Landscape & Visual Impact Appraisal

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Landscape & Visual Impact Appraisal
R & W Environmental
       Land off Spitfire Link – M3 Junction 9
WYG
[OFFICE ADDRESS]
                   Landscape & Visual Impact Appraisal
[TEL NO]
                                                   A101072
[EMAIL ADDRESS]
www.wyg.com                                 creative minds safe hands
                                                  May 2017
Landscape & Visual Impact Appraisal
R & W Environmental
Land off Spitfire Link – M3 Junction 9
Landscape and Visual Impact Appraisal

Document verification
 Client:             R & W Environmental
 Project:            Land off Spitfire Link – M3 Junction 9
 Job number:         A101072
 Document title:     Landscape and Visual Impact Appraisal
 Status:             Version 1
 Date:               May 2017
 Document reference: W:\A101000-A101999\A101072 - M3 J9 Planning
                     App\7_Reports\A101072 L&VApp v3.docx

 Document Checking:
 Prepared by:        Marcus Pinker                               Date:   May 2017
 Checked by:         Mary O’Connor                               Date:   May 2017
 Verified by:        Emma McRae                                  Date:   May 2017

 Issue               Date                         Status
 1                   May 2017                     First Draft
 2                   May 31st 2017                Final
 3
 4

This report is copyright: © WYG Environment Planning Transport Limited, 2017.
All drawings and photographs are by WYG Group Limited unless stated otherwise.
Drawings based on the Ordnance Survey map are reproduced with the permission of
Her Majesty’s Stationery Office: © Crown copyright
WYG Environment Planning Transport Limited licence number: AR 1000 17603

www.wyg.com                                                                         creative minds safe hands
5th Floor, Longcross Court, 47 Newport Road, Cardiff, CF24 0AD
Landscape & Visual Impact Appraisal
Contents

Report Overview                                  1

1.0    Introduction                              1
       1.2   Scope of the appraisal               1
       1.3   Appraisal methodology                2
       1.4   Weather                              4
       1.5   Guidance etc                         4

2.0    Landscape Policies and Designations       5
       2.1   National and local policy            5
       2.2   Designations                        11
       2.3   Interim summary                     13

3.0    The Proposed Development                  14

4.0    Effects on the Landscape                  15
       4.2   Assessment criteria                 16
       4.3   Landscape baseline                  18
       4.4   Site-specific appraisal             22
       4.5   Public access                       23
       4.6   Landscape baseline summary          23
       4.7   Effects on the landscape            25

5.0    Effects on Visual Amenity                 31
       5.2   Assessment criteria                 31
       5.3   Visual baseline                     34
       5.4   Visual receptors                    37
       5.5   Visual baseline summary             38
       5.6   Effects on visual amenity           38

6.0    Summary and Conclusions                   42
       6.2   Summary of findings                 42
       6.3   Policy considerations               44
       6.4   Designated landscapes               45
       6.5   Conclusions                         45

                                             3
Landscape & Visual Impact Appraisal
Tables

           Table   4-1   Indicative criteria for assessing landscape sensitivity                  16
           Table   4-2   Indicative criteria for assessing magnitude of landscape change          17
           Table   4-3   Indicative criteria for assessing landscape effects                      18
           Table   4-4   Sensitivity of landscape receptors                                       25
           Table   4-5   Summary of effects on the landscape                                      30
           Table   5-1   Indicative criteria for assessing visual sensitivity                     32
           Table   5-2   Indicative criteria for assessing magnitude of visual change             33
           Table   5-3   Indicative criteria for assessing visual effects                         33
           Table   5-4   Viewpoint details                                                        35
           Table   5-5   Existing view descriptions                                               35
           Table   5-6   View with development & magnitude of change                              39
           Table   5-7   Assessment of visual effects                                             40

Appendices

Appendix 1 - Methodology                                                                          46
           General Methodology                                                                    46
           Landscape Effects Assessment                                                           46
              Table A1- 1 Criteria to determine landscape value                                   48
              Table A1- 2 Criteria for landscape susceptibility                                   49
              Table A1- 3 Considerations for assessing magnitude of landscape
              change                                                                              50
           Visual Effects Assessment                                                              51
              Table A1- 4 Indicative criteria for visual sensitivity                              54
              Table A1- 5 Considerations for assessing magnitude of visual change                 54

Appendix 2 - Policy                                                                               56
           Hampshire Minerals & Waste Plan (NMWP) - 2013                                          56
           Winchester District Local Plan Part 1 (2013) & Winchester District Local Plan
           Part 2 (2017)                                                                          60

Appendix 3 - List of Figures                                                                      63

www.wyg.com                                                                                creative minds safe hands
5th Floor, Longcross Court, 47 Newport Road, Cardiff, CF24 0AD
Landscape & Visual Impact Appraisal
Report Overview
            Introduction; nature of project, likely effects and mitigation; scope of assessment/
             appraisal;
            Overview of landscape policies and designations;
            Findings of landscape baseline, summary of main findings of effects assessment;
            Findings of visual baseline, receptors identified and viewpoints studied, summary
             of main findings of effects assessment;
            Main findings and Conclusions.

1.0 Introduction

1.1.1   WYG is instructed by R & W Environmental to prepare this Landscape and Visual
        Appraisal (L&VApp) which relates to the planning application for a highways waste
        management facility on land off Spitfire Link (A272) M3 Junction 9, Winchester.

1.2     Scope of the appraisal
1.2.1   The proposal is for the application of planning application for a highways waste
        management facility with plant (machinery including: soils screener; trommel; concrete
        crushing; 360 backhoe excavator and loading shovel), site office and welfare facilities
        with associated staff parking, waste storage bays, a waste processing area, aggregate
        storage bays, and covered store for soils and products.

1.2.2   This Landscape and Visual Appraisal (L&VApp) provides an assessment of the effects of
        the development, on the landscape of the site and its context. The design of the
        development and the identification of mitigation measures incorporated within the
        design to minimise adverse effects, is informed by the findings of the appraisal. During
        the appraisal, effects on features identified as important to the scenic quality, or effects
        on the landscape character of the site and its setting are assessed. Effects on peoples’
        views of the site and its setting, or visual amenity, are also assessed.

1.2.3   For the purposes of assessing the landscape and visual effects of this proposal, study
        areas have been defined, shown on Figure LA.01:

            The “site” extends to the boundary shown in Figure LA.04-2;
            The zone of visual influence (ZVI) determines the area from which the site is
             potentially visible and is shown on Figure LA.04-1;
            The “landscape context” is determined by topography and vegetation and extends
             to a similar area to the ZVI.

