DLP - 25th Feb

The Fareham Society

Gayle Wootton
Planning Strategy Manager
Fareham Borough Council
Civic Offices
Civic Way
Fareham, PO16 7AZ


Dear Madam,


Observations of the Fareham Society on the Fareham Local Plan 2036 – Supplement (LPS)

Thank you for the opportunity of commenting on the above. This letter contains a bullet point summary of the observations of the Fareham Society and an appendix containing the detailed observations from which the summary is derived.


Summary


• There are two substantial concerns on the identification of the Strategic Growth Areas (SGAs).


First, on the rationale behind them. Here there are two issues:


a) SGAs are not the correct way to provide a contingency buffer should allocated sites fail to deliver housing on time. However, there is a suggestion in the LPS, which needs clarification, that they may in part be for this purpose.
b) On the use of SGAs in meeting the unmet need from other local Councils. Planning for South Hampshire (PfSH) is working on how these needs could be distributed in other Council areas. However, until this work is complete, which could well be some considerable time off, the identification of SGAs is premature. And there is no indication on how there will be public consultation on the findings.


Second, there is substantial concern on the land identified as SGAs. The first SGA is North of Downend on both sides of Downend Road. Development on both sides would, given the findings of the Council’s latest Landscape survey, harm the character and appearance of the area. This would be the most pronounced in development on the western side of the road which would intrude substantially into the lower slopes of Portsdown Hill. Finally, the

proposed means of access for both areas needs clarification to ensure that a satisfactory and affordable solution could be found. The Society would not wish to see the situation, as at Welborne, where legitimate concerns on highway impacts remain unaddressed and access costs have led to a reduction in affordable and Passivhaus housing. The second SGA occupies most of the Strategic Gap between Fareham and Stubbington. There is no statement on the scale of development envisaged which makes comment difficult. That said, the Policy wording is suggestive of substantial development. The retention of the Strategic Gap has long been seen as essential in preventing urban sprawl and the merging of Fareham with Stubbington, and past surveys indicate that it would not serve its purpose if other than very limited development within it occurs. The development at Welborne was promoted as a means of protecting the Gap and it remains the firm view of this Society that there should be no development in it that would adversely affect its function in providing for the separation of settlements.

Given the above the Society opposes the identification of the two SGAs.


• With a minor caveat on the amount of housing that could be accommodated, due to on-site constraints and noise issues from the adjoining M27, the Rookery Farm site is a suitable housing allocation. The housing allocation at 1-2 The Avenue, Fareham has some merit, subject to noise and air quality issues being addressed. However, there is some concern on the loss of employment land close to the town centre.

• The allocation of land south of Cams Alders is unacceptable. Although it would provide development in a sustainable location it would harm the pleasant wooded character of this part of the Cams Alders open space and be inappropriate given that most of the site is of importance for nature conservation. The allocation at 20 Botley Road, Park Gate is sustainably located, and in an area potentially suitable for increased densities especially on amalgamated sites. However, development of this site in isolation could harm the character and appearance of the area and neighbours’ living conditions.


• The Policy supporting Small-Scale Housing Development Outside Defined Urban Areas is a cause for concern. It could lead to many speculative proposals that, even with the Policy’s caveats, would be difficult to resist. Thus, giving rise to sporadic development cumulatively harmful to the Borough’s rural areas.


• The Policy on High Quality Homes – Space Standards is welcomed.


• The Landscape Policy on Areas of Special Landscape Quality (ASLQ) is welcomed with the following caveats. First, it should be strengthened to prohibit anything but small-scale development such as stables. Second, the ASLQ map should be revised to show as ASLQ, a) the entirety of the recent Posbrook Lane appeal site (APP/A1720/W/18/3199119); and b) the whole of the Wallington Valley north of the M27 and not just the eastern side.


• To be effective The Climate Change Policy needs to specify the standards sought.


• The Policy on Trees, Woodland and Hedgerows is welcomed. However, there should also be additional protection of valuable habitats such as SINCs.


• The Air Quality Policy is welcomed, but there should be a reference to the legal UK limits and the safe levels set by the World Health Organisation, and how air quality is to be monitored.


• The relationship of the report on SRTM modelling to the Local Plan Supplement is not clear, but the modelling does give cause for concern on highway impacts.


Final Observations


There are some things to be welcomed in the Supplement, which we have identified, and there are concerns on some of the housing allocations. However, the key concern of the Society is the identification of the two SGAs For all the reasons set out above it is considered that if they go ahead it would be of substantial detriment to the Borough and run counter to long held environmental protections.


Yours sincerely,

B.M. Clapperton

(Mrs) B.M. Clapperton MBE
Hon. Secretary
The Fareham Society