REPRESENTATIONS ON MAJOR MODIFICATIONS – WELBORNE PLAN
For latest news from the alliance of civic amenity groups opposed to Welborne (and others who are against the continuing destruction of our Countryside/ Open Spaces) please click on the link to Inform Fareham below:
WVCA Response to Outline Planning Application. Letter dated 18th April 2017
WELBORNE OUTLINE PLANNING APPLICATION (P/17/0266/OA) 1. On behalf of Wallington Village Community Association (WVCA), I offer the following comments on what is clearly a very comprehensive Outline Planning Application (OPA) by Buckland Development Ltd (BDL): A) TRAFFIC IMPACT - The OPA submission, confirms our earlier fears over the level of Welborne derived traffic that will come South on the A32 into Fareham and onto already heavily congested roads. It is particularly disappointing to reflect, that the limited measures that are being proposed in order to mitigate this impact on existing residents, are highly unlikely to have any real impact. Were the proposed Bus Rapid Transit (BRT) system to be found financially viable and regardless of the BRT route ultimately chosen, the system will inevitably have to run on roads that are already congested. There is little if indeed any confidence in the output of the HCC Transport model and indeed, the "assumptions" on which it is based, remain both unclear and are considered potentially flawed. (ie: the assumption that only 2% of Welborne traffic will go North on the A32 towards Wickham!) B) AIR QUALITY - The importance of Air Quality as an issue, is now increasingly recognised and the further congestion on both the M27 and local road networks, caused by Welborne (and also the 6,000 additional houses that FBC are planning elsewhere across the Borough), will only serve to exacerbate this problem. C) FLOOD RISK - The fact that a Flood Risk Assessment has at long last, been conducted for Welborne is welcomed. In the absence however of any real detail as to the design of the SUDS system(s) and equally importantly, the responsibility for their maintenance in the long term, then it is difficult to have any real confidence in the assurances that "Surface Water Run Off" to the Rivers Wallington & Meon will not increase beyond current levels.
D) M27/JUNCTION 10 - Clearly this is a key element of Welborne infrastructure. It remains unclear however, as to whether making this Junction "All Moves" is fully funded, whether the design has been approved by Highways England and indeed whether the recent Southern Gas Network (SGN) concerns regarding the encroachment of the proposed "Meadows Roundabout" on the Gas Pipeline can be adequately addressed. E) HEALTH CARE PROVISION - Despite the issue of Primary and Secondary Healthcare (GP and QA Hospital provision respectively) having been raised many times with FBC over recent years, there has been very little if indeed any, assurance from the local Clinical Commissioning Groups (CCG's) and responsible Health Trusts, that they can accommodate the additional housing numbers that FBC alone, are proposing (let alone whether QA will be able to cope with the future demands being placed on its services, by the huge increase in houses being planned within the QA Catchment Area). This may not be a "Material Planning Issue", but quite clearly these are issues of fundamental importance to existing Residents and ought be taken equally seriously by FBC. Please be in no doubt, that it is FBC who agreed to the PUSH derived Housing figures and it is FBC who will ultimately be held accountable for the subsequent consequences of having done so. F) VIABILITY/INFRASTRUCTURE PROVISION - Much has been written on this subject in recent years and clearly the Welborne Phasing Plan needs to be written, not just in robust terms, but also in such a way as it clearly identifies who precisely is responsible for what. In particular, I am reminded of the unequivocal assurance given by the FBC Leader who is on Public record as having said: "Not a brick will be laid (@ Welborne) before the infrastructure requirements have been
properly assessed, costed and the funding guaranteed" ("In Touch" - Summer 2011) Clearly the viability of any major development proposal such as Welborne (Calling it a Garden City/Town/Village, is frankly both immaterial and totally irrelevant - it will, shamefully, destroy almost 1,000 acres of Open Countryside!) will be heavily impacted upon by the Community Infrastructure Levy (CIL) - which for Welborne, had previously been agreed as being "Zero Rated". The very fact that BDL are now having to seek clarification as to this status, perhaps speaks volumes as to the absolute immaturity of FBC's so called "Welborne Plan". DAVID WALTON
WELBORNE UPDATE (Feb 2016)
At a meeting of the much-deferred “Welborne Standing Conference” in mid February, FBC made a surprise announcement regarding a “New Development Strategy for Welborne”; theoretically, in order to provide “certainty” that Welborne will deliver its housing targets.
