Comments on Local Plan

Unique Reference Number: 
BSGD-C6-LPU23-702
Status: 
Submitted
Author: 
Winchester City Council
No. of documents attached: 
0
Author: 
Winchester City Council

Comments

The Spatial Strategy – Between Now and 2040

Policy box, Figure or Paragraph Number: 
Support

Housing numbers

Figure 4.1: Housing Requirements

Notwithstanding any concerns regarding specific allocations, WCC welcomes the aspirations of the Spatial Strategy and Policy SPS1 Scale and Distribution of Development to accommodate all of the required housing need within the Borough, including an additional 10% buffer.  WCC are also able to meet all of our required general housing needs within the Winchester District and have therefore not asked BDBC to accommodate any unmet housing needs.

WCC will continue to keep the matters of housing requirements and supply under review via ongoing meetings, the formal Duty to Cooperate process and consideration of this issue within the Statement of Common Ground.

Policy HSG9: Gypsies, Travellers and Travelling Show People

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Comment

WCC supports the aspiration of Policy HSG9 to meet all of the identified needs for gypsy and traveller pitches, mostly within the boundaries of strategic development sites; whilst recognising that the extent of need has yet to be identified.

Officers from BDBC will be aware from our correspondence that WCC does not have sufficient capacity to fulfil the identified need for gypsy traveller pitches and we would welcome any contribution that BDBC may be able to make towards fulfilling these needs.  To this end WCC has already formally requested help with meeting Winchester’s unmet needs.  In the response BDBC indicated that it was not currently in a position to make any provision for the gypsy and traveller pitches of WCC.

WCC will continue to work with BDBC on the identification and fulfilment of required needs though ongoing cooperation under the Duty to Cooperate mechanism. This issue is expected to form part of the Statement of Common Ground between the two authorities.

Policy ENV4: Nutrient Neutrality

Policy box, Figure or Paragraph Number: 
Support

The Council supports the aim of Policy ENV4 to require measures to address the nutrient impact of new developments.  WCC shares the Test and Itchen catchment area with BDBC and we will continue to work with BDBC on this issue through the Duty to Cooperate.  This issue is expected to form part of the Statement of Common Ground between the two authorities.

Policy ENV11: Energy standards

Policy box, Figure or Paragraph Number: 
Support

Officers from WCC support Policy ENV11: Energy standards that includes Energy Use Intensity (EUI) measurements and we would been keen to encourage joint working between Officers at WCC and BDBC on this key policy area in light of the Government’s Written Ministerial Statement on Local Energy Efficiency Standards.

Policy SPS5.4: Southern Manydown

Policy box, Figure or Paragraph Number: 
Comment

The Council notes the substantial proposal at this location for 7,500 new homes in total (2,400 over this plan period) and a significant amount of other development including a new hospital and health campus.  The location of this site is immediately north of junction 7 of the M3 with a principal access proposed from the A30 (which becomes the A303 further west, leading to Popham and the Winchester District beyond).

Before BDBC progresses to the Regulation 19 stage, it is essential that further work is undertaken on this long-term complex strategic site which must be supported by a comprehensive transport assessment and travel plan that includes consideration of wider impacts including on links to the Winchester administrative area.  Opportunities to support the development of public transport links that extend to the wider area will need to be fully explored before BDBC progress to the Regulation 19 stage, particularly around the proposed new hospital which is intended to serve some of the health needs of Winchester residents.

Policy SPS5.5: Popham Garden Village

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Object

It is extremely disappointing that we are not aware there has been of any specific engagement has taken place with WCC Officers, WCC Ward Councillors or Micheldever Parish Council regarding the wording of the supporting text and the site allocation policy given that the site is located directly adjacent to the WCC administrative boundary.  This should of, in our opinion, taken place before the Reg 18 stage. 

As this site allocation is directly adjacent to the WCC administrative area, in line with the Duty-to-co-operate, meaningful discussions about this site should have taken place prior to the publication of the Regulation 18 Local Plan.  The site allocation is completely silent on the fact that the Popham Garden Village is located immediately adjacent to the WCC administrative boundary which is a considerable oversight. 

Background to development in this area

BDBC will be aware that there have been proposals for a new settlement at Micheldever Station have a very long history as a new settlement was first put forward in 1980s and early 1990’s.  It was vigorously promoted for 5,000 dwellings at the Examination in Public of the Hampshire County Structure Plan in 1991.  The proposal was rejected by the Examination in Public (EIP) Panel, which concluded that there was no requirement for a new settlement.  The Secretary of State endorsed this view and the proposal was, not therefore, included with the Structure Plan, which was adopted in 1994. 

The proposal was again promoted by Eagle Star in relation to the Hampshire County Structure Plan Review during 1990s for 3,000 dwellings.  The site was not included in the Structure Plan Review which was adopted by HCC in March 2000.

The Micheldever Station site was promoted for 12,500 dwellings in the South East Plan.  The site was again rejected by the EIP Panel Report which gave full consideration to this option but concludes by listing various reasons why such a proposal would not be appropriate, sustainable or consistent with the Plan’s strategy (paragraph 26.33 of the EIP Panel Report).  The conclusions of the EIP Panel were very clear that the new settlement at Micheldever Station were not sustainable and the site was not included in the South East Plan.  

