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Design Chapter Summary Comments

D1: High Quality Design

D2: Impact on Living Conditions

D3: Historic Environment

D4: Coordination of Development and Piecemeal Proposals

D5: Energy and Water Efficiency

D6: Water Resources

Representations on Policy D1: High Quality Design

Number of representations on policy: 11

Objection: 0

Support: 3

Comment: 8

Support

Supports the Local Plan in Principle.

Historic England welcomes and supports Policy D1 especially criterion a) and paragraphs 10.3 – 10.8 and 10.19 – 10.25 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).

HCC supports point d) in prioritising pedestrian and cycle access. (Hampshire County Council – Highways).

We support HCC's suggestions for the creation of new bridleways as part of the green infrastructure for Welborne. (British Horse Society)

Comment

The area includes a number of drainage ditches which are part of the River Alver catchment. It will be important to understand the impact of any development on potential for surface water flooding in the vicinity and the water quality of the River Alver. (Gosport Borough Council).

It is suggested that FBC amends the supporting text of the policy by deleting text from paragraph 10.13 in relation to the provision of SUDs and substituting with the following text: "All planning applications for major development are required to ensure that sustainable drainage systems are used for the management of surface water unless demonstrated to be inappropriate. All new developments in areas at risk of flooding must give priority to the use of sustainable drainage systems. Details relating to surface water run-off will be addressed should be provided, in accordance with Lead Local Flood Authority Advice, for major proposals and instances involving minor developments where surface run-off is a concern. (Hampshire County Council – Strategic Planning).

Paragraph 10.13 is confusing to the reader as it confuses different aspects of flood risk management. If the intention is for this section to address several different ways of managing various sources of flooding then it needs to be expanded to address each of the separate issues in turn. It needs to be clear that this paragraph is referring only to the management of surface water flood risk within sites. As stated previously in other representations, the inclusion of a flood risk policy should be considered. (Environment Agency).

Historic England would like to see a reference to 'historically significant features' added to 'valued trees' and 'landscape features' in paragraph 10.8 as features to be retained in new development. (Historic England).

We welcome paragraph 10.26 in principle, however, more explanation should be required about what assets are at risk and why, and could be expanded to refer to alternative courses of action to address heritage assets at risk. (Historic England).

Concern over the additional waste that will be created by households from new developments, especially at Welborne. Particularly concerned that the existing facilities, including the household waste recycling centres will not be able to cope with the additional waste and recycling created. A more holistic approach, such as the bring-bank and glass banks should be a requirement of new development.

Hampshire County Council as the waste disposal authority note that there is a very limited mention of waste or recycling within the Draft Local Plan. There should be recognition of the importance of this infrastructure alongside those contained within the document. There is no reference in the supporting text for Policy D1 in respect of the need for infrastructure to process resulting waste material. (Hampshire County Council – Strategic Planning).

Concern that the current Public Rights of Way network in the Borough is fragmented. Thought should be given by the Council as to how connectivity could be re-established to allow non-motorised users to navigate around the Borough, such as creating more shared routes. (British Horse Society).

Concern that there is a lack of bridleways in the Borough and a lack of parking for horse boxes and trailers where there is access to safe off-road riding. Specific issues in the Borough include negotiating the bridleway underpass between Junctions 9 and 10 if the M27, difficulty in accessing the Meon Valley Trail, the impact of the Stubbington by-pass on horse riders and access to Hill Head from Crofton (British Horse Society).

We would request the following new routes:

Multi user routes at footpaths 71b, 74 and 68.

Multi user route around the perimeter of Daedalus.

Mounting blocks to be positions either side of Bridleway 82.

The classification of footpath 37 as a Bridleway.

The creation of footpaths 16, 15 and 86 into Bridleways.

Reduce the speed limit on Whiteley Lane to 40mph.

Creation of a green loop around Welborne to be used by all non-motorised users.

The creation of multi user routes in open space/green infrastructure areas.

(British Horse Society)

Developers have borough sites containing redundant glass houses to use as a land bank to then apply for planning permission for the use of the site for housing. Reference should be made to Section 215 of the TCPA in the supporting text to the policy to ensure that the site is kept/tidied up to a reasonable quality.

