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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.

Daily Echo, 4 May 2018: THE Liberal Democrats have again emerged as the winners on Eastleigh Borough Council with a landslide victory in yesterday’s election. But it wasn’t all plain sailing, as they lost all three seats in Bishopstoke to Independent candidates with deputy leader Anne Winstanley being one of the Lib Dems to lose out. After the count, which saw all 39 councillors up for election, the Lib Dems have won 32 seats to the Conservatives’ four, along with three Independents. Jubilant Independent candidates: Lou Parker Jones (who won the most votes, pictured), Ray Dean and Gin Tidridge said they were expecting such a result and felt overwhelmed with the support they had received. Watch video of Independents celebrating being elected to Eastleigh Borough Council!

ADD UPDATE, 1 May 2018: Ahead of the local elections this Thursday, 3 May, ADD has invited each candidate standing for Eastleigh Borough Council (EBC) and Winchester City Council – as well as in the parish elections in Allbrook and North Boyatt, Chandler’s Ford, Hiltingbury, Colden Common & Twyford and Owslebury – to supply us with up to 350 words on their views on EBC’s Local Plan.

As you will be aware, on 11 December last year, EBC chose ‘options B and C’ for its Local Plan, namely proposals for 5,200 houses and a major new road north of Bishopstoke, Fair Oak and Allbrook and south of Colden Common, Owslebury and Upham, significantly affecting Boyatt Wood, Chandler’s Ford, Hiltingbury, Otterbourne, Brambridge, Highbridge, Twyford and Bishop’s Waltham.

As part of this virtual hustings, Chris Yates, Conservative candidate for Hedge End South, has sent us the following email:

“I am standing as a Conservative candidate in Hedge End South with Jerry Hall and Andrea Lunnon. I am currently a Hedge End town councillor and have been since 2015. I was not able to involve myself in local politics before this as my previous employment precluded me from doing so.  There can be no argument that I am new to this process but that said I have lived in Hedge End all my adult life and Botley during my childhood. 

I have watched the areas change from small villages to almost one sprawling town. Where have the green fields gone? We all know the answer to that.  The over-development in Boorley Green, Hedge End and Hamble alone beggars belief. The road networks cannot cope with the traffic already and will only get worse, doctors’ surgeries are oversubscribed etc – and there’s still no Local Plan!

I honestly believe it is time for change but the only way to do that is to remove the councillors that are currently in post and this coming election is the ideal opportunity to do this. All borough seats are up for election and the Conservatives are the only party that have a realistic chance of beating the Lib Dems. This will only happen if people get out and vote and are vocal. Residents of Easleigh borough need their stories not just told but heard so that others can see that what we have is not a bed of roses.”

Chris Yates, Conservative candidate for Hedge End South on Eastleigh Borough Council

ADD UPDATE, 30 April 2018: Ahead of the local elections this Thursday, 3 May, ADD has invited each candidate standing for Eastleigh Borough Council (EBC) and Winchester City Council – as well as in the parish elections in Allbrook and North Boyatt, Chandler’s Ford, Hiltingbury, Colden Common & Twyford and Owslebury – to supply us with up to 350 words on their views on EBC’s Local Plan.

As you will be aware, on 11 December last year, EBC chose ‘options B and C’ for its Local Plan, namely proposals for 5,200 houses and a major new road north of Bishopstoke, Fair Oak and Allbrook and south of Colden Common, Owslebury and Upham, significantly affecting Boyatt Wood, Chandler’s Ford, Hiltingbury, Otterbourne, Brambridge, Highbridge, Twyford and Bishop’s Waltham.

As part of this virtual hustings, Ray Dean, Independent candidate for Bishopstoke on Eastleigh Borough Council, has sent us the following email:

“Having never been a member of any political party, I am standing as a truly independent candidate for the borough council elections on 3 May.

I believe that there is no room for party political “bun fighting” at local government level and that councillors should represent the views of their electorate.

I have supported ADD’s campaign from the start because I feel that EBC’s options B and C for the Local Plan will be disastrous for our community: increasing traffic, not providing the homes required to meet the local need, destroying our countryside, and over-stretching our infrastructure and local services.

For truly independent representation at the borough, vote Independent. Thank you.”

Ray Dean, Independent candidate for Bishopstoke on Eastleigh Borough Council