ellen kendrick barch (hons) assistant planner boyer ... · pdf fileboyer planning wokingham t:...

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From: Ellen Kendrick [[email protected]]Sent: 21 November 2013 17:11To: Planning Policy and Urban DesignCc: Tim Burden; Donna PalmerSubject: Local Plan (Allocations) - Representations o.b.o. Markfield InvestmentsAttachments: Representations on behalf of Markfield Investments.zip

Dear Sir/Madam,

On behalf of our client Markfield Investments, please find attached our representations to the current Regulation 19 consultation on the Local Plan (Allocations) Publication Version. The zip file attached includes the required forms (x4), our statement of representations and a Preliminary Development Proposals document.

Please confirm receipt of this submission, and do not hesitate to contact me if you have any queries.

Regards,

Ellen Kendrick BArch (Hons) Assistant Planner Boyer Planning Wokingham

t: 01344 753 090

Correspondence Address: Crowthorne House, Nine Mile Ride, Wokingham, Berkshire, RG40 3GZ. Boyer Planning Ltd - Registered Address: Crowthorne House, Nine Mile Ride, Wokingham, Berkshire, RG40 3GZ. Registered in England 2529151. To see full disclaimer that applies to this email please click here. To see our Standard Terms and Conditions of Contract please click here.

mailto:[email protected]

UNIT 2 MONTPELIER BUSINESS PARK • STATION ROAD • BRISTOL • BS6 5EE

T 0117 942 8286 W ANGUSMEEK.CO.UK

F 0117 942 0495 E [email protected]

20TH NOVEMBER 2013 - REVISION B

2317 •LANDOFFHAVANTROAD,EMSWORTH

DS02 • PRELIMINARY DEVELOPMENT PROPOSALS

01

2317 • LAND OFF HAVANT ROAD • EMSWORTH DS02 • 20TH NOVEMBER 2013 - REVISION B

INTRODUCTION

This document aims to set out the context for the potential development of land to the south of Havant Road on the western edge of Emsworth.

It aims to provide an overview of the preliminary specialist reports to date, with specific commentary on the established constraints of the development site including planning policy, flood risk and drainage.

It will also provide an analysis of the existing site to establish the physical constraints and opportunities, which will inform detailed design parameters. This will include access to the site, topography and landscaping and a consideration of the nett developable area given the constraints outlined above.

An overview of the surrounding built environment will also be included.

02


PLANNINGPOLICYOVERVIEW

• Enclosedsitewithdefinedboundaries;• GoodaccessontoHavantRoad;• Protectlandtosouthfromfurtherdevelopmentand

opportunitytoreinforcelandscapeedge.

BoyerPlanningconsiderthatinadditiontotheabove,furtherbenefitsincludeit’saccessibilitytoarangeoffacilitiesanditsproximitytopublicfootpaths,includingthecoastalpathlocatedtothesouthofthesite.Furthermore,itisarguedthatthesiteisinasustainablelocationwithinapproximately1.3kmofEmsworthdistrictcentrewherearangeoffacilitiesareaccessible.Thedistrictcentrecanbereachedbyfoottakingapproximately15-20minutesor8-10minutesbycycle.FootpathsandcyclelanesarealreadyinusealongtheHavantRoad,providingasafeandpopularaccessintothecentrefromthewesternsideofEmsworth.Inaddition,numerousbusstopscanbefoundintheimmediatevicinityofthesitealongHavantRoad.Withthenetworkofsustainabletransportoptionsavailablefromthedevelopmentsite,itisnotconsideredthatitsdistancefromthetowncentreisaconstraint.

TheotherconstraintspreviouslyidentifiedabovebyHBCinrelationtothedevelopmentsitearealsoconsideredintheconsultationresponse.

Local Gap & AONBHankinsonDuckettAssociatesLandscapeConsultantshaveproducedareportstatingthatthedevelopmentsiteissuitablefordevelopmentasitisvisuallywellcontainedfromallsignificantviewpointswithinthesurroundingAONB,andconsiderthatthedevelopmentofthesitewouldmakealogicalextensiontothesettlementbyvirtueofitscloseassociationwithHavantRoadandtheexistingurbanedge.Thereportcontinuesbyrecommendingstructuralplantingtothesouthandwestboundariestoreinforcethecontainmentofthesite.

ItisconsideredthattheconclusionsreachedontheimpactoftheAONBalsoapplytothelikelyeffectontheLocalGap.Furthermore,itisarguedthatthedevelopmentofthesitewouldhavenoeffectontheseparationofthetwosettlements.

Flood Risk & DrainageItisacknowledgedthatupto20%ofthesiteisinafloodzoneandafloodriskanddrainageassessmenthasbeencommissionedbytheclienttoinformthedetailedlayoutforthesite.Thefindingsofthisdocumentarediscussedlaterinthisdocument.

Please also refer to Boyer Planning ‘Consultation Response to the Draft Local Plan (Allocations)’ document for further details on planning policy.

HavantBoroughCouncilhavepublishedtheirLocalPlan(Allocations)Publicationversionforconsultationendingon22ndNovember2013.ThisDevelopmentProposalsDocumentaccompaniestheconsultationresponsepreparedbyBoyerPlanningtothisconsultation.

WorkonthepreparationoftheLocalPlan(Allocations)followstheadoptionoftheCoreStrategybytheCouncilinMarch2011.TheCoreStrategysetahousingtarget(PolicyCS9)of6,300newdwellingsbetween2006and2026withapproximately12%(826)ofthesedwellingstocomeforwardfromtheEmsworthsub-area.

ThecurrentconsultationbuildsontheearlierconsultationontheDraftLocalPlan(Allocations)documentinDecember2012,whichhadbeeninformedbyanumberofconsultationdocumentsavailableinthepublicrealmincluding:

• HousingSites:WhichWouldYouChoose?

