The Fareham Society response to the
Strategic Development Area (SDA) Scoping Report, July 2009
"The Scoping Report was prepared for Fareham Borough Council (FBC) as part of the Sustainability Appraisal (SA) of the North of Fareham Strategic Development Area (SDA) Area Action Plan (AAP). ...
Scoping is the process of deciding the scope and level of detail of an SA, including the environmental effects, the assessment methods to be used, and the structure and contents of the SA Report. Documenting this process, the Scoping Report sets out the scope of, and methodology for the SA of the AAP and summarises the tasks and outcomes of the first stage of the SA process."
The above was taken from Section 1.1 of the FBC Report. Many such reports on Welborn can be downloaded the FBC web-site by clicking here.
The Society responded promptly by letter, the text of which is reproduced below. Comments inserted in italics in square brackets quote the most relevant extracts from the FBC Report and are included so that the reader can obtain a better understanding of the Society's remarks in the correct context.
The Society's response by letter
"Society Membership just under 1,000
The Fareham Society
12 High Street
Hampshire PO16 7BL
Telephone: 01329 280526
10 August 2009
Department for Planning Policy
Fareham Borough Council
Fareham, PO16 7AZ
Sustainability Appraisal of Area Action Plan for the North of Fareham SDA Scoping Report
The Society has carefully studied the above report which in so many ways confirms and clarifies many of the Society's concerns and difficult issues raised throughout the consultation period for the SDA.
It is absolutely essential that potential problems are researched in great detail and nothing "left to chance". Although, on the whole, this is a very comprehensive document there are data and factual omissions, which arise when consultants do not always know the area they are reporting on.
The Society's responses are following a page-by-page order.
page 17: Refers to policies on the best and most versatile agricultural land (1, 2, 3A).
["National planning policy states that the best and most versatile agricultural land (defined as land in grades 1, 2 and 3a of the Agricultural Land Classification) should be considered through the planning process. It also states that where significant development of agricultural land is unavoidable, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality, 'except where this would be inconsistent with other sustainability considerations.'"]
The Society has referred to areas of high quality agricultural land in previous responses centred towards the northern area of the area of search, or more accurately on the western side of the A32. This is a topic that has not been raised in evidence studies to date.
page 21: Accessibility and Transport
["These road, rail and air links however mask significant potential accessibility issues for the SDA. As a greenfield site, cut off from the rest of the built up area of the Borough by the M27, walking and cycling routes are currently limited, and existing local public transport services (including bus routes 69, 93 and 95) are unlikely to be adequate for the needs of the SDA. Congestion on the local road network, particularly around Junctions 10 and 11 of the M27, is also a major issue, and one which is likely to increase as the SDA is brought into use. This places further constraints on accessibility from the SDA."]
The baseline position underlines one of the most difficult and major issues arising from the location of the SDA and its sustainability and proposed size. This is exacerbated by an already acknowledged congestion problem in the borough, particularly severe at many key roads and junctions.
Without major financial public transport investment, the SDA's accessibility will be unsustainable and unable to adequately serve the needs of those particularly without cars. A development of the proposed size of the SDA will put extreme pressures on the nearest communities and urban areas in North, Central and East Fareham and the villages of Wickham and Knowle.
The transport pressures, if not efficient, subsidized and resourced will create huge future problems and result in the downgrading of the whole area and not satisfy the needs of the new community. No matter how well planned an area is on the ground, if adequate resources are not available to fund the services and infrastructure required from commencement of the development enormous problems will arise. Examples of this were seen at Greenhithe.
The SDA to all intents and purposes is an urban extension to the borough, "a Greenfield site cut off from the rest of the built up area of the Borough by the M27", to quote para.4 on p.21.
Information on table 4.2 dated 2001 and no data trends available.
page 24: Air Quality
["Existing air quality in the SDA is dominated by the road network, and in particular is affected by the proximity of the M27 motorway to the site. ...
Following an Updating and Screening Assessment in 2003, which indicated that the level of air pollutants were within specified limits, an air quality progress report was submitted to DEFRA in May 2004. This report utilised results from an extended nitrogen dioxide (NO2) survey in the Borough using an increase number of monitoring sites. This report suggested that readings for NO2 at some locations may exceed the National Air Quality Objective. Subsequently, after further monitoring, an Air Quality Management Area (AQMA) was declared for NO2 for a section of Gosport Road in Fareham in July 2006, and in December 2007 for Portland Street in Fareham. Both of these designations are due to emissions from transport. As part of the AQMA designation, continuous monitoring is being undertaken at these locations.
Whilst these AQMAs are not located adjacent or near to the SDA, the SDA has the potential to have impacts on air quality across the Borough, including the town centre, where the AQMAs are located. This is acknowledged by the Air Quality Action Plans developed for the AQMA, which suggest that the SDA has the potential to add to Fareham town’s congestion problems."]
Like all reports where official data is quoted these tend to be out-of-date. The SDA is not well situated; as quoted it is "dominated by road network". This fact has been emphasized by all sustainability studies including the government's own for the South East Plan, which did not recommend the location of the SDA for an SDA. However, this, it was said, could be overcome by mitigation measures!
There will obviously be a significant knock-on effect from the increased traffic, from the SDA on the town centre, roads leading to it and the areas of AQMA.
Appendix D7 indicates that "significant areas of open space" will be required to mitigate any effects from pollution. This will reduce the area of land available for housing and industry, etcetera.
page 33: Biodiversity and Geodiversity
["There is one National Nature Reserve (NNR) in the Borough, and two Local Nature Reserves (LNR). ...
