New Design Update on Planning Portal!
Dear wonderful people,
Can you help object to the new responses from Silverlake on the portal. They just dumped nearly 70 documents all at once - which we can all respond to.
YOUR CHANCE TO BE HEARD! please OBJECT BY OCTOBER 13TH to UPDATED SILVERLAKE DOCUMENTS (dated 1/9/2025) email us @ communityagainstsilverlake@gmail.com for further information.
LINK:
https://planning.hants.gov.uk/Planning/Display/HCC/2024/0464
Here is one objection response to just one document - if we all read one doc and object it would help:
We strongly dispute the description and policy interpretation set out in Aspect Landscape Planning’s Landscape and Visual Impact Assessment (LVIA) (ref. 8285.LVIA.004). The LVIA downplays the rural, agricultural, and countryside character of the site and surrounding landscape, and it overlooks key elements of national and local planning policy that should safeguard this field from inappropriate industrialisation.
1. Mischaracterisation of the Site as Suitable for Expansion
The report itself acknowledges (para. 2.3) that the eastern half of the site is currently arable farmland and classified as ‘Open Countryside’ under adopted planning policy.
Despite this, the LVIA repeatedly treats this land as an extension of the existing industrial site, rather than recognising its primary rural character, role in the agricultural economy, and contribution to the landscape setting of Shedfield Parish.
The LVIA’s methodology (GLVIA3) is applied selectively and dismisses the wider rural setting, instead overemphasising existing roadside planting and the presence of the existing Silverlake site as justification for encroachment. This is not consistent with GLVIA3’s requirement to consider landscape character at all relevant scales, including local countryside context.
2. Policy Conflict – Development in the Countryside
Winchester Local Plan Policy MTRA4 makes clear that development in the countryside will only be permitted if it has an operational need for a countryside location (e.g. agriculture, horticulture, forestry) or is a proportionate expansion of an existing rural business.
The proposed expansion is not agricultural, nor does it demonstrate any operational need to be located on productive arable land.
The proposal is disproportionate, sprawling into undeveloped farmland rather than being contained within the existing industrial curtilage. This is exactly the type of creeping industrialisation of open countryside that MTRA4 and Policy DM22 (Rural Character) are designed to resist.
3. Visual and Landscape Harm
The LVIA claims no significant impact on views, yet it acknowledges that the nearest listed building (para. 2.4) directly overlooks the site. The effect on the heritage setting has been minimised and requires independent assessment.
The site is visible from Public Right of Way 207/10/1, meaning rural users of the landscape will directly experience the industrial intrusion.
The proposal conflicts with Policy CP20 (Heritage and Landscape Character) and Policy DM14 (Local Distinctiveness), both of which require conservation of rural landscape character and recognition of countryside beauty, tranquillity, and local distinctiveness.
The viewpoint locations chosen for the visual impact study (see drawing 8285 revision A) have been chosen to show least affect and impact on the countryside view. For example there is no viewpoint location shown at Hall Court looking through Rowash Farmhouse which is an amazing viewpoint to see the solitary 220 oak tree. The community and pedestrians at Hall Court are often found walking and seeing this view. Why is it not included in the viewpoints? Because it is a would show a high impact effect. This whole report is skewed to minimise impact of visual affect.
Another example of this aspect is that viewpoint 5 is not indicative of the impact of pedestrians and that a viewpoint should be taken in the middle of the public footpath between Row Ash House and Rowash Farmhouse which is a stunning view of a beautiful 220 year old tree backed by the SINC woodland (which is healthier than indicated – see expert tree report objection in public consultation by Peter Mila). The visual impact viewpoints need to be reviewed and underplay and undervalue the impact, which in reality is stunning and to have a factory built there would be a huge loss of beautiful visual countryside.
4. Protection of Agricultural Land
The LVIA acknowledges the eastern portion of the site is in agricultural use. Development would result in the irreversible loss of countryside farmland, contrary to the NPPF (para. 187), which requires recognition of the intrinsic character and beauty of the countryside and protection of the best and most versatile agricultural land.
No true and responsible justification has been provided (other than for commercial gain and ease and monopoly of use) as to why industrial expansion must occur on this particular field, when the NPPF (para. 11) emphasises making effective use of previously developed land in urban areas.
5. Biodiversity and Green Infrastructure
The LVIA acknowledges proximity to a Site of Importance for Nature Conservation (para. 2.5), yet seeks to downplay the ecological connectivity between the site and the surrounding countryside.
Policies CP15 (Green Infrastructure) and CP16 (Biodiversity) require net biodiversity gain and protection of ecological corridors. Expanding the industrial footprint into open countryside fragments habitats and contradicts these requirements.
6. Local Planning and Community Guidance
The Shedfield Parish Plan and Village Design Statement (2016) is a formally adopted Supplementary Planning Document and therefore a material consideration. It highlights the importance of protecting the countryside setting, tranquillity, and local views. The LVIA references this document but dismisses its weight in favour of expansion, which is a misrepresentation.
Conclusion
The LVIA attempts to frame the site as a logical extension of the existing Silverlake premises. In reality, the proposal represents unjustified industrial encroachment into open countryside farmland, in direct conflict with:
NPPF paras. 8, 11, 135, 187 (countryside protection, sustainable use of land, character, biodiversity)
Winchester Local Plan Policies MTRA4, DM22, CP15, CP16, CP20
Hampshire Minerals & Waste Plan Policy 5 (Protection of the Countryside)
The rural setting of Shedfield Parish must be safeguarded. Approval of this development would set a dangerous precedent for further countryside industrialisation and would cause permanent and irreversible harm to the character, landscape, and tranquillity of the area.