This new approach was subsequently endorsed by the FBC Executive, on 22nd February 2016; whether such a fundamentally important decision (involving as it does very significant financial risk to FBC), ought to have been discussed “In Full Council” is a quite separate matter!
In essence, this new approach “potentially” involves land acquisition using Compulsory Purchase Orders (CPO’s) and the appointment of a “Preferred Development Partner” – rather than allowing the existing Welborne Landowners to develop the site.
The “New Development Strategy for Welborne” (regardless of whether the CPO process is embarked upon) is likely to delay Welborne by at least 2 years if not longer and will cost some £1 - £2M of taxpayers’ money (excluding the huge cost of the CPO itself). It is, I believe, fraught with risk and has the potential to be subject to hugely expensive and time consuming legal challenges. (By the existing Landowners)
Having been involved with Welborne for over 10 years now, I fully appreciate that it is a hugely complicated, multi-agency project that has massive infrastructure requirements of which the design and funding of M27 J10 (still yet to be agreed, let alone funded) is but a small part. I despair however on hearing, yet again last night, that: “We need Welborne in order to address the FBC Housing Waiting List” – refer back, if you would, to the Planning Inspector’s comments at the Public Enquiry into FBC’S Core Strategy circa 2012. “The Affordable Housing at Welborne cannot be “Ring-Fenced” for Fareham Residents” – it is a Strategic/SE Regional requirement”.
Clearly there has been a complete breakdown in both communication and, perhaps more importantly trust, between FBC and the Landowners. Were FBC to pursue the CPO option then I fear that a lengthy legal battle, at our expense is the almost inevitable outcome. It would appear, that what lies behind FBC’s latest and frankly ill-conceived approach to Welborne, is a desperate attempt to try and salvage their Housing development strategy – in order to try and prevent development elsewhere across the Borough, ie: Newlands etc.
Accordingly and as a direct consequence of FBC’s approach (which many of us believe will NOT deliver the “certainty” they are seeking, quite the opposite in fact) the plethora of unanswered questions regarding key Welborne issues such as, Traffic impact, SUDS Design and Flood Risk Assessment remain unanswered and are likely to remain so for a considerable period of time.
The situation is of course compounded by the fact that the Partnership for Urban South Hampshire (PUSH) has recently required FBC to deliver an additional 2,000 new homes between now and 2036, the location of which has yet to be decided.
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At the time of posting (8th June ) Fareham Borough Council is to decide today whether or not to adopt the Local Plan. This will mean rubber stamping, or not, the development named 'Welborne' proposed for the (currently) open agricultural land between Fareham and Wickham.
On behalf of the alliance of local amenity groups David Walton has issued a further Press Release:
Welborne - Press Release 8th June 2015
"The last FBC Council meeting to discuss Welborne, clearly demonstrated that a number of Councillors had little grasp of the issues/procedures involved and were simply voting on Party Political lines, regardless of the discussion/debate that took place on the night. In summary, it was quite correctly reported on as such by the local media as "A complete shambles" (Daily Echo). Accordingly, the Local Community Groups will be neither making any Deputations to, nor attending the meeting on 8/6.
Our opposition to Welborne remains exactly as stated in our Press Release of 13/5 when the Inspector's decision was announced and which is attached for your convenience - please feel free to draw on this in your coverage of Monday's meeting.
We have for a number of years now, been concerned that Fareham residents are largely unaware of the huge impact that the 10,000 homes that FBC agreed to in their "Core Strategy" some 3 years ago, will have. (Some 6,000 at Welborne plus a further 4,000 homes elsewhere in the Borough, PLUS, those additional Houses that Developers might very well, "Win on Appeal" - Newlands, Cranleigh Rd. et al - Be aware, the precedent has already been set!
People should be under absolutely no illusions: FBC have chosen to take: (Without proper Consultation) a "Very High Risk Strategy" on Fareham's future:
Fareham is already "Over Developed"
Note also the FACTS: Fareham is currently ranked:
a) As being "the 10th most congested place in "the whole of the UK" AND
b) "Is the most car dependent Town in the whole of the UK" (by the Daily Telegraph - July 2014, both Ref's)
Further Development on the massive scale now being planned by FBC (or is it PUSH?), will destroy some 1,500 acres of Countryside, cause enormous Environmental damage to which they appear oblivious, will also generate as yet un-quantified additional traffic congestion and perhaps, most importantly of all, will adversely affect the Quality of Life of what is actually, a rather important, albeit forgotten Group - we are called, "Existing FBC Residents"
Accordingly, you should be aware that a Focus Group has recently been formed to address just this issue. It is called "Inform Fareham" and full details are available on the website at www.informfareham.org.uk "
Be of absolutely no doubt, Welborne (A New Town of some 6,000 homes (The size of Petersfield), Will have a huge impact on Fareham: - BUT FOR WHAT PURPOSE?