• HousingSiteEvaluationMatrices• EmsworthProposedAllocations&DiscountedSitesPlan

(seeleft)

UndertheDecember2012consultationdocument,HBCidentifiedtheproposeddevelopmentsiteasapotentialallocationsite(ParcelUE11)forresidentialdevelopment,butthiswasdiscountedforanumberofreasonsincluding:

• thelikelynegativeeffectonthelocalgap;• thelikelynegativeimpactontheChichesterharbour

AreaofOutstandingNaturalBeauty(AONB);• floodrisk;• potentialdrainageissues:• thedistancefromthetowncentreandtrainstation.

HBCinsteadallocatedtwositestothenorth(ParcelsUE13&37)forresidentialdevelopment.Thesetwoallocationshavebeenretainedinthecurrentconsultationdocument,althoughfordifferentlevelsofdevelopment.BoyerPlanningproducedaConsultationResponsetotheDraftLocalPlan(Allocations)documentinJanuary2013,inwhichtheyarguedthecaseforthereassessmentofthethreesites(ParcelsUE11,13and37).

Intheiropinion,thetwoallocatedsitesshouldbediscountedandthedevelopmentsite,previouslydiscounted,shouldbeallocatedforresidentialdevelopment.

TheystatethatinrelationtolandwestofEmsworth(ParcelUE11),theCouncilconsiderthesitetohavethefollowingbenefits:

03


N

SITELOCATION&CONTEXT

E M S W O R T H

EMSWORTHRAILWAYSTATION

EMSWORTHPRIMARYSCHOOL

GLENWOODSECONDARY

SCHOOL

TOPORTSMOUTH

TOCHICHESTER

TOWN

CENTRE

R A I L W A Y

A27

L O C A L

G A P

WARBLINGTONSECONDARY

SCHOOL

WARBLINGTONRAILWAYSTATION

W A R B L I N G T O N

POTENTIALNEWLINEOFLOCALGAP

INCORPORATINGFIELDTOSOUTH

Surrounding ContextThedevelopmentsiteissituatedimmediatelytothesouthofA259HavantRoadtothewestofEmsworthtowncentre.

TheA259HavantRoadisamainaccessroadleadingintoEmsworthtowncentrefromthewest.Theroadincorporatescyclelanes,numerousbusstopsincloseproximitytothedevelopmentsite,andisflankedbyfootpathseithersidecreatingexcellentsustainabletransportlinkstovariouspublicamenitiesfromthedevelopmentsiteincluding:

• Primary&SecondarySchools

• RailwayStations

• LocalShops

• Doctor’sSurgery&Dentists

• Harbour

Local Gap Aspreviouslydiscussed,planningpolicystatesthatitisessentialforsettlementstomaintaintheirownindividualcharacterandidentitybylimitingdevelopmentandgrowththatislikelytocreateurbansprawl.Thisisachievedbymaintainingadevelopmentgapbetweensettlementsashighlightedonthediagramtotheleft. TheproposeddevelopmentsiteisontheedgeofEmsworthandconcernhasbeenraisedastotheeffectofdevelopmentonthelocalgap.

Asshownonthediagramopposite,thenarrowestpartofthelocalgapisbetweenthedwellingstothewestofSelangorAvenueandthedwellingstotheeastofWarblington.Itcanbeseenthatanydevelopmentonthesitewouldhavelittleeffectonthegapandwouldactuallyservetoenhancethesettlementboundary,particularlywhencombinedwiththefieldimmediatelytothesouth.ItisconsideredthatthiswouldcreateamorelogicaledgetothesettlementofEmsworthandprovideanequallystrongsettlementboundary.

EcologyAspecificBrentGoose&WaderAssessmenthasbeencarriedoutbyHankinsonDuckettAssociatesanditwasfoundthatthedevelopmentsite(ParcelUE11)isnotimportantforeitherBrentGeeseorWaders.

Thereisnorecordofwadersusingthedevelopmentsiteandonlyoneinstancein63separatesurveysbetween1997and2012whereBrentGeesehavebeenrecordedusingthesite.

H A V A N T R O A D

BUSSTOPS

PROPOSEDNEWLINEOFLOCAL

GAP

EXISTINGLINEOF

LOCALGAP

S I T E

BUSSTOPS

04


SITEPHOTOGRAPHSASEXISTING

VIEW EAST ALONG HAVANT ROAD VIEW WEST ALONG HAVANT ROAD

EXISTING SITE ACCESS FROM HAVANT ROAD, NORTH EAST CORNER EXISTING SITE ACCESS FROM HAVANT ROAD, NORTH WEST CORNER

BIRDS EYE VIEW OF DEVELOPMENT SITE FROM THE NORTH BIRDS EYE VIEW OF DEVELOPMENT SITE FROM THE SOUTH

05


SITECONSTRAINTS&OPPORTUNITIESN

NO

RE

FA

RM

AV

E.

SE

LA

NG

OR

AV

E.

AREAFORNEWSITEACCESS

FALL

H A V A N T R O A D

CYCLEPATH

+9.8mAoD

EXISTINGSTABLES

FLOODZONE

(3)

CYCLEPATH

TOWARBLINGTON&PORTSMOUTH

(VIAA27)

TOTOWNCENTRE

DRAINAGEDITCH

FUTUREACCESS

REQUIREMENT

EXISTINGACCESSTO

FIELD

BA

RN

CL

OS

E

EXISTINGFIELDGATE

A R E A O F O U T S T A N D I N G

N A T U R A L B E A U T Y

AccessAccesstothedevelopmentsitecurrentlyexistsatthenorthwestcornerintheformofafieldgateanddrivewayleadingtostablestothesouth.

Thereisalsoanotherfieldgateaccessatthenortheastcorner,whichleadsdirectlytothefieldbelowtheapplicationsite.

Thelocationforapotentialnewaccessintothedevelopmentsitehasbeenindicatedonthediagramtotheleft.ThiswouldbeoffHavantRoadtothenorthandcentraltothesitetoensurethattheexistingjunctionsprovidingaccesstoSelangorAvenueandNoreFarmAvenuearenotadverselyaffected.

