The South East Plan (now scrapped because of changes in Government policy) included a package for South Hampshire intended to ‘pump prime’ economic development. This development was in response to a perceived need to address deprivation in Portsmouth and Southampton.
The Local Development Framework (LDF) is a set of planning policies and proposals that will underpin development and land use in the Borough on a twenty-year time scale. It should be able to answer questions like where new houses, hospitals, schools, offices and shops should be built to cope with expected growth. The policies of the ‘Core strategy’, which have been rolled out in stages, have had to recognise key principles of the South East Plan.
The most significant element of the core strategy for our local plan was a policy proposal for the North Fareham Strategic Development Area (SDA). A second SDA within the over-arching structure plan was proposed for Hedge End to serve economic needs to the west (Southampton).
When the main structure plan was scrapped the imperative for the SDA’s evaporated – a result which Hedge End were quick to accept and their SDA was binned. Fareham, on the other hand, has decided to press ahead despite a growing list of objections from a number of groups.
LDF/SDA as Outlined in 2009
Local Development Framework and The Strategic Development Area
1. The LDF seeks to identify how Fareham will be developed between now and 2026. In particular, it addresses how the Government’s house building and job creation targets will be met and on which sites development will be allowed. The good news for Wallington, is that the village sites previously identified in the LDF for potential development (Gauntlett’s field, Pinks Hill and land at the junction of North Wallington/Standard Way) have now been dropped from the latest version of the LDF. The reason for this is because FBC aim to achieve their targets by using existing “brownfield” sites, together with the SDA itself; the latter will be the only “Greenfield” site on which new development will be permitted.
2. The (North of Fareham) SDA is a major new development of up to 10,000 houses, with associated schools, community and employment facilities that will be built between Fareham and Wickham in the period 2016 – 2026. Although the exact boundary of the SDA has yet to be agreed, it will however straddle both sides of the A32, will reach from the M27 up towards Wickham and will encircle Funtley and Knowle. Currently it is not clear how much of the SDA will be to the East of the A32 (i.e.: on our side of the Wickham road). It is likely that a new access road will be built from Junction 11 of the Motorway to serve as the primary access route in/out of the SDA. In order to limit the traffic impact of the SDA, major improvements to public transport are intended, including a Bus Rapid Transit (BRT) system which will link the SDA with Gosport, Fareham and Portsmouth and the use of Junction 10 of the motorway as a priority route for buses and High Occupancy Vehicles (HOV’s).
3. Depending on exactly where the boundaries of the SDA are finally drawn, this massive development will potentially have a significant impact on our lives in the future. Accordingly and as a part of an ongoing consultation process, the following comments on the LDF and SDA proposals have been submitted by WVCA, in order to try and minimise the impact on the Village.
Note: The LDF/SDA documents on which these comments are based are contained on the FBC website and can be accessed by using the following link: www.fareham.gov.uk/council/departments/planning/ldf/cssreport.asp
Initial WVCA Response
A) EMPLOYMENT/SUSTAINABILITY – Whilst the concept of sustainable employment is fully supported, the reality is that unless firms moving into the SDA are incentivised to employ those actually living there, then the concept becomes ineffective. Fundamentally, employers will retain the right to recruit the most suitable employees and in practical terms the sustainable employment concept of the SDA is un-enforceable. Accordingly “worst case scenario” data ought to be used when calculating daily commuter traffic in/out of the SDA.
B) DEVELOPMENT CONTROL POLICY (DCP)2 – States …….that the SDA “ought not detract from the surrounding countryside, landscape quality, skyline etc”. Specifically, how can the impact of the SDA on the countryside views currently enjoyed by residents in North Fareham (The Meadows/Furzehall Avenue and Wallington), be minimised?