Will Welborne reduce Numbers on the FBC Housing Waiting List? - Not at all, unless FBC stop "Selling Off" their existing Council Houses, under the mistaken belief of "Right to Buy"
Alas, the FBC subservience to PUSH, is entirely responsible for the dilemma we are now in.
Hope the above helps and that both your Papers will now both provide a more balanced (and indeed detailed) input to your readership, on what is unquestionably, the biggest single issue that Farehan has faced in the past 50 Years.
WELBORNE –PRESS RELEASE (Final Version)
Speaking on behalf of the local Community Groups and CPRE (Hants), David Walton said:
“We are naturally very disappointed by the Inspector’s decision. Fareham neither needs nor wants, development on the scale of Welborne, which will destroy almost 1,000 acres of open Countryside and high grade farming land, for what purpose?
Residents were told by FBC (May 2011 – Special Edition of Fareham Today) that the rationale behind Welborne was to provide affordable housing for local people. That myth was exposed years ago when FBC were forced to admit, that such homes could not be “ringfenced” for Fareham residents. To compound matters, recent changes to the Welborne plan now allow the Developers to undershoot targets for the delivery of affordable homes, on viability grounds.
The traffic impact assessment work is both incomplete and we believe, fundamentally flawed (The HCC prediction that a mere 2% of Welborne traffic will head North on the A32 does little to generate confidence in their Transport model as a whole). There are no funded plans as to how capacity on the existing local road network/M27 can be increased to cope with the additional traffic generated by Welborne and the design for M27/J10 has yet to be agreed, let alone funded. Existing Fareham residents ought to prepare themselves for yet more traffic congestion, increased journey times and worsening air pollution.
Settlement buffers between Welborne and existing Villages are a derisory 50 metres, the downstream flood risk assessment to Wallington, Funtley & Titchfield has yet to be even started and FBC’s confidence that this will be a “sustainable development”, is now so low that even the sustainability targets, have been removed from the Welborne Plan.
The timely provision of infrastructure and its funding, remains as uncertain today as it was when the issue was first raised over 5 years ago and to make matters even worse, neither FBC nor the local Clinical Commissioning Group (CCG), can provide assurances that primary & secondary healthcare provision can cope with development on this scale. This includes not just the 5,500 homes @ Welborne, but the further 4,500 elsewhere across the Borough and the yet further development that is planned across the wider QA catchment area.
What has now become abundantly clear, is the extent to which FBC are totally subservient to an organisation that most people in the Borough have probably never heard of namely the undemocratically constituted, Partnership for Urban South Hampshire (PUSH), for it is PUSH who have been setting the housing target figures.
In declaring the Welborne Plan “Sound” the Planning Inspector appears unfortunately, to have succumbed to what was no doubt immense pressure from his political masters and has allowed a deeply flawed plan, regardless of the consequences, when patently the Welborne plan is anything but sound.”
WVCA has submitted the following detailed comments to the Planning Inspector via FBC in respect of Major Modifications 1 – 23 to the Welborne Plan.
MM 1 (Review of Local Plan)
It is understood that the review of the PUSH Spatial Strategy will be published in mid 2015/early 2016.
MM 2 (Relationship between Welborne & Fareham to the South – WEL 2)
This issue has been mired by muddled thinking from the outset and has never been properly addressed; to the extent that during the Full Council meeting on 21 Jan, Welborne was variously described as being “a New Town” and “an Urban extension of Fareham”, by none other than FBC’s Executive Member for Planning & Development. The revised wording now being offered under this modification serves to contradict and confuse rather than add clarity to the issue.
It should be remembered that the issue of making Welborne “South facing” was included in the Welborne Plan at the specific behest of Winchester City Council, which has long standing concerns that the additional traffic generated by Welborne, together with the provision of full functionality to J10 of the M27, will have the effect of causing a significant increase in Northbound traffic on the A32. Neither the local Community Groups (nor we suspect Winchester CC), have any confidence in the current output of the Traffic model, which predicts only a 2% increase in Northbound traffic on the A32. We contend, that this is a prime example of the extent to which the transport modelling is both incomplete and fundamentally flawed.
