From: Bethan Wallington Sent: 30 November 2017 12:22 To: DevelopmentControl Subject: FW: Motorway Service Area at Junction 6 M3 - 17/03487/FUL Attachments: Winslade Response A - General comments and objections.pdf; Winslade Response B - Analysis of Moto Planning Statement.pdf; Winslade Response C - Highway Safety, Traffic Impact and Need.pdf; Winslade Response D - Useof access off Dickens Lane.pdf
From: John Raymond [mailto:[email protected]] Sent: 30 November 2017 10:52 To: Bethan Wallington
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Dear Bethan As requested and further to our telephone conversation this morning, I am resending the submission from Winslade Parish Meeting concerning the M3 J6 Moto MSA application as one e-mail. Please see below and attached. On 23rd November these comments were submitted as five separate e-mails, four e-mails from me and one from our Transport Consultant, Simon Tucker, of David Thomas Associates. He was submitting Response C attached direct. Thank you for agreeing to ensure these responses do not appear duplicated on the B&DBC Planning web-site. Kind regards John Raymond for Winslade Parish Meeting From: John Raymond Sent: 23 November 2017 14:41 To: '[email protected]'
2 Basingstoke and Deane Borough Council
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL
RESPONSE A: GENERAL COMMENTS AND OBJECTIONS
Winslade Parish Meeting in association with Home Farm Hackwood residents
Prepared by Edward Dawson Planning Advisor 23 November 2017
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 1
Contents
Background 3
Principle of Development 3
Nature of the Site 4
Concept of Sustainability 4
Unsustainable Site 5
Relationship to Basingstoke 5
Loss of Wildlife and Biodiversity 6
Quality of Design and appearance 6
Impact on Heritage 7
Landscape and Visual Intrusion 7
Effect on Local Highways 8
Water Resources and Drainage 8
Loss of Quality Agricultural Land 9
Conclusions 10
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 2 Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents
Background These comments and objections are made on the application from Moto Hospitality for a Motorway Service Area proposed for junction 6 on the M3 at Basingstoke. They are made by the Winslade Parish Meeting in association with Home Farm residents, within the estate of Hackwood Park. This submission is made to fit the statutory period for public consultation on application 17/03487/FUL as lodged with the planning authority at Basingstoke and Deane. It is intended as an initial or preliminary response, and will be followed by more detailed commentary in amplification, and with further material points.
The Winslade and Home Farm Group is concerned at the promotion of this scheme, which is not required, and which appears to have little or no support in the local area. The possible need or advantages of a new facility are strongly outweighed by the harm that would be caused. The transport and safety implications of a major service area on a busy road junction, and the entry point to the town of Basingstoke, are considerable, and unlikely to be resolved in the short or medium term.
The proposal in an unspoilt rural area to the south of the town is a threat to the character of the countryside and is unwelcome either by those in town or country. Its proximity to a major historic building and heritage feature of great significance makes the proposal wholly unacceptable.
Principle of Development The Group is opposed to the principle of development at junction 6. It does not believe that the location is suitable, or acceptable as a major service station site. The National Planning Policy Framework presumption in favour of sustainable development is much generalised and cannot be advanced in its favour without greater underpinning. It should be examined in relation to the site and its wider effects. It can be demonstrated that this site is inappropriate for such commercial use as a result of this application.
This application is controversial and has aroused much public opposition. There are many written objections. These come as much from the urban side as from the rural. The concern is with potential damage to historic heritage and countryside character, as with the need for the town to determine its own course free from undue commercial pressures. A lack of local infrastructure capacity and overall justification works against accepting the principle of development in this case. The NPPF does not specify where development is acceptable or desirable.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 3 The principle of major development at this juncture and within this particular context and location is not strategically justified. It essentially represents an outside imposition, which is wholly unacceptable. The reluctance of existing residents to accept it is understandable, and they have made sustained and strongly felt objections. There has been no attempt at ensuring a welcome for this scheme. The level of consultation has been poor and inadequate. Such debate as there has been in the town has been focused on the lack of need and confusion as to the wider purpose. At no point has the principle of development been accepted by the community, or any view taken as to be value of this site being developed.
A greater understanding is required of the presumption of sustainability, the quality of life and the validity of assumptions made by the proposer. The Group considers that these uncertainties should carry considerable weight against these proposals.
Nature of the Site The application site is remote by any standards, and rarely visited by local people. This is because motorists use the roundabout to access the town with little thought as to the surrounding area. The existence of the common and the plantation nearby are of course attractions for families and visitors alike. The greater area, remote though it may be, is still of value to the community. It provides an open rural setting to the south, and any encroachment would be highly detrimental to all local communities.
This site is promoted as an add-on of development, in an area already experiencing growth over many years. It is not promoted as any kind of sustainable extension to the town itself, either as an effective way of adding to the existing community, or as an acceptable method of securing additional new facilities. It does not make use of previously developed land in an urban area. It does not have the potential to make best use of existing facilities and services, or reduce the need to travel.
The proposed services are not within walking distance of existing facilities, such as local shops, or within easy cycling distance of the town centre. They are purely for car borne use. The size of the scheme, its weak relationship with the existing urban area and the poor potential to gain access through existing areas may diminish the opportunities for improved public transport, and facilities for walking and cycling. Thus the Group criticisms of these aspects of sustainability are well-founded, and widely considered throughout the communities.
Concept of Sustainability Clarity is needed as regards the approach taken towards sustainable development. The definition in the NPPF can be applied to show the lack of sustainability. The definition should cover economic, environmental and social criteria, and have a long-term value.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 4 Sustainability is now a central part of the planning system. The Government is committed to the principles of sustainable development, as set out in the UK Sustainable Development Strategy. This recognises the important role of the planning system in regulating the development and use of land in the public interest. There are a large number of definitions of sustainability, but in essence, it means that the sum total of decisions in the planning field, as elsewhere, should not deny future generations the best of today’s environment.
