Our ref: J029050.151221.tc Mr S Opacic, Head of Strategic Planning, Winchester City Council, Colebrook Street, Winchester SO23 9LJ sopacic@winchester.gov.uk 21 st December 2015 Dear Mr Opacic, Winchester District Local Plan Part 2 Development Management and Site Allocations Publication Draft for Consultation GL Hearn acts on behalf of Crest Nicholson (Crest) in relation to the promotion of SHLAA site 356 comprising land at The Vineyard and Land to the east of Tangier Lane (the Tangier Lane Site), Bishop s Waltham. Crest has been promoting the land since March 2011, through the Winchester District Local Plan Part 1 review and subsequently via the evidence gathering stages associated with development of the Bishop s Waltham Parish Development Plan and the Winchester District Local Plan Part 2 Development Management and Site Allocations. GL Hearn is instructed to make representations on behalf of Crest to the current consultation stage of the Winchester District Local Plan Part 2 Development Management and Site Allocations (hereafter LPP2). They are made with the objective of achieving a sound plan without undue delay in the preparation process. Crest remains broadly supportive of the emerging Local Plan and wishes to help constructively facilitate delivery of the key housing allocations. These representations should be read in conjunction with previous representations made by GL Hearn through the plan making process (7 th March 2014 and 5 th December 2014). Background and general approach to Housing allocations The Winchester City Council Local Plan Part 1 was adopted in March 2013. Policy MTRA2 of the Plan prescribes a target of about 500 new homes for Bishop s Waltham. The material supporting the Bishop s Waltham Development Strategy identifies 128 dwellings that are classified as completions/commitments within the Plan period, leaving a residual requirement of 372 dwellings to be allocated. Source New Dwellings Completions (1.4.2011 31.3.2015) 49 Outstanding Permissions at 31 st March 2015 55 SHLAA sites within settlement boundary 24 Total Supply 128 Page 1 of 7
This approach would deliver up to 500 dwellings within the settlement via allocations, with the flexibility required by the NPPF and the target of about 500 dwellings being provided by windfalls that the Council expects to be delivered and which have not been taken into account in the supply figures. However, we noted in our previous representations to the Bishop s Waltham Development Plan (dated 7 th March 2014 and the previous consultation on the draft LPP2 dated 5 th March 2014) that reliance on all commitments coming forward and all SHLAA sites delivering as predicted is probably optimistic. Therefore, in our view it would be sensible to plan positively for a housing target at the upper end of the range implied by about 500 dwellings at Bishop s Waltham. It would be reasonable to conclude that this would be up to 550 dwellings during the Plan period. If it is assumed that around 100 of the identified commitments come forward and around 50 windfalls could be delivered then having regard to the opportunities that have been identified by the Development Strategy, it would be positive and pragmatic to aim for these allocations to deliver around 400 dwellings, subject to the requirement that sites should be delivered in accordance with the principles of sustainable development. This would provide a positive approach to planning for housing, rather than relying on all sites being delivered in full to meet the minimum requirement, and hoping that unidentified sites come forward to boost supply. It would also include a margin of flexibility and adaptability advocated by the NPPF (paragraph 14; paragraph 157). The Winchester District Local Plan Part 2 site allocations strategy identifies allocations that collectively could deliver circa 380 dwellings during the Plan period, apportioned to the following sites: Coppice Hill (Approx. 80 dwellings) Martin Street (Approx. 60 dwellings) The Vineyard and land to the East of Tangier Lane (Approx. 120 dwellings) Albany Farm (Approx. 120 dwellings) Tollgate House (limited market housing to facilitate the restoration of Tollgate House) The representations below address the proposed site allocation at The Vineyard and land to the East of Tangier Lane (the areas of SHLAA site 356 that have been identified as a development option). The Vineyard and Land to the East of Tangier Lane Allocation Crest supports the allocation of land at the Vineyard and land to the east of Tangier Lane (Tangier Lane Site) as one of the principal locations for new housing at Bishop s Waltham. The site has been identified as a result of discussions with the Bishop s Waltham Parish Council and Winchester City Council. Crest has engaged with the Bishop s Waltham Neighbourhood Plan Working Group and has provided evidence in support of the development potential of the site. Plans and proposals for development of the whole of