Furthermore, the absence of an agreed layout for the proposed J10 of the M27, has not only adversely impacted on the Traffic Impact Assessment work which now appears to have stalled, but also means that the SANGS deficit cannot be quantified. The various layout options will have a different “land take” and given the proximity to the M27, it remains our view that none of Fareham Common, ought to be considered part of the SANG provision.
We contend, that the above paragraphs demonstrate that the Plan fails to meet the NPPF requirement in terms of justification as it is not based on appropriate or proportionate evidence and cannot therefore be considered “Sound”.
With regard to Self containment, it should also be noted that the target figure has now been completely removed from the Welborne Plan; an omission that casts further doubt as to the sustainability of the Welborne development.
We similarly contend therefore, that it is neither positively prepared nor consistent with National policy.
MM 3 (Settlement Buffers)
It is the unanimous view of the local Community Groups, that the current proposals completely fail to satisfy WEL 5 (prevention of coalescence between Welborne and existing settlements) This view is obviously shared by those FBC Councillors whose Wards are closest to Welborne, who at the Council Mtg on 21 Jan raised a number of motions which sought to “strengthen” the Welborne Plan by increasing the size of the Settlement buffers. Suffice to say, all these motions were rejected by FBC Councillors, predominantly by those on whose Wards, Welborne will have the least impact. The only conclusion that can be drawn, is that Localism is an alien concept @ Fareham!.
It is worthy of note, that the so called “Strategic Gaps” South of the M27, (Deemed necessary by FBC in order to prevent coalescence between existing Villages/Settlements in that location), are very significantly greater in size than the derisory “Settlement Buffers” deemed acceptable for Welborne.
It should also be noted, that specific concerns regarding the inadequacy of Settlement Buffers were raised by the Chairman of the Standing Conference in his submission of 3 Dec 2014 (Responses post Examination – Issue 3 – Doc.CD38 refer)
The fact that the current draft completely ignores the views that have been repeatedly raised by the Welborne Standing Conference (SC) is not only extremely disappointing; but more importantly now calls into serious question, whether any useful purpose is being served by that particular body. The SC was established by FBC “as an Engagement Mechanism”, given that it would appear that FBC no longer take any heed as to its output, the inference is clearly that it no longer serves any useful purpose.
Given that FBC are taking heed of neither the local Community Groups nor the Standing Conference then we would contend, that MM3 in it’s current form does not meet the Duty to Co-operate, is not justified and is thus “Unsound”
In conclusion, the 50/75m Settlement Buffers singularly fail to deliver the “Visual & Physical separation” required by Policy WEL 5 (MM3 is inextricably linked to MM 16 – Pse see those comments with specific regard to the use of false evidence and the failure to take proper account of the topography of the land – CD 38 refers.)
We contend therefore that MM 3 cannot be justified, as it is based on evidence that is both inaccurate and misleading.
MM 4 (General Design principles)
The proposals to highlight the importance of noise & light pollution, together with air quality are supported; clearly however the baseline data needs to be captured in advance of any development on the Welborne site. The modification (criterion v) ought be further strengthened however by inclusion of the words “need to be measured, monitored and taken full account of” in developing proposals …….
MM 5 (Pedestrian & Cycle movement across the A32)
Whilst the modification is supported, it is disappointing to reflect that the draft offers no suggestions as to how this aspiration might be achieved.
MM 7 (Early Office provision)
Early provision of Office employment space has the potential to generate significant levels of additional traffic; accordingly, the highways infrastructure needs to be in place in advance of any such early provision.
MM 8 (Retail & Leisure development within the District Centre)
Whilst an improvement on the earlier text, this modification still fails to adequately describe the relationship between Welborne & Fareham/Wickham centres. (See earlier MM 2 Comments)
MM 9 (Location of the Secondary school)
Whilst the location is agreed, it is firmly believed that to delay provision until the end of Main Phase III (2026) is far too late and needs to be brought forward in the Phasing Plan. By 2026 some 2,860 houses are expected to have been completed and at no stage has any evidence been produced that existing secondary schools in North/East Fareham have the spare capacity to absorb this level of demand for school places. (MM 21 Comments also refer)
MM 10 (Affordable housing)
Given that a substantial part of the rationale behind Welborne was to provide affordable housing, it is extremely disappointing that the Developers have been given so much latitude to undershoot the targets on viability grounds. We would contend therefore, that this lax approach to affordable housing provision, which has no mechanism that demonstrates affordable housing will be deliverable over its period,begs the question as to whether the Plan is effective in NPPF terms and therefore Sound.
