Object

Draft Local Plan - Supplementary Consultation

Representation ID: 6694

Received: 14/02/2019

Respondent: Gillian Griggs

Representation Summary:

This allocation would be a large scale encroachment into the countryside and Green Belt extending well beyond the built limits and natural topography of Knowle. The topography and substantial changes in levels are not addressed in the masterplan. Without information on levels, infrastructure impacts (particularly highways/junction impacts/mitigation), impacts on Knowle Conservation Area and clarity on the GB and LWS boundaries, it is not possible to support this allocation and the draft concept masterplan. The issues raised by the NF Landscape Study and Masterplanning/Design and Design Coding Study need first to be addressed before any allocation can be supported.

Full text:

My response to Q22 which sets out why I consider an 'in principle' objection to this allocation should be maintained pending further information from the Council on infrastructure and other matters raised in the Forum's original objection.
This is expanded upon below having regard to the information in the Landscape Study by Crestwood Environmental and the Heritage and Character Study and Masterplanning/Design and Design Coding work by Urban Vision Enterprise CIC.
In its submission to the 2016 DLPR consultation, the Neighbourhood Forum made comments on these two sites which raised questions over the allocations given the Council's own evidence base. This showed that:
* the sites are at the least accessible end of the scale and are poor in locational terms with no public transport access
* development would be a significant encroachment in to the Green Belt and countryside
* the parcels are 'best performing' and, arguably, 'moderately performing' Green Belt
* the impacts of additional traffic, particularly on the High St junction need to be explained as well as potential impacts on the Conservation Area
* further work is needed to understand the impact of topography on development, both housing and sporting, and of development on trees, hedgerows and Local Wildlife Sites.
Since then the Forum has had three meetings with the site promoters and the Council when their baseline studies have been shared. Whilst this was welcomed by the Forum, there has been no substantive responses or progress on the above matters. In particular:
1. The Council state that this allocation is consistent with Option G of the Spatial Strategy for the significant expansion of rural villages. However, the Spatial Strategy does not appear to favour any one Option and this option was one of the worst performing in the Interim Sustainability Appraisal.
2. The Council has not shared transport study findings with the NF as promised. However, the NF has been made aware of the 'measurable impact' that the Council's own Transport Study has shown at the High St junction. Despite this, the impacts of proposed development on traffic flow, junctions, village centre, Conservation Area and station parking are not mentioned in the Supplementary Update. Nor is there any indication of how impacts can be mitigated or how a bus service to this site can be achieved.
3. The Council considers that the main parcel of land at Hampton Rd would be a 'rounding off' of the settlement. A site visit demonstrates that this is not the case. Development here would be a major incursion into the countryside and Green Belt setting of Knowle.

4. The Atkins assessment of the larger parcel of Green Belt (parcel 36) as moderately performing is questionable. It is scored only as a 2 in terms of safeguarding the countryside from encroachment even though it meets the criteria to score 3, as does parcel 37. In terms of preserving the setting of the historic village it scores a 0 despite the fact that the landscape and topography play an important role in protecting the rural and historic setting of the village. The 'considerations' set out in the table on p7 of the GBA state that an assessment of topography has been taken into account in the scoring of this GB purpose but it is not evident in the scoring of this parcel. The scoring needs to be revisited. See also my comments in response to Q2 on inconsistencies in scoring.
5. The Council refers to providing a defensible GB boundary to the smaller parcel of land and continuing the GB boundary on the larger parcel by continuing the GB boundary on from the rear of properties along Wychwood Avenue down to Hampton Rd. However, there is no existing definitive boundary on site where shown on the masterplan- it is proposed to create a new boundary through road construction. This appears to be a novel approach to creating new GB boundaries and is inconsistent with the insistence elsewhere by the Council that sites cannot be reduced in size because strong existing defensible boundaries must be adopted. A number of other large sites may perform better in the Council's assessments if some areas can be excluded by creating new GB boundaries.
6. More information is required to explain how the Council has concluded that this is a 'green' site. Without this it is not possible to accept the Council's conclusion that development will only have no, or relatively low impact on relevant considerations, or that a severe impact can be mitigated.

