Objections to the Proposed Four Marks South Large Development Site

11/1/2019 Mail - Woodgate, Jenny - Outlook

Objections to the proposed Four Marks South Large Development Site

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Objections to the proposed Four Marks South Large Development Site

Objections concerning Large Development Sites (Regulation 18) Consultation Questionnaire (3 September – 15 October 2019)

Objection submitted by:

Name: Email: Address Line 1: Post Town: Post Code:

Objections submitted by email to: [email protected]

And also, by post to: Planning Policy, East Hampshire District Council, Penns Place, Petersfield, Hampshire GU31 4EX

1 Proposed Four Marks South Large Development - Comments & Objections

A Brief Summary of objections to the proposed Four Marks South Large Development Site, with greater detail, fuller argumentation and source references shown below:

A) General Comments and Objections based on relevant local, Council and UK Government documentation

Local, East Hampshire District Council and UK Government documentation all confirm that the proposed Four Marks South Large Development Site is inappropriate and contravenes, conflicts with or violates local, Council and UK Government policies (see more detailed argumentation in the proposed Four Marks South Large Development Site ‘Objections in Greater Detail’ section below this ‘Brief Summary’):

• The Four Marks settlement boundary does not include the land designated for the proposed Four Marks South Large Development Site. • Countryside is defined as any area outside a Settlement Policy Boundary and development will be largely restricted in the countryside to protect its character and attractiveness. • Policies will be put in place to help retain the rural character of the parishes as this is seen to be central to the character of both the Four Marks and Medstead settlements and something to be cherished and protected. • The individual identity of settlements and the integrity of predominantly open and undeveloped land between settlements will not be undermined, furthermore, development proposals in the countryside will only be granted planning permission in exceptional circumstances where there is a genuine and proven need for a countryside location and they are in compliance with other policies in the Development Plan. • It is not appropriate to further widen the settlement ribbon by absorbing a swathe of the rural farmland that bounds the Four Marks settlement along its southern boundary. • The housing requirement for Four Marks/South Medstead has already been exceeded • Once ‘made’, neighbourhood plan policies form part of the development plan used when determining planning applications and where a planning application conflicts with an up-to-date development plan (including any neighbourhood plans that form part of the development plan), permission should not usually be granted. • The Telegraph Lane area of Four Marks, which includes a part of the proposed Four Marks South Large Development Site, is considered to be an area with low levels of service provision and infrastructure but in a tranquil environment with good dark night skies. These latter qualities are considered to be under threat to creeping suburbanisation and plot intensification resulting in, amongst others things, some insensitive infill and this requires: that areas should be protected from further intensification of development or change of use; that development will only be permitted if it maintains the overall character of the area and does not have a detrimental impact on it; and that infilling development will not be permitted. • The proposed Four Marks South Large Development Site is inappropriate and will provide an enclave that may be more closely associated with a city suburban estate and this is considered to be out of keeping with the interests of the Four Marks village. • A rapid increase in development affects some areas, for example, Four Marks, with sites becoming built up over a short space of time but without clear integration with the surroundings; there is a corresponding loss of tranquillity as areas become busier and also a loss of views and connection with countryside where development has been extended. Furthermore, intensification of land for development within and around areas is putting pressure on existing facilities and affecting the quality of the rights of way network.

2 • An increase in development, particularly around key settlements such as Four Marks, has the potential to detract from landscape character if not managed properly.

B) Infrastructure and Sustainability - Material Considerations and Objections

• To date the infrastructure to support a sustainable community has failed to keep pace with housing developments and this will be further exacerbated by the proposed Four Marks South Large Development Site. • Already today there is congestion during peak times at the Telegraph Lane junction with the A31, and massive traffic congestion can be expected to occur when a considerable number of vehicles from the 800 or more new homes on the proposed Four Marks South Large Development Site wish to access the A31, in addition to those that already do so. • The proposed Four Marks South Large Development Site does not, in any satisfactory way, address the considerable extra vehicle usage that can be expected to descend upon the narrow village roadways and particularly the A31 junctions at Lymington Bottom and Telegraph Lane.

C) Biodiversity and Conservation Objections

• The published and widely distributed Four Marks South Large Development Site leaflet contains land biodiversity and ecological errors that lead one to suspect that there may well be a number of other proposed facts presented here that are either economical with the truth or just plain incorrect. The truth is that this land is not of “poor quality” and it harbours considerable bio-diversity. • The creation of the proposed Four Marks South Large Development Site will undoubtedly destroy wildlife and will certainly affect the red kite, a legally protected species. • Construction of the proposed Four Marks South Large Development Site will reduce or remove the existing farmland biodiversity and maybe a rare orchid species.

