The following is the response from the Upham Parish Council to the Eastleigh Borough Local Plan Proposals. Anyone who wants to add their own response will need to do so by 5pm on Wednesday 17th February.
Upham Parish Council (“ UPC”) was extremely disappointed that, despite the wide-ranging impact of the proposals in the Eastleigh Borough Council Local Plan (“The Plan”) on Upham Parish, no effort was made by Eastleigh BC to contact UPC to alert them to these matters.
Despite this lack of direct information and the resultant short response period, UPC has held an Open Village Meeting and Workshop that was attended by over 80 residents and other local parties. The responses to the Plan given below reflect the views expressed by Upham residents in this Workshop.
Having demonstrated their considerable concern and interest in the future of this Plan, UPC trusts that in future they will be informed directly by EBC of the next stages of this process on a timely basis. UPC urges EBC to consider the need for greater consultation with all authorities and Parish Councils bordering their area, which would be impacted by these proposals
Summary of Conclusions:
As will be seen from the answers given to the specific questions raised in the Plan, the consideration of Upham has been focused primarily on Options A, B and C, which present the biggest potential impact to the parish. Major discussion points, which are considered in greater depth in the detailed answers below, include:
- Housing Need: to be based on Eastleigh Housing Needs Survey – The calculation of Housing Need underpins so many of the assumptions in the Plan and needs to be precisely evaluated, avoiding overstatement or duplication, in order to ensure that the final target is a sustainable one.
- South Downs National Park: Statutory Obligation for EBC:- As this is on its boundary, EBC has an overriding statutory duty to consider the purposes of the South Downs National Park (“SDNP”), particularly the purpose to conserve and enhance the natural beauty, wildlife and cultural heritage of the area, in formulating its plans. Option C, which would extend to the boundaries of the National Park, would appear to put EBC in breach of this statutory obligation.
- Inadequacy of Proposed Link Roads to deal with Increased Traffic:- the proposed link road from Fair Oak to the M3 raises major economic, logistical and environmental concerns which impact on Upham and its residents, and thereby also the SDNP.
- Requirement to Maintain Gaps between Settlements:- Although EBC claim to consider this as an important factor, Options B and C would appear to merge a number of settlements and communities, both inside EBC and others lying just outside its boundary.
- Viability of either Option B or C on a stand-alone basis:- there are clear indications within the Plan that these options are co-dependant and that what is really being proposed is a single development of over 6000 new homes on some of the few remaining areas of unspoilt countryside that Eastleigh possesses.
Answers to Specific Questions on the Issues and Options Document:
Q1. Do you agree with the summary of the characteristics of the Borough as set out above and amplified in the Borough Profile, Scoping Report and Authority Monitoring Report?
UPC welcomes the recognition of the value of countryside areas in providing separation between settlements, biodiversity and important landscape features.
However, the summary makes no mention of the characteristics of areas immediately adjacent to the boundaries of the Borough and the constraints that these place on development. The most important of these being the South Downs National Park where EBC has a statutory duty under the National Parks and Access to the Countryside Act 1949 to consider the impact of any proposals on the Park and its purposes.
Q3. Do you agree with the strategic key issues identified? If not, please explain why.
UPC agrees that the importance of considering the impact on the South Downs National Park needs to be seen as a key issue.
However, UPC is very concerned that, despite earlier stress on the importance of the countryside and on maintaining gaps between settlements, these have not been identified as key strategic issues. The reference in the last bullet point to a need to “ensure a sense of identity for the Borough’s communities” is completely inadequate as a means of achieving this and UPC considers that explicit wording, confirming an undertaking to maintain adequate gaps between settlements, both within the Borough and those immediately on its boundaries, under the duty to cooperate with neighbouring authorities, should be included in the strategic key issues.
Q4. Have the key development constraints been identified above? If not, please identify which constraints should be added or removed.
As previously indicated, the inclusion of the South Downs National Park as a key development constraint is a statutory obligation for EBC and should be recognised as such.
As a member of PUSH and with a duty to cooperate with other local authorities, the Plan needs to consider the impact on areas on its boundaries under all headings. The only constraint that mentions this as an issue currently is the bullet point on Biodiversity.
Q5. What are your views on a new vision for the Local Plan and the possible objectives?