The contribution of the planning system to achieving sustainable development includes conserving the historic environment, such as in designated areas. It is fundamental to policies for environmental stewardship that there should be effective recognition and protection for the historic environment. These valuable aspects of the past feature significantly in the locality around Hackwood Park. Those elements identified as being of historic importance are to be valued and protected for their own sake, as a central part of our cultural heritage.
Unsustainable Site The site cannot be regarded as sustainable in itself. It is adjacent to but separate from the town. It would be newly built development, without effective regard to its relationship to the town or village settlements. All development should contribute to sustainability and this scheme does not. Protecting the historic heritage and stock of natural resources are essential components of sustainability. Greenfield sites must be avoided if at all possible. South of junction 6 is an open, greenfield location of local environmental importance. It represents a distinctive landscape of interest, quality and significance. The overall benefits of sustainability need to be more widely understood and better integrated.
It would be important to seek to define more closely the meaning of sustainable development, and its application in relation to the use of resources, landscape heritage and the loss of a significant greenfield site. Development at this site would be destructive of valuable open countryside and add pressure to travel patterns, thereby failing several tests of sustainability.
Relationship to Basingstoke The proposals are poorly related to the built-up areas of Basingstoke. They do not form a natural relationship to the town. If this were to become a destination for shopping or leisure activity then it would be out of keeping. Furthermore, it would draw business and trade from the town centre, where it is most needed. Retention of the town centre function has long been an objective of the borough and many plans have been prepared over the years to achieve this. Accepting a remote attraction, would have a detrimental effect on the town, resulting in expansion of the town outside the Local Plan, without adding character or creating an attractive and desirable location for residents or visitors.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 5 Basingstoke is an ‘expanded’ town, and has grown over the past 50 years. While the urban area has expanded, the rural area has remained the greater part of the borough. The smaller towns and villages make up much of the character of the area, which has accepted growth and become prosperous. It contains settled communities a distinctive way of life. It is more than a commuter belt, but a living and distinctive locality.
The introduction of an oversized motorway service facility on the outer fringes of the town does not sit well in this location. Local people look to the town centre for facilities, and this has long been recognised by the borough council. Some local families have lived within the community for successive generations. People who reside in the villages believe in maintaining their integrity and separation from the urban town of Basingstoke. However, they also appreciate the value of the town and its excellent facilities. They wish to see these enhanced and improved for all generations to enjoy. None wish to see this jeopardised by peripheral haphazard development which is of no relevance to their lives and of no value to any generation, that is intended only to serve the passing motorist with no interest in Basingstoke.
They are opposed to any significant development that would result in the loss of this vibrant unique spirit and urban rural mix. They are actively opposed to the provision of new service areas that would put at risk the aims and aspirations of the borough.
Loss of Wildlife and Biodiversity This is an area of sensitivity for biodiversity and wildlife. The existence of nearby ancient woodland is not apparently recognised. The Crabtree Plantation was once part of the Hackwood Estate and of considerable historic importance, as seen in the classical Bolton Arch, through which lies the main entrance to Crabtree. It was severed by the construction of the M3, but retains a natural connection to Hackwood and its ecology. Encroaching urban influences have taken their toll, and a further service station would only worsen this effect, and damage its valuable wildlife.
The existence of uncommon butterfly species relates to the survival of many mature elm specimens. The Crabtree Elms deserve a measure of protection as part of an historic piece of woodland dating back centuries. These areas and their associated watery environment around the motorway junction have suffered neglect and maltreatment, and require a better understanding and recognition of their importance. A new service area on the junction can only increase the level or urban influence and effluent flow.
Quality of Design and appearance The importance of good design and overall visual appearance is increasingly recognised. The design and style employed in this instance is of a low standard and quality, and indifferent grade. Poor quality build has long been a factor in service station construction and this adds to the problem.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 6 Some service stations are hidden within former conifer plantations, such as at Fleet. Others may have an urban or industrial setting or nondescript background. Layout and screening is often weak. Landscaping is of a standard type, often using non-native fast growing species that either never mature or die off quickly. This site has remained in rural use for many years and it is difficult to see how it might be made to fit it, or even enhance the setting. No quantity of planting would improve the views from Basingstoke Common, the Crabtree Plantation or areas to the south. The intrinsic beauty and character of natural areas would be adversely affected by a service station advancing upon the town’s southern flank.
Impact on Heritage This location has considerable heritage value, as part of the historic landscape of the area. Historic environments should be respected, and where possible enhanced. The value of listed buildings at Hackwood Park and their rural setting is also not fully recognised, and the public attaches importance to these elements.
The proposed site, immediately south of junction 6, is within the vicinity of the historic Hackwood Estate. Hackwood House is a 17th century mansion of considerable merit and architectural distinction. Its links with the Duke of Bolton; Lord Curzon, after being Viceroy of India; and with Viscount Camrose, noted press baron, are part of the history of Basingstoke. Even if sited north of Dickens Lane, the MSA is still within part of the original estate holdings. There would also be impact on the Hackwood Racecourse area as part of the Grade 1 Registered Park.
Greater recognition is now given to settings of heritage assets. The presence of a manor of ancient vintage is significant. The community has long attached value to the survival of the Grade I Registered Park and garden intact. It is an integral part of the heritage asset, and cannot be swept aside for commercial reasons. There is concern about glaring and intrusive light pollution in the historic parkland and its effect on wildlife in ancient woodland. Land extending south of the motorway is of value though not at present enjoying a designated or protected status.
Landscape and Visual Intrusion There is bound to be significant visual and physical intrusion into open countryside from the MSA. The topography of the site is well-recognised and this has been noted as having a quiet unspoilt rural character in the Borough Landscape Assessment: Main Report by Landscape Design Associates, June 2001. These proposals would result in an intrusive development that would impinge badly on a rural landscape.
