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Evidence Base Summary Comments

Objections

Support

Comment

Representations on the Evidence Base

Number of representations on Evidence Base: 39

Objection: 21

Support: 1

Comment: 17

Objections

Settlement Boundary Review

Concern over the proposed revision to the urban area boundary for WW7 (Sherwood Gardens). The proposed revision should be deleted. The assertion that the road has anymore permanence that any dwelling on this side is erroneous.

The review should allow for the increase in the amount of employment development at Daedalus as referenced in page 136 of the Landscape Assessment. It is inappropriate to include exclude the Daedalus employment area outside of the urban area and include the land as part of the Strategic Gap (The Fareham Society).

Object to the proposed boundary for WW9 (Land at 50 Newton Road). Amendment to the proposed boundary requested to include the rear of 46, 48 and 50 Newton Road (as shown on submitted map) to ensure the physical boundary is recognisable and likely to be permanent as stated in the NPPF.

Burridge is a sustainable location and should therefore have an urban area boundary. Both sides of Botley Road and Burridge Road should be included within the urban area boundary (as shown on submitted map). In addition, the Inset Map of Local Plan Part 2 illustrates the location on areas where there are special characteristics such as strategic gaps, SSSI and there is an absence of these in Burridge. The 1987 Whiteley Local Plan recognised that Burridge already had a 'semi-rural character' and could accept further residential development.

In the interests of consistency and equity, Fareham Borough Council is requested to amend the DUSB in respect of the permitted private garden land to the south of number 44 Thornton Avenue. This is to be incorporated in the urban area of Warsash, in line with the attached plan contained within this representation.

It is incorrect for the Council to consider the northern half of the land to the west of Anchor House to be within the Defined Urban Settlement Boundary (DUSB) but not the southern. There is no physical feature between north and south to justify the DUSB between them. Instead the DUSB should follow the tree-lined boundary along the southern edge of the site as it is readily recognisable and likely to be permanent. The proposed amended boundary is attached with this representation.

Strategic Housing Land Availability Assessment

Object SHLAA Ref 2890 should be discounted for the following reasons: Access to the site is a private road, 24 houses would be totally out of character with the surrounding area- density of the scheme should be lowered. Site is within the countryside and is adjacent to Holly Hill Nature Reserve.

Object SHLAA Ref 3012 should be discounted for the following reasons: Site is on a private road, site is located next to Holly Hill Nature Reserve, the site is a defendable barrier to the countryside. Any development would be out of character with the surrounding area.

Object SHLAA Ref 3050 should be discounted for the following reasons: Site is on a private road, 49 dwellings on the site would be totally out of character with the surrounding area. The site is located near to a Site of Importance for Nature conservation and is located in the countryside.

SHLAA ref 31 this site is not considered to be within an area defined as a 'valued landscape' and as such not in an area of high landscape sensitivity as stated in the SHLAA. (WYG on Behalf of Bargate Homes Ltd.)

SHLAA ref 31 – due to the limited opportunities for publicly available views of the site from public footpaths within the Meon Valley and the small magnitude of change that would occur within those views as a result of proposed developments, the assessment that the site is in an area of high visual sensitivity is disputed. (WYG on Behalf of Bargate Homes Ltd.)

Housing Evidence: Overview Report (2017)

The housing requirement does not provide sufficient flexibility given the likely increased requirements as a consequence of the standardised OAN methodology and meeting wider HMA needs.

South Hampshire Strategic Housing Market Assessment (SHMA)

The projections methodology underpinning the PUSH SHMA which informs the housing need for the Borough does not enable calculations of probability, standard errors or confidence intervals and cannot be calculated for the household projections and therefore in all probability have inaccuracies. As a result, the housing figure the draft Local Plan is working towards may not be an accurate depiction of reality. Furthermore, leaving the public consultation on the PUSH SHMA figures till Fareham's draft Local Plan consultation stage is too late in the planning process. There is no meaningful opportunity at this point for the public to realistically challenge the PUSH SHMA figures (which the draft Local Plan is based upon).

Infrastructure Delivery Plan

There is not enough land provision in the Borough for extra roads or capacity to expand existing roads. There is a lack of school places and doctor's surgeries to accommodate the pressure that will be created by additional development.

There is not enough emphasis on improving the public transport network.

There is not enough detailed information to enable a proper understanding of the impact of the development of the individual site allocations.

