The Fareham Society
12 High Street Fareham Hampshire PO16 7BL Tel: 01329 280526
Registered Charity No.271344
8 December 2017
Planning Strategy and Regeneration
(Draft Local Plan)
Fareham Borough Council
Fareham, PO16 7AZ
Draft Fareham Local Plan Comments
The Society accepts that new housing and employment allocations will have to be made to meet the identified requirements over the extended period to 2036. However, the Society has objected to the development of many of the sites identified as developable at many previous local plan examinations and in relation to planning applications. It therefore finds it difficult to support the proposed allocations in the draft plan because of the loss of countryside/undeveloped land and the impact on infrastructure.
Unlike most of the people and organisations commenting on the Draft Plan, the Society covers the whole Borough and does not favour development in one part of the Borough rather than any other part. The Society supports the identification of the most suitable sites through the use of sound and comprehensive evidence wherever they are in the Borough. It has therefore concentrated on the soundness of the published evidence and how that appears to have been used to select the preferred sites.
The Society notes that there is strong opposition to many of the allocations, particularly the larger housing sites in Portchester, Warsash and Newgate Lane. The Society believes that this opposition is, in part due to the way in which the plan has been prepared and in part due to the lack of information on the perceived adverse impact on infrastructure and community identity of the developments proposed. People are afraid that the proposed developments will have a significant adverse impact on them and there is little that they can do to alleviate this other than suggesting that the development goes elsewhere.
An earlier consultation on the ‘issues and options, as carried out for the now adopted Sites and Policies Plan, would have significantly improved understanding of the need for additional allocations, the options available and the impact of each option. It is the role of the Borough Council to set out options/ alternatives and not the role of consultees as suggested at the CAT meetings.
Other authorities appear to carry out much better forms of consultation, with evidence available as soon as it is prepared and genuine options and opportunities for changing the plan in the light of consultation responses. Our experience in recent years is that Fareham does not take enough notice of responses; it does not make evidence available as soon as it is prepared and rarely, if ever, makes any changes reflecting the responses. For example, the Society spent a considerable time responding to the Town Centre Vision consultation, but the report on the consultation responses does not summarise the Society’s views or if or how they were taken into account. The Society assumes that if sites currently included as proposed allocations are deleted, any replacement sites will be subject to proper public consultation.
Comments on the Draft Plan
The Society is pleased to see that after well over ten years of relying on totally unrealistic start dates and build rates for Welborne the council has accepted competent advice and included more realistic build rates in the Welborne background paper. However, the Society notes that the rate of employment development lags behind housing development housebuilding so significantly that it results in a plan that will increase commuting.
The permission for the IFA2 and the proposals for a significant increase in the amount of employment development at Daedalus result in its continued inclusion within the Strategic Gap being unsustainable and an impediment to the protection of other parts of the gap (see comments on Boundary Review. Paragraphs 4.21-4.23 do not fully recognise the scale of the impact of the proposals on the gap; the development of Faraday Park, IFA2 and the Swordfish Business Park will reduce the ‘expansive views southwards across the airfield’ and reduce the perceived gap to a much smaller settlement gap between two business parks at the northern end of the site.
Fareham Town Centre
The extensive development/redevelopment proposed in Fareham Town Centre will need to be carefully phased in order to avoid excessive disruption to the area. For example, the new multi-storey car park on the Market Quay site would have to be provided before the Osborn Road multi-storey car park is demolished.
The Society supports the residential redevelopment of suitable sites, but some of the sites proposed for housing are not likely to provide good quality residential environments and should be allocated for employment uses.
Many of the proposals for housing in the town centre appear to be over ambitious. The proposals for the Civic Quarter and Market Quay with multiple other uses appear to be particularly excessive/ unrealistic for the size of the sites.
The over-emphasis on housing at the expense of convenient parking, for example in the Civic Quarter, at Market Quay and the closest part of Lysses car park to the High Street will undermine the viability of the remaining shops in the Town Centre. The draft Plan appears to cause more harm to the viability of the Town Centre rather than to enhance it.
It is most important that more detailed plans adequately address safe pedestrian access between West Street and the Civic Quarter, particularly when the shopping mall is closed.
The housing allocations appear to exceed the estimated requirement, but not by much and certainly not enough to enable many, if any, sites to be excluded without causing problems with the overall land supply.
The words ‘planning permission will be granted’ are not appropriate if there is a genuine possibility that some sites can be deleted following consultation. The Council is saying that, having considered all the evidence, it considers permission should be granted on the sites identified. This makes it very difficult to subsequently say that the sites are unacceptable and permission should be refused; what reasons for refusal could be used that would be given sufficient weight on appeal? At this first stage of consultation the plan should not be so specific, it should only state that the sites are options and it will be decided whether they are to be included as allocations in a subsequent version of the plan once the response to the public consultation has been considered. The Council has decided its preferred approach without setting out the options that have been considered and the detail of how the preferred approach has been chosen.
The evidence used to identify ‘developable’ and ‘preferred’ sites appears to be comprehensive and to follow a logical progression, but closer inspection shows that there are many anomalies and inconsistencies. Some sites that are identified as ‘developable’ are in locations that are remote from existing urban areas, or are too noisy and therefore not ‘in a suitable location for housing development’ (NPPF para 47 footnote 12).