C) DEVELOPMENT CONTROL POLICY (DCP)4 – A “Downstream Flooding Impact Assessment” needs to be conducted by the Environment Agency in order to ensure that the SDA does not exacerbate the existing flooding problems in Wallington (Background and rationale as per the deputation made by WVCA to the LDF Steering Group Meeting on 14th Jan 09)
D) INFRASTUCTURE – Primary access to/from the SDA via J11 of the M27 carries significant risks. The junction is already at or near capacity and traffic volumes are increasing year on year; accordingly its ability to absorb the additional SDA related traffic is questionable and this may have the effect of effectively “grid locking” the eastern part of Fareham town centre during peak times. (See also TRANSPORT at Para I)
E) GREEN BUFFER ZONES – The proposal (North of Fareham SDA Para 1.46) to provide Open Space between the SDA and existing settlements (Funtley, Knowle, Wickham and the North of Fareham) is fully supported. This issue becomes particularly important with regard to the land/floodplain in the vicinity of M27/J11 and options regarding the “re-alignment” of the A32 in order to provide access to/from the SDA need to take serious account of this issue. (Deputation at Para C above also refers)
F) HOUSING PROVISION – Particularly given the current difficulties in the housing market, the principle that any shortfall in SDA housing provision will NOT have to be compensated for by an uplift in Fareham’s provision, is fully supported (Housing paper – Para 1.7) Similarly supported, is the LDF policy that the Fareham specific housing target will be met from within existing urban areas and the only element of building allowed on Greenfield sites between now and 2026, will be within the SDA itself.
G) SUSTAINABLE URBAN DRAINAGE SYSTEM (SUDS) (North of Fareham SDA Para 1.52) – This principle is fully supported and takes on particular significance given that the current proposals imply that a significant element (75%) of the employment/business infrastructure supporting the SDA will be to the East of the A32. All of this land drains ultimately into the River Wallington and stringent mechanisms will need to be put in place to ensure that flooding and river quality issues are not jeopardised. Additionally, the area on either side of the River Wallington and north of the Motorway adjacent to Junction 11 forms part of the Wallington Floodplain as designated by the Environment Agency. (Deputation at Para C above also refers)
This issue is recognised in part, by the Environment Agency in the Infrastructure paper at Para 1. 14, and the Agency are on record (in previous correspondence with WVCA) as stating that the policies contained within PPG 25 apply to this area.
H) PERCEPTIONS/IMPACT OF THE SDA – Until such time as the boundary of the SDA is identified, local people find it extremely difficult to understand/visualise what the impact will be. Whilst the reasons for this lack of clarity in the early stages are appreciated, a point in time will be reached at which FBC will become accountable (in every sense, including political) for the decision/agreement to build, on totally unspoilt countryside; albeit in pursuit of Government derived housing targets. Despite what is a very comprehensive and commendably informative website, I would suggest that the vast majority of Fareham residents have a very limited perception of what the impact of the SDA will be. This will represent a significant PR challenge, the extent of which needs to be recognised.
I) TRANSPORT – Noting that the SDA is projected to generate very significant traffic levels and that re-alignment of the A32 to J11 will have a high financial and environmental cost (1.25) this potentially strengthens the case for treating the re-alignment of the A32 as an essential pre-requisite before ANY part of the SDA is developed. In similar vein, given that J11 and indeed other Motorway junctions will be at or in excess of their capacity by 2016 let alone 2026 (1.28), then regional funding to address these issues ought also be considered as a prerequisite. Additionally, the suggestion (Infrastructure Para 1.6) to investigate M27 traffic management options and to examine the future loading on Junctions 9/10/11 is fully supported.
J) ENVIRONMENTAL/BIODIVERSITY IMPACT OF THE SDA – The Natural Environment paper correctly recognises (Para 1.42) that development of the SDA will result in the loss of large areas of countryside and some of the best and most versatile agricultural land; the impact of which has yet to be quantified. As a means of ameliorating this loss, it is for consideration that either regional funding and/or developer contributions ought be sought, in order to carry out environmental improvement and enhancement programmes on the fringes of those areas encroached upon by the SDA.
K) PROVISION OF OPEN SPACE – Table 1 (Natural Environment – Para 1.28) clearly shows a significant under-provision of Open Space for the residents in North Fareham & Wallington. The existing footpaths from Wallington Watermeadow towards Spurlings Farm and from Broadcut (over the M27 footbridge) towards North Fareham Farm, which currently provide access to the countryside beyond, go some way to ameliorating this shortfall. Accordingly, this issue serves to highlight the fundamental importance not only of the Buffer zone (see also Para E above) between Fareham/Wallington and the SDA, but of linking these footpaths to the open spaces being planned within the SDA itself.
