The Fareham Society's Response to FBC's Local Plan Part 2
26th November 2012
The Fareham Society wishes to submit the following comments on the Fareham Local Plan Part 2, the Sustainability Appraisal and the Retail Study (2012).
Settlement Boundaries and Strategic Gaps
Paragraphs 3.2 to 3.6 refer to 'Urban Area', 'Defined Urban Settlement Boundaries' and 'Settlement Boundaries'; to avoid confusion only one term should be used. The meaning of para 3.5 is unclear; is it intended to refer to the inclusion of allocations for new development within the defined boundaries? If there are to be both Urban Area and Defined Urban Settlement Boundaries the latter should be shown on the Proposals Map.
Fareham Town Centre
Para 5.5 refers to the 2009 retail study not to the 2012 study. The latter states in para 6.49, in relation to comparison goods floorspace, that 'based on current market shares, we estimate that there would be theoretical capacity to support an additional 15,280 sq m net by 2027. In paragraph 7.41 the 2012 study recommends "against large scale physical expansion" in Fareham town centre. This is not reflected in the local plan which in paragraph 5.5 refers to accommodating between 10,000 and 24,000 sq m of net additional floorspace by 2026. The TC policies included in the draft plan could result in large scale physical expansion contrary to the advice in the latest retail study.
Policies TC9-TC11. The Town Centre schemes seem to be very ambitious, what is the likelihood that the sites will be developed in the lifetime of the plan? The Society considers that there is a significant danger that if pursued in haste in constrained economic times, poor quality schemes will result. Economics eventually led the selection of what was not the best scheme for Market Quay; this resulted in poor architectural and design quality including materials and other detailing. For example, long distance views of the badly designed and executed rear elevation as seen from the Lower Quay and Salterns area. It appears that views from the waterside are not considered whereas those towards the water are.
Para 5.33 should refer to the 'listed' railway viaducts.
Para 5.35, the wording of the last sentence should be altered to 'include the museum with its coffee area and shop and the tourist information centre' (for accuracy).
Para 5.36. The Society disagrees that Westbury Manor would benefit from an alternative use and that other uses would make better use of its assets. The Museum is a public building to be enjoyed by residents and visitors. The fabric of the building is not subject to the sort of pressure that can occur with pubs or restaurants sometimes associated with town centre uses. Westbury Manor is a small elegant building of residential proportions and situated on quite a vulnerable site. The Museum use has been most appropriate for the building over many years; it is situated in the heart of West Street and centrally located to serve the whole borough whose history is reflected in the Museum. Catering establishments are so often short term uses and can often be unoccupied for long periods. The Museum and the Tourist Information Centre function well together. The statement that "the existing uses are not intensively used, reflected by the fact that the building is shut on Sundays and Mondays each week" is misleading. The Library, Civic Offices and some other facilities like offices and the medical centre are not open on Sundays which is not mentioned in the text. It should also be made clear that none of the museums in Hampshire are open on Mondays due to current economic circumstances; this is unlikely to be a permanent arrangement.
Westbury Manor is at a focal point in the town centre and features well in local festivals and celebrations. Its current uses display the local history of the area and also serve educational needs. It advertises local facilities to local residents and short and long stay visitors in an easily accessible location.
Policy TC8, Westbury Manor, the final sentence should state that "Uses which do not provide an active frontage, such as residential or office space will not be permitted": the plans text must be a mistake.
The Civic Area, Market Quay and the Shopping Centre
Paragraphs 5.43-5.66. The Civic area functions very well with its present cluster of uses, but would be improved if permeability can be achieved through to West Street to assist safer and convenient access to Ferneham Hall in the evenings. An arcaded glazed walkway through the shopping centre was suggested by the Fareham Society in the 1970s Town Centre Inquiry, where the disadvantages of the long east-west barrier formed by the shopping centre were well discussed.
In relation to Policies TC9, C10 and TC11 it is considered that an arcaded walkway through the shopping centre should be a priority. The Society seriously suggests that the clumping together of most of the public buildings on the Market Quay site could be counter productive. Having a more even spread of facilities in the relatively small area of the central town centre allows for a wider area of footfall benefitting all the shops both north and south of West Street, the new arcade taking the main flow, but of course keeping the other existing entrances to the shopping centre.
The present Market Quay site is not large enough to adequately accommodate a replacement library of a similar floorspace, a suitable replacement for Ferneham Hall, a Museum/Arts Centre of comparable size to the existing facilities, generous parking to serve an entertainments venue including the cinema and open space.
