Comments on the Draft Welborne Plan: Sustainability Appraisal
(Submitted 28th November 2013)
The Society's initial comment is that this document is both daunting in terms of length and complexity and is unlikely to be read by the general public. A very time consuming document for anyone to study!
It would have been much more helpful if this SA report had been published for consultation at the same time as the draft Plan to assist in the understanding of the Council's reasons for the chosen policies and suggested location of major infrastructure. Surely this is what the sustainability process is meant to achieve.
There also does not appear to be sufficient evidence to support the SA, particularly in relation to transport, waste water treatment, the location of the district centre, schools and the provision of greenspace.
The lack of response to The Society's comments on the many consultations on the SDA/Welborne is unhelpful. In relation to the Options consultation in July 2012, the Society commented:
"The consultation states that the options need to take into account the emerging evidence base on such aspects as sustainable construction, energy generation and transport. This evidence should be published, with sufficient time to consider it before decisions are made on which option is to be pursued.
There is no information on what evidence has influenced the selection of the options for the centre and secondary school. No site specific requirements are set out, what are they, what was used for the locations shown and what existing residents will be served by the latter?
No detailed evidence on noise is available; the Defra noise map for the Portsmouth area shows that the 40m assessment zone included on the site constraints map will be totally inadequate.
The standards to be applied should conform to the Noise Policy Statement for England and the guidance in the former PPG24 on determining applications for residential development to ensure that noise levels are acceptable.
The sound level within a residential building is not the only consideration. Most residents will expect their gardens and adjacent amenity areas to offer a reasonable degree of peaceful enjoyment. The advice in PPG24 was that general daytime, outdoor noise levels of less than 55 LAeq,T dB, are desirable to prevent significant community annoyance. The residential areas close to the M27 shown on most of the options are most unlikely to conform with this standard.
The April 2010 SDA Emerging Transport Strategy stated that it will be ratified by the South Hampshire Transport Modelling Suite during 2011. Ignoring the unjustified presumption that the Strategy will be 'ratified', when will the evidence from the transport modelling be published?
The transport options included in the consultation must be accompanied by the results of the modelling to show the impact on all local highways if a meaningful consultation is to be carried out. Information on the likely highway works and additional traffic on the local roads, including the A32 Wickham Road, North Hill, Old Turnpike, Park Lane, Highlands Road, Miller Drive and Arundel Drive and the other residential roads that are likely to be used as 'rat runs' to avoid the increased congestion is essential.
If the additional traffic on local roads outside the boundary of the Area Action Plan requires highway improvements which plan will consider the options available and make the appropriate proposals and who will pay?"
It will have been realised that The Society's response to the Options consultation constantly sought more evidence to assist in the making of meaningful responses.
The Society sought to obtain information on the input of the Highway Authorities and the traffic flows from the transport studies through the Freedom of Information request in May 2013. In refusing to supply this information the following statements were made in the Council's reply in June 2013:
"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 intended for publication in October. This validation process is currently underway and it is expected that the whole of the transport modelling evidence, including the data requested, will be finalised for publication in support of the pre-submission draft Welborne Plan in October."
"The initial outputs from the transport modelling work have informed the concept masterplan and other evidence supporting the draft Welborne 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."
"It is therefore considered that the harm in releasing early potentially misleading and unvalidated data sets far exceeds the benefits that would be gained in terms of public understanding of the proposals when a full and validated data set is intended for publication as part of the next phase of the consultation process in October."
This confirms that the transport data in the planning of Welborne so far has been incomplete and untested or un-validated and potentially misleading. It is obvious that this data is not in a suitable form to be used in the SA and any decisions on transport networks based on it, including the proposals for Junction 10 must be premature.
The Society understands that there are significant problems with the trip rates in the transport modelling and that these were reported to Eastleigh's Cabinet on the 26th September 2013.
The Society can only assume that the same trip rates were used in the modelling for Welborne and the transport modelling work will have to be repeated. Presumably this explains why 'a full and validated data set is intended for publication as part of the next phase of the consultation process in October' promised in the Council's response to the Freedom of Information request is still not available at the end of November.