On the 18th November 2010 there was a meeting of the full Borough Council at which it was proposed that the SDA at North Fareham be endorsed in principle. WVCA concerns over this potential development have been laid out in editions of the OIAW over the last two years and on this website.
David Walton made a deputation on our behalf at that meeting and also represented the Wickham Society, Knowle Residents’ Association and CPRE. The following is a synopsis.
Whilst it was accepted that some development would be necessary, he argued that there was a fundamental need to ensure that we did not build unnecessarily on some of the best agricultural land in the County and equally, that we did not adversely affect existing Residents in the process.
The two options seemed to be either:
Based upon Fareham’s own Housing requirement, having regard to issues of size, footprint and the infrastructure funding guarantees before any commitment to the SDA
Firm caveats to be put into the Core Strategy such that when the Area Action Plan (AAP) is prepared a failure to satisfy them should result in the SDA being stopped. It was felt that the caveats currently in place were weak and inadequate.
Throughout what was acknowledged to be a comprehensive and persuasive submission, there was an absolute presumption in support of the SDA - no other options had even been mentioned. This appeared to be at odds with the principle of ‘collaborative involvement of local Community Groups & Neighbourhoods’ shortly to be enshrined within the “Localism Bill”.
Main reasons objections from so many interested groups were:
The M27 Motorway would be at capacity by 2016 and no funding was indicated to carry out supporting works to Junctions 10 and 11. Neither was there any funding (currently estimated at £25 - £40M) in prospect for the new access road to Junction 11.
Although the Bus Rapid Transit (BRT) was assumed vital to the SDA details of its route during the period 2016 – 2021 had not been published nor was there any guarantee of its funding. Both should have been made a pre-requisite before the SDA strategy was endorsed.
It was patently clear that since all the SDA traffic would have to use Junction 10 for the first five years the existing road network in North and East Fareham could not cope with the increase.
The existing road infrastructure was already proving inadequate and that, far from proposing new development in the Borough, attention ought to focus on less development. It should be recognised that Fareham is already over-developed.
HOUSING NEED AND EMPLOYMENT NEED:
The (disputed) Housing Need:
Analysis of the figures within the Core Strategy submission make it clear that what is being proposed is far in excess of Fareham’s own housing need. Over 4,500 of the SDA homes are being built to cater for “inward migration” into the Fareham area. It is not a smart way of meeting affordable housing needs; other options have not even been looked at.
The (disputed) Employment need:
Fareham is one of the least deprived areas in Hampshire and with one of the lowest Unemployment rate and yet it is planned to build a Business Park at Junction 11, two miles from the centre of the SDA and in an area of ‘Special Landscape Quality’.
Objectors felt that the Business Park has a very tenuous relationship with the SDA; it will simply add to the daily commuter traffic on the motorway generally and Junction 11 in particular. A better location would be in one of the “Unemployment Hotspots” in the PUSH [Partnership for Urban South Hampshire] region. This was a view shared by members of both Gosport and Portsmouth Councils, who see it as a potential threat to their own local employment sites).
There was also concern about the fact that so much of the limited employment space within the SDA is being earmarked for B8 i.e. Warehouse use. This actually generates very few jobs but does generate increased levels of vehicle/lorry traffic. This was felt to be another example of a rushed and poorly considered employment plan.
CONSULTATION WITH BOROUGH RESIDENTS
The Community Liaison Group meetings had played a useful part but there was no conviction that the Council had listened to the points that had been raised.
The remainder of the consultation process had been very poor with the result that most people have absolutely no idea about the enormity and impact of what is being proposed. For example:
The primary access road is un-funded and won’t be built until 2021 (at the earliest)
For at least five years all SDA traffic will have to use Junction 10 and therefore the existing road network.
No mention of the massive traffic congestion it will generate or any of the other downsides within the ‘spin’.
