COMMENTS ON THE DRAFT SOUTH EAST PLAN

 

NAME:        EMWORTH RESIDENTS’ ASSOCIATION

Chairman:          Mr Chris Curry

Address:            White House, 33, Horndean Road, Emsworth, Hampshire. P010 7PU

Tel:            01243 372312

Fax:           01243 370548

E-Mail:      ccurryems@aol.com

 

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Support: Section A paragraph 3.2 sustainable development

     paragraph 3.4 climate change

    paragraph 3.7 resource use (eg water and waste)

Section C1: Summary: The plan identifies some of the problems faced by the region, but it doesn’t explain the steps that will need to be taken to solve them, and as discussed the proposals for over-development will in fact worsen them.

Section D1: Full response

The Sustainability Appraisal commissioned by regional assembly concludes that if the South East Plan goes ahead as proposed, it will lead to an increase in resource consumption, increased waste, increased transport emissions, increased water consumption, a reduction in the range and quantity of wildlife and still fails to solve the problem of providing sufficient affordable housing.

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Oppose: Section B paragraph 7.4.2

  Section D2 paragraph 1.1 and paragraph 1.181

  Section E1 paragraph 2.1 and 2.17

Section C: Summary: We are concerned at the emphasis placed on the Gross Value Added economic target.

Economic growth should not be a goal in its own right. The primary goal should be the well-being of society and the conservation of the resources and environment that sustain us. We argue that an index, such as the ISEW, that measures changes in these things should replace the GVA target.  An alternative option would be to measure GVA growth per capita.

Section D1: Full response

Official figures show that in the period 1997-2003 our region had the fastest growth in Gross Value Added (GVA) of any in the UK.  It was one of only two regions (the other being London) that were net contributors to the Exchequer. However, we contend that above a certain threshold of income, greater wealth does not bring a commensurate increase in well-being.

 

UK Sustainable Development Commissioner Prof Tim Jackson, of the University of Surrey, has compared the increase in GDP over the past 50 years with a number of other measures, including many that have a direct bearing on our quality of life. The graphs below are taken from a submission to SEEDA and can be found at: http://www.seeda.co.uk/news_&_events/event_reports/prosperity_&_sustainability/docs/TimJackson_files/frame.htm#slide0020.htm

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

        Measuring economic impacts of economic development

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


          Social Trends over same period

 

So, despite living in the UK region with the best economic performance, people are no more content in 2006 than they were 30 years ago, when the South East's economic output was half what it is today.

 

We note that in figure A2 (Section A) a MORI poll shows that 43% of residents questioned considered they had a very good quality of life. However, assessment of quality of life is relative. The SE has undergone a huge influx of people moving from London. Quality of life may be perceived to be better in the SE than in London. Indeed that may be one reason for the exodus of older people and families from the capital. However, that does not mean that long-term residents of the SE do not consider that quality of life is decreasing.

 

We expect the desire for a better quality of life to be a factor behind the net movement of SE residents to other regions where development pressure is less. We know from our own conversations with people that over-development with its concomitant loss of green space and increase in traffic congestion was one of the most commonly cited concerns of residents.

 

If greater prosperity does not bring greater happiness - but instead heralds greater inequalities between rich and poor, higher carbon emissions, resource depletion, congestion and pollution (as shown by the graphs) - then why rely on such crude measures as GVA or GDP to evaluate success?

 

We believe a measure such as the Index of Sustainable and Environmental Welfare (ISEW) would provide a more appropriate basket of indicators with which to assess the state of the region.


There are some key differences between ISEW, as a measure of sustainable economic welfare, and GVA/GDP, as a measure of production. Most notably ISEW:

 

An alternative option would be to measure GVA growth per capita, which is surely more relevant to the well-being of the region than overall GVA growth.  This former implies higher average skill levels and household incomes; the latter could just depend on how many people are imported to Hampshire.

 

Finally, the over-development of the SE is actually counter-productive if GVA is growth is your goal. The Draft Regional Economic Strategy 2006-2016 (page 26) states that perceived quality of life in the region is one of factors that make it attractive to business. The SE Plan will severely undermine this attractiveness. 

 

Even if the 3.5% target for growth is adopted as a general objective, we are not in agreement that this should necessarily apply to all areas within the SE. Some areas will be more and others less than the target and in any case the average is too high and we would prefer possibly closer to 3.25% by 2021-2026. There should also be other factors considered such as quality of life.