1.2.4   The objectives of the appraisal are to:

                                                  1
     Describe and evaluate the landscape of the site and surrounding landscape context
                 and visual amenity of the surrounding area, which might be affected by the
                 development;
                Examine the development proposals and analyse the potential effects on the
                 landscape and visual amenity associated with the scheme’s design or operation;
                Provide an assessment of the landscape and visual effects of the development with
                 integral mitigation measures in place.

1.2.5      The L&VApp is presented with separate chapters dealing with effects on landscape,
           effects on visual amenity. The L&VApp is illustrated by plans and photographs, as
           follows:

               Figure LA.01            Site Location Plan
               Figure LA.02-1          Designations: Landscape & Heritage
               Figure LA.02-2          Designations: Habitat & Species
               Figure LA.02-3          Designations: Public Access
               Figure LA.03-1          Landscape Character: National
               Figure LA.03-2          Landscape Character: County
               Figure LA.03-3          Landscape Character: County
               Figure LA.03-4          Landscape Character: District
               Figure LA.04-1          Visual Appraisal: Topography
               Figure LA.04-2          Visual Appraisal: Site Context
               Figure LA.05            Site Photographs
               Figure LA.06            Viewpoint Photographs
               Figure LA.07            Layout Plan
               Figure LA.08            Landscape Proposals

1.2.6      Detailed information is presented in Appendices as follows:

               Appendix 1              General Assessment Methodology
               Appendix 2              Landscape Policies
               Appendix 3              List of Figures

1.3        Appraisal methodology
1.3.1      The methodology used for assessing the landscape and visual effects is based on the
           recommendations in Guidelines for Landscape and Visual Impact Assessment 3rd Edition
           published by The Landscape Institute and the Institute of Environmental Management

www.wyg.com                                                                 creative minds safe hands
5th Floor, Longcross Court, 47 Newport Road, Cardiff, CF24 0AD
& Assessment in 2013 (GLVIA3). A summary of the methodology used is set out in
           Appendix 1.

1.3.2      The Landscape Institute has advised in relation to Landscape & Visual Appraisals
           outside a formal EIA process in its “Statement of Clarification 1/13”1:

                In carrying out appraisals, the same principles and process as LVIA may
                be applied but, in so doing, it is not required to establish whether the
                effects arising are or are not significant given that the exercise is not
                being undertaken for EIA purposes. … The emphasis on likely ‘significant
                effects’ in formal LVIA stresses the need for an approach that is
                proportional to the scale of the project that is being assessed and the
                nature of its likely effects. The same principle – focussing on a
                proportional approach – also applies to appraisals of landscape and visual
                impacts outside the formal requirements of EIA.

1.3.3      The appraisal process comprises a combination of desk studies and field surveys, with
           subsequent analysis, and involved:

               A review of landscape designations and planning policies for the landscape, and of
                other landscape studies relevant to the area, including national and local landscape
                character assessments;
               A survey of the site and landscape context study areas and inspection of views of
                the site from publicly accessible viewpoints, including a photographic survey. The
                surveys were carried out on 16th February 2017;
               Evaluation of the features and elements of the landscape and their contribution to
                the landscape character, context and setting, based on these studies;
               Analysis of the development proposals and consideration of potential landscape
                and visual effects;
               Assessment of the susceptibility and sensitivity of the landscape to the changes
                likely to arise from the development;
               Identification of the extent of theoretic visibility of the development and potentially
                sensitive viewers and view locations, supported by a viewpoint analysis;
               Consideration of proposals for mitigation measures to avoid, reduce or offset
                adverse effects;
               Assessment of magnitude of change and the degree and nature of effects on the
                landscape and on visual amenity, with the mitigation proposals in place.

           Assessment and mitigation
1.3.4      The effects of the development, whether beneficial or adverse, may vary in nature and
           degree through its lifecycle and, where feasible, mitigation measures are proposed to
           be incorporated in the design of the development. Where design measures cannot
           address identified likely adverse effects, measures such as management of the

1   Landscape Institute website: https://www.landscapeinstitute.org/technical/glvia3-panel/glvia3-
    clarifications/ [accessed February 2017]

                                                     3
construction and operational processes are proposed. The purpose of mitigation
           measures is, first, to prevent or avoid the potential adverse effects identified, and if that
           is not possible, to reduce the potential adverse effect. Where adverse effects are
           unavoidable, the purpose is to offset or compensate for the effect.

1.3.5      Details of the assessment criteria for landscape effects and visual effects are set out in
           those respective chapters.

1.4        Weather
1.4.1      The weather is a factor affecting the assessment of, especially, visual impacts. The Met
           Office2 publish average statistics for weather patterns for the region, monthly and
           annual, for maximum and minimum temperatures, days of air frost, hours of sunshine,
           amount of rainfall - both generally and the number of days when rainfall is above 1mm.
           For Martyr Worthy, the nearest Climate station to where the site is located:

                Rainfall above 1mm per day, which limits visibility, occurs on an average of 116.2
                 days in the year, about 31.8% of the year
                There are on average 53.8 days when air frost occurs, which can produce hazy
                 conditions limiting visibility, about 14.7% of the year
                There is an average of 1564 hours of sunshine per annum for the station, less than
                 the England SE & Central S regional average of 1627.7 hours.

1.5        Guidance etc
1.5.1      In addition to GLVIA3, the Landscape Institute’s Advice Note 01/11 Photography and
           Photomontage in Landscape and Visual Impact Assessment was referred to.

1.5.2      Relevant policy, landscape character assessments, and other contextual information
           sources were also referred to, including:

                Landscape Character Assessment: Guidance for England and Scotland, published
                 by Countryside Agency, 2002
                Natural England updated character area descriptions, 2014 & 2015
                Policies relevant to the landscape and visual amenity in national and regional policy
                 including Hampshire Minerals and Waste plan (2013), Winchester District Local
                 Plan Part 1 (2013), Winchester District Local Plan review (2006), Hampshire
                 County Integrated Character Assessment (2012), and Winchester District
                 Landscape Character Assessment (2004).