D) Other Development Plans, Additional Comments and Objections

• Why does the Railway Station Hub proposal outlined in the Neighbourhood Plan 2015-2028, not now appear as a reasonably Large Development Site for all the good reasons cited in the 2015-28 Neighbourhood plan? • The Four Marks South Large Development Site consists of a real hotchpotch of pieces of land that have been scrambled together to construct a large infilled site, the land for which is to be acquired from a variety of different landowners, by five different developers, and therefore the site has necessarily been brought together with a totally irregular formation. In fact, the proposed Four Marks South Large Development Site can be considered to be just one huge infill between Blackberry Lane and Alton Lane. Infill on this scale for the proposed Four Marks South Large Development Site is both inappropriate and not normally permitted. • 10 Large Development sites is a nice round number. Why not 3 or 5 or 15 or 20 or more? And of the 10 there are several which may be inappropriate including the Four Marks South Large Development Site, which is totally inappropriate. • Three, maybe four, of the 10 Large Development Sites would seem to be far more appropriate sites than that at Four Marks South and particularly since properties bought in Four Marks were bought with sure knowledge that the Four Marks Settlement Policy Boundary had been supported and confirmed on many occasions and which had been cited in several local and Council documents.

3 • In response to its own Frequently Asked Question (FAQs), the East Hampshire District Council has confirmed that the infrastructure for Four Marks had not kept pace with recent development and that the absorption of the proposed Four Marks South Large Development Site would indeed exacerbate this. • The East Hampshire District Council hoped or believed that consultation on the proposed Four Marks South Large Development Site would establish a robust evidence base – all this without disclosing to the public, that were to be involved in the consultation, 1) who it was that provided the so called detailed comments refuting the Council’s view, made in the point above concerning exacerbation of the infrastructure problems (was it one of the developers for the proposed Four Marks South Large Development Site or an interested party?), or even, and just as importantly, 2) what the so called comments were. • If the Council was so fully aware of local concern about infrastructure and services in Four Marks why was it not doing something about it, with or without approval of the Four Marks South Large Development Site? • The developers map does not show 800 homes but merely 427 homes, and squeezing 800 homes, or dwellings as the developers call them, into the area shown on the map would require there to be nearly twice as many dwellings shown on the map than the developers have actually indicated, at a density of 42 dwellings per hectare, which is quite a high figure for a newly developed site, in a rural area, and built on non-previously developed agricultural land. It would seem that maybe the developers have in mind to build pretty small dwellings and gardens on this land in order to cram in 800 dwellings alongside a suitable green infrastructure, so, is this yet another issue on which the developers have mislead us? Furthermore, we might expect that in order to meet the target of 800 or more dwellings, the developers will ‘unexpectedly’ need to reduce the strongly promoted and necessary green space and linkages. Is all of this a tall order for the developers or a tall story? The proposed Four Marks South Large Development Site is inappropriate and will provide an enclave that may be more closely associated with a city suburban estate, and this is considered to be out of keeping with the interests of the Four Marks village. • A rough calculation shows that the proposed Four Marks South Large Development Site will grow the population of Four Marks village by 40% without including any natural growth of the village population that may also occur over the period. How, you may ask, is our already depleted infrastructure going to cope? Our village is going to be under very considerable infrastructural pressure if the proposed Four Marks South Large Development Site is approved and permitted to go ahead. Recall that the East Hampshire District Council already acknowledges that infrastructure to support a sustainable community has failed to keep pace with housing developments and that this will be further exacerbated by the proposed Four Marks South Large Development Site. • This proposed Four Marks South Large Development Site really must not be approved and permitted to go ahead.

4 Objections to the proposed Four Marks South Large Development Site in Greater Detail and with Source References

A) General Comments and Objections based on relevant local and UK Government documentation

1. While the necessity to regularly review local plans for land and housing development is well understood, East Hampshire District Council must by now be well aware that the people, the residents, the community of Four Marks have spoken and, on several occasions, made their views known on land development and housing in the Local Interim Planning Statement for Four Marks and Medstead Sustainable Future1 and most recently for the 2015-2028 Medstead & Four Marks Neighbourhood Plan2 and for the Draft Local Plan 2017-20363. These and other documents have confirmed that the Four Marks settlement boundary does not include the land designated for the proposed Four Marks South Large Development Site. It was hoped and believed that housing growth in Four Marks/South Medstead and Medstead Village will have been contained by the clearly defined Settlement Policy Boundaries and that that these boundaries would preserve the quality of the setting2.

