OBJECTION

Of Adam Welch & Bernadette Welch

To

Winchester District Local Plan Part 2

OPEN SPACE STRATEGY Sept 2015

Winchester City Council

Winchester Town including Badger Farm, Harestock

and Oliver’s Battery

Date: 21st December 2015

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1. Foreword

The first draft Open Space Strategy (OSS) was approved by Cabinet to go forward to public consultation, on Monday 22nd September 2014. The OSS report presented to Cabinet is held on the WCC Planning web portal as CAB2615 Appendix 3, against the cabinet meeting date of 22/09/2014. This version of the OSS will be referred to as OSS-Cabinet, in this report.

Both Adam & Simon Welch spoke at the Cabinet meeting (22/09/2014) and their statements are in Appendix A & B, and Mr A Welch statement to the Town Forum is in Appendix C.

The Winchester District Local Plan Part 2, Open Space Strategy is split into three parts and is the amended OSS-Cabinet version, subject to public consultation ending on 5/12/2014. For that OSS-Cabinet report, our analysis was based primarily on Part 3 as it covers Winchester Town, but other parts are also referred to, in the context of Littleton and Kingsworthy. These versions of the OSS will be referred to as OSS-LP2, in this report. Mr A Welch & Mrs B Welch made objections to OSS-LP2 which included the discovery of a fundamental logic change in recording criteria for “Existing Sports Ground provision” for Winchester Town. We found for Winchester Town, this has amounted to 38.8 hectares (approx 96 acres) being recorded against “Existing provision” when in fact there is no public access, and therefore should not have been used. This produced an inaccurate and misleading impression that sports grounds in Winchester Town provide an existing provision of 61.79 ha against a CP7 requirement of 33.57 ha, giving a surplus of 28.22 ha, when in fact, if the 33.8 ha of sport grounds that do not have public access are excluded, the surplus becomes a deficit of -10.58 ha (approx -26 acres) and the existing provision is 22.99 ha not 61.79 ha.

A copy of Mr A Welch & Mrs B Welch OSS-LP2 objection is supplied as a separate document A_B_Welch_OBJECTION_to_Open_Space_Strategy_20141205.

After public consultation ended on OSS-LP2, council officers made amendments in relation to comments received and published Open-Space-Strategy-Sept-2015, for public consultation, which will end on 21st December 2015. This version of the OSS will be referred to as OSS-LP2-SEPT2015, in this report.

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Essentially there have been three Open Space Reports produced to date, with evidence of logic changes and discrepancies.

Policy CP7 sets the Open Space minimum standard of 4 ha per 1000 population, split into 6 categories of Open Space. (1-Allotments 2-Equipped children’s and young peoples space 3-“Informal” green space 4-“Natural” green space 5-Parks,Recreation Grounds 6-Sports fields)

2. Fundamental change to Open Space recording

2.1 There has been a fundamental change in the recording of existing Sports ground provision in OSS-LP2 when compared against OSS-Cabinet. Essentially, the OSS- LP2 now records (in some cases) Sport Fields areas where there is no public access. This effectively means the data recorded in the OSS-LP2 is neither robust nor accurate. However the OSS-LP2-SEPT2015 addressed most of these discrepancies, except for the case of Harestock, but there is still persistent inaccuracy in the ‘Needs and Opportunity’ text for many areas, which still means the OSS- SEPT2015 is not fit for purpose, robust or effective.

2.2 The OSS-LP2-SEPT2015 lacks a matrix summary page for Winchester Town, instead providing continuous detail per area without consolidation and general overview. A summary consolidated matrix would be useful.

2.3 Harestock had in two previous OSS reports (OSS-Cabinet & OSS-LP2) had a recorded population of 3,077. The latest report (OSS-LP2-SETP2015) records a large reduction in population to 2,235. This reduction of 842 in population (or 372 households @ 2.26 persons per household) gave rise to a reduce CP7 requirement of -3.37 ha. I have email exchanges between myself and WCC Landscape, (See Appendix D) with evidence in the email that makes me question the validity of this population reduction. The email in question, was from WCC Landscape Officer, Mr S Dumbar-Dempsey, to myself, date 3 Dec 2015, 2:17 PM. It contained a confusing explanation, but significantly it included ‘Harestock within H3 = 3249(2014), 3263(2015)’ . Clearly, by data contained in WCC own email, the true population for Harestock within policy boundary H3 should be 3263, not 2,235 as reported. I believe this figure should be robustly validated. Why is 2235 used for population of Harestock and not the 3263? This change makes no sense on the ground, as houses have not been demolished and there is no evidence of a mass migration, leaving 372 home empty!!!

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Extract from email in Appendix D N.B. Littleton H3 = 814 (2014) ,818 (2015); with Harestock within H3 = 3249 (2014), 3263 (2015), not far off the 3601, 3602 for the Littleton and Harestock parished area which accounts for population in countryside.

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2.4 Harestock has two school including Henry Beaufort Secondary School, but the OSS- LP2-SEPT2015 has recorded 9,199 sq.m as ‘existing provision’ for Henry Beaufort School. Even though the small Astro Turf pitches can be hired in term time only, they are not normally publically assessable. This is the case for other school facilities in Winchester which have not been recorded as ‘existing provision’. Harestock existing Sports provision should be reduced by 0.92 ha, therefore taking the existing provision from 2.03 to 1.11 ha, therefore making the adequacy -0.57, not the reported +0.35 ha.

