Woodford Neighbourhood Draft Plan

Policy ENV1 lacks any robust justification to determine why the ‘important local views’ are identified for protection. The evidence base that justifies this approach is deficient, considered to be highly subjective and does not contain the justification for the specific viewpoints identified for special protection.
The evidence base is the Woodford-Landscape-and-Environment-Report-Part-1-September-2018. PLSL's site is considered within this document under two separate character areas:
• Central Woodford, Area 5; and
• Central Woodford, Area 7
The document, produced on behalf of the WNF, does not follow a clearly stated methodology . PLSL object to an evidence base document that supports a range of environmental policies within the plan, including ENV1 which seeks to protects views and vistas, yet does not properly cross reference view point locations on plan or photographs. Having specific regard to the assessment of Area's 5 and 7. The report states that there are 'treasured' views of the distant Pennines from many locations. Such statements are highly subjective and should not form part of the NP evidence base. PLSL also note that the Greater Manchester Green Belt Assessment assesses the Woodford area as part of parcel SP-BA03 and it is judged to have a sense of urban encroachment as a result of the existing development/housing, new development and the transport infrastructure through this landscape.

Furthermore, PLSL's own studies of the area, undertaken by fully qualified Landscape and Visual Impact Assessment consultants (see Appendix 1), conclude that wider views to their site are limited by the surrounding landscape, vegetation and generally flat topography. Limited long distance views are available from the surrounding landscape due to the lack of highly elevated topography. Although development would be outside of the limits to development for Woodford, it is considered that while a change in the local landscape character would be noticeable due to the change from agricultural fields to the proposed development, the predicted change would be relatively small due to the limited extent of the views and the proximity of existing housing to the eastern, southern and western boundaries.

It is considered that the landscape mitigation offered would integrate the scheme into the local landscape and the proposed development would not have a significant impact on the landscape character of the area. Views of the development from the wider area are filtered and screened by the intervening buildings and surrounding mature hedgerow and tree boundaries and surrounding curtilage vegetation.

Policy ENV2 lacks robust justification for the countryside and green spaces identified. It identifies all of the land at Hill Top Farm, Woodford (Areas 5 and 7) in conflict with the draft allocation for housing in the emerging GMSF. The Policy defines what is
effectively the whole of Woodford as Countryside and Green Space, seeking to prevent all development that might have a detrimental impact on defined areas. Areas 5 and 7 should be removed from the policy.

Policy DEV3, should demonstrate general conformity with the adopted development plan and emerging SLP. No justification is provided for seeking 50% affordable housing when the current adopted plan requires 40% affordable housing. Indeed, the NP evidence base document: Housing Needs Assessment recommends that there is no requirement for a specific affordable housing policy in the NP.

PLSL has several fundamental concerns relating to this evidence base document. The Housing Needs Assessment (HNA) dates back to July 2015 and this is already some 3 years out of date. The HNA bases its findings on the 2008 Greater Manchester SHMA and 2010 Update and assesses the need between 2011 and 2026 (which does not align with the NP duration of 2018 to 2033). It has not been updated to consider the more recent assessments undertaken and published by Stockport Council and Greater Manchester Combined Authority (GMCA) , nor emerging government guidance on assessing housing need. Furthermore, the forthcoming revision to GMSF will be supported by a revised evidence base, which the NP cannot take into account by attempting to run ahead of the strategic plan for the area.

As such PLSL consider that the evidence base and methodology for the HNA is out of date and the weight that should be afforded to it is limited. Before the draft NP is finalised and submitted, an up-to-date HNA should be undertaken and the draft NP reviewed accordingly. The NP should follow, rather seek to pre-empt, emerging strategic policy. Given these fundamental concerns regarding the HNA methodology being out of date, this representation does not go into specific detailed comments on the methodology utilised other than to object to any weight being given to an out of date HNA.