2   The data quoted are those for Martyr Worthy, England SE & Central S, obtained from The Met Office
    website: http://www.metoffice.gov.uk/public/weather/climate/gcp4eqcmh [accessed February 2017]

www.wyg.com                                                                     creative minds safe hands
5th Floor, Longcross Court, 47 Newport Road, Cardiff, CF24 0AD
Photography
1.5.3     Photographs have a special role in describing landscape character and illustrating key
          views. In order for photograph to be representative and to create an image that is as
          similar as possible to that which is seen with the human eye, the LI advises using a lens
          with a focal length equivalent to 50 mm for a 35 mm Single Lens Reflex (SLR) camera,
          and a horizontal field of view of a little under 40 degrees3. The camera used for the
          appraisal photography was a Canon EOS 5D Mark iii digital SLR camera with a full frame
          sensor. Photographs were taken with a focal length of 50mm.

1.5.4     Landscape photography includes wide angle or panoramic views requiring a sequence
          of photographs to be taken across the view. Where this approach is taken, a series of
          overlapping photographs are digitally spliced together PTGui Pro using a cylindrical
          projection to provide a panorama approximating to the normal field of view in a
          landscape context. Where necessary, the contrast and brightness of individual
          photographs is slightly manipulated in order to create a consistent panorama without
          visible joins. The viewpoint locations are shown on Figure LA.04-1.

2.0 Landscape Policies and Designations

2.1       National and local policy
          National Planning Policy Framework
2.1.1     The National Planning Policy Framework (NPPF) published in March 2012 sets out the
          Government’s economic, environmental and social planning policies for England, and
          their vision for sustainable development. It includes an overarching ‘presumption in
          favour of sustainable development’ which means ‘approving development proposals that
          accord with the development plan without delay’. The presumption allows for only
          refusing permission where adverse impacts clearly outweigh the benefits, or NPPF
          polices indicate developments should be restricted.

2.1.2     A set of core land-use planning principles should underpin decision-taking. The core
          principles (Paragraph 17) of key importance for this decision are to:

              (a) proactively drive and support sustainable economic development to deliver the
               homes, businesses and industrial units, infrastructure and thriving local places that
               the country needs;
              (b) seek to secure high quality design and a good standard of amenity for all
               existing and future occupants of land and buildings;

3
    The Landscape Institute, Landscape Institute Advice Note 01/11, Photography and photomontage in
    Landscape and Visual Assessment, March 2011, on LI website:
    https://www.landscapeinstitute.org/visualisation/ [accessed February 2017]

                                                   5
     (c) recognise the intrinsic character and beauty of the countryside and supporting
                 thriving rural communities within it;
                (d) support the transition to a low carbon future in a changing climate, taking full
                 account of flood risk and coastal change, and encourage the reuse of existing
                 resources, including conversion of existing buildings, and encourage the use of
                 renewable resources (for example, by the development of renewable energy);
                (e) contribute to conserving and enhancing the natural environment and reducing
                 pollution; and
                (f) encourage the effective use of land by reusing land that has been previously
                 developed (brownfield land), provided that it is not of high environmental value.

2.1.3      Paragraph 111 - Planning policies and decisions should encourage the effective use of
           land by re-using land that has been previously developed (brownfield land), provided
           that it is not of high environmental value. Local planning authorities may continue to
           consider the case for setting a locally appropriate target for the use of brownfield land.

2.1.4      Paragraph 115 requires that ‘Great weight should be given to conserving landscape and
           scenic beauty in National Parks … which have the highest status of protection in relation
           to landscape and scenic beauty’.

           Local Policy
2.1.5      The site lies within the boundaries of Hampshire County Council and Winchester City
           Council. Local planning policy relevant to the proposed development of the site is
           provided by the Hampshire Minerals & Waste Plan (adopted in 2013), Winchester
           District Local Plan part 1 (adopted 2013) and Winchester District Local Plan Part 2
           (adopted 2017). Relevant policies relating to the proposed development are outlined
           below. Details of these policies can be found in Appendix 2 of this report.

           Hampshire Minerals & Waste Plan (HMWP) - 2013
           The most relevant policies are:

2.1.6      Policy 1: Sustainable minerals and waste development: The Hampshire
           Authorities will take a positive approach to minerals and waste development that
           reflects the presumption in favour of sustainable development contained in the National
           Planning Policy Framework (NPPF). Minerals and waste development that accords with
           policies in this Plan will be approved without delay, unless material considerations
           indicate otherwise.

2.1.7      Policy 4: Protection of the designated landscape: Minerals and waste
           development should reflect and where appropriate enhance the character of the
           surrounding landscape and natural beauty, wildlife and cultural heritage of the
           designated area. Minerals and waste development should also be subject to a
           requirement that it is restored in the event it is no longer needed for minerals and
           waste uses.

www.wyg.com                                                                    creative minds safe hands
5th Floor, Longcross Court, 47 Newport Road, Cardiff, CF24 0AD
2.1.8    Policy 5: Protection of the countryside: Where appropriate and applicable,
         development in the countryside will be expected to meet highest standards of design,
         operation and restoration.

2.1.9    Policy 9: Restoration of minerals and waste developments: Temporary minerals
         and waste development should be restored to beneficial after-uses consistent with the
         development plan. Restoration of minerals and waste developments should be in
         keeping with the character and setting of the local area, and should contribute to the
         delivery of local objectives for habitats, biodiversity or community use where these are
         consistent with the development plan.

2.1.10   Policy 10: Protecting public health, safety and amenity: Minerals and waste
         development should not cause … unacceptable adverse amenity impacts. Minerals and
         waste development should not:

            cause unacceptable dust or lighting; and
            have an unacceptable visual impact.

2.1.11   Policy 13: High-quality design of minerals and waste development: Minerals
         and waste development should not cause an unacceptable adverse visual impact and
         should maintain and enhance the distinctive character of the landscape and townscape.
         The design of appropriate built facilities for minerals and waste development should be
         of a high-quality and contribute to achieving sustainable development.

2.1.12   Policy 18: Recycled and secondary aggregates development: Recycled and
         secondary aggregate production will be supported by encouraging investment and
         further infrastructure to maximise the availability of alternatives to … local land-won
         sand and gravel extraction.

2.1.13   Policy 25: Sustainable waste management: The long-term aim is to enable net
         self-sufficiency in waste movements and divert 100% of waste from landfill. All waste
         development should:

            reduce the amount of residual waste currently sent to landfill; and
            be located near to the sources of waste, or markets for its use.