2.5 As a general rule of thumb, I believe it is not appropriate to record any school facility as existing provision, because they are not public assessable out of term time or weekends and thus skew data and do little to uphold the function of the OSS.

2.6 The OSS-LP2-SEPT2015 on page 6, states in the third paragraph :-

“Several school playing fields and other private sports grounds are not included in the assessment, either because they are not accessible to the public or they are not visible from the public realm and can not be said therefore to be contributing to the character and appearance of a locality.”

The evidence clearly indicates this statement is false, and the OSS-LP2-SEPT2015 can not be view as accurate, robust or meeting the requirements of NPPF & NPPG.

2.7 “Needs and opportunities” text for Harestock area

“Harestock, taken in isolation as a suburb of Winchester, lacks sufficient public open space when assessed in accordance with the standard in LPP1 Policy CP7. There are shortfalls in all categories except sports grounds. However, there are opportunities to expand the provision of public open space available to the area as part of the Barton Farm major development area becomes available. Some 23 hectares of open space will become accessibel to this north west part of the town.”

I have already objected previously to this text, in the last OSS draft. My objection is still applicable, as changes have not been made. Even though in an email the Landscape officer did say he would make the changes see Appendix E. See Section 7 for objection detail regarding Harerstock.

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3. Local Plan Part 1 and NPPG Policy relating to Open Space

Local Plan Part 1, section 3.2.3 “Retension of open space and consideration of opportunities to address any under- provision”

Local Plan Part 1, section 3.6.3 “Although some shortfalls will remain and opportunities to remedy them will be sought, there are difficulties in assembling land for this use given the high values within the town. Allocating land beyond the town boundary would have only limited benefits and the open spaces provided would not be accessible to residents in the more central wards.”

Local Plan Part 1, section 6.2.23 “Policy CP7 requires that where important open areas, including hard surfaced areas such as courts, are proposed to be lost completely, replacement open space should be provided nearby. Where this is not possible, then the community benefit of the development should be shown to clearly outweigh the harm caused by the loss of the open space”.

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Par 17. (whole paragraph not listed)

Be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. Plans should be kept up-to-date, and be based on joint working and co-operation to address larger than local issues. They should provide a practical framework within which decisions on planning applications can be made with a high degree of predictability and efficiency;

Not simply be about scrutiny, but instead be a creative exercise in finding ways to enhance and improve the places in which people live their lives;

Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings ;

Promote mixed use developments, and encourage multiple benefits for the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage or food productions);

Par 73.

Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the needs for open spaces, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessment should be used to determine what open space, sports and recreational provision is required.

Par 74.

Existing open space, sports and recreational buildings and land, including playing fields should not be built on unless:

An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

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The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

Par 182.

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

Par 187. Local planning authorities should look for solutions rather than problems, and decision-takers at every level should seek to approve applications for sustainable development where possible. Local planning authorities should work proactively with applicants to secure developments that improve the economic, social and environmental conditions of the area.

LPP1-Chapter-4-6 Par 4.6, bullet point 6.

“Provide open space and recreational provision to address future requirements and existing deficiencies – there is a shortfall of recreation land available for the size of population, and some housing areas are poorly served in terms of access to play or sports facilities”

LPP1-Chapter-4-6 Policy WT1, which includes. additional open space and recreational provision, including: _ opportunities to address any under-provision of open space, to be secured through new allocations and in conjunction with development;

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Extracts from National Planning Policy Framework, DCLG 2012

“Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well being of communities.”

“Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision.”

“The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area.”

Information gained from the assessments should be used to determine what open space, sports and recreational provision are required.” (National Planning Policy Framework, DCLG 2012).

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4. General objections relating to OSS-LP2-SEPT2015

4.1 Appropriate recording of Informal Green Space.

There are examples of road verges and roundabouts grassed areas, being recorded and mapped as Open Space. See in St Barnabas ward, (Ref 6) Fromond Road , Taplings Road and the roundabout at this connection. These areas, though offering a local distinctiveness and visual relief to the build form, do not offer a safe location for children or adults to use. Therefore, is it appropriate to record them as Open Space when they are neither high quality, safe or offer the opportunity for sports and recreation, which are the requirements of NPPG Par 74 & 75. Their inclusion in the OSS-LP2-SEPT2015 does little to provide a robust assessment of existing provision, and in fact skews the reader into believing there is more useable provision than there is. This affectively undermines the function of the OSS.

4.2 Is OSS-LP2-SEPT2015 a robust and objective assessment of Open Space.

The simple answer to this question is NO.

The report for Winchester Town is particularly poor. The Winchester Town is made up from the six Wards (St Barnabus, St Batholomew’s, St John’s, St Luke’s, St Michael & St Pauls) plus three adjacent housing areas of Badger Farm, Harestock and Oliver’s Battery, making nine areas in total. As there are six categories of open space (Allotments, Equipped Play, Informal green space, Natural green space, Parks/Recreation grounds and Sports grounds) coupled with the nine Winchester areas we can make a matrix of (6 x 9) 54 elements, making up an summary overview of adequacy. This matrix will at a glance provide an excellent overview of the open space adequacy for Winchester Town. However, such a useful matrix has not been provided in the OSS- LP2-SEPT2015. I have provided it below. I suggest such a matrix would be useful in describing the current state of Winchester Town’s Open Space and offer a quick reference to check that statements made by the LPA are upheld by the relevant data.

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Paper=A3 Adequacy Matrix for Winchester Town, using OSS-LP2-SEPT2015 data.

