11/25/2019 Mail - Woodgate, Jenny - Outlook
Large Development Sites Consultation - Representations on behalf of Harrow Estates @savills.com> Tue 15/10/2019 17:47 To: EHDC - Local Plan
6 attachments (18 MB) Doc 4 FINAL Northbrook Landscape Analysis_JC_HB.PDF; Doc 5 FINAL Northbrook Ecology Technical Note_151019_IS_HM.PDF; Harrow Estates EHDC Large Development Sites Questionnaire.pdf; Doc 1 FINAL Chawton Heritage Note October 2019.pdf; Doc 2 FINAL Chawton Landscape Addendum and AVR Photography.pdf; Doc 3 FINAL Northbrook Masterplan Analysis 14.10.19.pdf;
Dear Sir / Madam
On behalf of Harrow Estates please find attached the following in response to the Large Development Sites consultation which closes at midnight.
§ Large Development Sites Questionnaire § Representations on behalf of Harrow Estates § Document 1. Chawton Park Farm Heritage Assessment (Pegasus, October 2019) § Document 2. Chawton Park Farm Landscape Addendum (Tyler Grange) § Document 3. Northbrook Park Masterplan Analysis Plan 1 & 2 (Savills Urban Design) § Document 4. Northbrook Park: Landscape Analysis (Tyler Grange) § Document 5. Northbrook Park: Ecology Note (Tyler Grange)
Please note the following documents will follow on separate emails due to file size: § Document 6. Technical Paper 1: Chawton Park Garden Village: Transport Feasibility Report (Calibro, October 2019) o Document 6. Technical Paper 1: Appendices Part 1 o Document 6. Technical Paper 1: Appendices Part 2 o Document 6. Technical Paper 1: Appendices Part 3 o Document 6. Technical Paper 1: Appendices Part 4 § Document 7. Technical Paper 2: Land at Northbrook Park (Calibro, October 2019) § Document 8. Technical Paper 3: Neatham Down (Calibro, October 2019)
Please let me know If you would like hard copies of any documents.
I would be grateful of your confirmation of receipt.
Yours faithfully,
Planner Planning
Savills, 2 Charlotte Place , Southampton SO14 0TB Tel Mobile Email @savills.com Website :www.savills.co.uk
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Large Development Sites (REGULATION 18)
CONSULTATION
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
QUESTIONNAIRE 3 September – 15 October 2019
East Hampshire Local Plan Large Development Sites This questionnaire has been prepared to assist you in responding to the consultation and should be used alongside the Large Development Sites consultation document and the Why, when and how to get involved guide. Please note that the Council is unable to accept anonymous comments and for a comment to be formally accepted, a name and contact address (preferably e-mail) must be provided. Comments to this consultation are part of the evidence base which supports the emerging Local Plan. As such, all comments submitted as part of the consultation will be used in line with our Planning Policy Privacy Notice and kept according to our Retention Schedule, both of which can be found on our website. Your comments will be made publicly viewable at the appropriate time. If you wish to be kept updated about this consultation and other Local Plan matters, please register for email alerts via our website. Name
Organisation (if applicable)
Email (preferred method of contact)
Address Line 1
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
Post Town
Post Code
To be completed by agents acting on behalf of a client
Client Name
Client Organisation
Client Email
Client Address Line 1
Client Post Town
Client Post Code
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
How to respond using this form Please refer to the Why, when and how to get involved guide available on our website. When responding, please include the name of the site your comments refer to. If commenting on more than one site, please make it clear which comment relates to which site. There are a series of consultation questions. These are: 1: Do you have any comments on the proposed uses? 2: What infrastructure is required to support the proposal and when? This could be on or off-site provision. 3: Do you know of any other constraints to developing the site? Please provide detail and evidence. 4: What opportunities and/or benefits do you think the proposal could bring. Please explain how. 5: What are the cross-boundary considerations and the potential implications? How can they be overcome? The site promoters consider their proposal to be deliverable within the Local Plan period up to 2036. 6: Is there any reason that this is not achievable?
7: Is there any other Large Development Site that could deliver over 600 homes and other supporting uses by 2036, that is not included in this consultation? 8: Do you have any comments on the assessment of Large Development Sites, as set out in the Council’s background paper?
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
9: Do you have any comments on the relationship between Large Development Sites and the draft Local Plan (2017-2036), particularly in relation to what other policies and proposals the draft Local Plan should contain? 10: Is there any feedback you would like to give us about this consultation?
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
Large Development Sites
When responding to a consultation question please quote the question number from the list provided and where applicable, the site name. Please provide your comments in the box below. Use additional sheets as required. Click here to enter text electronically
Please see the accompanying Representation and technical documents that are attached to this questionaire. The main representation document is divided into chapters for each of the relevant large development sites and responds to the consultation questions under each chapter.
LARGE DEVELOPMENT SITES CONSULTATION QUESTIONNAIRE
Click here to enter text electronically
SUBMISSION Please submit your comments to reach us by midnight on 15 October 2019 either by:
E-mail to [email protected] By post to Planning Policy, East Hampshire District Council, Penns Place, Petersfield, Hampshire, GU31 4EX Thank you for taking the time to have your say.
Harrow Estates October 2019
East Hampshire Local Plan: Regulation 18 Large Development Sites Consultation
Representations on behalf of Harrow Estates
savills.co.uk East Hampshire Local Plan: Regulation 18 Large Development Sites Consultation Representations on behalf of Harrow Estates
Contents 1. Introduction 1 2. Chawton Park Farm 3 3. Northbrook Park 12 4. Whitehill & Bordon 24 5. Extension to Land East of Horndean (Hazelton Farm) 27 6. Land South East of Liphook 30 7. Four Marks Sites 33 8. Neatham Down 35 9. Remaining questions 37
Documents 1. Chawton Park Farm Heritage Assessment (Pegasus, October 2019) 2. Chawton Park Farm Landscape Addendum (Tyler Grange) 3. Northbrook Park Masterplan Analysis Plan 1 & 2 (Savills Urban Design) 4. Northbrook Park: Landscape Analysis (Tyler Grange) 5. Northbrook Park: Ecology Note (Tyler Grange) 6. Technical Paper 1: Chawton Park Garden Village: Transport Feasibility Report (Calibro, October 2019) 7. Technical Paper 2: Land at Northbrook Park (Calibro, October 2019) 8. Technical Paper 3: Neatham Down (Calibro, October 2019)
Harrow Estates October 2019
East Hampshire Local Plan: Regulation 18 Large Development Sites Consultation Representations on behalf of Harrow Estates
1. Introduction
1.1. These representations, prepared by Savills on behalf of Harrow Estates, are made on the Regulation 18 Large Development Sites Consultation forming part of the evidence gathering for the draft East Hampshire Local Plan (EHLP). These representations should be read in conjunction with Harrow Estates previous Regulation 18 (Reg18) representations on the draft Local Plan dated March 2019. Whilst this representation does not repeat the March Reg18 submission and technical appendices, to provide context set out below is a summary of the key concerns previously raised by Harrow Estates which renders the currently drafted EHLP ‘unsound’, including:
a. A failure to meet the test of being ‘justified’ pursuant to NPPF1 paragraph 35 (a), in terms of: . Not being an ‘appropriate strategy’, having selected the unsustainable site of Northbrook . Not duly taking into account ‘reasonable alternatives’, in particular the possibility of allocating Chawton Park to act as a principal location to support the strategic settlement of Alton . Being inconsistent with (and directly contrary to) the evidence base
b. Failure to meet the test of being ‘effective’, pursuant to NPPF paragraph 35 (b), particularly in terms of having allocated Northbrook, which is not a deliverable site;
c. Inconsistency with national policy, pursuant to NPPF paragraph 35 (c), particularly in terms of:
. Promoting an unsustainable pattern of development . Being undeliverable . Lacking a clear strategy . Failure to co-operate with Waverley Borough Council Borough Council (WBC), with regards to Northbrook . Lack of evidence-based underpinning of policies for Northbrook . Failure to use the Sustainability Appraisal process to duly inform the plan, resulting in the selection of an option that would cause significant adverse impacts that are avoidable, despite the availability of a deliverable option that would reduce or eliminate such impacts . Allocation of housing in a site which is not well located, not supported by the necessary infrastructure and facilities, not able to support a sustainable community by virtue of its size, and not able to demonstrate a quality development, all of which are required by the NPPF . Departure from NPPF provisions concerning new settlements, urban extensions, and an array of other considerations associated with the design of development to reflect social, economic, and environmental gains . Failure to fulfil the ‘duty to co-operate’ in relation to Waverley district
1.2. Harrow Estates welcomes the acknowledgement by EHDC in the introduction of Site Assessment Background Document that significant comments and objections were also received during the draft Local Plan Reg18 consultation from statutory consultees, neighbouring councils and other key
1 MHCLG February 2019
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stakeholders. Whilst much of this objection was directed at the allocation of Northbrook a review of the responses highlights that the lack of testing of reasonable alternatives and the conclusions of the SA were also very common themes of objection.
1.3. The Consultation document states in the “What is the Purpose of this Consultation” section that… “At present, The Council does not have sufficiently robust evidence to consider the suitability of these sites, and needs to ensure this is in place by the next Local Plan consultation, to inform its decisions”. Harrow Estates fully endorse this statement for a number of the sites and this representation will set out the why specific sites should not be allocated through this selection process, as well as endorse the sustainable and deliverable credentials of a new garden village at Chawton Park Farm.
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2. Chawton Park Farm
2.1. Savills, on behalf of Harrow Estates, are supporting Chawton Park Farm in the Reg 18 Large Development Sites Consultation. Savills acknowledges Table 10 (p35) of the Site Assessments Background Paper2, and this representation demonstrates that these can all be addressed:
Issues Highlighted by Issues Highlighted by Site Name Partners Stage One Stage Two Chawton Park . Suitability of . Suitability of Issues likely to be of interest vehicular access development for to: proposals delivering a net gain . Hampshire County . Suitability of in biodiversity Council connecting to . Impacts from . Historic England existing wastewater development on . Natural England infrastructure listed Chawton Park . South Downs Farmhouse National Park . Suitability of Authority largescale . Thames Water development in terms of landscape impacts
Consultation question CP1: Do you have any comments on the proposed uses?
2.2. The Vision for Chawton Park is to create a distinct garden village with its own supporting facilities but has the unique advantage of being directly linked to Alton and the existing infrastructure that this key town provides. The Garden Village will benefit from excellent connectivity capitalising on the quality walking and cycling routes connecting to the existing facilities in the town, adjoining established bus services and the railway station. Key features will include:
. Quality design: The emphasis will be on retention of existing hedges, trees and woodlands. The design will focus on achieving spacious and efficient layouts and garden spaces, whilst incorporating Building for Life principles. Mature linear routes, often following the alignment of the linear drainage ditches and hedgerows, will be retained and streets aligned to create vistas to the woodlands, open space or other landscape and townscape elements. . Locally distinctive: The new neighbourhood will have a coherent architectural theme derived from local traditional building styles and estate character. Streets will be generous, with attractively designed roads and high quality semi-mature trees planted from the outset. Building heights and densities will respond to this structure, being greatest close to the existing settlement edge and on the lower slopes. . Well connected to nature: The development will feature a network of easily accessible green spaces
2 Site Assessments Background Paper For the East Hampshire District Local Plan Large Development Sites Regulation 18 consultation (September 2019)
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linked by tree lined streets. New, high quality homes will be arranged so as to respect existing woodlands, tree belts, individual mature trees and adjacent historic features. . Historic context: The new neighbourhood will be designed in a manner which respects the historic setting. The listed farmhouse will be preserved and its setting enhanced with sensitive design, appropriate set-back distances to ‘frame’ the farmhouse and improve understanding and enjoyment of it, as a key feature in the overall scheme. The site has been subject of a Heritage Assessment3 which finds that the impact upon the Listed Building is less than significant. . Green infrastructure: New routes through the woodlands will provide recreational benefits for residents and local people. The open spaces, greenways and private gardens will also provide amenity spaces for residents. It is envisaged that there will be a linked network of open spaces, play spaces and cycleways through the development. The development will include a series of village greens which will accommodate a children’s play area and fronted onto by the new local centre. . Travel choices: There will be a well-connected network of footpaths and cycle routes (including those of national significance) linking with the surroundings. . Civic pride: There is a strong commitment and leadership from the landowners. The aim is to achieve support from partners and communities, with a commitment to continuous engagement with the community throughout the project. . Long term management of high quality green spaces and public realm would be secured either by transfer to the Parish Council, community board, or management company, along with play areas which benefit the community, in addition to potential transfer of new woodland to the Forestry Commission.
