Advocacy

Eddington Hill, Hungerford from Port Down

Eddington Hill, Hungerford from Port Down: land in the AONB initially identified by West Berkshire Council as suitable for housing, but later deleted following a suspension of the Examination after advocacy by Green Balance

West Berkshire Council proposed in its Core Strategy in 2010 to build 10,500 houses in the Plan period 2006-2026. Of these, 2,100 would be supplied within the North Wessex Downs Area of Outstanding Natural Beauty (AONB), mostly on greenfield sites on the edges of towns and villages. A Public Examination into the Plan opened in November 2010. Green Balance prepared the written and oral evidence on behalf of the North Wessex Downs AONB Unit, challenging the proposals at the Examination.

The Core Strategy was vague about where houses would go within the AONB, leaving this for a future Allocations Plan. It offered no evidence that the proposed scale of housing could be absorbed without significant damage to the AONB landscape. There would be substantial growth around Hungerford and Pangbourne, while a number of villages risked being swamped by development, all in the AONB. The ‘exceptional circumstances’ required by national planning policy to justify such development were not offered. The AONB Unit argued that the emphasis should be on affordable housing provision in the AONB, not general needs housing which did not need to be there. No other AONB in the South East had been allocated housing supply obligations on anything like this scale, and this approach was a challenge to national policy.

The main housing issues were heard at the Examination on 3 rd November 2010. Following our advocacy throughout the day, the Inspector summoned senior Council officers for a response to the concerns we had raised. He announced on the spot that he would be suspending the Examination for six months to give the Council time to address the concerns raised by Green Balance.  The Inspector followed this remarkably abrupt conclusion by issuing a list of serious defects in the Plan regarding the AONB, identified by ourselves, including:

  • the housing assigned to the AONB “had not specifically taken into account the potential landscape impact”;
  • “there seems to have been no explicit consideration by the Council of what national advice means by development in the AONB meeting ‘identified local needs’”; and
  • “No different approach or testing of the scale of development in the AONB appears to have been undertaken to that... in the non-AONB rural area”. 

He ruled that “In all these circumstances I could not conclude that this aspect of the Core Strategy is compliant with national policy”.

West Berkshire Council then commissioned a landscape assessment, which reduced the choice of plots in the AONB outside settlements said to be suitable for housing from 3,542 to 1,829.  This substantially alleviated the threat of inappropriate development to many villages and urban edges in the AONB as a direct result of our interventions.  The Inspector was still not very impressed when the Examination reconvened in June 2011, commenting that “In my view, achieving the landscape objective… on some, if not many, of the greenfield sites in the AONB will be very challenging or impossible.”  He noted, though, that only some greenfield sites were needed to deliver the scale of housing proposed, as the Council had already allowed over 1,100 dwellings in the AONB.  He also expected two large previously-used sites to count towards the land supply, and he set an upper limit to development in the AONB.  On this basis the few remaining greenfield sites needed could be identified in the proposed Allocations and Delivery Plan, outside the AONB if sites inside proved unacceptable.

After the reconvened June 2011 hearing, the North Wessex Downs AONB Unit Planning Officer wrote to Green Balance:

“I was very pleased with the progress you made – I got the feeling in Inspector-speak ‘we were pushing against an open door’….  I was particularly pleased when most of the consultants round the table seemed to fall into line and agree mostly with our position.”

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