<------Adequacy taken from Open Space Strategy Sept 2015 in ha ------> Total Total Notes Notes St Paul's St Luke's St Luke's St John's St John's Harestock Harestock St Michaels St Michaels St Barnabus St Barnabus Badger Farm Farm Badger Oliver's Battery Oliver's Battery

St Bartholomew's Allotments -0.53 -0.45 -0.30 -1.13 4.34 3.70 0.79 -0.50 -1.25 4.67 Equipped Childrens Play -1.25 -0.84 -0.60 -2.72 -2.87 -1.95 -2.11 -2.95 -3.23 -18.52 Informal Green Space 5.16 -1.52 -0.53 -1.97 0.69 -3.70 5.80 4.85 -5.17 3.61 Natural Green Space 8.37 -2.24 0.63 -6.34 1.94 38.39 -5.31 62.72 -6.89 91.27 Parks & Recreation Grounds -1.98 -1.68 0.24 -3.83 5.27 0.72 0.63 -1.92 -3.43 -5.98 Sports Ground -1.98 0.35 b -1.12 -4.76 -1.39 12.47 -3.98 -4.95 -5.17 -10.53 Total 7.79 -6.38 -1.68 -20.75 7.98 49.63 -4.18 57.25 -25.14 64.52

Notes and objections: a) Harestock's population in OSS-Sept-2015 has been reduced by 842 in the report from 3077 to 2235!! This reduces Harestock Total CP7 requirement by -3.37 ha. But WCC Email from WCC Landscape show H3 Harestock population is 3263 (2015)!!! b) Harestock - Sports Ground Existing provision of 2.03 ha includes Henry Beaufort School playing field (0.92 ha), which has no public access. Therefore adequancy should be (0.35-0.92=-0.57 ha)

If the population of Harestock is in fact 3,077 (not the reported 2,235) then the Adequacy Total for Harestock will become -6.38 -0.57 -3.37 or -10.32 ha and not -6.38 ha

If the true Harestock Adequacy Total is in fact -10.32 ha then it has been under reported by ( (10.32-6.38)/(6.38/100) = 61% !!!

Page 12 v1 c) There are six categories of Open space and NINE areas (Badger's Farm to St Paul's) making 54 (6x9) MATRIX Entries for adaquancy.

36 / 54 matrix entries are NEGATIVE in deficit, representing 66.66% INADEQUATE with only 33% being Adequate. e) The Stanmore Planning Framework (in St Luke's Ward) promotes housing development on existing open space, garages and allotments. This will have a negative impact on the lives of people already living in St. Luke's ward. The Stanmore Planning Framework (assuming 150 units @ 32 dph) will require 4.69 ha for development. If say 70% is to be provided on existing Open Space and allotments, then the current shortfall of -4.18 ha will likely increase by 3.28 ha to -7.46 ha. The new development population will require open space of 1.36 ha ( (150*2.26)/1000*40,000 = 13,560 sq.m)

Therefore the existing deficit for St Lukes may rise from -4.18 to -8.82 ha (-4.18 -3.28 –1.36). This is an increase in shortfall of 111%.

Therefore the Stanmore Planning Framework actually promotes making the area 111% worse, in open space terms. This is in direct conflict with NPPF core principles and JCS1.

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4.3 Inconsistency in reporting of ‘Needs & Opportunities’

The inconsistent “Needs & Opportunities” assessments and misleading statements about Barton Farm providing 23 hectares of open space, without qualifying that the surplus over that required by the Barton Farm population is a mere 5.18 ha (accommodates just 1295 people), is misleading and can not be seen as meeting the requirements of NPPG and Par 74 & Par 75.

Further more, for St Barnabas and Harestock wards, the “Needs & Opportunities” assessment have missed reference to the St Barnabas & Harestock Community Action Plan (35 steps) where the locally identified need for additional open space, community facility and housing is high priority, even though Mr A Welch made a statement to Cabinet (22/09/2014) highlighting these issues.(See Appendix B). Although there is recognition that there are very few opportunities to add to the overall quantum, such opportunities have been ignored in the strategy, against NPPG policy. This in the context of a massive -80% shortfall in open space provision for the over nine thousand people living in St Barnabas and Harestock wards.

The NPPG and in particular par 74 & 75 policy is clear. Local plan makers should plan sustainable development to meet local needs, based on up-to-date, robust assessment. Clearly, St Barnabas & Harestock have a local need for housing, open space and community buildings, and the planners have chosen to ignore these needs, even when an opportunity is available and when NPPG states local authorities should be pro-active in providing new facilities to meet identified local needs. The needs are identified in the St Barnabas and Harestock Community Action Plan (35 steps), which itself is a SPD, as is the identified Open Space shortfall in OSS-Cabinet , OSS-LP2 and OSS-LP2- SEPT2015.

What is the point of an Open Space Strategy, when the strategy element is missing for St Barnabas & Harestock wards, where there is an identified shortfall of -80%, and opportunities exist to help meet those needs. An Open Space Strategy covering a twenty year period should assess all opportunities, no matter how few. The OSS-LP2-SEPT2015 makes no reference to potential sites that are known to the planning department by way of a pre-application consultation, planning application 14/02848/OUT, land availability in the SHLAA and statements made to Cabinet, where both the Head of strategic planning and Open Space Officer were present.