The Council should recycle all plastics with a recycling symbol.

The policy should include a requirement for the whole life management and maintenance of any SuDS features installed. In addition, SuDS features should be designed with the additional objectives of enhancing water quality and biodiversity. (Hampshire and Isle of Wight Wildlife Trust).


Representations on Policy D2: Impact on Living Conditions

Number of representations on policy: 2

Objection: 0

Support: 0

Comment: 2

Comment

Any additional traffic on Newgate Lane is likely to have an impact on the Air Quality Management Area (AQMA) at the north end of Newgate Lane and Gosport Road and therefore it would be necessary to include measures mentioned in Policy INF2 specifically to mitigate this impact for this development allocation. (Gosport Borough Council).

The draft policy should include measures/provide incentives on improving air quality. In particularly focusing on the use of public transport such as buses, the use of hybrid and electric vehicles and the use of bikes (including electric bicycles) and walking where appropriate.


Representations on Policy D3: Historic Environment

Number of representations on policy: 3

Objection: 1

Support: 0

Comment: 2

Object

Concern that allocated sites HA1, HA3 and HA7 do not add to local character and distinctiveness.

Comment

A reference should be included to indicate the positive role that heritage plays, and how that role can be protected and enhanced, and how heritage assets can be greater enjoyed by the communities as a result of implementation of planning policy. The County Council's archaeologist notes that the introductory elements of the Local Plan falls short of defining 'positive strategy' to enhance conservation and enjoyment. For instance, the historic environment can have a positive role within green infrastructure and this is not currently acknowledged in policy CF5. (Hampshire County Council – Strategic Policy).

The supporting text does not provide any connectivity with archaeological issues which might arise. For example, paragraph 10.23 does not explore the role of mitigation and archaeological recording arising out of harm identified in a heritage statement and through planning policy. HCC recommend an additional sub-clause to address archeaological recording as a mitigation strategy is added to the policy wording (Hampshire County Council – Strategic Policy).

Greater emphasis should be placed on the policy and supporting text on the presumption of the preservation of significant heritage assets and harm to nationally important heritage assets being 'wholly exceptional' as referenced in the NPPF (Hampshire County Council – Strategic Policy).

Policy D3 goes some way to fulfilling the NPPF requirements, however, Historic England have a number of concerns related to the Draft Policy. Clarity should be provided in the policy that development proposals which would harm the significance of a designated heritage asset, including the special interest, character and appearance of a Conservation Area, will only be permitted where that is the case or in the circumstances listed in the NPPF. (Historic England).

A development management policies or policies should be included in the Local Plan setting out the requirements of development proposals and providing a clear indication of how a decision maker should react to a development proposals as required by paragraph 154 of the NPPF. This policy should include criteria for assessing the potential impact of development proposals on the significance of all relevant heritage assets. The policy/policies should reflect the requirement in paragraph 132 of the NPPF that any harm or loss of a heritage asset should require clear and convincing justification, most often in the form of public benefits. The policy should also identify those particular characteristics of each type of heritage asset that should be protected or enhanced through development proposals. (Historic England).

We consider the Plan fails to set out an adequate positive strategy for the conservation and enjoyment of, and clear strategy for enhancing, the historic environment as required by the NPPF and is therefore not sound in this respect. (Historic England).

The Council should assess whether or not it should identify any areas where certain types of development might need to be limited or would be inappropriate due to the impact that they might have upon the historic environment, this may include tall buildings. (Historic England).

A new policy specifically tailored to listed buildings should be added to the Plan to provided even greater protection to listed buildings, specifically for the Town Centre sites and a number of the allocated sites in the plan (Historic England).


Representations on Policy D4: Coordination of Development and Piecemeal Proposals

Number of representations on policy: 2

Objection: 0

Support: 2

Comment: 0

Support

HCC as a landowner and public service provider supports the intentions of the policy because it is effective in delivering comprehensive development (Hampshire County Council – Strategic Planning).