2.3. Overall, the approach will be to work in harmony with the landscape surroundings. Whilst Chawton Park has environmental sensitivities that will be carefully mitigated and managed, our proposals will protect and enhance these, whilst also turning them into assets of value to the community.
2.4. Chawton Park can deliver a significant proportion of Local Plan housing requirements on a single site, and this will bring numerous benefits:
. Development will be comprehensively planned and phased, within a sustainable landscape-led framework, but with flexibility over the lifetime of the plan period to respond to any future policy or market changes. This will ensure that phases can be fine-tuned to ensure that the needs of different groups in the community are met. . This scale of development will enable a mixture of housing types to be brought forward together, including starter homes and family homes. This is consistent with NPPF4. . As part of a mixed community we will be able to make provision for accommodation suitable for elderly in the form of Lifetime Homes, and for the provision of wheelchair accessible units. . Within a large development, it will be possible to ensure through the application process that designs and styles are of high quality, integrated and suited to the area and to housing needs. This is preferable to an ad-hoc approach on a larger number of unrelated sites. . A highly effective balance of affordable housing (up to 480 in total) can be guaranteed and the right balance of tenures, dwelling types, and numbers of bedrooms can be provided to specifically meet
3 Chawton Park Farm Heritage Assessment (Pegasus, October 2019) 4 Paragraph 72 c)
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local affordable housing needs. The development can support the delivery of affordable housing and there are no known large abnormal costs or infrastructure that will prohibit Chawton Park Garden Village from being policy compliant thus delivering much needed affordable housing. . The local centre (capable of being up to 1ha, although the scale is to be agreed with EHDC) will provide retail and community uses for the benefit of the residents, but this will have a wider benefit to the community of Alton and its different groups. The critical mass generated by the scale of the development will also ensure the vitality and viability of the local centre and importantly sustain a 2 FE Primary School. The Local Centre will not compete with Alton High Street. . Over half of the site (approximately 50.4ha) will be utilised for informal and formal open space) and will have an important socio-economic benefit and promote a healthier lifestyle.
2.5. During the consultation process we received some questions over the quantum of the development. The site is self-contained and its boundaries well defined by topography and woodland. Using best practice urban design and technical analysis plus a density that responds to the character of the area, the site can accommodate up to 1200 dwellings. In addition this quantum of development will be able to support and sustain the local centre with the primary school by providing a suitable critical mass to make the facilities viable and deliverable.
2.6. The site could in principle accommodate a number of gypsy and traveller pitches and travelling showpeople plots, but further investigation is required to determine a suitable location for the pitches and plots within the site boundaries; and discussions with East Hampshire District Council are required to determine the scale of the need for each type of accommodation in this area.
Consultation question CP2: What infrastructure is required to support the proposal and when? This could be on or off-site provision.
2.7. Chawton Park is in an ideal location to capitalise on, invest in, and promote new infrastructure. Technical Paper 15 has been submitted to support this representation and provides a strategic appraisal of the transport, highways and accessibility credentials of Chawton Park Garden Village, Alton, with a view to establishing its development potential for residential use.
2.8. At a district scale, Alton is by far the best-served settlement in relation to existing infrastructure and this includes health, education, leisure, transport, and other community infrastructure. The pre-eminent position of Alton is affirmed by the Council’s own Settlement Hierarchy Background Paper (Dec 2018), which places it at the apex of the hierarchy as a ‘Market Town’, scoring 100% in the chosen matrix (40 out of 40. Alton has the largest area of Strategic Employment Sites (policy S14) in the draft local plan. Paragraph 72 (b) of the NPPF supports larger scale development where there is good access to employment opportunities, which Chawton Park Farm can demonstrate being in close proximity to Alton and with excellent accessibility.
2.9. Railway infrastructure is of particular note and Alton is able to avoid contributing to dependence on the private car. Chawton Park Farm can robustly argue that it is in a sustainable location and has the ability to genuinely encourage modal shift. The unique advantage of Chawton Park Farm is also the support of
5 Technical Paper 1: Chawton Park Garden Village: Transport Feasibility Report (Calibro, October 2019)
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East Hampshire Local Plan: Regulation 18 Large Development Sites Consultation Representations on behalf of Harrow Estates
Stagecoach which is addressed later. Development at Chawton Park would, reinforce the vitality of the existing Alton-Waterloo rail service by positioning a significant number of potential passengers within close proximity. Consultation has been undertaken with SUSTRANS regarding proposals to improve Route 224 of the National Cycle Network who have expressed their support for the proposals to enhance the existing provision in the area and to address existing deficiencies in the NCN.
2.10. It is also notable how close the site is to other facilities, such as Alton Community Hospital (with Boots the Chemist), Alton Leisure Centre, Alton Tennis Club, and Alton Cricket Club. As well as increased patronage, the facility would have the opportunity to benefit from circa £15m of CIL contribution to be generated by the proposal.
2.11. EHDC should also take note of the Alton Drainage Strategy6, which confirms (para 2.2) that Alton is served by its own treatment works just on the edge of town; this discharges into the river Wey (a tributary of the Thames). Off site reinforcement and upgrades of existing provision is necessary to deliver Chawton Park Garden Village, the costings and timeframes for which have been factored into the viability appraisal and delivery trajectory.
2.12. There is no nitrates constraint affecting this site.
2.13. Chawton Park Farm is located outside of any buffer boundary for any Special Protection Area (SPA) which negates the need for the provision of Suitable Alternative Natural Greenspace (SANG). Allocation of Chawton Park Farm would not adversely affect the integrity of any SPA.
2.14. In terms of planned infrastructure, the allocation of Chawton Park would provide an important contribution in its own right:
. We propose to divert nos. 64 and 38 services into the site, agreed with and unequivocally supported by Stagecoach. Service 64 is the most regular and fastest growing bus service in East Hampshire, and would provide a regular, direct bus service to Alton, Alresford and Winchester . Provision of a new primary school, which will counterbalance the tendency in Alton for most schools to be distributed to the east of the town. The proposed development would generate the need for 360 primary school places, but make provision for 420 school places. As such, the development would make an appreciable net contribution to the local area in education terms. . The proposed Local Centre would include a new pub, shop and community centre, as well as employment, which would be of benefit to the wider community and not just the future residents of Chawton Park. This Local Centre would be of a scale that would not compete with Alton High Street providing only small convenience shopping for residents. . Incorporate and where possible upgrade the existing National Cycle Network Route 224 which runs through the Site and integrate to the wider off-road cycle network in consultation with SUSTRANS. Upgrade Chawton Park Road where necessary to address the existing width restriction and substandard geometry as it connects onto Northfield Road, aiding the efficiency and safety of all travellers, particularly bus services.
6 Alton Drainage Strategy Stage 1 – Initialise/Prepare (Thames Water). Published version post stakeholder review v1.1
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. Significant additional work has been undertaken to demonstrate the technical viability of the proposed access strategy (as detailed in Section 5.2 of Technical Paper 1). This includes the fact that proposals have been updated to reflect topographical survey which confirms that the proposals are entirely deliverable within land controlled by the promotion or which is adopted public highway. Detailed capacity analyses have also been undertaken of the operation of the railway bridge using best available data, including traffic generation rates provided by Hampshire County Council, and this confirms the availability of significant reserve capacity in the network. . Notwithstanding the results of the capacity analyses, additional design work has been undertaken to demonstrate how potentially larger infrastructure improvements could be delivered, within land controlled by the promotion or dedicated public highway, if justified by future analysis. . To provide a new contiguous footway that connects to existing network of footways, enabling residents of the development to travel into the centre of Alton by foot, whilst increasing opportunities for residents of Alton to access the countryside that adjoins Chawton Park. These improvements will help meet the new objectives in the very recent Enhance East Hants Strategy7 which has key placemaking objectives for Alton in terms of access and movement. . Alterations are proposed to Northfield Road which would allow the Jubilee playing fields car park to be extended.
2.15. Harrow Estates is committed to the early delivery of infrastructure and would make available the land for the primary school and provide services to the site at an early stage in the build programme.
Consultation question CP3: Do you know of any other constraints to developing the site? Please provide detail and evidence.
2.16. There are no known constraints that will restrict or hinder the development of this site. Harrow Estates has undertaken thorough site due diligence and as result a substantial and robust technical evidence base supports the masterplan, drawing on topography, highways, ecology, landscape, drainage and other relevant considerations, This evidence base demonstrates that the amount, mix and layout proposed is both suitable and achievable.
Consultation question CP4: What opportunities and/or benefits do you think the proposal could bring. Please explain how.
Economic Benefits
2.17. Chawton Park provides and reinforces economic opportunities for the whole community:
. Alton is the established key economic hub of East Hampshire. However, in terms of retail spend, EDHC have identified a deficit within the borough as a whole and Alton in particular8:
7 East Hampshire Place-Making Strategy 2019-2036 (Council, 19 September 2019) 8 Table 4.4, East Hampshire Retail and Main Town Centre Uses Study Final Report (October 2018)
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East Hampshire Local Plan: Regulation 18 Large Development Sites Consultation Representations on behalf of Harrow Estates
Destination 2018 Turnover Benchmark Turnover Surplus/Deficit Alton 63.47 80.83 -17.36 Whitehill & Bordon 36.89 27.34 +9.55 Liphook 38.17 27.12 +11.05 Clanfield 3.41 1.57 +1.84 Four Marks 4.99 6.78 -1.79 Grayshott 5.89 5.94 -0.05 Horndean 25.99 31.25 -5.26 Other East Hampshire 4.11 4.11 n/a TOTAL 182.92 184.93 -2.01
. The new residents (up to around 3000) would, given proximity and connectivity give rise to a substantial spend in Alton town centre and represent an important boost in the centre with the largest deficit against benchmark turnover in the district. . The site is located directly off the A31, the district’s key economic corridor, and our proposed bus service would sustainably reinforce this. . New residents would be close to, and able to walk and cycle to, the new employment allocation site SA24 and help make that site is attractive for inward investment. . Provision of a deliverable local centre on-site would also contribute towards jobs and local business opportunities. . The central location of Chawton Park and Alton within the district mean, the retail spend of new residents would have relatively low ‘leakage’ to other districts. . Allocating Chawton Park provides long term certainty over steady/ progressive release of homes through plan period. . Redrow recruits locally, including apprentices, and sub-contractors have local labour clauses as part of our Considerate Constructors scheme ensuring funds stay within the local area, . Chawton Park could deliver CIL contributions in the region of £15m and this could support an array of local projects, in parallel with a Neighbourhood Plan review.
2.18. Overall, though primarily comprising housing, Chawton Park would in itself bring appreciable economic benefits to existing and new residents.
Environmental Benefits
2.19. Chawton Park provides the opportunity to safeguard and enhance existing ecological features, whilst creating new habitats and improve connectivity between existing habitats and the adjoining woodlands. Harrow Estates have assessed the biodiversity value of the site (technical ecology studies were submitted with March 2019 Reg 18 submission), and from this ecological features and considerations have been fully incorporated into the masterplan. This will ensure that important habitats such as trees and hedgerows are retained and that the biodiversity of the local area is enhanced. The site itself is well enclosed being set in a valley and sheltered within the woodland that provides visual containment and
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this ensures that impacts on the setting of the National Park are minimised. Given the scale of the site and the level of green infrastructure a net biodiversity gain will be achieved on this site meeting the evolving government policy.
