Ref: (For official use Winchester District Local only) Plan Part 2: Development Management and Site Allocations Draft Stage Representation Form Winchester District Local Plan Part 2: Name of the document this relates to: Development Management and Site Allocations Please return to: Head of Strategic Planning, Winchester City Council, City Offices, Colebrook Street, Winchester, Hampshire SO23 9LJ or by email to [email protected] no later than 12.00 midday on Friday 5 December 2014. You may also use this form to comment on the Sustainability Appraisal/Strategic Environmental Assessment and Habitat Regulations Assessment within the same period. This form has two parts – Part A – Personal Details Part B – Your representation(s). Please fill in a separate Part B for each representation you wish to make. Part A 2. Agent’s Details 1. Personal Details* (if applicable) *If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2. Title Mr Miss First Name Adam Jade Last Name Welch Ellis Job Title (where relevant) Assistant Planner Organisation (where relevant) Turley th 6 Floor North 2 Charlotte Place c/o agent Address Southampton Post Code SO14 0TB Telephone Number E-mail Address (This will enable us to contact you regarding future stages of the Plan) Part B – Comments on Local Plan Part 2 and supporting documents. Use this section to set out your comments on Local Plan Part 2 or supporting documents (such as the Sustainability Appraisal or Habitat Regulations Assessment). Please use a separate sheet for each representation. 3. Name or Organisation : The Welch family 4. Please set out clearly on which paragraph, policy, or map you are commenting. Paragraph Policy 2.13; 2.15 Map Other number number 5. Is your representation: Supporting Objecting Commenting 6. Please set out clearly why you are objecting to, or supporting, the specific areas of the plan. If you are objecting, please set out what change(s) you think should be made to Local Plan Part 2. See section 2 of the accompanying report which in addition to the specific paragraphs comments on the strategy for Winchester Town (Continue on a separate sheet /expand box if necessary) Part B – Comments on Local Plan Part 2 and supporting documents. Use this section to set out your comments on Local Plan Part 2 or supporting documents (such as the Sustainability Appraisal or Habitat Regulations Assessment). Please use a separate sheet for each representation. 4. Please set out clearly on which paragraph, policy, or map you are commenting. Paragraph Policy 3.3.1-3.3.6 Map Other number number 5. Is your representation: Supporting Objecting Commenting 6. Please set out clearly why you are objecting to, or supporting, the specific areas of the plan. If you are objecting, please set out what change(s) you think should be made to Local Plan Part 2. See section 3 under ‘Housing’ and ‘Affordable Housing’ of the accompanying report (Continue on a separate sheet /expand box if necessary) Part B – Comments on Local Plan Part 2 and supporting documents. Use this section to set out your comments on Local Plan Part 2 or supporting documents (such as the Sustainability Appraisal or Habitat Regulations Assessment). Please use a separate sheet for each representation. 3. Name or Organisation : The Welch family 4. Please set out clearly on which paragraph, policy, or map you are commenting. Paragraph Policy 3.6.1-3.6.3 Map Other number number 5. Is your representation: Supporting Objecting Commenting 6. Please set out clearly why you are objecting to, or supporting, the specific areas of the plan. If you are objecting, please set out what change(s) you think should be made to Local Plan Part 2. See section 3 under ‘Development Needs’ of the accompanying report (Continue on a separate sheet /expand box if necessary) 3. Name or Organisation : The Welch family 4. Please set out clearly on which paragraph, policy, or map you are commenting. Paragraph Policy DM6 Map Other number number 5. Is your representation: Supporting Objecting Commenting 6. Please set out clearly why you are objecting to, or supporting, the specific areas of the plan. If you are objecting, please set out what change(s) you think should be made to Local Plan Part 2. See section 4 of the accompanying report which relates to the implement of Policy DM6 and the Open Space Straetgy (Continue on a separate sheet /expand box if necessary) 5 December 2014 Delivered by email and post Head of Strategic Planning Winchester City Council City Offices Colebrook Street Winchester Hampshire SO23 9LJ Dear Sirs DRAFT LOCAL PLAN PART 2: DEVELOPMENT MANAGEMENT AND SITE ALLOCATIONS CONSULTATION (DECEMBER 2014) On behalf of our client, the Welch family, please find set out below formal representations in respect of the Winchester City Council Draft Local Plan Part 2 (LPP2) Development Management and Site Allocations. By way of background, our client has an interest in land adjacent the Down House, Harestock Road in Winchester measuring