Comments on the Draft Welborne Plan
(Submitted 9th June 2013)
The Society has objected to the proposed SDA/New Community/Welborne since it was first proposed because it believes that far too much development was being proposed in the wrong location with an inevitable harmful impact on the environment and quality of life of the residents of Wickham and North Fareham.
The Draft Welborne Plan reinforces the Society’s objections because over and over again significant problems result from the very poor location of the development that cannot be fully overcome by more detailed policies in the draft plan. Examples of these problems include the insurmountable traffic impact because of the location adjoining motorway junctions, severance by the A32 if development takes place both to the east and west, the loss of a large area of the best and most versatile agricultural land and the practicality and viability of dealing with waste water.
The totally unrealistic proposals originally put forward, particularly in relation to the scale of the development and the timescale, have been significantly revised as the difficulties and constraints of the location have gradually been recognised. The Society welcomes the reductions that have been made to the scale of the development since the initial proposals were made, but believes that further reductions in scale and density may be necessary to fully recognise existing constraints and to reduce the remaining harmful impact on the environment and quality of life of local residents and future residents in Welborne.
The aspirations for the new settlement have changed over the years from a sustainable development, to an eco-town and now to garden city principles without a proper definition of what this means. Unfortunately the aspirations for a highly sustainable ‘exemplar’ development have been abandoned as viability has been given precedence over sustainability. This is particularly evident in the way that the findings of the Sustainability Appraisal have been largely ignored in relation to many of the most fundamental parts of the draft plan. Too much weight has been given to the early viability at the expense of longer term sustainability.
The Society has objections to the policies and paragraphs as set out:
Paragraphs 2.4 and 2.8 which change the aspirations for ‘a high level of self containment’ to ‘will encourage self containment’. The location and phasing of the district centre, the employment to the east of the A32 and the secondary school will undermine the aspiration to achieve a high level of ‘self-containment’. Better locations for these facilities would enable a higher level of self containment.
Paragraphs 2.14-2.16 and Policy WEL2 because they are confused and do not properly describe what is meant by ‘New Garden Community’ or ‘21st Century Garden City’. How would differ from any other proposed large scale development.
Additional Development Principles
WEL2 in relation to the clustering of education provision to the east of the A32, see below.
Paragraph 3.15 final sentence, the reference to ‘assumed that it will be possible’ should be deleted and replaced by ‘to ensure that it will be possible’.
Allocation of Land
WEL3 in relation to allocation of land east of the A32 for the Secondary School and one primary school, see below.
Employment Area East of A32
Policy WEL9 in relation to the location of the ‘campus’ employment area to the east of the A32 which is in a visually prominent location, divorced from the residential areas. Its location means that it cannot be integrated with Welborne (paragraph 4.14) and it will therefore result in increased traffic congestion.
The site is not suitable for large B2 or B8 buildings because of its prominence and proximity to the collection of listed buildings Roche Court and North Fareham Farm. The scale of the changes to the Pook Lane/A32 junction to accommodate freight movements (paragraph 5.20) will have a significant harmful impact on Roche Court, its Gate Lodge and historic parkland. No account either appears to have been taken of the high pressure gas main (paragraph 3.7) or the ground water source protection zone on the Concept Masterplan.
Employment to the east of the A32 will undermine the principle of co-location referred to in paragraph 5.2. All employment should be located to the west of the A32 making use of the parts of the site most affected by noise which are not suitable for the housing which is currently proposed.
Policy WEL10 because the location and phasing of the district centre will result in an out of town shopping ’destination’ not a true district centre. The district centre should be located towards the centre of the site; the location which the Sustainability Appraisal demonstrates is by far the most sustainable. The other locations are significantly less sustainable than the central location contrary to the statements in the Masterplan Options: Summary of Evaluation (page 168).
The retail impact assessment is required before the scale and location of the district centre is determined in the draft plan, it cannot be left until the planning application stage.
Policy WEL14 in relation to the primary school proposed to the east of the A32 with its requirement for a bridge and at level crossing because it is not a sustainable location for a primary school.
