Planning a Development in Worcestershire
Worcestershire is a unique county in terms of its planning ‘set up’ as it has six main Local Planning Authorities (LPA) that make up the whole of Worcestershire. They are:
- Wychavon District Council
- Malvern Hills District Council
- Worcester City Council
- Wyre Forest District Council
- Bromsgrove District Council
- Redditch District Council
Wychavon, Malvern Hills and Worcester City make up ‘South Worcestershire’, which has its own local development plan (applicable to all three LPAs), whereas Wyre Forest, Bromsgrove and Redditch are very much their own LPAs and have their own Local Plans (LP) and policies.
From a Worcestershire planning consultants‘ point of view, we can summarise what to expect if we as submit a planning application on your behalf in any of the LPAs in Worcestershire.
Wychavon covers the southeast of Worcestershire with its base being in Pershore, and other key towns being Evesham and Droitwich. Wychavon is one of three LPAs that forms South Worcestershire that has an overarching development plan. Wychavon is the largest LPA (in terms of land mass) within Worcestershire, with circa 117,000 people living in the council area (2021 census).
Malvern Hills covers the south and west of Worcestershire, with its base being in Malvern, and other key towns being Tenbury Wells and Upton. Malvern Hills is the next of three LPAs that forms South Worcestershire that has an overarching development plan. Malvern Hills is the second largest LPA (in terms of land mass) within Worcestershire, with circa 75,000 people living in the council area (2011 census).
Worcester City, suggestive in its name, covers the city of Worcester only. It is the final LPA that forms South Worcestershire that has an overarching development plan. Worcester City is the smallest LPA (in terms of land mass) within Worcestershire but has a population of circa 99,000 people (2011 census).
Wyre Forest district covers the north/north west of Worcestershire, with its base being Kidderminster, and other key towns being Stourport-on-Severn and Bewdley. Wyre Forest have their own policy, which is currently the Core Strategy (2006 – 2026) but are in the final stage of adopting a new Local Development Plan. Wyre Forest is one of the smaller LPAs (in terms of land mass) within Worcestershire, with circa 98,700 people living in the council area (2020 estimate data).
Bromsgrove district covers the north/north east of Worcestershire, with its base being Bromsgrove. Bromsgrove have their own policy which is ‘the Bromsgrove District Plan 2011-2030’. A District Plan review has been launched but the plan update is not expected to be adopted until mid-2024. Bromsgrove is again one of the smaller LPAs (in terms of land mass) within Worcestershire, with circa 94,000 people living in the council area (2020 estimate data).
Redditch Borough covers an area in the east of Worcestershire with its base being in Redditch. Redditch have their own policy – ‘The Borough of Redditch Local Plan’. A review of the plan is in the very early stages of planning, with a timetable yet to be published. Redditch is the second smallest LPA (in terms of land mass) within Worcestershire, with circa 84,000 people living in the council area (2011 census data).
The Current Situation with Local Plans and the Authorities
South Worcestershire Development Plan
The South Worcestershire Development Plan (SWDP) was adopted in February 2016. It provides visions and objectives for South Worcestershire up to the year 2030, as well as policies for delivering such objectives to control and make the development sustainable. The adopted SWDP is followed closely by all three of the LPAs that have adopted it, hence why when applying for planning it is so important to enlist the help of a planning consultant who is familiar with the policy and is therefore able to advise you on the best course of action for your development.
From our perspective, when applying for planning with any of the three LPAs, complying with the SWDP – as well as the National Planning Policy Framework (NPPF) (which is a material consideration but does not change the status of the Local Plan) and any other relevant policies – is absolutely paramount. Without such compliance, there is a high chance that your application will be, at best, queried by the planning officer and we will be allowed to respond to such queries, or, at worst (and most commonly), refused. There is very little room for deviation from policy in the absence of very special circumstances – the starting point for determination of applications is always the Local Plan in accordance with S38(6) of the Planning and Compulsory Purchase Act 2004. As planning consultants based within Worcestershire, we are familiar with advising on the ability to use exceptions, or making your proposals comply with relevant policy.
The SWDP is currently undergoing a review following government guidance that all development plans should be updated every five years. The review was commenced at the end of 2017, with an aim to finish such review by the end of 2021 and provide the adopted updated version to meet the five-year time frame. However, this has been delayed due to COVID. The latest update on the progress is that the public consultation will not begin until earliest June 2022. This has altered the timetable significantly and the three LPAs are yet to approve the new timetable. This means that the likely earliest adoption of the new SWDP will be October 2023.
If you are a landowner or person within the three LPAs that adopt the SWDP, it is worth keeping abreast of the timeline. If you are interested in making comment at the public consultation stage but are unsure of how you will do this, this is something that we as planning consultants will be able to assist you with. We will be able to write responses or assist you with understanding the proposed policy changes and how it may impact on your development objectives.
