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Cranborne Chase Area of Outstanding Natural Beauty

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Cranborne Chase Area of Outstanding Natural Beauty Cranborne Chase Area of Outstanding Natural Beauty AONB Office, Shears Building, Stone Lane Industrial Estate, Wimborne, BH21 1HD Tel: 01 725 517417 Email: [email protected] Web site: www.ccwwdaonb.org.uk Kenny Green Development Services Central Wiltshire Council Bythesea Road Trowbridge BA14 8JN By Email: [email protected] 17 June 2015 Dear Kenny 14/06562/FUL Amended Plans; development of 203 residential dwellings, open space, landscaping, sustainable urban drainage, vehicular and pedestrian accesses, and associated infrastructure and engineering works Land to west of St Andrews Road, Warminster, BA12 8ES Thank you for consulting the AONB on this amended application. In relation to the matters raised in my letter if 1 September 2014 there seem to have been few changes of relevance in the amended scheme even though the documentation lists the matters raised by you and the plans show a modified layout. For ease of reference I attach a copy of that letter, and I can confirm that neither the applicants nor their agents have consulted the AONB about resolving or overcoming the matters raised in that letter. I can also confirm that the AONB has not been involved in any consultations / discussions relating to the master plan for the Core Policy 31 strategic allocation extending to include the current site or other sites on the south side of Victoria Road. 1. The Cranborne Chase and West Wiltshire Downs AONB has been established under the 1949 National Parks and Access to the Countryside Act to conserve and enhance the outstanding natural beauty of this area which straddles three County, one Unitary and five District councils. It is clear from the Act, subsequent government sponsored reports, and the Countryside and Rights of Way Act 2000 that natural beauty includes wildlife, scientific, and cultural heritage. It is also recognised that in relation to their landscape characteristics and quality, National Parks and Areas of Outstanding Natural Beauty are equally important aspects of the nation’s heritage assets and environmental capital. The AONB Management Plan is a statutory document that is approved by the Secretary of State and is adopted by the constituent councils. It sets out the Local Authorities’ Objectives and Policies for this nationally important area. The national Planning Practice Guidance [Natural Environment paragraph 004] confirms that the AONB and its Management Plan are material considerations in planning. 1 2. The National Planning Policy Framework states (paragraph 109) that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes which include AONBs. Furthermore it should be recognised that the ‘presumption in favour of sustainable development’ does not automatically apply within AONBs, as confirmed by paragraph 14 footnote 9, due to other policies relating to AONBs elsewhere within the Framework. It also states (paragraph 115) that great weight should be given to conserving landscape and scenic beauty in AONBs, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in these areas. 3. This site is close to the AONB boundary. It is also in the view from the elevated Open Access Land of Cley Hill within this AONB, and Cley Hill is a key feature in the view from the site. It is, therefore, in the setting of this AONB. It is also relevant to recall, at this stage, that views to and from AONBs and the impacts of potential developments in the settings of AONBs on such views and the perception of AONB attributes, have been important matters in leading Planning Inspectors to dismiss appeals. Additional Policy Issues 4. The site is part of a larger strategic development area described in detail on pages 256 -259 of the adopted Wiltshire Core Strategy. Within the Key Objectives of that allocation are • the delivery of high quality housing, • protection of the setting of and views to this Area of Outstanding Natural Beauty, and • ensuring the environment within and around the strategic site is conserved and enhanced. 5. The adopted Core Strategy is quite clear that the quantum of development for the West of Warminster allocation remains at 900 dwellings and that a masterplanning process will have to consider all aspects of the development template, including land for mitigation. It is explicit [page 256] that the strategic allocation ‘does not provide for additional development’. 6. Core Policy 51 refers to development within the setting of an AONB as well as within an AONB. This is explained at some length in the supporting text to the Core Policy. 7. The current application appears to be avoiding that masterplanning process for the whole of the strategic allocation even though it would have been possible to join with those involved [Hearn / Persimmon] with the larger part of the area. The application therefore appears to be in conflict with the adopted Core Strategy. 