Publication Welborne Plan: Fareham Society Comments


  This contents list does not form part of the document but is included to indicate its sections.



    Self-containment; phasing of houses and jobs

    Phasing Plan

    Employment Floorspace

    Employment Area East of A32

    Transport, Changes to [M27] Junction 10

    Transport, Junction 10 Preferred Option

    Transport, Evidence

    Transport Assessment

    Air Quality

    Waste Water

    Green Infrastructure/SANGs



    Housing East of the A32

    Clarification, corrections and minor changes requested



The Society has objected to the proposed SDA/New Community North of Fareham/Welborne since it was first proposed because it believes that far too much development is being proposed in the wrong location with an inevitable harmful impact on the environment and the quality of life of the residents of Wickham and North Fareham.

The Publication 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 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 Society believes that there are many issues of soundness that need to be considered at the examination. It is difficult to separate them into specific matters such as housing or employment because they are so interrelated, for example, the issue of traffic noise from the M27 and A32 has an impact on the location and capacity of housing and employment, the character of the development and its viability. Similarly the issue of viability is affected by the phasing of changes to Junction 10 because this has a very significant effect on the timing of the development of the employment areas.

Many of the soundness issues stem from the way in which the Welborne Plan has evolved from the first proposals for a Strategic Development area in this location made by the Partnership for Urban South Hampshire (PUSH) in the early 2000s. This evolution continues, with the Publication Plan differing significantly from the adopted Core Strategy proposals.

The Society is represented on the Standing Conference and supports its recommended changes to the Policies WEL3 Allocation of Land, WEL5 Maintaining Settlement Separation, WEL6 General Design Principles, WEL7 Strategic Design Codes, WEL15 Primary and Pre-School Provision, WEL16, Secondary School Provision, WEL39 Flooding and Sustainable Drainage Systems, and WEL41 Phasing and Delivery.

The Society also supports WEL32 Strategic Green Corridors and Connections and WEL 37, Water Efficiency, Supply and Disposal but subject to the network plan and the environmental assessment being developed and completed before the Welborne Plan is adopted.

The Society supports the intention of Standing Conference's recommendation relating to WEL24, but believes that a statement by HCC and FBC is not sufficient, a full transport assessment and proper consideration of the options, including sustainability appraisal, is required before the preferred option could be identified.

The Society invites the Inspector to find the aspects of the Plan described below to be unsound for the reasons set out. Where possible, The Society has recommended changes to the Plan, but in too many cases the reasons relate to the lack of robust evidence rather than specific policies.


The Stage 2 Viability Testing Report states in paragraph 1.41 that there is 'a significant overall scheme deficit using current forecast costs and values.' The reasons for this are set out as follows:

1.53 We consider that this principally relates to the onerous nature (capital cost and profile) of the current IDP, which at a cost of c. £47,000 (net of fees) per residential dwelling, we consider to be extremely onerous. In particular the IDP costs in the first ten years are significantly higher than the forecast receipts. Given these findings it is apparent that there are a number of areas where wider site viability could be significantly enhanced.

The original proposals for concentrating a significant proportion of South Hampshire's greenfield development into two SDAs was based on the belief, with limited evidence, that SDAs maximise the funding from Government and developers towards the cost of transport and other infrastructure, including affordable housing. The Viability Testing Report demonstrates the totally inadequate basis for this belief in the following paragraphs.

1.54 One of the key barriers facing the development market in the current financial environment is how to provide finance and funding for major new infrastructure on sites that require remediation, access or social and green infrastructure to thrive.

1.55 This is particularly acute in large new communities, such as the development proposed at Welborne, which is inhibited by significant up-front infrastructure costs that are common with a development of this type and scale.

The report refers to further work being carried out; presumably this will be available in time for the examination.

The report provides the following advice on how the Borough Council should seek to improve viability:

1.56 GVA Financial Consulting will be progressing with a review of infrastructure funding and delivery options in Q1 2014, wherein all avenues for infrastructure funding will be explored in an effort to aid viability and in particular to reduce peak cashflow requirements with a focus on the first ten years of development.

1.72 Based on the above analysis and in particular the prevailing viability constraints, we at this stage are minded to advise the Council to maximise the use of S106/S278 and reduce the role of CIL to a nominal or zero rate.

1.73 The fundamental issue of a lack of demonstrable viability under the presented 'baseline scenario' (i.e. when the development assumes all the IDP costs) means that the CIL 'route' would likely not stand up to scrutiny and public examination.

