On 5th November representatives from SOLVE and SWAG (South West Action Group) accompanied Maria Miller MP to a meeting with the Planning Minister, Brandon Lewis MP. Maria Miller has issued a Press release see - http://www.solveloddon.org/filemgmt/v...php?lid=22
Although a question on housing numbers was not unexpected, reference to the SE Plan, revoked by the current Government, was unhelpful and surprising since this was a figure imposed by the previous Government for political reasons using questionable evidence.
Planning Inspector questions - In addition to the points made on 5th November the Inspector’s comments reflected many of our submissions, the Inspector questioned environmental issues on the Loddon Valley sites pointing out that these sites are near the Incinerator and potential green infrastructure. He asked for evidence that the LP was effective and how housing proposals square with the Council’s proposals for Green Infrastructure and the creation of a biodiversity Project Area in the Loddon Valley. He also questioned the resources available to implement the waste water treatment and the cumulative impacts on traffic congestion on key routes such as the A33.
The Inspector’s concerns will form the basis of an exploratory meeting, open to the public, with the Borough Council on 11th December. The Council will have to answer these questions or risk rejection of the plan.
Basingstoke and Deane Borough Council Officers are considering the many comments sent in response to the public consultation. There are over 2000 comments from around 600 individuals and organisations from both last autumn and this year. We understand that at this stage there is nothing major which will require the plan to return to full Council so the draft plan should go to the Planning Inspector in the Autumn.
As you would expect, comments from other groups around the borough do not necessarily accord with our own. For instance, South West Action Group (SWAG) supporters would like less building to the south-west of the town and more to the east.
For information, under the draft Local Plan to 2029, Borough housing numbers on some Greenfield sites are as follows:- South West 1310 (Kennel Farm and Basingstoke Golf Course), North East 1560 (Pyotts Hill, Redlands, Swing-Swang Lane, Razors Farm and Cufaude Farm). Not included in the SW or NE are Manydown and Kiln Farm (towards Sherborne St John). Manydown is subject to a Master Plan currently being prepared separately.
Despite our differences we have been talking to SWAG about our common objectives. They are:
• Capping the annual housing target at 748, lower if possible, on the basis that Basingstoke has over-supplied in the recent past and that it should not be penalised for doing so now.
• Brownfield first – resisting any further incursion onto Greenfield sites. Instead, allowing brownfield, often unidentified, opportunities to be taken into account. See Campaign for the Protection of Rural England (CPRE) below.
• Enshrining the idea of 'no development before appropriate infrastructure'. This includes exerting influence to ensure essential infrastructure is identified, funded and delivered.
• Trying to prevent pre-emptive development before the Local Plan is in place.
SOLVE and SWAG met with Maria Miller MP, during July. This was followed by a joint SOLVE/SWAG briefing paper for Maria to present to the new Planning Minister, Brandon Lewis, and/or his officials prior to a meeting.
Part of our case uses latest planning guidance, 6th March, from the then Minister, Nick Boles, which said, amongst other things:-
• “past over-supply of housing to be taken into account when assessing housing needs”. We believe that this policy is aimed exactly at Basingstoke’s situation. Housing completions in Basingstoke and Deane 2006-2013 was 39 houses per 1000 population. Amongst our near neighbours the next highest was Rushmoor 28, followed by Reading 26. Over the last ten years Basingstoke has seen the third highest housing completions in the country.
• “ensuring that infrastructure is provided to support new development, and noting how infrastructure constraints should be considered when assessing suitability of sites”. We believe that this should enshrine the idea of 'no development before appropriate infrastructure'. The BDBC Infrastructure Development Plan has a funding shortfall of £247 Million.
• “stressing the importance of bringing brownfield land into use making clear that authorities do not have to allocate sites on the basis of providing the maximum possible return for landowners and developers”. Read on for the (CPRE) report. See the CPRE “waste of space” campaign on http://www.cpre.org.uk/
The consultation on the changes to the draft Basingstoke and Deane Local Plan which, amongst other things, will determine the housing requirement in the Borough up to 2029, ends at 4pm on June 13th.
