Local Plan: The Unasked questions

We hope many residents will have taken part in Fareham Council’s consultation on the Draft Local plan. Below is the response from Fareham Liberal Democrats, in which we have tried to explore some issues which we believe have not been properly considered in the list of questions put to the public.

Fareham Local Plan Consultation

The indented, italic paragraphs in this abstract from the Consultation document set out the questions Fareham Liberal Democrats would like to be considered about the assumptions underlying the Draft Local Plan

Key issues: Fareham’s housing need

As you have already seen, the new Local Plan isn’t just about housing. However, as the Government has increased the number of new homes that need to be built in the Borough, it is a major consideration in this consultation.

Any future Local plan needs to be fair and balanced when considering subsequent housing allocations. All communities should share some of the pain with regard to new housing. 

The whole of the borough runs alongside EU designated areas, namely Ramsar, Special Protection Areas and Special Areas of Conservation. Can the Government’s housing allocations be achieved without damage to these areas?

Making housing affordable

Planning the most suitable mix of shared ownership, affordable rent and social rent homes for local need, whilst ensuring development can occur, is an important issue.

Getting this policy right within the new Local Plan is vital to gain new housing that can be provided at an affordable level.

To make this a realistic ambition, the council must improve its target for building iits own homes for rent. Fareham and partner councils must press central government to allow a much bigger share of receipts from council house sales to be used to provide new housing.

Much of the fall in the construction of new homes is due to local planning authorities leaving new housing provision to the private sector, with the attendant risks of land-banking and market manipulation.

Ensuring good home design

The Council wants to ensure the design of a home is adequate for its occupants and wishes to use the new Nationally Described Space Standards in its Local Plan. If successfully evidenced by the Council, this would help ensure developments would provide adequate living and bedroom space, sufficient storage and floor to ceiling heights.

Do you agree this is an issue the Council should be tackling? Are there any other elements of design you think are important?

As well as applying this aproach to new-build housing, The council must ensure conversions of commercial properties are not used to evade planning criteria, leading to supply of sub-standard housing.

Large or small developments?

The Government stipulates that at least 10 per cent of the new developments in the Local Plan must be on small to medium sites of up to one hectare (around two and a half acres). The Council’s preference to date has been to see most of new homes built in a small number of larger cluster developments.

Ensuring that the right infrastructure is in place for our growing population is vital. The Council is looking to continue with its large ‘cluster sites’ approach, where infrastructure improvements are typically easier to design and deliver. Often schools and road improvements can be incorporated into larger development schemes, and when land is required for local public medical and healthcare facilities, this can be provided for. Developers are responsible for the delivery of suitable infrastructure through legal (Section 106) agreements signed with the Council.

In the following pages we will ask questions about specific areas in the Borough; however, do you agree with the overall approach we are proposing?

The justification offered for cluster sites is very hollow. Is it compatible with the requirement that 10% of development should be on small sites?

Can the Council ensure targets for affordable homes are met while ensuring sufficient developer contributions to provide infra-structure? 

The Council seems to have little sway with HCC Highways and what is presently being delivered in the way of infrastructure improvements on present housing allocations coming forward is merely window dressing and do not address the concerns residents have. HCC Highways are not listening to the public and are happy to dismiss many other public concerns with regard to highway issues.

The Council believes Health is not part of a developers remit when bringing forward Housing allocations, so one of the contentious areas residents repeatedly raise while considering house developments is simply waved away. The National Planning Policy Framework is clear, Health forms part of sustainable development.

Key issues: Planning for Good Growth

The Local Plan defines this as building homes and creating employment spaces in such a way as to improve quality of life whilst protecting the most valued natural and historic environments. It cites valued landscapes, providing open space and leisure opportunities to encourage healthy and active lifestyles and encouraging more of us to use active forms of travel rather than the car.

Encouraging active forms of travel is desirable. But why is there no mention of public transport?

After asking landowners and developers where development land might be found, we know there are such sites in Fareham Town Centre, the Western Wards, Titchfield, Portchester and Stubbington. This includes brownfield sites, as well as a large number of greenfield sites.

Urban areas

Do you support the Council in continuing to allocate brownfield sites that are likely to deliver homes in the period we are planning for?

