SOLVE Comments on the Pre-submission Local Plan
Thursday, September 26 2013 @ 07:22 PM BST
Contributed by: Peter Bloyce
The deadline for submissions to the public consultation on the Basingstoke and Deane Borough Pre-Submission Local Plan (LP) is noon on 4th October. Details on the BDBC website:
Our goal remains to prevent over-development to the east of town across the Loddon Valley. The sites of concern to us are Pyotts Hill, (East of Basingstoke, policy SS3.9) 900 homes and Redlands Farm (adjoining Pyotts Hill to the north, policy SS3.7). These are the gateway to the Loddon Valley.
The Council has issued a special edition newspaper “Deciding the Borough’s future”. The document sets out the Council’s ambitions, yet is short on detail and glosses over the very real dangers associated with over-development on top of an infrastructure that is already at capacity. There is little mention of the very serious issues relating to traffic, water quality, sewage problems and general over-crowding that this plan will cause, and no concrete plans for how these issues will be overcome.
The SOLVE comments are summarised below. These are not exhaustive.
Infrastructure - There is an ‘Infrastructure Delivery Plan (IDP)’ to accompany the LP which gives a list of projects needed to accompany the housing development. Policy CN5 states: “New infrastructure should be provided prior to occupation of the development, or in larger schemes, prior to the occupation of the phase of the development for which it is needed.” SOLVE would normally support this ideal. However, implementation of this policy is unlikely, since figures presented in the IDP show that most major projects are not funded. Only a proportion of the money will come from developers as part of the Community Infrastructure Levy (CIL) which has yet to be negotiated. CN5 is not sound.
Transport Assessment - Evidence Base, Report Number: 3512774A-PTG / 02 Dated August 2013, gives details of predicted traffic growth and suggested measures to tackle this. There are a number of comments that SOLVE will be submitting including:- Congestion on the A33; planned changes to junctions; public transport, in particular the suggestion of a bus gate [Volume 1, January 2013, p112] which will be vigorously opposed by local residents. These are major infrastructure projects and policy CN5 is paramount. With costs yet to be identified for these changes then the LP is unsound as CN5 is unworkable.
Flooding - Policy EM7 (p91) states that a sequential approach to development will follow national guidance, i.e. sites with a lower risk will be developed first. The plan contravenes the Flood risk policy since it has put Pyotts Hill (SS3.9) ahead of other sites with a lower flood risk.
Water Quality of the Loddon [Policy EM6. Water Quality. p88; Policy SS4. p47 and para. 4.10. p26] – The Council accepts that the South East is ` water stressed' and that River Loddon currently fails to meet `good' status under the Water Framework Directive. Present day technology cannot improve the status, para 4.10. Action needs to be proactive before development is committed, not reactive after the event.
Ecology and the Environment – This will be the subject of a separate submission.
Landscape Capacity – The studies of 2008 and 2010 recommended that the north of Pyotts Hill should not be developed. There should be a clear buffer between the conservation areas along Park Pale and any development. Redlands - SS3.7g, states – “This should not be developed in isolation”.
The Council’s ‘Planning and Infrastructure Committee’ consistently recommended that (SS3.9) should not be developed.
Incinerator and Sewage Works (Policy SS3.9 and SS3.7) – Originally these were sited away from settlements, now there are plans to put housing close by. The current Thames Water Business Plan proposes a new renewable energy unit alongside these sites to “pressure cook” sewage from areas as far apart as Guildford and Newbury.
Environment Agency – The EA recommended removal of SS3.9 from the list. They described it as “high risk”, (SHLAA all versions, including the last, version 7).
Number of houses, Pyotts Hill – The Landowner, Hampshire County Council (HCC), is promoting 450 houses on SS3.9 during this local plan period as opposed to 900 as proposed by Basingstoke and Deane Borough Council. The site is therefore not fully available and is therefore unsound.
Suggested Alternatives to East of Basingstoke (SS3.9) and Redlands Farm (SS3.7)
Policy SS3. Greenfield Sites, p35 - As an alternative to sites Redlands and East of Basingstoke, Hounsome Fields, adjacent to Kennel Farm (SS3.2), should be included. This was included in previous versions of the SHLAA. The Flooding sequential test alone places this before SS3.9.
Policy SS7. Nuclear Installations - Tadley and Burghfield. p52 - Tadley is the second largest settlement in the Borough with 10% of the population. The policy constraints are questionable given that the Borough has said they will consider each application on a “site by site basis”. The Secretary of State thought the risks were acceptable when he allowed an appeal regarding the Boundary Hall site in 2011. It is likely therefore that more sites will come forward and be approved. The SHLAA shows there is the potential for nearly 1,800 houses. The LP should include a Tadley “windfall” for a substantial proportion of this.
Policy SS3.10 – Manydown – The Council Manydown Executive Committee recommended 4,000 houses over this plan period. The Local Planning Inspector during the 2005 inquiry considered 360 dwellings per annum (dpa) to be realistic, and version 6 of the SHLAA quoted 350 dpa. Tibbalds Planning and Design produced a report in September 2012 which also recommended 350dpa. The allocation can therefore be increased from 3,080 to 4,000 houses during this plan period.
Basing View (SS8) - Recent History (10-15years) shows that even during an economic growth period the amount of Business Park accommodation in the borough has exceeded demand. Even newly built buildings with good infrastructure remain empty. Whilst the redevelopment of a rundown Basing View is welcome, the attraction of a renewed Basing View is likely to displace businesses from elsewhere in the Borough, not increase the overall number. Technology has reduced the need for office space whilst increased home working (approx 500,000 more in UK over the last 5 years) will continue to reduce requirements. The Government has recognised this and relaxed the planning laws on conversion of office space to residential accommodation. Policy EP2 - The Borough should take advantage of this.
Basing View occupation rates calls into question the increase in 6,500 jobs over the plan period, Para 4.8.
Para 4.7 - Figures released by the DCLG in April confirmed the decline in household formation and increasing household size over the last 10 years. From our discussion on this subject with Borough Officers is unclear whether this has been taken into account in housing target.
If you have comments please do so by 4th October. Although you should be aware of the guidance given by the Council on making your submission, do not let that divert you from making your point. The Council will accept letters and emails as long as the relevant passage in the LP documents are quoted. They will pass on all comments to The Planning Inspector who must be made aware of all concerns.
Peter Bloyce, SOLVE