action Area should specify Informal Recreation and Landscape Improvement.
Paragraph 18.39: The paragraph should provide explicit recognition that: The Riverside is subject to its own Park and Conservation Area status, along with the Historic City Conservation Area which abuts it, and as such its existing character should be strengthened and protected.
Omit reference to it being an underused asset, and instead state that: The Riverside has a vital role as a landscape setting for the Cathedral and city centre, and an attractive open area of major importance as a resource for local people and visitors, and therefore makes a significant contribution to the attraction of the City for regional, national and international tourism.
Paragraph 18.40: Omit first sentence and replace with: In the context of the full recognition of the role of the Riverside clarified in the Riverside Park and Conservation Area Appraisals and elsewhere in the SWDP, the specific suggestions at Croft Road and Copenhagen Street contained in the Masterplan for hotel, multi-storey car park, commercial and residential development, are not appropriate.
Paragraph 18.40: After the second sentence: A major new public open space is shown on the policies map either side of the Viaduct to be developed early in the Plan period in order provide a location for larger scale events and activities on the Riverside, with provision of a visitor centre/café and links to the local Active Travel Routes. Alter to include major triangular green open space either side of the Viaduct as outlined in the Plincke Landscape Plan of 2008.
St Clements Gate (SWDP 44/8) – WCS disagree that the development of this area should follow proposals as set out in the Masterplan as this would be an overdevelopment of this area which would lose important open and recreational space in the city and the proposed large developments would overshadow the important asset of the viaduct and provide a poor public realm for the proposed low line route to the river. Development of open space should be linked to the suggested amendments above to include the riverside park as detailed in the Plincke Landscape scheme.
Comments in this part of the WCS response relate to the following sections of the SWDP: 3 Vision and Objectives; 7 Transport; 10 Infrastructure.
2.1 Concerns. WCS is extremely concerned at the lack of recognition in the SWDPR of the severe transport problems facing Worcester in the context of the proposed scale and location of major growth.Congestion problems contribute to significant levels of unreliability in journey times around and across the built-up area. Small incidents can bring much of the city and the by-pass to a standstill, indicating how close the city is to saturation level. In the longer term we are concerned that these conditions will impact on the attractiveness of Worcester to businesses and visitors and on the vitality of the city centre and undermine other objectives and policies in the SWDPR. The improvements to the by-pass are unlikely to provide a remedy beyond 2025, as general traffic levels grow and the extra capacity attracts more journeys (SWDPR para 7.7).
Increasing car congestion is linked to and compounded by decreasing investment and focus on public transport provision. The recently published Worcestershire Passenger Transport Strategy (2019-30) concentrates on the procedures for apportioning a reduced level of spending, leading to continued reduction in service levels for those reliant on buses or trying not to use the car. Equally, within the city there is worsening quality of life as traffic continues to dominate the main routes into and around the city centre, affecting adversely those walking and cycling and living along the routes. The whole of the city has recently been declared by the City Council to be an Air Quality Management Area. Growing use of electric cars may only improve the situation in these areas marginally over the next 10 years in relation to air quality but will not address issues of congestion and pedestrian safety.
The evidence base provided with the SWDP Review makes clear that the proposed developments up to 2041 will significantly exacerbate area wide traffic problems:
- The Parkway and Rushwick sites and the sites in the City will generate an extra 3,000 trip from homes and an extra 5,000 trips to employment locations in the morning peak (Modelling Report October 2019 by Jacobs, page 7). This equates to an 11% increase in demand on the network from the 2031 expected levels, and a significant 20% increase in delays (op cit page 14).
- There would also theoretically be generation of about 1,000 extra public transport trips (rail and bus). However, the modelling suggests that increased highway demand beyond 2031 reduces average bus speeds and public transport patronage actually declines overall (op cit page 20), despite the extra rail station at Rushwick and the increase in X51 service included in the model.
WCS are pleased that section 7 incorporates the Local Transport Plan 4 (LTP4) into the SWDPR, in so far as it relates to South Worcestershire. It also appears to have introduced some new policies since the LTP4’s publication. However, the South Worcestershire Infrastructure Study October 2019 by Arup confirms that it will be vital for a new LTP5 to include schemes aligned to the proposed levels of growth in the SWDP Review. However, it concentrates on the need for road investment, for instance at M5 Junctions 6 and 7 to allow them to cope with the increase in local traffic generated by the new settlements for which they have not been designed (op cit pages 22-23); and on rail investment including updated signaling at Foregate Street Station (op cit page 24). The SWDPR contains radical proposals promoting multi-modal transport, which we support. However, these should relate to Worcester City and other areas as a whole and not simply to application sites.
