Unit 2B, The Tack Room Top Barn Business Centre Worcester Road Holt Heath Worcester WR6 6NH

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1 Stage 2 of the Examination Hearings Hearing Statement Matter X3: Category 1 Villages Wychavon (SWDP 59 & PM ) On behalf of: CALA Homes (Midlands) Ltd (612691) Thursday 4 th June 2015, AM & PM Unit 2B, The Tack Room Top Barn Business Centre Worcester Road Holt Heath Worcester WR6 6NH T E admin@prp-consultants.com W prp-consultants.com

2 CONTENTS: 1. QUESTION QUESTION QUESTION APPENDICES: 1. SHLAA (April 2015) assessment of sites in Offenham

3 Main Issue Whether or not the residential site allocations in the Wychavon Category 1 Villages are soundly based and deliverable. 1. QUESTION 1 Are the site allocations and the amount of development proposed for each site justified, having regard to the likely impacts of the development and the provision of necessary infrastructure? 1.1. We have assessed all of the SWDP housing allocations within 3- miles of the site CALA Homes has an interest in this being the site known as Land off Boat Lane, Offenham. The below table outlines the situation with each of these sites. Table - SWDP Housing Allocation Sites that fall within 3 miles of Land of Boat Lane, Offenham: 2

4 1.2. As can be seen by studying the above table the vast majority of the SWDP proposed housing allocation sites that fall within a 3 miles radius of the site known as Boat Lane, Offenham, have the benefit of planning permission; are pending a planning permission; or are currently under construction or have been completed. However, from our research it appears that there are 4 sites (proposed allocations) in the area that do not benefit from either a planning permission or even a planning application. These being: SWDP50/5 Land at Offenham Road, Evesham = 15 units SWDP50/6 Land behind Lichfield Avenue = 20 units SWDP50/7 Land off Abbey Road, Evesham = 200 units SWDP59/24 Laurels Avenue, Offenham = 19 units 1.3. Given the current level of house building that has taken place in and around Evesham the deliverability of these allocations has to be questioned if at least planning applications have not come forward on these sites in the past few years Such a comment can also be made in the context that the housing delivery within this 3- mile radius includes a number of speculative planning applications on sites that have not been proposed as SWDP housing allocations. This includes sites, like the 22 units at Land Adjacent to 90 Bretforton Road, Badesy (LPA Refs: W/13/00138/OU and W/13/01909/OU); and 28 units at Land at and including 53 Bretforton Road, Badsey (LPA Ref: W/13/01598/OU) In the case of the 200 units at Land off Abbey Road, Evesham (known as Abbey Fields and Gardens), we note that Hallam Land Management are involved with the promotion of the site. Hallam Land Management are a national strategic land promoter who secure planning permissions and then sell sites onto housebuilders to build out. This is evidenced by their work on the Temple Laughern site (the Worcester West Urban Extension) under SWDP45/2; a site they have submitted an outline planning application on. The Abbey Road site is a much smaller site, yet no planning application has been submitted on this site. Given the nature of Hallam Land Management s business (they are a land promoter not a builder), one has to question the deliverability of this site, as Hallam have failed to secure a planning permission on this site at a time when Wychavon District Council would have granted a favourable consent due to their lack of a five- year housing land supply. 3

5 1.6. In addition, we also raise questions over the deliverability to the market of the remaining three housing sites of 15, 20 and 19 units respectively. It is apparent that this sector of the house building market is fragile, as very few builders have access to the necessary finance to build at this small scale. Whereas the larger more regional and national house builders are now only considering sites in excess of units, because of the start up costs associated with building on a site, and the actual level of open- market housing that can be built and in turn sold when the affordable housing provision is up at 40% of a total development On this basis, these three sites cannot be considered as justified housing allocations. This leaves a shortfall of 54 dwellings ( ) to be found on alternative sites in this locality of Wychavon. Alternative Site Land off Boat Lane, Offenham: 1.8. Given the above comments, we advance an alternative site at Land off Boat Lane in the Category 1 village of Offenham We are aware that the village of Offenham currently has four sites proposed for housing allocations in the emerging SWDP, totalling some 108 dwellings. These being: SWDP59/23 Land off Main Street, Offenham = 30 dwellings SWDP59/24 Laurels Avenue, Offenham = 19 dwellings SWDP59 x Land between Leasowes Road and Laurels Road = 50 dwellings SWDP59 x Spencer Commercial Services Ltd, Evesham Road, Offenham = 9 dwellings We note that the two sites recently added to the SWDP at the Proposed Modifications stage were granted on appeal and therefore have planning permission. Having searched the Council s web site we cannot find any records that the Main Street and Laurels Avenue sites having received planning permission. We wonder whether this raises a question against their deliverability, because with other sites coming forward in the village surely the owners of these sites would have also looked to submit planning applications to protect their interests. 4

