H WINCHESTER DRAFT LOCAL PLAN PART 2 DEVELOPMENT MANAGEMENT AND SITE ALLOCATIONS PRE-SUBMISISON CONSULTATION DECEMBER 2015 Representations on behalf of Portico Property Limited Prepared by Paul Slater BSc (Hons) MSc MRTPI Representations on behalf of Portico Property Limited CONTENTS INTRODUCTION 2 PLAN SECTION 4.6 SWANMORE 2 Appendix 1 Land adjacent Cobbett Close Concept Plan Appendix 2 2012 SHLAA Extract Appendix 3 Winchester Draft LPP2 October 2014 Consultation Extract Appendix 4 2014 SHLAA Extract Appendix 5 2015 SHLAA Extract Appendix 6 Land at Dodds Lane LVIA June 2015 Appendix 7 Winchester Initial Site Sieve Winchester Draft Local Plan Part 2 Pre-submission Representations, December 2015 1 Representations on behalf of Portico Property Limited INTRODUCTION 1.1 These representations are submitted in response to the ‘Winchester Draft Local Plan Part 2 – Development Management and Site Allocations’ (LPP2) and on behalf of Portico Property Limited (Portico). PLAN SECTION 4.6 SWANMORE 1.2 Portico objects to the overall approach to the site assessment and selection of draft allocation sites as it applies to Swanmore and the lack of ongoing consideration of sites in the South Downs National Park (SDNP) throughout the process. 1.3 Portico have land under their control at Dodds Lane, Swanmore. The land extends to 1.34ha and forms part of a site which has been considered through LPP2 as site reference 2458. The site lies within the SDNP area but relates well to the built up area of the settlement being to the rear of a recently constructed affordable housing scheme (Cobbetts Close) and also adjoining existing housing on Chapel Road. The land is available and suitable for residential development and can deliver around 27 dwellings. A concept masterplan has been produced for the site and is attached as Appendix 1. 1.4 Portico made representations to the Draft LPP2 in December 2014 highlighting its concerns with the approach to site assessment and the draft allocations at Swanmore. These representations should be read alongside and as an update to previous representations. 1.5 In Portico’s view, the exclusion of Land at Dodds Lane, as a site on the edge of Swanmore, from key parts of the site selection process (such as the SHLAA) is unsound - not justified, not effective and not consistent with national policy. 1.6 It is acknowledged that the LPP1 housing targets remain relevant and are the starting point for the LPP2 site allocations. Accordingly LPP2 does not re- examine these but is allocating sites to meet the previously agreed targets. Policy DS1 of LPP1 distributes 2,500 homes to the Market Towns and Rural Areas and Policy MTRA2 requires about 250 homes in Swanmore. 1.7 It is also acknowledged that LPP2 only considers Winchester District and not the SDNP area. SDNP are currently preparing a Local Plan for the SDNP area and recently published a Preferred Options consultation in October 2015. Winchester Draft Local Plan Part 2 Pre-submission Representations, December 2015 2 Representations on behalf of Portico Property Limited 1.8 There are numerous references in LPP2 to how sites at Swanmore have been assessed and selected for allocation. Paragraph 2.19 of LPP2 states that: Where sites are within the South Downs National Park but adjacent to one of the settlements, they were flagged as such and still subject to assessments so that Winchester City Council may approach the National Park Authority if it was considered that the site is more suitable for allocation than alternative sites outside of the National Park. 1.9 Paragraph 4.6.7 in relation to Swanmore states that: …All the potential housing sites in and around Swanmore that were promoted through the SHLAA were considered… 1.10 Portico supports the intent of these statements but is concerned and objects that they were not followed through in the site allocation process. 1.11 Sites on the edge of Swanmore within the SDNP were considered at early stages of the LPP2 plan. Land at Dodds Lane was included in the 2012 SHLAA (published February 2013) and given an indicative capacity of 31 dwellings (Appendix 2). 1.12 Public consultation undertaken by the Parish in 2013 -2014 identified a local preference for site 2458, Land at Dodds Lane, Swanmore. This was highlighted in the Winchester Draft LPP2 October 2014 Consultation documents (Appendix 3). 1.13 Land at Dodds Lane (Site 2458) had, however, been removed from the 2014 SHLAA – no reason is given but it is assumed that it was due to the site’s location in the SDNP (Appendix 4). 1.14 The Winchester SHLAA Update 2015, Table 7, identifies that Site 2458 Land at Dodds Lane, Swanmore was removed from the SHLAA because of its location within the SDNP (Appendix 5). 