The Fareham Society
12 High StreetFarehamHampshirePO16 7BL Tel: 01329 280526
Registered Charity No.271344
Mr Mark Wyatt
Fareham Borough Council
Fareham, PO16 7PU
Dear Mr Wyatt,
Welborne Outline Planning Application P/17/0266/OA : Buckland Development Limited
The Society has spent considerable time assessing the application and all the supporting documents. It has tried to concentrate on the items that are to be permitted rather than those which are to be reserved matters to be the subject of future determination.
The main comments and objections therefore relate to the works to M27 Junction 10, the three roundabouts and the related works to the A32, and the impacts of these works. Most of the other items listed in the description of the proposal are simply the components of Welborne included in the adopted local plan and comments are only made where there appears to be a significant diversion from the adopted plan or the proposals are unacceptable . Comments have also been made on the Parameter Plans because they are to be ‘bound to the outline’ by a condition saying reserved matters would be ‘broadly compliant’. We have also commented on the supporting information which should justify the proposals.
The comments that have been received from the various statutory consultees and other organisations clearly demonstrate that the application as submitted is deficient in many respects and cannot be permitted without significant revision and improved and updated supporting information. The Society has assumed that when the necessary revisions are made, and new supporting information submitted, a further consultation will be carried out.
The Society is pleased that some of the information it has been seeking for many years, particularly up to date information on traffic using the local roads, has now been provided. However even this is incomplete and in many other aspects the application provides little if any additional information than that included in the adopted Welborne Plan.
The inadequacies of the current application need to be addressed by the applicant and the Borough Council. The location and constraints of the Welborne site were always going to lead to problems at the detailed planning stage and this will be experienced by whoever develops the site.
Works to M27 Junction 10, the three Roundabouts and the Related Works to the A32
The Society has consistently objected to the changes to Junction 10 because of the impact of the increased traffic generated on the residents of North Fareham, Funtley, Wickham and other settlements on the A32 to the north. When the M27 was designed in the early 1970s, concern about traffic impact on these areas was the reason for the current limited moves junction.
The combination of the revisions to Junction 10 with the additional traffic generated by the Welborne development could have a significantly greater adverse impact on the locality. The adopted Welborne Plan relies on various measures to try to mitigate this impact and the information submitted with the application is the first time that specific measures have been set out and their likely impact quantified in the Transport Assessment.
It is clear that the transport modelling that has been used, the SRTM, is not in compliance with the Government guidance. In 2014, the Solent Transport Joint Committee agreed an upgrade of the SRTM because by 2015 it would be based on data that is at least five years old with some of the survey data used in matrix development being six or seven years old. The report to the Joint Committee referred to the Government WebTAG guidance which suggests that models should not be based on data over six years old (TAG Unit M3.1 Paragraph 8.1.1). It also referred to updating the planning assumptions of the evidence in the light of progress on local plans.
The SRTM evidence base currently utilises 2001 Census Journey to work origin and destination data, but the equivalent 2011 Census data was released in 2014. The upgrade of the SRTM has not yet been completed, therefore the Transport Assessment accompanying the planning application is based on modelling which has an evidence base which relies on journey to work origin and destination data which is now 16 years out of date and other data which is eight to ten years out of date. The upgrade of the SRTM has not yet been completed, therefore the modelling on which both strategic and local transport mitigation is based is too out of date to be relied upon. It is also a strategic model and therefore, even if
up-to-date is unlikely to be suitable for the modelling of local impacts of measures such such as the traffic management measures proposed.
The SRTM does not provide the information required for decisions to be made on the impact of Welborne with or without the changes to junction 10. It provides comparisons in traffic flows between the situation with Welborne and without Welborne. However, the latter includes an assumed distribution throughout South Hampshire of the quantity of development that is proposed to take place in Welborne. This assumed distribution is fundamentally unsound because it forces development into dense urban areas, particularly Portsmouth, where the very limited scope for further development is the prime reason for the
identification of Welborne as a strategic site for development. The design of the new M27 Junction 10 does not improve the existing substandard weaving distances between Junctions 10 and 11.
Impact on Local Roads
The impact of increased traffic generated by Welborne and the changes to M27 Junction 10 is of great concern to local residents. This impact, and the ease of vehicular access for the residents of north Fareham in particular, especially those living in or using North Hill, Old Turnpike, Kiln Road, Park Lane and Wickham Road should be clearly spelt out at this stage. (The deterring of vehicular traffic from using the North Hill route for access to their homes is suggested. What is an alternative route for residents, other than through nearby residential roads?) Unfortunately, this information is not easily accessible in the vast amount of information in the Transport Assessment, and when it is found it is not credible.
The traffic problems foreseen by The Society and local residents were raised at the Local Plan Examination, but were not adequately addressed by the Council or the Inspector. It is vital that this issue is resolved now because, as the mitigation measures show, it will result in an irreversible situation requiring the pedestrian/cycling dual use of inadequate existing pavements and even the narrowing of
existing pavements in Wickham Road. Many roads will experience an unacceptable increase in traffic with the resulting increase in noise, vibration and deterioration in air quality.