The list of principal uses seems to be totally unrealistic even excluding the additional uses that will be sought if they can be delivered. A reference to a library and entertainment/arts should be included in Policy TC9 Civic Area and the reference to library should be deleted from Policy TC10 Market Quay. There are advantages in having a venue for civic functions close to the Civic Offices.
Shopping in the rest of the Borough
Policy DS3 states that expansion of Portchester District Centre will be permitted but there is no explanation for the very significant expansion of the centre shown on the Proposals Map.
Transport and Access
Transport policy T6, New Community North of Fareham, is listed on Page 54 and was assessed in the Sustainability Appraisal, Appendix 4 page 4/6. What did this policy say and what has happened to the policy?
Para 7.6 the BRT Future Phases study should be available now to enable informed responses to be made to policy T1 and the text relating to BRT.
Para 7.7, states that "this critical east to west transport corridor" "acts as a bottleneck to many north to south travel movements on the peninsula". The north-south transport movements generally impede the east-west transport corridor. What evidence has been used to demonstrate that The Avenue acts as a bottleneck to many north to south travel movements on the peninsula and that justifies the dualling proposed? Para 7.12 and change to Proposals Map A79 propose the dualling of the A27; The Society believes that there is insufficient space for highway improvements at the Avenue primarily due to the presence of two important listed buildings; it is assumed that the policy and notation indicate that land outside the highway boundary is required. The Sustainability Appraisal assessment of policy T2, in Appendix lll of the SA, should include a negative impact in relation to SA Objective 2, to conserve and enhance built and cultural heritage.
Para 7.14 refers to HCC's longer term aspirations for the Gosport-Fareham Link Road and the Western Access to Gosport. If there is any prospect of these being implemented in the period to 2026 more details of the schemes should be included in the text and preferably options shown on the Proposals Map. If there is no prospect of them being implemented in the period to 2026 the references should be deleted because they introduce a significant uncertainty and are not helpful to planning. This is illustrated by the many comments on the Solar Farm application referring to the Stubbington by-pass.
Policy T4 appears to conflict with the current 'consultation' on the use of Yew Tree Drive.
Para 8.3 refers to the updated South Hampshire Strategy. This updated Strategy has not been subject to public consultation or independent scrutiny/examination and therefore cannot require the Borough Council to deliver a particular amount of housing through the Local Plan.
Para 9.2 refers to the preparation of a Design Supplementary Planning Document. The Society seeks confirmation that this will include Guidance for shop fronts.
Heritage and Conservation
Page 148, the Roche Court site should be added to the list of Historic Parks and Garden; the completed research produced by Hampshire County Council and the Hampshire Gardens Trust is available.
Policy C1 needs to be rewritten or the first two sentences deleted.
Policy C2 needs to clarify that the type of leisure and recreation that may be permitted are those that require a countryside location and do not involve the building of large structures. It should state that development will be strictly controlled.
Para 13.4 should refer to the area north of the M27 at Fareham as it provides opportunities for informal countryside recreation for a large proportion of the local population.
Policy BD1, how will enhancements 'be supported', by land or financial contributions from FBC?
Changes to the Proposals Map
Changes to the Proposals Map A19 and A114, appear to be inconsistent in proposing overlapping notations for the Locks Heath Centre extension and a SINC. The Locks Heath Centre extension notation should be removed from the area of the SINC.
Comments on the Sustainability Appraisal
The site options assessment should include a table of the assessment of all of the alternative sites considered as well as the sites that are now included in the Local Plan Part 2. It should properly record how the 61 shortlisted sites mentioned in para 1.2.4, were reduced to the shortlist of 34 to demonstrate that the decisions made have been informed by the SA process and how the assessment 'scores' have been used to determine which sites should be included in the reduced list and which have not.
The SA in paragraph 4.2.1 concludes that many of the sites have significant adverse impacts or unknown impacts on the sustainability objectives and states that these will require further detailed assessment. However, the draft plan relies on all of these sites to meet its housing and employment targets; what alternatives will be considered as potentially more sustainable sites?
The assessment of policy T2, widening of the A27, in Appendix lll should include a negative impact in relation to SA Objective 2.
What Policy T6 was assessed in Appendix 4? (See also comments on the Local Plan Part 2).
What transport evidence has been used to inform the site assessments and are copies of this available?
Comments on the Retail Study
The 'trendline' population projections used are totally inadequate as they do not relate to future house building. This is demonstrated by the forecast increase of only 684 for zone 8 which includes the NCNF and the increase of almost 12,000 in zones 3 and 4, Gosport in comparison with the HCC forecast of a reduction in Gosport's population of over 2,500 between 2011 and 2026. Is the NCNF not included in the forecasts in this document?