The retention of open countryside that surrounds Basingstoke has been seen as of key importance by successive local plan inspectors. It is a vital element of the character of the local area, particularly in relation to protecting the nature of the rural area. This is provided for in the National Planning Policy Framework; Policy C4 of the South East Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 7 Plan Regional Spatial Strategy, and Policy EM1 of the Adopted Local Plan 2011-2019. The present application is contrary to these provisions.
It makes clear that proposals are to be sympathetic to the character and visual quality of the area concerned. Development proposals must also respect, enhance and not be detrimental to the character or visual amenity of the landscape. The proposed MSA would damage the visual amenity and scenic quality of the area. It would disregard the high value placed upon retention of the views out of the town to the south, across the area proposed for development. The BDBC Landscape Study of 2010 is relevant.
Effect on Local Highways There is wide public concern about the impact of this development on the local road system. Unexpected and unplanned development schemes such as this will have unpredictable consequences. Existing problems will be exacerbated by this proposal.
Local traffic surveys are needed, and it is thought traffic flow will be twice that estimated in the proposals. Traffic volumes on main and local routes may be unsupportable on the existing road network and beyond the strategic road network. The current local road system was found to be inadequate, and led to the redevelopment of the entire Black Dam Roundabout in 2015. The existing road usage, including by HGVs, is heavy, especially so in the evenings and at weekends.
Traffic in the surrounding area, especially so during rush hours, is particularly heavy impacting not only roads in the local area, but also major local routes such as the A33. Any proposals by the applicant, via Section 106 funding, to improve local junctions in the area will not increase the overall highway capacity. It is difficult to see additional spending of any Section 106 funding helping to improve the situation.
Water Resources and Drainage There are particular issues regarding the supply of water resources and waste water treatment capacity. These have been known over many years, and long regarded as an impediment to development. As they remain unresolved, they are an important material consideration. Parts of the site may also have surface water drainage problems.
This development would require additional groundwater abstraction for drinking water, or new piped supply from other parts of the borough. South East Water holds licences to abstract water from the Basingstoke Chalk aquifer, but the pumping station that supplies water to Basingstoke already operates at 97 per cent of its licensed capacity in order to meet current demand. It is likely this proposal would cause considerable pressure both to the supply situation and to the drainage needs.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 8
The presence of headwaters of the River Loddon at junction 6 produced a significant conflict to this proposal. The South East River Basin Management Plan (updated December 2015) makes it clear that the quality of water from these aquifers does not reach good status. This is also confirmed by the Thames River Basin Management Plan, which makes reference to pollution caused by nitrates in the chalk aquifers resulting in nitrate levels in drinking water that exceed the drinking water standard. Pollution from waste water affects 40 per cent of water bodies in this river basin district. Rising nitrate levels have been found in borehole samples of local aquifer water, which has resulted in the Environment Agency declaring a Nitrogen Vulnerable Zone covering the area of Basingstoke and its surrounds.
Thames Water has made submissions to Basingstoke and Deane about their concerns in relation to certain parts of the borough, including to the south. They have concerns about the lack of overall sewerage capacity. They also believe that Sustainable Drainage Systems are not always appropriate (because of high water tables) and that to improve sewerage capacity they need a lead time (which could be 5-10 years) and for which there is no current provision.
Loss of Quality Agricultural Land This site contains productive farmland. The retention of good quality farmland has always been an objective of the planning system. This proposal would result in a significant loss of Grade 2 and 3a quality agricultural land. Productive agricultural land is an asset of national significance and is accorded importance by the public. This matter has not been given sufficient weight. It should form part of the reasons for rejection of this proposal.
It has long been national policy to protect agricultural land from development. This is defined as the ‘best and most versatile’ (BMV) agricultural land, and policies are included in the NPPF. Land graded as 1, 2 and 3a, is the most important from a planning viewpoint. It is described as the most flexible, productive and efficient in response to inputs. Once agricultural land is developed its return to best quality agricultural use is seldom practical. Development of BVM agricultural land should not be permitted unless opportunities have been assessed for accommodating development needs on poorer quality farmland.
The quality of agricultural land is determined through a system of classification devised by MAFF back in the 1960s. This Agricultural Land Classification system assesses the physical and chemical characteristics that impose limitations on food production. Land is divided into 5 grades. Grade 1 is the highest and grade 5 the lowest. Later survey work revealed that about half the agricultural land in England and Wales was grade 3. A refinement of the system was needed and this was introduced in 1978, sub-dividing grade 3 into 3a, 3b and 3c. A further review introduced more emphasis on the Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 9 environmental conditions, such as gradient, depth and stoniness, and less on the productive capability resulting from fertiliser inputs. The status of the land needs to be confirmed with the aid of Natural England. Due weight should be given to this aspect when calculating the overall planning balance.
Conclusions There is no support to be found for this scheme in any regional or local plan. The borough council local plan (2016) is silent on the subject, and it is a matter of public interest. The Adopted Local Plan acknowledges and appreciates the nature of rural areas south of the main urban area, particularly the distinctive nature of its unspoilt character and location. There may be scope for enhancement of these existing landscape features, not fully considered. The land south of Basingstoke should be regarded as part of the setting of the town and its essential gateway with some level of protection afforded. These proposals should not undermine the principle and approach.
Potential damage and detrimental effect on the rural area is completely unacceptable. Demonstrable harm to the aim of safeguarding the ‘best and most versatile’ agricultural land is clear. Such a major development, as proposed, is unacceptable to the community and would harm the identity of the borough, and its potential implications. Overall, junction 6 is an inappropriate site for the development proposed. We consider that material harm would outweigh any development advantage in the short term.