The OSS-LP2-SEPT2015 is not accurate, is not consistent in its recording of existing Sports ground provision, the “Needs & Opportunities” assessments lack thoroughness and consequently is not fit for purpose and is not following NPPG. The OSS-LP2- SEPT2015 is especially poor in relation to St. Barnabas and Harestock wards, where there appears to be an effort made to hoodwink the tax paying public and City Councillors into

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believing the situation is better than it really is. If a ward has a deficiency, then report it in its entirety and plan to fix it. That is the function of the Open Space Strategy.

5. OSS-LP2-SEPT2015 strategy conflicts with planning frameworks.

5.1 Stanmore Planning Framework.

The OSS-LP2-SEPT2015 strategy for wards where there is also a Planning framework (Stanmore, Abbotts Barton & Station Approach) is promoting planned increase in open space shortfall which is in direct conflict with NPPF. The OSS-LP2-SEPT2015 defends open space retention but the planning frameworks target existing Open Space. All the targeted development areas of open Space, garages and allotments in Stanmore are owned by WCC.

5.2 Planning Frameworks are unfair and not publically supported

There is public disquiet above the public consultation procedures and processes followed in the production of planning frameworks, as evident in the objections by Winchester Town Forum and others. The data analysis presented above, provides evidence that such Frameworks will be detrimental to the areas, in landscape terms. In the case of Stanmore, the existing shortfall in CP7 space is likely to increase by 111%. There are concerns that the LPA has a conflict of interest, as they are both the land owner and decision maker. Had the open space not been owned by the LPA, would the planning frameworks development be allowed? I don’t believe so.

5.3 Police HQ in St Paul’s ward

The proposed development at the Police HQ does little to improve the public realm, in an area which is the most deprived in open space terms of all the Winchester wards. Such development will create more demand for open space, which the OSS strategy does not address.

5.4 Bushfield Camp Knowledge Park and it’s Open Space potential

Various studies have been commissioned which have resulted in uncertainty regarding the prospect of the Knowledge Park being delivered, due to viability. The Church Commission who own the site have promoted a retirement village due to viability issues. A retirement village is not a Knowledge Park, though there is not a definition of a Knowledge Park in the Local Plan. WCC have responded by commissioning yet another report, with a prime objective to find a specific ‘Retirement Allocation’ was not required, as the emerging Local Plan provided enough flexibility for retirement village like applications. Clearly, if the

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Bushfield Camp is not viable and the owners don’t want a Knowledge Park, there is little prospect of gaining the new open space the City needs. This situation will mean the places people live in Winchester continuing to be poorly serviced by Open Space and the Local Plan fails to effectively address those needs. Even if Bushfield’s open space was delivered, it is in the wrong place to affect the majority of wards in deficit and the timeline is too in the future. Only new small Greenfield development will have the potential to quickly alleviate open space needs, in both the short and long term.

5.5 Is the OSS-LP2-SEPT2015 following Local Plan Part 1 policies

Within Local plan Part 1, section 3.2.3 and 3.6.3, there is a clear commitment to “Retension of open space and consideration of opportunities to address any under-provision” and “Although some shortfalls will remain and opportunities to remedy them will be sought”. Effectively, OSS should seek as a basic principle to proactively search for opportunities to address identified shortfalls in open space in every ward. The assessment text should be consistent and follow the LP1 principles in all wards with a shortfall.

Currently the OSS-LP2-SEPT2015 does not consistently present an objective assessment text.

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6. OSS-LP2 and St Barnabas ward

6.1 Inaccurate existing “Sports Ground” provision is Zero - corrected

St Barnabas ward has a population of 6,345 and the OSS now correctly reports existing Sports grounds as ZERO ha.

However, Fromond Road central reservation (Ref 6) is identified as Informal Green space. This in previous OSS draft reports was not identified. Is it really a good idea to include central reservations and roundabouts, with roads all around as ‘useful’ informal green infrastructure. I don’t believe this is useful or provide ‘high’ amenity value.

6.2 Affordable housing on Westman road Open Space – correctly removed

The Westman Road play area has been lost to an Affordable housing scheme and therefore been removed from the report.

6.3 St Barnabas Community Action Plan (35 steps) omitted

The assessment text has missed reference to the St Barnabas & Harestock Community Action Plan (35 steps) where the locally identified need for additional open space, community facility and housing is high priority, even though Mr A Welch made a statement to Cabinet (22/09/2014) highlighting these issues.(See Appendix B) and Mr Welch has emailed the planning department regarding these omissions.

Why is the land lost to affordable development in Westman Road not being replaced by new open space in quantity, as required by NPPG and JCS1, when opportunities exists and the planning department is aware of them. (Welches Harestock Road pre-app and SHLAA and 14/02848/OUT).

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6.4 OSS-LP2 and “Needs & Opportunities” stated for St Barnabas

Below is the assessment provided for St Barnabas in OSS-LP2-SEPT2015.

Assessment for St Barnabas (Population: 6345) presented in OSS-LP2- SEPT2015 Taken in isolation as a suburb of Winchester, St Barnabus Ward is dificient in open space provision when assessed against the standard in Local Plan Part 1.

There are very few opportunities to add to the overall quantum of open space and the strategy is to concentrate instead on improving what exists in terms of quality and accessibility. The major development area at Barton Farm will add to the open space available to this part of town.

Assessment for Oliver’s Battery (Pop: 1489) presented in OSS-LP2-SEPT2015 A suburb of Winchester with good access to open countryside but with shortfalls of public open space.

Additional land and facilities are required.

6.4.1 “Deficient” provision

To state the St Barnabas ward is “deficient” in open space is an understatement in the extreme. The St Barnabas ward has a -81.28% shortfall in open space provision for a population of 6,345. The St Barnabas ward is 40% larger than Barton Farm in population terms, as the expected population in Barton Farm MDA is 4,520.