A proper infrastructure plan is needed / concern that such a plan has not been published to identify infrastructure needs and costs which will need to be provided up to 2036. This would ensure sustainable community living, including safe roads and adequate provision of schooling (as examples) before schemes can be properly outlined.

This does not demonstrate that the required infrastructure is known in sufficient detail and will be provided when required (The Fareham Society)

Concern that this makes reference to CIL funding for several categories of infrastructure that are not currently included on the CIL 123 List (e.g. Fire Station re-provision / library provision). The CIL 123 List should be updated urgently to incorporate contributions towards the provision of additional facilities (The Fareham Society)

The CIL 123 List should include the provision of health facilities and use the formula proposed by the CCG within the Draft IDP for calculating contributions (The Fareham Society)

This doesn't include enough detail on costs or funding for proposed new facilities (e.g. schools and health provision)

Employment Land review

It is understood that a more detailed scoring assessment of individual employment sites to be retained or discounted for protection for employment purposes is to be produced at the Reg 19 stage of the Local Plan. It is requested that a detailed scoring assessment is undertaken separately for Cams Hall and the wider business park within the Cams Estate; so that fair consideration can be given as to the suitability of Cams Hall for employment retention. It is also requested that further information is disclosed on the assessment criteria used as part of this scoring process. It is our view that Cams Hall in isolation, is not a strategic employment site for the Borough and that there is a desire within the market for other users to be considered to ensure the conservation of Cams Hall in the longer term. (Wilky Group Ltd)

Transport Assessment

Welborne is not included in the 2036 baseline for the Transport Assessment (TA) and as such, does not form a credible baseline against which the incremental traffic impacts of the proposed site allocations can be compared. Despite the TA stating the M27 all-moves junction 10 is included within the model, it is not included in any of figures within the assessment.

Many of the Figures are of poor quality and do not include Portchester and Stubbington/Hill Head which will be significantly affected by the local plan allocations.

There is insufficient information to enable comparisons of actual flows of traffic. There should be actual flow figures for the 2015 baseline, so that comparisons can be made with the 2036 actual flows demonstrated.

There would be an expectation of congestion being shown off M27 Junctions 9 and 10 in the pm period as well as the am.

There is insufficient information and explanation of what the modelling outputs show. Improved clarity is required.

Housing Site Selection Paper

States that sites such as HA10 Funtley Road South have medium landscape sensitivity but the Landscape Assessment assesses the whole of the Upper Meon Valley as having high landscape sensitivity. The Landscape Assessment does not reflect the statement made in the Housing Site Selection paper, it does not identify any parts of the valley as having medium landscape sensitivity.

Landscape Assessment

The Fareham Landscape Assessment describes area 6.1 as a 'crucial role in defining the natural limits to growth of settlements to the north and east, preventing further sprawl into open countryside to the west of Stubbington and south of Titchfield and Fareham and the potential coalescence of these settlements.' This is a generalisation because the whole of area 6.1 is not essential to prevent either physical or visual coalescence.

The 2017 assessment compared to the 1996 assessment does not acknowledge to the same degree the variety in character and landscape quality that exist across the character area 6.1 (WYG on Behalf of Bargate Homes Ltd.)

Sustainability Appraisal / Strategic Environmental Assessment / Habitats Regulations Assessment

Some concern relating to whether an environmental assessment has been undertaken

Sustainability Appraisal

Noted that the Site Options Assessment notes that there are fourteen non-listed historic buildings on Daedalus East (Faraday) and six on Daedalus West (Swordfish). Its considered there should be a further assessment of the historic significance of these buildings, ideally before this site goes forward and certainly before any demolition is allowed, and that this requirement should be reflected in these policies (Historic England).

Equalities Impact Assessment

Noted that this states contributions towards local childcare facilities, primary and secondary schools will only be collected for schemes totalling 100+ dwellings

Green Space Study

There is no provision mentioned for horse riders in the draft local plan.

Support

Settlement Boundary Review

The proposed changes to the Urban/Settlement Boundary is supported. (Titchfield Neighbourhood Forum).

