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Community Facilities and Open Space Chapter Summary Comments

CF1: Community and Leisure Facilities

CF2: Community and Leisure Facilities Outside of the Urban Area

CF3: Loss of a Community Facility

CF4: Educational Facilities Outside of the Urban Area Boundary

CF5: Green Infrastructure

CF6: Provision and Protection of Open Space

Representations on Policy CF1: Community and Leisure Facilities

Number of representations on policy: 12

Objection: 6

Support: 3

Comment: 3

Objections

Strong concerns over the pressures that development will put on existing health care facilities – due to already long wait times.

Community facilities and retail floorspace should be provided on all sites allocated in the Local Plan.

Concerns that there are insufficient school places for existing children in the Borough and also that there will be insufficient places to accommodate children from any proposed development.

Concerned that there will not be any open spaces remaining in the Borough, particularly for sports/playing pitches.

Concern over the amount and speed of development happening in the Borough.

Concern that medical facilities, particularly at QA Hospital and the Fareham Community Hospital are overstretched.

Concern over the impacts this policy will have on wildlife in the Borough.

Concern over the quantity and location of community facilities in the Borough, in particular that there are more facilities located in the west than in the east.

Support

The Theatres Trust welcomes and supports Policy CF1 as it seeks to promote new community and cultural facilities, such as theatres, and therefore reflects the NPPF (Theatres Trust).

We welcome and support criterion b) of Policy CF1 as part of the positive strategy for conserving and enjoying, and a clear strategy for enhancing the historic environment as required by the NPPF (Historic England).

We are pleased to note that the plan provides for Places of Worship within and outside of the urban area boundary.

Comment

It will be important to understand whether the proposed development at Newgate Lane can be sufficiently supported by other community facilities in the vicinity such as health facilities and community hall provision. In particular, whether it will be necessary to provide new facilities as part of the proposed development. Without this information, the proposed development cannot be supported. In addition, it is also considered appropriate for FBC to further assess the community requirements of a development of the scale in HA2 and include such provision within the site allocation. (Gosport Borough Council).

It is noted that the plan includes a number of policies relating to community facilities and open space which seek to retain and improve existing facilities (Gosport Borough Council).

A replacement Fareham Community Centre should be included as a policy requirement.

All new development should provide funding towards the provision of additional health facilities. In particular, to ensure that doctors and hospitals can provide additional staff within facilities to meet the needs of proposed new development in the Borough.


Representations on Policy CF2: Community and Leisure Facilities Outside of the Urban Area

Number of representations on policy: 2

Objection: 1

Support: 1

Comment: 0

Objections

An additional point on light pollution should be added to criterion b) of the policy (CPRE).

Support

Historic England welcomes and supports the inclusion of criterion b) of the policy as part of the positive strategy for conserving and enjoying, and a clear strategy for enhancing the historic environment as required by the NPPF. (Historic England).


Representations on Policy CF3: Loss of a Community Facility

Number of representations on policy: 2

Objection: 0

Support: 1

Comment: 1

Support

The Theatres Trust Welcomes and Supports this Policy.

Comment

In order to be effective, Draft Policy CF3 needs to provide the necessary flexibility to respond to the changing needs of public services providers to continue to ways of providing for such services, including the loss of a facility no longer needed. On this basis, the current draft Policy CF3 is considered unsound as it is not effective in recognising the role of public services and how they function. The requirement for a 12-month marketing assessment to prove that a facility is surplus to requirements can be inappropriate and unhelpful to public service providers such as the County Council. The "loss" of any County Council facility is preceded by a considered assessment that, where it provides a statutory public service, includes an alternative provision strategy that will satisfy criteria (a), (b) and (c) of the draft Policy.

In order for Policy CF3 to be sound, it is recommended that it is amended to distinguish between commercially-run and publicly-owned or managed community facilities as set out below.

New and Existing Community Facilities:

1. Development proposals for new and/or expanded community facility infrastructure will be permitted where:

a. They demonstrate a local need;

b. The scale of the proposed infrastructure is proportionate to the local area;

c. There has been prior local community engagement;

d. They are accessible and inclusive to the local communities they serve; and

e. Appropriate consideration has been given to the shared use, re-use and/or redevelopment of existing buildings in the host community.

2. Development proposals that would result in the loss of, or have an unacceptable adverse impact upon, an existing community facility, will not be permitted unless:

a. For commercially run community facilities, evidence is provided of a robust marketing campaign of at least 12 months that clearly demonstrates there is no market demand for the existing use or an equivalent community use; or

b. For community- or publicly-owned or managed facilities, it can be robustly demonstrated that there is a lack of need for the existing facility, or an equivalent community use, or

c. Alternative community facilities are provided that are accessible, inclusive and available without causing unreasonable reduction or shortfall in the local service provision. (Hampshire County Council – Strategic Planning).