Barton Farm itself requires 18.08 ha of open space to meet the minimum CP7 standard. The planned open space provision at Barton Farm is 23.26 ha, giving a surplus of just 5.18 ha. Using the 4 ha per 1000 population CP7 standard, the 5.18 ha surplus at Barton Farm will accommodate approximately 1295 people.

The existing open space provision of Harestock & St Barnabas total only (1.65 + 4.63) 6.28 ha (when including the Henry Beaufort School fields 0.92 ha) , against a CP7 requirement of (8.95 + 25.38) 34.33 ha, giving a shortfall of 28.05 ha or 69 acres. Taken together Harestock & St Barnabas have a shortfall of -81.70%.

Taking the population of 9,422 for Harestock (2235 3077) and St Barnabas (6345), which is more than twice the expected population of Barton Farm (4520), and giving

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their combined shortfall of -81.70%, it is completely inappropriate that the seriousness of the shortfall is not commented on in a more meaningful way.

Compare the OSS-LP2-SEPT2015 statement for Oliver’s Battery, which has only -28% shortfall for a small population of 1489. In this case a statement is made that “Additional land and facilities are required”. The evidence is overwhelming, the OSS-LP2- SEPT2015 should urgently seek land for additional open space provision, in line with NPPG and JCS1, secured through new allocations and in conjuction with development.

JCS1 LPP1-Chapter-4-6 Policy WT1, which includes. additional open space and recreational provision, including: _ opportunities to address any under-provision of open space, to be secured through new allocations and in conjunction with development;

The OSS-LP2-SEPT2015 is neither accurate, robust, effective or justified.

6.4.2 “Very few opportunities to add to the overall quantum of open space ”

The statement recognises there are a few opportunities to add to the overall quantum and for some unexplained reasons does not expand on them, but instead states the 20 year strategy is on improving what there is. This is in stark contrast to the Oliver’s Battery assessment statement of “Additional land and facilities are required.”. This is out of step with NPPG (specifically Par 17, 73, 74, 182 & 187) and can not be reasonably viewed as up-to-date, accurate, effective or justified.

In the context of Harestock and St Barnabas having a -81.70% shortfall amounting to - 28.5 ha or 69 acres, and the planning department have consulted on a pre-application that put forward 5 acres of new open space in Harestock road with a barn for conversion to a community facility, well connected to Harestock and St Barnabas, brings into question the motives of this deliberate omission. This is against national policy in NPPG.

Why is Harestock and St Barnabas, with such large identified shortfalls not treated the same as Oliver’s Battery?

Why is the land lost to affordable development in Westman Road not being replaced by new open space in quantity, as required by NPPG, when opportunities exists and the planning department is aware of them. (Welches Harestock Road pre-app and SHLAA).

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7. OSS-LP2-SEPT2015 and Harestock ward

7.1 Inaccurate existing “Sports Ground” provision reported

Harestock ward has a reported population of 2,235 (down 842 from 3,077 in the previous two OSS reports) and has one school playing fields recorded as existing Sports provision. But an Email from WCC shows a H3 Harestock population for 2015 as 3263. This needs investigation as it has major implications in the CP7 requirement for this area. The OSS needs to be accurate.

The Harestock Primary School which existed in the previous OSS report and had an area of 11,123 sq.m and is no longer recorded? It does not have public access but should have been recorded.

The Henry Beaufort School (ref 6) has an area of 9,199 sq.m and is recorded as having public access. The Henry Beaufort school has 5 aside football pitches that are available in the evenings only and not during the schools summer holiday. To record in the OSS-LP2-SEPT2015 an existing Sport grounds provision of 9,199 sq.m when the pitches are less than 600 sq.m is misleading and incorrect. Schools can not be considered as having public access as they are not available during the day or weekends or summer holidays. This is not consistent treatment of school playing fields.

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7.2 OSS-LP2 and “Needs & Opportunities” stated for Harestock

Below is the assessment provided for Harestock in OSS-LP2-SEPT2015.

Assessment for Harestock (Population: 2235 3263? ) in OSS-LP2-SEPT2015

Harestock, taken in isolation as a suburb of Winchester, lacks sufficient public open space when assessed in accordance with the standard in LPP1 Policy CP7. There are shortfalls in all categories except sports grounds. However, there are opportunities to expand the provision of public open space available to the area as part of the Barton Farm major development area becomes available. Some 23 hectares of open space will become accessibel to this north west part of the town.

Assessment for Oliver’s Battery (Population: 1489) presented in OSS-LP2 A suburb of Winchester with good access to open countryside but with shortfalls of public open space.

Additional land and facilities are required.

7.2.1 “Lacks sufficient public open space” provision

To state Harestock “Lacks sufficient public open space” is an understatement in the extreme. There is uncertainty regarding the population of Harestock. The reduction of 842 in population reduced the corresponding CP7 requirement, which has knock-on issues.

However, needless to say a shortfall of open space for Harestock is massive. Harestock is of similar or larger size, in population terms to the new Barton Farm MDA. It is not the function of Barton Farm to support Harestock deficit, as flexibility in policy JCS1 policy is in place to make provision to make up any shortfall.

Barton Farm itself requires 18.08 ha of open space to meet the minimum CP7 standard. The planned open space provision at Barton Farm is 23.26 ha, giving a surplus of just 5.18 ha. Using the 4 ha per 1000 population CP7 standard, the 5.18 ha surplus at Barton Farm will accommodate approximately 1295 people.