Transport Assessment

HCC support the methodology of the Borough Council in preparing an interim Transport Assessment (TA) and the use of the Sub Regional Transport Model (SRTM) to assess the wider transport impacts of the strategic disposition of proposed development across the borough. The purpose of the TA is to identify those key locations on the transport networks where impacts have been predicted by the strategic model as a focus for further investigation and to identify potential mitigation measures to deal with significant impacts. It should be noted that the use of the SRTM and the TA assessment is focused at a strategic level and intended to identify potential strategic transport infrastructure obstacles to successful delivery of the development levels proposed in the local plan review in combination. The TA and this response do not concern themselves with the localised traffic and transportation impacts of each development site and these will need to be assessed by site or cluster specific TAs that can be prepared in full knowledge of the detailed characteristics of each site and its surroundings. (Hampshire County Council – Highways Authority)

Comment

Settlement Boundary Review

The boundary has been amended to include the houses and gardens of Farmhouse Close and 16B and 16C Lychgate Green. The review should also include 16A and 17 Lychgate Green.

The Titchfield Neighbourhood Forum propose an extension to the Urban/Settlement Boundary to include most of Southampton Hill- See plan attached with representation. (Titchfield Neighbourhood Forum).

Proposes the inclusion of Chapel Road and Spring Road in Sarisbury as part of the urban area boundary. This part of Sarisbury Green is a sustainable location and the absence of this land from the urban area boundary would prevent the delivery of sustainable residential development.

Strategic Housing Land Availability Assessment

This document does not take into account the Air Quality issue that exists in the Borough. Potential development sites should be assessed against the contribution to the air quality problem. Certain SHLAA sites such as SHLAA ref 27 act as important pollution sinks and this should be taken into account within the SHLAA document.

SHLAA Ref 3102 this site is Available, Achievable and Suitable for residential development. The supporting information justifies this. (Foreman Homes Ltd).

SHLAA Ref 3050. The site has been classed as suitable in the SHLAA and has received a good Sustainability Appraisal (SA) score. Alternative less sustainable sites (according to the SA) have been chosen above this site such as HA10, HA18, HA5 and HA12. It is argued that this SHLAA site constitutes a more appropriate site for residential allocation than several of the proposed allocations namely those identified above. (WYG on Behalf of Bargate Homes Ltd).

SHLAA Ref 2890 should be listed as discounted in the SHLAA for the Following reasons. The area is considered countryside and is adjacent to Holly Hill Nature Reserve. The access to the site is on a private road. An application for 2 dwellings on the site was refused and dismissed at appeal, the inspector concluded that 'the proposal would be detrimental to the character and appearance of the countryside'.

SHLAA Ref 1336 and 3103. Both these sites are considered Available, Achievable and Suitable and should be included within the Local Plan to meet the Hosuing needs of the Borough (Foreman Homes Ltd).

Parking provision and the number of cars associated with each potential development should be included within the SHLAA Assessment.

Housing Site Selection Paper

It is not clear how the site selection priorities/refining points have been used. There is no discernible difference between the summaries for sites selected and those rejected. It would be beneficial to have a table for each site showing how the score against each priority/point is included. There is an issue with using point 7 relating to highways impacts because there is no reference to the interim Transport Assessment in the list of evidence. Questions raised about how the comments regarding point 7 being made and what evidence is behind these comments. In some cases, point 10 relating to 'provide and maintain a defensible urban edge following development does not appear to have been used.

There is no reference to the assessment of high, low or medium potential in the Housing Site Selection Paper.

Infrastructure Delivery Plan

Recommended that further information is added to the IDP on the provision of education for 16-19 year olds. Table 3 sets out the phases and types of education considered as infrastructure, but could be amended to include 16-19 phase, or reference made to this having been included within the secondary phase. Tables for secondary education also appear absent from the IDP (Education and Skills Funding Agency)

Table 7 sets out the detailed infrastructure requirements and planned infrastructure projects, including the need for school expansions by settlement and the numbers of primary school places generated by proposed development in that area. Presumably there is not sufficient capacity in secondary schools to absorb all housing growth in the plan to 2036. The new housing will also generate pupils requiring a place at a special school, about which the IDP is silent (Education and Skills Funding Agency).

As well as being informed by the Hampshire School Places Plan, the IDP should provide sufficient detail on the longer-term expectation of all education needs and provision costs associated with the Local Plan period to 2036 (Education and Skills Funding Agency)

Would be useful if a Planning for Schools topic/background paper could be produced, expanding on the evidence in the IDP and Hampshire County Council's School Places Plan, setting out clearly how the forecast housing growth at allocated sites has been translated (via an evidence based pupil yield calculation) into an identified need for specific numbers of school places and new schools over the plan period. This would help to clearly demonstrate that the approach to the planning and delivery of education infrastructure is justified and based on proportionate evidence (Education and Skills Funding Agency).

