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Message from Bishopstoke Parish Council, 20 July 2018: In order to help formulate Bishopstoke Parish Council’s response to Eastleigh’s Local Plan, the council will be holding a Community Listening Exercise for residents to share their views at 7.30pm on Friday 27 July. Here is a message below from Cllr Sue Toher, chair of the council (pictured above), with the details:

“Bishopstoke Parish Council is holding a Community Listening Exercise on Friday 27 July at Bishopstoke Community Centre. The Centre will be open from 7.00pm and the meeting will start at 7.30pm.

The aim is for the parish council to hear the views of local residents on the current version of the Local Plan, which we hope you have been able to see at the recent borough council drop-in sessions. All the opinions shared will then be used when the parish council meets to decide its own response to the Local Plan.

For anyone who has not yet seen the detail of the Local Plan, a copy is available at the parish office, next to the Memorial Hall on Riverside. The office will be open on Monday and Thursday next week, but other days may be available by appointment.”

Please note that relying on your parish council’s objection to the Plan is not enough. Please submit your own objection too. For an easy guide for how to do this, click here.

ADD UPDATE, 19 July 2018: Since we posted our guidance on submitting representations on the Local Plan last week, two things have happened. Firstly, several people have told us the whole process remains too complicated. And secondly, Eastleigh Borough Council (EBC) have listened to our criticisms about their online form and made several important improvements. As a result, while our template [link] remains a valid way of submitting a representation, EBC’s form may now be the easier option.

While EBC’s online form may still look mind bogglingly complicated, it is actually a lot simpler and quicker than it looks. A few vital tips:

1. You do not have to answer all or even many of the questions. The main thing is that you are seen to make clear you think the Plan is unsound. It is ADD’s job to provide a detailed critique – and we are employing consultants to help us do so.
2. You only need complete the first two sections – i) About you (your details) and ii) Overall assessment of the Local Plan – though we encourage those who so wish to complete other sections.
3. Answering section two (Overall assessment of the Local Plan): When providing an overall assessment, we suggest you answer the legal compliance question by saying you are unsure. ADD is currently taking advice on this question. Our main argument is about its soundness. If you wish to object then you have to answer ‘no’ to the question:  “Do you consider the Local Plan to be sound?
4. You will then be asked to make comments about the soundness. It is essential to begin your answer “I/we believe the Local Plan to be unsound because …”. If you fail to use these words your submission is likely to be ignored.
5. All the other sections are optional. If you complete any of them, please always start: “I/we believe this policy to be unsound because …” This should ensure your views are considered.
6. Finally, make sure that your objection has been sent – job done!

Some of points you might like to make in answering section two:

Answering section two. Your comments can be brief. Below are some of our main objections. There’s no need to list them all, and feel free to add your own.

a) We believe the plan was predetermined. Emails that the council was forced to make public suggest that the leadership was already deciding the Local Plan in detail months before the public consultation.

b) The council then ignored the results of its own public (Issues and Options) consultation in December 2015, which showed that options B and C were by far the least popular. In fact, option B (including the new road) had more objections than the other nine options combined.

c) The council has made no serious attempt to consider the suitability of other options. In their comparison of options B/ C and D/E it uses the phrase “it is considered that” no less than 61 times.  This is no substitute for hard fact.

d) It voted to proceed with the plan on 11 December 2017 when nearly 40% of the evidence was still missing including the vital environmental impact and traffic reports.

e) It failed to provide prior consultation to bodies it was required to advise such as Hampshire County Council and the Environment Agency, making the consultation process less well informed.

f) Much of the council’s evidence is incomplete and vague (e.g. traffic impact assessment) and poorly costed (e.g. the proposed new link road).

g) The council appears to have ignored or even contradicted its own evidence in places (e.g. impact on the River Itchen Special Area of Conservation).

Other sections. You may be asked whether your comments apply to the bold text or to the rest of the text or both. Unless you have a lot of time, we suggest you stick to the bold text. As already stated, your main aim should be to register an objection to the soundness of the Plan. ADD will provide the detail.