These proposals represent a significant challenge to local opinion within the Borough of Basingstoke. They also fly in the face of a more sustainable and community-led planning system. The Group believes the application should be dismissed at this time, as unwelcome and unsustainable, and a massive intrusion and encumbrance in the landscape. It will provide further information and commentary in due course.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE A: GENERAL COMMENTS AND OBJECTIONS Winslade Parish Meeting in association with Home Farm Hackwood residents 10 Basingstoke and Deane Borough Council
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL
RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT
Winslade Parish Meeting in association with Home Farm Hackwood residents
Prepared by Edward Dawson Planning Advisor 23 November 2017
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 1
Contents
Overview 3
Background to motorway services 3
Stations planned but never built 3
Impetus for Basingstoke 4
Misjudged application 5
Need for an MSA 5
Site description and surrounding area 6
Proposed Basingstoke MSA 6
Development Plan, national and other policy 7
Planning Assessment 8
Conclusions 9
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 2
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents
Overview Moto submitted a Planning Statement to accompany its application 17/03487/FUL to develop a motorway service station at Junction 6 on the M3 at Basingstoke. It is a full application, and said to contain all the appropriate and necessary detail to enable the Council to make a proper determination. In so doing, it should have the certainty that the package of information is complete. This response considers the information and material supplied, and should be read together with the Winslade Group’s formal objections and comments submission.
Background to motorway services The introduction to the Planning Statement contains a summary of the background to MSAs in England. This is a bland and selective narration and suggests MSAs have had a straight forward history without concern from councils, and without opposition from the public. The development of the sector has led to near monopoly situations emerging, with familiar old names like Blue Boar and Take a Break disappearing. Mergers and acquisitions have resulted in most service areas now owned by three mega groups: Moto, Welcome Break and Roadchef.
While the early MSAs were disagreeable places where few stopped for long, they have become more sophisticated and alluring. People no longer stop just to use the public conveniences, but to buy over-priced food and coffee. Questions of cleanliness and pricing remain public issues, as revealed in surveys by the AA. Surveys consider road safety, facilities, food, shopping, pricing and hygiene, and frequently raise grave concerns about some of the services offered.
Food at service stations has often been criticised in the media for being at once expensive and of indifferent quality. Many also have the most highly priced petrol and diesel to fill vehicle fuel tanks. Yet others are criticised for poor signposting, a lack of outdoor facilities and unclean toilets. Visitor feedback can be graphic, with customers describing having ‘entered into a time warp’, with drab colours and stalls of remaindered poor quality books and outdoor clothing. Continental service stations are frequently regarded as superior to British ones.
Stations planned but never built Planning for service stations has for the most part been either non-existent or sporadic. Applications come out of the blue, and many never proceed. The ‘Basingstoke Services’ was proposed at J7 by Granada in 1995 following completion of the M3, which
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 3
created a continuous road between Basingstoke and Southampton with no services. The design would have been very similar to that of Stafford (North), with a hexagonal amenity building and adjoining lodge. There would have been parking for 539 cars, 42 HGVs, 12 coaches and 10 caravans.
The site would have been in the north-western corner of the junction, with the entrance being on the A30 spur road and exit leading back to the main roundabout. The application was refused mainly because of concerns about the additional traffic (this was one of the quietest junctions on the M3, with no plans to upgrade it) and because the Winchester services were put forward at the same time and the council preferred that, even though it would not serve the A303.
‘Kempshott services’ was planned on the M3 between J6 and J7. These services would have been just before the A303 to Exeter splits from the Southampton road. There are four 'ghost slips' and two clearly-shaped fields. The Observer Road Atlas of 1976 has the services marked as open but unnamed. It is one of the 'original three' services planned for the M3, along with Fleet and Trumps Green. The idea was that Trumps Green and Kempshott would open first, with Fleet opening later. All three were subject to a difficult planning process, and at Kempshott several alternative sites were examined, including one at Andwell.
Two proposals to run the services were received, but both the Planning Authority and the Landscape Advisory Sub Committee felt that they did not do the location justice, so they re-opened it to new tenders. There was little interest, and with Trumps Green struggling to pass a public inquiry, the plans were changed and the Ministry accepted Fleet would do the job.
Impetus for Basingstoke One problem with Kempshott was a lack of space: the next junction to the east is three miles away, west is one mile away and the one after that heading west is two miles away. Fleet, which until recently was the only service station on the M3, is located 13 miles from Kempshott. In some respects this was the perfect place to serve traffic before the routes split. Rear access would have been provided to Beggarwood Lane, still currently in use as a farm access.
In September 2016, Applegreen, an Irish-based group, made a surprising announcement, that they wanted a new service area to be built at Kempshott. Talks were ongoing. Applegreen are keen to break into the UK market, but the decision to use a crowded section of the M3 was an odd one. They would face objections on traffic grounds, and allegations that their plans for a small site would only take traffic away from more capable facilities.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 4
It was not clear whether Moto's decision was related to the Applegreen plans, but was thought related to Moto's recent announcement of a development at Rugby. With some eight years since Moto opened any wholly new services, industry concerns were immediately raised about the need for the MSA, and the suitability of the site.
Misjudged application The Moto Planning Statement attempts to justify the application, and the need for an additional facility on the M3. It quotes Department for Transport Circular 02/2013 The Strategic Road Network and the Delivery of Sustainable Development. This includes the point that a good ‘road network enables growth by providing safe and reliable journeys’, and roadside facilities are there ‘to support the safety and welfare of the road user’. These are generalised points which few would oppose, but do not indicate where facilities are located. It quotes Highways England recommending the maximum distance between MSAs being no more than 28 miles apart.
Motorists do not stop at every station. If stopping places are for the benefit of road users, then their stated views are to be taken into account. It is a simple fact that motorists driving between Fleet and Winchester find the distance acceptable, with no requests for more stopping points made to the county council or to elected local members. We conclude from this that the need for an infill station between Fleet and Winchester is purely speculative and unrelated to road safety considerations. The statement suggests planning authorities should consider only distances in relation to road safety, and not seek to thwart commercial competition. While these may be normal sentiments, they could be held to suggest a specific course that does not exist.