2.20. The East Hants Green Infrastructure Strategy9 identifies a deficiency of open space around Alton and the need for a strategic project to provide 60 to 400 hectares of new semi natural green space in the Alton/Four Marks Area. Chawton Park Farm is located right in the middle of this search area and provides a real opportunity to make a significant contribution to the GI strategy through the provision of a substantial amount of public open space. Chawton Park Wood, adjacent to the site, is valued as a resource for recreation because of its proximity to Alton. Development at Chawton Park would allow access to this recreation site with the potential for CIL to be used for new visitor facilities in line with the Green Infrastructure Strategy and the ongoing management of the wood, the tracks and trails within by Forestry England. We are engaging with both the Forestry Commission and Forestry England.
2.21. The design and mitigation measures include, in particular:
. Focusing development on the least ecologically important site habitat (grassland). . Protecting the ancient woodlands through the incorporation of sufficient buffers, and ensuring a sensitive lighting strategy to avoid impacts on nocturnal species. . Management plans in relation to the Sites of Interest for Nature Conservation (SINCs) . Creating an interconnected multi-functional network of green infrastructure in order to benefit the site as a whole in terms of biodiversity, amenity, drainage, and visual integration with the surroundings. . Strengthening connectivity for wildlife by creation of new habitat and improved management of the retained hedgerows and tree lines. . Creating new wetland habitat by providing a sustainable drainage system. . Creating habitat woodpiles in discrete locations and installing bat, bird, and insect boxes and hedgehog-friendly fence panels. . New planting, particularly on the western boundary, will create an additional wildlife corridor between two previously unconnected woodlands, which accords with the objectives of the district Biodiversity Action Plan (BAP). . Residential development at Chawton Park Farm would be resilient to climate change and would provide opportunities for solar power generation due to the south facing valley side.
2.22. There is also the potential to gift areas of planted woodland to the Forestry Commission (FC). This would be consistent with established FC management plans for the woodland which feature ecological connectivity, as well as public access. Opportunities will also be taken to increase the interpretative/ educational value of the site, for instance by involving nearby schools in monitoring and management works, or by providing better access to nature. A Landscape and Ecology Management Plan will be employed to maximise the biodiversity potential of retained and new habitats.
2.23. It is notable that Chawton Park drains ultimately into the River Thames, and hence development cannot lead to the additional deposition of nitrates in the Solent, which is a significant benefit to the scheme.
9 East Hampshire Green Infrastructure Strategy (May 2019)
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2.24. These representations are supported by an Addendum10 to the Landscape and Visual Appraisal that supported the March Reg 18 submission. This Addendum considers the landscape impact from Chawton House following engagement with the representatives of the House who raised concerns through the previous consultation. The Addendum reinforces the containment of the site through the surrounding woodland and concludes that land to the south of Chawton Park, outside of the site area, features more prominently in limited views from Chawton House. If necessary, mitigation measures can be implemented that would not have a detrimental impact on the visual amenity of Chawton House.
Transport Benefits
2.25. Chawton Park will make exceptionally good provision for the four key sustainable modes of transport:
Bus transport 2.26. Section 4.4 of Technical Paper 1 details that the development will divert nos. 64 and 38 services into the site. This has been agreed with and is unequivocally supported by Stagecoach. Service 64 is, by some margin, the most regular and fastest growing bus service in East Hampshire, and would provide a regular, direct service to Alton, Alresford and Winchester. This could be achieved from first occupation of dwellings at Chawton Park, and offers synergy with committed development (Borovere Farm/ Treloar Hospital). Stagecoach have indicated the potential to improve frequency of the 64/ 38 services to deliver a 15-minute headway. The secondary schools and 6th form college in Alton are accessible using the 64 bus, along with Perins in Alresford and schooling in Winchester.
Cycling 2.27. Section 4.3 of Technical Paper 1 details that Chawton Park already benefits from excellent access for cycling, and the development will improve this. An existing cycle-route extends over 16-kilometres using tracks through Chawton Park Wood and continues to Bentworth Village. This forms part of National Cycle Network route 224 from Farnham to Medstead via Alton, and Wickham to Gosport. There are opportunities to incorporate and enhance this provision through an integrated masterplan for Chawton Park, whilst enhancing connectivity to the countryside for the wider Alton community, in line with the objectives of the Alton Neighbourhood plan and the Green Infrastructure Strategy. It is also possible to safely cycle within the carriageway of existing roads. Our modelling indicates that c.10,000 jobs are accessible within the 5-kilometre catchment, particularly at Alton. This figure can be expected to increase significantly further as the new employment allocations are developed.
Rail 2.28. Section 4.5 of Technical Paper 1 details that Chawton Park is located approximately 3km from Alton Station, and would be accessible to it via cycle routes or the diverted bus service. Based on a 40-minute total travel time, Chawton Park would facilitate access to a catchment containing approximately a further 5,000 jobs. However, this number would increase markedly when considering the likelihood of longer rail- based commutes, as services from Alton provide connections to Farnham, Aldershot, Woking, West Byfleet, London Waterloo and the wider rail network. In this context, rail can unlock access to significant employment opportunities across the region from Alton.
10 Chawton Park Farm Landscape Addendum (Tyler Grange)
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Walking 2.29. Section 4.2 of Technical Paper 1 details that two bridleways already run through the site and connect to the nearby settlements of Medstead and Four Marks to the west. The bridle path along the southern part of the site also routes towards a Public Right of Way from Chawton Park Road to the nearby residential area of Beech. Opportunities exist to connect the existing formal pedestrian network along Chawton Park Road to the existing Leisure Centre, where a good surfaced route exists. This would be incorporated within existing highway verge. The site can thus be serviced from a well-formed network of footpaths and enable residents safe access to many facilities and public transport connections by foot. These include Alton Cricket Club, Alton Sports Centre (with swimming pool, gym, AstroTurf football, crèche, climbing and soft-play). Chawton Park Surgery is within a 1.2-kilometre walk and sits alongside a local pharmacy. A new school will be developed within the site, and in addition Butts Primary School is located within an acceptable walking distance. There are also opportunities for informal walking to the historic village of Chawton and the South Downs National Park.
Consultation question CP6: Is there any reason that this is not achievable?
2.30. There are no technical reasons why this development is not achievable. Harrow Estates have commissioned a serious of technical reports which have been appended to this representation and our previous Reg 18 Draft Local Plan Representation dated March 2019. The Site can deliver within the Local Plan period to 2036.
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3. Northbrook Park
3.1. The table below sets out a summary of statutory consultee representations to the March Reg 18 submission for Northbrook Park, which demonstrates the significant number of objections and concerns raised and that a much more robust evidence base and scrutiny of the Northbrook Park proposals is required. It is noted that Council undertook their own summary11, which also identified a significant number of issues raised.
Consultee Objection / specific issue Comment summary Further work is needed to address the following site constraints and ensure the site is deliverable. Where public sewerage capacity constrains development and appropriate mitigation cannot be agreed it may be necessary for local planning authorities to phase or delay occupation of development in order to allow time for the necessary improvements to the public sewerage system to take place. A Level 2 SFRA is required and the allocation Deliverability / waste water / must satisfy the Exception test to be deliverable. Environment Agency flood risk / biodiversity net The North Wey which flows through the southern gain section of the site is an internationally rare and sensitive habitat. Policy SA21 should list the North Wey as a key green infrastructure asset within the site and reference the requirement for an undeveloped buffer zone measuring a minimum of 10m from the top of the river bank on both sides of the watercourse. The buffer zone would need to be free from all built development including footpaths / cycleways except in specifically agreed locations. The development of this site should retain the listed buildings and preserve or enhance their setting, which would be expected to be in an Preserve or enhance setting open landscape. of Grade II listed buildings / Further archaeological investigation of this site Historic England potential presence of very should be undertaken before this site is taken large prehistoric enclosure forward as an allocation to provide further south of A31 evidence on whether or not this feature should be scheduled and how it would affect the developable area (and therefore quantum) of this site.
11 Draft Local Plan 2017-2036 Regulation 18 Summary of Responses (June 2019)
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We have serious concern about the deliverability of Northbrook Park in particular. No evidence as to why this site is in any way superior, on any material planning grounds. Northbrook Park not of a scale sufficient to internalise many day-to-day journeys. Only 1FE primary school. Can’t take advantage of existing services and Deliverability / scale / infrastructure. Stagecoach sustainable transport Some distance from rail service at Bentley. Poor accessibility by public transport. Too far to walk to stations. Cycling would mean along the A31. Bus link would require exceptionally high level of ongoing revenue support. 800 dwellings would be entirely insufficient to justify any increase in frequency of the existing bus service. Not appropriate to divert inter-urban bus service into the development. Presumption against providing new or substantially improved direct access into residential development land from A roads. Applicants will be required to demonstrate that access will be safe, comply with current Highway design standards, and that any negative impacts Highways / potential Hampshire County Council on the efficiency and resilience of the highway minerals network can be mitigated Potential minerals present in accordance with the Mineral Consultation Area (MCA) and therefore require further investigation or a mineral assessment to be included alongside other site investigations New homes will not be “directed to the most sustainable and accessible locations in the area”. It is our view that seeking to meet a significant proportion of the District’s housing needs at Northbrook Park will not achieve this objective. Significant increases in traffic and congestion in Highways / sustainability / Surrey County Council Wrecclesham would be likely to result from the scale / minerals development proposed in the draft Local Plan at Northbrook. Therefore, should the Local Planning Authority decide to pursue the proposals for a strategic allocation for 800 homes or more, the provision of a relief road will be needed to mitigate the impacts on the community in Wrecclesham.
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Questionable as to whether any form of bus connection to Bentley and Farnham stations could be economically viable. The achievement of a modal shift away from the private car is considered likely to require dedicated cycle routes to Farnham, Wrecclesham and Bentley alongside bus services provided in perpetuity. The creation of an entirely self-reliant site would require expansion of the existing proposals on a massive scale and a substantial investment in transport infrastructure. Proximity to soft sand MSA that surrounds Alton Road Sandpit, which has permission for the extraction, filling and restoration over 11.5 years. Potential to exacerbate congestion on the road network due to out-commute (evidence base WLP 2017). Assessment does not extend outside of Waverley Borough Council Highways / flood risk Hampshire. Not clear that the sequential test for flooding has been satisfied. Development in East Hampshire risks increasing flood risk downstream. The policy itself should in particular include requirements that development does not harm views from the National Park, with regards the siting, scale, height, design and light pollution with respect to Dark Night Skies. South Downs National Park Authority Setting of the SDNP We strongly recommend that built development is kept away from the southern portion of the site. Development of the site must incorporate means of access to Alice Holt/SDNP by means other than private car. Concern regarding this proposal is the likely traffic impact on the roads leading into Hart from the Northbrook area, particularly on the rural roads and lanes that lead toward the A287 in the Hart District Council Highways south of the district. Traffic to the M3 towards Hook and Basingstoke will use this as the most direct route, but these roads are unsuited to supporting strategic levels of growth.
3.2. Savills, on behalf of Harrow Estates, objects to Northbrook Park for the reasons set out in the consultation questions below.
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Consultation question NBP1: Do you have any comments on the proposed uses?
3.3. To comment on the proposed uses for Northbrook Park Savills Urban Design and the Technical Team has undertaken a masterplanning and urban design appraisal of the proposals and constraints. In addition a detailed analysis of accessibility and barriers to non-car access can be found in Technical Paper 1 by Calibro which supports this representation. This capacity assessment exercise has demonstrated that there are significant delivery and site issues, these include:
. site capacity . high net housing density . under-provision of landscape buffers. . an under-provision of Public Open Space . an undersized primary school and; . loss of priority habitat
3.4. In addition we have also identified a number of 'good practice' masterplanning issues that the scheme falls short of primarily as it seeks to deliver as many units as possible to try and justify a sustainable development with the delivery of essential facilities in this isolated location.