MM 11 (South facing Development)
This modification, which links directly to MM 2, is entirely aspirational and has yet to be backed by detailed traffic impact assessments on the already heavily congested local road network in Fareham. Notwithstanding the press releases in late Jan 2015 regarding additional Government funding being provided to the Solent LEP there is a complete lack of clarity as to which highways scheme(s) relating to Welborne are now funded and which are not. The continuing lack of clarity regarding infrastructure funding in general, does nothing to engender confidence that Welborne is a financially viable project and specifically, whether it is justified and based on proportionate evidence.
MM 12/13/14 (Traffic Management measures on the A32)
These modifications serve only to demonstrate the absolute immaturity of the means by which the significant levels of additional traffic generated by Welborne will be managed. They add no clarity whatsoever, are entirely unsatisfactory and need to be re-considered within the Phasing Plan.
MM 15 (Allotment provision)
The reduction in Allotment provision whilst understood; serves merely to reinforce FBC’s “Confused” approach to Welborne, which since its gestation has been variously described as being: “Built on Garden City principles, an Eco Town, A New Community, A New Town and most recently, an Urban Extension”
MM 16 (Structural Landscaping Schemes)
Given the sloping nature of the Welborne site, it is difficult to envisage how any amount of structural landscaping will be capable of protecting the “long distance views” particularly from the South and East.
Additionally, the Landscape schemes designed for the “Settlement Buffers” need to take full account of the topography of the land in question. As a case in point, the illustration @ CD 38 (Section 1/Funtley) depicts a level site – the reality however is that the land slopes steeply from the Funtley side and thus the “scheme” as currently proposed, would be wholly ineffective in terms of providing Visual Screening.
This lack of “detailed consideration” is manifest throughout the Welborne plan and you will be aware that in previous submissions, the Community Groups rightfully took objection to a picture of a 100 year old Tree belt (albeit of some 50m in width), being included within CD 38 as “an illustration of the Separation Buffers @ Welborne”
Accordingly, we contend that MM 16 cannot be justified in that it relies on evidence that is both inaccurate and misleading.
MM 17 (High Energy Efficiency standards)
Whilst this modification is a slight improvement on the previous text, it is disappointing that energy efficiency targets are being set so low and that the whole section remains riddled with caveats that will allow the Developers to undershoot the target on viability grounds, the rules on which are undefined.
MM 18 (Water supply and Waste water disposal)
The whole purpose of this modification was to provide clarity to the Inspector (and indeed to the Public also) as to the means by which Waste water in particular, would be dealt with. It adds no such clarity and is symptomatic of an immature and incomplete Welborne plan that requires much further work. It is inconceivable that the Welborne plan can be considered “Sound”, when such fundamental issues of infrastructure provision remain undecided and in the absence of a clearly defined waste water treatment plan over the project lifetime.
MM 19 (Flood Risk & SUDS provision)
The local Community Groups sought assurances in this regard at the time of the Core Strategy and were placated then, by promises that it would be addressed at the AAP/Local Plan stage of the Planning process. Yet again, FBC are now seeking to defer until a Planning application is submitted, a fundamental issue such as determining the downstream flooding risk posed by Welborne, to the villages of Wallington, Funtley & Tichfield. This is entirely unsatisfactory and in the absence of any evidence that the downstream flood risk can be mitigated, then we contend that the Plan can be considered neither deliverable nor effective.
MM 20 (HWRC)
This modification is supported.
MM 21 (Phasing Plan)
The proposal(s) to defer completing J10 of the M27 (2022) and provision of a Secondary School (2026) are believed to be not only fundamentally flawed, but will also generate wholly unacceptable traffic impacts.
Provision of a Primary Care Centre is not envisaged until the end of Main Phase III (2026); this ought be advanced in the Phasing Plan. By then, some 2,800 homes will have been completed and no evidence has been produced at any stage, that the existing Surgeries can cope with demand on this level.
In similar vein, FBC have neither sought nor received any assurances, that QA can cope; not only with the 6,000 homes being proposed for Welborne and the further 4,000 across the Borough as per their Core Strategy), but also, with all the other development being planned within the QA Catchment area. (QA Hospital has failed to meet it’s A & E targets for the past 2 years and was recently named as being the 6th worst performing Trust in the entire Country - Southampton General was ranked as 12th worst and so clearly there is no “spare capacity” in the local area; existing FBC Residents have every right to be very concerned).
There is a disproportionate volume of housing proposed for either side of the Knowle Road in the early phases of the plan; this sits somewhat uneasily with the notion that Welborne is “South facing” and will establish vehicle movement patterns, in advance of the highways improvements, that will subsequently prove difficult, if not impossible to break.