1.15 The September 2015 Cabinet paper CAB2711(LP) – APPENDIX E (as referred to at paragraph 3.7 of the Regulation 18 Consultation Statement Part 2 2015) provides some commentary on consideration of Land at Dodds Lane. It is noted that site was considered by Winchester to perform well against several key criteria including accessibility, impact on the Settlement Gap and Winchester Draft Local Plan Part 2 Pre-submission Representations, December 2015 3 Representations on behalf of Portico Property Limited community support (the site is within the sector preferred for development in the Parish Council’s questionnaire). 1.16 Swanmore Parish Council are also noted as supporting the development of Land at Dodds Lane, particularly if land at Belmont Farm (part of the proposed SW1 The Lakes allocation) was not developed. 1.17 The reasoning for the rejection of the of Land at Dodds Lane by Winchester, therefore, appears to relate to: the sites location within the SDNP; and landscape impacts. The sites location in the SDNP area 1.18 Firstly, whilst due regard must be given to the purposes of the National Park and conserving it’s landscape and scenic beauty, the National Park designation does not rule out development in that area. In Portico’s view, it is a factor for consideration in an assessment of alternatives but not a reason to automatically exclude the site from consideration or from the SHLAA. 1.19 Portico similarly does not consider the site’s location in the SDNP area, and outside the LPP2 area, sufficient justification for failing to consider the site. It is clear that the guidance relating to SHLAA concludes that such assessments should consider cross boundary sites such as Land at Dodds Lane – in line with the Duty to Co-operate. 1.20 The NPPG (Reference ID: 3-007-20140306) provides guidance on SHLAA’s. It states that: ‘The area selected for the assessment should be the housing market area and functional economic market area. This could be the local planning authority area or a different area such as two or more local authority areas or areas covered by the Local Enterprise Partnership.’ 1.21 The NPPG (Reference ID: 3-008-20140306) goes on to state that: ‘The assessment should be undertaken and regularly reviewed working with other local planning authorities in the relevant housing market area or functional economic market area, in line with the duty to cooperate.’ Winchester Draft Local Plan Part 2 Pre-submission Representations, December 2015 4 Representations on behalf of Portico Property Limited 1.22 The removal of Land at Dodds Lane from the Winchester SHLAA has informed the LPP2 site allocation process and is a flawed approach when considered against national policy and guidance. 1.23 It is acknowledged that SDNP have also prepared a SHLAA which has considered Land at Dodds Lane. The site is rejected by SDNP due to impacts on the character and appearance of the landscape. Portico rejects this assessment but would also assert that the inclusion of the site in the SDNP SHLAA does not address the failure to assess the site in the Winchester SHLAA. A comprehensive and consistent assessment of sites within and on the edge of Swanmore should have been undertaken to inform the final LPP2 – thereby enabling meaningful consultation and site assessment. Landscape impact 1.24 The indicative layout for the Land at Dodds Lane is presented at Appendix 1 has been informed by a Landscape and Visual Impact Assessment June 2015 (Appendix 6) prepared by Terra Firma Consultants. This LVIA was emailed to both Winchester and the SDNP in July 2015. 1.25 The LVIA concludes that there are no significant landscape effects on individual elements or on landscape character. The north-western part of the site shares few of the SDNP characteristics and is influenced by the proximity of the adjacent residential development. 1.26 Furthermore, the assessment concludes that there are no significant visual effects from the wider landscape within, or outside the SDNP. The only residual effect are the views from the modern housing development off Cobbett Close which abuts the site. This is due to the screening effect of the existing and proposed buffer vegetation to the south and west of the site, the built form of Swanmore and by siting the proposed built form to the west of the site away from the most visually exposed land. 1.27 Therefore, whilst inevitably the development proposals do give rise to some landscape and visual effects, these are not significant except for close range impacts from within existing development at Cobbett Close. 1.28 Furthermore, as the site has been removed from the SHLAA, it is apparent that Portico’s landscape evidence has not been considered in the site selection process. Portico consider that the landscape impact of development on Land at Winchester Draft Local Plan Part 2 Pre-submission Representations, December 2015 5 Representations on behalf of Portico Property Limited Dodds Lane Swanmore has been overstated in the evidence underpinning LPP2, including the Sustainability Appraisal.