Need for an MSA The basis of need for an MSA is said to be related to the needs of safety and welfare. Moto suggests a gap in the MSA network may exist irrespective of the spacing of existing stopping places. They also contend that it is for the private sector to promote MSAs through the planning system. However, they fail to recognise that the planning system has two streams, resolving planning applications and setting out plans for the future. While the Development Control system will be well used to dealing with speculative applications, the forward planning system, through the local plan, would expect to plan ahead for required infrastructure. No suggestions of the need or desire for additional facilities on the M3 motorway were made to the recent review of the now adopted Basingstoke Local Plan 2011-2029. No one from Moto attended the public inquiry in 2016 to review or advance the case for an MSA.
The issues of infrastructure were thoroughly considered at the inquiry before a planning inspector. Moto goes on to say that the distance between existing MSAs are both
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 5
‘within and outwith’ the Government’s maximum distance between MSAs of 28 miles. In view of this, Moto claims that a case exists for an infill MSA in accordance with Circular 02/2013. In reality, there can be no case without some form of planning in a land use and highways context. Such forward planning would normally extend to public consultation of all options. Only at that stage would the private sector be able to promote new facilities. It can be concluded that there is no policy basis or public support for a new MSA at J6 on the M3. Furthermore, no examination of the background and policy issues has been undertaken with all parties able to contribute.
Site description and surrounding area The description of the site confirms the development area as just over 15 hectares, within an application site of 21 hectares. It also confirms the rising nature of the land towards the Oaken Plantation. This topography shows the land rising from the west to east across the site. The Plantation is held to form a natural backdrop to the proposed MSA buildings. Such mature landscape features are however, best seen in their true context and in the evolution of the countryside.
The PS states that the nearby villages of Tunworth, Upton Grey and Herriard lie some distance away from site. Despite this, the urbanising influence and social impact is likely to be significant and they fail to mention the Winslade community of listed properties at Hackwood Home Farm. The attractiveness of these small village settlements to the urban population of Basingstoke is considerable for reasons of tourism and rural refreshment.
Agricultural land is found on the western side, with the Oaken Plantation to the east, and the Crabtree Nature Reserve to the north. The main urban area of Basingstoke lies northwest, with residential neighbourhoods, resulting from expansion during the development era of the 1960s. The screening of fences and trees and goes a little way to offset the impact of a major road, with its containment effect, noise disturbance and reduced air quality. Grades of farm land in arable use are noted, with no trees or buildings, but with some woodland to the north and east.
Proposed Basingstoke MSA Access from the motorway is an important issue both in terms of public safety and amenity. The proposal allows for a single new slip road and vehicular access point from the south side. Questions of highway safely and avoidance of conflicts will need to be carefully assessed by the Highway Authority, especially during periods of congestion and in the initial novelty value of any new facility. Other highway improvements are suggested as part of the overall planning offer.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 6
The service area operators plan a two-storey Amenity Building over 9 metres in height and west-facing, with external cladding and some seating areas. A number of food kiosks are included, and the experience of such kiosks is often open to question. Repeated surveys have found the food to be over-priced and the cleanliness poor. The normal requirement of free toilet and hand washing facilities will be met, with showers for lorry drivers. A familiar assortment of food and other retailers is offered in this scheme, with seating and an adult gaming centre.
A lodge building is planned to the north of the site, and close to the plantation area. It has 100 bedrooms divided between standard and family accommodation. It is two storeys high and may become an overpowering structure, though it is said to be lower that the tree canopy of the Oaken Plantation. The roof level is over 7 metres from ground level at its highest point. The drive-thru coffee house is single storey, but the 18-pump fuel-filling station will have a canopy and lighting which will have a significant visual impact and across the site and beyond.
The design proposals are set out in a separate Design and Access Statement. The principles are said to include a uniform and consistent visual appearance across all main buildings. This may inspire little confidence given the experience most people have of such structures. While the external appearance of these service areas has failed to improve significantly over the years, they have been conditioned by a culture of utility and opportunism. Public resistance and even hostility to the proposed new facilities is not surprising. It is born of bitter experience and will add to the lack of empathy and a desire to see the proposals refused.
Development Plan, national and other policy The Development Plan is the Adopted Local Plan 2011 to 2029, which is silent on the question of further MSAs on the M3. Under the Use Classes Order, the proposed change of use would be classed as ‘Sue Generis’, or as unconventional and undefined. In the absence of identification in the ALP, the development control system can only rely on relevant ‘material considerations’ and the concept of sustainable development.
Sustainability was originally an environmental concept to which social and economic elements have been added. While the Moto PS suggests all such criteria are met, the economic benefits blatantly are marginal, the social impact on the community is ignored, and the environmental effect is to destroy valuable farmland and damage Basingstoke’s heritage. The Moto statement makes no mention of local infrastructure delivery plans. They seem unaware of the Basingstoke Infrastructure and Delivery Plan (IDP), produced as a supporting document for the evidence base informing the Local Plan and
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 7
the spatial policies included. It allows partners and service providers to identify issues and priorities as part of an integrated approach to planning and infrastructure provision.
The IDP involved detailed appraisals of many Strategies and Reports commissioned. It also covered the outcome of meetings and workshops with key partners and service providers. These enabled essential priorities to be identified and infrastructure needs examined. The IDP details infrastructure requirements to 2029, but focuses on measures needed in the first phases of plan. The IDP categorises infrastructure as ‘essential’, ‘necessary’ and ‘desirable’. A new MSA would be rated as necessary. While much future provision relates to new housing, past deficiencies, omissions and the need for improvements also plays a role.
The HCC Local Transport Plan (2011 – 2031) sets out measures for delivery which include plans to improve capacity at congestion bottlenecks and optimise management of the highway network. A Transport Statement was developed by HCC in consultation with the borough council for the period to 2027. The Transport Statement links to economic priorities, including those developed by the Enterprise M3 LEP. Local Plan Transport Assessment (2013) has identified the improvements and interventions needed to deliver the Local Plan. None of these assessments identify the need for additional public service areas on the M3.
