Dear Fareham Borough Council The RSPB welcomes the opportunity to comment on the Fareham Draft Local Plan 2036. Our primary area of concern in responding to this consultation is to ensure appropriate recognition is afforded to the internationally important coastal habitats, and the waders, waterfowl and seabirds these support within and adjacent to Fareham Borough. Policy NE2: Biodiversity and Nature Conservation We welcome the inclusion of Policy NE2 and reference in the policy and the supporting text to some of the key nature conservation principles of the NPPF, including the avoid-mitigate-compensate hierarchy and the requirement to seek enhancements (net gain) to biodiversity through the planning system. These principles have great significance to Fareham Borough, and to the Local Plan 2036, due to the large number of international, national and local wildlife sites within and adjacent to the Borough. Policy NE3: Solent Special Protection Areas We further welcome Policy NE3 and, in particular, reference to the Solent Recreation Mitigation Partnership's Definitive Mitigation Strategy and the Waders and Brent Goose Strategy. However, the Council should be aware that the Solent Waders and Brent Goose Strategy (2010) has recently undergone significant work and an updated version will soon be published. All references in the Draft Local Plan to this document, as well as individual site categorisation will therefore need to be reviewed against the updated Strategy (paragraph 9.16 and development allocations maps). This will have significant We note that the next draft of the Local Plan will be taken forward to the HRA: Appropriate Assessment stage. However, it is critical that before the HRA proceeds to this next stage of assessment, all site allocations are reassessed against the updated Solent Waders and Brent Goose Strategy (or the most recent available draft, if the new Strategy is still in preparation at the time of the re-assessment). This is extremely important because a number of the proposed allocation sites coincide with or are immediately adjacent to wader/brent goose sites that are now recognised as having greater importance to the network of SPA supporting sites, including at least three sites that are identified as "Primary Support Areas". We refer the Council back to Policy NE2 of the Draft Plan, which correctly reflects the avoid-mitigatecompensate hierarchy of the NPPF. Therefore, before the Council considers whether the direct or indirect damage to any such sites forming part of the Solent waders and brent goose network can be mitigated or compensated, the Council must demonstrate that all less damaging options have been excluded. Only then should such sites be considered for allocation. In the absence of this further assessment, we consider that the Plan would fail the NPPF Local Plan tests of soundness (para 182), including being: Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework. We are particularly concerned with the following sites: • HA2 - Newgate Lane South, Peel Common (ID 3133) – identified as "Low Use" in the updated Solent Wader and Brent Goose Strategy (site ref F23) • HA5 - Romsey Avenue, Portchester (ID 207) – identified as "Primary Support Areas" in the updated Solent Wader and Brent Goose Strategy (site ref F21) • HA6 Cranleigh Road, Portchester (ID 3014) – adjacent to a site identified as "Primary Support Areas" in the updated Solent Wader and Brent Goose Strategy (site ref F21) • HA7 Warsash Maritime Academy, Warsash (ID 3088) - identified as adjacent to a "Primary Support Areas" in the updated Solent Wader and Brent Goose Strategy (sites ref F60 and F61) • HA12 Moraunt Drive, Portchester (ID 3032) - adjacent to a site identified as "Secondary Support Areas" in the updated Solent Wader and Brent Goose Strategy (site ref F46A) • HA23 Stubbington Lane, Hill Head (ID 1078) - adjacent to a site identified as "Low Use" site in the updated Solent Wader and Brent Goose Strategy (site ref F13) • E1 - Strategic Employment Land Provision (ID 3113) - identified as a "Low Use" site in the updated Solent Wader and Brent Goose Strategy (site ref F13) • E2 - Employment Allocations (ID 3114) - identified as a "Low Use" site in the updated Solent Wader and Brent Goose Strategy (site ref F13) We recognise the challenges the Council faces as it seeks to accommodate development on the scale predicted to be needed in the Plan period. However, given the significant constraints affecting Fareham Borough in terms of land availability, sustainability and, in particular, the sensitivity of the surrounding natural environment, it may not be possible for the Council to deliver the assessed housing need while still meeting legislative and other policy requirements. If the Council is unable to allocate sufficient land for development without impacting on statutory wildlife sites, it may be necessary for the Council to pursue a housing requirement that is less than the objectively assessed figure. A number of local authorities nationwide have done this successfully where there are significant constraints on land allocation within their administrative area. The duty to cooperate must also be fully explored as to whether there is the potential for any shortfall against objectively assessed need in Fareham to be provided within another local authority area within the housing market area. We hope that these comments are helpful, and would be happy to meet with the Council to assist in addressing the matters raised above ahead of the next draft of the Local Plan.
The impact on the local wildlife will be unmeasurable, land which once considered to be of high sensitivity suddenly downgraded to low sensitivity, WHY? To remove an obstacle to development? We have a duty to ensure we protect our environment not just by the use of the written word but the way of deeds. Communities have a passion for their local wildlife habitat because they are a place to enjoy, a place where one can unwind and refocus but more importantly, our wildlife also needs a home and why should our wildlife have to play second fiddle to our hunger to build on Greenfield sites out of sheer blind panic. Our response to the Cranleigh Road Inspector should be one of control and measured and not be presenting developers with all they demand because that is what this local plan does.
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