SHLAA site 356 were drawn up and presented to the Group and advice was given on the nature of development that could be achieved. Planning and sustainability appraisals have been carried out; masterplan feasibility studies and transport assessments have been undertaken and shared with the Parish and City Councils. The work and evidence previously presented to the Councils to date has demonstrated that a 200 dwelling scheme with supporting open space, arranged across the whole of SHLAA site 356 could be delivered sustainably. The current consultation information shows the Vineyard/Tangier Lane Site (part of the SHLAA Site 356), now allocated for approximately 120 dwellings, using only the northern most part of land to the south east of Tangier Lane and the northern half of the Vineyard, to the north west of Tangier Lane. While it is acknowledged that the Councils have adopted a dispersal approach to allocating sites for residential development to meet the requirement identified in Local Plan Part 1, this should not be an exercise dictated by the objective of apportioning a set quantum of dwellings across the sites selected as the most appropriate for development, pursued without careful regard to site-specific factors; which may support the sustainable delivery of additional dwellings within these sites. Crest has prepared a draft illustrative masterplan that Page 2 of 7
could comfortably accommodate 120 dwellings on the land identified by the Council. Whilst Crest supports the site s allocation for 120 units, our client considers that the masterplan demonstrates the site could accommodate between 120 and 150 units. The masterplan is attached to these representations (Drg No. 2064-SK-1005-B Sketch Site Layout). The layout uses the northern component of the land to the south east of Tangier Lane and the northern half of the Vineyard, to the north west of Tangier Lane. The draft concept masterplan indicates two access points, via Albany Road and The Avenue, with pedestrian and cycle links across Tangier Lane, linking the parcels either side of the lane. Highways Implications and Site Access With respect to the wider cumulative impact of the allocated housing sites upon the wider highway network at Bishop s Waltham, Winchester City Council commissioned SYSTRA, transport consultants, to undertake a study to assess the cumulative impacts of the development growth proposed within LPP2 along the B2177/B3354 corridor. The study focused on a number of key junctions along this route and in relation to Bishop s Waltham included Winchester Road/Winters Hill; Winchester Road/Old Station Road roundabout and Winchester Road/Botley Road roundabout. Traffic performance statistics revealed that these junctions have capacity to accommodate planned and background growth to 2031. With respect to access to facilities and sustainable modes of transport, the Council s Transport Assessment of Potential Site Allocations rates the site as adequate in terms of accessibility. However, the WCC Sustainability Appraisal suggests that the distance of the site from the majority of services and facilities located in the town would lead to minor negative effects in the short/medium term. The Vectos Transport Assessment prepared on behalf of Crest disagrees with this, concluding that the location of the site accords with current transport policy regarding accessibility and that local facilities and services could be conveniently accessed by a number of sustainable transport modes, including walking, cycling and public transport services. The site is well located within walking distance of the town centre and its associated health and community facilities. While it is located slightly beyond the 2 kilometre threshold for walking to the local village schools, the site is well connected to existing public rights of way and established footpath links, on routes which are not heavily trafficked. As a requirement of any allocation it would be reasonable and feasible to seek some improvement to pedestrian links between the site and key local facilities in the centre of Bishops Waltham. The Vineyard/Tangier Lane allocation is one of the two main sites identified to deliver housing growth in Bishop s Waltham, the other being Albany Farm (120 dwellings); The Vineyard/Tangier Lane site is both closer to the local schools and town centre facilities, and is also more accessible by non-motorised modes of transport. During the December 2014 public consultation on LPP2, the majority of the representations received relating to Policy BW3 The Vineyard/Tangier Lane Housing Allocation were concerned with options available to access the site. GL Hearn has advised in previous representations that three potential options exist to provide access to The Vineyard/Tangier Lane site (via Albany Road, Tangier Lane and The Avenue). In this respect a transport assessment associated with the site has been undertaken by Vectos Transport Planning. The assessment