2. In planning terms, countryside is defined as any area outside a Settlement Policy Boundary where more restrictive policies would generally be applied. The only development allowed in the countryside will be that with a genuine and proven need for a countryside location, such as that necessary for farming, forestry, or other rural enterprises.4 It is the Local Planning Authority’s priority to protect the countryside for its intrinsic value and development will still be largely restricted in the countryside to protect its character and attractiveness3. The settlements of Medstead and Four Marks have always had a rural/countryside character and this has largely been preserved until today. The Neighbourhood Plan seeks to put in place policies to help retain the rural character of the parishes as this is seen to be central to the character of both settlements and something to be cherished and protected2. The proposed Four Marks South Large Development Site violates these requirements

3. The individual identity of settlements and the integrity of predominantly open and undeveloped land between settlements will not be undermined, furthermore, development proposals in the countryside will only be granted planning permission in exceptional circumstances where there is a genuine and proven need for a countryside location and they are in compliance with other policies in the Development Plan3. Four Marks is a semi-rural ribbon settlement that straddles the A31/Watercress Line with a relatively small number of village centre facilities1, it is not, therefore, appropriate to further widen the settlement ribbon by absorbing a swathe of the rural farmland that bounds the Four Marks settlement along its southern boundary in order to construct the proposed Four Marks South Large

1 Four Marks and Medstead Sustainable Future, Local Interim Planning Statement; pp. 2, 4, 7, 10-13 Appendix 3 (East Hampshire District Council, 2014 p.4 & 10 - Four Marks and Medstead Settlement profile Maps) http://easthants.moderngov.co.uk/documents/s1546/LIPS%20Appendix%201.pdf (accessed 09/10/2018) 2 Medstead & Four Marks Neighbourhood Plan 2015-2028; p.11, 13, 15, 17 & 32 D- Policies Map Inset 3: Four Marks (East Hampshire District Council, 2016) https://www.easthants.gov.uk/sites/default/files/documents/Medstead%20and%20Four%20Marks%20Neighbourhood%20Plan% 20%28pdf%202.27%20mb%29.pdf (accessed 09/10/2018) 3 Draft Local Plan 2017-2036 (Regulation 18) Consultation 5 February – 19 March 2019; p.5 & 214 and Policies Map; p.22 (East Hampshire District Council, 2019) https://www.easthants.gov.uk/sites/default/files/documents/Draft%20Local%20Plan.pdf (accessed 09/10/2018) https://www.easthants.gov.uk/sites/default/files/documents/Policies%20Map.pdf (accessed 09/10/2018) 4 The East Hampshire District Local Plan: Joint Core Strategy; CP19 Development in the countryside p.55 (East Hampshire District Council, 2014) https://www.southdowns.gov.uk/wp-content/uploads/2018/04/Ex01-East-Hampshire-Joint-Core- Strategy.pdf (accessed 09/10/2018)

5 Development Site, since this would contravene the East Hampshire District Council’s Development in the countryside Policy in the Draft Local Plan 2017-2036.

4. The Four Marks Community Plan (2012)5, a survey of residents to identify issues and an Action Plan for the future showed that 92% of respondents thought the village did not need any more housing development and this seems to remain to be the case today. Furthermore, the housing requirement for Four Marks/South Medstead has already been exceeded through the granting of planning permissions. These sites are allocated within the East Hampshire Housing and Employment Allocations Plan (H&EA)2. Given this, there is no need to allocate the proposed, mainly agricultural, land south of Four Marks for the proposed Four Marks South Large Development Site.

6. The East Hampshire District Local Plan: Joint Core Strategy6, sets out the minimum number of new dwellings to be developed in each of the levels in the settlement hierarchy and identifies: Four Marks/South Medstead to provide a minimum of 175 dwellings over the plan period. However, as residential development has already been built and recently more planning permissions have been granted, Four Marks has substantially exceeded this number. East Hampshire District Council has advised that there is no need for the Medstead & Four Marks Neighbourhood Plan to allocate any additional homes over the plan period3. Therefore, there is no need to allocate the proposed, mainly agricultural, land south of Four Marks for the proposed Four Marks South Large Development Site.