1.74 We also consider that, despite the increased flexibilities proposed in the drafted CIL (Amendment) Regulations 2014, that bespoke planning agreements and conditions that are agreed between the parties in each case provides for materially greater flexibility (as compared to CIL) - flexibility that is often crucial to the delivery of complex large strategic sites such as Welborne.

Put simply, the development is not currently viable using current forecast costs and values; therefore the consultant's advice is to further reduce the amount of infrastructure paid for by the development by using Section 106 agreements rather than CIL, and/or reducing the list of infrastructure to be delivered.

The finding that the development is not currently viable using current forecast costs and values means that the Plan cannot be sound. This should not be addressed by reducing the amount of infrastructure funded by the development. The current non-viability should be addressed by a fundamental review of the location, type and scale of development proposed. If it is decided that this is not possible, the viability must be addressed by revising the phasing of the housing in Chapter 10 so that it is better coordinated with the development of the employment and the funding of the necessary infrastructure is borne by a greater quantum of development in the early years of development. (see also self-containment and phasing section below).

Self-Containment; Phasing of housing and jobs

The relative phasing of the development of housing and jobs has a significant Impact on the aspirations for high level of self-containment and therefore on traffic generation.

The original PUSH intention, set out in its advice to the South East Regional Assembly in 2006, was that there would be 10,000 jobs to go with the 10,000 dwellings then proposed at the Fareham SDA (Welborne).

The PUSH South Hampshire Strategy 2012 shows that this intention has not materially changed; the background paper 'Employment floorspace and house building provision figures' states that:

2.2 'the intention that the scale and timing of employment development in the New Community North of Fareham should keep pace with housing development to maximise self containment and sustainability.'

The importance of providing jobs at the same time as housing is emphasised in the Welborne Employment Strategy (Wessex Economics November 2013) which states:

Wessex Economics would make the case that every effort should be made to ensure that jobs and homes are delivered in tandem, and that, if possible jobs are delivered in advance of homes. This will maximise the scope for self-containment.

The Society objected to the Draft Welborne Plan which changed the aspirations set out in the adopted Core Strategy from 'a high level of self containment' to 'will encourage self containment'. The phasing of the jobs proposed in the Publication Plan makes the position even worse; it is very unlikely that even a low level of self containment will be achieved. The provision of jobs now lags significantly behind the housing; page 7 of the Appendix to the Welborne Employment Strategy, shows that only 2,147 jobs are estimated to be provided in the employment areas by 2036 when 6,000 houses are phased to be completed (Table 1.1). It is recognised that there will also be people working at or from home, but the objective to encourage self containment has been completely undermined by the revised phasing of the employment areas.

There is no evidence that the likely significant reduction in self-containment and the resulting impact on commuting has been taken into account in the transport modelling.

The provision of the housing so far in advance of the employment will establish a pattern of out commuting for work which is unlikely to be reversed in the longer term. The resulting reduction in self-containment is so significant that the Society believes that the Publication Plan does not comply with Core Strategy CS13 which states:

the development will provide up to 90,750 sq.m of employment floorspace, in a range of employment opportunities which contribute to sub-regional economic development objectives and contribute towards creating a high level of self containment and accessibility to reduce the need for commuting;

It is also not in accordance with the first of the Welborne Employment Strategy's key principles set out in paragraph 5.2:

'Welborne should provide a range of jobs so that residents have the opportunity to work locally. This will support the principle of self-containment by minimising residents? need to travel between home and work.'

The Plan is therefore not sound and could only be made sound by significant revisions to the phasing of the housing or jobs set out in Chapter 10 to ensure that jobs are provided in step with housing.

Phasing Plan

The Society believes that the phasing plan needs to be revised significantly to address the imbalance in the phasing of jobs and housing set out above and other issues such as the need for the earlier provision of the first primary school. The main foodstore should also be provided earlier rather than not being provided before potentially 1,500 dwellings have been completed.

The Plan is therefore not sound and could only be made sound by significant revisions to the phasing plan.

Employment Floorspace

In addition to the significant delay in the provision of the employment areas, the type of floorspace proposed has changed significantly. The original PUSH proposals for the SDA (Welborne) were for 60% B1 floorspace and 27% B8.

The PUSH South Hampshire Strategy 2012 background paper 'Employment floorspace and house building provision figures' refers to the New Community North of Fareham accommodating 34,000sqm of offices (B1a) and 34,000 sqm of manufacturing and distribution (B1b and B8).