N.B: It is assumed that there will be restrictions on the use of these roads by construction traffic and that these restrictions will be rigorously enforced.
The 2016 traffic counts provide up-to-date information for use as a base for estimating the impact of Welborne and the changes to M27 Junction 10. However, there are several gaps in the 2016 data, particularly in relation to the junctions of Old Turnpike and Serpentine Road with Wickham Road and the junction of Serpentine Road with Park Lane. There is also no information on traffic in High Street and Osborne Road: how is it possible to provide realistic estimates on the future flows on these roads without up-to-date base information?
The future estimates for the local roads appear to result in some figures which defy rational explanation. For example, why would traffic flows in Broadcut be reduced to less than half the current flows in 2036 with or without Welborne? In particular, why would the turns from Wallington Way westbound into Broadcut be more than halved? There are many more examples like this: perhaps the most extreme is the estimated change in flows A27 East to A27 West where the figures show flows increasing from 9 in 2016 to over 1,700 in 2036 with or without Welborne.
In relation to Wickham Road south of the Southampton Road junction, the absence of 2016 figures for the Wickham Road, High Street, Osborne Road junction makes understanding difficult. It appears that the increase in traffic flows is of the order of 250% to 350% and much turns into or from Osborne Road. Where is this traffic coming from and where is it going?
It appears that the use of the SRTM for modelling these local roads results in these irrational figures, possibly because the part of the model which determines the routes taken by vehicles through the road network has not been informed by detailed understanding of the way in which the local roads are used.
Welborne Internal Road Network
The road system within Welborne results in too much traffic being directed through what should be primarily residential roads. The supporting information shows that this is largely due to the attempt to reduce traffic on the A32 and thereby reduce the separation of the areas of housing to the east from the main part of Welborne to the west of the A32. However, this results in two busy roads separating parts of Welborne rather than one. The intention to reduce the flows of traffic on the A32 between the north roundabout and the south (Meadow) roundabout results in an excessive volume of traffic on Welborne Way.
This is contrary to the intentions of the adopted Welborne Plan which in paragraph 7.24 which states that:
‘Within Welborne itself, a spine network of more minor roads will provide primary
access to the district centre, local centre, major employment uses and other
Comments and Objections on the Parameter Plans
The extension of the boundary to the north of Albany Farm is unacceptable as it intrudes into a countryside area beyond the boundaries of the Welborne Plan strategic development area. The allotments should be sited more centrally for the benefit of the community.
Access: Roads and Junctions
Deviations from the Strategic Framework Diagram in the adopted Welborne Plan result in the submitted outline application being unacceptable, particularly in relation to the district centre, schools, sports pitches, allotments, landscape buffers/greenspace (which also covers the setting of the historic buildings) and the primary road network.
The Society objected to the siting of the District Centre adjoining the A32 because its location and phasing would result in an out of town shopping ’destination’ not a true District Centre. The Society stated that the District Centre should be located towards the centre of the site; the location which the Sustainability Appraisal demonstrated is by far the most sustainable.
The Land Use Plan and the Design and Access Statement, which provides more detailed information on the District Centre, show that The Society’s objections were fully justified. The centre is not well connected to the main residential parts of Welborne and appears to be located so that it will attract as much custom from outside Welborne as possible. The application proposals appear to show the High Street as a potentially busy road which is contrary to the Welborne Plan Strategic Framework Diagram and would result in an unattractive centre.
The location of the proposed schools adjacent to the main distributor roads within the development is unsatisfactory and will result in unacceptable congestion and air quality impacts. The Design and Access Statement, which provides more detailed information, on page 123 shows the District Centre primary school with busy roads on three sides and is totally unacceptable.
Densities, building heights, land use, green infrastructure and sequencing are all identified on the respective Parameter Plans. These may well require significant alteration at the Reserved Matters stage so should not be approved in principle as part of this application.
The height of buildings in the district centre close to the Grade II* listed Dean Farm should be reduced to avoid a significant adverse impact on the listed building. The deviation from the Strategic Framework Diagram of the adopted plan has caused an unacceptable situation re the setting of Dean Farm and has also removed the generous landscaping buffer protecting the boundaries of Roche Court. This should be reinstated.
Deviations concerning green infrastructure from the Strategic Framework Diagram have already been mentioned. The location of the sports pitches immediately to the north of the M27 is undesirable because of the poor air quality and noise.
Inadequate provision for open space and SANGs is shown. Dashwood, outside the application boundary, is not within the Borough, is a SINC and is not suitable for intense recreational use. A smaller proportion of Dashwood should be considered to form part of the overall SANGs provision. SANGs are intended to provide adequate land for dogs to be walked off the lead. If Dashwood is to retain its nature conservation interest and SINC designation in the long term, the area for open access for dogs should be reduced.
As already referred to, a belt of semi-natural green space should be provided between Roche Court and any adjoining housing in order to retain the setting of the listed building and the historic parkland.
