Publication (Pre-Submission) Local Plan Part 2:
Development Management and Site Allocations
Comments
Part A
Personal Details:
Winchester Heritage Centre, 32 Upper Brook Street, Winchester, SO23 8DG,
01962 851664, secretary@cityofwinchestertrust.co.uk, Chairman: Keith Leaman
Part B Legal Compliance and Duty to Co-operate
The Trust considers the Plan is legally compliant.
The Trust considers the Plan complies with the Duty to Co-operate subject to what is stated about paragraph 1.13 under Soundness.
Part C Soundness
The Trust does not consider the Plan is sound in all the representations set out below.
Introduction and Background
Paragraph 1.13 Duty to Co-operate
Not positively prepared nor Justified.
Why
Winchester City Council’s area (The District) and adjacent areas within Hampshire are going to be subjected to increases in vehicular traffic on the road network during the plan period as a result of housing and other development. Hampshire County Council (HCC) is the highway authority and it is important that the impact of developments on the highway network is considered as a whole. Although the Duty to Co-operate Statement refers to meetings with HCC, there is no evidence that HCC has considered the effects of traffic as a result of developments in Hampshire on the District’s road network nor co-operated in implementing the recommendations of the 2009 Transport Assessment by MVA Consultancy (The MVA Transport Report) of the transport needs of the District.
In Winchester Town there has been no significant progress in considering traffic management on the existing road network since the Winchester Town Access Plan (WTAP) was published in 2011 and there has been no action taken to improve air quality and reduce congestion. This requires co-operation between Winchester City Council (WCC) and HCC and there is no evidence that this has taken place. The need for local authorities to co-operate is a requirement of paragraph 31 of the NPPF.
Proposed Changes
The paragraph should acknowledge the need for more joint working between HCC and WCC to deliver the actions recommended in the MVA Transport Report and as it was prepared about 6 years ago it may be that a more up to date assessment is now required.
Winchester Town
Employment : References to Bushfield Camp. Paragraphs 3.4.1 and 3.4.4
Not Positively Prepared nor Justified nor consistent with National Policy.
Why
In the view of the Trust the cumulative effect of these paragraphs fails to take forward accurately the extremely restrictive nature of the allocation of Bushfield Camp for employment use in LPP1. The current wording in LPP2 is not sound as it fails to recognise the requirement in the second criterion under Policy WT3 of LPP1 that any development at Bushfield has to deliver:
necessary social, economic or environmental development which could not otherwise be accommodated within or around Winchester,
does not compete or detract from the town centre,
is compatible with the provision made elsewhere through this strategy,
and reflects other policy statements prepared by the Council including the Vision for Winchester;
Bushfield Camp is not within the Town as is suggested in para 3.4.4 and it is of a different nature than the other employment sites mentioned because of its location and the constraints imposed by WT3.
Since Bushfield Camp was allocated in LPP1 for employment use, the proposals for the redevelopment of the Station Approach area include an additional amount of land being available for employment use.
Proposed Changes
1. In paragraph 3.4.1 include reference to the restrictions on development at Bushfield Camp set out in WT3.
2. In paragraph 3.4.4. remove all reference to Bushfield Camp.
Infrastructure – Education paragraph 3.6.8
Not positively prepared nor Justified.
Why
The Plan describes in para 3.6.8 the implemented and current plans required to meet the needs for additional pupils to receive primary and secondary education in the City. It does not state if further provision will need to be made during the course of the Plan period up to 2031.
No reference is made to further education. The City has two universities and a sixth form college.
The University of Winchester and Peter Symonds Sixth Form College are two major institutions in the City. They have grown and expanded in recent years and continue to do so, with the need to provide new teaching accommodation and student housing. Peter Symonds is reputed to be the largest sixth form college in England.
Not to mention the consideration of the future requirements of these two institutions is a significant omission. There are likely to be similar concerns about Southampton University which is rumoured to have plans for expansion in the area of the art school in Park Avenue.
Proposed Changes
Evidence should be provided that their future needs have been assessed and, if necessary, provisions made in the Plan accordingly.
Infrastructure Transport Paragraphs 3.6.6 - 3.6.7
Policy WIN 1 Winchester Town and paragraph 3.7.3 and WIN 2 Town Centre
Not Positively Prepared, Justified nor Effective.