Many people will want to answer section five – about Fair Oak and Bishopstoke, which would lose their identities, suffer horrendous levels of traffic congestion and see local amenities such as ancient woodland permanently and seriously degraded, according to the Woodland Trust among others.

Arguments should relate to good planning – for example, damage to ancient woodland and the River Itchen, damage to the landscape, the fact that the council has not modelled the traffic impact on the national park or adequately considered the Allbrook rail bridge and how the siting of the development would add unnecessarily to car use. Simply stating that you do not like something will not wash.

Again, having said you ‘oppose’ a policy, start your comments with “I/we believe the policy to be unsound because…”

For ideas for completing sections two and five of EBC’s online form, please click here – though DO REMEMBER TO USE YOUR OWN WORDS. If you use any of these examples verbatim, it will not count as a separate representation.

Please also be aware that EBC will likely want to use its form to demonstrate there is broad support for many of its policies – hence why it asks respondents to state whether they support/oppose its policies. This is not relevant to the planning inspector. What’s relevant is whether the Plan is sound or not.

Good luck! Any questions, please contact us via [email protected].

Campaign Against Urban Sprawl in Essex (CAUSE) welcomes the recent letter from the Planning Inspector about the North Essex Garden Communities Plan. In the letter Mr Roger Clews raises a number of problems with the Plan, concluding that it is unsound, and that the proposals have not been shown to have a reasonable prospect of being viably developed. The letter highlights shortcomings including major flaws in the viability appraisal of the proposals, including failure to deal adequately with transport infrastructure costs, weaknesses in the deliverability of affordable housing and no feasibility study or costing of mass rapid transit options.

ADD GUIDE, 10 July 2018: Eastleigh Borough Council’s emerging Local Plan 2016-2036 has now entered the public consultation stage.  This is the part of the formal process where the Council must seek the comments of residents, interested groups and statutory consultees (e.g., Hampshire County Highways; the Environment Agency) on whether the Plan is sound, and whether the Council has met its legal requirements in terms of the 2012 Local Planning Regulations.  A Planning Inspector will review the Plan and consider the comments that have been submitted, provided these are deemed valid. The object of this guide is therefore to help you submit a valid representation (before the deadline of midnight on 6 August).

If you care about the future of the borough, it is very important that you submit your comments as a formal “representation”.  We want to demonstrate to the Planning Inspector that there many local people who care passionately about the Local Plan. You might have made a representation at an earlier stage in this Local Plan process – the Issues and Options consultation phase, in early 2016.  This is different; this time, your comments must relate to the Proposed Submission Local Plan published in June 2018, and your representation needs to concentrate not on the policies themselves (EBC are, sadly, not going to change those), but on why the process by which the Plan has been developed is unsound.  We do recommend that you read at least some of the evidence base on the Eastleigh Local Plan website, so that you can make informed comments that will carry more weight with the Planning Inspector.  Our advice about which policies you might want to look at, with reference to legal requirements and soundness, is below, under the heading ‘EBC’s emerging Local Plan: Making a representation’.

Ways of submitting a representation

This section describes the available mechanisms for submitting a representation. Representations may be made by email or letter or via the bespoke form on the EBC website.

Note that the Council must make all representations made visible to the public, but individuals may choose not to have their name and address published with the text of their representation.

If you use EBC’s online form:

Please note that you do not have to answer every question in the online form; skip any that are not of interest and focus on the questions that matter to you.

If you would like to refer to ADD’s ‘user guide’ to the EBC form, click here.

If you are sending your representation by letter or email:

We have created a template (click here) which you may use if you find it easier than the form provided on EBC’s Local Plan pages on its website.  Our template includes prompts for the mandatory and the optional information that EBC requests in its online form. We recommend that you use the template in conjunction with the advice below, under ‘EBC’s emerging Local Plan: Making a representation’.

Click here for a sample submission. A representation on each policy requires a separate sheet (Part B).