HRA Screening Report

Report considers the New Forest SPA/SAC/Ramsar sites. Would like to highlight the importance of taking a cooperative and strategic approach to help ensure designated international nature conservation sites are avoided. (New Forest District Council).

Planning Obligations SPD

Noted that this sets out the Council's approach to securing infrastructure through CIL and developer contributions. Recommended that a light touch review of this SPD is undertaken to reflect the latest planning policy at the local and national level with regards to ensuring education contributions made by developers are sufficient to ensure the additional school places required to meet the increase in demand generated by new developments (Education and Skills Funding Agency).

Also noted that this SPD currently includes very little reference to education and a review of this document will be an opportunity to clarify how the council would approach onsite delivery of new schools where these are necessary to make development acceptable in planning terms. Alternatively, more detail could be provided in the Local Plan. Where a planning obligation is considered the most effective mechanism for securing appropriate developer contributions for education, this should include the free transfer of land to the County Council and contributions to construction that are commensurate with the school places generated by the development (Education and Skills Funding Agency).

The Council policy on seeking contributions should also align with Hampshire County Council's guidance: 'Developers' contributions towards Children's Services facilities'.

Habitats Regulations Assessment and Strategic Housing Land Availability Assessment

It is noted that Paragraph 0.3.5 of the HRA Screening Report states that none of the proposed allocation sites is an 'important' site, as per the 2010 strategy. However, the site classifications have been revised and whilst none of the allocation sites is a Core Area or Primary Support Area, some of the sites are Secondary Support Areas or Low Use sites (SHLAA Refs: 207, 3028, 3114, 3113). This needs to be reflected in the HRA and those SHLAA sites. Mitigation and off-setting requirements will be necessary for these sites as they are integral to the ecological network within the Solent. (Natural England).

Strategic Housing Land Availability Assessment

Consideration will need to be given to land take associated with all sites included within the updated SWBGS as well as recreational pressure arising from development adjacent to sensitive sites. For example, site 3014 is located adjacent to a Secondary Support Area. (Natural England).

Renewable and Low Carbon Energy Capacity Study

The plan showing the areas of least constraint for Solar energy has included some sites identified as Secondary Support Areas in the forthcoming update of the Solent Wader and Brent Goose Strategy. We would advise that this plan is updated in due course in line with the forthcoming SWBGS maps. (Natural England).

Habitats Regulations Assessment

Natural England usually advises that any local plan HRA can refer to the agreed Water Resources Management Plans (WRMPs). However, the HRA for Southern Water's extant WRMP cannot be relied upon to ensure there will be no adverse effects on designated sites arising from future development within Southern Water's area. In addition, the risk of adverse effects remains until the deficit in public water supply resultant from the licence changes is fulfilled by alternative options and or the compensatory habitat requirements are met. (Natural England)

Natural England and the Environment Agency have been working closely with the PUSH authorities with regard to the Integrated Water Management Study for South Hampshire. The assessment has identified that there is a gap in evidence and therefore some uncertainty with regard to achieving the full development growth throughout the plan period. Continued joint working will be needed and that there may be a need for mitigation to accompany development during the later stages of the PUSH plan period. This may require new development to ensure it is 'nutrient neutral', which could be delivered via a Nutrient Management Plan (NMP). At this stage, Natural England recommends that water quality issues are included within the local plan HRA screening assessment for further examination. (Natural England).

Paragraph 6.1.2 states that 'Allocations which are retained from the DSP Plan (adopted June 2015) have already undergone HRA during preparation of that plan are not considered again in the current HRA'. It is important to carry out a screening review of the allocated sites retained from the DSP Plan. This is to confirm if there is any new evidence that changes the conclusions and requires further consideration. One example of new evidence would be the forthcoming updated Solent Wader and Brent Goose Strategy and the Bird Aware Definitive Strategy. For example, we would recommend that housing allocation 3119 is reviewed in the HRA Assessment. (Natural England).

Green Space Study

Whilst development occurs in Fareham and the neighbouring authorities leading to pressure on the existing infrastructure, it is important to retain small fingers of green space for natural habitats and well-being of the area. 

Ensure open spaces are afforded maximum protection and provide a continuous countryside facility for people and nature to thrive in.

The Open Space behind Fareham College should be retained. It provides a respite to the students of the college as well as local residents. It would serve as an excellent area to hold events and competitions as well.

The Open Spaces in Titchfield Common are essential for the residents Borough and should continue to be retained.



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