The current proposals are for 41% B8 and only 25% offices; this will have a significant effect on the amount of employment, the character of Welborne, particularly when viewed from the M27, and the number of heavy goods vehicles generated.

The Welborne Employment Strategy refers to the possibility of Welborne accommodating large format warehousing and/or a large distribution hub and states:

'Wessex Economics believes that proposals for large format warehousing should be assessed, if they materialise, on their merits. Such development might enhance viability or help fund key elements of infrastructure and thus help delivery of the overall plan.

However, Welborne may not be the best location in South Hampshire for such facilities, and might detract from the character and appeal of the emerging residential community. Provision of large scale warehousing might have adverse effects on traffic flows that make delivery of the overall scheme harder.

'The possibility has also been raised by BST that there might be a way to advance the delivery of the all-moves Junction 10, through an early deal with major occupiers to provide either a major distribution centre or large single user office development on land owned by BST to the north of the M27 and west of the A32. The suggestion is that these might help fund the junction improvements required. It is suggested that this would kick start employment provision at Welborne, and be a part solution to the issue of funding infrastructure investment.

With regard to the possible establishment of a large distribution hub at Welborne Wessex Economics would comment that this would probably take up a large proportion of the allocated employment land, but generate relatively few jobs. As the very first thing to be developed it would very likely shape the perception of Welborne as a residential and business location in a way that is not helpful. On the other hand if this were to be the thing that makes the scheme as a whole deliverable, then it would have merits.'

The Society strongly supports the view that Welborne is not the best location in South Hampshire for large format warehousing and a large distribution hub would not be helpful in shaping the perception of Welborne.

The current employment proposals are not in accordance with the PUSH South Hampshire Strategy approved in October 2012. They will result in an adverse impact on the character of Welborne and increased heavy goods vehicle use and are therefore unsound. This can only be addressed by revising Policy WEL 9 to limit the amount of B8 floorspace and to exclude the development of large format warehousing and a large distribution hub.

Employment Area East of A32

The employment area proposed in Policy WEL9 to the east of the A32 is in a visually prominent location and divorced from the main residential area to the west of the A32. The land north of Pook Lane is not low lying and should not be included in the 'Meadow' character; the contours clearly demonstrate that it is part of the 'Parkland' area. Its location means that it cannot be properly integrated with Welborne 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 to and from this area, assuming that the traffic will not go through the proposed residential area to the north, will have a significant harmful impact on Roche Court, its Gate Lodge and historic parkland.

The Wessex Economics 'Fareham Economics Study', January 2014, identifies that across the PUSH area as a whole overall capacity for employment floorspace development exceeds requirements by over 50%. It appears that the development of this land is phased for the period 2030-2036. There is no need for the employment area to the east of the A32 during the period to 2026; it should therefore be deleted.

Transport, Changes to Junction 10

The location of Welborne next to the M27 close to two junctions results in the need for an invidious decision. Access from junction 11 requires a link road that would have a harmful impact on the countryside in the Wallington Valley and the westernmost part of Portsdown Hill; access from junction 10 changed to all-moves has a harmful impact on the residents of north Fareham and elsewhere along the A32 because of the significant increase in traffic that will transfer from other junctions as well as generated by Welborne. Junction 10 was designed with limited moves specifically to limit the harmful impact of the great increase in traffic on local residents to both the north and south of the M27 that would result from its opening.

The Core Strategy did not determine the strategic highway access to Welborne. In Policy CS13 it states:

'Access will initially be via the A32 and junction 10 of the M27;

At a later stage a link road may be required from the A32 to junction 11 of the M27;'

In paragraphs 5.120-5.123 it sets out how the transport strategy will be developed through the AAP and masterplanning process. Paragraph 5.123 states:

'The AAP will therefore provide detail of:

A full package of mitigation measures to demonstrate how the impact of the SDA on the local and strategic road network will be managed and mitigated, including the necessary measures on the A32 for access and safety reasons, in the vicinity of Junction 10;

The case for, and alignment of, a link road to connect the A32 to Junction 11 and interventions at Junction 11;'

The Publication Plan does not include a full package of mitigation measures. There is no evidence that the case for and alignment of a link to junction 11 has been considered and no detail has been provided.

It is clear that the Borough Council has decided that the Core Strategy intention to have the initial access from J10 has become the permanent solution. No evidence that has been used to support this decision has been published and the options have not been assessed through the Sustainability Appraisal. Without the evidence and proper sustainability appraisal of the options the Plan must be unsound.