Deferral of the main internal spine road network until some point in Main Phase III (2022 – 2026) is viewed with particular concern, as by 2022 full functionality ought have been provided to M27/J10, thus forcing all traffic onto the existing A32.
MM 22 (Deferral of Infrastructure contributions)
This modification is supported.
MM 23 (Monitoring & Review)
It is important that the Public have full visibility as to the delivery of key objectives and critical infrastructure for Welborne and the proposal to highlight risks that have impacted to the Standing Conference using a Delivery Risk Register is supported.
The Strategic Review Group, which thus far have met only very infrequently, has no Independent representation
Additionally, it should be noted that no Viability Risk Register for the Welborne Plan has been placed in the public domain and despite repeated requests, the infrastructure funding shortfalls for each Financial Year of the Welborne plan have not been made available.
Accordingly, there is not a shred of evidence as to the viability of the Welborne Plan and as a result, there can be no confidence as to whether the Welborne plan is deliverable. In the absence of any such information, we content that the Plan cannot be considered effective in terms of the NPPF and is therefore “Unsound”.
The Welborne Plan
The current position is that in February 2014, the Welborne Plan was endorsed by FBC (but thankfully NOT by either of our local Councillors, both of whom voted against) and published for a 6 week Public Consultation period, before being submitted to a Planning Inspector.
The “concept” of Welborne (A new Town of some 6,000 houses with associated infrastructure, employment areas, schools, shops etc and which will destroy almost 1,000 acres of prime farmland between the M27 & Wickham, on both sides of the A32) has already been agreed.
What FBC need to do now, is to convince the Planning Inspector that there is sufficient evidence within their submission to show that they have fully addressed the impact that Welborne will have, such that their plan can be considered “Sound” at a Public Enquiry, to be held later this year.
Conversely, what those of us who believe that Welborne will have an adverse impact on existing Residents in Fareham North/East, Funtley, Knowle & Wickham, have to demonstrate, by specific reference to FBC’s evidence base (a very weighty pile of Documents, believe you me!), is that the true impact of Welborne has not been properly considered and is therefore “Unsound”.
Accordingly, what follows is the final WVCA submission to the Public Enquiry Inspector; those who have had to write a dissertation will understand the copious references!
NB: if you wish to read the background material please go to the link on the Information Page entitled SDA/Welborne Background or click here.
FINANCIAL VIABILITY/FUNDING AND PHASING OF INFRASTRUCTURE (WEL 41)
The GVA Stage 2 report (Feb 2014) commissioned by FBC, whilst very much at an iterative stage, clearly demonstrates significant concerns as to the financial viability of the Welborne Plan, particularly in the first ten or so years and does little to engender confidence that the necessary infrastructure will be affordable. In similar vein, FBC’s “Welborne Infrastructure Funding Strategy” (Jan 2014) whilst conceptually sound, offers no firm guarantees that Welborne will only go ahead if the infrastructure funding can be assured.
With specific regard to Infrastructure phasing, it is firmly believed that to delay providing an “All moves” J10 (10.8) until the end of Main Phase 2 in 2022, is fundamentally flawed. By 2022, 1,500 homes (10.9), some 6,000 square metres of employment floorspace (Table 1.2), and the 1st Primary School (10.11) are projected to have been completed. By then, both the District and Local Centres are also projected to be “at least partially completed”.
HANDLING OF WASTEWATER (WEL 37) – The very fact that the means of delivering such a fundamental part of the Infrastructure provision has still to be determined at this late stage is perhaps a very telling indicator as to the current immaturity of the Welborne Plan. (9.21)
CONCLUSION – The funding and phasing of the infrastructure required to support Welborne are of critical importance, as is the timely delivery of full functionality to J10. These issues, together with the current perception of overall viability, are clearly major concerns with regard to the “Deliverability” of the Welborne Plan.
Accordingly, the Welborne Plan is considered UNSOUND, for the reasons cited above.
TRAFFIC IMPACT/PROPOSED BRT ROUTE (WEL 23/24/25) –. Currently the M27, which is a key part of the Hants Motorway network, is at or close to capacity (7.16) and traffic volumes are forecast (by the Highways Agency) to increase year on year, regardless of whether Welborne goes ahead or not. In similar vein, much of the local road network is already gridlocked for much of the day and it is generally recognised that Fareham already has a significant deficit in terms of highways infrastructure. Continuing uncertainties as to the design of the revised J10 have not only prevented the Highways Agency from endorsing the layout of the new Junction 10, but also prevented traffic modelling work by the Highways Authority (HCC) on other key parts of the local road network. (7.19 – 7.21 and as briefed by HCC to the “Standing Conference” on 25/2 2014)
The fact that Welborne will generate significant levels of additional traffic is fully recognised (7.25) as is the fact that considerable congestion already exists on the local road network (7.26).