The consultation documentation is crystal clear and states "This is a focussed consultation where comments should only be made on the proposed changes to the Pre Submission Local Plan since the previous consultation"
However, we understand that the South West Action Group (SWAG) have been advised by the Planning Department that, if you did not comment on something in the last consultation, you can still comment, whether it is a change or not. These comments will be passed to the Inspector later this year for consideration, along with all previous consultation submissions. It appears that some SWAG supporters failed to comment previously and are trying to reopen the debate. It is difficult to comprehend that comments not related to changes can be restricted to SWAG, and the change in policy appears to open the door for developers to propose additional sites for development. This change in the consultation, not widely known, and in direct conflict with the consultation documentation, may leave the process open to challenge and further delay.
Given this, supporters that did not comment previously, and wish to do so, now have another opportunity. Previous SOLVE and CountryWatch comments can be found on the Council website and a summary is also on this website under the entry for October 2013.
The main points to highlight in submissions from SOLVE supporters at this stage are:-
• No new Greenfield sites
• The housing target remains at 748 houses per annum.
• Reduction in the number of houses on Pyotts Hill to 450 at the behest of the owners Hampshire County Council (HCC), Policy SS3.9.
• The provision for a western by-pass linking M3 Junction 7 to the A339, Policy SS3.10m. This was also identified in the Transport Study issue 4. SOLVE supports this as it will help relieve over capacity and congestion from Junction 6 and the A33 corridor.
• Housing on Pyotts Hill has been brought forward two by years.
• A further 450 on Pyotts Hill may be included after 2029, policy SS3.9.
• We are aware that Taylor Wimpey representatives have been surveying Hodds Farm recently. Hodds Farm is not featured in the Draft Local Plan.
• We object to the deletion “new residential development will not be acceptable within Flood Zones 2 or 3”, para 6.51. This is inconsistent with specific mention of site flood zones, e.g. SS3.9f and SS3.11k.
• Policy CN6 - Infrastructure changes should be in place before new housing is occupied. This policy should be paramount.
• Under the Environment Agency Water Framework Directive, the River Basin Management plans, due in 2015, must form a significant piece of evidence on relevant sites (para 6.45) and be included in all planning applications.
• The Manydown site has been allocated 3400 houses during the plan period. Previous Cabinet decisions agreed 4000. The Major Development Area Plan for Manydown should recognise this, so should the Local Plan.
Although the draft plan is not perfect, on balance, we support its submission to the Planning Inspector. Without a Local Plan the risk is high from developers actively exploring opportunistic planning applications before it is approved, e.g. Hodds Farm.
Details of the revised Local Plan can be found on the Council website consultation page at http://www.basingstoke.gov.uk/ . This includes the draft Plan with tracked changes for ease of commenting. (All references refer to this except where otherwise stated.)
Basingstoke and Deane Council have approved the draft Local Plan for another round of public consultation between April 25th and June 13th. The Local Plan will determine the housing requirement and sites in the Borough up to 2029.
Any comments should be confined to changes that have been made since the last public consultation. All previous consultation submissions, from the end of last year, will be forwarded to the Planning Inspector.
Borough Elections 22nd May
SOLVE remains an apolitical organisation. However, we support Councillors who support our aims of protecting the Loddon Valley from development. Therefore SOLVE is delighted to hear that Councillor Onnalee Cubitt is standing for re-election as an Independent in the Basing Ward. We are indebted to her for her continuing support and work within the Council on behalf of her residents. She has worked tirelessly, diligently and passionately for her ward and it is good to see that there are still some politicians with the courage and integrity to put the interests of their residents before their political career.
Onnalee has a wealth of knowledge regarding the local plan, its background and the difficulties encountered during its preparation. She is ideally placed to take this forward on behalf of all the residents in our ward and it would be a tragedy if she were unable to represent us in the future. SOLVE has no hesitation in supporting Onnalee.
Councillor Cubitt was not allowed back into the Conservative group because she had the courage and integrity to stand up for the people who elected her even if it meant voting against the party she has supported all her adult life. In essence Councillor Cubitt was unable to give an assurance that she would not put her residents before the party. It is deeply ironic that this comes at a time when the whole country is questioning the motivation of politicians.