UPC agrees with the Vision as outlined in the Plan but questions whether these objectives have been fully taken into account in the more detailed considerations that follow.
Q6. What do you think of the summary of options for calculating the Borough’s housing requirement set out above? Are any of the options appropriate to meet the housing requirements in this area.
UPC is firmly of the view that, of the options for determining housing need, Option A, which is based on the very recent Eastleigh Housing Needs Study and incorporates the latest housing projection figures from DCLG, is the most appropriate as a basis for determining housing requirements in the area.
The other options which are intended to be taken forward for further consideration all include elements of over-compensation for earlier inadequacies in data and double-counting of need: neither of which is justified, given the rigorous approach demonstrated by the Eastleigh Housing Needs Study and DCLG.
Q10. What are your views on spreading new development across a number of extensions to settlement across the Borough (OPTION A)? Is this an appropriate option that merits further investigation?
The view of the Upham residents from the workshop held by UPC was that Option A is one that merits further investigation.
Comments were mixed but the general consensus was that this Option would be more sustainable than others under consideration as it promotes a number of smaller extensions to settlements and maintains the individuality of these settlements. In most cases, it would draw on existing infrastructure and be the least invasive into the rural areas at the north of the Borough.
UPC’s concern is that, whilst the overall figure of 5,000 new dwellings is identified, this is not sufficiently broken down between the various sites to enable us to comment on density of developments or the effect on infrastructure of the areas to the north that are under consideration and which could impact upon Upham.
Q11. What are your views on focusing new development in an expansion of Fair Oak and Bishopstoke to the north/north-east, with related development in Allbrook village and a new link road from Fair Oak to the M3 (OPTION B) ? Is this an appropriate option that merits further investigation?
UPC and Upham residents are unanimous in their view that this development would represent an extremely damaging option and is contrary to the stated aims of maintaining settlements and also of protecting fragile environmental assets and valuable landscapes. When combined with the fact that the economic viability and infrastructural impact of this development are based on a proposal for a new road that has major shortcomings, it is our view that this Option has no merit in being taken forward.
Unacceptable Impact on Important Areas of Environmental Significance:
- The land under consideration comprises very significant areas of high quality historic farmland; valuable woodland with public access and Special Areas of Conservation around the River Itchen. EBC would be required to undertake an Environmental Impact Assessment under EU regulations. Even EBC admit that this option has “potentially significant negative effects” on the environment.
- The effect of the proximity of this option to the South Downs National Park is not even mentioned, despite the statutory requirement on EBC to consider the implications of this development on the Park
Merging of Existing Settlements:
- Not only does this option create a merged area of Bishopstoke, Allbrook , Brambridge and Fair Oak but the scale of the development would completely submerge these communities.
- Although not explicitly stated under this option, it is clear from Option C that the potential cost of the new road linking the development to the M3 can only make economic sense if Option C is combined with Option B. This would result in bringing Upham into this amorphous mass of 6200 new dwellings, with very little indication of any real community infrastructure.
- UPC struggles to see how these Options can possibly promote the “thriving and healthy communities” or the “attractive and sustainable environment” of EBC’s vision statement?
Complete Inadequacy of Proposed Link Road:
The proposed new link road from Mortimer’s Lane to the M3 , through Highbridge and Allbrook, would not provide the necessary traffic solution for this development for the following reasons:
- The route proposed has significant sections which are in Winchester district, although there is no indication of this on Winchester’s own local plan (already adopted)
- The obstacle of the railway bridge at Allbrook would create significant congestion issues that would seem to be insurmountable without major additional expenditure. The proposals for road straightening would do almost nothing to alleviate this problem.
- Flooding risks at the same point would put additional pressure on this route and restrict options for improving the access under the bridge.
- Much of this road would fall within the immediate vicinity of the River Itchen and would need additional environmental impact assessments.
- The road would emerge at the roundabout at Junction 12 of the M3, which is already extremely congested at peak times.
- Following conversations with Hampshire County Council Strategic transport section, we are aware that their study, which underpins the options, is only an interim report on a very high level study and the results are not therefore robust at this stage as a basis for decision taking on the selection of options.
The inadequacies of the proposed link road would put increased pressure on the small lanes of Upham and Owslebury as an alternative route through to junctions 9 and 10 of the M3.
