11/25/2019 Mail - Woodgate, Jenny - Outlook LDS Consultation Representation - West of Lymington Bottom Road on behalf of Redrow Homes @blackboxplanning.co.uk> Tue 15/10/2019 18:50 To: EHDC - Local Plan <[email protected]> Cc: @redrow.co.uk> 1 attachments (12 MB) BBP Reps - West of LBR - Large Dev Site - Redrow - Issue Combined.pdf; Dear Planning Policy Team Please find aached a Representaon prepared in response to the Large Development Site Consultaon on behalf of Redrow Homes. I would be grateful if you can confirm receipt of this email. Kind regards Director Black Box Planning Ltd T: E: [email protected] W: www.blackboxplanning.co.uk Black Box Planning Ltd, 9 Marsh Street, Bristol BS1 4AA Company No: 11444297 P Consider our environment...please don't print this e-mail unless you really need to. ----------------------------------------------------------------------------------------------------------- E-Mail Disclaimer - The information in this email (and attachments) is confidential and may be legally privileged. It is intended solely for the addressee and access by anyone else is unauthorised. If you are not the intended recipient please notify us immediately and then delete this email. Any disclosure, copying, distribution of this email (and attachments), or any action taken in reliance on it, is prohibited. Email transmission cannot be guaranteed to be secure or error free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message which arise as a result of email transmission. If verification is required please request a hard copy version. https://outlook.office365.com/mail/none/id/AAMkADIxNjE3NWJlLTMxYmEtNDEwZC1iOGM4LTYxOTllYjNmN2MzZQBGAAAAAABrEkrzGtHSSpsf… 1/1 October 19 Large Development Sites Con- sultation – Local Plan 2017-2036 (Regulation 18) Land West of Lymington Bottom Road, South Medstead Prepared by Black Box Planning on behalf of Redrow Homes blackboxplanning.co.uk Large Development Sites Representation Land West of Lymington Bottom Road, South Medstead Contents 1. Introduction 3 2. Planning Policy Context 6 3. West of Lymington Bottom Road, South Medstead 9 4. Housing Requirement and the Spatial Strategy 20 5. Large Development Sites Assessment 24 6. Conclusions and Recommendations 32 Appendix 1 Information Pack Appendix 2 Site location plan additional areas Appendix 3 Concept Masterplan Appendix 4 Amended Concept Masterplan Appendix 5 Transport Note, October 2019 Appendix 6 Facilities Plan Appendix 7 Lymington Barn Retail Commitment Plan Appendix 8 Lymington Barn Planned Investment Plan Appendix 9 West of England Joint Spatial Plan letter, September 2019 This report has been prepared in accordance with the quality assurance procedures operated by Black Box Planning Ltd Created by: MRTPI Signature: Checked by: MRTPI Signature: Redrow Homes October 19 2 Large Development Sites Representation Land West of Lymington Bottom Road, South Medstead 1. Introduction 1.1. This Representation has been prepared in response to East Hampshire District Council’s Large Development Sites Regulation 18 consultation. It has been prepared by Black Box Planning on behalf of Redrow Homes Southern Counties (Redrow). 1.2. It is focused on the Large Development Sites (LDS) promoted through consultation in September 2019 and the approach to considering a larger number of large development sites, rather than the issues previously considered as part of the Draft Local Plan Regulation 18 Consultation in February 2019. The Representation prepared in response to the February consultation remains relevant, providing comment on the approach to the Spatial Strategy set out in the Draft Local Plan at that time. In addition, a number of policy and environmental constraints have emerged, in more detail, since the close of the February consultation which will have a significant impact on the deliverability of the spatial strategy set out previously. Such issues include the a change in Natural England’s position in respect of eutrophication (Nitrogen Neutrality) and impacts on Natura 2000 sites, including those located in the Solent. These matters are set out in more detail in Section 4. 1.3. Redrow has an interest in Land to the West of Lymington Bottom Road and these Representations provide an overview of matters in the context of that LDS. However, there is an element of overlap between the Land West of Lymington Bottom Road and the South Medstead LDS, including the existing Local Centre at Lymington Barn, the land identified for the provision of a new employment hub at Five Ash Crossroads and MED-022 (the land west of adopted, and now constructed, Local Plan Allocation FM1). Through the LDS Consultation, respective promotion teams have worked co-operatively and recognise that there are shared considerations in both assessment and delivery terms. Redrow Homes October 19 3 Large Development Sites Representation Land West of Lymington Bottom Road, South Medstead 1.4. For the purpose of these Representations where reference is made to the LDS known as the South Medstead LDS it will be referred to accordingly. However, where the geographic area of South Medstead (which includes the LDS at both West of Lymington Bottom Road and the South Medstead LDS) it shall be referred to as South of Medstead. 