2.2; Suggested changes
The concentration of new development at the two new settlements and at Rushwick related to new or existing railway stations is a definite advance in terms of sustainability, but rail is only part of the answer. WCS considers that in addition to the references to the stations and transport hubs (e.g. para 7.22), there are a wide range of initiatives that need to be flagged up in the SWDP to ensure that they are included in the LTP5 and other related transport strategies.
Paragraph 3.2: The Vision statement for 2041 states that residents and businesses will enjoy greater accessibility, but then concentrates on a list of infrastructure investments – with public transport, walking and cycling only mentioned at the end of the paragraph. WCS argues that central to future prosperity and quality of life in Worcester is the adoption of significant changes in travel behaviour. It is only with a major change in methods of travel that Worcester will remain a ‘highly desirable place in which to live and work’ (para 3.1). WCS therefore suggests that para 3.2 should refer only to the main infrastructure investments (excluding reference to public transport, cycling and walking), and that a new paragraph is added:
Paragraph 3.2 A:
Of great importance will be the major change in travel behaviour by those living, working and visiting the city. Publicity campaigns will have encouraged people to avoid use of the car. These will be have been accompanied by provision of long stay parking at transport hubs related to the new and improved rail stations, increased charges for and gradual reduction of city centre long stay parking, improved bus services with city wide real time information supported by the County Council, service providers and employers, integration of cycle facilities into all developments, an increasingly comprehensive and high quality cycle and walking network, and greater use of 20mph limits on city roads.
SWDPR 3: The policy heading refers to Transport Links which places too much emphasis on provision of linear infrastructure. In the context of need for greater sustainability the title should be changed to Transport Provision.
A. The reference should be to the latest (future) LTP not LTP4. It would be helpful for all LTP references (e.g. in F and G) to be changed to make clear the LTP4 cannot be considered adequate to the task of providing a sustainable transport system for South Worcestershire in the context of the SWDP Review.
E. Add to end of sentence; and facilities for parking (and recharging of electric) bikes.
F. WCS believe that there should be specific reference to the Worcester City Centre Transport Strategy and / or Worcester Transport Strategy which we understand has been drafted. Additionally, WCS considers that the blanket reference to the City Centre Masterplan (in vi.) is unhelpful as the Masterplan includes for instance construction of a new multi-storey car park in the centre, when a reduction in long stay parking will provide part of a more sustainable future for travel in the city. The reference to the Masterplan should be omitted and specific schemes added for instance:
ii. Worcestershire Parkway Station……. and Transport Hub (with park & ride facilities, and related trackway to enable a shuttle rail service into the city centre).
iv. Rushwick Railway Station……and Transport Hub (with park & ride facilities to enable the station to fulfil its potential since much of the walking/cycle catchment will be undeveloped – see strategic growth area diagram)
v. Worcester Shrub Hill…..including improved capacity for a shuttle service from Parkway, and extended taxi, bus and cycle facilities and safe pedestrian routes into the city centre.
K re. CIL and S106 contributions, WCS are concerned about co-ordination. Transport improvements, including road improvement lines if any, ought to be designed at the same time as development proposals. Road improvement design carried out after the application has been submitted may require the submitted development to be amended. (WDP e.g. this may affect the Sherriff St scheme at Newtown Road).
Paragraph 7.8: WCS support proposals for community buses and not just in rural areas. The needs of other travelers, who are not easily served by these routes, could be served by employers’ bus services, school and college buses or minibuses, shared cars and taxis. Modern communication systems could assist such alternative services in meeting the needs of individual customers. These services would also reduce the number of unaccompanied car drivers congesting the City.
Paragraph 7.16: WCS consider this paragraph to be extremely unhelpful. LTP4 provides proposals intended to address transport issues raised by the current SWDP, and with only partial success (see above). The blanket reference to providing additional capacity to accommodate growth is entirely inappropriate – not least in the context of the warning in paragraph 7.7. WCS’s expectation is that the current wording will be dropped and replaced by:
LTP5 will clarify the full range of measures required to ensure that the transport system will be able to provide for the travel needs of South Worcestershire. For Worcester City these will include reference to addressing key capacity constraints at junctions directly related to the major new developments, but also to measures to assist in the reduction of use of the car, and increased travel by public transport, walking and cycling.
Paragraph 10.19: Add travel hubs after reference to rail network.
3; OPEN/GREEN SPACES
3.1 Significant Gaps: “The SDWPR sets out how we will protect and enhance the historic environment and safeguard the landscape.” The more detailed definition within the SWDPR of the types of Open Space provision (including Green Space) is to be welcomed. However, a narrow definition of ‘open land’ has been applied in the formulating the recommendation to remove the majority of the Significant Gaps; this would leave such landscapes more vulnerable to the potential extension of urban and industrial development between these historic settlements or along the M5. This would be greatly to the detriment of the settlements’ rural context and of its biodiversity.