5 Once ‘made’, neighbourhood plan policies form part of the development plan used when determining planning applications and the Draft Local Plan 2017-2036 map for Four Marks does not in any way identify the Four Marks South Large Development Site as a proposed site allocation, rather it identifies other sites coded as SA25, SA26, SA27, SA28 and SA293.

6 The presumption in favour of sustainable development does not change the statutory status of the development plan as the starting point for decision making. Where a planning application conflicts with an up-to-date development plan (including any neighbourhood plans that form part of the development plan), permission should not usually be granted. Local planning authorities may take decisions that depart from an up-to-date development plan, but only if material considerations in a particular case indicate that the plan should not be followed7. The proposed Four Marks South Large Development Site should not be authorised since it quite clearly conflicts with the Four Marks development and neighbourhood plans

7 In the Neighbourhood Character Study for East Hampshire District Council8 twenty Special Character Areas were studied including that in and around Telegraph Lane which forms one of the four roads enclosing the proposed Four Marks South Large Development Site on its north east side. The Telegraph Lane area considered here includes a part of the proposed Four Marks South Large

5 Four Marks Community Plan; p.18 (2012) https://www.easthants.gov.uk/sites/default/files/documents/28.%20Four%20Marks%20Community%20Plan.pdf (accessed 09/10/2018) 6 The East Hampshire District Local Plan: Joint Core Strategy; CP10 Spatial Strategy for Housing p.41 (East Hampshire District Council, 2014) https://www.southdowns.gov.uk/wp-content/uploads/2018/04/Ex01-East-Hampshire-Joint-Core- Strategy.pdf (accessed 09/10/2018) 7 National Planning Policy Framework Presented to Parliament; p.6 & 7 (Ministry of Housing, Communities and Local Government, 2019) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2019_revis ed.pdf (accessed 09/10/2018 8 Neighbourhood Character Study for East Hampshire District Council Final Report: Classification and Description pp.3-4 & 25 (Hampshire County Council & Hampshire Services 2018) https://www.easthants.gov.uk/sites/default/files/documents/1EastHantsNCSSection1Chapter1to3FINALDec2018.pdf (accessed 09/10/2018)

6 Development Site.9 The Executive Summary for this report expresses the view that the twenty study areas that were assessed are areas of predominantly low to very low density 20th century residential developments with low levels of service provision and infrastructure. The distinctive, attractive and special qualities that these areas bring to East Hampshire are, amongst others, a strong green infrastructure, distinctive to East Hampshire and a tranquil environment with good dark night skies. It goes on to report that: these qualities are considered to be under threat to creeping suburbanisation and plot intensification, resulting in, amongst others things, some insensitive infill and this requires: that these areas should be protected from further intensification of development or change of use; that development will only be permitted that maintains the overall character of the area and does not have a detrimental impact on it; and that infilling development will not be permitted. Quite clearly on the basis of this report the proposed Four Marks South Large Development Site is inappropriate and will provide an enclave that may be associated with a city suburban estate, and this is considered to be out of keeping with the interests of the Four Marks village.

8 In another section of the Neighbourhood Character Study for East Hampshire District Council under the heading Key Issues, Trends and Sensitivities it is reported that a rapid increase in development affects some areas, for example, Four Marks, with green field sites becoming built up over a short space of time but without clear integration with the surroundings. There is a corresponding loss of tranquillity as areas become busier and also a loss of views and connection with countryside where development has been extended. Furthermore, intensification of land for development within and around areas is putting pressure on existing facilities and affecting the quality of the rights of way network.10

9 The East Hampshire Green Infrastructure Strategy commissioned by the East Hampshire District Council11 highlights the issue that an increase in development particularly around key settlements, and it identifies Four Marks as one of six settlements, that have the potential to detract from landscape character if not managed properly. B) Infrastructure and Sustainability - Material Considerations and Objections

10. The rural nature of the villages of Medstead and Four Marks is being radically altered by the urban nature of new developments, and investment in the infrastructure in our villages has lagged significantly behind the very rapid increase in the number of new houses that have been built2. To date the infrastructure to support a sustainable community has failed to keep pace with housing developments and this will be further exacerbated by the proposed Four Marks South Large Development Site.