Planning Assessment The planning assessment section of the Moto PS appears to be primarily a desk exercise. This dismisses every reasonable concern about this future development; every box is ticked in their favour. While space and time limit the extent of commentary possible, it can be noted that the taking of quality agricultural land is disregarded as being a significant issue. This is despite the need to preserve and protect such important resources. Similarly, the impact on the heritage site of Hackwood Park and its Grade 1 registered park and garden is said to be minimal, even though the site borders the Parkland in this open area of unspoilt countryside. This rural area is clearly an amenity of benefit to the whole of the borough.
It is also important to recognise the Basingstoke Local Plan is recent and up-to-date. That means great weight should be attached to it. By contrast, the adjacent district of Hart has a local plan that ran out in 1996, and relies on ‘saved policies’. This is a great credit to the borough and its forward vision. Were an MSA deemed to be required, it would feature in the plan, and does not. Moreover, no partner organisations have noted the need for a new facility.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 8
Conclusions It can be shown that this scheme has commercial backing but little other effective engagement. It is highly speculative and based upon little or no policy support locally, and devoid of public or partner acceptance. There is no support in the Adopted Local Plan, which is referred to bizarrely as ‘emerging’. The scheme is defective and essentially flawed in concept, and will not deliver the overall benefits alleged in the Planning Statement, and instead:
• Disregards all national, regional, and local planning policy aims; • Misreads and flies-in-the face of reasonable sustainability objectives; • Is irrelevant to meeting the safety and welfare needs of the motoring public;
• Diverts jobs away from town centre and adds no value to existing businesses; • Suggests a development of questionable quality not fit for the 21st century; • Proposes a scheme that would have a devastating environmental effect.
The need for an MSA at Basingstoke is neither clear nor compelling. If it were, then some reference or support would be expected in the National Planning Policy Framework, local plan and its associated assessments. There is none, however much the applicant seeks to perform summersaults with the policy. Without policy endorsement, pubic support or benign social impacts, the only conclusion is to request a firm refusal of these illegitimate proposals.
Proposed Motorway Service Area at J6 M3 Application: 17/03487/FUL RESPONSE B: ANALYSIS OF MOTO PLANNING STATEMENT Winslade Parish Meeting in association with Home Farm Hackwood residents 9
david tucker associates t r a n s p o r t p l a n n i n g c o n s u l t a n t s
Ms Lucy Page Basingstoke and Deane Borough Council Forester House, Doctor’s Lane, Henley-in-Arden, Civic Offices Warwickshire B95 5AW London Road Tel: +44(0)1564 793598 Basingstoke Fax: +44(0)1564 793983 Hampshire [email protected] www.dtatransportation.co.uk RG21 4AH
Our Ref: SJT/19478 23rd November 2017
Dear Madam
17/03487/FUL Proposed MSA, M3 J6, Moto Hospitality Ltd Response on Matters of Highway Safety, Traffic Impact and Need On behalf of Winslade Parish Meeting and Residents of Hackwood Home Farm
I act on behalf of Winslade Parish Meeting and residents of Hackwood Home Farm. I write to object to the above planning application in relation to matters of highway safety, traffic impact and need. Other planning matters are also covered on behalf of the same client group by Mr Edward Dawson.
Need
In transport terms, in the addition to the wider planning requirements and NPPF, the planning application should be considered in the context of Circular 02.13 – Published by the Department for Transport. In the case of an MSA development, the Circular sets out that there is a safety case for the provision of MSAs across the network at an appropriate frequency to serve the travelling public. In cases where this is proven, that safety case is generally accepted as providing the fundamental “need” case behind any application and against which the other negative impacts of any development need to be balanced.
In this case, other than general (and in parts erroneous) interpretation of the Circular the applicant has failed to present any positive evidence to support the case for the proposals. In short there is no gap in provision at this location. The Circular is clear that the prime objection is to achieve a network of 30 minutes / 28 miles. That is described thus:
B4. Motorway service areas and other roadside facilities perform an important road safety function by providing opportunities for the travelling public to stop and take a break in the
Continued/. . . DTA Transportation Limited - Registered Office: The Station, Wilmcote, Stratford-upon-Avon, CV37 9UP Registered in England & Wales No. 5305640 . . ./2 Basingstoke and Deane Borough Council SJT/19478 23rd November 2017 course of their journey. Government advice is that motorists should stop and take a break of at least 15 minutes every two hours. Drivers of many commercial and public service vehicles are subject to a regime of statutory breaks and other working time restrictions and these facilities assist in compliance with such requirements.
B5. The network of service areas on the strategic road network has been developed on the premise that opportunities to stop are provided at intervals of approximately half an hour. However the timing is not prescriptive as at peak hours, on congested parts of the network, travel between service areas may take longer.
B6. The Highways Agency therefore recommends that the maximum distance between motorway service areas should be no more than 28 miles. The distance between services can be shorter, but to protect the safety and operation of the network, the access/egress arrangements of facilities must comply with the requirements of the Design Manual for Roads and Bridges14 including its provisions in respect of junction separation.
The network in this location both for Motorway traffic and A303 traffic is well served by existing facilities. In particular, the distance between Fleet and Winchester is 24 miles and hence there is no “gap” in provision on this part of the network. Fundamentally therefore the core objective of the Circular to have a network of 28 miles / 30 minutes is already met in this case. There is therefore no justification for providing the MSA to fill any existing deficiency in network frequency provision.
The location could only therefore be considered at as ‘infill site’. Although the concept of ‘infill’ sites does not appear in the current Circular, the previous circular set out the need to demonstrate “clear and compelling need” in such cases. That test must remain an appropriate one in the wider planning context. Regardless of what Para B8 says about LPAs considering need, the LPA must clearly apply appropriate weight to the need case if they are to reach a proper and reasonable decision on the merits and impacts of the application in front of them.