Transport, Junction 10 Preferred Option

The provision of the evidence and sustainability appraisal to enable a decision to be made on the preferred motorway junction to be used to access Welborne is the first stage of the two stage process that is required. The second stage is the preferred design of the changes to the junction selected. This needs to be carried out before the Plan is adopted because of the significant implications for the wider area.

The various runs of the SRTM that have been published provide some of the data required if junction 10 is to be the preferred option, but a transport assessment is required to estimate the implications for the more local road network. Once this is available the Sustainability Appraisal can be carried out on the basis of sound evidence.

The Plan is not sound without providing the evidence for and the selection of the preferred changes to which of the junctions is selected as the preferred motorway junction to be used to access Welborne. The current Sustainability Appraisal in not sound because in only considers one of the options for changing junction 10 set out in the Welborne Transport Strategy. Without the transport assessment

Transport, Evidence

The Society has been seeking traffic evidence for the SDA/Welborne for many years, starting with its representations on the proposal for the Fareham SDA in the South Hampshire Strategy in the South East Plan.

The Society objected to both the Fareham Core Strategy and the Draft Welborne Plan because the transport policies were not supported by robust evidence that demonstrates that there will not be significant harm to local residents.

In the absence of the evidence, the Society submitted a freedom of information request in May 2013 seeking:

'Information from the Sub-Regional Transport Model (SRTM) used during the preparation of the Draft Welborne Plan on the changes in traffic volumes resulting from the development of the new community and the proposed changes to M27 Junction 10 on the following roads:

A32 north of Wickham and A334 north-west of Wickham; ~ A32 north and south of the M27; ~ North Hill; ~ Kiln Road; ~ Funtley Road; ~ Highlands Road; ~ Park Lane; ~ Trinity Street; ~ Serpentine Road; ~ West Street; ~ Wickham Road; ~ Wallington Way; ~ High Street; ~ Old Turnpike.

The initial testing and analysis of the SRTM outputs that enabled it to be concluded that a strategic highway solution focused on Junction 10 was likely to be a viable option on which to base future testing (Draft Plan, Paragraph 6.16).

All subsequent reports/results referred to in the Transport Modelling Summary and the Habitats Regulations Assessment Screening Report, Paragraphs 5.2.2-5.2.4.'

The Borough Council did not provide the information requested because it claimed that the information was intended for future publication. It stated that:

'The outputs from the transport modelling that you have requested are in a very early draft form at present. The material you have asked for is part of an ongoing piece of transport evidence which is subject to verification before the conclusions will be fit for public consumption or as valid data to inform the Draft Plan.

It is feasible that early sight of the draft data, however incomplete and untested or un-validated, may assist you in understanding how the early consultation draft has been arrived at and assist in public transparency and accountability in decision making terms by aiding your formulation of your consultation responses to that plan. However it is considered that the release of incomplete and draft outputs from the modelling work would be potentially misleading and prejudicial to the ongoing consideration of the emerging Plan and undermine the intentions of this stage of the consultation and the overall consultation process for the plan.'

The Borough Council, despite its claims in the response to the freedom of information request, has not published the information requested. It is now evident that the Sub-Regional Transport Model is not suitable for assessing the impact on most of the roads listed above. The transport assessment is needed to provide this essential information.

The Development Sites and Policies Plan in paragraph 6.4 states:

'The majority of visitors to Fareham Town Centre access the area by car and it is likely that these visitors also account for the most spend in the retail centre. It would therefore not be of benefit to the town centre to restrict access by car.'

The SRTM does not appear to recognise that there will not be any restrictions on access to the town centre by car and therefore is likely to underestimate the number of car journeys to the town centre for shopping.

The Borough Council's response to the freedom of information request confirms that the only information available at the time it decided to focus on access from junction 10 rather than junction 11 was based on early drafts of the modelling outputs that were incomplete, untested or un-validated and potentially misleading. The decision to focus access on junction 10 based on this evidence is therefore unsound.

Transport Assessment

The Society, when responding to the publication of the Draft Welborne Plan, objected to the creation of an all moves Junction 10 for the reasons set out in paragraph 32 above. The Society emphasised that the full transport assessment is needed now and cannot be delayed until the planning application stage.

A transport framework and a transport assessment are required by Policy WEL23 to accompany proposals to develop all or part of Welborne, the transport assessment is needed now because many of the most significant impacts are outside Welborne in the area covered by the Development Sites and Policies Plan. Any assessment needs to consider the impact of the developments proposed in both plans and to identify mitigation/improvement schemes. Many of these will be outside Welborne and therefore need to be included in the Development Sites and Policies Plan.