Site capacity 3.5. Looking at the core site north of the A31, we have concerns about the high proportion of built development within the red line. The site area north of the A31 is 31.7ha, and of that there is 7.5ha of woodland (most of which is Ancient Woodland and SINC). That only leaves a potential developable site area of 24ha. Within that the scheme proposes 18.4ha of built form uses. That equates to 76.6%, which is a very high proportion of net developable area for a strategic development site. Most strategic sites have a net developable area of between 50-65%.
3.6. Whenever a strategic site has a high proportion of built form uses, it raises a red flag about the robustness of the masterplan. In this case, it is clear that there is an insufficient provision of supporting uses and landscape buffers. Our analysis suggest that this site will only deliver a maximum of 540 units and more likely 450 units at more realistic and appropriate densities in this rural location. This in turn raises questions about whether a smaller number of units could realistically support the proposed local centre, sustain a new primary school and justify the viability of the private shuttle bus.
High net housing density 3.7. Our assessment work12 (Analysis plan 1) shows that the net density (the net housing areas excluding open space but including roads and verges) is 59dph. This contrasts significantly with our Chawton Park scheme, which (using the same approach) is 37dph. A net housing density of 59dph in this rural setting is too high and is more suited to an urban infill setting.
Lack of landscape buffers 3.8. To exacerbate the visual impact of a high density built form in a rural location, the layout lacks the appropriate landscape buffers along all of the outer edges of the scheme. This is particularly noticeable
12 Northbrook Park Masterplan Analysis (Savills Urban Design)
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along the north eastern and south western flanks of the scheme where development is hard up against both open countryside edges. In many cases only 1m or 2m from the existing field boundary which leaves no ability for structural or informal planting.
Under-provision of Public Open Space 3.9. It is clear that there is a woeful lack of formal recreation facilities. The only playing field shown is within the proposed primary school site. Previously, formal play was illustrated south of the A31 but the latest masterplan in the Information Pack now illustrates this area as informal space linked by the footway around the SANG. Interestingly, the clubhouse is still located south of the A31 which is not a desirable location and divorced from the residential development.
3.10. FiT Standards state that for 800 units the site requires:
. 0.48 Ha of equipped play . 1.06 Ha of informal play . 3.07 Ha of sports pitches
3.11. It would also seem that the 5.1Ha of informal POS that is provided is dominated by an existing lake.
Under-provision of Primary School 3.12. The school is approximately 1.3 Ha and it states in the information pack this is 2FE. HCC Guidance13 states that the minimum usable area for a 2FE Primary School needs to be at least 2.0ha:
School type School size Total site area 1fe (210 places) 1.2 ha Primary 2fe (420 places) 2.0 ha
3.13. The isolated nature of the site and its remoteness to any existing settlement means that the scheme can't rely on the use of existing facilities. This makes the need for properly sized on-site provision even more acute.
Loss of priority habitats 3.14. The site contains a number of priority habitats identified on MAGIC maps. The site contains Deciduous Woodland and Woodpasture, and Pasture to the north of the A31Coastal, and Floodplain Grazing Marsh to the south of the A31. The scheme could result in the destruction of a number of priority habitats including a significant portion of the Lawns Copse deciduous woodland. Other loss would include a significant amount of the Wood pasture and Parkland habitats north of the A31 and Flood plain grazing marsh south of the A31. The Northbrook Ecology Note14 explores the impact of the proposed allocation on the areas of priority habitat on the site and concludes that mitigation would be necessary for the loss to ensure conformity with legislation and planning policy.
13 Hampshire County Council Developers’ Contributions towards Children’s Services Facilities (November 2018) 14 Northbrook Park Ecology Technical Note (Tyler Grange)
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General notes on masterplanning
Street hierarchy 3.15. The lack of 'breathing space' in the scheme means that there is not enough room for a dominant and highly legible tree-lined primary street as the 'spine' road through the development. Instead, the large A31 roundabout leads directly into a lower order road which is difficult to track though the scheme.
Crondall Road edge (western edge) 3.16. The western edge of the scheme is situated within a narrow field between the Crondall Road lane and the linear tree belt to the east. At its narrowest point, the field is only 18m wide yet even within this constrained area the field is identified for development. To achieve access to this constrained parcel, the masterplan scythes two access roads through the tree belt and removes a significant portion of Lawn Copse. There is also a question over the development form which fronts the lane. Given its position on the outer edge of the scheme we would normally expect a 'broken' development form rather than continuous frontage terraced forms.
Courtyard parking 3.17. The high density nature of the scheme leads to an over-reliance on the use of courtyard parking at the back of the blocks. This is an approach to parking which has increasingly become discredited as a standard method for accommodating parking, primarily because of the safety and security issues that the lack of natural surveillance creates. It is also an urban solution which seems out of kilter with this rural setting.
Capacity Analysis
3.18. We have prepared two measured plans investigating the Northbrook Park Masterplan:
. Analysis Plan 1 is the Savills site analysis which uses OS data, GIS data and Flood Risk information from https://flood-warning-information.service.gov.uk. . Analysis Plan 2 is the Fabrik masterplan overlaid with our approximate measurements for each land use (drawn from the PDF in the information pack).
Net Residential Development Area 3.19. In Analysis Plan 1 we have measured a net residential developable area of only 13.6 Ha compared to Fabrik’s 15.4 Ha in Analysis Plan 2. We think that the difference in areas is due to Fabrik not providing the appropriate buffers of 10m to woodland and 15m to Ancient Woodland.
Density 3.20. We think that there is huge discrepancy about the actual density of the scheme. When we measure the net density (e.g. the net housing areas excluding open space) the actual density is 59dph in Analysis Plan 1 and 52dph for Analysis Plan 2 for the proposed 800 units.
3.21. The Information Pack for Northbrook Park states a 32dph GROSS density. We believe that this figure is derived by taking the developable area PLUS public open space for the area north the A31.
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3.22. At the density promoted in the Information pack (32dph) a correct net density only yields 435 units.
Flood risk 3.23. Analysis plan 1 demonstrates that the area for proposed employment is actually within Flood Zone 3. However, it is not clear from the Information Pack whether they have allowed compensation land to accommodate this loss. This should be subject to further technical assessment to understand whether even less developable area is achievable.
Formal Recreation Provision 3.24. The only formal sports pitches are provided as part of the (small) primary school. It would seem that they have not provided the appropriate quantum of formal recreation. E.g. they do not meet FiT standards.
SANG 3.25. Natural England provides guidelines for the creation of SANGS15: “ SANGS are intended to provide mitigation for the potential impact of residential development on SPAs by preventing an increase in visitor pressure on the SPA. The effectiveness of SANGS as mitigation will depend upon the location and design. These must be such that the SANGS is more attractive than the SPA to users of the kind that currently visit the SPA… The identification of SANGS should seek to avoid sites of high nature conservation value which are likely to be damaged by increased visitor numbers.”
3.26. The SANG proposed for Northbrook Park is both insufficient, unattractive and located in an area of priority habitat.
3.27. Thames Basin Heaths SPA requires 8Ha of SANG per 1000 population. For 800 units at an occupancy rate of 2.4 persons per dwelling, this would be a population figure of 1,920 and would therefore trigger a need for 15.36Ha of SANG. The Northbrook Information pack states 15.4Ha of SANG. Our Analysis Plan 2 illustrates that there is 17Ha of SANG of which 6.7Ha is outside of the District Boundary. The total area of SANG within the district boundary is only 10.3Ha, which could only support 536 dwellings.
3.28. The Northbrook Park Ecology Technical Note identifies a number of issues with the proposed SANG. The proposed SANG is remote from the residential part of the site by being located to the south of the A31. This could affect the functionality of the SANG by reducing future occupant’s propensity to use it and could indirectly put pressure on the ancient woodland within the site as an area for recreation and dog walking because of its proximity in comparison the SANG.
3.29. The SANG is proposed in a flood zone, utilising priority habitats (coastal and floodplain grazing marsh grassland or rush pasture; likely to be of importance to wading/ground nesting birds). It is unknown as to whether the proposed use of the land as SANG for recreational purposes is compatible with the area’s status as a priority habitat and the importance of the North Wey has been raised in the EA consultation response. Additionally, in order for the SANG to be functional during the times of the year when the area is likely to be flooded, a raised walkway would have to be provided. Raised boardwalks may not be an attractive/suitable route for dog walkers when the SANG is not flooded and therefore shortcuts/different
15 Natural England SANGS Guidance (July 2007)
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routes through sensitive bird nesting habitats may be created.
3.30. Due to the location of the employment land and travellers’ pitches, the area to the south of the A31 will likely be affected by artificial lighting, noise, and disturbance in a previously undisturbed area. The traveller pitches would result in the presence of people in the evening/night-time close to the SANG and it is not clear what kind of employment opportunities would be present within the employment land (i.e. night-time work/access and security lighting may be required). Unmitigated, these effects could have adverse impact on nocturnal species such as bats, as well as nesting birds, and other species.
Minerals 3.31. The Hampshire County Council online policies map shows the Northbrook Park site as being located within an area which indicatively contains deposits of Brick Clay and Superficial sand/gravel. It is not clear whether extraction of minerals on the site might be required. More clarity is necessary before any allocation as this could have a bearing on delivery and timing. The site is also within close proximity of the Alton Road Sandpit, which has permission for extraction, filling and restoration over 11.5 years and the movement of up to 170 HGV movements to/from the site off/onto the A31 per day. The number of HGVs permitted is likely to put further pressure on the A31. It is not clear whether this operation will have a significant adverse effect on the proposed development, infrastructure and delivery.
Consultation question NBP2: What infrastructure is required to support the proposal and when? This could be on or off-site provision.
3.32. The promoters of Northbrook recognise the importance of delivering social and physical infrastructure early in the development programme. This is fundamental given that Northbrook is in an isolated location, which will be reliant on the use of the private car even with the delivery of any new services. Sections 3 and 5 of Technical Paper 216 demonstrate the barriers to delivering non-car use and how inaccessible Northbrook is to existing employment work places and supermarkets. Interestingly, Northbrook Park’s nearest food stores are in Waverley Borough. The TCPA17 identifies the provision of services for day to day needs within walking distance of homes as one of the key principles for delivering a successful garden village. The delivery of the Local Centre and the identified uses is therefore of the utmost importance and EHDC need to be absolutely assured that these facilities and services will be both deliverable and then as importantly sustainable for the future.
3.33. Our Master plan and capacity analysis has already raised fundamental technical questions over the actual quantum of development that can be delivered on this constrained site. Our conclusions shows that the actual net developable area is 13.6ha north of the A31 which at 40dph a maximum capacity of only 540 dwellings can be achieved. However, when using the density which is being promoted within the design philosophy presented by Northbrook Park in the Information Pack (32dph) then the housing yield is only 435 units. Delivery of these units to provide a critical mass to support a local hub, shops and pub is an absolute requirement and even at the optimistic number of 800 units which is being promoted the viability and sustainability of these services is highly questionable. Any shortfall in the housing
16 Technical Paper 2: Land at Northbrook Park (Calibro, October 2019) 17 Understanding Garden Villages An Introductory Guide (January 2018)
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numbers would then be terminal for delivery of the local centre.
3.34. In light of its isolated location, Northbrook promoters have been forced to set out an incredibly ambitious infrastructure delivery programme before any dwellings are delivered. As a result the funding of and timing of the infrastructure shown to be delivered in Year 1 to 3 of their delivery timescales should be subject to most rigorous scrutiny. When planning large scale development EHDC should ensure that their size and location will support a sustainable community18. It is not clear that the size and location of Northbrook would support a sustainable community with sufficient access to services and employment opportunities within the development itself.