6 1.11. Turning to the proposed site known as Land of Boat Lane, the site measures some 3.6ha (8.9 acres). As can be seen by the work done by Pegasus in the accompanying Background Document (February 2015). A very detailed assessment has been undertaken which acceptably demonstrates that the site can accommodate approximately 80 dwellings The site was assessed in the latest SHLAA of April 2015 under site reference This assessment ruled the site on the basis is was Too important as an employment site. The nursery employs 3 permanent staff and occasionally 6 seasonal workers for planting and harvesting; therefore at any one time (and for short periods on the year) the site only employs 9 staff. It therefore does not follow that this is an important local employer, as eluded to in these SHLAA comments. assessment is attached at Appendix 1. A copy of the SHLAA Clearly the re- use of this site would tidy up a former nursery site, with its redevelopment actually adding to the attraction of the village (providing an extensive amount of green infrastructure), as well as opening up the village to the River Avon to the west of the site Offenham is the closest Category 1 village to a number of the Vale s major packers and growers, namely: Kane Produce (up to 1500 workers); Evesham Vale Growers (200 workers); Westland Nurseries (100 workers); Zenith Nurseries (100 workers); Vale Fresco (100 workers); Richard Holt & son (50 workers); Planet Produce (50 workers); Findons Nursery (25 workers); and a variety of additional small growers (100 workers). These figures vary through the season, but average in excess of 2000 workers. With continuing EU immigration, it is believed these figures will continue to increase year on year In addition, the proposal site is within reasonable proximity to other key employment sources of: HM Prison Long Lartin; Unipart; and The Weston Industrial Estate at Honeybourne. 5

7 1.16. A development of the type and scale proposed on this site would specifically assist in accommodating these workers and their families near to their places of work and would help to reduce traffic movement on village roads considerably, thus fulfilling one of the Councils main sustainability requirements of providing housing on sites that are readily accessible to places of work Offenham is a Category 1 village and is within 5.5km of Evesham, one of the key centres in the District (and in South Worcestershire for that matter) It is also interesting to note that the owner of the Evesham Country Park Shopping and Garden Centre (a 125 acre site) intends to develop the area opposite this site (on the other side of the River Avon) for the future expansion of the Park. This expansion comprises: 60 holiday cottages; new wetlands habitat; a nature reserve; skate park; cycleway and angling facilities on newly created lakes (LPA Ref: W/10/01376/OU) The site must therefore be considered to be locational sustainable. Although a level of housing development is already committed for the village (as discussed above), we know from recent appeal decisions that housing should be directed to the most sustainable of locations This was confirmed at Paragraph 46 of the Land at Station Road, Honeybourne appeal decision (APP/H1840/A/12/ ), in which the Inspector stated: 46. There are proposals for development on two more sites in the village: one for 75 dwellings at Grange Farm which the planning Committee have resolved to approve (subject to further details and construction on them); and, an outline application on the opposite side of Station Road for mixed use development. If all of the dwellings were approved this would result in the release of about 190 dwellings, where compared to the indicative number in the SWDP of 75 dwellings. Whilst this might be about a third of all the dwellings to be allocated by the plan in the villages of the area, Honeybourne is a highly sustainable location with a main line railway station, facilities such as a school, shops, public houses and a church and a major employer within cycling distance. At the inquiry, it was stated that this site is the least acceptable to the Council and local residents. This is the only site to which there are landscape objections and there would be a greater impact on ridge and furrow than either of the other two sites. However, the details of those cases are not before me and this case has to be determined on its own merits. The SWDP is at such an early stage that it has little weight in determining the number and location of dwellings locally. 6

8 1.21. This appeal decision in effect endorses the proposition that the level of housing provision suitable for a village should be informed by its sustainability credentials. There should be no pre- determined cap on numbers. From the above it is very clear that Offenham can accommodate more housing over the Plan period (the next 15 years) and as such, we advance this site as an appropriate site (especially given its current appearance) to deliver any replacement / further housing allocations required for the District through the SWDP plan- making process. 7

9 2. QUESTION 2 Are the specific requirements of the policy justified and consistent with national policy? 2.1. No, and this explained in our comments under Question 1 above. 8

10 3. QUESTION 3 Is the housing development that is proposed for each site deliverable in the timescales envisaged in the Council s delivery trajectories? 3.1. No, and this explained in our comments under Question 1 above The alternative site of Land at Boat Lane, Offenham by contrast is being actively promoted and will be delivered in full within the next 3- years, in order to help boost significantly the supply of housing. Word count excluding text in bold:

South Worcestershire Development Plan Examination Representation Form Additional Pages Consultation on Proposed Modifications to SWDP: 6 October 14 November 2014 South Worcestershire Councils Additional

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