The Council has a duty in the eyes of many to bring forward Brownfield sites before considering greenfield. However, it knows full well Brownfield sites are very limited in Fareham.

Brownfield schemes should be carefully examined to avoid increased congestion and pressure on already-over-stretched services.

Higher density developments include taller buildings and apartment blocks. Would you support this type of development where infrastructure, such as a railway station, exists?

Yes, provided it doesn’t put pressure on parking near the station which could discourage commuting by rail.

Protecting green space in your community

The Government’s National Planning Policy Framework allows Councils to highlight small areas of open space to be protected in a similar way to greenbelt land. These small parks, small areas of recreational grassland or woodland within or close to housing estates should have importance to the community living around them. This might be for cultural, wildlife or recreational reasons.

The Council is keen for residents to highlight important areas that may meet the Government’s criteria, so they can be included in the Local Plan and preserved for the community.

Are there any local areas of green space that you think the Council should protect?

The local plan should set an objective that all communities have a right to a quality allocation of green space, protecting the well-being of residents

This is largely an issue for local responses, but the Council should honour the pledge made earlier this year to protect designated open spaces, including those not in its ownership.

Strengthening retail health

What type of development do you think should be encouraged both in the Town Centre and other centres?

With fundamental changes on the high street which will only escalate further, serious consideration needs to be given to whether retail space needs to contract, thus allowing potential areas to be used for housing.

Given that the major banks are closing local branches because of the shift to online banking, could retailers be encouraged to offer part of their premises as banking hubs in local centres, where a large part of the footfall now has been older people who need access to traditional banking serives?

Could empty shops be used for popup leisure facilities on the lines of the table-tennis room in the Fareham Shopping Centre?

Can a way be found to reconcile new homes in shopping centres with pressure on already-crowded parking?

Potential areas for new growth

Are there areas that you think would support future growth or that merit protection from any future development?

Land around Welborne Garden Village

Largely with the exception of land close to Junction 11 being promoted for commercial use the Council has not received details of any land being promoted in this area, all of which is in private ownership. Additionally, this area is considered to be a valued landscape with limited scope to accommodate large-scale development.

The original proposal for Welborne was for some 10,000 homes, not 6,000. If the sustainable garden village concept can’t accommodate expansion, the Local Plan should explain why not.

And it should consider whether planning complexities surrounding Welborne mean that the housing delivery targets for the development are likely to be downgraded.

Land west of Portchester

A large site to the north west of Portchester, known as land West of Downend Road, has been promoted for development. There are on-going discussions with highway authorities and site promoters about whether access and capacity issues could be successfully overcome for development to come forward.

If the transport constraints could be resolved, do you think this area could support good growth?

No evidence is given that the transport constraints could be resolved.

Given its proximity to Portsdown Hill, shouldn’t the question be asked whether this is a valued landscape? And would development leave Portchester with adequate open space, given that there is virtually none between the A27 and the railway line?

To the south west of Portchester, whilst the Cranleigh Road Appeal opened the door to development land close to the urban edge, areas of undeveloped valuable landscape remain along the coastal area. No further sites have been promoted to the Council in this coastal area since the 2017 consultation. Additionally, the Council recognises the importance of the undeveloped coast and its limited scope to accommodate further development.

The importance of the undeveloped coast deserves more consideration in the draft plan as a whole. Other than the current discussions over nitrates, what assessment has there been on the effects of development on marine life?

Land between Fareham and Stubbington

This is a large area of open countryside south of Fareham and to the north east of Stubbington. There is an approved application to build the Stubbington bypass within this area, but extensive areas have been promoted to the Council for development.

The Council already proposed to allocate land east of the new Newgate Lane for housing in the 2017 consultation document. The alignment of the new Stubbington bypass may limit the area’s potential for development, particularly in terms of noise.

Previous planning policies have designated this area as a strategic gap in order to prevent coalescence between Fareham and Stubbington and help to define distinctive communities. Given the additional housing requirement, the Council is having to look again at the purpose of this existing strategic gap and its characteristics.

Careful planning could prevent the coalescence of these two settlements and deliver much needed housing, which could bring with it significant community, leisure and environmental benefits.

Do you think this area could support good growth?