It is accepted that Circular does suggest that MSAs can be located closer together than the 28 mile frequency. However, both the Planning Statement and Transport Assessment erroneously interpret that position as identifying a positive need. It clearly does not. The three circumstances where the Circular does seek to increase the frequency of facilities are set out below:
1) Where vehicle speeds at peak hours on congested parts of the network mean journey times between facilities are more than 30 minutes (Para B5). That is not the case here and therefore there is no “need” arising in that regard.
2) The applicant provides no details of any wider highway safety issue on this link that needs to be addressed and indeed makes reference to the very recent Route Strategy (March 2017) which confirms that overall this section of the M3 performs very well. . . ./3 Basingstoke and Deane Borough Council SJT/19478 23rd November 2017
3) To improve competition between operators (Para B8). In this case both Fleet and Winchester score well in recent surveys of customer satisfaction. Fleet South is undergoing substantial redevelopment and will be significantly improved on opening. There is no identified deficiency in terms of on-site facilities for car or HGV parking levels at either site, and therefore no clear benefit to the travelling public arising from the introduction of further competition.
The TA refers to Para B15 in seeking to justify the provision of an off line / junction MSA. That is irrelevant to the case. Para B15 states that “in circumstances where an on-line service area cannot be delivered due to planning, safety, operational or environmental constraints, a site sharing a common boundary with the highway at a junction with the strategic road network is to be preferred to the continued absence of facilities.” In this case there is no “continued absence” of facilities and there is no need for an MSA be is on or off-line.
On that basis it is clear that the proposed MSA is not required to meet any identified deficiency in the network either in terms of gap, existing safety issues, travelling speeds or user experience. On that basis and in accordance with Para 9 of the Circular and of course the wider provisions of the planning act, no positive benefit should be applied when considering the wider planning balance and merits of the case.
Safety
Having established there is no need for the facility or significant positive safety case, it is necessary to consider the negative impacts of the scheme in terms of traffic generation at J6. The planning balance clearly needs to consider the negative impacts of the increase in traffic at J6 on safety, economic and environmental issues.
The submitted TA confirms that the access arrangements require ‘Departures from Standards’ which have not been processed. At this stage there can therefore be no guarantee that the works can be safely carried out. The absence of any Road Safety Audit in accordance with HD19/15 is a significant omission and clearly needs to be properly reviewed as part of the decision making process.
It is also clear that, as part of that assessment the safety dis-benefits of any Departures need to be properly weighed against any benefits arising from the scheme. For the reasons set out above there are no proven benefits at present.
Traffic Impact
The Transport Assessment submitted with the application demonstrates that J6 will continue to operate over capacity, even with the improvements. Whilst that position may be consistent with an NPPF requirement to mitigate the impact of the development only it is clear that such . . ./4 Basingstoke and Deane Borough Council SJT/19478 23rd November 2017
a scheme runs wholly contrary to the requirements of the Circular, which notes a preference for on-line services which are “more attractive and conducive to encouraging drivers to stop and take a break”.
Although referring to a slightly different point (on –line vs junction sites) the relevance is that a MSA can only ever meet the needs of the public if it is attractive and easily accessible. Planning a scheme where it is accepted at the planning stage that access will be congested is incongruous and wholly counter to the principle of the benefits arising from an MSA. This represents a fundamental contradiction in the Moto planning and transport case.
As a point of detail the submitted Transport Assessment clearly does not take proper account of significant committed growth in the area. Including that growth properly will identify more significant capacity constraints and further affect the position presented. It is fundamental that those issues are properly addressed.
Yours faithfully
Simon Tucker David Tucker Associates
MOTORWAY SERVICE AREA AT JUNCTION 6 M3 REFERENCE: 17/03487/FUL
USE OF ACCESS OFF DICKENS LANE / TUNWORTH ROAD AS A MAIN SITE ENTRANCE.
1. MOTO APPLICATION DOCUMENT: ‘CONSTRUCTION AND ENVIRONMENTAL MANAGEMENT PLAN’:
In the Moto ‘Construction and Environmental Management Plan’, document it says concerning construction access to the MSA site from the rear:
CONSTRUCTION TRAFFIC STRATEGY: Site access: During the early stages of the project a temp road the farm track from Dickens Lane will be used as the access and egress to undertake initial set up and the works required to establish the site access from junction 6 of the M3. Once a site access and egress is established into the motorway junction this will become the primary route for all vehicles servicing the construction of the MSA. The farm track will then provide emergency access only. The forming of these works is estimated to take 10 to 12 weeks but will be subject to agreement with the Highways Agency.
2. THE TUNWORTH ROAD – A DANGEROUS RAT RUN:
The Tunworth Road, otherwise known as Dickens Lane, has the statutory 60mph speed limit which is fully used. It is a rat-run for A339 traffic wishing to reach Old Basing and the A30 eastbound particularly in the rush hour when regular users are in a hurry and may drive too fast.
It is a main access to/from Basingstoke for not only Winslade’s Hackwood residents but also for residents of Tunworth, Polecat and Upton Grey. It also links in with rat-runs through Old Basing.
During the re-design of the Black Dam roundabout, with all the resulting congestion, use of this rat-run increased dramatically. No doubt it will again increase dramatically if the alterations to J6 roundabout proposed in the Moto application cause major traffic delays.
Complaints about inconsiderate, dangerous and fast driving on this lane arise regularly. They have been reported to Hampshire Highways and a reduced speed limit requested.
3. THE SITE ACCESS POINT:
The proposed site entrance is through a farm gate at the bottom of the V of a straight switchback section of Dickens Lane. Coming from the A339, this gateway is on the left-hand side, opposite the entrance to the dozen or so houses forming part of the Hackwood Home Farm community.