 

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Oppose: Section C  paragraph 4.6.5

 Section D2 paragraph 1.1 and 1.23iii       

Section C: Summary: Housing development to provide homes for workers moving into the region will not increase the income of deprived communities within our area.

Section D1: Full response

The SE Plan is - in part - designed to provide homes for workers moving into the region so that the SE can reach its GVA target.

 

Section E1 South Hampshire paragraph 2.31 states

 

There is a requirement for new housing in south Hampshire to cater for demographic changes (e.g. more one and two person households and longer life expectancy). There is also a need to provide sufficient new homes for workers helping the local economy to grow. This strategy is to provide 80,000 dwellings during the 20 years to 2026. The type of properties required in each district area should be informed by housing market assessments.

 

It is difficult to see how this will benefit people living in the deprived communities Rowner, Gosport, Leigh Park, Wecock, Purbrook and particular districts of Portsmouth.

 

Section D2, para 1.23iii of the SE Plan states that moving into the region workers are likely to be better qualified than the workers already here. Therefore even if the unemployed are successfully upskilled, they will have competition to attain the better-paid jobs that could lead to greater prosperity.

 

A less optimistic outlook is that they will take on lower-paid jobs that provide services to those with higher paid jobs, leading to the "hourglass economy" described in the introduction to the Review of the Regional Economic Strategy 2006-2016. This has a large number of high-earners (the top of the hourglass), few middle-income earners (the waist of the hourglass) and a large number of low-income earners (the base of the hour glass) providing services for those at the top.  It is difficult to see how this kind of economy will reduce disparities within the region - one of the goals of the SE Plan.

 

There is of course an even less optimistic outlook - given that the "trickle-down" economic model has been discredited. That pessimistic outlook is that the unemployed will remain so.

 

Encouraging workers to move to south Hampshire from other regions (section E1 2.31) increases housing demand and prices in an area that has already seen a great deal of development.  The houses sold by private developers or rented out by private landlords will go to the highest bidder. Attracting workers to this region - particularly as they are likely to be better qualified - might lead to indigenous workers being out-bid for the new homes that become available. So people could see a further reduction in their quality of life due to over-development for little gain in housing terms.

 

Last but by no means least; we would imagine that the people moving to the SE for work would prefer to remain in their own areas if there was sufficient work and prospects. This country needs a more even spread of economic activity. This would benefit both people and the environment. Instead we have an attempt to shoehorn people and economic activity into one region while housing and facilities lie under-used in other areas.   The SE Plan seems to us to be admittance by Government that it is unable to steer the economy of this country.

 

Since the SE Plan is essentially driven by a central plan for all regions and by projections of economic growth, population, and housing, then it is not based on local needs agreed with local democratically elected people. In this case it should address national needs and growth, including economic needs and housing requirements for the population as a whole. The chart below shows population changes as from National Statistics and Hampshire County Council records.

 

 

Area

Population change  1981 to 2004

UK

+6.2%

England

+7%

SE Region excluding London

+11.8%

NE Region

-5.2%

NW Region

-2.0%

Hampshire County Council

+11.6% (1981 to 2001)

 

This suggests that a national plan co-ordinated through central government is failing to provide economic development in these areas where populations are declining or not growing near to the national average. This results in uneven distribution of the population growth with increasing poverty in some regions and excessive building in other areas. The resulting demand for houses in the SE Region pushes up the cost of houses resulting in the need for special schemes to try and provide low cost housing and introduce more houses to depress the price. These homes will go to the higher calibre staff required by employers in the SE Region who are being encouraged to the area because the present residents do not have the skills in sufficient quantity. The lower skilled people will remain out of work and an attempt will be made to attract more employers to take these people.

 

The commitment to economic growth is not matched by the commitment to infrastructure and the spiral will only stop when the population finally realise that conditions are unacceptable and start to move elsewhere. This is what the regional plan should be about; avoiding this uncontrolled activity, not encouraging it. The situation will control itself if the house prices are allowed to rise naturally and are not inflated by increasing the demand for development above what the local communities require. Leave the planning to the Local and County Authorities who are answerable to their electorates. Use the SE Plan to link their plans for infrastructure.

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Oppose: Section C 3.4.1 vi

Section C: Summary:  We do not support the proposal for significant housing and economic development in South Hampshire.