Topography & LandscapingTheexistingsitegentlyslopestothesoutheastandfallsapproximately2mfromthenorthwestcorneracrosstothesoutheastcorner.Existingtreesflankthenorthandsouthboundariesofthesite,witheitherfencingorhedgerowsinterspersedalongtheboundaries.

ATreePreservationOrder(TPO)currentlyexistsforasycamoretreenorthofthesitetowardstheeasternend,onlandbetweenHavantRoadandthesiteboundary.

Flood Risk & Drainage Refer to Campbell Reith Consulting Engineers Flood Risk Assessment for detailed analysis. Theexistingsiteisagreenfieldsiteandsurfacewatercurrentlydischargesviainfiltrationorintothesurroundingditchnetwork.Thereisanareatotheeastofthesite,whichisinafloodzonelevel3-i.e1%(1in100)orgreaterchanceofhappeningeachyear.Thisispredominantlyduetotheeasternboundarydrainageditch,whichisclassifiedbytheEnvironmentAgencyasa‘mainriver’,whichcontinuessouth,eventuallydischargingintoEmsworthHarbour.

AnyproposedsitelayoutwillconsiderthefloodriskanddrainageconstraintsandwillseektoavoiddevelopmentinthefloodzonebyincorporatinganareaofopenspacealongwithSUDSdrainage.Furthermore,thereispotentialforafootpathlinktobecreatedalongtheeasternboundarylinkingHavantRoadwiththecoastalpath.

S I T E

( P A R C E L U E 1 1 ) FALL

BUSSTOP

BUSSTOP

BUSSTOP

BUSSTOP

TPO

NETTDEVELOPABLEAREAAPPROX.2.75HA

EXISTINGFIELDGATE

7.8mAoD+

SUNPATHSUNPATH

06


EMSWORTHLOCALCHARACTER

TYPICAL DEVELOPMENT - NORE FARM AVENUE

TYPICAL DEVELOPMENT - FAR MEADOW WAY

TYPICAL DEVELOPMENT - BARN CLOSE

TYPICAL DEVELOPMENT - SELANGOR AVENUE

CONTEMPORARY DEVELOPMENT - WESTERN PARADECONTEMPORARY DEVELOPMENT - WESTERN PARADE

Existingresidentialdevelopmentintheareavariesinage,scaleandcharacter,fromearly20thcenturydevelopmentonNoreFarmAvenueandParkCrescent,tothecontemporaryindividualplotsalongthewaterfrontonWesternParade.

Developmentgenerallyconsistsofdetachedorsemi-detacheddwellingswithoff-streetparkingandgenerousplotsizes.

Proposedresidentialdevelopmentonthesitewilltakeintoaccountthecharacteristicsoftheareaandprovideamoderndevelopment,whichfollowstheestablishedurbangrainprovidingadensityofdevelopmentappropriateforthearea.

Furtherdiscussionswilltakeplacewiththelocalauthoritytoestablishdesignparametersandprinciplestoensureahighqualitydevelopment,whichwillhaveaminimalimpactonthisareaofoutstandingnaturalbeauty.

07


APPENDIXA

Planning

• ‘Havant Borough Core Strategy’ byHavantBoroughCouncil

• ‘Havant Borough Draft Local Plan (Allocations)’ byHavantBoroughCouncil

• ‘Housing Site Evaluation Matrices‘ byHavantBoroughCouncil

• ‘Emsworth Proposed Allocations and Discounted Sites Plan‘ byHavantBoroughCouncil

• ‘Consultation Response to the Draft Local Plan (Allocations) Consultation’ byBoyerPlanning

• ‘Consultation Response to the Housing Sites - Which would you choose?’ byBoyerPlanning

• ‘Tree Preservation Order No. 1922’byHavantBoroughCouncil

Other Specialist Reports & Documentation

• ‘Flood Risk Assessment’ byCampbellReithConsultingEngineers

• ‘Emsworth Ecology Brent Goose and Wader Assessment’ byHankinsonDuckettAssociates

• ‘Electricity Search Plans’ byScottish&SouthernEnergy

• ‘Drainage & Water Search’ bySouthernWater

• ‘Highways Search’ byHampshireCountyCouncil

Note:Inadditiontotheabovereports,enquirieshavebeenmadetoHavantBoroughCouncilrequestingdetailsofanyarchaeologicalorhistoricinterestwithinthesiteandithasbeenconfirmedthattherearenone.