GBC supports Policy D4 which aims to ensure a coordinated approach to development, and may be applicable to the development of sites such as Daedalus (Gosport Borough Council).


Representations on Policy D5: Energy and Water Efficiency

Number of representations on policy: 4

Objection: 0

Support: 1

Comment: 3

Comment

It is inappropriate that the Council will consider more favourably development that go beyond the requirements of those set out in the Building Regulations. The Council should support development wherever it meets the policy requirements set out in the Local Plan as such paragraph 10.35 should be deleted. (Homes Builders Federation).

Southern Water supports FBC's intention to achieve standards of '110 litres per day', but would suggest there is possibly a typographical error and this should state '110 litres per person per day' in order to be consistent with Building Regulations. Furthermore, to ensure sustainable development, Southern Water would more strongly support the target for water efficiency if it could be applied to all new development within the Borough, rather than solely within areas where there are presently water supply issues. This approach is supported by the NPPF. Suggest removal of 'that are located where there are water supply issues' be removed from policy wording. (Southern Water).

Legislation should be passed that requires all new homes and industrial buildings to have mandatory solar power systems capable of delivering 2500kWh per annum. Electricity, gas and water are precious and more costly to provide.

Abstraction from the Rivers Test and Itchen has to be reduced to maintain water for conservation.

Legislation should be passed to ensure higher standard of home insulation is needed to save energy.

Support

We support the inclusion of the higher water efficiency standards in this policy this is important not only to help water supply but also for protection of the environment, both species and sites that rely on certain water levels to thrive. There are also key links with foul water disposal, the amount of water that is treated at wastewater treatment works and therefore the capacity of these works to accept new flows. (Environment Agency).

We welcome the adoption by the Borough Council of the optional water efficiency requirement of 110 litres per person per day (l/pppd), which exceeds the Building Regulations requirement of 125l/pppd. We note that the policy states that such measures will be implemented 'where there are water supply issues'; taking a regional view of water resources management would suggest that this definition should apply across the south east, rather than being dependent upon water company boundaries (the 'water stressed' designation). It would seem short-sighted to allow greater water wastage in parts of the Borough simply because the water there is supplied by a different company whose resources are considered to be more reliable. (Hampshire & Isle of Wight Wildlife Trust).

Local Plans should acknowledge the uncertainty around delivery of water resources over the plan period. Whilst it is not the LPA's remit to plan to deliver water resources, policies requiring a high standard of water efficiency and re-use should be adopted within the Southern Water area. Consideration should be given to the use of grey water recycling, efficient appliances and to include policies that encourage the wise use of water in conjunction with the water companies. (Natural England).


Representations on Policy D6: Water Resources

Number of representations on policy: 4

Objection: 1

Support: 0

Comment: 3

Object

Concern over the consumption of water in the Borough. Abstraction from the Rivers Test and Itchen should be reduced to conserve water.

Support

We welcome the recognition of the need to protect and enhance waters within the Borough, which is in line with the requirements of the Water Framework Directive. The lack of reference to this EU Directive suggests that the Local Plan will seek to protect water resources regardless of the situation post- Britain's exit from the European Union; a commitment which we warmly welcome. (Hampshire & Isle of Wight Wildlife Trust).

Comment

We are pleased to see the inclusion of this policy but we feel that it should be subsumed into a more holistic water policy that looks at water quality as well as resource. We are especially pleased with the reference to the River Basing Management Plan. The policy makes reference to waste water and the supporting text considers water quality. We feel this should all be compiled into a strong overarching water policy that provides strong guidance on how water as a whole should be considered in new development (Environment Agency).

Development should follow the Building Regulations H3 (3) requirement to follow a drainage hierarchy, whereby surface water is dealt with separately from foul as a priority, which is line with Southern Water's aim to promote the efficient and sustainable use of water resources and waste water assets. (Southern Water).

The policy fails to address issues of water stress in Southern Hampshire. Historically plans were prepared for the construction of a long-term water storage reservoir south of Romsey, which has not been constructed. Without this water storage, it is unlikely that there will be sufficient water available for the population of Fareham.



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