One of the major inconsistencies is that sites shown as having high sensitivity in the Landscape Assessment, and/or low or medium development potential in figures 10.3 and 10.4 in Appendix D of the Sustainability Appraisal have been included as preferred housing sites, whereas, some of the sites identified as having low landscape sensitivity or high development potential have not been included as preferred housing sites. There is no reference to the assessment of high, low or medium development potential in the Housing Site Selection document.
There is no explanation for this in the draft Plan or any of the evidence. For example, the sites at Funtley Road South and east of Newgate Lane are shown as having high landscape sensitivity and low development potential in figures 10.3 and 10.4 in Appendix D of the Sustainability Appraisal, but are included as allocations. The Housing Site Selection states that Funtley Road South has medium landscape sensitivity, but the Landscape Assessment of the Upper Meon Valley, describes the whole valley as having ‘high landscape sensitivity’ and does not identify any parts of the valley as having medium landscape sensitivity.
The sites proposed for development in the draft Plan do not appear to be spread across the Borough in the same way that the sites with high development potential are in the SA figures 10.3 and 10.4. Some sites included as ‘developable but not preferred’ appear to be as suitable, if not more suitable than some of those that are ‘preferred’.
One of the overriding concerns in relation to all of the larger sites is the impact on the existing infrastructure, which is already inadequate in many locations, and the absence of specific proposals to improve the situation. The Infrastructure Delivery Plan does not provide the confidence that sufficient additional provision will be made (see under ‘Infrastructure’, page 4).
The almost 40 per cent shortfall in provision for office development will have a significant impact on the level of economic growth and employment in the Borough and will result in additional longer distance commuting and hence additional congestion. The shortfall means that the draft Plan is not in conformity with the PUSH Position Statement.
Community Facilities and Open Space
There is a very clear imbalance in the provision of community centres/facilities in the Borough, particularly in relation to the population, with far more located in the west than the east. A replacement for Fareham Community Centre should be included in the Plan.
The Borough Council appears to have taken little notice of the Society’s previous comments on the Town Centre Vision and continues to promote unrealistic proposals for housing development at the expense of convenient car parking and the retail viability of the Town Centre.
The Infrastructure section of the draft Plan, and the draft Infrastructure Delivery Plan are inadequate and do not demonstrate that the required infrastructure is known in sufficient detail and will be provided when required. The Council will be aware that the provision of additional health facilities is a major concern, but currently contributions towards the provision of additional health facilities are not included in the Community Infrastructure Levy Regulation 123 list. The draft Infrastructure Delivery Plan, in Table 7, also refers to CIL funding for several other categories of infrastructure that are not currently included in the Regulation 123 list, for example fire station re-provision and library provision.
The Regulation 123 list should be updated urgently to incorporate contributions towards the provision of additional facilities, particularly health facilities, as a matter of urgency, using the formula set out in the Fareham and Gosport Clinical Commissioning Group response set out in the draft Infrastructure Delivery Plan.
The approach to consultation, with no Issues and Options stage and not publishing evidence when available, but waiting until publication of the plan is contrary to the Planning Policy Guidance. This has resulted in people being faced with a vast quantity of evidence to read and understand at the same time as reading the plan and preparing informed comments. It has also resulted in the publication of a plan with too little flexibility and with no significant scope to delete sites in the light of consultation responses without resulting in land supply problems and the need to carry out further consultation on replacement sites.
The Council should have followed the same procedure with the new Draft Local Plan as it did with the existing Local Plan Part 2. If it had, and had published the evidence as soon as it was available rather than at the same time, local residents and communities would have all the information they need to express their preferences before the draft plan is published. For example, the Landscape Assessment is dated August 2017 and should have been made available in August.
Welborne Background Paper
See comments under the draft Plan Strategy.
Two of the options included in the Sustainability Appraisal and referred to in the draft Local Plan are accepted by the Council as not realistic because they are based on build rates at Welborne that are most unlikely to be achieved, quite bizarrely the Council itself decided that its own ‘reasonable alternatives’ were not reasonable! (SA paragraph 4.4.7). Three further options are now irrelevant because of the Cranleigh Road appeal decision. Therefore, five of the eleven options that the Council devised for consideration in the Sustainability Appraisal and subsequently in the draft plan are now irrelevant!
The Detailed Assessment Matrices do not include all of the allocated sites, for example Romsey Avenue is not included. The matrices do not include the sites that are identified as developable but not preferred, however the Housing Site Selection report includes references to the outcome of the
Sustainability Appraisal for these sites. The detailed assessment of these sites should have been included in the published Sustainability Appraisal’s Detailed Assessment Matrices.
A more relevant Sustainability Appraisal, including all of the reasonable alternatives that have been considered in preparation of the plan, will need to be prepared for the next version of the plan.
Infrastructure Delivery Plan
The draft Infrastructure Delivery Plan does not provide sufficiently detailed information to enable a proper understanding of the impact of the development of the individual site allocations.