11. Today the A31 junction at Telegraph Lane, and to a lesser extent at Lymington Bottom, continue to be a safety issue and this is a cause of important concerns. In addition, there is already considerable congestion, and especially during peak times, at the Telegraph Lane entry onto the A31 Winchester Road and also where Blackberry Lane joins Telegraph Lane just 10 or so metres from the A31. Because the shortest and quickest route from the proposed Four Marks South Large Development Site to access the A31

9 Neighbourhood Character Study for East Hampshire District Council Final Report: Classification and Description Section 6, Appendix 2: Study Area Maps pp.232-236 (Hampshire County Council & Hampshire Services 2018) https://www.easthants.gov.uk/sites/default/files/documents/6EastHantsNCSReportSection6Appendix2StudyAreaMapsFINALDe c2018Compress.pdf (accessed 09/10/2018) 10 Neighbourhood Character Study for East Hampshire District Council Final Report: Classification and Description Section 5, Appendix 2: Study Area Maps pp.202-203 & 216 (Hampshire County Council & Hampshire Services 2018) https://www.easthants.gov.uk/sites/default/files/documents/5EastHantsNCSReportSection5Chapter5to7FINALDec2018.pdf (accessed 09/10/2018) 11 East Hampshire Green Infrastructure Strategy commissioned by East Hampshire District Council p.17 (LUC 2019) https://www.easthants.gov.uk/sites/default/files/documents/East%20Hampshire%20GI%20Strategy%20May%202019_0.pdf (accessed 09/10/2018)

7 will be via the Telegraph Lane and Blackberry Lane junction at the A31 Winchester Road, it can be predicted that massive traffic congestion can be expected to occur at the Telegraph Lane junction with the A31, when a considerable number of vehicles from the 800 or more new homes on the proposed Four Marks South Large Development Site wish to access the A31, in addition to those that already do so. Furthermore, the proposed Residential Community Facility next to Blackberry Lane will add still further to congestion onto and out of Blackberry Lane. The most sustainable housing sites would minimise traffic impact on the A31 and clearly the proposed Four Marks South Large Development Site will not do so.

12. If the proposed Four Marks South Large Development Site should be approved, and I do not think it should for the various reasons outlined here and elsewhere, then the junction where Telegraph Lane exits onto the A31 Winchester Road must be modified to allow effective and efficient access to the A31 Winchester Road. One possible modification would be to establish a set of traffic lights at this junction and which, I suggest, should be planned for even if the proposal is not approved.

13. It should be noted that besides the limited transport/bus service between Alton and Winchester there is currently a scarcity of other facilities such as primary schooling, a limited range of small shops, one Petrol station, a small Village hall, overburdened doctor’s surgeries and healthcare facilities, there are no local public houses and limited employment possibilities. While the proposed Four Marks South Large Development Site seeks to address some of these issues it does not, in any satisfactory way, address the considerable extra vehicle usage that can be expected to descend upon the narrow village roadways and particularly the A31 junctions at Lymington Bottom and Telegraph Lane. And furthermore, the additional traffic, mentioned in point 11 above, along Blackberry Lane and Alton Lane feeding into Telegraph Lane, along the sides of the proposed Four Marks South Large Development Site, will cause some disturbance for walkers along the Pilgrims Way and St. Swithuns Way.

C) Biodiversity and Conservation Objections

14. Four Marks is situated within the Hampshire Downs with much of it covered by the Green Infrastructure Network. It is closely abutting the South Downs National Park as well as having the St. Swithuns Way & Pilgrims Way, historic pilgrimage routes and ancient tracks between Winchester and Canterbury, run along the south side of Four Marks, alongside the near parallel north-east and south-west boundaries of the proposed Four Marks South Large Development Site. Whilst the farmland is classified as Grade 3 Agricultural Land the leaflet titled Four Marks South Large Development Site unaccountably claims, 1) that this is land of “poor quality” and this is not correct, Grades 4 and 5 are for land of poor quality, Grade 3 is land of moderate to good quality agricultural land and 2) that “The area is therefore considered to have limited ecological value.”12 This also is not true, it harbours considerable biodiversity. There are in and over the farmland a variety of common birds as well as green woodpeckers, wagtails and red kites (Milvus milvus) that have full legal protection in the UK under Schedule 1 of the Wildlife and Countryside Act, 198113 and are listed as Near Threatened on the global IUCN Red List of Threatened Species14, see also a Hampshire & Isle of Wight Wildlife Trust publication15.