The Sub-Regional Transportation Model reports provide an inadequate evidence base for the Publication Plan because they only deal with strategic transport issues and cannot be used for the local transport assessment that is required. In addition to this the figures/plans included in the reports are almost incomprehensible because of their poor quality with many of the traffic flow numbers unreadable. The reports should include much better plans and simple tables. There should be separate information for heavy goods vehicles.

The Borough Council has now helpfully provided a simple table showing the changes in flows on the A32, North Hill, Kiln Road and Park Lane, taken from the SRTM run8b and a workshop was held for members of the Standing Conference to discuss the more detailed traffic management measures that may be required. It was never expected that workshops endeavouring to solve the problems would be held so late in the process and particularly during the 6 week consultation period and without the necessary transport data.

The traffic on Wickham Road in Fareham is already heavy to the north and south of the M27 in part because it provides access to the M27 to travel east. The changes to junction 10 to allow moves to and from the west will result in a significant increase in traffic, particularly heavy goods vehicles, to the north and south of the M27. The development of Welborne will also result in a significant increase in traffic on the A32. Run 8b shows that there will be increases in traffic on Wickham Road south of the M27 ranging from 42% southbound in the pm peak to 159% northbound in the pm peak.

Many of the predicted traffic flows on the local roads appear to be low, presumably because they take account of the unspecified traffic management measures mentioned in paragraphs 7.25-7.29 and Policy WEL25. It is totally inadequate to rely on the statement in paragraph 7.26 that states:

'The effectiveness, deliverability and viability of any proposed measures will be assessed in detail as the planning process moves forward.'

These traffic management measures will have a significant impact on the residents of North Fareham Funtley and Wickham. The transport assessment cannot be deferred until the planning application stage but should accompany the submission local plan as Eastleigh has done with its revised pre-submission local plan. The Plan is unsound without evidence on the effectiveness, deliverability and viability of the traffic management measures that are required.

Air Quality

The issue of air quality has been raised by the Society in its previous representations on the SDA/Welborne and it is still not dealt with. It should be remembered that the Sustainability Appraisal of the Draft Proposed Changes to the South East Plan recommended that the Fareham SDA should be deleted because of air pollution problems. The Plan includes Air Quality Management Areas, AQMAs in the list of abbreviations but makes no further reference to the issue. This is a major omission.

The Sustainability Appraisal states:

'Existing air quality in the plan area is dominated by the road network, and in particular is affected by the proximity of the M27 motorway to the site. The allocation of employment land within Welborne has been designed to make an efficient use of land which would be unsuitable for residential uses because of air quality and noise impacts emanating from the motorway. However, air quality may worsen in locations close to new or upgraded road junctions, or roads which are predicted to receive significantly increased volumes of traffic.

There are two Air Quality Management Areas (AQMA) in Fareham - Gosport Road and Portland Street. The impacts of additional traffic in these areas in particular will be closely monitored. The National Air Quality Standards will need to be met in these two locations. Strategic modelling results have so far shown limited impacts on these two locations in terms of traffic increase. The measures contained within the Transport Strategy, both in terms of infrastructure provision to reduce congestion and measures to reduce the level of private car use, will serve to mitigate impacts on these two locations.'

The Sustainability Appraisal Baseline information, paragraph 2.3.1 states that the proximity of Welborne to the M27 has the potential to lead to air quality issues in the south of the plan area. However there is no information on air quality in this area and the SA does not consider it further.

The Plan is not sound without recognition of the issue of air quality, without robust evidence and without proper consideration of the evidence in the Sustainability Appraisal.

Waste Water

The choice between the use of the Knowle works or Peel Common will have fundamental impacts on the timing and viability of housing development. There is no clear evidence of the workability of the Albion Water process on such a large scale as proposed at Welborne. There are no works of a similar scale elsewhere in the UK using this process. A great deal of extra work needs to be carried out before a decision can be made.

There is also no reference to the additional HGV traffic generated by the Albion Water option. A system designed for 750 dwellings results in dried waste lorries regularly leaving the site.

There is no evidence to enable a robust sustainability appraisal to be carried out and to show which option results in the least harm. Without this evidence and a decision on which solution is to be used the Plan is not sound.