A Conservative candidate, who was rejected by the Basing and Lychpit Conservatives, has been imposed on the Ward by people who do not live here and who were at the heart of the campaign to exclude Manydown from the original Local Plan. Onnalee’s stance was vindicated when a Judicial Review declared the Local Plan “unlawful” in 2012 (See below the report on 18th April 2012). This action, to reject Councillor Cubitt and impose a candidate, prompted a number of Basing and Lychpit Conservatives to resign from the party and support Onnalee’s campaign.
For the record, SOLVE does not endorse any other candidate or party standing in this May’s elections. Any claim, inference or oblique references by other candidates, either in the Basing and Lychpit Ward or elsewhere, were not agreed by SOLVE. We will continue to be loyal to those who have supported us.
A meeting of the Council Planning Infrastructure and Scrutiny Committee (PIOSCOM) on January 30th decided to recommend an unchanged Local Plan (LP) housing target of 748hpa. This went against the recommendation from the Borough Planning Officers to increase the target to 807hpa. Councillors had misgivings over the assumptions on economic and employment growth. One Councillor suggested the Officers were ‘naïve’ if they accepted these assumptions given the record on economic predictions in the past.
Councillors also questioned the consequences of the Council’s Economic Growth Strategy which is being used by developers to show the need for more people to move into the town rather than improve the prosperity of those already here. Handing developers a weapon with which to press the case for increased housing in the Borough was not the smartest move.
SOLVE has been lobbying Councillors to reject the Officers’ housing growth agenda and instead reflect the very clear wishes of residents across the Borough which is that we have already carried more than our fair share of development.
No new Greenfield sites
At the PIOSCOM meeting on 5th March to consider a revised pre-submission Local Plan (LP), Councillors accepted the recommendation of the Portfolio Holder (Councillor Mark Ruffell) not to add any new Greenfield sites to the revised plan. This means that the threat to Hodds Farm, Lodge Farm and Poors Farm has receded for the time being. Unfortunately Redlands Farm (150 houses) remains, as does East of Basingstoke/Chineham. These have been brought forward to 2017 from 2019 but the latter has been reduced to 450 houses from 900 during this plan period.
CountryWatch and SOLVE submitted a proposal to reduce the Local Plan period. In essence we are proposing a 15 year plan, 2011-2026, instead of the proposed 18 year plan to 2029. Adopting a 15 year plan, which is all that is required, reflects the position of some neighbouring councils and would reduce the Borough housing target by 2,400 homes. If the longer period is adopted it would allocate, some say blight, some sites for an unnecessarily long period of time and simply increase developers’ land banks. Some councillors were sympathetic but the majority, clearly weary of the process, did not wish to take this forward at this stage.
A further public consultation is due to begin in April for 7 weeks but will be restricted to the changes made since the previous draft.
Although it is good news that no new Greenfield sites are proposed, the lack of a Local Plan, adoption due in July 2015, leaves the Borough open to speculative applications from developers. This is already happening in other parts of the Borough. There is also no guarantee that the Planning Inspector will approve the plan. Councils and groups like SOLVE look on, often in horror, at planning decisions and recommendations in other areas in the country. The changes to the planning laws have, as many suspected, handed the construction industry all the cards leaving local people and Councils all over the UK frustrated and angry.
An adviser to Number 10 has warned that the Government's planning reforms have led to a planning 'free for all' and that the resulting 'physical harm' to the countryside could become the 'defining legacy of this government'. See SOLVE Facebook page.
SOLVE and our advisors have been studying the many hundreds of pages commenting on the Pre-Submission Local Plan as a result of the public consultation. This has raised a number of issues and the Council Planning and Infrastructure Overview and Scrutiny Committee (P&IOSCOM) debated these on 14th November.
The P&IOCSOM recommended further work and a requirement for a further public consultation should there be, as expected, major changes to the plan. A new timetable was agreed which means the plans will not be adopted until 2015.Amongst the further work required is:
The Borough’s objectively assessed housing need. Developers have made alternative proposals for a higher housing allocation. SOLVE and others have made proposals for lower housing numbers but these appear to carry less weight.
Amendments to site allocations, including the identification/assessment of new ones, as suggested by respondents. This includes changes to the Pyotts Hill site East of Basingstoke/Chineham now that the landowner, Hampshire County Council (HCC), has confirmed they will promote only 450 houses on this site before 2029.