         Provision will be made for the management of non-hazardous waste arisings with an
         expectation of achieving by 2020 at least:

            60% recycling; and
            95% diversion from landfill.

2.1.14   Policy 27: Capacity for waste management development: In order to reach the
         objectives of the Plan and to deal with arisings by 2030 of:

            2.49mtpa of inert waste;

                                                 7
The following minimum amounts of additional waste infrastructure capacity are
           estimated to be required:

                0.29mtpa of non-hazardous recycling capacity; and
                0.39mtpa of non-hazardous recovery capacity.

2.1.15     Policy 29: Locations and sites for waste management: Development to provide
           recycling, recovery and/ or treatment of waste will be supported on suitable sites in the
           following locations:

                i. Urban areas in north-east and south Hampshire;
                ii. Areas along the strategic road corridors.

           Any site in these locations will be considered suitable and supported where it:

                is previously-developed land; and
                is of a scale compatible with the setting.

           Development in other locations will be supported where it is demonstrated that:

                the site has good transport connections to sources of and/or markets for the type
                 of waste being managed; and
                a special need for that location and the suitability of the site can be justified.

2.1.16     Policy 30: Construction, demolition and excavation waste development:
           Development to maximise the recovery of construction, demolition and excavation
           waste to produce at least 1mtpa of high quality recycled/secondary aggregates will be
           supported.

           Principle of the Development

2.1.17     Policy 25: Sustainable waste management of the Hampshire Minerals & Waste
           Plan (2013) supports development which encourages the management of waste at the
           highest achievable level within the waste hierarchy and reduces the amount of residual
           waste currently sent to landfill.

2.1.18     Policy 27: Capacity for Waste Management Development supports proposals for
           the provision of additional waste infrastructure capacity through the delivery of new
           sites, where these are in accordance with Policy 29 of the Plan.

2.1.19     Policy 30: Construction, demolition and excavation waste development
           supports construction, demolition and excavation waste development producing high-
           quality recycled/secondary aggregates.

2.1.20     The proposal would seek to deliver new capacity for waste management through the
           delivery of a new site which would recycle highways waste at the highest achievable
           level within the waste hierarchy, producing high-quality recycled aggregate and

www.wyg.com                                                                       creative minds safe hands
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reducing the volume of waste sent to landfill. As such the proposal would be in
         accordance with policies 25, 27 & 30 of the HMWP (2013).

2.1.21   The site lies outside of the settlement boundary as shown on Map 31 (south-east
         Winchester) of the Winchester District Local Plan Part 1- Joint Core Strategy Adopted
         2013 and therefore lies within the countryside. Policy 5 (Protection of the countryside)
         of the HMWP (2013) states that minerals and waste development in the open
         countryside, outside the National Parks and Areas of Outstanding Natural Beauty, will
         not be permitted unless the nature of the development requires a countryside or
         isolated location. Minerals and waste development in the open countryside will be
         subject to a requirement that it is restored in the event it is no longer required for
         minerals and waste use.

2.1.22   The site lies within the Strategic Road Corridor (SRC) as identified in the Key Diagram
         of the HMWP (2013). Policy 29 (Location of waste management development) of the
         HMWP (2013) supports waste management development on suitable sites in areas of
         Hampshire within the SRC. Part 2 of Policy 29 states that development within the SRC
         will only be supported where it would be part of a suitable industrial estate; on land
         that has permission or is allocated for general industry/ storage; or is previously
         developed.

2.1.23   For the purposes of determining a retrospective planning application, the development
         status of the land is required to be considered in accordance with its condition prior to
         the development in question taking place. As the land was previously undeveloped
         prior to the implementation of the proposal, the land is required to be considered as
         greenfield.

2.1.24   As the site is required to be considered as greenfield the proposal does not meet the
         requirements of part 2 of Policy 29. As such, in order for the proposal to be supported
         in the location, part 3 of Policy 29 requires the applicant to demonstrate that the
         development would have good transport connections to the sources of and/or markets
         for the type of waste being managed, a special need for the location and additionally
         that the suitability of the site can be justified.

2.1.25   Paragraph 6.205 of the HMWP (2013) accepts that activities which predominantly take
         place in the open such as construction, demolition and excavation (CDE) recycling are
         often, by virtue of associated noise, odours and other emissions, more suitable to sites
         in isolated countryside locations.

2.1.26   Paragraph 6.195 states that sites which have not previously been developed (i.e
         greenfield), but are in well-screened locations away from residential areas may provide
         opportunities for locating facilities which require a more isolated location.

2.1.27   Paragraph 6.209 states that open-air facilities can be justified on sites outside the main
         urban areas where there is a special need or exceptional circumstances.

                                                   9
2.1.28     Therefore, for the site to be considered appropriate the applicant will need to
           demonstrate that the site has good transport connections to the sources of and/or
           markets for the type of waste to be managed and a special need for that particular
           location. Furthermore, it will need to be demonstrated that the site can be effectively
           screened from surrounding viewpoints.

           Landscape & Visual Impact

2.1.29     Policy 13: High-quality design of minerals and waste development of the
           HMWP (2013) states that minerals and waste development should not cause an
           unacceptable adverse visual impact and should maintain and enhance the distinctive
           character of the landscape and townscape.

2.1.30     Policy CP19: South Downs National Park of the Winchester District Local Plan Part
           1 (2013) states that development within and adjoining the South Downs National Park
           which would have a significant detrimental impact on the rural character and setting of
           settlements and the landscape should not be permitted unless it can be demonstrated
           that the proposal is of overriding national importance, or its impact can be mitigated.

           Winchester District Local Plan Part 1 (2013) & Winchester District Local
           Plan Part 2 (2017)
2.1.31     Policy CP19: South Downs National Park: New development should be in keeping
           with the context and the setting of the landscape and settlements of the South Downs
           National Park. The emphasis should be on small-scale proposals that are in a
           sustainable location and well designed. Proposals which support the economic and
           social wellbeing of the National Park and its communities will be encouraged, provided
           that they do not conflict with the National Park’s purposes.

2.1.32     Policy CP20: Heritage and Landscape Character: The Local Planning Authority …
           will support new development which recognises, protects and enhances the District’s
           distinctive landscape and heritage assets and their settings. These may be designated
           or undesignated and include natural and manmade assets associated with existing
           landscape and townscape character, conservation areas, scheduled ancient
           monuments, historic parks and gardens, listed buildings, historic battlefields and
           archaeology.