Green Infrastructure/SANGs

The Habitats Regulation Assessment refers to the Natural England advice and the need for 84 ha of suitable alternative natural greenspace (SANG) to be provided on or adjoining Welborne. However sites with the potential for only 70.5 ha have been identified in the Publication Plan, with the remaining 13.5ha expected to be provided by incorporating an element of the semi-natural green space proposed for Welborne into the network of SANG.

The SANGs are proposed primarily to reduce the number of residents of Welborne visiting the coast with their dogs and disturbing overwintering birds. The SANGs must be sufficiently attractive to resident dog walkers if the numbers of visits to the coast are to be reduced. The SANGs currently proposed are unlikely to be sufficiently attractive, particularly the currently noisy Fareham Common which will be made even noisier and reduced in area if junction 10 is made all moves at this point. The noise report specifically refers to Fareham Common as being unsuitable for particular forms of residential development because of the impact of noise from the M27. Fareham Common which includes a Site of Importance for Nature Conservation and other areas being considered as possible SANGs, are also likely to suffer from poor air quality because of their proximity to the M27.

Other areas proposed, such as Dash Wood, a Site of Importance for Nature Conservation, may not be suitable for increased use without causing harm to their biodiversity importance.

The total area of SANGs currently proposed is below the 84ha required and the areas proposed are unlikely to be suitable or sufficiently attractive to fulfil its purpose and therefore the Plan is not sound. It could only be made sound if more attractive SANGs are identified and proposed.


The character of Welborne will be significantly influenced by views from the M27 and areas to the south. The proposed employment area along the whole length of Welborne to the north of the M27 will be very prominent and will have to be very well designed with an attractive landscape setting to create a suitable character. The Welborne Employment Strategy, in addition to advising that Welborne may not be the best location in South Hampshire for large format warehousing and might detract from the character and appeal of the emerging residential community states:

Similar considerations apply with applications for B2 development. The revised Plan should seek to set out criteria that would be applied to determine if B2 and B8 uses are compatible with the overall objectives for Welborne as a new community.

These criteria would include contribution to job creation, traffic and environmental impacts, and contribution to funding infrastructure and overall scheme delivery. It is envisaged that a Design Code will be developed and compliance with the Design Code will be an important factor in determining planning applications.

The need to create residential areas without subjecting residents to excessive levels of noise could also have a significant adverse impact on character. See below.

The Plan does not deal with this issue with robust policies and is therefore not sound. The changes to Policies WEL6 &7 will partially address this issue, but the revised policies should also include criteria that would be applied to determine if B2 and B8 uses are compatible with the overall objectives for Welborne as a new community as suggested in the Welborne Employment Strategy.


The Noise Assessment report does not include any noise measurements within the existing communities and only includes one short-term attended location to the south of the M27. The survey was undertaken for a limited time only in July in warm, dry conditions with little or no wind. The report does not appear to consider how the noise experienced by residents varies with atmospheric conditions throughout the year. Research by Uppsala University shows that errors of the order of 20 dBA could be introduced if weather is not taken into account.

The report does not estimate the likely effect of additional noise from the Welborne development or the new infrastructure including the proposed revised junction 10 on the current communities.

The measures proposed to address noise issues, locating employment close to the motorway and using 4m fences or bunds are also likely to have a significant adverse impact on the landscape and character of Welborne.

The changes by the Standing Conference to Policies WEL6 &7 will partially address this issue, but the revised policies should also include criteria that would be applied to fencing or bunds that may be required to attenuate noise from the M27 and A32.

Housing East of the A32

The housing east of the A32 will have a significant adverse impact on the more sensitive landscape on the western part of the Wallington Valley and will be separated from the main part of Welborne by the busy A32. The southern parts of the proposed housing area will be subject to excessive noise and any 4m fence or bund required to reduce the impact of noise on residents will add to the adverse impact on the landscape. The housing areas to the east of the A32 should be deleted.

Clarification, corrections and minor changes requested

The Society requests that the following correction/changes are made by the Borough Council before submission.

Garden Community

Paragraphs 2.4-2.10 and Policy WEL6 do not properly describe what is meant by 'New Garden Community' or '21st Century Garden City'. The concept does not appear to have any significantly different features from any other proposed large scale development.

The aspirations for the new settlement have changed over the years from a sustainable development, to an eco-town and now to garden community 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. Too much weight has been given to the early viability at the expense of longer term sustainability.

Green Infrastructure Corridors

The Plan should specify the width of these corridors and clarify whether they are additional to the settlement buffers or part of the buffers.

The Society would like to participate in the oral examination to clarify any issues that arise from its statement.