LIST OF REPORTS & DOCUMENTATION

08


APPENDIXB

ACCESSIBILITY PLAN

09


E M S W O R T H

EMSWORTHRAILWAYSTATION

EMSWORTHPRIMARYSCHOOL

GLENWOODSECONDARY

SCHOOL

TOPORTSMOUTH

TOCHICHESTER

TOWN

CENTRE

R A I L W A Y

A27

L O C A L

G A P

WARBLINGTONSECONDARY

SCHOOL

WARBLINGTONRAILWAYSTATION

W A R B L I N G T O N

H A V A N T R O A D

BUSSTOPS

S I T E

BUSSTOPS

APPENDIXC

SITE LOCATION & CONTEXT

10


N

APPENDIXD

STRATEGIC FRAMEWORK PLAN

11


APPENDIXE

LAYOUT CONCEPT DESIGNN

FIELDGATETOAGRICULTURAL

LANDTOSOUTH

SECONDARYACCESSFOREMERGENCY

VEHICLES

EXISTINGACCESS

RETAINED

PEDESTRIANLINKTO

BUSSTOPAGRICULTURAL

ACCESS

AMENITYSPACE

ALLOTMENTS&ORCHARDACTINGASBUFFER

BETWEENPRIVATEREARGARDENSANDRECREATION

/AMENITYSPACE

LOWERDENSITYDETACHEDANDSEMI-DETACHEDPROPERTIESTO

BOUNDARYOFSITE

SOFTLANDSCAPEEDGETO

DEVELOPMENTWITHREAR

GARDENSADJACENTTORETAINED

LANDSCAPINGTOSITEBOUNDARY

FEATUREBUILDINGTOPROMINENT

CORNEROFSITE

BUILDINGLINESETBACKFROMROAD

FRONTAGE

TPOTREESRETAINEDALONGSITEBOUNDARY

EXISTINGLANDSCAPE

BUFFERRETAINED

SINGLEACCESS/EGRESSTO

DEVELOPMENT

EXISTINGTREES

RETAINED

CLEARLYDEFINEDSTREET

HIGHPROPORTIONOFPRIVATE

GARDENSWITHSOUTHERNASPECT

LARGE4/5BEDPROPERTIESTO

ROADFRONTAGE

FOCALPOINTAMENITYSPACE

LANDMARKBUILDINGDEFININGENTRANCETOSITE

LANDMARKBUILDINGTOAIDLEGIBILITY

RIGHTHANDTURNLANE

HIGHERDENSITYDEVELOPMENTATCENTREOFSITE

LANDSCAPEPROVIDING

SUDSDRAINAGE

12


APPENDIXF

CIRCULATION STRATEGYN

PARKINGCOURT

TURNINGAREA

MAINSTREET

SHAREDSURFACEPRIVATEACCESSROAD

SHAREDSURFACEPRIVATEACCESS

FIELDGATE

FIELDGATE

PUBLIC

FO

OT

PAT

H

SECONDARYACCESSFOREMERGENCY

VEHICLES

FIELDGATE

BUSSTOP

BUSSTOP

BUSSTOP

AGRICULTURALACCESS

PEDESTRIANLINK

RIGHTHANDTURNLANE

PARKINGCOURT

SINGLEACCESS

Land west of emsworth

Havant Borough Local Plan (Allocations) Publication Version Consultation

Prepared by Boyer Planning on behalf of Markfield Investments November 2013

REPORT CONTROL

Document checking

Issue Date Status Checked for issue

1 12/11/2013 Draft TB

2 15/11/2013 Final TB

Project: Land West of Emsworth

Client: Markfield Investments

Job Number: 10.127

File Origin: \\MARTIN\Boyer Planning\Project Folders\10.127 Emsworth\LDF Reps\Site Allocations DPD\131122 Allocations DPD Pre-Submission consultation\131115 Reps - Final.docx

Primary author: Ellen Kendrick / Donna Palmer Initialled: EK / DP

Review by: Tim Burden Initialled: TB

Contents

1. Introduction ................................................................................................ 2

2. Housing Numbers ...................................................................................... 3

3. Emsworth Housing Allocations ................................................................ 7

UE13 – West of Horndean Road ........................................................................... 7 UE37 – West of Coldharbour Farm ........................................................................ 8

4. UE11 Land West of Emsworth ................................................................ 10

5. Conclusions ............................................................................................. 12

Havant Borough Local Plan (Allocations) Publication Version Consultation | Land West of Emsworth

2

1. INTRODUCTION

1.1 These representations have been prepared by Boyer Planning Limited on behalf of Markfield

Investments in respect of the Publication Havant Borough Council Local Plan (Allocations)

consultation (October 2013).

1.2 Our clients control a significant area of land to the west of Emsworth which is considered to be

suitable for development. Markfield Investments Ltd are participants in the emerging Local

Development Framework (LDF) process, through responses to various LDF documents produced

to date, including the Draft Location Plan (Allocations) Consultation that ended in January this year.

1.3 This submission is focussed on the Emsworth area and relates specifically to land west of

Emsworth (UE11). Our comments relate to both the overall housing requirement for Emsworth as

well as the sites selected for allocation.

1.4 We consider that our client’s site, UE11 Land West of Emsworth, is a suitable location for

development which warrants further consideration by the Council. Our detailed comments in

relation to our client’s site are set out in Section 5 of these representations and this section

highlights the benefits of allocating the site. As such we consider that the site should be allocated

for residential development comprising approximately 120 dwellings. A Development Proposals

Document has been prepared by Angus Meek Architects which accompanies this consultation

response, which sets out the context for the potential development of Land West of Emsworth.


3

2. HOUSING NUMBERS

2.1 The Havant Core Strategy (2011) set an overall housing target for the Borough of 6,300 dwellings

over the period 2006 to 2026 which was itself based on the South East Plan housing target. A

significant time period has elapsed since the adoption of the Core Strategy, and the preparation of

the evidence base for the Core Strategy and South East Plan on which it was based, which raises

concerns as to the appropriateness of the housing target given the significant additional

demographic and other data which has been published since this time. The importance of an up to

date housing target has been further emphasised by the experiences of both Waverley Borough

Council and East Hampshire District Council in producing their Core Strategies. As such, and given

the NPPFs support for the production of a single Local Plan (paragraph 153), it is questionable

whether the preparation of a Local Plan (Allocations) remains the most appropriate approach.

Notwithstanding this, we set out our comments on the consultation document below.

2.2 As set out in Table 3.0 of the Publication Local Plan (Allocations) the overall housing target will be

split across the five sub-areas of the Borough, with Emsworth to deliver between 745 and 826

dwellings over the plan period. The Council has calculated that the requirement for the Borough will

be delivered as follows:

Local Plan

Area

Requirement

2006–2026

Completed

2006–2013

at 01.04.13

Outstanding

permissions

at 01.04.13

Strategic

Site

Windfall

2019-

2026

Remaining to

be allocated

2013-2026

Emsworth 745 – 826 178 254 - 134 179 - 260

Havant &

Bedhampton

1755 - 1944 237 130 - 143 1245 - 1434

Hayling

Island

660 - 727 188 23 - 120 329 - 396

Leigh Park 1223 - 1357 554 32 - 76 561 - 695

Waterlooville 1917 - 2126 514 790 300 247 66 - 275

Totals 6300 - 6980 1671 1229 300 720 2380 - 3060

2.3 In calculating the number of units which remain to be allocated, the Council have considered all

potential sources of delivery. With the exception of the Waterlooville sub-area however the amount

of units remaining to be allocated in the sub-areas has increased from the Draft Local Plan

published for consultation in December 2012. The overall reduction in delivery from other sources

has largely come from the expiry of planning consents and a reduction in the windfall allowance in

each of the sub-areas. The reduction in windfall allowance is a result of windfall sites not being

included as a source of supply until 2019, whereas previously they were included from 2017.