8. Furthermore, NPPF paragraph 52 indicates that significant extensions to existing developed areas should follow the principles of Garden Cities. As this AONB has previously advocated, that approach would be more suitable for a rural market town such as Warminster than the dense scheme submitted. 2 9. On page 258 of the Cores Strategy details of landscape matters to be addressed within master plans and detailed schemes are set out. Emphasis is given to the AONB, maintaining open views, and ensuring the built form does not assume an unacceptable visual prominence. The importance of conserving and enhancing the field pattern and hedges is emphasised, along with a substantial landscape buffer to screen the urban edges. The setting of Cley Hill is specifically identified. 10. Page 259 indicates there should be a master plan for the strategic allocation which, by implication, means that individual elements of the area [such as the current application] should not come forward in a piecemeal way. 11. There is obviously an expectation by bodies such as the AONB Partnership and Natural England that the robust landscape treatments and development limits set out in the Core Strategy are adhered to. 12. This current amended application appears to increase dramatically the scale of housing development n the strategic allocation at the expense of the landscape and create very high density development more akin to an inner city situation than a rural market town. There is minimal landscape integration despite the close proximity to the AONB. The Amended Application 13. Redrow have submitted an application for 203 houses on the relatively small south-easterly corner of the strategic allocation. The proposed number of dwellings [203] at 28 per acre appears to be a ‘cramming’ exercise. Even considering 50% of that number takes the aggregate development for the strategic allocation well over the Core Strategy number. In addition one has to take account of the potential Bugley Barton Farm development, and including that in the process pushes the overall development way past the Core Strategy numbers. 14. It is, I suggest, worth recalling the scale and extent of the development template in the Core Strategy and the Key Objective to deliver high quality housing. I would also suggest that objective relates to the character and quality of living rather than simply quality of construction. The objectives to provide a. strong buffer to A36, having regard to Cley Hill and this Area of Outstanding Natural Beauty apply to this site. 15. Whilst the Addendum to the EIA seeks to correct weaknesses and errors identified in consultee responses to the original planning application, it does not inspire confidence about its attention to detail, and hence the validity of the assessments, with its variety of typographic errors [Cranbrook Chase; Cranbone Chase], the cut and paste errors regarding CS 51 on page 59, its location of Norridge Wood as south west of the site when it is to the north [para 8.23], and significantly inaccurate measurements [eg para 8.26 site to Cley Hill]. 16. The documentation still appears to fail to consider, other than as passing or dismissive comments, the appearance of the development in views to and from a key feature of this AONB, Cley Hill. Cley Hill is referred to in its context as an SSSI but not as a significant Open Access area within the AONB, and within National Trust ownership. Comments seem to be based on the current view of the site rather than, as should be the case, the visibility of the site 3 when developed. In that context, the blocks of 2.5 storey buildings appear to be in sensitive locations. 17. The landscape section of the Non-Technical Summary of the EIA is very strange. To suggest that existing landscape features and character ‘would be retained’ [para 8.3] seems very misleading as an open grass field would be completely changed to houses and roads. Furthermore, with other development nearby as part of the strategic allocation the cumulative impacts are unlikely to be negligible [para 8.8]. The EIA seems to avoid acknowledging that the development would create change, and hence it has difficulty assessing the landscape and visual changes and their potential adequacy and acceptability. 18. It is, nevertheless, very noticeable that considerable emphasis is put on retaining and managing the hedges and hedgerow trees in the boundaries on the western side of the site with the Rugby Club. This is laudable, as it implicitly acknowledges the importance of sustaining the character and health of these features to limit the visibility of the proposed development from key locations in the AONB, such as Cley Hill. However, all the plans that have been provided clearly show that the hedges and associated trees in the boundaries on the western sides are outside the ‘red line’ of the application area.
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