Representations on Policy CF4: Educational Facilities Outside of the Urban Area Boundary

Number of representations on policy: 3

Objection: 0

Support: 1

Comment: 2

Support

Hampshire County Council as a landowner and a public service provider support intentions of the policy in particular paragraph 8.22-8.23. (Hampshire County Council – Strategic Planning).

Comment

With the links to Policy to CF6 and in order to be found sound, we request that the supporting text of Policy CF4 acknowledges the role of Section 77 of the School Standards and Framework Act 1998 (5) when it seeks the development of school playing fields to rationalise its land holdings as a means of financing recreational and educational improvements. (Hampshire County Council – Strategic Planning).

Criterion b) of the draft policy should be amended to allow for comprehensive redevelopment of school facilities or intensification of an existing education use, such as the colocation of schools of significant expansion of a school if justified in the future due to rising populations. This would ensure a positive approach and that the policy is flexible, whilst taking account of an appropriate scale in relation to school development, recognising that each case must be considered on its own merits (The Education and Skills Funding Agency).

The ESFA supports criterion d) of the draft policy in respect of the loss of playing fields on educational sites will only be justified if they are surplus to requirements or will be adequately replaced elsewhere. The supporting text should include further details on what adequately replaced may constitute. For example, a slight reduction in quantity if justified by improved quality and/or accessibility (The Education and Skills Funding Agency).


Representations on Policy CF5: Green Infrastructure

Number of representations on policy: 7

Objection: 0

Support: 5

Comment: 2

Support

Campaign for Rural England supports this Policy.

Hampshire County Council Countryside Service supports these policies which seek to protect rights of way from fragmentation and harm, unless suitable mitigation is provided (Hampshire County Council).

The Environment Agency supports the inclusion of this Policy

Historic England welcome and supports the reference to the (historic) Forest of Bere in paragraph 8.29.

Natural England fully support this Policy (Natural England)

Comment

Natural England advises that the Plan should include policies to ensure protection and enhancement of public rights of way and National Trails, as outlined in paragraph 75 of the NPPF. Recognition should be given to the value of rights of way and access to the natural environment in relation to health and wellbeing and links to the wider green infrastructure network. The plan should seek to link existing rights of way where possible, and provides for new access opportunities. (Natural England).

Policy CF5 (Green Infrastructure) and its supporting text discusses the role of green infrastructure. The historic environment and heritage can have a positive role within green infrastructure and green infrastructure can have a positive role in enhancing the heritage and its enjoyment. This is not acknowledged in the policy wording of Policy CF5. For example the use of open space to protect heritage assets and or their settings, the use of heritage assets within green infrastructure to promote access and enjoyment, the relationship between historically established biodiversity (such as hedgerows and green lanes) with historic landscape character. The ability to use green infrastructure to conserve and enhance access and enjoyment to heritage assets might be acknowledged within the supporting text of policy CF5 towards revealing a positive strategy towards the heritage (Hampshire County Council – Archaeology).


Representations on Policy CF6: Provision and Protection of Open Space

Number of representations on policy: 6

Objection: 0

Support: 2

Comment: 4

Support

Hampshire County Council supports this Policy.

Natural England fully support this Policy.

Comment

The current wording of Policy CF6 is unsound as it is not sufficiently flexible to respond to the needs of public service providers and local stakeholder plans. In order to be sound, HCC requests that the supporting text acknowledges the role of section 77 of the School Standards Framework Act 1998 when it seeks the development of surplus school playing fields to rationalise its land holdings as a means of financing recreational and educational improvements. A Suggested wording is presented to be included as supporting text to Policy CF6 "In the circumstance where the Education Authority has received approval for the disposal of surplus school playing fields from the Secretary of State, in accordance with Section 77 of the Schools Standards and Framework Act 1998, an exception may be made to this policy where equivalent or greater community benefits are provided". (Hampshire County Council – Strategic Planning).

We are concerned that the Council has not set out the specific space requirements for new development within this policy but is proposing to set these out in Supplementary Planning Guidance (SPG). This is not appropriate as SPGs should be used to provide guidance as to the implementation of a policy not set out specific policy requirements. The provision of specific open space standards will impact directly on the delivery of a development, and potentially its viability and so must be considered as being a policy for the development and use of land. As such it is considered essential that specific requirements for an applicant must be tested through the examination in public and not left to be outlined in SPD.

A similar situation was recently considered in the case of William Davis ltd and other vs Charnwood BC. This decision quashed elements of an SPD that provided detail that should have been included in policy as they could be used in the determination of a policy. They were intended as more than guidance for its implementation and need to have been tested at through the Examination in Public. (Home Builders Federation).

Historic England would welcome and support the inclusion of "of historic significance" in the list of potential attributes of open spaces in paragraph 8.33. (Historic England).

The plan should avoid building on open space of public value as outlined in paragraph 74 of the NPPF. (Natural England).



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