2.4 Despite some existing planning consents expiring since the previous consultation, all permissions

as at 1st April 2013 have been subtracted from the overall requirement without any discounting for

non-delivery. The granting of planning permission is no guarantee of the delivery of these sites, and


4

we therefore consider that a 10% discount should be applied to all those sites identified as having

permission across all sub-areas to take account of potential non-delivery.

2.5 On this basis, it is submitted that the proposed housing target fails to meet the test of soundness.

The target is not justified, in that has it has been calculated on an unrealistic and impractical

assumption with regard the delivery of housing sites already permitted. As such, the Local Plan

(Allocations) is not effective as it consequently underestimates the amount of additional housing

required over the plan period, and so does not allocate sufficient housing sites to meet the

Council’s identified local need.

2.6 In addition, the housing trajectory in the Council’s adopted Core Strategy included a windfall

allowance of 37 dwellings per annum from 2020/21 onwards. The windfall allowance included in the

Publication Local Plan (Allocations), equivalent to approximately 103 dwellings per annum between

2019 and 2026, is therefore significantly higher than the level previously considered.

2.7 To justify the changed position the Council have produced an updated Windfall/Unidentified

Housing Development: Analysis and Justification Background Paper (September 2013), which

highlights the national policy approach under the NPPF (paragraph 48) to windfall development:

“Local planning authorities may make an allowance for windfall sites in the five-year supply if they

have compelling evidence that such sites have consistently become available in the local area and

will continue to provide a reliable source of supply. Any allowance should be realistic having regard

to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected

future trends, and should not include residential gardens.”

2.8 The Council have included a windfall allowance from 2019 to 2026 which in the Emsworth area is

for a total of 134 units. The Background paper produced by the Council advises that this is based

on the assessment of windfall delivery rates over the period 2006 to 2013. The Council consider

that, at Emsworth, the most reliable sources of continued windfall supply come from the following;

Residential garden land – average net gain 3.86 dwellings per annum

Residential redevelopment – average net gain 12.4 dwellings per annum

Conversion – average net gain 5.29 dwellings per annum

2.9 As before, the Council have included a discount of 10% to ensure the calculation is realistic rather

than optimistic, and on average the Council consider that 19 dwellings per annum will be delivered

on windfall sites in the Emsworth sub-area between 2019 and 2026. Although the windfall

allowance is not included as part of the five-year supply following adoption of the Local Plan

(Allocations), the guidance in NPPF paragraph 48 in assessing delivery rates remains pertinent. Of

the sites assessed in Emsworth in the latest SHLAA (6th

Edition – Updated September 2013), the

only sites considered to have potential were urban extension sites or two sites with planning

permission.

2.10 A schedule of the sites considered unsuitable is also included within the SHLAA. One of the

reasons for exclusion of sites was that they fell below the study threshold of a net gain of 5 units or

above. A total of 13 sites were excluded in the Emsworth sub-area for this reason, and assuming

that all these sites delivered the maximum amount possible below the study threshold (4 units) this

would only result in the delivery of 52 units. As such, the windfall allowance, and, consequently, the

housing target, is unsound as it has not been fully justified in accordance with the guidance in the

NPPF. The SHLAA identifies less than 40% of the number of units allowed for by the Council in


5

their anticipated windfall delivery set out at Table 3.0, and there is no indication of where these

additional sites will come forward from. This unjustified overestimation of the windfall allowance has

led to a shortfall in sites allocated for development in the Local Plan, and as such the plan will not

be effective as it fails to meet the Council’s identified local need.

2.11 As discussed above, the updated Windfall/Unidentified Housing Development Background Paper

identifies the historic windfall delivery rates for each of the sub-areas. In the Emsworth sub-area,

significant variation has been experienced annually in the level of windfall completions. The

Background Paper assumes that these trends will be replicated in the future, which, given the

findings of the SHLAA, is uncertain.

2.12 Furthermore, the Council have included residential garden land in their windfall delivery rates. The

windfall delivery rate is not included in the first five years of the plan period after adoption, which

has enabled the Council to include residential garden land in their calculations. However, since the

NPPF was published in March 2012 the policy position in relation to building on residential gardens

has shifted significantly. Private residential gardens are no longer considered to be previously

developed land, and paragraph 53 states that:

“Local planning authorities should consider the case for setting out policies to resist inappropriate

development of residential gardens, for example where development would cause harm to the local

area.”

2.13 Although the NPPF does not preclude it completely, it does take a more negative approach towards

so called ‘garden grabbing’, and so it is considered unlikely that this particular source of windfall

supply will continue at the same level. As such it is considered that the level of residential garden

land included within the windfall delivery rates is unjustified and not consistent with National Policy,

in that it fails to take into proper consideration the shift in the policy position with regards

development on private gardens brought about by the publication of the NPPF. The rate of delivery

from this source should therefore be discounted, we suggest from an average of 3.86 to 2 dwellings

per annum, in order to make the plan sound.

2.14 Overall therefore it is considered that the annual windfall delivery rate should be reduced to

approximately 16 dwellings per annum. This figure includes the reduction in the level of delivery

expected from residential garden land to 2 dwellings per annum, as well as an overall discount of

20% which should be applied to take account of the significant fluctuations which have been

experienced previously. This would result in an anticipated delivery of 112 dwellings over the period

2019 to 2026 at Emsworth, which we consider to be a more justified figure on which to base the

calculation of the remaining units to be allocated, which consequently would meet the tests of

soundness as defined by paragraph 182 of the NPPF.

2.15 Given the above considerations we consider that the figures for Emsworth should be amended as

follows:

Local

Plan

Area

Requirement

2006–2026

Completed

2006–2013

at 01.04.13

Outstanding

permissions

at 01.04.13

(discounted)

Strategic

Site

Windfall

2019-

2026

Remaining

to be

allocated

2013-2026

Emsworth 745 – 826 178 229 - 112 226 - 307


6

2.16 To meet these amended figures further sites should be allocated in the Emsworth sub-area through

the Local Plan (Allocations) to ensure sufficient housing will be delivered.