3.35. In Year 1 and 2, the Information Pack states that the new roundabout at the A31 and essential infrastructure will be in place. This could also include the upgrade to the Public Sewerage system requested by Environment Agency. To secure and implement the relevant planning and technical consents will take considerable time and cost particularly as the A31 roundabout is online. HCC will want to ensure the efficiency of this important A road during construction.
3.36. In Year 3 the internal roads and plot services will be implemented as well as the construction of village shops, Pub, and Hub. Retail and Pub operators have specific space requirements and it is unlikely an operator will be in place during these enabling phases before any houses and potential custom have moved into the new scheme.
3.37. The SANG and its associated infrastructure such as the pedestrian bridge across the A31 will also be provided before the end of Year 3. These both require a raft of consents and approvals from a number of statutory bodies. These again will have implications for the trajectory as well and the infrastructure costs in the first three years before any dwellings are delivered.
3.38. The infrastructure being delivered in Year 1 to 3 include:
. New A31 Roundabout . Essential site enabling infrastructure and services . Internal Roads and plot services . Construction of Retail shops, Local Hub, Community Hall and Pub . Completion of pedestrian bridge over the A31 . Completion of the 15.4 ha SANG
3.39. SCC have also raised the need for a relief road to mitigate the impacts on the community in Wrecclesham.
3.40. The cost of this enabling infrastructure should be estimated and form part of the evidence base before allocations are selected for next stages of the draft Local Plan. Our estimates show that the cost of the A31 roundabout, pedestrian bridge and SANG alone would be in excess of £6.5m. A shared footway/cycleway would in addition cost a further estimated £1.35m. Table 2 of Technical Paper 2 estimates a figure of approximately £24m in total costs for the infrastructure, including the costs of the
18 NPPF paragraph 72 b)
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serviced land parcels. This is not an exhaustive list of costs but demonstrates the level of up front infrastructure being put forward by the promoter.
3.41. The Information Pack states that most of these infrastructure items are to be completed prior to completion of the first phase of housing which is not planned until Year 4. This raises significant cash flow concerns and ability of the landowner/developer to raise funding to finance all of this key infrastructure in advance of land or sales receipts. The cash flow is even more questionable with an annual delivery of 60/65 units of which 40% are affordable homes.
3.42. The Information Pack proposes a £6m Bond to secure the funding for the Village Charter in perpetuity (although it later says for a period of 10 years) which will be used to fund ongoing management but there is absolutely no assurance of how the key infrastructure listed above will be delivered or funded. The Information Pack states that the company has a net worth of £25m to demonstrate that it can guarantee the Bond but it is without question that significant funding will need to be secured to finance the enabling and up front infrastructure. This finance will need to be secured for a number of years without the guarantee of rent or sales from the retail pre lets, pub operators and sales receipts from the residential phases. This will put tremendous strain on the viability and deliverability of the scheme which could result in very long lead in times and the ability of the scheme to support other important policy requirements such as Affordable Housing if the viability becomes marginal or negative.
3.43. Given the isolated location, the delivery of the local centre and the primary school are fundamental. The viability of pub in this location, with or without passing trade needs to be evidenced. There is evidence of pubs close to Northbrook that have the benefit of trade from the A31 which are already closed and for sale. The former Bull Inn, located on the A31 just outside the south west corner of the site has been closed since early 2017. It is likely that the provision of 3 shops within the site is unlikely to be viable given the limited population and inability to attract passing trade. The occupation of the shops, hub and pub is also vital to sustain the future of the Village Charter. The rents from these facilities are fundamental to the finances of the Charter. If operators are not secured or suitable rent achieved, this will put pressure on the Management and Village Trust and ultimately the level of service charges imposed on the new residents.
3.44. The provision of a 30 minute shuttle bus would also need to be heavily subsidised adding further financial burden on the scheme. Para 4.7 of Technical Paper 2 estimates these costs to be £150,000 per annum. Investment in the existing bus services is also required which Stagecoach do not support in their March Reg 18 representation
3.45. The proposed allocation claims to be a mixed use scheme but is reliant on access via an over-bridge across the A31 to provide connectivity between the residential area to the north and limited employment uses to the south. Moreover, given concerns regarding the commercial viability of local bus services operating within the site, there would be a requirement for residents and staff associated with the employment use to access existing bus services operating along the A31, using the proposed footbridge to access such services. However, national guidance contained in MfS and DMRB states that footbridges should be avoided, especially where the topography does not avoid the need for ramped/stair access. Consequently, an allocation of this site would represent poor plan-making since reasonable alternatives for development are available which are not reliant on undesirable infrastructure that would further
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reduce the propensity to walk and cycle.
3.46. The proposed allocation also relies on a proposed cycleway along the northern verge of the A31 to connect to Farnham. However, this would not address the undesirable environment that is created alongside a high speed (70mph) dual carriageway and there are technical difficulties in how the cycleway could safely continue over at least five junctions, and accommodate requisite signage infrastructure without impeding flow.
Consultation question NBP3: Do you know of any other constraints to developing the site? Please provide detail and evidence.
3.47. The Savills Analysis Plan 1 demonstrates the overlap of Flood Zone 3 into the area designated for Employment and SANG In the Northbrook plans. The site is also susceptible to surface water flooding and groundwater flooding. The Environment Agency requires a Level 2 SFRA and that the allocation must satisfy the Exception test to be deliverable. It has not been demonstrated that the proposed uses and layout of the site are compatible with the water environment.
3.48. In general terms the Sustainability Appraisal19 recognises the constraints of Northbrook Park:
. Landscape and townscape . A number of biodiversity designations . Flood risk in terms of flood zone 3 and areas of high surface water flood risk . The site’s rural location in terms of the provision of sustainable transport . Heritage
3.49. The East Hampshire Landscape Capacity Study20 specifically identifies a low capacity for development for both Local Areas that the Northbrook site falls within (4b.1 Alton to Bentley, north of A31 and 4b.2 Alton to Bentley, south of A31). The concluding paragraph to each Local Area ends with a recommendation that, outside of a very small amount of development, the area should otherwise remain undeveloped. A large development on both sides of the A31 would not comply with the recommendations of the Study. The Study’s relevance to Northbrook Park is detailed in the Landscape Analysis submitted with this representation21.
Consultation question NBP5: What are the cross-boundary considerations and the potential implications? How can they be overcome?
3.50. Paragraph 24 of the NPPF places a duty on local planning authorities and County Councils to cooperate with each other on strategic matters that cross administrative boundaries. The Northbrook site is located hard up against the boundary with Waverley/Surrey and is located closer to Farnham than any settlement of comparable size in East Hampshire. 6.7ha of SANG required to mitigate against the
19 Sustainability Appraisal (SA) of the emerging East Hampshire Local Plan Interim SA Report (December 2018) 20 East Hampshire District Council Landscape Capacity Study (September 2018) 21 Northbrook Park: Landscape Analysis (Tyler Grange)
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impact of Northbrook is located over the boundary within Waverley/Surrey.
3.51. Farnham Town Council, Waverley Borough Council and Surrey County Council objected to Northbrook as part of the East Hampshire Reg18 consultation. Furthermore, Farnham Town Council assessed and chose not to include land at Northbrook Park as an allocation within modifications to the Farnham Neighbourhood Plan22. Farnham’s assessment identified the remote location of Northbrook Park, viability in the face of significant advance infrastructure and services to be provided, and a significant detrimental impact on landscape of high sensitivity. The amendments to the scheme since the Reg18 consultation are unlikely to overcome the issues identified.
3.52. The proximity of Northbrook Park to the administrative boundary and service centre of Farnham is likely to result in consumer spend being made outside of East Hampshire that would contribute to the deficit against benchmark turnover identified by EHDC23. This potential negative economic outcome should be carefully considered.
3.53. WBC declared an Air Quality Management Area in Farnham in 2005 and a Borough wide Air Quality Action Plan in 2008. The Farnham Herald has launched a ‘Cut the Pollution’ campaign24 and the local MP has called for an emergency pollution summit for Farnham. The attraction of Farnham for any future occupants of Northbrook Park as a destination for shopping, as a place of work or as a place through which to commute, and their reliance on journeys by car to do so, is likely to exacerbate the air quality issues identified in the town. This negative cross boundary issue should be considered.
22 Farnham Housing Land Availability Assessment (December 2018) 23 Table 4.4 East Hampshire Retail and Main Town Centre Uses Study Final Report (October 2018) 24 Farnham Herald website 30 September 2019
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4. Whitehill & Bordon
4.1. The table below sets out a summary of statutory consultee representations to the March Reg 18 submission for Whitehill & Bordon.
Consultee Objection / specific issue Comment summary Both new SANG’s proposed as mitigation for increased recreational pressure are areas of high bio-diversity designated as SINCs. The ability to change the use of these SINCs while Natural England SANG maintaining and enhancing their biodiversity in line with other Policies requires assessment at Plan level before this option can be confirmed at Regulation 19. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of Sewage treatment works the development. The scale, location and Southern Water capacity delivery timescales of any required network upgrades will be determined once Thames Water have required information on location, type, scale and phasing of development. The Local Highway Authority’s Transport Strategy for Whitehill & Bordon is based and tested against the ‘current’ quantum of development set out in the Masterplan. The LHA Hampshire County Council Highways is concerned that additional development at that location could prejudice the delivery of the Transport Strategy, particularly elements relating to the local highway network. We have concerns about the additional dwellings proposed in Whitehill Bordon and the potential to generate significant increases in traffic on the Surrey County Council Highways already overstretched network of the A325, through Wrecclesham, and on the A31 Farnham Bypass. We are concerned that significant additional traffic will arise from this site, and that the additional local traffic will displace through traffic, South Downs National Parks Authority Highways & SANG with potential negative impacts on the SDNP’s setting. It will be essential that sites mitigate against harm to the Wealden Heaths and any SANGs must be provided and of high quality,
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and not undermined or reduced in quality in the future.
4.2. Savills, on behalf of Harrow Estates, does raise concern on the potential over reliance of Whitehill & Bordon for the reasons set out in the consultation questions below.
Consultation question WB3: Do you know of any other constraints to developing the site? Please provide detail and evidence.
4.3. The table above highlights the comments received from the statutory consultees. To deliver the additional units at the Strategic Development Area (SDA) four new smaller SANGS will be need to be provided in advance of these homes. These SANGS (Slab, Oxney, Broxhead and Gibbs Lane) vary in size and character. It is acknowledged in the Information Pack that the SDA is subject to a number of nature and ecological designations, these include SINCs and Priority Habitats and from the master plan it appears that felling of habitat woodland will be required. Prior to any allocation being confirmed, the Regulation 19 draft Local Plan should be supported by a robust evidence base as well as Natural England (NE) approval demonstrating that these additional houses will not only mitigate any ecological adverse impact but that the multiple SANGS meet the design criteria set by NE. The capacity for a further additional 1,300 units should be scrutinised.
Consultation question WB6: Is there any reason that this is not achievable?
4.4. Policy S1.5 of the draft Local Plan states that the minimum housing requirement in the period 2017 to 2036 is 10,456 units across the District (excluding the South Downs National Park area). The supply Table on page 54 of the draft Plan sets out how many units that the Whitehill & Bordon Strategic Development Area (SDA) will deliver and this shows a total 4,424 units (excluding Hollywater and Whitehill Road). This supply consists approx. of:
. Bordon Garrison 3,700 (2,400 units approved plus the additional 1,300) . Louisberg Barracks 500 units . Mill Close Academy 150 units (Policy SA12)
4.5. Therefore, the SDA will provide 42% of the total housing supply. This does raise concerns of an over reliance on the SDA. If there is any delay to the SDA programme which can be typical of projects of this scale or if the market absorption rates fall then then the overall housing supply in the District will fail.