Section D1: Full response

This appears to refer to the two Strategic Development Areas (SDA) proposed for South Hampshire. We will keep our comments to the north of Fareham SDA as an example. Our opposition to this will be given more fully in our response to the south Hampshire section of the SE Plan. However, we would like to mention a couple of objections here:

 

The SDA is in an important gap that defines the communities of Fareham and Wickham. It is designated as an Area of Special Landscape Quality within the local plan.   It is likely that the many people living there will have to travel out of the new town to work and since the main transport link is the motorway then the development will encourage car travel. It therefore does not meet the government's sequential test for development which prioritises previously-developed sites over greenfield sites and sites with good public transport links over those with none.

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Oppose: Section D3 paragraph 1.8

Section C: Summary: More emphasis needs to be given on bringing empty properties into use.

Section D1: Full response

This will reduce the amount of new build required. We will give information on the local situation in our response to the south Hampshire situation plans.

 

 

Oppose: Section D3 Policy H1 Housing Provision

             Section E1 Policy SH12 Scale and Location of Development

Section C1: Summary:  The South Hampshire sub-region allocation, and corresponding district allocation in Policy H1, is based on an economic target of 3.5% GVA growth which even Hampshire County Council does not feel is achievable.  We support using the ISEW (Index of Sustainable and Environmental Welfare) as a measure of appropriate growth. The amount of available previously developed land (excluding that of ecological merit) has been underestimated.  The overall figure is not based on local need or population predictions, and at least 7,000 dwellings, and up to 10,000 dwellings, should be held back as a strategic reserve pending the outcome of future pdl capacity and local demand studies. There is no mechanism in the Policy for reallocation within the sub-region should, for example, Southampton, be able to take more of the sub-regional allocation. Furthermore, the intended locations and SDAs will not lead to an improvement in deprivation in the areas which need it most. 

 

The South Hampshire Sub-region is the smallest sub-region at only 659 sq km, but is taking 14% of the  entire regional allocation with 80,000.  This is based on PUSH assumptions of growth at 3.5% GVA, but we feel that a more appropriate measure would be the ISEW (Index of Sustainable and Environmental Welfare) as discussed.  If however, a GVA target is to be used, along with Hampshire County Council, we believe that a sensible aspiration of GVA growth rising to 3.25% by 2021-26, is more likely to be achievable.  We suggest that the figure of 80,000 dwellings has been allocated to South Hampshire not based on local need and the requirement for urban renaissance and regeneration, but simply to fulfil a numbers requirement.

 

Population estimates for South Hampshire taken from the PUSH submission and checked in the Profile of Hampshire 2005 (from Hampshire County Council website) confirm that over the 20 year plan period the population will increase by only 70,000, of which 60,000 is due to in-migration.  Firstly, we fail to see why 70,000 people (even including a back-log of 6,000 in need) should require 80,000 dwellings.  That is more than 1 dwelling for every new inhabitant.  The Hampshire wide average is over 2.4 people per dwelling, so even a conservative estimate would require only around 33,000 new dwellings.  Unbelievably the population predictions actually expect one Hampshire district to have lost population by 2026 compared to 2001 - Havant.  This loss is expected to be 3,200 persons, or 2.8%.   The other authorities in the sub-region with expected large gains, all above 10%, are Test Valley, Winchester, and Gosport.  Secondly, we have been repeatedly assured that this housing is needed to provide for local need.  This is not supported by these population predictions.  Indeed, recent revisions to the level of household formation (Bramley (2005) drawing on DETR (1999); ODPM Housing Statistics) have revised downwards the expected new household formation in the South East.   Since there is currently almost full employment it is not clear why, if the population change is to be only minimal as predicted, there is a need for such vast increase in employment floorspace alongside the proposed housing.  If the justification is that the current employment land is unsuitable, then it would follow that this surplus land could be redeveloped for housing thus increasing the supply of brownfield land and decreasing the need for the current high greenfield allocations.