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The statement does not recognise the existing opportunity the LPA is fully aware of (Welch SHLAA sites in Harestock Road, Planning app 14/02848/OUT and statements read to Council by Mr A Welch & Mr S.Welch). This is in stark contrast to the Oliver’s Battery assessment statement of “Additional land and facilities are required.” In context of just a 27% shortfall for Oliver’s Battery.

Ignoring the opportunity in Harestock Road is in direct conflict to NPPG (specifically Par 17, 73, 74, 182 & 187) and JCS1 and can not be reasonably viewed as up-to-date, accurate, effective or justified.

In the context of Harestock and St Barnabas having a -81.70% shortfall amounting to - 28.5 ha or 69 acres, and the planning department have consulted on a pre-application that put forward 5 acres of new open space in Harestock road with a barn for conversion to a community facility, well connected to Harestock and St Barnabas, brings into question the motives of this deliberate omission. This is against national policy in NPPG and JCS1.

Why is Harestock and St Barnabas, with such large identified shortfalls not treated the same as Oliver’s Battery?

Why is the land lost to affordable development in Westman Road not being replaced by new open space in quantity, as required by NPPG, when opportunities exists and the planning department is aware of them. (Welches Harestock Road pre-app and SHLAA).

7.2.2 “There are shortfalls in all categories except sports grounds”

This statement is incorrect, as the “Existing Sports grounds” should be 1.11 ha, not 2.03 ha. Harestock in fact has a shortfall in all six categories of Open Space.

The data presented should follow NPPG and be robust, up to date and accurate.

7.2.3 “opportunities to expand the provision of open space”

As like St Barnabas, the assessment text presents 23 hectare of new open space at Barton Farm, without qualifying that there is only a surplus of 5 ha, over and above that required by Barton Farms expected population. This is very misleading and certainly not robust.

The assessment statement does not identify the opportunity for an additional 5 acres of new public open space, and a barn for conversion to community use, that has been

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subject to the planning departments pre-application consultation, a planning application (14/02848/OUT) and is also available in the SHLAA. Instead it only discusses one option for open space improvement, via the Barton Farm MDA.

The assessment text has missed reference to the St Barnabas & Harestock Community Action Plan (35 steps) where the locally identified need for additional open space, community facility and housing is high priority, even though Mr A Welch made a statement to Cabinet (22/09/2014) highlighting these issues.(See Appendix B) and Mr Welch has emailed the planning department regarding their omissions.

8. Conclusion

Decision makers, tax paying public and City Councillors, must be able to rely on the accuracy of Officers reports. This report falls far short in this regard and its journey from draft to draft to draft, highlight some serious logic and accuracy flaws.

The Open Space Strategy OSS-LP2-SEPT2015 is not consistent in objective assessment.

The Open Space Strategy OSS-LP2-SEPT2015 is not accurate, justified or effective.

It falls far short of the standard required by NPPF & NPPG.

Text describing “Needs and Opportunities” mismatch the presented data and often misleads the reader into believing there is more available open space buffer, than there is. (Barton Farm Open Space 23 ha, but buffer is only 5 ha).

The Open Space Strategy OSS-LP2-SEPT2015 is not fit for purpose and does not meet the policy requirements of NPPF & NPPG. Particularly in regards to Harestock and St Barnabus ward.

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APPENDIX A

APPENDIX A - Simon Welch statement to WCC Cabinet 22.09.2014 Read statement by Simon Welch on 22.09.14 at the WCC Cabinet meeting, held at Winchester Guildhall

I consider LPP2 is not based on sound public consultations. Some information is misleading and incorrect and Planning decisions have not taken local circumstances into account.

Community engagement states you have worked with local communities (para 1.12). Evidence in the Consultation statement (Regulation 18 Consultation Statement para 2.15) claims on the 24th February there was a meeting focusing on St Barnabus Ward and Harestock. This is incorrect. (Press release for the workshops stated “meeting aimed at each ward and Parish of Winchester. There might be a number of more local issues that may have land requirements or need to be addressed”)(No mention of the complaints made about the workshops)

The meeting did not discuss local needs or planning issues in the area. An email from Councillor Learney (26.02.14 “insufficient explanation about the scope of LPP2. Anne , Susan and I had asked for the area of North Winchester to be discussed.”) and Eileen Berry (to myself)and an article in the Chronicle agreed it did not. Councillor Learney (in her email)claimed she would tell officers of her disappointment that North Winchester was not discussed.

The public consultation was inadequate and misleading. It is a legal requirement that comments be taken into account and there must be meaningful and proactive engagement (para 1.24 Regulation 18 Consultation Statement).

I would suggest this requirement has not been met for Winchester Town.

There is a Contradictory inconsistent approach to planning. Winchester Town responses requested to consider impact of town cramming and expanding the boundaries.

Expanding the boundaries with small scale development considered the best approach for Bishops Waltham and Waltham Chase (para 3.92)to minimize impact (Para3 Settlement specific summaries in REg 18 Consultation Statement).

A full boundary review was considered not necessary for Winchester Town (Settlement boundary review para 15) ( para 34 – Jan 2013 Town Forum and Parish councils were asked to reassess the settlement boundaries as part of the process of identifying future development needs and how to accommodate them. Few comments were received. ???)

Why is it important to minimize impact in two other communities but not in Winchester?

Further inconsistencies.