12 Four Marks South Large Development Site – Leaflet https://www.easthants.gov.uk/sites/default/files/documents/Four%20Marks%20South%20A4%20Leaflet.pdf (accessed 09/10/2018) 13 Wildlife and Countryside Act, 1981 http://www.legislation.gov.uk/ukpga/1981/69/contents (accessed 09/10/2018) 14 The International Union for Conservation of Nature’s (IUCN) Red List of Threatened Species https://www.iucnredlist.org/ (accessed 09/10/2018) 15 Hampshire & Isle of Wight Wildlife Trust https://www.hiwwt.org.uk/wildlife-explorer/birds/birds-prey/red-kite (accessed 09/10/2018)

8 15 Red Kites are regularly seen feeding over the farmland just south of the Four Marks Settlement boundary. Other animals and insects are found to live in and on the farmland to the south of Four Marks, and these include dormice, badgers, rabbits, deer, butterflies and bees amongst others. The creation of the proposed Four Marks South Large Development Site will undoubtedly destroy this wildlife and will certainly affect the red kite, a legally protected species. In addition, these errors that have been found in the published and widely distributed Four Marks South Large Development Site Leaflet lead one to suspect that there may well be a number of other proposed facts presented here that are either economical with the truth or just plain incorrect. (See also the number of dwellings error considered in point 26)

16 The leaflet titled Four Marks South Large Development Site also claims “...opportunities to enhance flora and fauna as part of a site-wide approach to open space and biodiversity”. The developers of the proposed Four Marks South Large Development Site will be unable to maintain or replace most of the existing flora and fauna once the development is completed, and they certainly have not shown where, what and how they will do this, and how they will exploit the so called ‘…opportunities’. Of particular interest to some of Four Marks’ inhabitants was the discovery of the Violet Helleborine [Epipactis Purpurata] a rare orchid in Four Marks in and around Telegraph Lane, Alton Lane and Blackberry Lane, and they have been noted on the rare plants register16. Since Four Marks is considered a hot spot for this rare orchid17, it seems entirely possible that these rare orchids also exist in the area bounded by these three lanes, and this area equates to the proposed Four Marks South Large Development Site. Construction of the proposed Four Marks South Large Development Site will reduce or remove the existing farmland biodiversity and maybe a rare orchid species.

D) Other Development Plans, Additional Comments and Objections

17 The Neighbourhood Plan2 is primarily about ‘spatial policy’ or land use and in this plan, it was proposed, and quite extensively discussed as Policy 6, that there should be a Railway Station Hub development in Four Marks and that this was strongly supported by 75% of those who commented on the proposal. Although the number of households in this proposed development would be less than 600, it, together with several of the other sites shown in the Policies Map Draft Local Plan 2017-20363, would provide a significant number of new household in Four Marks that would obviate the desecration of good quality agricultural land that would be required for the proposed Four Marks South Large Development Site; land that forms part of the rural landscape of Four Marks. Why does the Railway Station Hub proposal outlined in the Neighbourhood Plan 2015-2028, not now appear as a reasonably Large Development Site for all the good reasons cited in the 2015-28 Neighbourhood plan? Was this, perhaps, because it was not suitable or convenient for a consortium of large-scale developers, but rather that it suits smaller developers and local housebuilding companies that are less able to form a consortium capable of addressing the East Hampshire District Council’s request for a large development site?

18 Compared with most of the other 10 proposed Large Development Sites except for those in South Medstead, the Four Marks South Large Development Site consists of a real hotchpotch of pieces of land that have been scrambled together to construct a large infilled site, the land for which is to be acquired from a variety of different landowners, by five different developers, and therefore the site has necessarily been brought together with a totally irregular formation. It is a fact that the largest of the four disconnected pieces of land that make up the proposed Four Marks South Large Development Site consists of about 17 pieces of land with round about 70 linear site edges around its periphery, rather than

16 Wildlife Support & Conservation http://wildlifesupportandconservation.org/violet-helleborine-rare-orchid/ (accessed 09/10/2018) 17 Newsletter of the Hampshire & Isle of Wight Wildlife Trust’s Flora Group https://www.hantsplants.org.uk/docs/Flora%20News%20Autumn%202012.pdf (accessed 09/10/2018)

9 the more normal 4 to 10 linear sides or arcs to a site periphery. Just go and look carefully at the higgledy- piggledy outline map of the proposed Four Marks South Large Development Site shown in the Large Development Sites Consultation Local Plan 2017-203618 and make up your own mind about this abomination of a design skirting around all the various existing properties bordering the Site between Blackberry Lane and Alton Lane. In fact, the proposed Four Marks South Large Development Site can be considered to be just one huge infill between Blackberry Lane and Alton Lane. Several documents, cited in section A) above, have indicated that infill on this scale for the proposed Four Marks South Large Development Site is both inappropriate and not normally permitted.