Key issues and challenges:
— Potential effects on European designated nature conservation sites including from: strain on water resources; air pollution; waste water pollution; disturbance from recreation;and loss of supporting habitats. Similar effects on other nationally and locally designated sites.
— Potential effects on Botley Wood and Everett's and Mushes Copses SSSI, the condition of which is currently "unfavourable recovering".
— Potential impacts on BAP (Biodiversity Action Plan) habitats and species from new development."]
The Society considers that some indication of the proximity of the quite recently confirmed South Downs National Park should be included in this section of the report, particularly as it is usual to have a form of "cordon sanitaire" around National Parks. As this will have an A.O.N.B. notation it should be on one of the maps - it will be closer to the north of the SDA than some of the sites referred to in the survey and falls within 10 kilometres of the SDA.
The key issues and challenges (4.5.3) which are of significance, due to the proposed size of the SDA and its knock on effect on the surrounding countryside, water courses, particularly with further pressure for recreation.
page 59: Historic Environment and Landscape
["The features designated for their historic environment importance within the SDA are as follows: — Boundary Oaks School, Roche Court (Grade II listed building) — Lodge at Boundary Oaks School, Roche Court (Grade II listed builiding)"]
Historic Buildings within the SDA Area of Search omitted from this Report are Dean Farmhouse - Grade II*; North Fareham Farmhouse - Grade II; Greenhill Cottage, Spurlings Lane - Grade II; Down Barn Farmhouse - Grade II; Down Barn Cottage - Grade II, both in Boarhunt Road. The latter four are close to the proposed diversion of the A32 leading to Junction 11 and their settings cannot be ignored in this appraisal. The issue of the environment and setting of Portsdown Hill and the area east of the A32 is highlighted in pages 56, 57, 59 - this is extremely important. As traffic pressures have built up over recent years the country lanes and the Portsdown Hill Road have been increasingly used as "escape routes" by those trying to avoid congestion on the M27 and A27.
It should also be emphasized that the land in the SDA Area of Search and indeed the SDA has been given over almost entirely to continuous arable cultivation for centuries and this ties in with the comments made on quality farmland designation.
These should be mapped.
The sensitivity of the land to the east of the A32 is emphasized in this report.
page 68: Water
["The SDA is situated within the catchment areas of two rivers, the River Meon and the Wallington River. ...
Both rivers are classed as ‘over-abstracted’ by the East Hampshire Catchment Abstraction Management Strategy (CAMS).
The Area of Search for the North of Fareham SDA is located above a major intermediate aquifer. Parts of the aquifer have been identified as a groundwater Source Protection Zone, where the risk of contamination from any activities in the area that may cause water pollution is monitored. The Area of Search is also within a Nitrate Vulnerable Zone.
Borough-wide, chemical water quality has been fluctuating since the 1990s. In 2006 seven percent of rivers were classed as of ‘poor’ chemical quality, and 48% were deemed to be of ‘fair’ quality. Alongside, only 45% of waterways were deemed to be of ‘good’ chemical water quality, which is significantly less than for the South East and England. Similarly Fareham’s biological water quality has been fluctuating since 1990, and has seen an overall decline. Only 39% of rivers were classed as good quality in 2006 and this is significantly below regional and England averages, where rivers determined to be of ‘good’ biological quality represent 77% and 65% of the total respectively. Significant improvements in the Borough are therefore required to meet the target of all watercourses to reach ‘good’ biological and chemical water quality status by 2015, as required by the Water Framework Directive."]
This section of the Report highlights the work required to make significant improvements in the biological and chemical water quality by 2015 in the Borough as required by the Water Framework Directive.
Both the Rivers Meon and Wallington are over abstracted.
The table on page 71, no.4.14.3, indicates significant problems with potential increase in flood risk downstream at North Wallington and Titchfleld, both facts highlighted by the Society in previous responses to consultation documents.
The flood plain map is inadequate as it does not demonstrate clearly enough the extent of the flood plain in the south-east corner of the SDA Area of Search. The Capacity Analysis Study, 8.1.09, indicated "that SUDS requirements had not been taken into full account as not known at present". What is the present situation?
The major intermediate aquifer area, groundwater source protection zone and nitrate vulnerable zone referred to in Para.69, should be mapped along with the flood risk information to clearly illustrate the situation.
The issue of contamination and flooding is a subject of paramount importance for the whole borough as well as a potential SDA.
Where is the subject of waste water treatment dealt with? This was quite a major issue at the South East Plan Inquiry at Chichester.
The standards to be reached under various European Directives by 2016 were not clear, particularly on water quality and the effect of waste-water problems on the Solent SPA. It became clear there were significant shortfalls in the west of the South Hampshire areas, which may have to be solved looking eastwards to the Portsmouth/Fareham area - is this Peel Common?
The Agent for Southern Water told the Panel he could not give them assurances or a great deal of detailed information as many of the potential outcomes were unknown.
An additional issue not yet raised by the Society is that of health. Statistics show the general health of the Borough as being good, by local and national standards. However, in planning the SDA, how helpful are past statistics, particularly if there is to be quite a high percentage of in-migration. Surely the availability of services, i.e., hospital capacity, general medical services, etcetera, are details that should be known at a very early stage.
The satisfactory solution of many of the major issues raised in this report will influence the future size and viability of the proposed SDA.
The Society's already voiced concerns remain.
Brenda Clapperton, MBE (Mrs)
Hon. Secretary: The Fareham Society
Registered Charity No. 271344"