For those who would prefer not to use our template, here are details of what is mandatory for a valid representation, and what is optional:

Mandatory

• The following are mandatory if you want your representation to be considered: You must provide your name and address (if you do not want these published alongside your representation, you must state this).
• For each policy you want to comment on, use a separate page and provide the related policy number
• For each policy you comment on, state whether you support or oppose it, and why.
• State your overall view as to the legal compliance of the Local Plan – see below (I do/do not consider the Local Plan to be legally compliant). Provide an explanation of why you take this view, and what modifications you believe are required to make the plan legally compliant.  Include reference to all of the specific policies, paragraphs and/or documents that your comments relate to.
• State your overall view as to the soundness – see below (I do/do not consider the Local Plan to be sound). Provide an explanation of why you take this view, and what modifications you believe are required to make the plan sound. Include reference to all of the specific policies, paragraphs and/or documents that your comments relate to.
• If your representation is seeking a modification to make the Local Plan legally compliant or sound, state whether you consider it to be necessary for you to participate at the oral part of the examination, and give your reasons, if you do wish to speak at the examination.

Optional

The Council also asks you to provide the following information, but you do not have to:

• Whether you are writing on your own behalf or are representing another person or an organisation.
• Your telephone number, so that any queries arising from your representation may be followed up.
• Your email address, if you wish for an acknowledgement from EBC of safe receipt of your representation.
• Your age, within a 10-year range (this is for the Council’s analysis of the demographics of the respondents to the consultation).

Where to send your representation

Letters:
Reference Local Plan 2016-2036 Consultation, Eastleigh Borough Council, Eastleigh House, Upper Market Street, Eastleigh SO50 9YN.

Emails:
[email protected]
Subject line: Reference Local Plan 2016-2036 Consultation

EBC’s emerging Local Plan: Making a representation

This section gives guidance on ensuring that your representation is valid.  It explains the tests of legal compliance and soundness.  Finally, Table 1 (below) presents some areas of the Plan that supporters of ADD’s campaign might wish to comment on in representations.  You do not need to comment on every part of the Plan; ‘skip’ the policies that do not apply and focus on the policies that are of interest to you.

There are two key parts of the Plan that the team at ADD are expecting that members of the public will want to comment on:

• The proposed new Strategic Growth Option (SGO) at Options B and C (Policy S5 – New Communities, land north of Bishopstoke and land north and east of Fair Oak)
• The proposed new road between Fair Oak and Allbrook (Policy S6 – New Allbrook Hill, Bishopstoke and Fair Oak link road)

Table 1 below shows the key issues and some further issues on which we think people might wish to comment in their representation, together with the most relevant policies.

Making sure your representation is valid

Two of the mandatory questions in the online form, which must also be addressed in written or emailed representations, relate to whether the Plan is ‘sound’, and whether the Council has met its legal requirements, in accordance with the regulations set out by the Planning Inspectorate.  If your representation does not give an opinion (I do/do not consider the Local Plan to be legally compliant; I do/do not consider the Local Plan to be sound) and an explanatory comment, your representation will not be deemed ‘valid’ and will not be looked at by the Planning Inspector.  Therefore, for each part of the Plan to which you object, it is crucial that you provide an explanation as to why you consider it not legally compliant, or not sound. Legal compliance and soundness are explained below.

Legal compliance:

To be legally compliant, a Local Plan must be prepared according to the following regulations:

• Statement of Community Involvement and other relevant regulations: the Council has a duty to consult appropriate bodies, in line with the Council’s Statement of Community Involvement.
• Duty to Co-operate: the Council must prepare its Local Plan in co-operation with the relevant local planning authorities and statutory bodies – for example, Winchester City Council; the Environment Agency. EBC’s Duty to Co-operate statement is here.
• National Policy and Legislation Compliance: the Plan must be prepared in accordance with relevant national policy and legislation – for example, the National Planning Policy Framework (NPPF).
• Sustainability Appraisal Report: the Council must carry out an adequate Sustainability Appraisal. See EBC’s Sustainability Appraisal (non-technical summary), Main report, and Appendices.
• Habitats Regulations Assessment: the Council must carry out an appropriate assessment under the Habitats Regulations.

If it fails in any one of the above tests, the Plan is not legally compliant.

For initial examples of ways in which we believe the Plan is not legally compliant, click here.