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In Alresford (par 3.66)and Kingsworthy developments have been chosen to allow for improvement of deficiencies in open space provision . The open space argument overrode the Lovedon lane site being remote and sensitive.

If it is important to consider open space deficiencies in Kingsworthy and Alresford why is this approach not considered important for the community in Winchester?

Paragraph 3.19, 3.20, 3.21 you suggest development is not allowed in Winchester just to improve open space. ( This goes against the NPPF – this states the purpose of planning is to improve the conditions in which people live)

However you used this argument in Alresford and Kingsworthy.

It is a NPPF requirement to promote healthy communities and improve conditions in which people live, work, travel and take leisure.

Increasing the population within the boundary will increase deficiency in open space and add to congestion and pollution. Communities concerns about this have been disregarded. (written responses identified the approach would not address deficiencies in open space)

This plan promotes town cramming by building on windfall sites. NPPF states this must not be residential gardens and you must resist building on open space. How can the community comment when you have not stated where exactly this will be?

(There has been no consultation showing exactly where the additional 2000 houses will be within the boundaries – only developments mentioned were Barton Farm and Silver Hill )

I also suggest the reliance on a change in economy (para 3.8)is not a reliable planning method to achieve the need for affordable housing.

This is largely regarded as only achievable on Greenfield sites and reiterates my argument that a full boundary review should be considered.

I suggest the document does not consider local needs for open space, affordable housing and has not been planned to improve the conditions in which people live.

With these points in mind, the document should be looked at again with full boundary review for Winchester Town, to address all the issues of local need.

(41% of written responses believed the approach would not meet the needs)

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APPENDIX B

APPENDIX B - Adam Welch statement to WCC Cabinet 22.09.2014 Read statement by Adam Welch on 22.09.14 at the WCC Cabinet meeting, held at Winchester Guildhall

Good morning.

My name is Adam Welch.

I was born and raised in Weeke & Harestock. I married a Winchester girl, and we have raised four children here.

My family owns land in Harestock Road, which has been subject to a pre- application with the planning department for up to 45 homes, including more than 40% on-site affordable housing, 5 acres (that’s 2 ha) of NEW open space, and a barn for conversion to a community use.

This represents a rare opportunity for Harestock & St Barnabas and has been completely missed in the Open Space Strategy report. Our land is also in the SHLAA.

The open space strategy report does not reference the local needs identified in the St Barnabas & Harestock Community Action plan (35 Step) where open space and play areas were top priority(3 out of 35) and facilities for youth, elderly and recreational facilities were all priorities.

SHLAA sites have not been included as opportunities in the open space strategy report.

The report is not in line with paragraph 73 of NPPF, where it is a requirement for planning policies to assess opportunities for new provision.

The open space strategy report, relating to Harestock & St Barnabas, does not identify any need or opportunities in either, even though there is a shortfall of around 80% in both areas.

The Open Space Strategy report has omissions in terms of identifying needs and opportunities, which undermine its function and can not be viewed as robust or meeting it objectives, specifically in relation to St Barnabas and Harestock.

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Both Harestock and St Barnabas have over the last 40 years, had absolutely no NEW open space, even though the shortfall had been identified in previous Local Plans.

Housing The current strategy to develop 2000 house as part of WT1, within the existing boundary of Winchester, creates an open space requirement of 47.42 acres for the extra 4,800 residents.

Winchester Town does not have room for either 2,000 extra houses or 47 acres of new open space, let alone the school places and medical facilities, without extending the cities boundary.

In regard to Bushfield Camp, there are no guarantees it will be delivered, or it’s Open Space. Its viability is questionable, even with the land valued at zero, the return over and above the estimated build costs is only 4%, with a speculative, untested market model.

There is clear evidence that SHLAA sites within the city do not achieve the expected delivery, and therefore SHLAA numbers are grossly over estimated. Please look at Blue Ball Hill (20 became 6), Firestation (36 became 16), SilverHill(307 became 177), police HQ (300 to 194 currently).

Development within the city boundary does not achieve affordable housing either on-site or by way of a financial contribution, due to viability.

Windfall numbers are over estimated. Over time, the finite land area used by windfall sites, reduces the future potential of windfall.

The current strategy for Winchester City will not deliver mixed developments, will not deliver affordable housing, with not deliver well planned, integrated, inclusive developments and will be detrimental to the special character of our historic city.

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APPENDIX C

APPENDIX C - Adam Welch statement to WCC Town Forum 24.09.2014 Read statement by Adam Welch on 24.09.14 at the WCC Town Forum meeting, held at Winchester Guildhall

Date 24th Sept 2014

From the Adam Welch Statement to Winchester Town Forum, 6:30 pm

Introduction Good evening.

My name is Adam Welch.

I was born and raised in Weeke & Harestock. I married a Winchester girl, and we have raised four children here.

I spoke at the Cabinet meeting last Monday (22nd Sept) about the short comings and inconsistencies in the Open Space Strategy report, presented to cabinet. The questions I raised were not answered.

The planning department are meant to follow the NPPF, in their plan making, and it is evident they are not doing so.

My particular concern is that in Open Space Strategy report, the needs and opportunities for Harestock and St Barnabas have been omitted, even though the Planning and Landscape departments are fully aware of their existence, but have chosen not to report them. My simple question is why?

Why is it that for St Barnabas ward, with a population of 6270 and a shortfall in open space provision of 80%, under the Needs & Opportunities heading in the report, there is no comment.

Why is it that for Harestock, with a population of 3077 and a shortfall in open space provision of around 80%, under the Needs & Opportunities heading in the report, there is no comment.