2.17 These amended figures should be taken into account when considering the allocation of sites in the

Emsworth sub-area through the Draft Publication Local Plan (Allocations) to ensure sufficient

housing will be delivered.


7

3. EMSWORTH HOUSING ALLOCATIONS

3.1 As part of the preparation of the Local Plan (Allocations) document, the Council have undertaken a

detailed assessment of all potential sites for allocation for residential development. This work is

summarised in the Council’s Site Evaluation Matrices (November 2012). This document assesses

all the potential housing sites that were considered in the Draft Local Plan (Allocations), which was

published for public consultation in November 2012.

3.2 Each matrix lists fourteen key variables for which a positive (green), negative (red) or uncertain

(amber) response was recorded for potential housing sites. Where a variable is not applicable to a

site, its response is recorded as a grey tone, for example, gaps are not designated on Hayling

Island. The variables were derived from the following sources:

National Planning Policy Framework (NPPF);

Objectives set out in the Sustainability Appraisal (SA) of the Local Plan (Allocations);

Key priorities set out in the Local Plan (Core Strategy) and Sustainable Community Strategy;

Consultation responses.

3.3 Our comments regarding the detailed conclusions in relation to each of the sites are discussed

below.

UE13 – West of Horndean Road

3.4 Land west of Horndean Road is proposed to be allocated for 140 dwellings under draft Policy EM1

(Emsworth Housing Allocations). This has increased from 100 dwellings under the previous

consultation, although the site area has not increased. The Council’s Statement of Consultation

(Appendix 1) explains that the increased capacity has resulted from “discussions with the

landowner and the EA on the flood alleviation scheme has freed up part of the site that was not

considered developable because of flood risk and therefore the site can accommodate more units

than previously indicated.”

3.5 The development of Site UE13 is identified in paragraph 3.55 of the latest Sustainability Appraisal

(October 2013) as ascertained as being “key to delivering the Emsworth Flood Alleviation Scheme”

as a result of on-going discussions with the Environment Agency, and this appears to have been

significant in the Council’s decision to allocated UE13. The Emsworth Flood Risk Strategy (October

2013) proposes that a new flood storage area will created in the arable land immediately to the

west of UE13, which will hold back water at times of high rainfall.

3.6 As we have discussed in our previous consultation response (January 2013), the site is currently

designated as a Strategic Gap (Saved Policy UF1) and an Undeveloped Gap between Settlements

(Policy CS11). This has not been identified as an important consideration in the policy wording. We

consider that land to the north of the A27 has a significant role in maintaining the perceived

separation of Havant and Emsworth.

3.7 The proposed development would be perceived as a significant incursion into the countryside to the

west of Emsworth which would be perceptible from a number of locations and would have a

detrimental impact on both the Strategic Gap and the Undeveloped Gap. The detrimental impact

would also be increased by the flood storage area to the west of the site.


8

3.8 This detrimental impact would also be further exacerbated by the increased housing number now

proposed on the site. Although Draft Policy UE13 requires a landscape buffer to the west of

development to define the site, we do not consider that this would be sufficient to overcome our

concerns regarding the impact on the Strategic Gap and Undeveloped Gap. Although we

acknowledge that the buffer would help to soften the western boundary of the development, the

development as a whole would result in a significant incursion into the gap. It is also somewhat

unclear as to whether the landscape buffer would be set between the new development and the

flood storage area or to the west of the storage area. If the former were proposed consideration

would need to be given to the need for an appropriate landscaping treatment to the flood storage

areas to ensure that the flood storage area does not further emphasis the visual intrusion of the

development into the gap.

3.9 Although a limited amount of development has taken place to the west of Horndean Road

historically, allocating development in this location would breach and erode the defensible boundary

which Horndean Road currently presents. It is considered that in addition to the impact of the

currently proposed development, the allocation itself would significantly weaken the case for the

Council’s retention of the gap in this location in future. As such, it is considered that the allocation of

site UE13 is unjustified and unsound given the significance of the impact of the development on the

Strategic Gap and the Undeveloped Gap.

UE37 – West of Coldharbour Farm

3.10 West of Coldharbour Farm is proposed to be allocated for 47 dwellings under draft Policy EM1.

This has increased from 35 dwellings under the previous consultation following an increase in site

area, which now encompasses the part of the site which is at risk of flooding.

3.11 Access to the site will be provided through this area of flood risk, however it is unclear how this

matter can be satisfactorily addressed in principle. Paragraph 100 of the NPPF states that:

“inappropriate development in areas at risk of flooding should be avoided by directing development

away from area at highest risk.”

3.12 The allocation of a site where the residents of the development would be subject to an acceptable

level of flood risk in accessing their homes is therefore contrary to national planning policy,

especially where alternative sites exist.

3.13 UE37 is also designated as a Strategic Gap. Again, this has not been identified as an important

consideration in the policy wording, and the negative impact of the development on the Strategic

Gap does not seem to have been adequately considered by the Council. Although the site is

bounded to the west by the existing petrol station accessed from the A27 it would be visually

disconnected from the main urban area of Emsworth. Hollybank Recreation Ground currently

creates a transition between the main urban area of Emsworth to the north of the A27 and the

Strategic Gap. The erosion of this transition through the development of this site would have a

negative impact on the Gap, particularly when considered in combination with the impact of the

allocation of UE13.

3.14 In addition, and as the list of known constraints on page 30 of the consultation document identifies,

the site is located adjacent to a Site of Importance for Nature Conservation (SINC). In order to

develop the site at west of Coldharbour Farm, a new access would have to be formed through the

SINC, and this is identified as a ‘likely significant effect’ of development on the site in the


9

Sustainability Appraisal of the Havant Borough Local Plan (Allocations) Publication Version

(October 2013).