- This route would be within the SDNP and have serious implications for the tranquility of the Park;
- Typical of this part of the National Park are the narrow lanes with no pavements and restricted visibility of Upham and Owslebury. Upham Street and its extension to the Morestead Road is already under increasing pressure from traffic from the Eastern side of the Southampton Conurbation seeking a rat run route to Winchester and the North of the County, as the M27 and M3 become increasingly clogged with traffic South of Winchester and East of Southampton. This causes damage to the road and verges and poses a severe threat to the tranquility of this part of the park. The banks and verges are also identified.
- HGV traffic would cause even greater concerns.
- The lane is entirely unsuitable for any increased traffic volume of this sort, having a junior school on the road but no footpaths.
Q12. What are your views on the idea of expanding Fair Oak village to the east and north (OPTION C)? Is this an appropriate option that merits further investigation.
This option was never part of any earlier Plan and both the UPC and the residents of Upham are convinced it is far and away the least sustainable of all those listed on the Plan.
Contrary to Statutory Duty to South Downs National Park:
The most important objection to this proposal is that it goes right up to the National Park boundaries and must be accepted as having such a detrimental effect on the purposes of the National Parks that Eastleigh would be in serious breach of its statutory duty to “conserve and enhance the natural beauty, wildlife and cultural heritage of the area” under s.11A of The National Parks and Countryside Act 1949, as amended by s.62 of the Environment Act 1962.
The development would present an unacceptable threat to:
- The tranquility of the Park – this area being identified as one of the most tranquil in the Park;
- The dark skies policy of the SDNPA.
- The safety and enjoyment of those using the park, whether as residents, walkers, bikers or other leisure users.
- Views of and from the Park;
- Wildlife and habitats;
The SDNPA preferred options shows that it places great stress on: “Distinctive towns, villages and communities with real pride in their area”.
There is no doubt that Upham exemplifies this aspiration with thriving local organisations and an exceptional community spirit. However, as a village of some 700 residents and 250 dwellings, there is little chance that this ethos could continue to thrive when swamped by 2500 additional dwellings, which would extend right up to the parish boundary.
This concern is mentioned in paragraph 6.29; however, UPC would say that it is not just Lower Upham but all of Upham that is impacted, given that they are all one parish.
Viability of Option C on a stand-alone basis:
Whilst being shown as a separate development, it is clearly not tenable as a stand-alone development but only as part of Option B. Its justification is that:
- There is already a great deal of “promoter” interest in this area (contrast Option F where EBC are concerned that there is no interest); and
- The additional houses here would also rely on the proposed link road and would therefore spread the cost of this infrastructure over almost twice the number of properties, thereby possibly making the proposal economic.
- Neither of these are reasons to justify the development of an area which does not have any other basis for being considered; they are just part of a circular argument that serves to to show how unsustainable this Option would be.
- We understand that this option has to be considered because it has been put into the public domain by developers. However, we do not believe that it can be seen as compatible with the strategic visions expressed elsewhere in the Plan.
Inadequate Proposals to deal with Major Traffic Issues:
As the rationale for this development is the fact that it would benefit from the proposed relief road through Allbrook, all the same major concerns over traffic issues (see Option B above) are equally applicable here. However, with houses almost to the top of Mortimer’s Lane, there is a far greater likelihood that drivers would choose to take the short cut through the village (and the National Park), rather than joining the traffic jams going through either Twyford or Allbrook. Upham Street and other local roads would become completely congested with a major impact on safety, particularly of children, and the quality of life within the village.
Lack of Other Facilities:
- It is admitted in the Plan that there are no community facilities included in Option C, other than a new infant school – arguably not the best place to put such a school when there is already a thriving local school in the village so close by. Indeed, the plans would entail the loss of a local golf course that provides very popular affordable outdoor leisure facilities in an area not well served by other fitness opportunities – other than the rapidly disappearing countryside.
- It is suggested, in the summary of interim findings for this Option, that developers (rather than EBC) have indicated that new dwellings in Option C would benefit from the facilities proposed as part of Option B. Clearly this only serves to emphasise that Option C is completely unsustainable as a stand-alone development.
Q18. Have we identified all the main spatial options and locations of development? What options should we also consider? What are their potential benefits and impacts?