2.1.33     Particular emphasis should be given to conserving:

                recognised built form and designed or natural landscapes that include features and
                 elements of natural beauty, cultural or historic importance;

2.1.34     local distinctiveness, especially in terms of characteristic materials, trees, built form and
           layout, tranquillity, sense of place and setting.

2.1.35     Policy DM15: Local Distinctiveness: Developments should respect the qualities,
           features and characteristics that contribute to the distinctiveness of the local area.

www.wyg.com                                                                     creative minds safe hands
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Proposals which accord with the Development Plan will be permitted where they
         conserve or enhance:

             the landscape and townscape framework, including the ‘key characteristics’
              identified in local Character Assessments and adopted Design Statements;
             trees and hedgerows which contribute to local distinctiveness.

2.1.36   Policy DM16: Site Design Criteria: Development which accords with the
         Development Plan will be permitted provided it:

             responds positively to the character, appearance and variety of the local
              environment, within and surrounding the site, in terms of its design, scale and
              layout;
             provides boundary treatments that respond positively to the local context around
              the site and between different elements within the site of larger schemes;

2.1.37   Policy DM23: Rural Character: Outside defined settlement boundaries,
         development proposals which accord with the Development Plan will be permitted
         where they do not have an unacceptable effect on the rural character of the area, by
         means of visual intrusion, the introduction of incongruous features, the destruction of
         locally characteristic rural assets, or by impacts on the tranquillity of the environment.

2.1.38   The following factors will be taken into account when considering the effect on the rural
         character and sense of place:

             Visual - intrusion should be minimised, including the effect on the setting of
              settlements, key features in the landscape, or heritage assets. The cumulative
              impact of developments will be considered.
             Physical – developments will be encouraged to protect and enhance the key
              characteristics of the landscape and should avoid the loss of key features or the
              introduction of elements that detract from the special qualities of the place. Any
              re-modelling of the landscape will also be taken into account.
             Tranquillity – developments should not have an unacceptable effect on the rural
              tranquillity of the area, including the introduction of lighting or noise occurring as a
              result of the development, taking account of the relative remoteness and
              tranquillity of the location.

2.1.39   Developments should not detract from the enjoyment of the countryside from the public
         realm or public rights of way.

2.2      Designations
2.2.1    Landscape designations provide an indication of landscape value. They are areas that
         have been recognised for qualities such as scenic beauty and the recreational potential
         of the landscape. Designations are shown on Figure LA.02-1 to -3.

                                                 11
National Park/ AONB
2.2.2      The South Downs National Park (SDNP) lies on the opposite side of Spitfire Link (A272),
           its boundary running approximately 35m parallel to the eastern site boundary. The
           national park covers all of the land in the east of the study area as well as parts of the
           River Itchen valley, outside of urban Winchester, to the north-west. The boundary of
           the SDNP is shown on Figure LA.01.

           Historic and Cultural landscape designations
           Conservation areas and listed buildings
2.2.3      Winchester Conservation Area, which covers a large part of the city centre and its
           suburbs, lies about 0.8km to the south-west of the site. The nearest listed buildings to
           the site are located in Winnall, approximately 0.9km to the south-west, the closest
           being the Grade II listed 55-57 Wales Street, 53 Wales Street and ‘The First In and Last
           Out’ Public House. Central Winchester, about 1.5km to the south-west of the site, has
           numerous listed buildings. Listed buildings and structures and conservation areas
           located within 3km of the site are shown in Figure LA.02-1. The setting of
           conservation areas and listed buildings is a consideration during the preparation of
           landscape and visual impact appraisals.

           Scheduled Monuments
2.2.4      Scheduled Monuments are shown on Figure LA.02-1. The nearest to the site is a late
           Neolithic to Bronze Age dated ‘round barrow cemetery on Magdalen Hill Down’,
           approximately 0.8km to the south of the site and prominently situated on a south facing
           slope. There are two further conservation areas in central Winchester: Wolvesey Palace
           and Winchester Cathedral Close, both about 1.6km to the south-west.

           Ecological designations
           Special Areas of Conservation
2.2.5      The River Itchen SAC crosses the study area from the south-west to the north-east,
           arching around the study site and being approximately 600m to the west at its nearest
           point. The Itchen is a classic example of a sub-type 1 chalk river and is dominated
           throughout by aquatic Ranunculus spp. SACs and other ecological designations are
           shown on Figure LA.02-2.

           Sites of Special Scientific Interest
2.2.6      The only SSSI within the study area is the River Itchen SSSI, covering the valley bottom
           about 600m to the west of the site. This site is notified for classic chalk stream and
           river, fen meadow, flood pasture and swamp habitats, particularly formations of in-
           channel vegetation dominated by water crowfoot Ranunculus spp, riparian vegetation
           communities (including wet woodlands) and side channels, runnels and ditches
           associated with the main river and former water meadows.

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Wildlife Trust Reserve
2.2.7    Winnall Moors WTR is situated approximately 600m to the west of the site and covers
         the flat valley floor around the River Itchen. A small section of the site to the south,
         adjacent to urban Winchester, has a car park, designated footpaths and viewing areas.

         Nature Improvement Area
2.2.8    The area covered by the SDNP was established as a Nature Improvement Area (NIA) in
         2012 ‘to create joined up and resilient ecological networks at a landscape scale’. The
         vision was for ‘a better connected and inspirational chalk ecosystem, sustainably
         managed to enhance biodiversity and people’s well-being for now and the future.’
         Funding ended in March 2015.

         Public access
         Public rights of way
2.2.9    There are no public rights of way either within or adjacent to the site and the area
         around the site is notable for how few public rights of way there are. The nearest
         public footpath, a short section that runs through the retail park to the west of the M3,
         is just under 0.2km from the site at its nearest point. The nearest bridleway to the site
         follows Easton Lane, about 150m to the north of the site. Beyond these the only other
         public right of way within the context area of the site follows the River Itchen about
         0.6km to the west, it is also part of the Itchen Way and Three Castles Path long distant
         footpaths. The South Downs Way national trail follows public rights of way 1km to the
         south of the site. Public rights of way and areas with public access are shown on
         Figure LA.02-3.

         Access land
2.2.10   The nearest access land to the site, and the only area within 2km, lies on the south
         facing slopes of Magdalen Hill Down about 0.8km to the south.