1.5. The Large Development Sites Regulation 18 consultation is focused on identifying suitable large development sites for inclusion in the East Hampshire Local Plan 2017-2036. It seeks to consider whether the large sites can fulfil the ‘key drivers’ for strategic plan making, as set out at Section 2 of the Site Assessments Background Paper, September 2019 (the Background Paper). In essence, the premise of this approach is set out in the Foreword to the Consultation Document where it sets out that: 1.6. ‘We need to look at all possible options for large development sites to ensure we have the information we need to make an informed decision, and because this scale of development can often address some infrastructure concerns that have been raised. Ad hoc, small-scale development often only adds pressure on infrastructure, rather than help alleviate it.’ 1.7. Redrow supports the consideration of delivering strategic scale development as part of the Spatial Strategy in the Local Plan. The Land West of Lymington Bottom Road and the South Medstead LDS provides a genuine opportunity to deliver a scale of development which will bring forward meaningful gains in the delivery of social and economic infrastructure for both existing and future residents. It recognises the settlement as a sustainable and suitable location for additional housing development as a matter of principle. However, as set out at Section 3, the benefits of delivering a coherent development strategy which integrates with the existing community and underpins the delivery of a range of additional services and facilities, will enhance the sustainability credentials of the settlement for the benefit of all. The delivery of infrastructure is Redrow Homes October 19 4 Large Development Sites Representation Land West of Lymington Bottom Road, South Medstead central to such an approach but this does not just concern utilities and other hard forms of infrastructure (such as roads), it should incorporate all forms of environmental, economic and social infrastructure which is viable, useable and effective. Growth at South of Medstead, given proximity to existing infrastructure assets, is extremely well placed to deliver sustainable development which also results investment into the existing community. 1.8. This is in contrast with other LDS locations subject to this consultation, which bear no relationship to existing settlements, infrastructure provision and are unlikely to be deliverable in their own right. Redrow raise a number of concerns with alternatives being considered. The inclusion of a number of the LDS’ identified would undermine the soundness of the draft Local Plan. In addition, the concerns raised in the February 2019 Representations regarding the pursuance of a spatial strategy which seeks to locate largescale development in the most environmentally sensitive locations remain relevant. 1.9. This Representation should be read in conjunction with the following documents, which are appended for ease: • Information Pack (Appendix 1); • Site Location Plan (additional site areas, Appendix 2); • Concept Masterplan as considered as part of public consultation (Appendix 3); • Amended Concept Masterplan (Appendix 4); and • Transport Note, October 2019 prepared by RPS (Appendix 5). Redrow Homes October 19 5 Large Development Sites Representation Land West of Lymington Bottom Road, South Medstead 2. Planning Policy Context 2.1. An overview of the relevant planning policy context pertinent to the preparation of the Draft Local Plan was set out in the February 2019 Representations. However, in assessing the ten LDS locations proposed, the tests of Soundness and policy approach to planning for strategic scale development set out in the National Planning Policy Framework remain of particular relevance. National Planning Policy Framework, February 2019 (last updated June 2019) 2.2. The National Planning Policy Framework (NPPF) contains the Government’s national planning policy relevant to the preparation of Local Plans and the test for soundness for the purposes of sections 19(2)(a) and 20(5)(b) of the Planning and Compulsory Purchase