19 10 Large Development sites is a nice round number. Why not 3 or 5 or 15 or 20 or more? It seems that the East Hampshire District Council has plumped for 10 because it is large enough and round enough to satisfy all future enquiries about the effort it has made to find a suitable Large Development Site, while not being so small as to be dismissed as an unsatisfactory endeavour by the Council to put forward a satisfactory recommendation for Large Development Sites in the East Hampshire District. Or were 10 large sites imposed by Government? It would seem much more appropriate that the Council had done its own homework and research to carefully select three or so of the most reasonable Large Development Site options in the District and then put those out for consultation, rather than engendering the very considerable effort that has had to be put in by a vast number of people, as well as those employed by the Council, in order to facilitate the presentation and consultation on 10 Large Development Sites, several of which may be inappropriate including the Four Marks South Large Development Site, which is totally inappropriate.

20 The proposed Northbrook Park Large Development Site seems to have been considered as an appropriate site for development without significantly affecting the rural countryside and surrounding villages. (No detailed knowledge of this site is in my possession.)

21 The proposed Whitehill & Bordon Large Development Site also seems to have been considered as an appropriate site for development without expressly detracting from the already well-developed local towns. (No detailed knowledge of this site is in my possession.)

22 Similarly, the proposed Large Development Site for the Land South East of Liphook also seems to be an appropriate site for development without diminishing the already mature local town. (No detailed knowledge of this site is in my possession.)

23 And, almost equally, the proposed Chawton Park Large Development Site seems to be reasonably distant from the Alton urban area and may well be an appropriate site for development. (No detailed knowledge of this site is in my possession.)

24 Three, maybe four, of the 10 Large Development Sites would seem to be far more appropriate sites than that at Four Marks South, but of course I would say that wouldn’t I since I live in a house that is adjacent to the proposed Site and my pleasant rural farmland view, the wildlife and the biodiversity will be destroyed if this proposed Four Marks South Large Development Site is approved. But I, like many other inhabitants of properties on the south side of Four Marks, bought their property in the sure knowledge that the Four Marks Settlement Policy Boundary had been supported and confirmed on many occasions and which had been cited in several local and Council documents, including those relating to the comments made in section A) above.

18 Large Development Sites Consultation Local Plan 2017-2036 (Regulation 18) Consultation 3 September – 15 October 2019; p.30 & 39 (East Hampshire District Council, 2019) https://www.easthants.gov.uk/sites/default/files/documents/Large%20sites%20Consultation%20doc%20for%20web_0.pdf (accessed 09/10/2018)

10 25 The Large Development Sites Consultation Local Plan 2017-2036 contained, amongst other things a set of Frequently Asked Questions (FAQs)18 which included: Why are areas that previously had little proposed development (e.g. Four Marks) now being presented with significant development proposals? Among the East Hampshire District Councils’ answers were: a. ….it was generally concluded that services and facilities in this area had not kept pace with recent development, and that further development would exacerbate this. and b. The Council is fully aware of local concern about infrastructure and services in this area, and indeed in many parts of the district. It seems, on the one hand, that the Council has confirmed that the infrastructure for Four Marks had not kept pace with recent development and that the absorption of the proposed Four Marks South Large Development Site would indeed exacerbate this, whilst on the other hand, merely alluding to the so called detailed comments that had been received stating that the evidence base did not justify this position, and that the impact of development from individual sites was negligible. Hence the Council hoped or believed that consultation on the proposed Four Marks South Large Development Site would establish a robust evidence base – all this without disclosing to the public, that were to be involved in the consultation, who it was that provided the so called detailed comments (was it one of the developers of the proposed Four Marks South Large Development Site or an interested party?), or even, and just as importantly, what the so called comments were. Furthermore, if the Council was so fully aware of local concern about infrastructure and services in Four Marks why was it not doing something about it, with or without approval of the proposed Four Marks South Large Development Site? And bear in mind that council tax that is demanded from householders in Four Marks when compared with that of the London Borough of Westminster, for example, where the council tax is very much lower at just 35% of that in Four Marks for a band D property.19