Residents already find exiting the driveway to their homes dangerous due to the fast moving traffic up and down this switchback. It is questioned how major slow moving HGVs laden with excavated material will exit onto the lane safely.
The Moto Management Plan states concerning construction traffic movements: The peak heavy vehicle volume will occur during the importation of fill materials for the roads and parking areas and the concurrent removal of subsoil and topsoil. The current estimated volumes are: Subsoil and topsoil removal 45,000m3 Imported engineered fill 40,000m3. Averaged over the predicted construction periods this equates to 95 vehicles per day over a period of approximately 20 weeks. Given there will be peaks and troughs in activity we anticipate a maximum of 120 per day.
Traffic movements during this 20 week period from this proposed site entrance will therefore be considerable.
4. LACK OF CONSULTATION:
Moto has made little attempt to consult more than superficially with Winslade residents living at Hackwood Home Farm. They glossed over these concerns at a Parish Meeting they attended and would make no commitments or listen to local views stating this was a wholly unsuitable location for a major site access. Those presenting on behalf of Moto made us feel that had not actually visited the Tunworth Road. If they had they would have noted that in places this lane has no central white line, and it is in bad repair. It is truly a small country lane with at points no verges. Two cars have difficulty passing in places. It is totally unsuitable for use by lorries in large numbers.
Home Farm residents are concerned they will in future live opposite a cross roads with this back entrance to the MSA site being regularly used for service access, by staff and maybe even clever members of the public. If the council is mindful in the end to approve this application, a pre-condition must bar the use of this access to all traffic other than emergency vehicles or similar. It must have a locked gate across the exit.
Moto has given no indication to residents concerning any of these concerns or even the finish and look of this exit if the MSA is built.
5. HISTORIC 1712 BRIDGE.
As said above concerning consultation we wonder if those who prepared the construction plan have really thought this through and visited the location. Arriving from north or east, the most convenient way to reach this Tunworth Road access gate, avoiding the busy A339 to Alton roundabouts, is by using Huish Lane from the A30 at Old Basing to Polecat Corner, then turning right at Polecat onto the Tunworth Road towards the gates of Hackwood on the A339. Between this turning and the access farm gate the road passes under a low historic bridge.
The bridge shows 14’ 4” clearance. It was damaged recently when an articulated lorry became stuck and forced its way under. A survey reported that structural strengthening work will now be required.
The brick bridge was built in 1716 and carried the main drive to Hackwood Park from the Bolton gate up at Crabtree Plantation off the old A30 to the front of Hackwood House. In 1940 Lord Camrose loaned Hackwood House to the Royal Canadian Army as a hospital and some 16,500 troops were treated there. Interesting detailed carvings by recuperating soldiers from various WW2 allied forces may be seen on the bridge.
The current owner of the structure who lives beside the bridge among the Hackwood Home Farm community reports how increased traffic during and since the diversion resulting from the Black Dam roundabout works, has led to further degradation to the bridge.
If the application is approved with the Tunworth Road farm gate as the site access point, site traffic must be banned from exiting left under the bridge, all should turn right and join the A339 at Hackwood gates even if this means joining the queues of traffic that always back towards Alton for a long way at peak times.
6. THE TUNWORTH ROAD USED BY BICYCLISTS, WALKERS AND HORSE RIDERS
It is well known and clearly advertised that the A339 is one of the more dangerous roads in the county. To avoid the A339 the Tunworth Road is much used by walkers, bicyclist and horse riders:
- walkers taking the circular footpaths leading off the main drive of Hackwood House; - bicyclist on a circuit from the Candovers, passing through Cliddesden, crossing the A339 to pass down Tunworth Road to avoid the A339 and then through to Upton Grey and onto Odiham or Herriard - Horse riders are much in evidence as there are a number of livery stables in the area.
Therefore, the road is an important recreational amenity to locals and should not be used for construction traffic. However careful HGV drivers are and those controlling the construction are, mud will end up on the road which will be a serious hazard for bicyclists travelling fast down the switchback
7. ROAD SAFETY
The Tunworth Road is a narrow country lane unsuitable for major use by construction vehicles. Winslade’s Transport Consultant, Simon Tucker, in his Response C concerning this Moto’a application to B&DBC, points out that Moto’s application lacks the required ‘Road Safety Audit’; also that ‘Departures from Standards’ have not been processed. This would show how Moto understands the works can be carried out safely and where their construction plans may depart from required standards.
We feel certain the use of this Tunworth Road access will be a major consideration in these reports, and we would expect our residents to be fully consulted while evidence for these report is gathered.
8. CONTRARY TO POLICY IN LOCAL PLAN AND RECOMMENDATION OF REFUSAL
The Local Plan 2011-2029 contains the following relevant policies which should be considered when judging the suitability of the use of this access onto the Tunworth Road / Dickens Lane.
Policy CN9 – Transport: The council will work in partnership to promote a safe, efficient and convenient transport system which will: ii) Promote transport choice, through improvements to public transport services and supporting infrastructure, and providing coherent and direct cycling and walking networks to provide a genuine alternative to the car and facilitate a modal shift. Development will be permitted where it: e) Does not have a severe impact on the operation, safety or accessibility to the local or strategic highway networks;
Policy EP4 – Rural Economy: All development proposals must be well designed and of a use and scale that is appropriate to the site and location when considering: g) the accessibility of the site; h) the impacts on the local highway network including the type of traffic generated, the appropriateness for the rural roads and the impact on their character;
There currently appears to be no other suitable access to the site to carry traffic for this initial proposed construction phase. The application therefore fails on these points of Policy based on the way the construction plan is currently scheduled.
This alone offer clear grounds for refusal or the requirement for a total rewrite of Moto’s construction plan laying out alternative arrangements for the construction phase that avoids using the Tunworth Road / Dickens Lane.
John Raymond For Winslade Parish Meeting 23rd November, 2017