The last statement is question-begging. Could development on the eastern flank beyond the land allocated east of Newgate Lane in the 2017 draft plan be achieved on eastern flank without destroying the rural feel of the established settlement around the old course of Newgate Lane?

Should it also be looked at in conjunction with the Alver Valley as part of a continuous separation zone between Fareham and Gosport?

Can lthe farmland straddling Peak Lane with its informal leisure opportunities relative absence of light pollution be encroached on without diiminishing the sense of separation and is an important leisure resource.

Again the question can be asked whether this is a valued landscape, particularly given the presence of Crofton Old Church and other historic buildings.

Meon Valley

Some areas of land are being promoted for development within the Meon Valley.

This is the most significant area of valued landscape in the Borough and benefits from a number of environmental protections. The merits of this landscape have been recognised by recent appeal decisions at Old Street in Hill Head and land east of Posbrook Lane in Titchfield. These decisions endorsed the Council’s view that the Meon Valley is an important landscape and that the proposed new housing would have had a negative impact.

To date the Council has not considered land between the Fareham and the Western Wards the most suitable for development and has designated this area as a strategic gap. The Council will also be working with PUSH to consider the potential for greenbelt land across local authority areas. For example, there could be scope for this area to become part of a South Hampshire Green Belt or to be protected in other ways. Consequently, the Council could consider designating this area or other areas as a valued landscape.

Should this area remain protected from development by the Council?

See the previous answer. Should the Meon Valley and the adjoiniing farmland to the east of it not be viewed together as separating the urban areas.The mention of Green Belt looks like window-dressing unless there is some indication of its intended extent and the measures which would protect it. Similarly, in what “other ways” could the area be protected?

Land south of Locks Heath

Most of the land to the south of Locks Heath is not being promoted for development. This area has few urbanising features, such as roads or buildings, and is largely in agricultural use. Additionally, the undeveloped landscape along the coast is highly valued by residents and visitors.

With this mainly rural landscape and isolated location it would be difficult to support large-scale development here although some limited small-scale development may be appropriate adjacent to the existing urban areas.

Would you support limited small-scale development in this area?

The term “Isolated location” is question begging, since no consideration is given to negotiations with suppliers to improve public transport links, as was done in regard to the proposed BRT extension to Welborne.

Should te relative proximity of Locks Heath district centre and the Community Hospital not be considered in this context? This is certainly a highly valued landscape. But the question should be asked whether a larger, sustainalble deveopment might have a lesser impact than smaller piecemeal developments.

Land to the west of the Western Wards

The Council already proposed to allocate land for housing development north and south of Greenaway Lane in the 2017 consultation and many of these sites have received a resolution to grant planning permission from the Council. Other, smaller areas have been promoted to the Council and where these lie adjacent to the settlement, these could be considered good growth opportunities. However, beyond the built-up area, there is an important stretch of undeveloped rural landscape alongside the Hamble river.

Given the valued landscape along the Hamble, it would be difficult to support large scale development here, but, again, limited small-scale development may be appropriate close to the existing urban area.

Would you support limited small-scale development in this area?

What does small-scale mean in this area? Small groups of affordable homes? Or more large riverside houses in substantial grounds? This question is too vague to be meaningful.

Land around Swanwick station

The Council has already proposed to allocate land for housing development at Beacon Bottom, but significant areas of land are being promoted both north and south of the motorway within reasonable proximity to Swanwick station.

This area could be suitable for development, either on a small scale or more significant development close to the railway station?

Would you support small-scale development or larger scale if close to the railway station?

As with Fareham railway station, development which encourages use of the rail link would be desirable, providing it doesn’t inhibit existing park-and-ride usage.

Land around Burridge

To date the Council has not considered proposing large-scale development here because of the relatively limited access to services. This has been supported by a recent appeal decision at Sopwith Way. However, significant areas of land are being promoted in and around Burridge.

This area could be suitable for limited small-scale development close to the existing built-up area in Burridge.

Would you support limited small-scale development in this area?

As with the land south of Locks Heath, would larger development with sustainable services and improved transport links have less impact on the landscape than piecemeal development?

Does its proximity to the motorway offer opportunity for growth without undue pressure on feeder highways?

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