THE SDA’S IMPACT ON WICKHAM, KNOWLE AND FUNTLEY.
Wickham is a small and attractive market town of 1,100 homes and one of the jewels in the local crown. Up to 7,500 new houses within ½ mile will totally spoil it. Much of the SDA traffic will turn north out of the SDA - merely adding to the existing congestion.
Knowle and Funtley will be totally overwhelmed and disappear off the map – drowned in a sea of houses.
Wallington concerns include the downstream flooding risk generated by the SDA. Because the footprint of the SDA, the Junction 11 development and the route of the access road have all yet to be determined, the Environment Agency is unable to assess the downstream flooding impact. This is a major issue for Village residents.
The Council should not even consider endorsing such a massive commitment without a very clear and funded plan explaining how the Community, Transport and other infrastructure issues are going to be resolved.
Endorsing the plan under these circumstances would be grossly irresponsible. Fareham residents would be sold down the river in order to satisfy, what began as a PUSH initiative now being passed off as a means of satisfying Fareham’s “Affordable Housing Need” – a need which had neither been properly quantified nor justified within this submission.
On behalf of the following organisations David asked for opposition to the current plans to be placed on record:
Wallington Village Community Association
The Wickham Society & Wickham Parish Council
The Fareham Society
Knowle Village Residents’ Association
Funtley Residents Association
The Portchester Society & Portchester Civic Society
CPRE & SHUV (South Hants Unheard Voices)
THE RESULT AND BEYOND
Regrettably, the final Council vote favoured endorsement of the proposed development despite an exceptional number of objections. The CPRE has been very energetic in its opposition to this deplorable project and launched a postcard campaign - their cover picture forms the heading of this article. In recent weeks over 800 of the CPRE Postcards objecting to the SDA have been received by the Housing Minister and the Council has itself received both several hundred objections and a petition containing over 1400 signatures.
David Walton has worked long and hard with Fareham Society and others on this (depressing) job. Brenda Clapperton, Secretary of the Fareham Society, said in their spring newsletter ‘- The consultants preparing the master plan have now been signed up by the financial backers of the scheme who are a consortium of local landowners. The society has an enormous dilemma because it still objects to this large SDA but feels obliged to study proposals for its future in case they become a reality and not to do so would leave us out of the debate.’
A dilemma indeed! Was it a dilemma for those who voted in favour of the plan? How easily could they reconcile the desecration of an area of outstanding landscape quality with their official conscience?
FBC will forward their SDA submission to the Planning Inspectors and there will be a Public Inquiry in mid 2011, which is our next opportunity to bring common sense to bear. Residents are advised to follow events and take every opportunity to make their opinions known.
Vote of no confidence:
Following the Council meeting on 18th November the Community Liason Groups decided against resigning en masse from the CLG process but recorded instead a unanimous vote of no confidence over the manner in which FBC had handled and consulted on the SDA thus far.
Click here to view “Vote of no confidence”
Submission to Planning Inspectorate
Click here to view “Objection to Planning Inspectorate”
Sustainablility Appraisal Report submitted by Fareham Borough
Glossary: HIGH LEVEL SUSTAINABILITY APPRAISAL
A sustainable plan is a structured course of action that is designed to meet the current needs of those concerned, to ensure that the impact of development on the social fabric of communities is considered and taken into account, while not taking away the needs of future generations. A sustainability plan often involves making the most efficient use of available resources, while also seeking to ensure that the impact for later generations is a positive benefit. (PPS1 refers)
In April 2011 WVCA responded to the Sustainablility Appraisal Report submitted by Fareham Borough along with other documents to the Secretary of State for independent examination in public by the Planning Inspectorate (Public Enquiry in old speak).
The WVCA submission to the Planning Inspectorate contended that:
- The North of Fareham Strategic Development Area (SDA) could not be considered a “sustainable development” and that, accordingly, economic growth ought not take precedence over core sustainability considerations.
- Across all the key areas, namely environment, infrastructure, use of resources and economic sustainability, that the SDA was not a “sustainable development proposal” and that the Core Strategy submission by FBC could not therefore be sound.
To see the full submission and Appendix 1 click here.