ADD’S SUBMISSION TO REG 19 CONSULTATION – ALL EYES ON THE PLANNING INSPECTOR
A big ‘thank you’ to the hundreds of residents who registered objections to Eastleigh’ Borough Council (EBC)’s Local Plan during last summer’s (Regulation 19) consultation period.
Links to ADD’s submission, which like everyone else’s has been sent to the planning inspector, are below. You’ll see that it’s wide-ranging and extensive, and draws on the evidence of an impressive array of consultants and other experts, all pulled together by our planning consultant and planning barrister.
Our work, much of which was carried out by unpaid volunteers, has left us even more convinced that there are big gaps, inaccuracies and contradictions in EBC’s evidence base, as well as serious flaws in their processes.
We demonstrate there are better, less destructive ways to meet Eastleigh’s housing targets. Eastleigh’s Plan will do virtually nothing to help local people find homes. It will, though, mean handsome profits for the developers – £250 million according to an EBC study.
In short, we are buoyed by the tremendous and growing level of local support and the strength of our case – and the realisation that we can win this battle. All eyes now on the planning inquiry in a few months’ time!
The progress we have made so far has been possible only thanks to the generosity of the public. Without your donations we could never have engaged the professional support that has been so essential to our work. The studies they have produced are below; you’ll see they are of the highest quality.
If you are affected by Eastleigh’s Plan, either directly or because you love the ancient woodlands and the glorious river and countryside that are threatened by these proposals, or because the estimated 26,000 extra daily vehicle movements will create road misery or simply because you loathe the injustice of it all, then we ask you to give money to the cause. If ADD is going to succeed we need to continue to commission the best transport, ecology, planning and legal advisers to make our case.
To donate, click here.
We know we are asking a lot but hopefully you will agree it’s a small sacrifice to make for the future environment and quality of life of this special part of Hampshire.
ADD’s representation, August 2018
- Main report (response to question 4 for policies S5 and S6)
- Appendix 1 – Aquascience report (River Itchen SAC)
- Appendix 2 – Phlorum report (ecology)
- Appendix 3 – DTA report (transport)
- Appendix 4 – Terra Firm report (landscape)
- Appendix 5 – Hereward Phillpot QC – opinion, July 2017
- Appendix 6 – Hereward Phillpot QC – opinion, December 2017
- Appendix 7 – Report and Masterplan for Allington Lane
- Appendix 8 – Email from Professor Rob Wilby, Loughborough University (flood management)
- Response to S5 and S6 (b)
- Response to S4 and S5 – Employment
- Response to S2 and S3 – Housing
Eastleigh Borough Council (EBC) is without a Local Plan. Its last attempt to agree such a plan was thrown out by the planning inspector in 2014. A new plan, which will cover the period to 2036, is now nearing completion. Our aim is to ensure EBC adopts a fully evidence-based Local Plan.
- We recognise that as a growing, successful borough, Eastleigh needs to provide thousands of new homes to hard-working people. Managed well, developments of this nature could make a significant contribution to the economic, cultural and social fabric of the borough. These developments are inevitable, but need to be done right.
- EBC’s identified two Strategic Growth Options (SGOs), namely options B and C or options D and E, one of which it said had to be chosen if the borough is to deliver the 3,350 houses it says it needs beyond the numbers already identified in the plan period.
- Despite these SGOs being developer-led, we believe that if EBC chose the right option, the resulting developments could bring widespread benefits across the borough of Eastleigh: (i) they could improve transport links by opening up rail connections between Eastleigh, Fareham and on to Portsmouth; (ii) they could help build stronger communities by creating comfortable homes, including affordable homes, for families and doing so in a manner that integrates these new homes successfully into the borough, building stronger, closer ties between people; and (iii) they could also be managed in a way that minimises environmental impact. Eastleigh is fortunate to have some of the finest countryside in South East England and this needs to be carefully preserved.
- A plan to deliver each of these requirements already exists. However the leader of the council’s choice for its SGO – options B and C (5,300 houses, nearly 2,000 more than required, and a new link road north of Allbrook, Bishopstoke and Fair Oak) – would create an isolated community on the northern edge of the borough, separated from the rest of the borough, hampered by inadequate transport links (which will be heavily road dependent) and one which cause irreparable long-term harm to the beautiful countryside.
- Approval of this choice by the government planning inspector would be a major blow for the whole of the borough as well as several adjacent communities, now and for generations to come. It would cause real, lasting damage and fail to capitalise on the positive potential development of this scale could bring to the borough.
- All we want is for EBC to adopt a fully evidence-based Local Plan.