The Society would like to know what degree of self containment is being used as the basis for the transport modelling. Does the modelling take account of the cumulative impact of surrounding development and does it include data for commercial vehicles? It is essential to know this before proper sustainability assessments can be undertaken.
The assessments included in the 'non-technical summary', Table 5.1 and appendices E, F and G do not appear to have been carried out on an objective basis: they appear to be very subjective and biased in favour of the draft plan policies. For example, the assessment in line 99 in Appendix E, the option to reduce the size of development to reduce impact to avoid and mitigate the impact on internationally protected sites is inadequate and misleading. It seems reasonable to enquire whether these tables appear to be so biased because they have been prepared without any independent multi-disciplinary input.
In its comments on the SA of the New Community in the North of Fareham Options (April 2013), the Society said that the SA was 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 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.
In north Fareham the level of noise varies tremendously with atmospheric conditions; the consultant's report submitted at the time of the request for an Environmental Impact Assessment Scoping Opinion in July 2013 shows the extent of the problem with some quite draconian solutions.
The Society also said that 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. These issues do not appear to have been addressed in the SA of the Draft Welborne Plan.
There is so much missing from this Sustainability Assessment and there is too much reliance on public transport, cycling and the behavioural change that will be required for the mitigation of the transport proposals; how are the measures quantified/assessed? The consequences are too severe to get this wrong.
The impact of Welborne will inevitably be felt well beyond the site. Therefore the SA Objectives should deal with issues affecting the areas surrounding Welborne and not be limited to the impact on the new community as is suggested in Objective 6.
Noise is included in SA 6 but not adequately dealt with in the SA. Noise should be included as a key sustainability issue for Welborne in the light of the evidence submitted at the time of the request for an Environmental Impact Assessment Scoping Opinion in July 2013.
N.B. Uplands Lodge should be included in paragraph 4.2.42.
Para 5.2.6 should state that four of the less sustainable masterplanning options summarised in Table 5.1 may be taken forward for inclusion in the Welborne Plan, the location of the District Centre should be included in the list.
Para 5.2.7 should state that a detailed assessment of the transport options will also be undertaken. This is necessary because, as stated in the Council's response to the Freedom of Information request, only early unvalidated data sets were available from the transport modelling at the time the Sustainability Appraisal Options Assessment was carried out.
The option included within the Draft Welborne Plan is closest to Option 3, not option 2 which includes employment development at J11.
Location of district centre:
The statement on the location of the District Centre in Table 5.1 is wrong. It is shown in the South-east corner of the site on the Preferred Concept Masterplan, not in a 'largely central location'. The site included in the Draft Welborne Plan is not the site that was assessed as most sustainable in the Sustainability Appraisal Options Assessment. The most sustainable site, option 4, was more centrally located to improve accessibility for the greatest number of new residents. The site included in the Draft Welborne Plan is almost the same as option1, but because the Draft Plan does not include any housing to the east of the site, it now should have the same negative scores as option 2.
The claim that the most sustainable location is included within the Draft Welborne Plan is misleading. The land east of A32 at Pook Lane was not included in any of the options. In Appendix F WEL9, in relation to the employment proposed to the east of the A32, should be scored with the same negatives as for the employment at Junction 11.
Household Waste Recycling Centre
The claim that the most sustainable location is included within the Draft Welborne Plan is grossly misleading. The only options were 'HWRC on-site' or 'no HWRC'. More site specific options for the HWRC should be considered, including sites outside Welborne.
Location of Primary Schools
The claim that the most sustainable location is included within the Draft Welborne Plan is wrong. The options consultation did not include a primary school to the east of the A32 and the later SA of the options did not show that having one school to the east of the A32 would be the most sustainable.