         National cycle routes
2.2.11   National Cycle Route 23 (NCR 23), which connects Reading to Southampton, crosses
         the motorway junction immediately to the north of the site. The route follows minor
         and residential roads, crossing the study area from the north-east to the south-west.
         Although not a national cycle route, the South Downs Way national trail is open to
         cyclists and follows public rights of way 1km to the south of the site.

2.3      Interim summary
2.3.1    The following elements of the landscape policies and designations are relevant to the
         assessment of landscape and visual effects of this proposal:

             The site lies between urban Winchester and the South Downs National Park.
              Waste planning policy pertinent to the site is set out in the Hampshire Minerals &

                                                13
Waste Plan (2013) which stipulates that development effecting designated
                 landscapes should ‘enhance the character of the surrounding landscape and
                 natural beauty, wildlife and cultural heritage of the designated area’;
                The Winchester Local Plan states that ‘new development should be in keeping with
                 the context and the setting of the landscape … of the South Downs National Park’
                 and that the ‘emphasis should be on small-scale proposals that are in a sustainable
                 location and well designed’;
                Aside from the SDNP, there are no designated landscapes within the context area
                 of the site, all scheduled monuments, listed buildings, ancient woodland and
                 conservation areas are both distant and screened by topography, buildings and/or
                 vegetation;
                There is no public access to the site. The adjacent A272 is a busy road with fast
                 moving traffic (national speed limit) and has no provision for pedestrians. The
                 footpath through the centre of the junction 9 roundabout is the only area within
                 the vicinity of the site with regular use by pedestrians and cyclists; and
                There are no ecological designations within the context area of the site,
                 topography and development screening out those along the River Itchen about
                 600m to the west of the site.

3.0 The Proposed Development

3.1.1      Details of the proposed development are provided on the application plans and the
           Planning Statement accompanying the application. This chapter describes the main
           aspects of the proposed development which may affect the landscape and/or visual
           amenity. It also identifies features of the proposals which will assist in mitigating
           adverse landscape and visual impacts.

3.1.2      The site is situated on the eastern edge of Winchester, occupying a narrow strip of land
           between the M3 and the A272 (Spitfire Link). It is surrounded by semi-mature
           vegetation on embankments that drop down to the surrounding roads. The vegetation
           is sufficient to screen the site. The site falls from a high point of about 67m AOD in the
           north to a low point in the south of about 56m AOD and is accessed via an entrance off
           the A272 on its south-eastern side. The site was formally used to dispose of surplus
           material from the M3 construction contract in 1983 and subsequently was reverted to
           agricultural use.

3.1.3      The proposals are to use the site as a highways waste management facility, which
           would experience approximately 100 vehicle movements a day (50 in and 50 out), of
           which about 12 may be during night time hours. Proposed structures on the site would
           include an office and welfare facilities and a topsoil barn, the latter being approximately
           6m high. The site would also operate movable equipment associated with the sorting
           and grading of materials and contain stockpiles of this material.

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3.1.4   Buildings on the site would be located near the site entrance, the office and welfare
        facilities in the southernmost part, screened by existing trees, with a parking area
        adjacent. The northernmost part of the site is to be maintained as chalk grassland.
        Between the two would be two screening bunds, approximately 3m high and to be
        planted with vegetation which would assist in integrating the site into its environment
        and subdivide the site into sections in views towards it. Additional planting is also
        proposed along the south-western boundary to strengthen the gappy vegetation
        between the site and the M3.

        Sources of potential effects on landscape and views
3.1.5   The main features of the development proposal which are likely to result in landscape
        and visual impacts are:

            Change of land use;
            Site welfare facility cabins;
            Storage mounds of inert material;
            Machinery used and/or stored on site;
            Movement of machinery within the site;
            Vehicles accessing and leaving the site;
            Establishment of potential screening vegetation.

        Mitigation measures
3.1.6   The potential for adverse effects on landscape and visual amenity has been recognised
        and mitigation measures incorporated in the scheme to avoid or reduce adverse effects
        or to offset or compensate for unavoidable adverse effects.

3.1.7   As the proposals are for the long term use of the site, mitigation measures incorporated
        into the scheme are designed to take this into account, and include the strengthening
        of vegetation around the site boundary, particularly to the south-west where there is
        currently very weak screening between the site and the M3. Screening bunds, which
        would be approximately 3m high, with vegetation are also proposed in two places
        across the site in order to subdivide the site into sections and reduce its visual
        presence, particularly in views towards the site from the south.

4.0 Effects on the Landscape

4.1.1   This chapter deals with the effects on the landscape of the site and its context of the
        proposed construction and occupation of the site.

                                                15
4.2        Assessment criteria
4.2.1      The assessment process is described generally in section 1.3. The general methodology
           for assessing the effects is set out in Appendix 1, and the criteria used in this L&VApp
           are set out in the tables below.

4.2.2      The degree of the likely landscape effects of the proposed development is determined
           by relating the sensitivity of the receptors to the changes arising from the development
           proposals, and the degree and nature of the changes in the landscape arising from the
           proposals.

           Sensitivity
4.2.3      As described in Appendix 1, the sensitivity of landscape receptors4 is dependent on
           their value and susceptibility to, or ability to accommodate, the changes that would be
           brought about by the proposed development. The sensitivity of landscape receptors
           combines professional judgments of the value attached to the landscape or its
           components, established in the baseline study, and their susceptibility to the type of
           change arising from the development, as follows:

4.2.4      The following categories of landscape sensitivity to change are used, combining
           consideration of landscape value and susceptibility, with the criteria applied:

           Table 4-1 Indicative criteria for assessing landscape sensitivity
            Category           Indicative criteria
             High sensitivity          A highly valued landscape e.g. of national or international
                                       importance, whose character or key characteristics are very
                                       susceptible to change;
                                       Aspects of the landscape character are highly valued as “key
                                       characteristics” and identified as susceptible to change in
                                       national or local character assessments;
                                       The landscape character is highly valued as intact and in good
                                       condition and particularly vulnerable to disturbance;
                                       A highly valued landscape with no or limited potential for
                                       substitution or replacement.
             Moderate                  A landscape of local importance or value, whose character or key
             sensitivity               characteristics are susceptible to change;
                                       Other characteristics of the landscape character also noted in
                                       national or local character assessments and susceptible to
                                       change;
                                       The landscape character is valued for moderate condition and
                                       not particularly vulnerable to disturbance;

4   The term used for elements and aspects of the landscape that might be affected by the proposals and
    people with views of the development.