Policy WEL15 because the location to the east of the A32 has not been justified and conflicts with the findings of the Sustainability Appraisal. The need for a pedestrian and cycle bridge and an 'at-grade' crossing on the A32 demonstrate the total unsuitability of this location.
The secondary school should be located near Funtley; the location which the Sustainability Appraisal demonstrates is by far the most sustainable, or slightly further to the north nearer to Knowle as also considered favourably in the Sustainability Appraisal.
There is a significant conflict between paragraphs 5.67 and 5.72. If the secondary school is not needed until 2028, there is no justification for the statement that “the location allocated ensures that the secondary school can be commenced during the early phases”.
The almost total absence of evidence currently available that supports the transport proposals. It is evident from paragraph 6.16 that the Highways Agency and Highway Authority have not yet given their support to the policies in the draft plan.
Paragraph 6.2; the Highways Agency did not “broadly support the Emerging Transport Strategy”; they were put in a very difficult position at the public examination of the Core Strategy.
Paragraph 6.8; there was no evidence to demonstrate that there was a transport solution for the scheme. At the time of the preparation of the Core Strategy and the public examination ‘it was all to come’.
Policies WEL 16 and 17 because they are not supported by a transport assessment that demonstrates that there will not be significant harm to local residents. In particular the Society objects to the creation of an all moves Junction 10 because this junction was specifically restricted to limited moves to avoid the harmful impact of the vast increase in traffic on local residents. The full transport assessment is needed now and cannot be delayed until the planning application stage (paragraph 6.28).
Paragraph 6.41 because Travel Plans can only demonstrate how more sustainable travel could be achieved. There is no mechanism for ensuring that sustainable travel will be achieved.
Green Infrastructure and Biodiversity
Paragraph 8.39 because it appears that only very limited improvements to existing routes are proposed which will in no way compensate existing residents for the loss of the existing access to the countryside which will be lost to development.
Policy WEL29; the GI proposed does not appear to include any areas of sufficient scale and attractiveness, particularly to dog walkers, to reduce coastal visits. The proposals could have an adverse impact on existing ancient woodland and SINCS. The policy should be revised to state ‘Proposals to develop all or part of Welborne, whether in full or outline, must be accompanied by a full green infrastructure network and management plan for the site as a whole to be agreed with the Borough Council before any part of the Welborne development commences.’
Policy WEL37 because it gives insufficient protection to the sites historic assets. It should be revised to state:
‘Development will be required to avoid or minimise conflict between the heritage assets conservation and any aspect of the proposal. It will take into account the:’
The change pages 155-156 from “fully mitigate any environmental or traffic impacts” to “minimise the traffic impacts on the local and strategic road network and mitigate any environmental impacts”.
The SA is inadequate because it deals with air quality issues within the NCNF only. It is essential that evidence is provided so that it also deals with air quality in relation to the residents of roads outside the NCNF where there will be significant increases in traffic including North Hill, Kiln Road, Highlands Road, Park Lane, Trinity Street and Wickham Road and through Wickham Village.
The SA does not appear to address the NPPF requirement to seek to use areas of poorer quality land in preference to that of higher quality.
The Society supports many of the other policies of the draft plan, in particular it supports:
WEL4, a comprehensive approach;
Wel5, settlement separation;
WEL8, the preparation of a Strategic Design Code;
WEL18, the principle of BRT, but would like to see more detail of the routes to be used to the south of the M27;
WEL20 Cycling and pedestrian linkages
WEL36, the requirement for detailed landscaping schemes;
Correction and changes requested
The Society requests that the following correction/changes are made.
Site and Setting
Paragraph 3.2 should refer to ‘park and go’ not ‘park and ride’ because it is entirely car based without any bus link.
Paragraph 3.16 should refer to Furzehall Farm, Uplands Lodge and The Potteries, Wickham Road.
Green Infrastructure and Biodiversity
Paragraph 8.24 should state that the land provided to meet the requirement for alternative natural greenspace must meet the guidance set out in Natural England’s ‘Guidelines for the creation of Suitable Alternative Natural Greenspace’.