demonstrates that The Avenue and Albany Road each provide viable access options; the respective junctions with Winchester Road are each capable of safely accommodating traffic associated with a development of up to 200 dwellings. The assessment, which was submitted with previous representations made on behalf of Crest, also accompanies these representations. It demonstrates that each access option could safely accommodate a higher volume of traffic than the draft allocation would require. Additionally, the report shows that the site is well-connected and that there are no impediments to delivery in respect of safe vehicular and pedestrian access. To facilitate access via the end of The Avenue there would be a requirement for the access road to cross the corner of Priory Park, entering the allocation at the north eastern corner of the land to the east of Tangier Page 3 of 7
Lane. The route could be delivered with only limited land-take from the playing field, comprising an area not used for pitch provision. Title to the land, which rests with the Parish Council, has been checked and there would be no restriction on using the land for access purposes. To achieve access via Albany Road the road would extend across the unmade section of track leading to the allotments and cricket field to the south, and would be routed in an easterly direction encroaching on a small section of the land designated as a Site of Importance for Nature Conservation (SINC). As part of the proposed access works the section of carriageway leading from the end of Albany Road into the site would be made up to adoptable standard, incorporating existing sections of verge and parts of the unmade surface into parallel parking bays beyond the running sections of carriageway. Given the width of this part of the allotment access track there is also the opportunity to provide dedicated parking/loading bays for allotment holders, to the benefit of users of the allotments and residents of the local area. The extent of land would also offer an opportunity to introduce verge/boundary landscaping alongside the allotments to help enclose and shield the plots, creating an attractive arrival point at the end of Albany Road. It is noted that an access point via Tangier Lane was considered in an earlier Vectos Transport Assessment, which advised that a case could potentially be made for accessing the site from the Lane. However, given the availability of alternative options via Albany Road and The Avenue, this option was not actively pursued. Following initial feedback during the public consultation period, Vectos Transport Planning has reviewed the original assessment of Tangier Lane. The updated assessment considers that an access of suitable width could be delivered via Tangier Lane subject to the removal of some existing foliage and the relocation of street lighting. A meeting was held between Crest, Vectos Transport Planning and Hampshire County Council on 11 th December 2015 at which the principle of accessing the site via Tangier Lane was agreed. A plan submitted with these representations shows details of the proposed access points from Albany Road, The Avenue and Tangier Lane and demonstrates that all of the accesses are feasible and deliverable (Drg No. 2064-SK-1100-A Indicative Access Arrangements). Crest has control over the land necessary to facilitate access via Albany Road. The land required to deliver a suitable carriageway width via Tangier Lane is either within the limits of the highway, or comprises land owned by a third party with whom Crest is in discussions regarding the securing of an option. The small section of Priory Park required to facilitate access is owned by the Parish Council, who have been instrumental in identifying and selecting the draft housing allocations, including the proposed points of access. It is therefore reasonable to conclude that they are willing to make the land available to provide a means of access. Within the representations made by Crest to the LPP2 in December 2014, it was stated that Policy BW3 should be amended to include access via Tangier Lane as an option within the policy. The latest iteration of the policy, within the Submission Draft of LPP2 makes reference to Tangier Lane as a potential means of access. However, as currently worded the policy requires the development to secure access via all three points. This is unduly onerous and as demonstrated by the submitted transport assessment, would be unnecessary. Mindful of this, the following amendments to the proposed Policy BW3 are sought: Policy BW3 The Vineyard/Tangier Lane Housing Allocation Land at The Vineyard and land east of Tangier Lane, as shown on the Policies Map, is allocated for the development of about 120 dwellings. Planning permission will be granted provided that detailed proposals accord with the Development Plan and meet the following site specific development requirements: Nature and Phasing of Development - A masterplan establishing principles for the disposition of housing, open space, access points and linkages with adjacent sites and the wider countryside, including proposals for the SINC to ensure that there is no net loss of biodiversity for the whole allocated area, should be submitted Page 4 of 7