The sustainability of Welborne is very heavily dependent, some might argue “over dependent” on a viable BRT system, that is funded, not just initially, but through life (Yet to be assured). It should be noted that BRT Phase I, whilst having exceeded expectations in terms of passenger numbers, has reduced traffic volume on the A32 by a mere 2% and this key part of the local road network remains gridlocked for the majority of the day.
This somewhat stark reality helps put (7.34) into perspective. Accordingly, it would be grossly irresponsible to over-emphasise the benefits that a BRT link to Welborne will bring in terms of reducing existing traffic congestion, let alone that post-Welborne. The Local Plan, clearly shows that despite Fareham (apparently) having a “comprehensive Bus network“, some 80% of trips made by Fareham residents are currently made by car” (7.32) One can only wonder why!
Much of the proposed BRT route from Welborne to Fareham BR Station (Figure 7.1) (J10, via Wickham Rd and past the St Christopher’s Hospital Site, to “Red House”, via the Sainsburys roundabout, along Wallington Way to the Delme roundabout, via the notoriously congested, Delme, Quay Street and Town Station roundabouts) is patently fraught with risk. These routes are already heavily congested at peak hours and measures to demonstrate how the additional Welborne derived traffic will be mitigated, are limited to a series of proposals that seek to afford priority to BRT usage. Clearly this will be to the detriment of other road users and will simply worsen the existing congestion in this part of Fareham. There is conclusive evidence that in Fareham, such prioritisation of roads to Bus usage, simply does not work and merely adds to traffic congestion. Exactly this type of proposal was trialled by HCC in 2013, (From the Quay Street to Station Roundabouts). Suffice to say, it failed miserably and subsequently required a completely new scheme (currently funded, but yet to be delivered/proven) costing in excess of £1M.
In short, the current proposal is NOT a viable transport solution, to the additional traffic generated by Welborne and, contrary to Table 4.1 of the Sustainability Appraisal (SA), it will reduce rather than increase capacity on the local road network. Additionally, it should be noted, that by increasing the functionality of J10 this will, in its own right, attract additional traffic from both North & South of the A32, to J10; this seemingly obvious fact, is completely ignored by the Transport Planners at HCC. As a resident having lived close to J11 for over 30 years, I would contend that the slight reduction in Motorway traffic cited at (7.18) as being a “key consideration” and positive benefit of making J10 an “All Moves Junction” will be more than offset, by the additional traffic that will be attracted to use an “All Moves” J10 in the future.
The proposal however (at Table 4.1 of the SA and at 7.29), to close Pook Lane to through traffic, in order to prevent it becoming a “rat run” to J11, is fully supported.
CONCLUSION - There is not a shred of evidence within The Welborne Plan, that either the M27 or the local road network can cope with the additional traffic that Welborne will inevitably generate, nor are there any assurances that funding for the necessary Motorway and Highways improvements will be provided. The current transport proposals fail to support WEL 23, WEL 24 or WEL 25; accordingly the Transport, Access & Movement Plan at Chapter 7 of the Welborne Plan, is considered to be UNSOUND.
DOWNSTREAM FLOODING RISK (Wallington, Funtley/Tichfield) (WEL 39) – Despite the welcome assurance at WEL 39, that a Sustainable Urban Drainage System (SUDS), to a standard acceptable to the Environment Agency will be used at Welborne and that the downstream flooding impact will be assessed in due course, the inescapable fact, is that to date, the effect of Surface Water Run off from Welborne on the Rivers Wallington & Meon has still not been assessed, despite repeated requests over the past four years that this be done. This failure is considered an unacceptable shortcoming of the current Plan, particularly given the well-documented flooding risk that already exists, to Wallington in particular, for which the last “Severe Flood Warning” was as recent as Dec 2012.