approximately 5.3 hectares in area (see Appendix 1 of our representations). The site offers the opportunity to deliver up to 45 dwellings, 40% of which will be affordable and on-site open space provision (over and above the provision associated with the development of 45 dwellings). In respect of the LPP2 Development Management and Site Allocations, the main thrusts of our client’s representations are: The absence of the identification of any sites to meet local housing needs on the built up edge of Winchester is in direct conflict with adopted Policy WT1 of the JCS; Sites within the built up area will not deliver sufficient affordable housing to meet objectively assessed housing needs alone, nor will they provide new open space to address the existing deficit; The identification of greenfield sites to provide the necessary certainty of delivery to meet objectively assessed local market and affordable housing needs; and deliver much needed open space; The deliverability of various elements of Winchester’s housing requirement within the built up area are questionable. In the interests of positive and proactive planning the Council should allocate greenfield sites such as land adjacent the Down House, Harestock Road in order to ensure sufficient flexibility over the plan period; and 6th Floor North 2 Charlotte Place Southampton SO14 0TB T 023 8072 4888 turley.co.uk Registered in England Turley Associates Limited no. 2235387. Registered office: 1 New York Street, Manchester, M1 4HD Land within our clients’ control at Harestock Road, offers the opportunity to deliver high quality public open space which will make a significant contribution to addressing local deficiencies in the Harestock area. On this basis the Draft LPP2 Development Management and Site Allocations is neither ‘Positively Prepared’, ‘Justified’ nor ‘Effective’ as required to satisfy the tests of soundness set out in paragraph 182 of the National Planning Policy Framework (NPPF). I trust these comments are duly noted and I look forward to receiving you acknowledgement of this in due course. Please do not hesitate to contact me should you require further information. Yours Sincerely Jade Ellis Assistant Planner [email protected] 2 Draft Local Plan Part 2: Development Management and Site Allocations Consultation Land adjacent the Down House, Harestock Road, Winchester December 2014 Contents 1. Introduction 1 2. Meeting Development Needs 3 3. Winchester Town 4 4. Development Management 12 5. Summary 16 Contact Jade Ellis [email protected] 5 December 2014 i 1. Introduction 1.1 These representations have been prepared by Turley on behalf of the Welch family in response to the Winchester City Council Draft Local Plan Part 2 (LPP2) Development Management and Site Allocations. It is understood that the LPP2 follows on from the Local Plan Part 1 – Joint Core Strategy (LPP1) that was adopted by Winchester City Council and the South Downs National Park Authority in March 2013, and will identify the development sites necessary to meet the remainder of LPP1’s requirements throughout the District (excluding the South Downs National Park). 1.2 For absolute clarity, our client has an interest in land adjacent the Down House, Harestock Road in Winchester measuring approximately 5.3 hectares in area. The site is identified in the Council’s Strategic Housing Land Availability Assessment (SHLAA) December 2012 (updated February 2013) as ‘Land at Kennel Lane/Main Road’ as part of a larger area of the land under site refs. 423, 424 and 2489. The site identified on the ‘Broad Land Uses Plan’ included at Appendix 1 offers the opportunity to deliver up to 45 dwellings, 40% of which will be affordable and on-site open space provision (over and above the provision associated with the development of 45 dwellings). 1.3 In summary, the site offers the opportunity to provide a high quality residential development and the provision of new open space and community facilities on the north west built up area of Winchester, the largest settlement in the District, in a location within a 10 minute walking distance of schools, GP surgery, community and recreational facilities at the Weeke Local Centre. 1.4 In respect of the LPP2 Development Management and Site Allocations, the main thrusts of our client’s representations are: The absence of the identification of any sites to meet local housing needs on the built up edge of Winchester is in direct conflict with adopted Policy WT1 of the JCS; Sites within the built up area will not deliver sufficient affordable housing to meet objectively assessed housing needs alone, nor will they provide new open space to address the existing deficit; The identification of greenfield sites to provide the necessary certainty of delivery to meet objectively assessed local market and affordable housing needs; and deliver much needed open space; The deliverability of various elements of Winchester’s housing requirement within the built up area are questionable.