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Category               Indicative criteria
                                A moderately valued landscape with some potential for
                                substitution or replacement.
         Lesser sensitivity     No or little evidence of value or importance attached to the
                                landscape area, its features or characteristics;
                                Few features, characteristics or qualities susceptible to
                                disturbance or particularly susceptible to improvement or
                                upgrading
                                Good potential for substitution or replacement

4.2.5   These are the criteria against which receptors are considered in order to arrive at a
        judgement as to their sensitivity, but it is not necessary for all the criteria set out for a
        category to apply.

        Magnitude of change
4.2.6   The degree of the likely landscape effects of the proposed development is determined
        by relating the sensitivity of the receptors to the changes arising from the development
        proposals, and the degree and nature of the changes in the landscape arising from the
        proposals.

4.2.7   The scale of magnitude of the changes is related to considerations of the size or scale
        of the change, the geographical extent of the area influenced, and the duration and
        reversibility of the change. The scale of magnitude of the changes is graded, as
        follows:

        Table 4-2 Indicative criteria for assessing magnitude of landscape change
         Magnitude of       Landscape Change
         Change
        Great change            Major size or scale of change, affecting the landscape type or
                                character of the area within which the proposal lies or extending
                                over the wider area; likely to be longer term or permanently,
                                with low prospect of reversibility
        Medium change           Intermediate size or scale of change, affecting part of the
                                landscape type or character of the area within which the
                                proposal lies, or larger scale of change at the level of the site or
                                immediate context; likely to continue into the medium term, with
                                good prospect of reversibility
        Small change            A minor proportion of the extent of the character type or area is
                                affected or smaller scale of change over a larger extent; the
                                changes occur at the level of the site or immediate context, and
                                likely to be short term and reversible.
        None                    No change to landscape characteristics

                                                 17
Assessing effects
4.2.8      The degree of effect, whether adverse or beneficial, is assessed by relating the
           sensitivity of the receptor and the magnitude of change, by considering the following
           indicative criteria:

           Table 4-3 Indicative criteria for assessing landscape effects
            Landscape effect     Indicative criteria
             Major                       Highly sensitive landscape completely degraded or greatly
                                         changed, with little or no scope for mitigation;
                                         Great improvement, sufficient to upgrade overall landscape
                                         character.
             Moderate                    Medium change to moderately sensitive landscape or its
                                         character; lesser change to higher sensitivity landscape or
                                         greater change to less sensitive landscape.
             Minor                       Small or limited adverse change to the existing landscape or its
                                         character; greater change to less sensitive landscape;
                                         Considerable scope for mitigation;
                                         Small improvement to the existing landscape.
             Negligible                  No perceptible change to the existing landscape or its
                                         character;
                                         The change is difficult to discern.

4.2.9      Intermediate conditions may be described, such as Moderate-Major, where the criteria
           for Moderate may be exceeded but not qualify as Major. Where magnitude of change is
           “None”, the effect would correspondingly be “None”.

4.2.10     Effects may be adverse or beneficial. In some instances, the effect may be offset by
           other considerations, for example, through the mitigation or landscape proposals, and
           the resulting effect may be neither beneficial nor adverse.

4.3        Landscape baseline
4.3.1      The landscape baseline is a description and analysis of the existing landscape, against
           which the effects of the proposed development are assessed. The landscape is
           described, first, by reference to landscape character assessments for the area in which
           the site is located, at national and local levels and, then, from site-specific surveys and
           analysis carried out for the purposes of this assessment.

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National landscape character assessment
4.3.2     The desk study has made reference to National Character Areas for England5. National
          Character Areas (NCAs) divide England into 159 distinct natural areas. The new NCA
          profiles update the previously published Joint Character Area (JCAs) and Countryside
          Character Area descriptions (1998-1999 by the Countryside Agency). Each NCA ‘is
          defined by a unique combination of landscape, biodiversity, geodiversity and cultural
          and economic activity. Their boundaries follow natural lines in the landscape rather
          than administrative boundaries, making them a good decision making framework for
          the natural environment.’

4.3.3     The site is located close to the southern boundary of National Character Area 130
          Hampshire Downs. To the south of the site is National Character Area 125
          South Downs. The key characteristics of NCA 130 of relevance to the site are
          identified as:

              The rolling, elevated, chalk arable downland has an open, exposed character that
               provides open skies and long-distance views.
              Elevated plateaux and upper valley slopes are characterised by extensive open
               tracts of large, low-hedged fields with thin chalky soils, shelterbelts, and ancient
               semi-natural woodland blocks on clay-with-flint caps on some of the steeper
               slopes.
              The rivers and streams of the Test and Itchen catchments are internationally
               significant, and distinctive chalk rivers, running in deep valleys, cut into the Chalk.
              A network of distinctive and ancient droving roads and trackways is a particular
               feature across the Downs.
              There is widespread evidence of prehistoric settlement on the open downlands,
               including burial mounds with visually prominent iron-age hill forts. In the valleys,
               there is evidence of Roman estates and nucleated medieval village settlement
               patterns, and fieldscapes and farmsteads across the downlands evidence the
               gradual and planned enclosure from the medieval period.
              The area’s distinctive appearance derives from the use of chalk cob (in the west),
               weatherboarded timber frame and small, handmade local brick with flint in
               traditional rural buildings and walls surrounding farm courtyards, with thatch
               surviving in many places.
              The settlement pattern varies between the relatively dense strings of villages along
               the lower river valleys and the very low-density, nucleated settlements in the
               upper reaches of the rivers and on the Downs.
              The ancient city of Winchester is located at the heart of this landscape and at the
               centre of the Itchen Valley.

4.3.4     The key characteristics of NCA 125 of relevance to the site are identified as:

5
    National Character Area Profile - Character Area 130: Hampshire Downs: Natural England, 2014

                                                  19
     A broad elevated east–west chalk ridge with a predominantly steep north-facing
                 scarp slope and a gentle southerly dip slope, breaking into a series of hills in the
                 west and terminating in distinctive chalk cliffs in the east.
                Woodland a feature of the central downs and, to a lesser extent, the western
                 downs, also concentrated on the steep scarp slopes, consisting of both
                 broadleaved, mostly ancient, woodland with beech, veteran trees, ash and
                 sycamore, and conifers, with some large plantations.
                Roads and villages concentrated in the river valleys, the more elevated areas
                 sparsely settled with scattered farmsteads.
                Flint, brick and timber frame conspicuous in the built environment in walls,
                 buildings, churches and barns, while roofs are of tile, slate or traditional thatch.
                 The South Downs was once lined with windmills, some of which survive.
                Bronze-age round barrows and prominently sited iron-age hill forts, such as Old
                 Winchester Hill, are notable prehistoric features of the scarp and hill tops,
                 especially in the west (most of which are designated as Scheduled Ancient
                 Monuments).
                Public rights of way following drove roads and ancient routes along the accessible
                 downland tops, benefiting from panoramic views across the downs and the Low
                 Weald NCA. Roads and lanes striking across the downs perpendicularly and
                 following historic tracks that originally brought livestock to their summer grazing.