Whereas, in the case of Oliver’s Battery, with a population of 1489 and a shortfall in open space provision of 28%, under the Needs & Opportunities

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heading, the text reads “There is a shortfall of public open space and additional land and facilities are required”.

The St Barnabas & Harestock areas, account for 9347 people, both areas have a 80% shortfall in open space provision, and for both areas the Open Space Strategy assessment makes absolutely no comment. It does not report a shortfall or aspiration for addition land and facilities, although it had for Oliver’s Battery. Why?

Why are St Barnabas & Harestock ignored in this way?

Why are the potential from SHLAA sites ignored?

Why is there no mention of the identified needs contained in the St Barnabas & Harestock Community Action plan (35 Step)? Its on the planning portal website!!

My family owns land in Harestock Road, which has been subject to a pre- application with the planning department for up to 45 homes, including more than 40% on-site affordable housing, 5 acres (that’s 2 ha) of NEW open space, and a barn for conversion to a community use.

This is a low density development (16 dph) on 12 acres, with 5 of the 12 (41%) acres as NEW open space.

This represents a rare opportunity for Harestock & St Barnabas and has been completely missed in the Open Space Strategy report. Our land is also in the SHLAA, and should not have been ignored.

In Par 74 of the NPPF, there is a requirement to replace open space lost to development, with equivalent or better open space in quality and quantity. This means the 1 acre Westman road development could be replaced by an acre of land we are proposing, under this policy. Why do the planners ignore this potential.

With the massive identified need, which has existed since the 70’s and the loss of open space from the YMCA and Westman Road, the Open Space Strategy does not contain ANY aspiration for meeting this need, even when opportunities exist.

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Par 17 of NPPF states plans should be used “in finding ways to enhance and improve the places in which people live their lives”.

The Open Space Strategy report covers the period to 2031, and currently does not meet the standards set by NPPF, in terms of accuracy and objective assessment.

In fact, Para 73 of NPPF states that assessments of open space should assess opportunities for new provision. The Open Space Strategy report says it is following NPPF par 73 & 74, but the evidence is, this is not the case.

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APPENDIX D

APPENDIX D - Email between Mr S Dumbar-Dempsey & Adam Welch, dated 3 Dec 2015, 2:17 PM

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On 3 Dec 2015, at 11:11, wrote:

Adam

Apologies for the delay in responding to your email, we are just extremely busy at the moment. I have provided some responses to your questions in red type below.

I notice that you have corrected the recording of school playing fields as "existing Sports provision, to ZERO", as they have no public access, in all Winchester wards EXCEPT Harestock. Correct.

Have you made a mistake? No, not on this occasion.

All other schools are recorded as ZERO for "Existing Sports Provision", except Harestock!! Yes. The Harestock Road Football Pitch is publically accessible and Henry Beaufort School have an all weather pitch facility which they offer for public use. This contrasts with the other Winchester schools which do not offer public use of their sports grounds, ie Peter Symonds College, Stanmore Primary School, Kings School, Winchester College, and Westgate School.

Also the Harestock population was 3,077 in OSS_LP2_15072015 but is currently set to 2,235 in OSS_Sept_2015, giving a population reduction of 842!!!!

Using the Barton Farm CP7 open space population per dwelling conversion rate of 2.25, the 842 represents (842/2.25) 374 households.

I don't believe Harestock has lost 374 households or 27% of all the housing in Harestock.

Obviously such a massive reduction in population also affects the CP7 requirement for Harestock by some -3.3 ha!!!!

Winchester's population seems to have gone from 44,761 to 43,994, and magically all from Harestock. Which seems a bit odd!!!!

I would have thought that had Winchester's population reduced, then you would evenly pro- rata distribute that reduction across all Wards.

Is the Harestock population of 2,235 correct? Is Yes, please give me the source of this data change. I have consulted colleagues in Strategic Planning for some clarification of the population of Winchester and its wards and the sources for this information and I copy this for you below;

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population forecast Area 2014 2015 Source From: HCC 2013 based small area population

Winchester Unparished area 39,087 39,322 population of parished and unparished areas From: HCC 2013 based small area population

Olivers Battery parish 1,402 1,400 population of parished and unparished areas From: HCC 2013 based small area population

Badger Farm parish 2,583 2,594 population of parished and unparished areas Sum 43,072 43,316

Area 2014 2015 Source From: Estimated population within H3 settleme

John Kelly Jan/Feb2014. John used the HCC

percentage change for each settlement. He as

is the same as the change for the LSOA which

is partially in two/three or more LSOAs he ave

H3 Winchester City 45,507 45,761 LSOAs concerned.

Calculation: Difference between H3 population and unparished area including Oliver’s Battery a Harestock within Winchester Town area

Area 2014 2015 Population of Harestock within Winchester Town 2,435 2,445

N.B. Littleton H3 = 814 (2014) ,818 (2015); with Harestock within H3 = 3249 (2014), 3263 (2015), not far off the 3601, 3602 for the Littleton and Harestock parished area which accounts for population in countryside.

Thus, the latest figure we now have for Harestock (2,445) is a figure someway between the earlier 3,077 and the more recent 2,235. We will adjust the OSS accordingly.

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Kind regards,

Stuart

Stuart Dunbar-Dempsey CMLI

Landscape Team

Winchester City Council

Council Offices, Colebrook Street

Winchester SO23 9LJ

Ext: 2425

Direct line: 01962 848 425

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