SWDP Hearing Statement Matter F Development at North East Malvern (SWDP 56)

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Dinah Stokes
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SWDP Hearing Statement Matter F Development at North East Malvern (SWDP 56) Town and Country Planning Act 1990 Planning and Compulsory Purchase Act

1 SWDP Hearing Statement Matter F Development at North East Malvern (SWDP 56) Town and Country Planning Act 1990 Planning and Compulsory Purchase Act 2004 Localism Act 2011 On Behalf Of: Halkin Developments Prepared By: Patrick Downes BSc (Hons) MRICS Harris Lamb Ltd Job Ref: P833 Date: 3 rd February 2015

2 INTRODUCTION 1.1 This statement has been prepared by Harris Lamb Planning Consultancy on behalf of Halkin Developments, the owners of land at Lower Howsell Road, Malvern. 1.2 The land owned by the Objector is the subject of proposed modification PM164 and which introduces Policy SWDP52i Land at Lower Howsell Road (former allotment) 81 dwellings on 5.21 hectares. 1.3 Although we support the allocation of the site in principle we have made specific comments about the number of units and the extent of green infrastructure expected on the site and this matter will be the subject of separate discussion later on in the examination. 1.4 However, our concern with Matter F relates to proposed modifications to SWDP56 which is the policy which allocates land for development at North East Malvern. 1.5 PM180 confirms the allocation of the former allotment site but goes on to state that: But it is considered that, subject to detailed assessment and comments from the Highway Authority, consideration will be given in the first instance to the main vehicular access to the former allotment site will be through the North East Malvern urban extension, to the Worcester Road. 1.6 The reason given for this change is that the wording explains the relationship of the Lower Howsell Road site to the north east Malvern site. PM177 contains a similar reference. Job Ref: P833 1 Date: 3 rd February 2015

3 1.7 It is the case that the Objector has submitted a planning application for development of the Lower Howsell Road site and this application shows how the site can be accessed using the existing road network with access off Lower Howsell Road and Vandra Close. The site does not need to be accessed through the North East Malvern development site. 1.8 The basis of our Client s objection is that whilst it may be appropriate for any scheme relating to the North East Malvern site to show how it might be connected to the surrounding area, such as through the use of footpath and cycle links, the policy should not be worded so as to imply that the release of another site is dependent upon another, particularly when alternative access solutions under control of the site owner are available. Accordingly we seek the removal of the suggestion that there must be a vehicular connection between the land at Lower Howsell Road and the North East Development site. 1.9 In response to the Inspector s questions we comment as follows: 1. Are the site allocations and the amount of development proposed for the site justified having regard to the likely impacts of the development and the provision of necessary infrastructure? 1.10 We agree that the North East Malvern development site is acceptable in principle and the level of development proposed appears to be appropriate. 2. Is the development proposed for the site deliverable in the timescale set out in Part D? 1.11 We have no specific comment to make on this point and will leave it to the site promotor to comment further. 3. Are the specific requirements for the policy justified and consistent with National Policy? Job Ref: P833 2 Date: 3 rd February 2015

4 1.12 We consider the requirement that access to the former allotment site at Lower Howsell Road be linked to the access arrangements for the allocation under SWDP56 is not justified and we consider that the content of the policy is far too detailed. We consider that access solutions to each site must be considered separately and should be judged on the merits of individual schemes through the development management process. We have certainly never encountered a case where the local plan has stipulated that an access to one site should be taken through another The current planning application for the land at Lower Howsell Road (reference 14/012310/OUT) demonstrates that a satisfactory access to the Lower Howsell Road allocation is achievable and is not dependent upon access arrangements relating to other sites Our view is that the attempt to tie the two sites together could easily hold up the release of the Lower Howsell Road site and this would be inconsistent with the Government s approach to boost significantly the supply of housing land (para 47 of the Framework). It is also the case that the Council is dependent upon sites coming forward at an early stage in order to address the five year housing land supply shortfall and if sites are tied to the delivery of larger allocations this will clearly inhibit their ability to be released in the short term Furthermore, the Council s policy will be likely to have implications for the more important ecological areas of the Lower Howsell Road site which the current planning application addresses by the use of landscaping and open space areas. The suggestion that a road connects the sites would have implications for habitat Accordingly, although we do not object to the original wording of SWDP56iv which suggests that footpath links and cycle links might be achieved through to the Royal estates, we do not think there is any need to refer to vehicular access linking the site with land at Lower Howsell Road. Job Ref: P833 3 Date: 3 rd February 2015

5 1.17 It should be noted that our proposals for the Lower Howsell Road site would enable pedestrian access and cycle links to be achieved between the two allocations We respectfully request that PM180 is not included in the plan These comments will apply to PM177 as well. Job Ref: P833 4 Date: 3 rd February 2015

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