IMPACT ON EXISTING RESIDENTS – It is extremely disappointing to note, that there is no overarching Welborne Policy that relates to the impact on existing Residents. All the local Community Groups most affected by WELBORNE, (Wallington, Knowle, Funtley & Wickham) together with the Fareham Society and CPRE (Hants) remain totally opposed to development on this scale, which far exceeds that required to satisfy Fareham’s affordable housing needs. There is similarly widespread concern within the Wards of Fareham North & Fareham East, as it is widely believed that Welborne will adversely affect the quality of life for existing residents in these areas of the Borough. Traffic congestion will worsen, air quality will suffer as a direct consequence and traffic noise will increase. It is particularly disappointing to note that within all the Welborne Plan documentation, there is not a single palliative measure that seeks to address the adverse effect of Welborne on existing Residents. A case in point, would perhaps be a firm commitment to seek M27 Noise reduction measures, which would benefit both existing and Welborne residents alike.
CONCLUSION – It is frankly inconceivable that the Welborne plan can be considered SOUND when thus far, neither the resultant traffic impact nor the downstream Flooding risk have been assessed, when it’s financial viability in terms of infrastructure provision, remains so uncertain and given that so many of the Core Planning Policies have yet to be adequately addressed.
SUSTAINABILITY APPRAISAL/HABITAT ASSESSMENTS – Both documents very clearly demonstrate that Welborne will have a negative impact, with very little mitigation possible. Specifically, the destruction of almost 1,000 acres of prime agricultural land has not been adequately justified, nor has the true impact been adequately captured within the SA, a great deal of which is based on medium or low levels of confidence, due to insufficient data (SA 2.5.2 refers).
There is for example, scant regard paid to the fact that the majority of this land is either Grade 2, or 3a/3b and the impact the loss of this land will have on farming, future food production capacities and the disturbance to wildlife across the Welborne site.
Accordingly, it is submitted that FBC have demonstrably failed at both the Core Strategy and Local Plan stages, to explain the “exceptional circumstances” on which the decision to sacrifice this land is based. The land East of the A32 is recognised as being of High Landscape Sensitivity (SA 9.2.12 and Fig 9.1) and yet, incongruously, some of this land is earmarked for Employment B8 use. (Warehousing) (5.3). The extent to which Welborne becomes a “sustainable development” is directly linked to the degree of self containment that is achieved and whilst the need to balance land allocation between housing and employment is fully understood, the Plan currently allocates some 20 hectares to employment use (5.3 – 5.5). It is of concern that such a high percentage (50% of this total) is earmarked for B8 use, given that the latter contributes so little in employment terms and yet has the potential to be so intrusive on the landscape.
SETTLEMENT BUFFERS – Measures to prevent coalescence with Knowle, Wickham, Funtley and Fareham are implicitly required (WEL 2 & WEL 5) and yet despite repeated representations over several years, that a 50m wide buffer at Funtley for example, is entirely ineffective and therefore unacceptable, this derisory size of buffer strip remains in the final version of both the SA and the Welborne Plan. (3.62). The rationale being offered, is that to increase the size of the Buffer zones would necessitate an increased in housing density. There is of course an alternative solution that is conspicuous by its absence, namely to accept that it would reduce the total housing numbers available at Welborne. (In terms of housing numbers, it should be noted that the SA still refers to 6,500 whilst the local Plan talks in terms of about 6,000).
THE “KNOWLE TRIANGLE” – This is a “Ransom Strip” parcel of land, that is not currently owned, by the two major (Welborne) Landowners and which importantly, lies under the jurisdiction of Winchester City Council (WCC), rather than FBC (5.94). This piece of land was always intended as a “Green Buffer” (Para 5.29 of the WCC Plan refers) and for it to be enclosed as a fenced Playing field, is contrary to both the letter and spirit of the WCC Plan. As a “Green Buffer” zone it had the potential to contribute towards the SANGS deficit that currently exists and thus the Sustainability argument for Welborne. Use as a fenced playing field, has changed the “open and rural nature” of this land, which was specifically designated as such, “in order to prevent changes that would urbanise its undeveloped character”
CONCLUSION – By its own admission, large parts of the Sustainability Appraisal are lacking in firm data. The proposed Settlement Buffers are inadequate and fail to satisfy Core Policies within the Welborne Plan. The Self Containment data is entirely aspirational and it is disappointing to note that the previous target figure of 40% has now been removed and not replaced, from the Publication version of the Plan. The SANGS provision is already in deficit and this could worsen still further, dependent upon which layout is chosen for J10 and the resultant “Land Take” from Fareham Common. Accordingly, it is submitted that there are too many fundamental flaws in the evidence base, for Welborne to be considered a “Sustainable Development” and accordingly, the Plan cannot be considered SOUND at this juncture.
Wallington Village Community Association