4.6. Whilst it is acknowledged that new infrastructure such as the relief road, Hogmoor Inclosure and the secondary school are either complete or under construction, the actual number of housing units completed to date is very low which increases the concerns over market absorption and makes the delivery trajectory even more acute. The Information Pack states that the additional 1300 units can be delivered within 10 years but the Opportunities section highlights that whilst Louisberg and Quebec Barracks are underway, Bordon Garrison has only 480 units approved under Reserved Matters with more applications submitted in summer 2019.
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4.7. When further scrutinising the Supply Table on p53 & 54 of the Draft Local Plan25 this shows that in 2017 138 units had been completed on Louisberg Barracks and 79 on Quebec. That leaves a total of 4,207 units to be constructed and completed in the remaining 18 years of the draft Local Plan Period. This is an average of 233 units per annum which is an optimistic annual delivery target which has not yet been proven in the Bordon market area. It becomes even more unrealistic when the Information Pack states it can deliver the additional 1,300 units in 10 years and at the very best this will likely be at the back end of the plan period.
25 Draft Local Plan 2017-2036 (Regulation 18) Consultation 5 February-19 March 2019
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5. Extension to Land East of Horndean (Hazelton Farm)
5.1. The table below sets out a summary of statutory consultee representations to the March Reg 18 submission for Land East of Horndean.
Consultee Objection / specific issue Comment summary The Land East of Horndean Road, Rowlands Castle site is within the setting of the Grade II listed Pyle Farmhouse and two other listed structures. The development of this site should Historic England Setting of listed buildings preserve or enhance the setting of these buildings and this should be included as a requirement in the allocation policy if this site is taken forward. The site abuts the SDNP, which lies to the immediate east. Pyle Lane and Pattersons Lane are rural in character, and form an important part of the setting of the National Park, the boundary of which runs along these roads. We recommend strengthening the policy to specify that new housing on these lanes is of a lower scale and density compared South Downs National Park Authority Setting of the National Park with other parts of the site, and is set back behind the existing roadside vegetation, in order to avoid a hard wall of development along the SDNP boundary. This is to ensure that development along these lanes is of an appropriate scale and density to reflect the rural character and transition between the built up area of Horndean and the rural area of the SDNP.
5.2. Savills, on behalf of Harrow Estates, objects to Land East of Horndean for the reasons set out in the consultation questions below. It is noted that policy HN1 of the Housing and Employment Allocations Plan26 , which forms part of the current development plan, allocated Land East of Horndean with an indicative timeframe of 2017-2023. Outline permission 55562/001 was originally granted for a maximum of 700 dwellings in February 2016. This permission has lapsed. A new outline application for up to 800 dwellings (55562/005) was submitted in December 2018 that is still yet to be determined.
Consultation question HD2: What infrastructure is required to support the proposal and when? This could be on or off-site provision.
26 East Hampshire District Local Plan: Housing and Employment Allocations, April 2016
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5.3. Any future allocation would need to demonstrate that it can provide the infrastructure required to meet the needs of future occupants. In the case of Land East of Horndean, the HCC consultation comment to application 55562/00527 raises that the secondary school at Horndean Technology College is full and is forecast to remain so for the foreseeable future. Not only is the existing application impacted by this but any future allocation would put further pressure on schools in the area and HCC have not yet undertaken feasibility studies or consultation to identify the best way of accommodating the additional demand generated for school places. HCC are seeking a contribution of approximately £4.2m to expand Horndean Technology College for application 55562/005. It is not clear that the demand for places that an allocation for an additional 1,000 dwellings in the area could be accommodated at the College.
Consultation question HD6: Is there any reason that this is not achievable?
5.4. As set out in paragraph 5.2, outline application 55562/005 for an existing allocation is yet to be determined. At this point in time, even without further delays, it appears unlikely that the allocation under policy HN1 of the current Housing and Employment Allocations Plan will be completed before 2030. The EHDC 5YHLS Position Statement (July 2019) sets out that the first units are expected to be delivered in 2022/23 and the Design and Access statement that supports the application indicates 7-10 years for the development to be completed.
5.5. This is significant, as page 8 of the Information Pack document for the proposed allocation states that “if development is approved it is likely to follow after development of the LEOH site to the north.” Considering that the proposed allocation is for 1,000 dwellings, should development follow a similar timetable to the current allocation under policy HN1, it is unlikely that the development could be delivered within the Draft Plan period.
5.6. One likely source of delay is the potential impact on the Solent International sites. Natural England is seeking to achieve nutrient neutrality in the Solent region and recommends that any proposal which includes residential accommodation is accompanied by an appropriate assessment of calculating nutrient budgets. Land East of Horndean would affect this region.
5.7. The latest consultation response from Natural England on application 55562/00528 advises that the nutrient budget submitted does not allow the competent authority to be assured that the scheme will not lead to additional nutrient loads to the Solent International sites. This is clearly an issue for the current application that may prohibit the deliverability of housing on the allocated site. Should the allocation under policy HN1 not be delivered EHDC would be required to find an alternative site to deliver the 700 dwellings required by policy HN1.
5.8. Having regard to the need for nutrient neutrality in the Solent region it is likely that any future allocation on Land East of Horndean would also be impacted by this issue. Not only would a future allocation have the potential to be undeliverable, but also have an impact on the soundness of an updated local plan.
5.9. It is notable that there are objections to application 55562/005 on landscape grounds from the South
27 Dated 06 August 2019 28 Dated 20 September 2019
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Downs National Park Authority29. The site sits adjacent to the National Park and the SDNPA continues to object that the application does not address the landscape impacts of the proposal in terms of the impact of the development on the setting of the National Park. A future allocation of Land East of Horndean would also likely have an impact on the setting of the National Park given its proximity.
29 Dated 23 August 2019
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6. Land South East of Liphook
6.1. Savills, on behalf of Harrow Estates, objects to Land South East of Liphook for the reasons set out in the consultation questions below.
6.2. Awaiting comments
Consultation question LP1: Do you have any comments on the proposed uses?
6.3. The Information Pack refers to the site as being well located and accessible to the centre of Liphook with its associated services and facilities. As an extension to the Tier 2 settlement the majority of the site is actually beyond a reasonable walking distance to these facilities when on the ground. This was recognised by the Planning Inspector in upholding an enforcement notice for a site east of Devils Lane in 201630, which concluded at paragraph 87 of his decision, ‘…it was highly unlikely that the facilities in Liphook would be accessed on foot by the occupiers of the Appeal Site because those facilities are not, in my assessment, within a reasonable walking distance. It is also clear that the position of those bus services mean that it is unlikely that those bus services would be utilised by the occupiers of the Appeal Site.’
6.4. Whilst it is acknowledged the promoter’s proposals open up access into Willow Gardens, which would not have been a consideration by the Inspector for the Appeal proposals, the fact remains that the majority of the site would be beyond a 10 minute walk to even the Station walking on the ground, with only those units closest to Willow Gardens afforded an opportunity to get close to a 10 minute walk. The proposals south of Chiltley Lane are unlikely, we suggest, to use Willow Gardens. So instead would rely on either Chiltley Lane or Highfield Lane for pedestrian/cycle routes, which comprise rural lanes with no footpaths or street lighting for significant sections. Taken as a whole therefore, the Inspector’s comments remain valid in our opinion. A greater dependency on the private car may well be a consequence of this, which should be accounted for in sustainability assessments to the detriment of this location.
6.5. With regards to cumulative highway impacts, it is noted from the Atkins Liphook Phase 2 Transport Feasibility Study (2018), a report commissioned by HCC and used by EHDC as evidence for the emerging Local Plan, that peak time traffic congestion is primarily traffic moving from the east of the village to the west in the morning and vice versa in the afternoon. The extent of growth proposed at this location is likely to exacerbate such congestion, particularly at The Square and other central junctions that are reported to be approaching or exceeding capacity. Reference is made by the promoters to off- site improvement works by way of mitigation, but no detail is provided over what such works are, or how and when they would be delivered. It is equally unclear whether this would provide any betterment for the community, or just maintain the status quo by mitigating additional traffic generated by the development
6.6. The impact of the traffic generated from these proposals on the character and amenity of the narrow rural lanes of the area should also be evidenced; Devils Lane and Chiltley Lane in particular. The Planning Inspector when upholding the enforcement notice for the site east of Devils Lane referenced in
30 APP/M1710/C/15/3024015
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paragraph 6.3 concluded on such matters at paragraphs 50, 64 and 69 and 71. In respect of the removal of existing hedge to form a single access (as opposed to the multiple access points proposed by the SE Liphook promoter), the Inspector concluded, ‘I am of the view that the loss of the hedgerow would be wholly detrimental to the character and appearance of this part of Devils Lane and would severely impact the enjoyment derived by users of Devils Lane.’ The Inspector concluded likewise regards the impact of additional traffic on such a narrow single track rural lane, for a comparatively minor proposal, not the 600 homes plus ancillary uses proposed here. The Inspector had highway safety concerns regards the narrowness of the lane and lack of passing places, which if rectified would similarly impact negatively the character of the lane (paragraph 64). At paragraph 69 of the same decision the Inspector concludes, ‘I therefore conclude for the reasons explained above that the additional traffic generated by the proposed use along the relevant stretch of Devils Lane would not be safe or convenient for users of that highway. The proposed use should be prevented on transport grounds because the impact of the proposed use on the safe and convenient use of Devils Lane would be severe. For the reasons explained above, there would be conflict with the relevant parts of the Core Strategy (our emphasis). Finally, the Inspector raised highway safety concerns regards the junction with Devils Lane and Highfield Lane (paragraph 71).
6.7. There is insufficient justification or evidence provided for a satellite school or annex to other schools in the area in this location. This appears to be acknowledged on page 14 of the Information Pack which states “The delivery of a school here would be subject to existing capacity and delivery timings”. Harrow Estates are concerned this will merely fragment school facilities across Liphook, making them harder to service and maintain in the longer term.
6.8. The proposed SANG is isolated from the proposed development and lies with the SDNP. This will therefore require cross boundary approval and there is no guarantee of delivery. The irregular shape of the SANG will also need to comply with Natural England’s Design Guidance and to ensure that the area promoted will actually deliver the SANG requirement of 15.4 ha. In addition the SANG land is designated as Priority Habitat which will require further scrutiny of the suitability of the SANG land. The proposed SANG would necessitate access via narrow rural lanes with no footpath or lighting along significant section which is highly likely to encourage driving to the SANG.
Consultation question LP5: What are the cross-boundary considerations and the potential implications? How can they be overcome?
6.9. Approval of the SANG will be required from SDNP as this part of the proposal lies outside the EHDC boundary.
Consultation question LP6: Is there any reason that this is not achievable?
6.10. The large development site is in control of a number of landowners and developers as confirmed in the Information Pack. These fragmented land ownerships will make the delivery of essential and necessary social and physical infrastructure uncertain. We understand that there are no formal consortium agreements in place and all the land interests have been brought together as part of this consultation exercise to demonstrate that they can be defined as a Large Development Site (over 600 units). Previously, the sites were submitted as smaller individual sites. Without any formal agreements or equalisation there is the real possibility that the school, local centres and other community facilities will
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not come forward and certainly not early in the delivery programme.
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7. Four Marks Sites
7.1. Savills, on behalf of Harrow Estates, objects to the sites at Four Marks for the reasons set out in the consultation questions below. For clarity this representation does not repeat the same point for each site as they are relevant to both.
Consultation question FMS2 & SWR2: What infrastructure is required to support the proposal and when? This could be on or off-site provision.
7.2. Both of the options at Four Marks South and Land South of Winchester Road share the same fundamental constraint of the lack of local social and physical infrastructure in this location. Four Marks is defined in the Joint Core Strategy31 as a Tier 3 Small local service centre which is described as a location with a more limited range of services.