There is now a danger that developers will make applications on land that was not identified in the original Local Development Framework. We are concerned that in addition to 450 houses East of Pyotts Hill, Lodge Farm (BAS102) & Poors Farm (BAS103) may be included because of this delay.
Taylor Wimpey has submitted a comprehensive 174 page report much of which is a re-hash of their previous rejected evidence. They want a massive increase in housebuilding in Basingstoke. In essence it would increase the number of houses in the Borough by 50% during the plan period up to 2029. Their main aim is the release of land owned by the Kings Fund, which Taylor Wimpey has options on, for housing to cover much of the Loddon Valley to the north and east of Old Basing and Chineham.
Hodds Farm also at risk – At the P&IOSCOM in November, Council Planning Officers presented, without warning, a further site to the East of Old Basing, Hodds Farm. Unsurprisingly, many Councillors were infuriated by this, in particular the lack of notification. Hodds Farm is land in Old Basing East of the VW garage, between the A30, the railway line and Ashmoor Lane with the potential for 1000 houses.
This site was rejected by the Planning Inspector in 2005. However, the submission from Taylor Wimpey, in which they said they ‘had an interest in Hodds Farm’, was not put forward by them as a specific site during this consultation. This was an initiative by the Borough Officers who have told us that they are “exploring alternatives”. It would be understandable if other Landowners and Developers, for example Pellipar Investments representing the developers of Hounsome Fields in the SW of the Borough, might also look for preferential treatment.
The possible inclusion of Hodds Farm will require further evidence such as a Landscape Assessment, sequential testing for flood risk, transport impact of an additional 1000 homes accessed off the A30 and the impact of a road linking the A33 to the A30 across the Loddon Valley.
Our goal remains to prevent over-development to the east of town across the Loddon Valley. The sites of concern to us are Pyotts Hill, (East of Basingstoke, policy SS3.9) 900 homes and Redlands Farm (adjoining Pyotts Hill to the north, policy SS3.7). These are the gateway to the Loddon Valley.
The Council has issued a special edition newspaper “Deciding the Borough’s future”. The document sets out the Council’s ambitions, yet is short on detail and glosses over the very real dangers associated with over-development on top of an infrastructure that is already at capacity. There is little mention of the very serious issues relating to traffic, water quality, sewage problems and general over-crowding that this plan will cause, and no concrete plans for how these issues will be overcome.
The SOLVE comments are summarised below. These are not exhaustive.
Infrastructure - There is an ‘Infrastructure Delivery Plan (IDP)’ to accompany the LP which gives a list of projects needed to accompany the housing development. Policy CN5 states: “New infrastructure should be provided prior to occupation of the development, or in larger schemes, prior to the occupation of the phase of the development for which it is needed.” SOLVE would normally support this ideal. However, implementation of this policy is unlikely, since figures presented in the IDP show that most major projects are not funded. Only a proportion of the money will come from developers as part of the Community Infrastructure Levy (CIL) which has yet to be negotiated. CN5 is not sound.
Transport Assessment - Evidence Base, Report Number: 3512774A-PTG / 02 Dated August 2013, gives details of predicted traffic growth and suggested measures to tackle this. There are a number of comments that SOLVE will be submitting including:- Congestion on the A33; planned changes to junctions; public transport, in particular the suggestion of a bus gate [Volume 1, January 2013, p112] which will be vigorously opposed by local residents. These are major infrastructure projects and policy CN5 is paramount. With costs yet to be identified for these changes then the LP is unsound as CN5 is unworkable.
Flooding - Policy EM7 (p91) states that a sequential approach to development will follow national guidance, i.e. sites with a lower risk will be developed first. The plan contravenes the Flood risk policy since it has put Pyotts Hill (SS3.9) ahead of other sites with a lower flood risk.
Water Quality of the Loddon [Policy EM6. Water Quality. p88; Policy SS4. p47 and para. 4.10. p26] – The Council accepts that the South East is ` water stressed' and that River Loddon currently fails to meet `good' status under the Water Framework Directive. Present day technology cannot improve the status, para 4.10. Action needs to be proactive before development is committed, not reactive after the event.
Ecology and the Environment – This will be the subject of a separate submission.
Landscape Capacity – The studies of 2008 and 2010 recommended that the north of Pyotts Hill should not be developed. There should be a clear buffer between the conservation areas along Park Pale and any development. Redlands - SS3.7g, states – “This should not be developed in isolation”.