The historic environment is a major facet of the attractiveness of our county to tourists and residents, both current and potential, as is the rural setting and its thriving biodiversity. Although not a feature of the National Planning Policy Framework (NPPF), the Significant Gaps should be maintained to provide an added layer of protection to our ‘natural environment’, retaining connectivity for leisure use and biodiversity, rather than leaving those areas at the mercy of short-termism in relaxing planning controls in response to developer pressure. Equally, these gaps also protect important cultural landscapes and views (see below).
The likelihood of an urban sprawl around South Worcestershire swallowing the individual historic settlements is not to be welcomed, for both aesthetic and environmental reasons. While an ‘open’ aspect may be maintained, the “avoidance of harm” by developers is recognised as insufficient sanction – but the “net gain” to be demonstrated by a developer to the natural environment is currently not quantified and could be minimal.
3.2: Suggested changes. Specifically, WCS would like to see the maintenance of significant gaps along the M5 corridor to the east of the city and also the proposed new strategic allocation at Rushwick. The gaps at Rushwick need defining in advance of any development proposals. In particular, it is important that views towards the Malverns, that inspired the music of Elgar are also protected.
Another option to enhance the protection of these important open space would be to identify Strategic Open Land (SOL) in the document, as has been successfully applied in the London area:
SOL should be protected from inappropriate development and development proposals that would harm SOL should be refused. SOL meets at least one of the following criteria:
- it contributes to the physical structure of Worcester by being clearly distinguishable from the built-up area
- it includes open air facilities, especially for leisure, recreation, sport, the arts and cultural activities, which serve either the whole or significant parts of Worcester
- it contains features or landscapes (historic, recreational, biodiverse) of either city wide or regional value
- it forms part of a strategic corridor, node or a link in the network of green infrastructure and meets one of the above criteria.
This would protect both important gaps between new strategic allocations and the city of Worcester and also be used to protect important open spaces within the city boundary of both natural, cultural and recreational value, such as Middle Battenhall Farm or Everdine fields playing fields.
4; ENVIRONMENTAL EHNANCEMENT AND PROTECTION
Comments in this part of the WCS response relate to the following sections of the SWDPR document: 3 Vision and Objectives; 9 Historic Environment and 14 Environmental Enhancement and Protection.
4.1: SWDPR 25 Design – WCS would like to emphasise the importance of clause iii (and section 14.16 justification) in relation to retaining important views. The importance of the historic skyline of Worcester city centres and its church spires needs further emphasis here to discourage tall building development across the city and stop the incremental upwards creep in height that has been evident in recent development applications. This needs to be linked to a building height policy for the city centre as noted above. Equally, as noted above this needs to be accompanied by the publication of appendix two of the supplementary planning document Design Guidance at the time of adoption of the revised SWDP to support this control of development. This policy also needs to be strengthened by the commitment to produce supplementary shopfront design guidance for Worcester, which is currently not available (with only Wychavon and Malvern Hills of the South Worcestershire councils publishing these.
4.2 SWDPR 28 Management of the historic environment – Roadside Heritage Assets
“The landscape is of a very high quality and the countryside is distinguished by the upland areas of the Cotswolds (including Bredon Hill) and Malvern Hills AONB, as well as the river valleys of the Avon, Severn and Teme. There are approximately 5,600 listed buildings, 150 Ancient Monuments, 13 historic parks and gardens, 105 conservation areas and numerous protected trees and woodlands. In addition, the urban greenspace enhances the environmental quality of the area. All these environmental attributes mean that south Worcestershire attracts a significant number of tourists and visitors, who account for approximately 11% of local expenditure.”
Worcestershire has a substantial number of historic milestones, including survivors from the 1700s as well as the unique concrete mileposts designed by Deputy County Roads Surveyor Harold Brooke-Bradley in the 1930s. Many of these milestones are classed as Grade ll ‘listed buildings’ by Historic England.
The area within the SWDPR hosts many milestones along all the radial roads from the city. These are already at risk from traffic collisions, casual neglect, theft and vandalism. The urban and industrial developments proposed in the SWDPR will require the widening of the roads within the South Worcestershire area and their use by heavy construction traffic. This will put the milestones at even greater risk. Hence acknowledgement of the fully spectrum of heritage assets is required in the SWDPR in order to safeguard these wayside heritage assets.
Dr Heather Barrett
Chair of the Planning Panel
On behalf of Worcester Civic Society