Soundness:

There are four key phrases that define ‘soundness’ in terms of a Local Plan

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, i.e., it should be based on well researched evidence.
• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
• Consistent with national policy – the plan should enable the delivery of sustainable development, in accordance with the policies in the National Planning Policy Framework (NPPF).

If it fails in any one of the above tests, the Plan is not sound.

For initial examples of ways in which we believe the Plan is not sound, click here.

Commenting on aspects of the Local Plan

There is no expectation that members of the public will wish to comment on each of the 111 policies that constitute this Local Plan.  It is perfectly acceptable to skip questions in the online form and not to address them in a written or emailed representation.  ADD suggest that our supporters focus on two or three aspects of the Plan that are of particular interest to them, and be sure to comment on at least some of the associated policies.  As a minimum, we ask you to comment on the proposed new Strategic Growth Option (SGO) at B and C, and on the proposed new road.

Remember that, to make a valid representation, you must:

1. Refer to the associated policy number, using a separate page for each policy to which you object.
2. State that you object to the policy, on the grounds of legal compliance and/or soundness.
3. Explain why.
4. State what modifications to the Policy are necessary to make the plan legally compliant and/or sound.

Table 1 proposes some aspects of the Local Plan that are likely to be of interest to ADD’s supporters, together with some of the policies that relate to them. The list is not exhaustive. Page numbers refer to the Eastleigh Borough Local Plan document (June 2018) and are provided for your reference.

Table 1 – Issues and associated policies

If you have any queries about this document or the advice given, please email [email protected]

ADD UPDATE, 6 July 2018: In our post of 23 June – ‘Eastleigh publishes Local Plan – CRUCIAL final consultation launched. Reality bites. Action required!‘ – we said we would post guidance today on how to make valid representations to the Planning Inspector on the soundness and legal compliance of Eastleigh Borough Council (EBC)’s Local Plan.

However, over the last couple of weeks, it has become apparent that EBC has decided to abandon the Planning Inspectorate’s standard guidelines on how members of the public and expert bodies should make representations – and adopt a new online system. We’ll post our advice as soon as we’ve digested this new system.

Stay tuned!

ADD UPDATE, 23 June 2018: Eastleigh Borough Council has just confirmed with us that all documents relating to its Local plan, including the supporting evidence, have now been published on its website. Click here for its ‘new and updated evidence base’. This fires the starting pistol for a six week ‘Reg 19’ consultation period, which will run until midnight on Monday 6 August.

We urge everyone opposed to Eastleigh’s shocking Plan, individuals and organisations alike, to submit their representations against it. Please note – and this is IMPORTANT – that any representations MUST relate to the ‘soundness’ of the plan.

The ADD team, together with all our professional advisers, are already ploughing through the documents to assess the council’s evidence. We will post guidance on how to make valid representations on Friday 6 July. All representations will then be taken into account by the Planning Inspector when the Plan goes to him or her later in the year. If you would like guidance on what you might say, please look again on 6 July. Alternatively, if you already feel comfortable writing about how Eastleigh’s Plan is clearly unsound, you will be able to ‘consult’ via this link from midday on Monday, 25 June.

This is the stage of the process we have all been waiting for – and have always fully expected! It’s now critical we all play our part in ensuring the Planning Inspector has ALL the evidence in front of him or her when the time comes. On 6 July, we will post again on how best you can make the Planning Inspector aware of the Plan’s numerous failings.

Thank you.

Eastleigh News, 20 June 2018: Campaigners opposed to the construction of thousands of homes on countryside north of Bishopstoke say they are “delighted” to have been given the support of a butterfly conservation group. A spokesperson for ADD told Eastleigh News that Butterfly Conservation was the latest group “to add to the long list of organisations concerned about Eastleigh council’s plans to devastate the most environmentally sensitive parts of the borough.” But responding, Council Leader Keith House said he is “confident” the new development will “increase bio-diversity” not diminish it. Butterfly Conservation say surveys carried out 10 years ago show the site chosen by Eastleigh council for 5,200 houses has previously supported a diverse variety of butterfly habitats and could still be home to even more species.

ADD UPDATE, 15 June 2018: Butterfly Conservation, the charity devoted to saving butterflies, moths and their habitats throughout the UK, has added its concern for Eastleigh Borough Council (EBC)’s Local Plan.