7.3. The JCS in Policy CP10 also allocated a minimum of 175 dwellings at Four Marks and whilst it is acknowledged this is a minimum figure, the actual number of completions and planning permissions have far exceeded that number. Indeed the recent appeal at Friars Oak Farm Medstead32 in paragraph 20 stated:
“Since 2011 close to 400 dwellings have been granted planning permission in the Four Marks/South Medstead area, which is a number more than double the minimum target of 175 dwellings identified in Policy CP10”
7.4. This considerable level of growth has put more pressure on the limited local services and meant Four Marks has become even more of a dormitory town with significant reliance on the private car. Employment opportunities are also limited which encourages residents to travel to work to Alton, the main Market Town, and further afield to key centres such as Winchester, Farnborough and Guildford.
7.5. Therefore any further additional growth at the scale envisaged in the Information Packs would require the delivery of significant social and physical infrastructure before any new housing was completed. In essence Four Marks should at the very least become a Level 2 Large Service Centre to service the current rate of unplanned growth before even more growth is contemplated.
Consultation question FMS6: Is there any reason that this is not achievable?
7.6. Throughout the Sites Assessments Background Paper in Appendix 2 it is confirmed the Large Development Site is in multiple ownerships. This fragmented land ownership will make the delivery of essential and necessary social and physical infrastructure uncertain. We understand that there is no formal consortium agreement in place and all the land interests have been “thrown” together as part of this consultation exercise to demonstrate that they can be defined as a Large Development Site (over 600 units). Previously, the site was submitted as smaller individual sites, many of which were by
31 East Hampshire District Local Plan: Joint Core Strategy (June 2014) 32 APP/M1710/W/19/3225766 Land at Friars Oak Farm, Boyneswood Road, Medstead
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developers.
7.7. Without any formal agreements or equalisation there is the real possibility that the school, local centres and other community facilities will not come forward and certainly not early in the delivery programme.
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8. Neatham Down
8.1. Savills, on behalf of Harrow Estates, objects to Neatham Down for the reasons set out in the consultation questions below.
Consultation question ND1: Do you have any comments on the proposed uses?
8.2. The proposal at Neatham Down will breach the physical boundary of the A31. Whilst the Information Pack suggests that the site sits within a natural enclosure provided by ridgelines, any development breaching the A31 will be the first significant urban development at Alton south of the A31. This precedent should not be considered when there is another reasonable alternative at Alton which:
. is supported by a robust and credible base . is visually self-contained, . is north of the A31 and; . is not in close proximity to the National Park boundary.
8.3. The Information Pack supporting Neatham Down seeks to promote a new community of 600 homes supported by a village shop, pub and primary school. This critical mass raises serious questions over the deliverability and viability of these critical services. The ability of this proposed development of 600 homes to sustain any retail or pub is highly questionable and without any passing trade this makes the delivery of this services extremely difficult. Without pump priming these services at the expense of other uses (such as affordable housing) these services will not be delivered making the development unsustainable.
8.4. HCC Guidance33 states that the minimum usable area for a 2FE Primary School needs to be at least 2.0ha. HCC has a preference for delivering 2FE entry primary schools yet the child yield of 600 units (180 pupils) will not even yield enough places for a 1FE entry school. This raises significant doubts over the suitability of this site for a primary school.
School type School size Total site area 1fe (210 places) 1.2 ha Primary 2fe (420 places) 2.0 ha
Consultation question ND2: What infrastructure is required to support the proposal and when? This could be on or off-site provision.
8.5. The proposed allocation proposes an electric shuttle bus service operating between the site and Alton railway station. However, reflecting on earlier representations of the local bus operator, Stagecoach, has confirmed in an email dated 14th October 2019 (copy in Technical Paper 334) that the proposed quantum
33 Hampshire County Council Developers’ Contributions towards Children’s Services Facilities (November 2018) 34 Technical Paper 3: Neatham Down (Calibro, October 2019)
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is insufficient to enable the viable diversion of the existing Number 65 bus service. The proposal for an electric shuttle bus service between the proposed allocation and Alton town centre would also be both unviable in perpetuity and would be technically difficult to service from the distant bus depots in the region.
8.6. We are aware, from involvement in the nearby Lynch Hill employment scheme (now consented) that the A31/Montecchio Way roundabout operates at capacity and results in vehicles queuing back considerably along Montecchio Way into Alton. Any proposal to create an additional source of demand at the junction, whereby significant demand will cross in front of the Montecchio Way approach will materially reduce capacity for traffic emerging from Alton and exacerbate the extent and duration of existing queues. This effect being emphasised by the likely over reliance of the private car at Neatham Down given a lack of infrastructure serving the wider region, especially by bus.
8.7. Technical Paper 3 that supports this representation details that the proposals for an at-grade crossing over the A31 are flawed in safety terms. The A31 is a road of county strategic importance and its efficient operation is therefore fundamental to the economic success of the region. Any safe crossing is likely to require the reduction in speed limit and/or introduction of traffic light control across the dual carriageway, both of which would increase travel delay along this strategically important route. Moreover, there is an over-reliance on the existing overbridge across the A31 and this recognised issue with overbridges is referenced within Manual for Streets and the Design Manual for Roads & Bridges. Other proposed alternatives are not reliant on such infrastructure, therefore significant weight should be given to those reasonable alternatives.
8.8. Consequently, the proposal would represent development in an unsustainable location which would not, and could not, be made sustainable, contrary to the requirements of NPPF (72,103, 108b), Objective B and Policy S30 of the emerging EHDC Local Plan. Moreover, any proposed mitigation is likely to impact on the efficiency of the strategic road network which is critical to the regional economy.
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9. Remaining questions
Is there any other Large Development Site that could deliver over 600 homes and other supporting uses by 2036, that is not included in this consultation?
9.1. No
Do you have any comments on the assessment of Large Development Sites, as set out in the Council’s background paper?
9.2. As detailed in Table 8 of the Site Assessments Background Paper35 the scoring process whilst providing a very high level form of assessment is also quite arbitrary. Whilst it provides a guide for selection purposes into consultation stage it should not be used for more detailed assessment and site selection of the preferred sites.
9.3. For example, the distance from a town centre or local centre is scored the same in the traffic light system as red if the site is 1.5km away. A site that is located 1.5km from a Town centre or the Tier 1 centre of Alton cannot be scored in the same way as a site which is 1.5km from a local centre. Indeed a site which is even within 800m of a Local Centre and scored green will not have access to the same level of services as Chawton Park which with its bus, cycle and pedestrian routes far more accessible to services.
9.4. Another example is Heritage. Chawton Park Farm is scored Red in the assessment given it is located within 50m of listed building. The Chawton Park Farm Heritage Assessment submitted with this representation has identified that the emerging masterplan for Chawton Garden Village is likely to result in less than substantial harm at the lower end of the spectrum to one Grade II Listed building, Chawton Park Farmhouse. This demonstrates that more detailed assessment is required for the selection of preferred allocations.
Is there any feedback you would like to give us about this consultation?
9.5. Harrow Estates and its team attended a Feedback Session with Officers on the 7th October as part of the Consultation process.
35 Site Assessments Background Paper For the East Hampshire District Local Plan Large Development Sites Regulation 18 consultation (September 2019)
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Director Planner
savills.co.uk Harrow Estates October 2019 1
Chawton
12147_R05 Northbrook Park: Landscape Analysis
1.0 Introduction
1.1. Tyler Grange Group Limited (TG) considers in this short technical report, the documentation presented within the Northbrook Park Large Development Site Information Pack September 2019, which provides an overview relating to the proposals.
1.2. This has been undertaken as a high-level landscape and visual analysis based on field and desk studies for Harrow Estates PLC.
1.3. The Northbrook Park site is one of ten “Large Development Sites” considered by East Hampshire District Council as part of the current Local Plan consultation process.
1.4. The production of the Draft Local Plan has been informed by the Council’s evidence base and with regard to landscape matters the key documents include the “East Hampshire District Council Landscape Capacity Study” (September 2018) produced by Terra Firma and the AECOM “ Interim Sustainability Appraisal (SA) Report” (December 2018). It is noted that of the sites assessed within the SA report, (including Chawton Park and Northbrook Park amongst others), that Chawton was the best performing against all other options.
1.5. This technical report considers the performance of Northbrook Park site in terms of landscape and visual matters and has been undertaken by an experienced Chartered Member of the Landscape Institute (CMLI).
2. Background
East Hampshire District Landscape Capacity Study (Terra Firma 2018)
2.1. The “East Hampshire District Landscape Capacity Study” (Study) was produced by Terra Firma Consultancy Limited in June 2018. The Study informs the evidence base for the Draft Local Plan and at a strategic scale assesses the capacity of the landscape to accommodate housing development outside of settlement boundaries.
2.2. It is noted that the Study has in turn been informed by the “East Hampshire Landscape Character Assessment” (2006) produced by LUC. While this is the base document for Terra Firma’s Study, TG have also considered anything of pertinence arising from the suite of published landscape character assessments that include at a national level the National Character Areas and at a county level the Hampshire Integrated Character Assessment.
2.3. South Downs National Park. (SDNP). Northbrook Park site lies within close proximity, approximately 200m distance from the boundary of the SDNP, one of the highest landscape designations in England. It is agreed by Terra Firma and TG that the site lies within the “setting” of the SDNP. Terra Firma explains below;
Tyler Grange Group Limited Tel: 01285 831804 www.tylergrange.co.uk Registered in England No. 11435090 Vat Reg. No. 326 7564 81 Registered Office: Marsden Estate, Rendcomb, Cirencester, Gloucestershire. GL7 7EX
Birmingham ・ Cotswolds ・ Exeter ・ London ・ Manchester
“For the purposes of spatial planning any development or change capable of affecting the significance of the SDNP or people’s experience of it can be considered as falling within its setting. The scale, height, siting, use, materials or design of a proposed development will determine whether it affects natural beauty and special qualities of the SDNP. A very large or high development may have an impact even if some considerable distance from the SDNP boundary. Therefore, there is no defined boundary where the setting of the SDNP ends. However, distance away from the SDNP will obviously be a material factor in that the further away a development is from the boundary the more impact is likely to be reduced.”
2.4. The closeness of the SDNP designation and implications in terms of adverse effects upon it must be a key consideration.
2.5. Local Areas. Terra Firma have subdivided the District into 41 Local Areas to provide officers with evidence to understand where landscape and visual impacts would be greatest and to identify which general areas may have capacity to accommodate change.
2.6. The Local Areas have been determined by the LUC East Hampshire District Landscape Character Assessment (2006). Northbrook Park occupies a small part of 2 larger local areas that are split by the A31, namely Local Area 4b.1 Alton to Bentley (north of A31) and Local Area 4b.2 Alton to Bentley (south of A31).
2.7. The methodology employed relates to all local areas studied by Terra Firma and an overview of the Northbrook Park fiindings is set out below (bearing in mind that Northbrook Park is split across 2 Local Areas by the A31).
Terra Firma Capacity Study Northbrook Park Local Northbrook Park Local Area Area 4b.1 (north A31) 4b.2 (south A31) Visual sensitivity Medium Medium Landscape sensitivity Medium/high Medium/high Landscape character sensitivity Medium/high Medium/high Wider sensitivity Medium/high High Overall landscape sensitivity Medium/high High Landscape value Medium Medium Landscape capacity Medium/low Low Potential capacity conclusion Medium/low Low
2.8. Considering each assessment result in turn: • Visual sensitivity – both are “medium.” • Landscape sensitivity – both 4b.1 and 4b.2 record “medium/high” scores in terms of natural factors, cultural factors and perceptual features. • Landscape character sensitivity - is a simple combination of visual sensitivity and landscape sensitivity arrived at via a matrix. As a result, both 4b.1 and 4b.2 record high scores of “medium/high.” • Wider sensitivity – the “high” score attributed to 4b.2 reflects strong landscape and visual links and has been assessed as being an important part of the wider landscape. • Overall landscape sensitivity - is a simple combination of landscape character sensitivity with wider sensitivity with 4b.2 attributing the “high” score. • Landscape value – taking both 4b.1 and 4b.2 together, they only record a “medium” score which might be considered to be too low. The data search for ecology has returned higher values in relation to Northbrook Park over a general search area (10km search with a RAMSAR, and some SAC’s and SPA’s but specifically a SSSI at Bentley Station Meadow).This could be considered to elevate both local areas to “medium/high.” • Landscape capacity – this is a matrix combining overall landscape capacity with landscape value. Given the potential to assign “medium/high” values to both 4b.1 and 4b.2, this would mean that both would record a “low” landscape capacity. The classification of low landscape capacity has been described by Terra Firma as follows – “the local area could not accommodate areas of new development without significant
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and adverse impact on the landscape character. Occasional, very small-scale development may be possible providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas.” In any event, 4b.2 remains “low.” • Potential capacity conclusion – Terra Firma conclude that local area 4b.2 has a “low” potential capacity and is heavily constrained by the River Wey and its rural setting and is recommended to remain undeveloped. Regarding 4b.1 within the same valley but north of the A31 potential development capacity is assigned, “low and medium/low.”