One of the key impacts of the delay to the SWDP has been to Malvern Hills as an LPA. When looking at the five-year housing supply, Malvern Hills do not have a sufficient supply as an individual LPA at present. On adoption of the current SWDP in 2016, Malvern Hills were able to amalgamate with Wychavon and Worcester City in terms of the housing land supply so were afforded five years of housing supply via Wychavon and Worcester City’s surplus. As five years have now passed and, due to the delay of the SWDP review, Malvern are now deemed as not having a five-year housing supply. Thus, any applications with Malvern Hills should now be assessed with a tilted balance approach and in line the presumption in favour of sustainable development contained within the NPPF. While the term ’tilted balance’ may not be something you are familiar with, as planning consultants, this is something we have a strong understanding of and would be able to advise you on, in relation to any proposed development you may wish to do within Malvern Hills as an LPA.
Wyre Forest Core Strategy
The Wyre Forest Core Strategy was adopted in December 2010 and covers the period 2006–2026. It sets out the amount of development to be delivered in the district up until 2026, as well as the broad locations for delivering housing and other major develop needs such as employment, retail, and transport. This current adopted policy is followed closely by the LPA but does allow for some flexibility where reasoned justification can be provided. However, to comply with, or to provide sufficient reasoned justification, it is important to enlist the help of a planning consultant, such as Eldnar Consultancy, who is very familiar with the policy on the best course of action for any proposals you may have.
From our perspective, when applying for planning permission with Wyre Forest District Council (WFDC), it is important to comply with the policy, but there is often also a pragmatic approach to the assessment of the proposed development by officers. As planning consultants, we are able to have reasoned discussions with the officers and are able to work to submit applications that are policy compliant, or very closely compliant with reasoned justification for any deviation from policy.
The WFDC Core Strategy is in the very last stages of review, with the updated Local Development Framework set to be adopted in early 2022. The plan will be for 2016–2036. Final consultation, running for six weeks, is set to take place imminently which will invite members of the public to submit their comments in respect of the main modifications. If this is something that you as a member of the public are interested in learning more about, we as local planning consultants are able to advise you on this and can assist with submitting comments on your behalf.
Once the new plan is adopted, we envision there to be slightly tighter regulation on things such as conversion of agricultural buildings to residential units using the full planning application route. It is also important to note that while this may alarm you and cause you to want to rush an application through to be assessed against the current policy, due to the minimum eight-week period for applications to be assessed, there is chance that the new policy could be adopted before your application is determined. The impact of this is that your application will be assessed against the new policy. This may mean that while your application would have been acceptable under existing policy, the new policy may say different. As this is such a grey area at present, it is always worth getting in touch with us (Eldnar Consultancy) as professional planning consultants to seek our advice.
The Bromsgrove District Plan
The Bromsgrove District Plan (BDP) was adopted in January 2017 and covers the period 2011–2030. It forms part of the statutory development plan for the district and sets out the council’s vision and strategy for the area until 2030, providing a basis for decisions on planning applications. While a majority of the policies set out in the BDP are followed closely, the council do not have a five-year housing land supply. The impact of this is that often application is assessed with a ‘tilted balance’ approach and in line with the NPPF paragraph 11 policy.
When applying for planning permission with Bromsgrove District Council, it is important to consider relevant policy in the BDP, but also to assess the impact of tilted balance and consider NPPF paragraph 11. We are able to advise on these matters and assist with any development that may need to consider these points.
The BDP is also currently under review and is still in the early stages of this process, with the current predicted adoption date being May 2024. This means that there will be opportunity for public consultation, and while the timings for these consultations are not clear, we would be able to advise you on the proposed policies impact in regards to any planning or development objectives you may have, or we can represent you at public consultation stage.
Borough of Redditch Local Plan
While Redditch Borough is a separate LPA to Bromsgrove, they work together very fluidly and have similar (albeit specific to locations) local plans. The Borough of Redditch Local Plan (BRLP) was adopted in January 2017 and covers the period 2011–2030. The BRLP is an important planning document at the local level and provides a framework approach for the growth of the borough, and it will form part of the statutory development plan, providing a basis for the decision of planning applications.
Applications in Redditch Borough must be complaint with policy. Similarly to Bromsgrove, Redditch Borough do not have a five-year housing land supply. Therefore, this will also be assessed under the NPPF paragraph 11 and looked at for the ‘tilted balance’ assessment. As with Bromsgrove, this is something we are able to advise on and assist with applications on.
The BRLP is currently under review and is in the very early stages. No indicative timeline of the review has been published yet. However, at some point throughout the process, there will be opportunity for public consultation. This is something that we as planning consultants will be able to assist with advising on, or we will be able to represent you at the public consultation stage.
What can we do as consultants?
As alluded to throughout this article, we are Worcestershire-based planning consultants with a strong handle on the current policy and requirements of all LPAs within Worcestershire. Whether you are looking to achieve a specific development plan or you are unsure on what development objectives you want to achieve, we are able to advise and provide you with our services as appropriate.
If you are unsure of your objectives, we can provide an initial review of your land or site via an options appraisal. Alternatively, if you have specific objectives, we will be able to advise on whether your ideas comply with the relevant policies. We also work with a list of suppliers that can provide any surveys required, be it highways, architects or ecology and can provide an all-encompassing package of works to achieve your objectives. If you wish to have an initial discussion with us, book one of our 15 minute mini chats through the contact page of our website.