Rebuttal to Section 3: Baseline Assessment
1. Rural Setting and Policy Status
The LVIA repeatedly acknowledges that the eastern portion of the site is undeveloped arable farmland and is classified in planning policy as open countryside. This alone establishes the site as highly sensitive to inappropriate development.
Attempting to dilute this policy position by citing surrounding influences (traffic on the A334, presence of vineyards or solar farms, etc.) does not remove the fundamental fact: the proposal constitutes industrialisation of countryside land, which conflicts with Winchester Local Plan Policy MTRA4.
2. Misrepresentation of Landscape Value
The LVIA places undue weight on the absence of statutory landscape designations. However, the NPPF (para. 187) is clear that the intrinsic character and beauty of the countryside should be recognised and safeguarded, regardless of designation.
Farmland and scattered mature oaks (some with Tree Preservation Orders) are valuable rural features in themselves. The report attempts to minimise their importance by claiming they are “not distinctive” or “in poor condition,” but the presence of TPOs confirms that Winchester City Council already recognises the value of these trees as part of the local landscape character.
The attempt to classify the site’s sensitivity as “Medium/Low” is flawed. By GLVIA3’s own definitions, the combination of open countryside designation, arable use, protected trees, and proximity to heritage assets (Row Ash House, Raglington Farmhouse, Shedfield House, There is a Queen Anne house at Hall Court and Rowash Farmhouse dates from 1700setc.) strongly supports at least a Medium–High sensitivity rating.
3. Public Rights of Way and Visual Amenity
The LVIA claims that the PRoW network is “relatively sparse” and therefore impacts are limited. In fact, PRoW 207/10/1 and PRoW 207/9/1 both provide clear public views of the site in its current open, rural state.
High sensitivity receptors such as walkers, riders, and residents will directly experience industrial expansion. GLVIA3 requires that receptors’ sensitivity is properly weighted — dismissing PRoW views as “limited” is contrary to best practice.
The introduction of large-scale industrial buildings and operations cannot be screened without significantly altering the character of the countryside. Planting belts or screening cannot replicate the openness and rural quality of farmland.
4. Heritage Setting
The report underplays the proximity of Row Ash(Grade II), and Rowash Farmhouse built directly adjoining the site. Its historic rural setting includes open fields, which will be irrevocably compromised by expansion.
GLVIA3 and the NPPF both emphasise the need to consider indirect and setting impacts on heritage assets, not just intervisibility. The character and significance of listed buildings derive from their rural context — replacing this with industrial activity is unacceptable.
5. Tranquillity and Countryside Character
The LVIA argues that traffic noise and nearby diversification schemes reduce tranquillity. However:
The A334 is a rural highway, not an industrial corridor.
Agricultural diversification (vineyards, solar panels, farm shops) still fall within the countryside economy supported by planning policy. They do not justify large-scale industrialisation which Silverlake Expansion is industrial in nature with its proposed high stack car towers and huge 48 ft high factory building.
Noise from the existing Silverlake operation is already a concern. Expansion will worsen this, contrary to Policy DM22 (Rural Character) and Policy CP20 (Heritage and Landscape Character), both of which seek to preserve countryside tranquillity.
6. Safeguarded Site Misuse
The LVIA refers to the Hampshire Minerals and Waste Plan, suggesting the site’s status as a “Safeguarded Site” makes development acceptable. In fact, safeguarding exists to prevent conflict with future waste management needs, not to justify unrelated industrial expansion onto farmland. This is a misapplication of policy.
7. Conclusion on Baseline Sensitivity
The LVIA’s conclusion that the site is of “Medium/Low sensitivity” is unsound. By any reasonable application of GLVIA3, the site’s combination of open countryside policy status, agricultural land use, TPO-protected trees, heritage setting, PRoW visibility, and contribution to rural tranquillity elevates its sensitivity to at least Medium–High.
Development would therefore cause significant adverse landscape and visual effects, which cannot be mitigated through planting or screening.
Rebuttal to Section 3: Baseline Assessment
LVIA Claim: The site is not subject to any landscape designations, therefore sensitivity is “Medium/Low.”
Our Rebuttal: Absence of designation does not mean low value. The NPPF (para. 187) requires recognition of the intrinsic character and beauty of the countryside. The site is open farmland with TPO-protected trees, and is therefore of Medium–High sensitivity.
LVIA Claim: Surrounding land uses (vineyards, golf course, solar panels) reduce rural quality.
Our Rebuttal: These are examples of agricultural diversification, which still fall within countryside policy and retain a rural character. They do not justify large-scale industrialisation.
LVIA Claim: The site is visually contained by roadside hedgerows and vegetation.
Our Rebuttal: In reality, PRoW 207/10/1 and 207/9/1 provide open public views across the field. Screening would require artificial bunding or dense planting, such as a 5ft high fence which would itself would harm countryside openness.
If this proposal were to happen it would set a precedent for Hampshire villages all over the county to be subject to industrial type expansion – is not the planning process set up to stop this happening?
THANK YOU ALL!!