The Transport Assessment, in paragraphs 4.3.1-4.3.3 states that a run of the sub-regional model undertaken by PUSH taking account of all committed developments and transport infrastructure interventions to 2036 in the region provides the baseline against which the incremental traffic impacts of the proposed site allocations can be compared. It does not do this because Welborne is not included in the 2036 baseline.
The interim Transport Assessment therefore does not do what it states in the introduction. It does not consider the potential transport related impacts of the proposed land allocations in the emerging Local Plan; it considers the impact of the proposed allocations together with the allocations at Welborne.
The Transport Assessment also states that the Welborne M27 all movements Junction 10 is included in the model. It is not included in any of the of the figures in the Transport Assessment.
As the Transport Assessment does not identify separately the traffic impacts of the site allocations included in the draft Plan, but adds in the impact of Welborne it cannot be considered to be sound.
Irrespective of the fact that the Transport Assessment is unsound and does not do what it states, the figures included raise other issues. Many of the figures do not include Portchester and Stubbington/Hill Head which will be significantly affected by the proposed developments at Romsey Avenue, Downend Road and Daedalus.
The poor quality of the figures obscures many of the numbers and its diagrammatic nature, in parts, confuses the picture. For example, Figs 6-7 and 6-8 appear to show a new road from Dibles Road to Hook Lane/Little Abshot Road. Presumable this is meant to be the route along Fleet End Road and Hook Lane through Hook village.
There is insufficient information to enable comparisons of actual flows of traffic, for example there should be actual flow figures for the 2015 base so that comparison can be made with the 2036 actual flows shown in figures 6.1 and 6.2.
In the light of the daily experience of traffic at a standstill the Society would expect paragraph 3.1.2 to include congestion off M27 junctions 9 and 10 in the pm period as well as the am period.
There are many changes if the actual flows and volume/capacity rates that appear to be inexplicable even accepting that the Transport Assessment does not identify the impacts of only the sites allocated in the draft Plan. Future Transport Assessments must contain sufficient information and explanations for what the modelling outputs show.
The statement in paragraph 6.2.3, copied below, is totally inadequate to explain the output of the assessment.
“These indicate that there is forecast to be a general increase in traffic on most links during both the AM and PM peak hours, especially on the A27 between Fareham and the M27. However, there is a reduction of traffic on the M27 during the AM peak hour. This is likely to be because of additional traffic congestion at junctions with the motorway that restricts access to it and causes traffic to divert on to alternative roads to avoid the traffic congestion.”
Can it be possible that the impacts of development on the allocated sites is sufficient to cause such severe additional congestion on the M27 that will result in traffic diverting to alternative routes that are also already congested and which will become more congested because of the development of the allocated sites?
There are many other examples where improved clarity is required, for example paragraph 6.2.7 refers to ‘a reduction on Wickham Road during both peak hours’. The data shows that there is a reduction on Wickham Road north of the M27, but there is a significant increase in traffic on Wickham Road south of the M27.
Housing Site Selection
Paragraph 1.3 states that ‘This paper is intended to increase transparency in how complex evidence base documents and planning considerations have been used in establishing the preferred approach to housing site allocation. It is not intended to provide a detailed overview or assessment of individual sites.’ However, the ‘broad site summaries’ do not include sufficient information to make the choices made transparent.
It is not clear how the Site Selection Priorities/Refining Points; have been used. In many cases the summaries for sites that have been selected are almost identical to those that have not been selected. It would help if a table for each site showing how the ‘score’ against each priority/point is included.
There is a particular difficulty with point 7 relating to highway impacts because there is no reference to the Interim Transport Assessment in the list of evidence, however many of the assessments refer to ‘minimal highway works required’ or other highway issues. How has point 7 been used and what evidence lies behind the comments?
In some cases, point 10 ‘to provide and maintain a defensible urban edge following development’ does not appear to have been used. In relation to Site HA10 Funtley Road South, the ‘view corridors’ are totally inadequate to maintain views that properly recognise the site’s landscape context.
In relation to Site HA8, Pinks Hill, what is the evidence for saying that ‘noise and other associated amenity issues due to A27/M27 can be mitigated?
The Society is uncomfortable with allocating sites for housing that are excessively noisy or have their primary access through an industrial estate or narrow residential roads.
Settlement Boundary Review
The Settlement Boundary Review should have also considered the effect of the proposals for increases in the amount of employment development at Daedalus. It is wholly inappropriate to continue to include the Daedalus employment areas as outside the urban area and as part of the Strategic Gap. This is recognised in the Landscape Assessment which, on page 136, states:
“The area for assessment also excludes the Daedalus Airfield Strategic Development Allocation at the southern end of the area, which will effectively lie within the urban settlement boundary following proposed future redevelopment.”
The publication of the draft Plan with specific allocations and statements that ‘planning permission will be granted should have followed an earlier consultation on the potential sites. The absence of this has made it impossible for people to suggest alternative sites based on sound evidence, and the marginal land supply would require a further consultation stage if any sites are to be deleted. There are too many examples of insufficient, inadequate or unsound evidence which would render the plan unsound at examination unless significant Improvements are made before the submission stage.
B.M. Clapperton MBE