Steve Wheatley, Butterfly Conservation’s Senior Regional Officer for South East England, told us: “The land on which EBC plans to build 5,200 houses and a new road [just north of Bishopstoke and Fair Oak] is currently a really lovely area with a nice variety of habitats. 25 different butterfly species have been recorded in this area and several more butterfly species have been recorded nearby.

“A butterfly survey was walked in this area for fifteen years (1994 to 2008) as part of the UK Butterfly Monitoring Scheme (UKBMS). This highlighted the presence of these butterflies, including the White Admiral, a UK Biodiversity Action Plan (UKBAP) species and Species of Principal Importance in the Natural Environment and Rural Communities (NERC) Act 2006 (see image). It is important that local authorities take steps to conserve and enhance populations of such priority species.”

Steve Wheatley also noted that “other lovely butterflies already recorded in the threatened area include the Marbled White, Silver-washed Fritillary and Purple Emperor” and suggested that “other UKBAP species could be found, including the Grizzled Skipper and the Dingy Skipper”.

He added: “More searches and surveys for butterflies are encouraged. In addition to being lovely to see, butterfly diversity and abundance are widely accepted as an indicators of a healthy environment and a healthy ecosystem.

Steve concluded: “I hope butterflies can help to inspire support for this threatened landscape. I strongly urge local people to record butterfly sightings using the free (and fun) iRecord Butterflies app. The data collected contributes directly to the national dataset (one of the best insect databases in the world) and provides crucial evidence of the wildlife that is present and could be lost. Indeed, it would also be great if the old transect survey could be revived. This would be one of over 1,000 walked every week around the UK, providing objective methodically collected data that can be compared with other sites and which planning authorities should consider.”

If you would like to take on this weekly survey please contact Steve Wheatley on [email protected] who will connect you with Butterfly Conservation’s Hampshire & Isle of Wight Branch (www.hantsiow-butterflies.org.uk).

ADD UPDATE, 9 June 2018: Eastleigh Borough Council’s Local Plan, which includes the development of 5,200 new houses in countryside north of Bishopstoke and Fair Oak, has drawn severe criticism from many quarters for its lack of soundness. As the long list of opponents from many walks of life point out, it is simply unsustainable and undeliverable. Owslebury, just outside Eastleigh in Winchester, is one local village that is up in arms about the Plan’s significant failings, particularly with regards to transport infrastructure, and the way in which decisions have been made.

Owslebury villagers have sent ADD this video (below) that they have made to broaden awareness within their community about the Plan’s failings from their perspective and to campaign against it. We thought it was worth sharing. Do take a look: it’s short, to the point, beautifully made and extremely alarming.

ADD UPDATE, 29 May 2018: Would you and your family and friends like to be official Guinness world record breakers? If so, now is your chance! Come and support our campaign and be part of an official attempt to break the Guinness world record for the largest gathering of people dressed as trees (currently 1,000 people!). The purpose of the event is to have fun – and to draw attention to the terminal threat posed to our seven ancient woodlands by Eastleigh’s Local Plan (click on map here).

When: Saturday 7 July 2018 – 1.30pm to 3.00pm

Where: Stoke Park Junior School, Underwood Road, Bishopstoke, Hampshire, SO50 6GR

Dress according to Guinness guidelines: brown trousers, green top and headdress with branches and leaves on it (these can be fake or the real thing) – see picture above. Alternatively, design your own head-to-toe tree costume. This will need to be pre-agreed a few weeks in advance by Guinness, so please contact the organisers direct (see contact details below).  

Bring as many people dressed up with you as you can! All branches of your family and neighbourhood welcome, whatever age! This will be a truly memorable, and hopefully historic, event! 

The current world record of 1,000 ‘trees’ is held by the people of Mumbai, India. Can the people of South Hampshire do better? Surely! Root for our trees and join us.

PLEASE SPREAD THE WORD HOWEVER YOU KNOW HOW!

Minimum £1 donation to enter. 

To find out more, contact Charlotte and Mark: email: [email protected]; mobile: 07775 693994.