 

The PUSH submission is based on a target that 38 or 39,000 dwellings of the 80,000 can be accommodated on brownfield sites (under 49%).  Current brownfield development in Hampshire is running at 71%, and there is no reason to assume that this level cannot be maintained for the foreseeable future.  In any event, maintaining a high level of ongoing brownfield is clearly an aspiration that should be supported, except in those circumstances where a brownfield site is of exceptional ecological merit.  Should a level of 70% be maintained, then 56,000 dwellings could be achieved on previously developed land.  This could result in the deletion of the Fareham SDA, the lowering of targets in the southern parishes of East Hampshire, and a reduction in the additional figures allocated at West of Waterlooville.  Some of the councils that make up PUSH itself were of the opinion that the Urban Capacity figure had been underestimated.  Eastleigh felt a figure nearer 50,000 was more appropriate, and Winchester City Council felt it should be raised to at least 55,000 dwellings.  We do not feel that enough consultation or effort has been put into evaluation of these proposals, and since this is of critical importance in the likely allocation of sites, it should merit considerable further investigation.  We would urge that we do not wish to see a repeat of the mistakes of the past when appropriate windfall capacity was vastly underestimated leading to large greenfield MDAs being specified in the Hampshire County Structure Plan, which have ultimately turned out to be either unnecessary or only needed on a reduced scale.  A reserve sites policy provides some protection against this.  (The member groups that make up SHUV are more than happy to discuss urban capacity in their specific areas of expertise).

 

The allocation of 1,200 dwellings to the southern parishes in East Hampshire is not based on local need, and would have a detrimental impact on the setting of the designated South Downs National Park in contradiction of Section 85 of the Countryside and Rights of Way Act. 

 

The allocation of 6,739 dwellings to the southern parishes of Winchester is not based on local need, but on a purely convenient extension to the West of Waterlooville MDA, and as discussed below under Section E1 Policy SH1 this will have an injurious effect on the deprived localities in neighbouring Leigh Park, Havant.

 

The allocation of 6,301 dwellings to the Havant Borough also seem quite contrary to the acknowledged population figures which are as follows:

 

 

1961

1971

1981

1991

1997

2001

2008 est

2011 est

Havant Borough

74.6

109.3

116.7

121.2

120.0

119.6

117.997

118.0

% change

 

46.6%

6.8%

3.9%

-1.0%

-0.3%

-1.3%

-1.7%

% change from 1981

 

 

 

3.9%

2.8%

2.5%

1.1%

1.1%

% Change Overall

 

46.6%

56.5%

62.6%

61.0%

60.4%

58.3%

58.3%

 

The above demonstrates that whilst the population in the Havant Borough increased by 46.6%  in the 60s & 70s and by a further 6.8% in the next decade, this had slowed to 3.9% by 1991 following which there has been a consistent decline to  -1.0% in 1997 and –0.3% by 2001,  est –1.3% by 2008 and est –1.7% by 2011.

 

These population figures provide no justification for the proposed increase in housing provision in the Havant Borough, in fact suggests the reverse.

 

Despite the decline forecast for the population of the Borough of Havant, it is noted that the rate of building for the period 1996 to 2011 used in the Adopted District-Wide Local Plan is 199 dwellings per year. The proposal from PUSH, which has recently been amended and increased, is for an average of 315 dwellings per year. This is a 58% increase in the building rate above the present Adopted Plan (adopted in 2005). This is spread over the period from 2006 to 2026 in a very irregular pattern. It hardly seems possible that this pattern is anything but meeting some planners target and is divorced from need or demand. The result will certainly be more car journeys and it seems impossible that this can be considered sustainable.

 

Havant Borough proposed building rates in dwellings per year.

2006-2011

2011-2016

2016-2021

2021-2026

Total

360

590

133

133

315

 

 

 

Oppose: Section D3 Policy H5 and H7

Section C1: Summary:  The housing numbers will have a significant negative impact upon wildlife and the environment.

Section D1: Full response

Re housing, wildlife and water conservation: the proposed amount of building (housing and commercial) means that vast areas will be covered in concrete or tarmac. It must be remembered that wildlife is not restricted to wildlife reserves; it is found throughout the wider countryside and in our towns and cities. In conjunction with other comments on the lack of environmental sustainability of the Plan, the proposed amount of building is an added nail in the coffin of local wildlife. 

This is particularly crucial at a time when we know that wildlife-friendly gardens or communal areas are of more value for wildlife than is sterile farmland. Not only can private and communal gardens provide food and shelter for a huge (and essential) range of plants, insects, birds and mammals but they can form small wildlife corridors between isolated areas of open green space in cities.  As Hampshire Wildlife Trust points out, we can also benefit from the extra interest that wildlife brings to the garden. 

Secondly, where are the plans for capturing the water that will be lost through run-off from the tarmac and concrete with which the ground will be mostly covered?  Development plans must include communal areas planted with native plants and managed for wildlife, and drives and paths should use grassed concrete paving that allows water to drain through.