3.15 Site UE32, another site in Emsworth promoted for development, was rightly discounted as a

potential allocation as a result of the potential impact on an adjacent SINC. It is therefore surprising

that the allocation of UE37 is to be retained given that the formation of a new access for the

development through the SINC itself will have a significant detrimental impact on the SINC.

Although UE37 is sustainably located in that it is close to the town centre, the development on

balance would not be sustainable from an environmental point of view due to significant impact on

the Site of Importance for Nature Conservation that adjoins the site.

3.16 Furthermore, it is considered that the close proximity of the site to the A27 raises real concerns

regarding potential noise and light pollution. Although it may be possible to mitigate these concerns

with landscape planting or bunding, any mitigation is likely to reduce the developable area of the

site.

3.17 As such, this allocation is not fully justified when considered against all the reasonable alternatives

(including UE11 Land West of Emsworth) and so the allocation of UE37 is considered unsound.


10

4. UE11 LAND WEST OF EMSWORTH

4.1 The site at Land West of Emsworth was considered by the Council for development as part of the

‘Housing Sites – Which would you choose?’ consultation. Land West of Emsworth was included as

a contingency site in Options A and B for 100 dwellings and was excluded from Option C. The

Council based those options on pro-formas and indicative drawings submitted to the Council in

November 2011. The illustrative concept masterplan that we submitted to the Council at that time

clearly demonstrated that the site is capable of accommodating approximately 120 dwellings. The

previous Sustainability Appraisal (November 2012) also incorrectly identifies the site as being

proposed for 50 dwellings and so mistakenly raises concerns regarding the density of development

proposed. Although an updated Sustainability Appraisal has been published in support of this latest

consultation on the Publication Local Plan (Allocations), it does not include a full assessment of the

site at Land West of Emsworth as the Council have already discounted it based on an unsound

evidence base.

4.2 The Sustainability Appraisal should therefore be amended to accurately reflect the quantum of

development proposed, to reassess whether the site is a suitable allocation for residential

development. In addition, it is important to note that in the conclusions of the previous Sustainability

Appraisal (November 2012), Option B for Emsworth (which included the site at Land West of

Emsworth) was considered the best performing overall, and paragraph 3.5.3 confirms that “The

option performs positively in relation to the economy; housing; community wellbeing; transport and

the need to travel; and accessibility of services and facilities”.

4.3 As a background document to the current Publication Local Plan (Allocations) consultation, the

Council have published a Statement of Consultation (October 2013), which includes a summary of

the main issues raised and changes made to the Local Plan (Allocations) Publication version as a

result. In relation to site UE11, the document states:

“This site was discounted in the Draft because the council considered there to be better sites

available to meet the development needs of the area set out in the Plan. Following the Draft

consultation the council took into account the representations made and all available evidence. The

council is satisfied that it is allocating the best and most sustainable sites in Emsworth to meet the

needs of the Publication Plan. This does not include this site, which has been discounted.”

4.4 A Development Proposals Document has been prepared by Angus Meek Architects which

accompanies this consultation response, which sets out the context for the potential development

of Land West of Emsworth. It aims to provide an overview of the preliminary specialist reports to

date, with specific commentary on the constraints highlighted by the Council, including planning

policy, flood risk and drainage.

4.5 It is acknowledged that the site is located with the Area of Outstanding Natural Beauty which, as

confirmed by the NPPF, is to be afforded a high level of protection, and that the sites proposed for

allocation at Emsworth are not subject to this designation. Notwithstanding this however we

consider that a balanced judgement should be taken when considering the merits of the sites taking

account of all relevant matters, including flood risk, impact on strategic gaps, accessibility and the

AONB.


11

4.6 Furthermore Policy CS2 of the Core Strategy does allow for development in the AONB, confirming

that development will be permitted where it:

1. “Carefully assesses the impact of individual proposals, and their cumulative effect, on the

Chichester Harbour AONB, and its setting.

2. Is appropriate to the economic, social and environmental wellbeing of the area or is desirable

for the understanding and enjoyment of the area.

3. Conserves and enhances the special qualities of the Chichester Harbour AONB (as defined in

the Chichester Harbour AONB Management Plan).

4. Meets the policy aims of the Chichester Harbour AONB Management Plan and Havant

Borough Core Strategy March 2011

5. Provides mitigation of any detrimental effects including where appropriate the

6. improvement of existing damaged landscapes relating to the proposal.”

4.7 It is considered that development of the site could be successfully accommodated within the

parameters established by Policy CS2. To help inform the Council’s consideration of the potential

for the site’s development, the Development Proposals Document also provides an analysis of the

existing site to establish the physical constraints and opportunities, which will inform detailed design

parameters. This includes consideration of access to the site, topography and landscaping, and

analysis of the net developable area given the constraints outlined above.

4.8 We consider that Land West of Emsworth is suitable for a residential development of approximately

120 dwellings and performs better than to other sites which are currently proposed to be allocated.

Furthermore, given the significant concerns raised above in relation to both housing numbers in

Emsworth and the selected site allocations it is considered that without the allocation of the site the

plan is unsound in that it is not justified and effective.


12

5. CONCLUSIONS

5.1 These representations have been prepared by Boyer Planning Limited on behalf of Markfield

Investments in respect of the Publication Havant Borough Council Local Plan (Allocations)

consultation.