Why
Paragraphs 3.6.6 and 3.6.7 and Policy WIN 1
Reference is made to WTAP and reducing the level of traffic in the city centre. The Plan's 4 aims include the need to improve air quality, reduce carbon emissions and to lead a transition to walking and cycling. It also proposes reducing the amount of parking by 500 spaces by 2016. This objective is restated in LPP1 see pages 33-36 and para 4.22. Little if anything has been done to achieve this. There are no policies in LPP2 to deliver this reduction and the aims of WTAP and there should be. In contrast to this omission, there are some policies in the previous local plan, Winchester District Local Plan Review 2006 (see policies W.5, W.6 and supporting paragraphs) which are compatible with the WTAP. These are an important part of the park and ride strategy and remain essential if park and ride car parks are to be fully occupied and traffic in the town centre is to be reduced.
The Winchester District Car Parking Strategy is in conflict with the aims of WTAP in that it refers to retaining parking in the town at current levels and divides Winchester into quarters for different types of parking provision which are not appropriate for traffic management for the compact nature of the town centre. This will frustrate the realisation of the WTAP aims and will perpetuate the congestion of the city centre roads and will not improve air quality. The Air Quality Monitoring Report 2014 shows Nitrogen Dioxide emissions exceeding the guide lines regularly. All the conflicting provisions in the Car Parking Strategy should be disregarded in order to comply with the aims of WTAP.
While the principles in WIN 1(iv)(v)(vi) are laudable they are likely to be too general to be effective in achieving any significant benefits and will need more precise policies which require specific actions. This criticism of imprecision also applies to WIN2 (iii) (See policies proposed below).
Paragraph 3.7.3
This paragraph suggests a false dichotomy between sustainable economic growth and the environment. They are in fact complementary. The 4th sentence which begins ‘For example, the need’ shows this conflict most clearly. A sustainable transport network features walking, cycling and bus use and reduces the number of cars, reduces congestion and improves air quality. It is also clear from recent research papers (see for example ‘The Pedestrian Pound’ by Living Streets) that a vibrant economy is not inhibited but enhanced by sustainable transport measures as they produce a healthy and welcoming environment which attracts people and are particularly suitable to the characteristics of an historic city.
Proposed Changes
A. Paragraph 3.7.3. Rewrite this paragraph to remove the dichotomy.
B. Introduce specific policies which can deliver a sustainable transport system such as:
1. Reduce parking in the town centre by removing public car parks for example Cossack Lane/Middle Brook Street, Friarsgate, St Peter's Street and Colebrook Street. This which will reduce the number of cars coming in to the central area. The previous local plan, Winchester District Local Plan Review 2006 contained a similar policy WIN6.
To accommodate cars for which park and ride may not appropriate, the capacity of car parks on the edge of the Town Centre could be increased. Durngate and the Cattle Market are examples.
2. Encourage the extension of pedestrian only areas in the town centre where the opportunity arises.
3. Restrict severely private parking spaces for all new office and residential development in the Town centre and encourage development without any parking spaces being provided.
4. Encourage the provision of a car club for use by those who live in or near the Town Centre.
5. Encourage the redesign of roads like Jewry Street and St George’s Street, North Walls and Eastgate Street so that sections can be used as shared space between vehicles, bicycles and pedestrians.
6. Encourage re signing and redesigning roads so there is no cross town traffic.
C. In WIN1(iv) the general principle of ‘encouraging sustainable transport options’ would be more effective by including more precise requirements. For example the policy could refer to the WTAP and the Walking and Cycling Strategies and state that their aims and recommendations where relevant should be implemented when any development is permitted
Policy WIN 3 Views and Roofscape
Not positively prepared nor effective.
Why
In WIN 3(i) the terms ‘local character and distinctiveness’ are too vague and require explanation and more precision to be effective and useful.
In WIN 3(ii) the location of the key historic features are shown on Policy Maps 25 and 26.. They do not show the ‘panoramic views across the town are a defining characteristic of Winchester’ referred to in para 3.7.5 from which the historic features can be viewed.
Proposed Changes
1. The Plan/policy WIN3(i) should cross reference to a Character Appraisal for the Winchester Conservation Area Project 2003 for Winchester that analyses and explains issues such as topography, landscape features, historic development, street patterns, open spaces, building form, heights, and materials that combine to create character and distinctiveness.
2. In WIN(ii) views from St Catherine’s Hill, Compton Ridge, Romsey Road, Cheesefoot Head, St Giles Hill and others identified in the valuable study carried out and published by WCC in 2009 on Constraints, Visibility and Landscape sensitivity need to be shown on the Policy Maps or on an additional map to give integrity to this Policy.
3. In WIN 3 (iv) ‘micro – energy generation equipment’ should be defined in the glossary in Appendix A.
4. The visual impact of telecommunication structures should be included in Policy WIN 3.
Policy WIN 4 Silver Hill
Not positively prepared, nor justified.