Point (v) Policy 7: replacing larger dwellings with high-density flats, where there were wildlife-friendly areas around such areas, infilling has had disastrous consequences for wildlife. Such a policy must only be pursued with careful thought and full consultation with wildlife protection bodies and with provision to include communal areas planted with native plants and managed for wildlife, with drives and paths using grassed concrete paving that allows water to drain through.

NB I took this from an email you sent from Wendy Smith on 8 June

This point is very important for Emsworth in view of several developments on New Brighton Road to knock down large Edwardian villas and replace them with high-density housing units. I would also like to add the following about protecting trees:

Trees are an important part of our environment whether in areas of woodland, parks, private gardens or along road margins and as many as possible should be protected under Tree Preservation Orders (TPO’s). This is especially important on roads of Special Character since they contribute to the street scene and visual amenity value of the area. This point relates very strongly to the development of large houses with large gardens in that unless trees are protected by TPO’s it is usually the trees which are the first to go as soon as a site is acquired by a developer.

Please edit the above text as you think fit.   

The following relates to Section E1.2 Sub-regional policies paragraph 2.3.

Some brownfield sites have become valuable habitats for wildlife and probably also serve as useful water catchments where land is free from concrete and tarmac.  A full ecological assessment of brownfield sites is needed, so that any plans to develop them should only be pursued with careful thought and full consultation with wildlife protection bodies.  The blanket use of all brownfield sites is not an easy remedy to the perceived development needs of the south east and other choices must be fully explored; e.g. a proper review of the unsustainable economy resulting in population over-density – please refer to response to Section D1.

 

 

Oppose: Section E1 South Hampshire Paragraph 1.4 and  paragraph 2.14    

Section C: Summary:  The vision for South Hampshire is purely based on economic growth.  There is no mention of quality of life relying on clean land, water and air, productive soils, natural resources, and also distinctive and inspirational landscapes, wildlife, vibrant communities, open spaces and a healthy well managed countryside.  The vision must be altered to accommodate these issues.

Section D1: Full response

The guide “Environmental Quality in Spatial Planning” produced by the Countryside Agency, English Heritage, English Nature and the Environment Agency, makes it clear how planning authorities might achieve high standards of environmental quality in spatial planning.  Development should be sustainable in both built form and location; should respect the ability of the environment to accommodate change; should avoid damage to and enhance the environmental resource; should reduce risk to the environment; should respect local distinctiveness and sense of place; should reflect local needs and provide local benefits.  The South Hampshire vision is not only lacking these statements, but clearly violates them in numerous ways.  The numbers and locations proposed are unsustainable; the environment will clearly be unable to absorb this level and speed of development; the environmental resources such as water and waste are clearly put under threat; the Solent itself has not been mentioned in the plan; a Solent city with minimal gaps does not respect local distinctiveness and a community’s sense of place; and as discussed later the plans do not provide for local needs where the need is greatest.

 

The goal of the South Hampshire plan should be to improve people's quality of life of people living and to work towards living within environmental limits. Anecdotal experience shows that this is what primarily concerns people - not a lack of jobs or a lower economic growth rate than some parts of the SE.

 

We agree with the proposition that infrastructure should be in place before or at the same time as development. This is one reason to oppose the front loading of the Havant Borough housing targets. Where is the additional water, where are the Hospitals and Health Centres? Even the Oak Park Hospital planned for Havant has shrunk from 125 beds to 25. We suspect it will soon vanish along with Havant War Memorial Hospital and Emsworth Victoria Cottage Hospital and all other promises made by the NHS/ PCTs. __________________________________________________________________________

 

Object Section E1 paragraph 2.19 employment growth

Section C1: Summary: What is the justification for creating jobs for which we do not have workers, according to other parts of the plan? This is unfair to other regions of the UK which have the workers, but no jobs.

Object - Policy SH6 – Scale Location and Type of Employment Development

 

Given the unemployment in the Leigh Park wards and the need to reduce unnecessary car journeys, employment developments should be located as near as possible to these wards.  Other locations should be provided on good public bus routes.  Locating an industrial site between the two bridges at Emsworth, as is currently planned, seems particularly incongruous in meeting this objective.

 

 

Oppose: Section E1 Policy SH1 Overall Strategy    

Section C1 : Summary:  The overall strategy is well meaning, but the district allocation as drafted will not result in the regeneration of the most needy wards in the sub-region.   The task of urban regeneration must be more proactive and less reactive by the local planning authorities.  Cities should be the subject of master plans avoiding the tendency for piecemeal development, with a corresponding lack of coherent infrastructure and facilities improvement.  Any greenfield development should be PRECEDED by regeneration of deprived areas, and PRECEDED by appropriate infrastructure improvements.