On 23 December 2015, Eastleigh Borough Council (EBC) published its Local Plan 2011-2036 (Issues and Options), which set out eight spatial strategy options for meeting its planning needs. On 20 July 2017, it identified two SGOs, options B/C and options D/E. On 11 December 2017, EBC chose options B and C (see developers Highwood and Drew Smith’s proposal here). We believe these plans are by far the most destructive and impractical of all the options available. In particular we believe proposals for options D and E, now discarded by the council, offer a more sustainable solution than options B and C because:
- They are closer to the centre of the borough and more readily relate to the employment areas of Eastleigh and Southampton.
- They could be well served by an integrated transport strategy, including cycle routes and walkways into Eastleigh, a new station on the existing rail line (and/or a rapid transit system to Eastleigh or Hedge End stations), and a new Junction 6 of the M27.
- They are of less environmental quality than options B and C.
- This development area was favoured in the past by EBC’s own planning department and met with the approval of major conservation groups.
Our plan is to persuade decision-makers of the merits of our arguments by reference to clear evidence.
Why building 5,300 houses north of Fair Oak and Bishopstoke is the council’s most destructive option
Destructive traffic impact
- The development will only be accessible by road, far from infrastructure. The Campaign for Better Transport agrees that local traffic will get will get worse without a public transport solution.
- The new road will use the current Allbrook railway bridge, frequently flooded, too low for large lorries: it cannot ease Eastleigh’s truck congestion.
- The council expects the 26,000 extra daily traffic movements to be channelled via the M3 at junction 12. We assess congestion will increase on all local roads, through our communities, villages and the South Downs National Park.
Destructive to our communities
- The Campaign to Protect Rural England supports our campaign, concerned that quality of life will be damaged in our area.
- Fair Oak will double in size, with fewer accessible green spaces.
- The new road will divide Allbrook, splitting the village in two.
Destructive to our woods, River Itchen and wildlife
- The Woodland Trust say that building the road in the 120 metre gap between Crowdhill Copse and Upper Barn Copse will damage their Sites of Ancient Natural Woodland.
- The Test and Itchen Association are concerned that the road will damage the Itchen which has European conservation status.
- Acres of countryside and miles of footpath will become housing estates. Naturalist Chris Packham describes this as “eco vandalism”.
Some people ask why we focus our time opposing options B and C and encouraging more sustainable options rather than fighting the housing numbers imposed upon us by Eastleigh Borough Council (for it is EBC that sets these numbers, with guidance from PUSH).
First of all, everybody should know that, whilst we recognise we need more housing, we resolutely oppose the level of EBC’s housing numbers. That said, we also recognise that, as volunteers, our time is in short supply so we have decided to support the excellent work being carried out by Campaign to Protect Rural England (CPRE) who are challenging these numbers on everyone’s behalf. CPRE is a highly respected organisation and has the resources to do this far more effectively than we ever could, at EBC, PUSH and government levels.
As part of this work, CPRE is campaigning to ensure EBC makes the best use of PDL (previously developed land), otherwise known as brownfield land, including all aspects of regeneration and even housing estate densification/redevelopment if appropriate and suitable. On this matter, CPRE does not believe that EBC is being nearly ambitious enough in its targeting of redundant land. Take, for example, EBC’s decision last year to grant the site of the former civic centre approval for a new car show room, two fast food outlets and some offices but no housing at all! If anyone wishes to support CPRE’s work in this regard, please contact Caroline Dibden, chairman of CPRE South Hampshire at [email protected].
Secondly, as everyone knows, EBC had its last Local Plan rejected by the planning inspector in 2014. Officially this was because the Plan had “a number of shortcomings in relation to housing need, the identified housing requirement and housing supply”, although EBC only ever seems to refer today to the housing need. Given that EBC sets the housing numbers (and for council tax revenue purposes, it is in its interest to have as many houses as possible in the borough), we take the view that if CPRE’s efforts to reduce the numbers are unsuccessful, we must have a plan to address the consequence.
The fact is that EBC has now chosen options B and C as its preferred SGO. Given this is the hand we have been dealt, we believe that we must set out in clear terms, with all the supporting evidence, why B and C is the least sustainable, deliverable and affordable of the two options.
Of course, the best possible scenario for Eastleigh would be a council-led, rather than a developer-led Local Plan, which would think holistically about the needs of the borough. This would allow areas such as the grossly underused railway works site to proposed for new employment-related development and/or for housing to be built close to the transport hub at Wide Lane (adjacent to Eastleigh station, Southampton airport and junction 12 of the M27). But it is clear – sadly – that this is too much to ask of this council. For now.
We outline above, and elsewhere, the multitude of reasons why we oppose options B and C and advocate other available, more sustainable options, but we hope this adequately addresses why this is the focus of our campaign, rather than the housing numbers per se.