APPEAL
REFERENCES
:
APP/H1840/A/13/2199085
&
APP/H1840/A/13/2199426
TOWN & COUNTRY PLANNING ACT 1990 – SECTION 78.
APPEAL BY BARBERRY DROITWICH LTD & PERSIMMON HOMES LTD &
PROWTING PROJECTS LTD
LAND NORTH OF PULLEY LANE AND NEWLAND LANE, NEWLAND,
DROITWICH SPA, WORCESTERSHIRE
SUMMARY PROOF OF EVIDENCE (ENVIRONMENTAL PLANNING) ON
BEHALF OF SOGOS
BY: STEPHEN STONEY BA (Hons), MRTPI - TECHNICAL DIRECTOR,
WARDELL ARMSTRONG LLP.
Appeals APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426
Summary Proof of Evidence for SOGOS on Environmental Planning
1
RELEVANT QUALIFICATIONS AND EXPERIENCE
1.1
My name is Stephen Martin Stoney. I hold a degree in Urban & Regional
Planning and am a corporate member of the Royal Town Planning
Institute. I have over 30 years’ experience in planning including working
for four local authorities in development control, and am currently
Technical Director at regeneration consultancy Wardell Armstrong LLP
based in Stoke-on-Trent. My current duties include advising a range of
clients in both the public and private sector on planning, environmental
and regeneration matters. I have undertaken planning appeals for the
public and private sectors, and interest groups.
1.2
The evidence which I have prepared and provide for the appeals
APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426 in this proof of
evidence is I believe true and has been prepared and is given in
accordance with the guidance of my professional institution, the Royal
Town Planning Institute. I confirm that the opinions expressed are my
true and professional opinions.
1.3
I have been instructed by SOGOS, an unincorporated community group
from the Droitwich Spa area which was formed to promote sustainable
development in the town.
2
SCOPE OF EVIDENCE
2.1
My
evidence
is
prepared
on
behalf
of
SOGOS
and
deals
with
Environmental Planning matters.
2.2
Attached to this proof are four letters from members of SOGOS who wish
these to be considered as representations to the appeal rather than being
presented individually as personal statements, and are complimentary to
matters promoted in my evidence.
2.3
The scope of my evidence is directed towards Matters 1, 2 and 4 of the
identified 7 main matters for consideration.
ST13787/SPOE
Appeals APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426
Summary Proof of Evidence for SOGOS on Environmental Planning
3
MATTER
1:
THE
DEVELOPMENT
PLAN
AND
SUSTAINABLE
DEVELOPMENT
3.1
The approach taken by the Local Plan Policy ENV1 requires development
proposals to safeguard, restore or enhance the natural and built
environment in which they sit is in my opinion consistent with the NPPF’s
approach of seeking positive improvements in environmental quality (para
9) and conserving and enhancing the natural environment (para 17).
3.2
Policy GD1 ‘Location Strategy for new Development’ is clearly concerned
about where development takes place rather than how much. The
introductory statement at 2.3.1 confirms that its purpose is to ensure the
broad location of development is consistent with national objectives and
can be reasonably accommodated. Again, I consider this policy of similar
validity in weight terms to ENV1 through the same reasoning.
3.3
It is my opinion that neither of the appeal proposals is in accordance with
the provisions of the extant Local Plan, in particular Policy GD1 and I am
professionally most convinced by Ms Illman’s manner of dealing with
Policy ENV1 on behalf of the Council than any other interpretation.
3.4
I accept that there is a positive social and economic dimension in
providing housing in Droitwich Spa, although the same interpretation can
be given to any significant additional housing in any town. I consider the
most important matter is that of environmental acceptability, where I
consider there is an overall negative impact.
3.5
The simple fact of the case is that there is significant loss of land that
currently constitutes open countryside which is identified as being within a
Special Landscape Character. The NPPF (para 113) promotes a criteria
based approach. Development on the scale proposed in this sensitive
location in my opinion contravenes the NPPF objective of conserving the
natural environment.
3.6
There is clearly strong feeling, as reflected in the letter of Mr Sparrow at
Appendix 1, that there will be material and significant adverse impact on
the levels of amenity currently considered by residents of neighbouring
properties in Yew Tree Hill, Primsland Fields and Rebekah Gardens which
ST13787/SPOE
Appeals APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426
Summary Proof of Evidence for SOGOS on Environmental Planning
back on to Newland Road, which in particular is subject to substantial
change in form and character.
4
MATTER
2:
THE
EMERGING
SOUTH
WEST
WORCESTERSHIRE
DEVELOPMENT PLAN
4.1
The proposed developments when taken together (Appeal A and B) are
significant in that they are of the scale that would normally constitute a
strategic development in Plan-making terms (over 500 units). It is my
contention that granting approval through the appeal process either in
respect of both developments would significantly undermine the planmaking process by making a pre-determined judgement in isolation about
the location and scale of other housing development at a strategic scale.
4.2
These matters should as a matter of principle be addressed in the SWDP
as a Plan- making function, as justifying any development in isolation of
strategic consideration would have an adverse effect in perpetuity. This in
my opinion should not be considered lightly and considered arbitrarily
particularly in view of the existing Special Landscape Area designation of
the sites.
4.3
I think it is important to note that Yew Tree Hill was considered as an
urban extension in 2008 as part of the South Worcestershire joint Core
Strategy Preferred Options. Location and access were at issue, and also
landscape character impacts and the impact on the setting of the rural
character to the south of the town. These important factors remain in
influencing the area’s omission from the current version of the SWDP.
5
MATTER 4: THE EFFECT ON THE CHARACTER AND APPEARANCE OF
THE AREA
5.1
The proposed development would clearly result in significant impact on
the character and appearance of the area, and the residential amenity of
those residing in the locality. I have assessed all the Landscape evidence
put forward and take the view that there would be significant harm to the
character of the local landscape where I find it hard to see any
demonstrable justification at this time for ridge-line development (or
ST13787/SPOE
Appeals APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426
Summary Proof of Evidence for SOGOS on Environmental Planning
development cut in to the ridge). Mr Sparrow’s letter at Appendix A gives
a
local
resident’s
perspective
to
the
appeal
sites
and
the
local
environment.
6
CONCLUSION
6.1
There is clearly a significant and acknowledged weight in supporting
proposals for appropriate housing growth, but there also weight to be
given to established development limits in the adopted local plan and to
the policy objective to safeguard the countryside. Until the plan context
changes, this should carry significant weight.
6.2
It is my view that the material circumstances demonstrate significant
impacts and detrimental effect upon Droitwich Spa and its’ residents on
sites that are currently regarded as open countryside.
6.3
Both appeal sites lie outside the built up area of the town as defined in the
Wychavon Local Plan where Policy GD1 contains a presumption against
development and remains extant policy. Neither site is included within an
urban extension in the submitted South Worcestershire Development Plan.
This Plan-making process should undertake a strategic assessment of
future development and make a proper and informed judgment of
development needs, rather than ad-hoc decision making.
6.4
Drawing the overall planning balance, despite the weight afforded to
housing delivery in this case it is concluded that those considerations do
not outweigh the harm clearly set out as compelling objections.
6.5
I respectfully request, on behalf of SOGOS, that the Inspector dismisses
the appeals.
ST13787/SPOE
Appeals APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426
Summary Proof of Evidence for SOGOS on Environmental Planning
ST13787
January 2014
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