 

Some improvement of the situation presently applying to the South Hampshire Sub Region could be achieved although there are still significant decisions remaining to be formalised in the Plan.  Such future proposals ought to be the subject of full consultation with the areas affected and not left for unelected officer bodies to impose.

 

Section D1: Full response

South Hampshire has a number of centres of severe deprivation in terms of housing quality, Rowner in Gosport, Leigh Park in Havant to name the best known.   The table (3.2) below is taken from the 2005 Profile of Hampshire.  Fourteen of the twenty areas in Hampshire with the highest scores on the index are all within wards that constitute the Leigh Park area of Havant (Warren Park, Barncroft, Bondfields and Battins).

 

Table 3.2 Index of Multiple Deprivation 2004 - Hampshire's Twenty Most Deprived Areas

Rank     SOA code         Within ward District Rank

1          01022905          Battins Havant

2          01022967          Warren Park Havant

3          01022903          Battins Havant

4          01022933          Hart Plain Havant

5          01022917          Bondfields Havant

6          01022906          Battins Havant

7          01022970          Warren Park Havant

8          01022915          Bondfields Havant

9          01022934          Hart Plain Havant

10         01022901          Barncroft Havant

11         01022900          Barncroft Havant

12         01022902          Barncroft Havant

13         01022968          Warren Park Havant

14         01022966          Warren Park Havant

15         01022822          Grange Gosport

16         01023029          Holbury & N. New Forest Blackfield

17         01022969          Warren Park Havant

18         01022913          Bondfields Havant

19         01022844          Town Gosport

20         01023126          North Town Rushmoor

 

There are numerous incidences of boarded up derelict dwellings and there are underused and unsafe public places.  However, the worst deprivation is not found in the social rented sector of these estates, but in the poor owner occupiers.  The study Profile of Hampshire showed that Gosport was well below the national average in its symbols of success measure and only 8% so-called wealthy achievers.  The highest crime rates in Hampshire are in Gosport and Havant, with proportion of violent crime more than double that of the rural districts.  The two districts in the county having higher than the national proportion of people with poor basic skills are Gosport and Havant. The same is true for the two unitary authorities, Southampton and Portsmouth.

 

We maintain that the residents of Rowner in Gosport are not going to be helped by the building of the SDA north of Fareham, there will no improvement in their infrastructure and facilities.  Those who can leave will leave, leading to increased abandonment and hardship on the estate.  True urban renaissance would look to redevelop this area, which although high rise in places, is actually low density overall, allowing a major improvement in transport links along the currently highly congested A32 down the Gosport peninsula. There are proposals for other sites in Fareham which might be more beneficial to this desperately needy area than the suggested SDA to the north of the M27.  These have not been aired in a public forum, nor been the subject of comparative cost/benefit analysis, nor been the subject of environmental impact assessments.

 

The residents of Leigh Park in Havant are not going to see any improvement in their facilities or infrastructure as a result of the development West of Waterlooville.  It will only serve to suck the already fragile services out of Leigh Park and into the larger new settlement.  This was recognised by Havant Borough Council who themselves asked for a lower allocation to Waterlooville, in order to prioritise the regeneration of Leigh Park.  This allocation has been driven by an approach which only takes the easy option.  It is of course more difficult to resolve a 50 year back-log of deprivation, stretching back to the building of Leigh Park after the war to house many people in the same socio-economic group from Portsmouth. This is a prime example of what can happen when a huge housing estate is provided  without adequate infrastructure. 

 

The allocation at West of Waterlooville (in Winchester District) should be reduced, and replaced by a proper “road-map” for improvement at Leigh Park.  The population increase predictions for Winchester are likely to be as a result of proposed building in Waterlooville.  Investment into Waterlooville rather than into the regeneration of the more urban, and thus more complicated, Havant, will thus lead to further decline.  This is planning turned on its head, i.e. build more houses, so the population increases, so build more houses.  Real regeneration should focus on meeting a social requirement.