As regards the Masterplan, the draft report from Crestwood Environmental for the NF together with the Heritage and Character Assessment and the Masterplanning/Design and Design Coding by Urban Vision Enterprise CIC provide clear evidence and advice on what the masterplan for these sites should contain if development in these locations is confirmed. The following summarise the key landscape and design considerations which need to be taken into account as they are not reflected in the concept masterplan at present:
1. Levels and topography.
The masterplan fails to reflect the significant levels issues across the northern parcel and how they will be addressed both for housing and for sports pitch provision. The image of the masterplan is highly misleading without any indication of how the change of levels will be accommodated. This is a sensitive issue locally given that the change in levels across the recently completed Taylor Wimpey development at Middlefield Spring were not taken into account leading to extremely poor relationships between houses at the lower level being dominated by 3 storey apartments on the higher level.
There is a 17m change in level across the site with the ground rising to a high point on a ridge. The masterplan shows residential development extending beyond the ridge line thus impacting on the GB and on views on the approach into Knowle from Hampton Rd. The NF Landscape Study advises that development on this parcel should be contained by the existing hedgeline of the second field to provide a) a definitive GB boundary and b) sit properly within the landscape such that the natural topographical containment of the settlement of Knowle is respected without any adverse impact on its character.
The change of levels must also have regard to the relationship to existing properties, particularly those in Whateley Hall Rd and Alveston Grove.
The change in levels will necessitate some significant engineering work to accommodate residential development and also to create level sports pitches. This will lead to terracing which will alter the landscape and rural character, particularly of the Green Belt approach to Knowle. The provision of car parking, a sports building near the high point of the land, floodlighting and the erection of high netting (necessary for the cricket ground adjacent to Hampton Rd) will all add to this significant adverse impact. This is a particular concern raised in the Landscape Study which concludes that other sites should be preferred to the larger parcel because of its adverse impacts.
If development is to be accommodated on these parcels of land, the masterplan should be amended to show how the levels are to be taken into account and ensure that residential development is restricted to the natural topographical containment of Knowle. The extent of earth works to accommodate the community sports hub and more information on the location and size of the sports hub building need to be made available to residents before further comment on the suitability of this area to accommodate sports pitches and related uses can be assessed.
2. Densities:
The Council needs to be clearer about the definition of high, medium and low densities.
High density on the whole area of the east side of Hampton Rd is not acceptable bearing in mind:
i) the Council's own evidence that states both parcels have low landscape capacity. The evidence of the NF Landscape Study, Heritage and Character Assessment and Masterplanning/Design and Design Coding Study all recommend that any new development on the edge of built settlement should make a sensitive transition between the built development and the open countryside or Green Belt through adopting lower densities towards the rural edge to avoid the appearance of overdevelopment and to maintain the rural character;
ii) the sensitive relationship to Grimshaw Hall, a Grade 1 Listed Building; and
iii) the criticisms from local residents about the density of the adjoining recent residential development which is around 36 dph.
iv) such a large area of high density would be out of keeping with the local character and be inconsistent with both LP and NP policies which aim to respect local character. High density on part of the site may be acceptable for some dwellings such as specialist accommodation for the elderly.
Development on the larger parcel, which is also described as having low landscape capacity, should be of medium density transitioning to low density as it reaches the retained GB and open countryside.
3. Public open space and structural green framework
Both sites should have a clear structural green framework which should be in place early during any development and preferably before house building commences. The current masterplan needs to be much stronger on this. The larger northern parcel contains Local Wildlife sites as well as hedgerows, protected trees, a green buffer to Grimshaw Hall, protected footpaths and the sports facilities. All these, together with a green buffer to houses in Whateley Hall Rd and Alveston Grove, should be shown as structural open space for any development on this site.
Levels information is again necessary to an understanding of the functionality and attractiveness of the POS. It appears from the masterplan that the existing LWS is to be treated as POS to serve this development. If that is correct, it is not acceptable as this development must meet its own needs, not utilise existing protected wildlife sites. For clarity, the masterplan should exclude the existing LWS at Purnells Brook.
It is not acceptable for there to be no POS to serve the southern area.
The accessibility of the community sports hub in the retained Green Belt corridor to the public also needs to be clarified. Will the sports area be fenced off preventing access along the green corridor?
4. Design Coding
I support the recommendation of the Landscape Study that any allocation at Hampton Rd be subject to a Supplementary Planning Document or Design Code to inform development which should be consulted on with the Neighbourhood Forum. In addition, matters relating to levels, green infrastructure, landscape and visual impacts and floodlighting, together with transportation and heritage impacts, should be properly considered in advance of any allocation.
Concluding comments on this allocation and the masterplan
Without information on levels, infrastructure impacts (particularly highways/junction impacts/mitigation), and clarity on the GB and LWS boundaries, it is not possible to support this allocation and the draft concept masterplan in its current form. The issues raised by the NF Landscape Study and Masterplanning/Design and Design Coding Study need first to be addressed.
This is not to say that these sites are not capable of some development. It is acknowledged that these sites, particularly the Football Club and Cricket Ground, may have the potential for some sympathetic residential development but at present what is being proposed is not justified by either the Council's methodology, its evidence base or that of the Neighbourhood Forum.