with each application for development. Any subsequent applications for all or part of the site should also demonstrate how the proposal will accord with these principles and achieve the form of development intended buy this allocation as a whole. Access - Provide two points of access via Albany Road and Tangier Lane/or The Avenue, including traffic management measures to address any potential problems at the junctions with Winchester Road and with on-street parking; - Provide a new/improved footpath/cycleway along the northern edge of the site as part of a route along the southern edge of Bishop s Waltham to link with Priory Park and the Martin Street Site (Policy BW2) and the Albany Farm site (Policy BW4). Environmental - Provide substantial landscape framework to create a new settlement edge to the south and west; - Protect, retain and reinforce existing treed boundaries; - Provide on-site open space (Informal Open Space and Local Equipped Area for Play); - Minimise the impact of the access points on the Site of Importance for Nature Conservation (SINC) and Priory Park; - Improve/manage the SINC as Natural Green Space and ensure no net detriment to biodiversity (including habitat isolation and fragmentation) through onsite and, if necessary, offsite measures; - Create a green corridor along the southern boundary of the site to improve pedestrian and biodiversity links. Infrastructure - Contribute to the expansion of Bishop s Waltham Infants and Junior Schools and other infrastructure need to make the development acceptable in planning terms. Ecology During the December 2014 consultation on LPP2, Natural England raised concerns regarding the future of the SINC adjacent to Albany Road and the impact that public access may have on its integrity. Winchester City Council has had further discussions with Natural England regarding future management of the SINC during which potential compensatory biodiversity measures were explored as a requirement of the policy. It is important to note in this context that with the exception of the small corner section of the SINC required for access to The Vineyard, the draft concept masterplan shows the SINC land to the north of the Vineyard retained as an open landscaped buffer between the existing housing on Siskin Close and Ambleside and the proposed allocation. It is Crest s intention that this land would be improved and managed to the benefit of its habitat value and as a community resource. The Parish Council or Hampshire and Isle of Wight Wildlife Trust could be assigned the land, rendering it either as a publicly accessible space or as a protected area with restricted access, depending on the objectives of the beneficiary. Aspect Ecology has carried out an Ecological Appraisal of the SINC, which concludes that the current designation is merited. However, the grassland (the reason the site is of interest) has become impoverished though lack of positive management and as such, there is considerable potential to secure a net gain in biodiversity through implementation of a management strategy delivered as a requirement of any allocation. Aspect Ecology has also carried out an Ecology Appraisal of the wider site. Improved management of the SINC itself and the creation of green links and pathways through the wider design of the scheme, together with specific species mitigation and enhancement proposals, would help to facilitate net gains, in accordance with the objectives set out in the NPPF (paragraph 109). Page 5 of 7
Green Infrastructure Winchester City Council s Sustainability Appraisal of Potential Allocations suggests that development of the site would result in the loss of Green Infrastructure Assets. As described above, delivery of the SINC land to the north of The Vineyard as publicly accessible green space/improved habitat would deliver tangible Green Infrastructure benefits, along with suggested improvements to the pitches and environs of the allotments as outlined above. An increase in the quantum of development would help to support more comprehensive improvements in this regard. Development of the SHLAA site (and indeed the allocation now proposed) would not result in the loss of rights of way, public open space, allotments, local nature reserves or SSSIs. Contrary to the assessment it is contended that there would be GI benefits as a result of the development of the site. Through scheme design there is a valuable opportunity to create and improve lateral pedestrian links across the south of Bishop s Waltham improving accessibility to the public open space, allotments and cricket pitch immediately to the north west of the site. Housing would