 

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Oppose: Section E1 Policy SH2 Strategic Development Areas

Section C1 : Summary:  Any greenfield development in the Strategic Development Areas should be PRECEDED by regeneration of deprived areas, and PRECEDED by appropriate infrastructure improvements.  The allocation to Strategic Development Areas as drafted will not result in the regeneration of the most needy wards in the sub-region.   It is not clear why the Fareham SDA must be 10,000 dwellings in size, no justification has been provided.  The statement on preventing coalescence of the SDAs with neighbouring settlements needs clarification in the guidelines for the size of the areas of open land required.

Section D1: Full response

The proposed SDA does not meet the government's sequential test for development which prioritises previously-developed sites over greenfield sites and sites with good public transport links over those with none.  Since there are no other options for public transport the people who will living there will have to travel out of the new town using the motorway, and thus the development will encourage car travel.   Even with some employment sites within the “new town” commuting out and in will still put huge pressure on an already congested network.  Other potential sites in Fareham are located closer to already sustainable centres, and a proper comparison has not been made on the relative suitability of these alternative options.  This is in contradiction of all environmental assessment suggestions.

 

Meetings were held with the Fareham Society, other amenity groups and the public (at their own instigation) only after decisions on the Fareham SDA had already been made.  There has been no real community involvement to date, and the alternative sites and the associated potential infrastructure improvements to the congested A32 have not been put to public debate.  No justification has been provided for the size of the Fareham SDA at 10,000 dwellings, and it was originally proposed at 8,000 dwellings.  The change seems arbitrary.  If the justification were that this is a minimum size to qualify for sufficient infrastructure to be built, it would follow that both the Hedge End and Fareham SDAs should be of equal size.

 

The proposed location for the Fareham SDA is in an Area of Special Landscape Quality, and would set an undesirable precedent in stretching the urban footprint north of the M27.  The gap which exists currently between Fareham and Wickham is critical to separate the townscape of Fareham, with all its associated urban facilities from the essentially rural small market Meon Valley town of Wickham.  To fit 10,000 dwellings into this gap is already threatening the identity of these two very different areas.  It is not clear from Policy SH2 how wide the “areas of open land” to prevent coalescence should be.  This could be as narrow as one field.  It is critical that they are significant enough to prevent any visual connection between the settlements.

 

If Policy SH2 were actually to be followed as stated i.e. the impact of the SDAs “will be assessed in relation to their effect on surrounding districts and their sustainability”, then the SDA would not be proposed in this location at all.

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Oppose: Section E1 Policy SH3 Sub-Regional Gaps

                                      Paragraph 2.9

                                      Paragraph 1.1

Oppose: Section C  Policy CC10 Gaps     

Section C: Summary:  We object to the exclusion of the Denmead and Waterlooville, Emsworth and Chichester and the Southampton/Chilworth and North Baddesley gaps in paragraph 2.9., as suggested by PUSH.  We further ask that a Clanfield/Catherington and Horndean gap should be added.  We object to the criteria in Policy CC10b which only allows for strategic gaps to be between settlements of 10,000 dwellings apiece.  We propose that only one of the settlements need be of the order of 10,000 dwellings.  Therefore it follows that all the gaps in paragraph 2.9 with the additions of Denmead and Waterlooville, Southampton and Chilworth, and Clanfield and Horndean and Emsworth/Chichester Strategic Gap should be included as Sub-regional gaps in Policy SH3. This is critical in order to preserve local distinctiveness and community spirit.  A buffer zone should be added to prevent negative impacts along the southern boundary of the designated South Downs National Park, or rural parishes removed from the sub-region.

Section D1: Full response

As the SE Plan states in paragraph 2.7, gaps of undeveloped land help break up an otherwise almost continuous built-up area, well on its way to becoming the dreaded “Solent City”.  They are critical in maintaining community spirit and the separate identity of settlements.   However, it is just as, if not more, important to maintain a gap between a large settlement (greater than 10,000 dwellings) and a smaller village or town.  Without that provision, there is no protection to prevent the coalescence of every smaller satellite into the larger urban footprint. 

 

Similarly the suggestion that the gap between Emsworth and Havant should also be included in an LDD is welcome.  This is a truly Strategic Gap and its definition should not be subject to positive criteria.

 

The proposed new policy CC10b accepts that whilst strategic gaps are a helpful policy tool, the identification of gaps is best undertaken at local level through LDDs, but in accordance with the criteria set out in the revised Regional Policy.