The Council’s ‘Planning and Infrastructure Committee’ consistently recommended that (SS3.9) should not be developed.
Incinerator and Sewage Works (Policy SS3.9 and SS3.7) – Originally these were sited away from settlements, now there are plans to put housing close by. The current Thames Water Business Plan proposes a new renewable energy unit alongside these sites to “pressure cook” sewage from areas as far apart as Guildford and Newbury.
Environment Agency – The EA recommended removal of SS3.9 from the list. They described it as “high risk”, (SHLAA all versions, including the last, version 7).
Number of houses, Pyotts Hill – The Landowner, Hampshire County Council (HCC), is promoting 450 houses on SS3.9 during this local plan period as opposed to 900 as proposed by Basingstoke and Deane Borough Council. The site is therefore not fully available and is therefore unsound.
On the 25th July, at a Full Council meeting, a draft Local Plan (LP) up to 2029 was agreed. Although it commanded a majority, the decision was by no means unanimous, with Councillors on all sides failing to support the plan for a number of reasons.
As many will know the process has been subject to much delay mainly caused by attempts by some Councillors to exclude Manydown (proposed 3080 homes in this LP). Their actions and earlier Local Plan was ruled unlawful at Judicial Review, costing Council Tax Payers close to £1M. Sadly, in the debates over the summer, some Councillors continued to press for more homes east of Basingstoke
SOLVE's goal has been to minimise development to the East of town which bore the brunt of major development over the last plan period and where there are already clear signs of over-development. In doing so we seek to protect the Loddon Valley and its eco-system for the enjoyment of all in Basingstoke. At the start of the process we were concerned that 9,000 homes would be built across the Loddon Valley. For this Local Plan the recommended number is 1050. 900 homes at Pyotts Hill, (East of Chineham) and 150 at Redlands Farm (adjoining Pyotts Hill to the north). The larger areas around Lodge Farm and Poors Farm encircling Old Basing to the North and East are not featured in the plan. This does not mean they are safe from development, as current proposals open up a gateway to the Loddon Valley.
The next stage is the public consultation on the Local Plan, has just been announced (23rd August) on the Basingstoke and Deane Council website at:-
This gives us all one more chance to comment on all aspects of these weighty documents. Comments should be in by 4th October. Following that, the Plan has to be approved by the Planning Inspector, next spring.
SOLVE will be working with CountryWatch on our submissions using professional support as necessary and will publish a summary on this website. This may help some of our supporters with their own comments. Submissions to the public consultation should include any points you may wish the Inspector to see. It cannot be assumed that Inspectors will see everything that has gone before in this long process. However, the Council are seeking comments on ‘Legality’ and ‘Soundness’ which is explained on the Council website.
Given the number of adverse comments and criticisms from the public and local pressure groups during the preparation, in particular infrastructure deficits, it is difficult to see how the plan will get past the Inspector without some modifications. Privately, some Councillors think the Inspector will reject the plan.
To donate to the SOLVE fighting fund click on “What can you do?”.
Gridlock Predicted - As part of the Local Plan, up to 2029, a Transport Assessment across the whole Borough was commissioned and is currently being conducted by Parsons Brinckerhoff Ltd on behalf of the Borough Council. The assessment assumed that 770 houses per annum are built.
Their interim report was delivered to the Planning and Infrastructure Overview and Scrutiny Committee (P&IOSCOM) on 30th May. They concentrated on the highway assessment and presented what can only be described as a terrifying picture of the future of Basingstoke traffic. This was headlined in the Gazette on Monday 3rd June as “Experts Predict Gridlock”; something many have been warning about for some time.
The consultants looked at 27 junctions and said that 25 would be over capacity by 2029 but that 7 are already over capacity now. The consultants’ interim report modelled two major roundabouts, Binfields Roundabout on the A33 and Kempshott Roundabout on the A30. There was a noticeable gasp from both Council members and public alike when the figures for the increase in traffic at these junctions were presented. In some cases morning rush hour traffic will increase 3 fold and delays by even more. All the major junctions in and around Basingstoke will be modelled and are expected to show similar increases.