- UPC is concerned that each of these options is currently being considered in isolation – other than the obvious co-dependency of Options B and C as detailed above. However, once the housing needs have been more precisely determined, it may be necessary to look at a number of these options in combination, either as a whole or in part. For this purpose, Option A would need further examination to understand how far it overlaps with some of the other developments – information that is not available currently in this document.
- For those development options that are in more built-up areas with good infrastructure, UPC would welcome discussion as to whether the currently anticipated density of development is the optimal solution or whether it would be possible to increase this in the urban areas in order to relieve the pressure on the countryside.
- We are also expected to accept the figures given by EBC for current development capacity from existing permissions and the development of “windfall brownfield sites”. However, UPC has no basis for understanding whether there is further capacity in either of these areas.
- There is very little reference to the potential for urban regeneration within the centre of older areas. Given the Government’s recent encouragement for this option, UPC would have expected to see some evaluation of EBC’s options in this respect.
- UPC recognises that these alternative options are often more complicated and less popular with developers than the cheaper option of developing greenfield sites. However, they consider that EBC has a duty to consider these areas more fully than currently appears to be the case.
- Once the countryside has been developed it can never be reinstated: this plan would appear to encompass a significant proportion of Eastleigh’s remaining undeveloped land.
Q19. Which approaches to the countryside do you think are most appropriate?
- UPC believes that the countryside, and particularly the National Park, is an important amenity for Eastleigh residents, that needs to be protected as it plays an important part in the well being of all those in the Borough, not just those who live in that area.
- UPC considers that much can be gained in this respect in allowing local communities to take a leading role in determining what is suitable for their area, subject to some overarching principles that should be adhered to.
Q20. Do you think gaps still play a part in Eastleigh? Was the approach in the previous Plan sound? Should we review gaps to retain only the minimum land required to maintain separate identity?
- UPC considers that gaps are essential in maintaining the identity of individual settlements and to stop the Borough becoming one amorphous development.
- However, it is essential not only to maintain gaps between settlements in the Borough but also with those that fall outside the Borough – cooperation with neighbouring Boroughs to adopt a mutually agreed policy in this respect is a duty of the Borough and an integral part of being involved in the PUSH initiative.
- The gap between Fair Oak and Upham needs to be included in the gaps to be maintained in this respect.
- UPC considers that, although a review of the extent of these gaps may be required from time to time, it is essential that the gaps are fully mapped in order to ensure certainty.
- Gaps should be of sufficient size to ensure clear separation of communities – a small area of soft landscaping is never going to fulfill this requirement.
Q27. Do you agree with any of the approaches identified for influencing building standards and density of development?
- UPC believes that minimum density requirements should be increased in urban areas of high accessibility in order to reduce the amount of greenfield sites required to be developed.
- UPC would be supportive of measures to increase the number of homes that meet high accessibility standards in order to meet the needs of older or disabled residents.
Q30. Which approaches to addressing transport issues do you think are most appropriate? Are there any other options we can consider to try and help balance development with traffic and congestion?
- UPC is very concerned that there should be a much stronger commitment to improved public transport to overcome the inevitable congestion that will arise from these developments, other than Park and Ride Schemes.
- “Encouraging improvements to public transport hubs” is simply not enough.
- Without greater use of buses, it would be impossible to decrease the parking provision on new developments and these will need to be increased to accommodate the inevitable increase in cars.
- Emphasis needs to be given to improving cycle paths as a means of allowing essential journeys, not just leisure activities.
Q31. Which approaches to delivering and protecting Green Infrastructure do you think are most appropriate? Are there any other approaches we can consider?
- UPC supports the approach of the previous local plan, where the importance of protecting existing green space provided by nature conservation areas and historic countryside is given prominence.
- The importance of green spaces as a gap between settlements should also be considered.
- UPC agrees that designating Local Green Spaces should be considered.
- In designating new large green spaces as a part of new developments, additional facilities such as children’s play areas and hard areas laid out for outdoor games should be included to encourage recreational use.
Q33. Are there any other approaches, other than that described in the Local Plan, to address pollution issues in the future?
UPC considers that greater emphasis needs to be given to the protection of sensitive sites, particularly the South Downs National Park, on the boundaries of the Borough.