26 If you were to carefully study the map titled What is being proposed? on the third page of the Four Marks South, EHDC Large Development Sites, Public Consultation document20 (or the leaflet shown as reference 12), you would find that the developers map does not show 800 homes but merely 427 homes, and this allows for counting, as houses, what appears on the map to be tiny squares that may in fact be supposed to be garages (see Appendix I). Maybe the developers would claim this map to be an illustrative example, nevertheless squeezing 800 homes, or dwellings as the developers call them, into the area shown on the map would require there to be nearly twice as many dwellings shown on the map than the developers have actually indicated. A more realistic consideration of the proposed Four Marks South Large Development Site would show you that perhaps 250 to 300 houses of a moderate size could be constructed on the land but even then, the gardens could not be very large; however, the housing density would then be much lower at around 15 dwellings per hectare. If you don’t believe me just look at the sizes of the surrounding houses on the aerial photograph of the map and work out how many you could crowd in to the proposed Four Marks South Large Development Site. This seems to be yet another issue on which the developers have mislead us.

27 The developers claim that they will place about 30 dwellings per hectare. The site size is around 25 hectares. (assuming that this is a reasonably accurate indication of the site size provided by the developers), then at 30 dwellings per hectare this would indicate that just 750 dwellings should be built on

19 Council Tax Index 2019/20 (Property Data sourced from https://www.gov.uk/ , the Department for Communities and Local Government). It is also noted that other London Boroughs: Wandsworth, Hammersmith & Fulham, City of London & Kensington & Chelsea, all have band D council taxes below £1,000 with Westminster a £434 https://propertydata.co.uk/council- tax & https://www.telegraph.co.uk/finance/personalfinance/tax/10988691/Council-tax-how-does-your-bill-compare.html (both accessed 09/10/2018) 20 Four Marks South, EHDC Large Development Sites, Public Consultation document https://www.easthants.gov.uk/sites/default/files/documents/Four%20Marks%20South%20Banners%20Reduced%20File%20Size. pdf (accessed 09/10/2018)

11 the proposed Four Marks South Large Development Site. However, these 25 hectares of site also include all the open green spaces, the greenway linkages through the site and all the roadways, so, if we subtract these, which I assess from the developer’s map to cover, maybe, 6 hectares (and I think this may be an understatement), then we are left with 19 hectares of site for the 800 houses and gardens and this now equates to a density of 42 dwellings per hectare. which is quite a high figure for a newly developed site, in a rural area, and built on non-previously developed agricultural land.

28 It would seem that maybe the developers have in mind to build pretty small dwellings and gardens on this land in order to cram in 800 dwellings alongside a suitable green infrastructure with significant areas of open green space and biodiversity enhancement, greenway linkages through the site between Blackberry Lane, Alton Lane and the south west of the development, as well as all the other offerings they have made in the Public Consultation document, and these in addition to other significant requirements that will undoubtedly be demanded of them. Furthermore, if the developers should get the go ahead for the proposed Four Marks South Large Development Site, we might expect that in order to meet the target of 800 or more dwellings, they will ‘unexpectedly’ need to reduce the strongly promoted and necessary green space and linkages. Is all of this a tall order for the developers or a tall story? The proposed Four Marks South Large Development Site is inappropriate and will provide an enclave that may be more closely associated with a city suburban estate and this is considered to be out of keeping with the interests of the Four Marks village.

29 A rough calculation: the population of Four Marks at the 2011 census was 3,983. I do not know the current population of the village, but it is going to be greater than 4,000 and maybe as much as 5,000 residents, when one considers the substantial number of houses that have been built in the village during the past eight years; so let’s say that the current population of Four Marks is around 4,800. The proposed Four Marks South Large Development Site, we are told, will contain 800 houses. The average household size in the UK today is 2.4 people. If we apply this average number of people per household to the new site, then the population of the new site will be 1,920 people, representing a 40% growth in the size of the population of Four Marks village, without including any natural growth of the village population that may also occur over the period. How, you may ask, is our already depleted infrastructure going to cope? This calculation may not be exactly correct but it does show that our village is going to be under very considerable infrastructural pressure if the proposed Four Marks South Large Development Site is approved and permitted to go ahead. Recall that the East Hampshire District Council already acknowledges that infrastructure to support a sustainable community has failed to keep pace with housing developments and that this will be further exacerbated by the proposed Four Marks South Large Development Site.18

This proposed Four Marks South Large Development Site really must not be approved and permitted to go ahead.

12 Appendix I