address these areas positively seeking to create links between the site and the under-used mini football pitch and area of green space adjoining the boundary of The Vineyard to the west. A large mature oak tree situated on this boundary could be incorporated as a key landscape feature, with dwellings fronting onto, and positively addressing it, accentuating views towards the open space beyond. The layout could create a focal point around this established landscape feature and create links around the tree into the open space to the west, thereby drawing it into the settlement and inevitably increasing its use and value to the community. Crest have been in discussions with Bishop s Waltham Cricket Club who neighbour the site to the north west with regard to the provision of an additional cricket green to the south west of The Vineyard. This is positively supported by the local cricket club and would further provide positive net green infrastructure gains to Bishop s Waltham arising from the development. Overall, the allocation would encourage incorporation and enhancement of existing green infrastructure and the creation of a network running through the southern margins of the settlement, in accordance with the draft objectives set out within the emerging Local Plan Part 2. Landscape The Council s Landscape appraisal suggests that part of the SHLAA site (south west part of the Vineyard site, to the north of Tangier Lane) is most Sensitive in landscape terms due to (its) special quality and sense of place in terms of local landscape character. This assessment of the quality of the landscape in this location is disputed. It is pertinent to note to there are large pylons running in close proximity parallel to the south western boundary of The Vineyard. Furthermore the existing hedgelines within The Vineyard site would act as obvious visual buffers to the development, and could readily be supplemented to provide screening, if required. As noted above, a concept Masterplan has been prepared to show how a scheme for residential development extending south to the first defined hedgeline within The Vineyard site could comfortably deliver 120 dwellings, including the allocated land to the east of Tangier Lane. The southern boundary of the development area within The Vineyard is bounded by a robust and clearly defined hedge with trees that create a logical and obvious line to define development on the site. Crest has also considered layout options that would take in additional land to the south within The Vineyard, extending to the second established hedgeline, which would also provide a robust, defensible boundary. The larger site could deliver further dwellings; such that if combined with the allocated land to the east of Tangier Lane there would be more than sufficient land to accommodate between 150 and 160 dwellings in total, with an extensive open space buffer extending towards that valley-bottom. The extension of the development boundary southwards within The Vineyard, to the second defined hedgeline, would create further capacity without compromising the criteria that have informed the allocation, providing a contingency position against under delivery from the other main sites (as outlined below). Page 6 of 7
In accordance with Policy CP2 of the Winchester District Local Plan Part 1, the site has the potential to deliver a mix of market homes for sale; affordable homes and homes attractive to the private rented sector. It is considered that the sites identified by the Councils at Bishop s Waltham to accommodate the range of housing required are realistic. However, the quantum of development allocated to each should be adjusted to provide a more robust strategy to deliver up to the 400 dwellings advocated within these representations. Accordingly, it is suggested that the strategy for Bishop s Waltham should be defined as follows: Coppice Hill (Approx. 60 dwellings) Martin Street and Part of Priory Park (Approx. 60 dwellings) The Vineyard and land to the East of Tangier Lane (approx. 160 dwellings) Albany Farm (approx. 120 dwellings) Tollgate House (limited market housing to facilitate the restoration of Tollgate House) The Vineyard and land east of Tangier Lane site represents a sustainable location for new housing development in Bishop s Waltham. It is currently identified as having capacity for approximately 120 dwellings. However, there is potential for the quantum of development on the site to be increased without compromising any of the Councils objectives for allocation and to help provide a contingency against potential under delivery from some of the other proposed residential sites. If you require any further information please contact me without hesitation. Yours sincerely, Tony Clements Planning Director tony.clements@glhearn.com Enc: Illustrative Masterplan 2064-SK-1005-B Sketch Site Layout Indicative Access Arrangements 2064-SK-1100-A Indicative Access Arrangements Page 7 of 7