It is important to add that despite the site being rejected in the South East Panel’s Report, the site promoters (Eagle Star) put the Micheldever Station site forward for 12,500 dwellings as part of the Government’s invitation for “Eco Towns” in December 2007. Not surprisingly, given the unsustainable nature of the scheme, as noted in the EIP Panel Report, the site was not shortlisted by the Government as an Eco Town and the proposal was rejected by the Government in April 2008.  There was a subsequent challenge to the adoption of the Winchester City Joint Core Strategy which was upheld and the Micheldever Station site was not allocated for development in the WCC’s Joint Core Strategy.  

One of the key differences between the proposals for a new settlement at Micheldever Station and Popham Garden Village is that this site is even more  isolated and the railway station is located via an underpass on the opposite side of the A303. 

In view of the above, WCC objects to the allocation of the Popham Garden Village in the BDBC on similar grounds to the EIP Panel Report which are:

  • This is a remote rural location that cannot support this level of development;
  • Due to the level of infrastructure that would be required, the proposal would be unable to make any significant contribution to meeting need for housing for a number of years;
  • When the site is compared to other SHEELA options that are located within the BDBC administrative area, it would be an isolated location choice and there are more sequentially preferable locations that could be allocated for development; and
  • The scale of the development (which is less than the Micheldever Station proposals) would not create a sustainable community.

As mentioned above, WCC believes that for the same reasons that the Micheldever Station site has been rejected for a number of years by different Inspectors/Ministers the site allocation at Popham should also be rejected on similar grounds. 

The isolated nature of the site has been specifically highlighted in the BDBC’s own Sustainability Appraisal (page 900) which states that “The railway station at Micheldever Station which is located to the south west beyond the A303, which is likely to deter regular access by pedestrians and cyclists.  The parking facilities at this railway station are already significantly over subscribed leading to on-street parking concerns etc”.  The report goes onto state “School Travel: HCC Childrens Services state that the isolated location of this site will result in significant levels of additional traffic and additional costs for home to school transport”.  

WCC have the same concerns that have been identified in the BDBC Sustainability Appraisal as this site allocation appears an isolated site that is facing towards WCC administration area rather than being directly related to the needs of Basingstoke in terms of the location of main access road and the reliance on the services and facilities in Micheldever Station  The services and facilities in Micheldever Station are limited and Micheldever is in any event, a considerable distance away from the site and in the planning administration of WCC. In view of this we would question the sustainability of this particular site allocation which appears to not be related to any other development in Basingstoke.  The location of the access roads would also encourage people to use their private motor vehicles and we would question the principle of an isolated development in this rural location. 

We would also question the suitability of the Micheldever Station to Overton Road to be able to accommodate any planned active travel improvements to the Micheldever Railway Station (which is within the administrative area of WCC).   Allied to this, given the rural nature of the Micheldever Station to Overton Road it is also very unlikely in our opinion that people would walk/cycle to the railway station given that this involves walking/cycling underneath the A303 which is often prone to flooding and there is very limited lighting along this route. 

The station car park (which is also within the administrative area of WCC and has been highlighted in the BDBC Sustainability Appraisal as having capacity issues) has limited and over subscribed car parking capacity, no disabled access arrangement and is very restricted in terms of being able to expand.  We are also aware that the railway station and the train service have capacity issues and railway station has short platforms.  As all of the above planned active travel improvements, which fall within the WCC administrative planning area, question the suitability of this site to be able to accommodate 3,000 dwellings. 

Nutrients

Officers understand that the Popham Garden Village site is located within the River Test catchment area and as a result of this, the site allocation would need to demonstrate nutrient neutrality for total nitrogen. Paragraph 5.7 of the Addendum to the Water Cycle Study states that this is to be achieved through on-site mitigation measures. WCC has not received any information as to how the on-site mitigation will be provided or evidence of the site nutrient mitigation strategy as highlighted on page 920 of the Integrated Impact Assessment Appendices.

Summary

In summary, Winchester City Council does not consider this to be an appropriate location for 3,000 homes.  It is extremely disappointing given the fact that site directly adjoins the administrative boundary of Winchester/Basingstoke that no specific engagement has not taken place about the appropriateness of this site allocation and the infrastructure that would need to be delivered to support it (which is largely in Winchester City administrative area). 

WCC has commissioned HCC Trading Arm to produce a Strategic Transport Assessment to support the Winchester City Council Regulation 19 Local Plan.  Any cumulative impact on the highway network will need to use the highway data for this study. 

In view of the above, WCC would like to reiterate its objection to the Popham Garden Village site allocation.  It will be essential that Basingstoke & Deane demonstrates and fully justifies before progressing to the Regulation 19 stage, that this site allocation is not only a suitable and in a sustainable location for future development but other more sequentially preferable sites have been fully explored and exhausted. 

Information

Unique Reference Number: 
BSGD-C6-LPU23-702
Status: 
Submitted
No. of documents attached: 
0