Why
WIN4(vii) states that ‘appropriate car parking to replace any spaces lost through development should be provided...’. Although this is included in the 2009 planning permission it is contrary to the aims of WTAP. If this permission is not implemented then the car parking proposed here should be reviewed and significantly reduced. With the closure early in 2015 of the existing public car park, Friarsgate, because of disrepair it would be retrograde step to replace it, if the opportunity arises to remove it.
Proposed Changes
Redraft the public car parking provision to require this to be reviewed or ommitted from the redevelopment of Silver Hill if the current planning permission expires or is not implemented.
Policy WIN 5 Station Approach Area
Not Justified and not consistent with national policy.
Why
WIN 5 sets out the development principles to be followed and includes In WIN5(vi) retaining ‘existing trees where they make a positive contribution towards enhancing local distinctiveness’. Buildings are as important as trees but there is no reference to the retention of any buildings which make a positive contribution although in the following policy WIN6 there is reference to the retention of two specific buildings. It could be argued that there are other less distinctive buildings or groups of buildings which make a positive contribution to the area and so their existence needs to be referred to in this policy listing development principles. The NPPF introduced the definition of heritage assets and so this term should be used.
Proposed Changes
Include a principle that buildings should be retained which make a positive contribution to the character of the area and are assessed as heritage assets.
Not effective, not justified.
Why
WIN 5 (viii) Refers to the Council’s Parking Strategy and ‘that the overall quantity of public car parking spaces in the area is not reduced.’
The Parking Strategy is a flawed document as it is inconsistent with WTAP and also introduces the concepts of parking quarters which make little sense on the ground. The Station Approach area extends across two quarters although several of the car parks in the two quarters are very close to each other and ought to be considered as a whole.
While it is clear that the provision of some car parking in the area is sensible, the amount and the place it is provided needs to be considered carefully. Account needs to be taken of the extra parking capacity recently provided at the eastern side of the station by Network Rail/Southwest Trains and the existence of parking to the western side of the station which could be increased. As this area is important as a place for transport interchange it is vital that full consultation and co-operation takes place with Network Rail/South West Trains, the bus companies and HCC as highway authority. Account needs to be taken of the traffic impact from the residential development at Barton Farm and the park and ride site to be provided as part of this development.
Proposed Changes
WIN5(viii) Delete reference to ‘Council’s adopted Parking Strategy’ and the requirement to retain the existing amount of car parking. Include a requirement for consultation with the railway companies to establish whether they are proposing any more parking spaces on either side of the station and also consultation with HCC as transport authority.
Also delete reference to retaining the existing amount of parking and include the requirement for an overall movement study to establish the amount and location of public car parking.
Policy WIN11 Winnall
Not Justified Not effective.
Why
In Win11 the last paragraph states that all proposals should maximise opportunities to create or improve pedestrian and cycle links with the surrounding area but does not refer to the walking or cycling strategies.
Proposed Changes
This paragraph should include reference to implementing the walking and cycling strategies.
Development Management High Quality Environment
DM 17 Access and Parking
Not Justified, Not effective.
Why
DM17 gives undue emphasis to design for the needs of vehicles without sufficient regard to sustainable forms of travel which should be prioritised whenever possible. Parking where possible should be hidden or designed and located to reduce the visual impact of cars.
Proposed change
Redraft policy to give greater emphasis and encouragement for access on foot and with bicycles and to reduce the impact of cars by requiring parking to be in a subordinate or hidden space.
Comments on Sustainability Appraisal/Strategic Environmental Assessment
The Sustainability Appraisal (SA) assesses the individual development sites in some detail and their proximity to existing settlements and facilities but there is a lack of consideration about the scale of the increase in traffic which will arise over the period of the plan a a result of all these developments taken together both within the District and the further impact from increased traffic in the District as a result of development in neighbouring districts.
The SA has an objective of increasing accessibility, reducing car usage and the need to travel but it does not identify the measures needed to achieve this nor that these are absent from LPP2. The SA acknowledges the negative effects of traffic on air quality and traffic congestion in Winchester at the moment and accepts that these could get worse. It seems over optimistic that the vague measures it refers to will address these problems. It does not raise the important point that many of the recommendations in the MVA Transport Report are not referred to nor addressed in LPP2. For example, the MVA Transport Report supports the use of park and ride as a parking and access straegy but emphasises that this must be accompanied by a reduction in parking places within Winchester if it is to be effective in reducing traffic congestion and improving air quality.
Part D- Future Involvement
The Trust wishes to speak at the hearing sessions of the Examination.
This is necessary to clarify and expand on any aspect of the representations made by the Trust and to answer any points raised by others on any of the representations the Trust has made.
Data Protection Act 1998 and Freedom of Information Act 2000
The Trust agrees to its representations being made publically available and accepts responsibility for its representations.