 

An example of the reason why we cannot support the idea that the minimum size of settlements that strategic gaps should separate should be 10,000 persons is in the Emsworth-Chichester gap. In the Havant/Emsworth area there is a gap between Emsworth (population greater than 10,000) and Westbourne (much less than 10,000). The gap is now very small and could get smaller but there is an absolute need to retain the gap as wide as possible. We, therefore, might agree that one of these settlements defining a gap should be 10,000 persons, but not both. 

 

We oppose the criteria that “gaps should not be greater in size than is necessary”. We would suggest that this wording be replaced by the following:

 

“Gaps should be maintained as large as possible and any proposed reduction in size should only be implemented if an overriding case can be demonstrated for doing so. The case for any reduction in the size of a gap must also be subjected to a formal process of public consultation” 

 

It is unacceptable for unelected officer groups to decide what size of gap is necessary to prevent coalescence in local areas or for them to impose these on residents of local settlements.

 

In order to prevent significant negative impacts on the southern margin of the designated South Downs National Park, and to limit cross-border effects, a buffer zone should be considered to limit the intensity of development in the following area: Clanfield, Horndean, Rowlands Castle, Denmead, Newtown, Wickham, Swanmore, Bishops Waltham, Durley and Colden Common.  Alternatively these essentially parishes should be removed from the South Hampshire sub-region (precedent for this has been set in the Western Corridor part of northern Hampshire, where several parishes were removed from the draft boundary of the sub-region).  The local authorities have a statutory duty to conserve and enhance the designated National Park.

 

 

Object Section E1 Policy SH4  Implementation of Development Plans

Section C1: Summary: The people of South Hampshire must have some input into the implementation of this plan, which will have such a drastic effect on their home.  This should be through the democratic process. However, PUSH has so far failed to engage with the public and this should be made a requirement.

Section D1: Full response:  

Very few people in South Hampshire have heard of PUSH. Its meetings, minutes and agendas have not been made public. Although leaflets have been produced, the public has had little opportunity to question those who are responsible for the sub-region's plans.

 

Section D2: Revised wording:

Add: "This agency will be publicly accountable through the leadership provided by PUSH, which will seek to engage the public by opening its meetings, agendas and minutes to the public and by holding and publicising a series of public meetings so that people can question the leadership of PUSH."

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Oppose: Section E1 Policy SH5 Plan, Monitor and Manage

            Section E1 Paragraphs 2.6 and 2.12

Section C Summary:  Any greenfield development should be PRECEDED by appropriate regeneration of deprived areas.  There is not a rigorous enough mechanism in Policy SH5 or in Paragraph 2.6 to allow for the reallocation within districts of the sub-region should urban capacity and windfall sites exceed expectations such has happened in the region over the last plan period.  There should be a mechanism for reserve sites to be removed from the plan should the range of monitoring indicators show that the housing is no longer required since circumstances can change.  Policy SH5 should include the provision of reserve allocation, such as has worked well in the current Hampshire County Structure Plan.  At least 7,000 dwellings and up to 10,000 dwellings should be held in a reserve capacity, until need has been demonstrated.

Section D1: Full response

There should clearly be an additional policy such as the Hampshire County Council H4 monitoring policy which  monitors annually completions throughout the county, and releases allocations should local need be demonstrated.  There should be an additional policy for reserve sites in the district allocations, and in particular the Fareham SDA and the additional allocation to West of Waterlooville should be reserve allocations. Circumstances are highly likely to change over the 20-year plan period, for example house prices and affordability can be the subject of worldwide boom/recession, and are not simply based on local supply provisions.  Further, Southampton city councillors have informed us that it is likely that Southampton is likely to be able to take additional capacity from the other districts.  It is very important that there should be a policy which removes sites from the plan at the end of the period if they have not been required, so as to avoid planning blight, and to allow for future improvements in city centre regeneration that may prove less difficult under future more visionary legislation.

 

Paragraph 2.6 states that the rate of development in each SDA will depend on infrastructure provision, and that if more urban brownfield sites become available then the SDA development may fall after the plan period in 2026.  This would argue for a reserve site policy such as already exists in Hampshire.  This makes no allowance for circumstances to change, there should be no automatic assumption that the allocations should be carried forward into any subsequent plan, and there should be no allocations after the end of the plan period.  Should the rate of windfall supply exceed expectations, the SDAs and West of Waterlooville, should be removed from the plan.  Paragraph 2.12 also states that releasing major greenfield sites may undermine urban regeneration.  We would argue that even allocating major greenfield sites can have a similar damaging impact, and that this can be mitigated by holding them in reserve, pending that regeneration taking place first.