It is also essential that a wide planting belt should be provided on the eastern boundary of the housing land east of the A32 to reduce impact on the countryside and views from Portsdown Hill.
Comments on the Supporting Plans
The construction of district centre is shown as being in sequence 1 on the Development Sequencing Plan. The Transport Assessment assumes that it will be complete in 2023. It is stated that it will form part of
Sequence 2, 2022/23-2025/26 in the Planning Statement. The Retail Assessment is based on it being complete in 2029, that is sequence 3. Which is it?
As submitted granting permission could result in the establishment of another out of centre/motorway junction shopping attraction with virtually no housing near it. The Retail Assessment is based on the
centre not being completed until 2029 when over 3,000 houses will have been completed. However, without a robust agreement on phasing, tying the amount of retail development that can be built at the District Centre to the number of homes completed there is nothing to prevent the centre being completed much earlier. The Transport Assessment Sequencing of Works (P40) shows the total retail floorspace of
10,000sqm being completed in 2023. By which time only 1,160 ‘households’ completed. However, these houses will mainly be remote from the District Centre and will be served by the Village Centre. This would result in a much more significant impact on Fareham Town Centre than the retail study identifies.
If Welborne is to be as self-contained as far as possible a health centre/GP surgery should be provided as early as possible. The current phasing, provision in 2022-2024 may be as early as possible, but it does not appear to be supported by the relevant CCGs at the present time. These comments have been submitted by the CCG following the approval of the Welborne Plan. It is absolutely essential that the health provision at Welborne is confirmed before any permissions are granted. The CCG is treating Welborne as an urban extension of Fareham and not as a sustainable stand-alone ‘urban village or town’ which would definitely have its own health facilities identified.
Comments on the Supporting Information
As stated above the SRTM is inadequate for traffic and therefore air quality forecasting. A new run, using the updated SRTM due to be completed in May 2017, is required. The appropriateness of the updated SRTM should be subjected to local validation checks before it is used for the modelling of traffic on the local roads.
Whilst three primary and a secondary school are proposed, there is no evidence that they will be provided as currently phased. It appears that HCC is seeking school contributions approximately one third higher than the figures in the Infrastructure Delivery Plan.
Reference has already been made concerning healthcare facilities for which there appears to be no commitment from the relevant health authorities to staff them.
Flood Risk Assessment
The Flood Risk Assessment contains insufficient information to demonstrate that there will be no increased risk of flooding. It is noted that the Lead Local Flood Authority, the County Council, is concerned that the development may have an adverse impact on surface water drainage and overland flows and is not currently satisfied that this impact can be satisfactorily mitigated.
Historic Environment and Archaeology
The Society recognises that the impact of the Welborne proposals on the Grade II* Dean Farm is to be mitigated at the detailed design stage; however it does not believe that satisfactory mitigation could be achieved with the demolition of the adjoining farm outbuildings and the relocated barn. The proposed 16.5m high residential buildings to the north and west, the proposed 12m high employment buildings to the east, and the proximity of what will be a very busy dual-carriageway, arise from the deviations from the approved Welborne Plan causing the potentially unacceptable downgrading of the setting of the farm.
The Society fully supports the recommendations of the County Archaeologist re the provisions of the Heritage Strategy and Management Plan. It is hoped that Fareham Borough Council is equally supportive.
The inadequacies of the current application underline The Society’s belief that this is the wrong location for such a large development: it is too close to the existing communities and the M27, there are numerous constraints, and the limited extent of the land suitable for development is inadequate to accommodate all of the desired components of a new community (Garden Village/Town).
It is again clear that many issues have not yet been resolved to the extent that would enable permission to be granted. The Society therefore objects to the outline application for the following reasons:
•The design of the new M27 junction 10 does not improve the existing substandard weaving distances between junctions 10 and 11.
•It has not been demonstrated that 6,000 dwellings together with the necessary infrastructure can be accommodated within the application boundary.
•Deviations from the Strategic Framework Diagram in the adopted Welborne Plan result in the submitted outline application being unacceptable, particularly in relation to the district centre, schools, sports pitches, allotments, landscape buffers/greenspace (which also covers the setting of the historic buildings) and the primary road network.
•It has not been demonstrated that the development proposed could take place without significant adverse impacts on local residents of the surrounding residential areas and villages, through additional traffic congestion and the consequential air quality impact and vibration.
•It has not been demonstrated that the development proposed could take place without the risk of flooding on parts of the site and the A32 or increasing the risk of flooding on the rivers Wallington and Meon.
•It has not been demonstrated that waste water can be dealt with without risk to surface and ground water, see Environment Agency comments.
•The application makes inadequate provision for open space, sports pitches, SANGs and insufficient contributions towards the Solent Recreation Mitigation Partnership.
Whilst not explicitly part of the application to be approved, The Society also objects to :
•The phasing of the District Centre which could result in the construction of another out of centre retail destination with a consequential significant adverse impact on Fareham Town Centre.
Mrs B.M. Clapperton, MBE:
Hon. Secretary, The Fareham Society