           County and District level landscape assessments
4.3.5      The most recently published Landscape Character assessment of relevance to the site is
           the Hampshire County Integrated Character Assessment, which was published
           in May 2012. The site is located within the Landscape Character Area 3C: Itchen
           Valley but is on its easternmost boundary, to the east of this lies Landscape
           Character Area 8G East Winchester Downs. The sites location on the transition
           between the two character areas is notable in its overlap with the key characteristics of
           each character area:

4.3.6      Key characteristics Landscape Character Area 3C: Itchen Valley are identified as:

                The Itchen is a classic chalk stream, running through an area of soft permeable
                 rock, supplied by underground aquifers.
                A valley of contrasts from a small stream to a fast flowing river and then deep
                 estuary but the largely undeveloped floodplain is a unifying feature.
                The stream and some of floodplain is internationally designated as a SAC because
                 of its chalk stream habitat, rich in plants, invertebrates and fish.
                The valley floor is mainly neutral grassland, a complex mosaic of fen species rich
                 meadow and improved meadows, considered to be the largest assemblage of
                 species rich neutral grassland in England.
                The small villages and scattered farms sit comfortably within the valley.
                An extremely rich built heritage and setting to Winchester and developed valley
                 sides in lower reaches.

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    There is fairly good access to the valley by rights of way, and the Itchen Valley
             path follows the former towpath from Cheriton to Southampton.

4.3.7   Key characteristics Landscape Character Area 8G East Winchester Downs are
        identified as:

            Topographically varied and striking rolling landscape including steep scarps,
             extensive branching dry valleys systems which produce deep, narrow, rounded
             combes for example at Chilcomb and the Devil’s Punchbowl.
            Dominated by large 18th and 19th century fields of arable and pasture, bounded
             by sparse thorn hedgerows, creating an open landscape.
            Tracks surviving from the earlier manorial downland landscape are important
             historic landscape features.
            A strong sense of remoteness and tranquillity away from the major transport
             routes (M3, A31, A272) which cross the landscape.
            Large number of prehistoric and later earthworks, long barrows and round
             barrows, providing a strong sense of historical continuity.
            Good public access with a network of public rights of way, including the South
             Downs Way national trail, and open access land at Magdalen Hill Down and St
             Catherine’s Hill.
            Sparse settlement and isolated farmsteads of 18th-19th century, with more
             modern buildings along the B3404 on the edge of Winchester.
            Large open skies ensure that weather conditions are a dominant influence creating
             a dynamic, moody landscape, particularly on higher ground.
            The area forms an important eastern setting to Winchester.

4.3.8   In the Forces for Change section opportunities listed include:

            Use Planning policies and conditions to ensure that any new development is
             sympathetic to existing settlement form, styles and materials, and is well
             integrated into the landscape.
            Use planning policies and conditions to minimise the impact of intrusive structures
             through sensitive siting, and screening if possible.
            Use planning policies and conditions to retain open and distinctive skylines,
             especially where they contribute to the setting of Winchester. Any new
             development should be sensitively located to avoid prominent ridgelines, and
             screened with indigenous species where possible.

4.3.9   The Winchester District Landscape Character Assessment was produced in 2004
        Unlike the Hampshire Landscape Character Assessment the character area boundary
        runs along the M3 rather than Spitfire Link so the site is included within Landscape
        Character Area 12: East Winchester (Winchester to the west is not included within a
        character area). Key characteristics of relevance to the site are identified as:

                                               21
     Topographically varied landscape with high open expansive areas of arable
                 farmland, punctuated by steep escarpments.
                Free-draining area with no obvious surface water bodies and channels other than
                 occasional dew ponds and sewage works’ ephemeral lake. Forms part of the River
                 Itchen catchment area.
                Intensive arable farmland occasionally broken by shelterbelts and beech clumps. A
                 field pattern strongly influenced by informal and formal enclosure followed by
                 subsequent boundary loss and rationalisation, resulting in regular medium to large
                 fields. In particular, this has resulted in the extensive prairie fields of Longwood
                 Warren, returning the area to its former downland openness.
                The variety in landform and tree cover within the character area has given rise to
                 differing senses of enclosure throughout the character area, from the exposed,
                 panoramic nature of the Downs, to the more sheltered intimate feel of Chilcomb,
                 nestled at the base of Deacon Hill.
                Numerous historic features, including the prehistoric hillfort on St Catherine’s Hill,
                 and the enclosures south of Twyford Down and south of Avington Park. Drove
                 roads are also a common feature.
                A sparsely populated area, the only settlements include the small nucleated
                 Domesday villages of Chilcomb and Avington.

4.3.10     Landscape strategies for the character area include:

                Restore and enhance existing hedgerow structures through replanting (where
                 appropriate) and management, whilst retaining the openness of the downland.
                Encourage appropriate management of chalk grassland roadside verges.
                Encourage any new woodland planting to use locally indigenous species and to
                 respond positively to the contours and landform.
                Sensitively locate new development to avoid prominent ridgelines and plant locally
                 indigenous species where appropriate.
                Conserve the scattered pattern and sparsely populated rural character of the area.
                Minimise the impact of intrusive structures through sensitive siting and screening
                 with planting.

4.4        Site-specific appraisal
           The landscape of the site
4.4.1      The site consists of a single enclosure which been restored to a field following use
           during the construction of the M3. It is surrounded by a wood post and rail fence,
           beyond the fence is scrub and woodland planting on escarpments that drop to the M3
           to the west and the A272 to the east. To the west of the motorway is a retail and
           commercial park and to the east of the A road is open arable farmland. The land along
           the edge of the motorway and the A road is heavily wooded with a mixture of semi-
           mature deciduous and coniferous trees which screen these features in the landscape.
           The site has a history of commercial use being used to dispose of surplus material from

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