GI Avoiding and mitigating the impact on internationally protected sites:
The claim that the most sustainable location is included within the Draft Welborne Plan is not accurate. The options consultation did not include any reference to SANGS or the SDMP. The High Level Assessment in Appendix E appears to be biased against reducing the size of the development which should be recorded as having a positive effect on SA3, SA6, SA7 and SA8. There is currently insufficient evidence to demonstrate that SANGs will work as robust and attractive alternative locations, for example for dog walking for Welborne residents, to prevent a negative impact on local European Sites. It must be remembered that the Eastern Wards are already very deficient in Natural Green Space.
Chapters 6 and 7
There is too much reliance on monitoring which can only quantify the impact when the damage has been done. The crucial elements cannot be treated in this way and need to be addressed now.
WEL15 Secondary School Provision
This document does not include the information that is necessary to justify that Policy WEL15 proposes the most sustainable location for the Secondary School. A site to the west of the A32would be in a much more accessible location for the majority of Welborne residents and would therefore be much more sustainable.
Detailed Assessment Matrix
In many cases there does not appear to be adequate evidence to support the assessments, particularly in relation to the location of the district centre and schools and to transport, noise, air quality and waste water treatment.
It is very unhelpful where it includes 'positive/negative', for example on page 2/16, SA Objective 7 as it states that the 'effect of policy on this SA Objective depends on the success of the development principles and policies related to biodiversity and green infrastructure provision'; it should be recorded as 'uncertain'.
The Society could comment on very many of the 'scale of significance', 'positive or negative' and 'supporting comments' set out in Appendix G, but has set out some examples below.
Page 1/16 SA Objective 3, to conserve and enhance the character of the landscape, the Society believes that the allocations will have a major negative impact on the landscape.
Page 2/16, SA Objectives 4 and 6 are closely related and should both have the negative impact as 'moderate' (major?)
Page 4/16, SA Objective 3, to conserve and enhance the character of the landscape, the Society believes that the employment proposed will have a major negative impact on the landscape.
Page 5/16 SA Objective 8, should have the negative assessment as 'major' because the land to the east of the A32 is shown as Grade 2 on the Land Classification map (Fig 18.1 SA Scoping report for Fareham Site Allocations May 2012).
Page 7/16 SA Objective 6 should be recorded as having at least a 'moderate' negative impact because of the extra traffic generated by a secondary school in this edge of development location.
Page 9/16 SA Objective 4 should be recorded as having a 'major' negative impact because the all -moves junction will attract significant additional traffic onto the surrounding roads rather than 'supporting sustainable modes of transport'. SAs 5 and 6 should also be recorded as having a 'major' negative impact because of the emissions from the additional traffic generated by the all-moves Junction 10.
Pages 13/16-16/16 The waste water treatment section appears to be subjective with little evidence to support the assessments. The impact should be noted as uncertain. There do not appear to be any examples of the Knowle treatment process being operated on such a large scale that would provide the evidence that this could be an adequate and satisfactory solution. There is no mention in the Knowle section about solid waste lorries regularly leaving the site for disposal elsewhere. Surely there should be a possible negative impact because of the effect of an enlarged treatment works at Knowle on the River Meon.
In conclusion, The Fareham Society can only object to the Sustainability Appraisal in its present form in that the lack of adequate evidence, particularly in relation to transport issues and accessibility, must result in uncertainty about Welborne's impact (sustainability). The SA cannot conclude that there will be a positive or negative impact, minor, moderate or major, without the essential information.
The lack of adequate evidence has been a major issue since the SDA/Welborne was first proposed about 10 years ago. It is notable that the PUSH North of Fareham SDA Feasibility Study, November 2006, stated:
2.55 This study has identified a number of gaps in knowledge that need to be addressed to inform the planning of the SDA. These include transport modelling; impact on water resources; consideration of solutions to deal with surface water run-off to minimise storm flows into local river systems and avoid contamination of aquifers; green infrastructure/greenspace requirements; and the need for Appropriate Assessment under the Habitat Regulations.
We are still waiting for adequate, comprehensive and up-to-date information to fill the gaps in knowledge, without which the SA cannot be considered to be an adequate Environmental report.