5.2 This submission has focussed on the Emsworth area and relates specifically to Land West of

Emsworth (UE11). In summary, our submissions are:

The Council should seek to allocate sites in the Emsworth area to deliver 226 to 307 units over

the plan period;

Given our comments in Section 3 of these representations the Council should give further

consideration as to the suitability of the sites proposed for allocation in Emsworth and should

remove or reduce the proposed allocations of sites UE13 and UE37; and

Land West of Emsworth (UE11) should be allocated for residential development of

approximately 120 dwellings.

a Romans Company

Crowthorne House Nine Mile Ride Wokingham Berkshire RG40 3GZ01344 753 220 01344 753 221

[email protected]

LOCAL PLAN (ALLOCATIONS) PUBLICATION VERSION

Public Consultation

11th

October – 22nd

November 2013

Have Your Say! The consultation period on this document runs from 11 October to 22 November 2013. All comments and completed forms should be returned to the Planning Policy Team by 23:59 on 22 November 2013. The document and accompanying evidence base, including the Sustainability Appraisal, is available on the council’s website at www.havant.gov.uk/ Paper copies of the document and accompanying Sustainability Appraisal are also available at the Public Service Plaza and at libraries throughout the borough. Comments can be returned using the questionnaire, via email to [email protected] or posted to the following address: Planning Policy Team Havant Borough Council Public Service Plaza

Civic Centre Road Havant Hampshire PO9 2AX If you would like to comment on any part of this document then please complete the form overleaf. This form has three parts:

Part A - Personal Details

Please note that representations are not confidential and that they will be published on the council’s website and copies made available for public inspection. However, personal details, other than the respondent’s name and/or organisation, will not be made public.

Part B - Your Representation(s) Please fill in Part B for each representation you wish to make e.g. individual representations will need to be made for each site allocation, strategic or development management policy referred to. Please request additional copies of this form if necessary or supply information on separate paper Part C – Any other comments you wish to make Please fill in Part C for any additional comments you wish to make, not covered under Part B. If you have any questions or would like to discuss any elements of the consultation document further then please contact a member of the Planning Policy Team on (023) 92446539. Please note that comments received cannot be treated as confidential as all comments must be publicly available in accordance with government regulations. Please be aware that Havant Borough Council and East Hampshire District Council are working in partnership and information may be shared across the two organisations.

http://www.havant.gov.uk/


Please be aware that due to the likely volume of responses officers will be unable to provide a personal reply to representations made during the public consultation period. This questionnaire is available in other formats. To request any of these formats please contact 023 92474174.

If you already have a consultee reference please enter it here: _ _ / _ _ _ _

LOCAL PLAN (ALLOCATIONS) PUBLICATION VERSION

Public Consultation (Reg 19)

11 October – 22

November 2013

Contact Details Title: Mr………. Name: Tim Burden………………………………………………………….. Organisation (if relevant): Boyer Planning (on behalf of Markfield Investments)………………. Address: Crowthorne House, Nine Mile Ride, Wokingham, Berkshire…………………………. …………………………………………………. Post Code: RG40 3GZ…………………………… Email: [email protected]………………………………………………………….... Tel: 01344 753 220…………………………………………………………………………………… Important Information: Please provide your name and full address. ‘In confidence’ representations will not be

accepted Please complete Part A and then Part B for each representation made. Please copy or

download additional copies of Part B as required and Part C if necessary All representations are publicly available and can be viewed on request Please make your responses before the deadline of 23:59, 22 November 2013

Part A


Name or Organisation Boyer Planning (on behalf of Markfield Investments)

1. To which part of the Allocations Plan does this representation relate?

Strategic policy no.

Site Allocation

ref. no.

Dev. Management

policy no.

Paragraph no. 3.03

Page no. 21

Evidence Base Study

2. Do you consider the Allocations Plan ‘sound’?*

*The considerations relating to a development plan being sound areexplained in the National Planning Policy Framework (paragraph 182)

Yes No X

If you ticked the ‘No’ box, do you consider the Allocations Plan is unsound because it is not:

(1) Positively prepared Yes

(2) Justified Yes X

(3) Effective Yes X

(4) Consistent with national policy Yes

3. Do you consider the Allocations Plan complies with the legal/procedural requirementsfor preparing a development plan?

Yes X No

4. Please give details why you consider the Allocations Plan is unsound or not legallycompliant. Please be precise as possible. If you wish to support the soundness or legal compliance of the Allocations Plan please also use the space below to set out your comments.

Please refer to Section 2 of accompanying statement

(continue on a separate sheet if necessary)

Part B

5. Please set out what change(s) you consider necessary to make the Allocations Plansound or legally compliant. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.



Please note your representation should cover succinctly all the information, evidence and

supporting information necessary to support the representation and suggested change, as there

will not normally be a subsequent opportunity to make further representations based on the

original representation at publication stage. After this stage, further submissions will be only at

the request of the Inspector, based on matters and issues they identify for examination.

6. If your representation is seeking a change do you consider it necessary to participate

at the examination hearings?

No, I do not wish to participate in the examination hearings

Yes, I wish to participate in the examination hearings

X

7. If you wish to participate at the examination hearings please outline why you consider

this to be necessary:

The representation relates to a key policy in the Allocations Plan. We would like to participate in the oral examination to ensure that the necessary changes are made to the number of dwellings remaining to be allocated to ensure the plan is sound.


Please note the Inspector will determine the most appropriate procedure to adopt to hear those

who have indicated that they wish to participate at the examination hearings.

8. Do you wish to be notified at the address/email stated in Part A of any of the following:

Signature: (Tim Burden) Date: 22nd November 2013

(1) That the Local Plan (Allocations) has been submitted for independent examination X (2) The publication of the recommendation of any person appointed to carry out an independent examination of the Local Plan (Allocations)

X

(3) The adoption of the Local Plan (Allocations) X



Strategic policy no.

EM1 Site Allocation

ref. no.

UE13 Dev. Management

policy no.

Paragraph no.

Page no.

28 – 29 Evidence Base Study



Yes No X



(2) Justified Yes X

(3) Effective Yes X



Yes X No




Part B













X



The representation relates to a key policy in the Allocations Plan. We would like to participate in the oral examination to ensure that the necessary changes are made to the allocation of housing in Emsworth to ensure the plan is sound.







X




Strategic policy no. EM1

Site Allocation

ref. no. UE37

Dev. Management

policy no.

Paragraph no.

Page no. 28 & 30

Evidence Base Study



Yes No X



(2) Justified Yes X

(3) Effective Yes X



Yes X No




Part B













X



The representation relates to a key policy in the Allocations Plan. We would like to participate in the oral examination to ensure that the necessary changes are made to the allocation of housing in Emsworth to ensure the plan is sound.







X


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