Congestion problems can be mitigated by altering the junctions, e.g. slip roads, traffic lights, road widening, all requiring a lot of money. However, under questioning, the Council Officers were less than convincing when explaining where the money would come from. The consultants’ response to - What happens if the junctions are not changed? – was that such delays will cause people to change their travel arrangements. Some in the audience said people won’t want to come to Basingstoke. One solution, favoured by many, is to complete the ring road to the west of the town. Since so many houses are planned any solution is not going to reduce traffic amounts.
Local Plan Housing Numbers - On the 4th June the P&IOSCOM met to consider the annual housing requirement. Edge Analytics, demographic modelling consultants, presented an analysis and forecast with a number of options for consideration. The full report can be found on the Council website. Edge Analytics agreed that the report illustrated graphically that building more homes in Basingstoke has encouraged people to come here.
Following the presentation and some searching questions, Councillors, torn between the fear of the electorate and the Planning Inspectors, were reluctant to recommend a figure on the 4th June. The following evening, Councillors returned to the subject after consideration of the Strategic Housing Market Assessment where they accepted that the Borough should build 300 affordable houses per annum. They then recommended the Local Plan Housing numbers should be 748 houses per annum, a small reduction on the previous figure of 770.
The National Planning Policy Framework (NPPF), introduced by the Coalition Government, insists that Council housing targets take into account net migration. The Edge Analytics report demonstrates that building for local need only gives 550 hpa up to 2029. On the 6th June the Council Cabinet accepted 748 hpa as the figure which will go out to public consultation in the draft plan later this year.
Read on - Top Down Planning; CPRE Campaign; MP can't support 748; Tadley ONR Re-think; Massive Development Threat Remains.
Residents from Overton and Whitchurch were incensed by the Cabinet recommendation to add more houses to their villages. As a result a special meeting of the Council Planning & Infrastructure Overview and Scrutiny Committee (P&IOSCOM) was held on 28th March where Councillors from Whitchurch and Overton exercised their right to ‘Call in’ this decision. This is a process which scrutinises the reasons behind the Cabinet decision. The debate at the P&IOSCOM was very one sided with the Cabinet Portfolio Holder struggling to defend a weak Cabinet recommendation in the face of probing questions from all sides.
Following this, the Cabinet, meeting on 15th April, decided to withdraw their Decision Notice (DN) agreed on 28th February. Unfortunately this means that 150 houses on Redlands Farm (SOL002), taken out by the withdrawn DN, have gone back into the Local Plan. This is a setback for SOLVE as it opens up the land east of the A33 into the Loddon Valley. SOLVE is working hard to ensure that yet another fiasco in this long running saga does not adversely affect the Loddon Valley.
Housing Numbers Methodology, P&IOSCOM meeting, 12th March. ‘GVA edge analytics’ (demographic modelling consultants) presented a review of the methodology behind the housing figure. This was a comprehensive report which mostly supported the current work of the Borough Officers. Amongst other things GVA recommended BDBC use the same or similar demographic model as used by Hampshire County Council. More work on household size is required and they confirmed the view that – “if we build then they will come”.
In answer to questions, GVA confirmed that Borough policy will play a big part in housing numbers and should be modelled in. This includes the vision and growth policies led by the Local Enterprise Partnership (LEP) including Destination Basingstoke. Some believe the unelected LEP growth ambitions and the consequent expansion of Basingstoke could destroy everything the people love about Basingstoke. Not something the electorate have asked for.
Worryingly, GVA gave a strong impression, based on recent decisions, that the Planning Inspectorate is biased in favour of building houses. This was not lost on some Councillors. The Inspectorate should be independent and if they are not, then our task of defending the Loddon Valley, if it comes in front of the Inspector, will be challenging.
Incinerator Health Risks - Unfortunately Pyotts Hill (BAS121) remains in the list, recommended for 900 houses despite the owners, Hampshire CC, saying they will promote only 450. At the Cabinet meeting in February one public speaker with a long background in the Pharmaceutical industry highlighted the continuing debate around alleged health issues living close to Incinerators. He suggested that if BAS121 is developed there is an ideal opportunity to test these claims and counter claims if the Developers and Councils fund a 10 year research programme amongst the new residents. He gave a long list of medical conditions which could be investigated. (The full list can be viewed on the Council Cabinet Webcast, 28th February, approx 2hr 58mins from the beginning.)