2.9. In drawing a conclusion based upon the Study undertaken by Terra Firma, Northbrook Park and in particular 4b.2 (south of the A31) performance in terms of overall development capacity raises concerns about potential development.
3. Northbrook Park Large Development Site Information Pack
3.1. SDNP. As highlighted in section 2 above, in relation to the “East Hampshire District Landscape Capacity Study”, the site lies within the setting of the SDNP, one of the highest landscape designations and at a distance to the nearest point of approximately 200m. The effect of development within the setting, and in particular the proposed employment and gypsy/traveller/travelling show people locations south of the A31, would require careful consideration with regard to the effect on the designation. The introduction of development and in particular the type of development proposed, brings with it other negative aspects of urbanisation that include lighting, massing, vehicle movement, noise and visual interference.
3.2. Similarly, development to the north of the A31 would need to be assessed in terms of the designation as a dense urban settlement is introduced into the rural landscape.
3.3. In addition, any urbanising elements in relation to formal recreation pursuits both north and south of the A31 would require assessment.
3.4. Terra Firma Capacity Study. This has highlighted a “low” potential development capacity for the proposal south of the A31 because of the River Wey corridor and its rural setting with a recommendation that this is not developed. Its contribution to the wider landscape context is recognised.
3.5. Rural Location. The proposal is distant from settlements and remote from existing services and facilities. It occupies an area of countryside with poor east/west interfaces and with poor non- vehicular connectivity, either existing or proposed, with the wider landscape. The introduction of such a large settlement that is isolated in the landscape and with limited east/west containment would result in a significant landscape effect.
3.6. Vehicular dependency. The proposal is car/vehicle dependent. There are limited opportunities to connect with the few Public Rights of Way (PROW) that are located within the vicinity. Only one section passes through the site and this is disjointed, being a dead end from the A31 to the railway line to the south. There are no other potential connections to the PROW network within the wider landscapes that might offer Green Infrastructure (GI) opportunities. A cycle/pedestrian route proposed adjacent to the busy and noisy A31 dual carriageway and separated only by a grass verge does not deliver an attractive opportunity to tempt potential users.
3.7. A31. This is a key constraint. The effect of separation by the busy dual carriageway is significant for a great number of reasons that the introduction of buffer planting, a roundabout and bridge are unlikely to effectively mitigate.
3.8. Open Spaces. The distant location of sports pitches south of the A31 is contrary to para 92 of the NPPF in respect of integration of communities and lack of attraction for potential users due to the separation. There would be no surveillance of the public open space and sports pitches.
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3.9. River Wey. The sensitivity of the River Wey corridor and the respective floodplain require careful consideration within the masterplan, particularly any interface with adjacent built form and respect of its rural setting.
4. Conclusion
4.1 There are a number of important concerns raised in this report relating to Northbrook Park proposal with respect to landscape and visual issues and these are summarised below.
4.2 The key issues relate to: • the siting of the proposed settlement in a rural location in isolation; • the effect of the proposal with regard to the SDNP and to its setting; • the effect of the A31 dual carriageway in terms of severance; • the lack of existing PROW network for potential connectivity; • the unattractiveness of a cycle/walkway adjacent to the A31 dual carriageway; and • the compromised accessibility/surveillance of green spaces by the A31, employment use and traveller site.
The contents of this report are valid at the time of writing. Tyler Grange shall not be liable for any use of this report other than for the purposes for which it was produced. Owing to the dynamic nature of ecological, landscape, and arboricultural resources, if more than twelve months have elapsed since the date of this report, further advice must be taken before you rely on the contents of this report. Notwithstanding any provision of the Tyler Grange Group Limited Terms & Conditions, Tyler Grange Group Limited shall not be liable for any losses (howsoever incurred) arising incurred as a result of reliance by the client or any third party on this report more than twelve months after the date of this report.
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Northbrook Park 12147_R06_Ecology Technical Note
1.0 Introduction
1.1. This short ecological technical note has been produced by Tyler Grange Group Ltd (TG) to undertake an assessment of ecology and biodiversity-related information contained within the Northbrook Park Large Development Site Information Pack September 2019. This high-level desk-based appraisal of the potential ecological effects associated with development on land at Northbrook Park (hereby referred to as the “site”) has been undertaken for Harrow Estates PLC.
1.2. East Hampshire District Council (EHDC) undertook consultation events in 2019 as part of the Local Plan consultation process; with Northbrook Park being one of the ten Large Development Sites included in the consultation. Two of the ten sites will be included in the Local Plan, informed by the results of the consultation.
1.3. The Draft Local Plan production has been informed by EHDC’s evidence base, including AECOM’s Interim Sustainability Appraisal (ISA) Report. The ISA is referenced in this ecology note where necessary.
1.4. This ecology note has been produced by Ivi Szaboova, an experienced TG ecologist and member of the Chartered Institute of Ecology and Environmental Management (CIEEM).
2.0 Northbrook Park Large Development Site Information Pack
2.1. The Site Information Pack relating to ecology and biodiversity was evaluated and information relating to protected sites and species freely available online was interrogated.
Description and Evaluation of Protected Sites 2.2. The potential for adverse effects to protected sites is the most significant ecological issue in respect of future residential development of Northbrook Park.
2.3. The Multi-Agency Geographic Information for the Countryside website1 was accessed for information on the location of statutory designated nature conservation sites and for European Protected Species (EPS) licences issued by Natural England (NE) in the vicinity of the site.
2.4. The summary of the internationally protected sites is in Table 2.1 below. Figure 2.1. shows the protected sites in relation to Northbrook Park.
1 http://www.magic.gov.uk/MagicMap.aspx
Tyler Grange Group Limited, Marsden Estate, Rendcomb, Cirencester, Gloucestershire, GL7 7EX Tel: 01285 831804 www.tylergrange.co.uk Registered in England No. 11435090 Vat Reg. No. 326 7564 81 Registered Office: Marsden Estate, Rendcomb, Cirencester, Gloucestershire. GL7 7EX
Birmingham ・ Cotswolds ・ Exeter ・ London ・ Manchester
Site Name Designation Distance and Description and Summary of Reason for Direction from Designation Site (km; N/S/W/E) East Special Area of 4.2km SW The SAC is separated into several distinct Hampshire Conservation compartments. It is designated primarily for the Hangers (SAC) presence of the Annex I2 habitats: • ‘Asperulo-Fagetum beech forests’; and • ‘Tilio-Aceron forests of slopes, screes and ravines’. Other Annex I habitats present as a qualifying feature, but not a primary reason for designation: • ‘semi-natural dry grasslands and scrubland facies on calcareous substrates’; and • ‘Taxus baccata woods of the British Isles. Annex II3 species present as a qualifying feature, but not a primary reason for designation, is early gentian Gentianella anglica.
Thames SPA 4.2km NE The open heathland habitat consists of Basin fragmented heathland, scrub, and woodland. Heaths Scrub, acidic woodland and conifer plantations dominate, within which are scattered areas of open heath and mire. The SPA is designated as it supports important breeding populations of birds of lowland heathland such as nightjar Caprimulgus europaeus, woodlark Lullula arborea, and Dartford warbler Sylvia undata.
Thursley, SAC 4.7km SE The SAC is separated into several distinct Ash, compartments. It is designated primarily for the Pirbright, Annex I habitats: and • Northern Atlantic wert heaths with Erica Chobham tetralix; • European dry heaths; and • Depressions on peat substrates of the Rhynchosporion.
Thursley, Special 4.8km SE Legally underpinned by Thursley, Hankley & Hankley & Protection Area Frensham Commons Site of Special Scientific Frensham (SPA) Importance (SSSI). Commons Designated features: • Dartford warbler • Nightjar; and • Woodlark.
2 Annex I of the Habitats Directive (1992) Annex I of the Habitats Directive (1992) 3 Annex II of the Habitats Directive (1992)
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Site Name Designation Distance and Description and Summary of Reason for Direction from Designation Site (km; N/S/W/E) Shoreheath SAC 7.7km SW The SAC comprises a single parcel. It is Common designated primarily for the presence of the (also a Local Annex I habitat ‘transition mires and quaking Nature Reserve bogs’. LNR) Other Annex I habitats present as qualifying
features: • ‘European dry heaths’; and • ‘bog woodland’.
Wealden SPA 5.9km S The SAC qualifies under Article 4.1 of the Heaths Habitats Directive (79/409/EEC) by supporting Special populations of European importance of Dartford Protection warbler nightjar and woodlark (all Annex I Area species).
Thursley Ramsar Site 9.5km SE Legally underpinned by Thursley, Hankley & Bogs Frensham Commons SSSI. (also a National It is a diverse site with open water areas, and Nature Reserve valley mire complex within a matrix of heathland, (NNR)) where drainage is impeded with deep layer of peat built up from the remains of bog-moss Sphagnum sp. The site supports rare wetland invertebrates, reptiles, and nationally important breeding populations of nightjar and woodlark.
Table 2.1 Statutory Protected Sites
Figure 2.1: Northbrook Park shown in relation to the internationally important sites.
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2.5. SPAs and SACs are part of the European network of important, high-quality conservation sites (known collectively as Natura 2000 sites) that make a significant contribution to conserving the 189 habitat types and 788 species identified in Annexes I and II of the Habitats Directive (as amended) and Annex I of the Birds Directive. By virtue of their designation as important sites on account of their ecological interest, SPAs and SACs are of international ecological importance.
2.6. Nationally protected statutory sites such as SSSIs were identified within 2km of the site; namely Bentley Station Meadow SSSI (1.9km SW). The site is also within the Impact Risk Zone (IRZ) of the above SSSI, as well as Heath Brow SSSI (see Figure 2.2 below).
Figure 2.2: Northbrook Park shown in relation to SSSI’s IRZ.
2.7. Northbrook Park is within SSSI IRZ for:
• Any residential developments with a total net gain in residential units; • Any residential developments outside of existing settlements/urban areas with a total net gain in residential units; • Any industrial development that could cause air pollution; and • General combustion processes > 50MW energy input.
2.8. By the virtue of their designation, SSSIs are of national ecological importance.
2.9. Non-statutory protected sites are also present in the site’s vicinity (the details of these are not freely available online). In Hampshire they are known as Site of Importance for Nature Conservation (SINC) and Road Verge of Ecological Importance (RVEI); both protected under planning policy. SINCs are sites of conservation value in the context of the county and are selected on the basis that they meet the criteria for local wildlife sites selection. They are therefore of county ecological importance. RVEIs are considered to be of up to district
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ecological importance.
2.10. In Hampshire there are Core Non-Statutory Eco-Network’ sites and ‘Network Opportunity’ sites (the details of these are not freely available online). Such sites are not designated as non- statutory sites for nature conservation but are discussed in Local Policy CP21 – Biodiversity. Although the eco-network sites and the network opportunities are not designated as non- statutory sites, they are discussed in Local Policy CP21 and therefore they are considered to be of local ecological importance.
2.11. Ancient woodlands are present (defined as continuous woodland cover since at least 1600 AD; see Figure 2.3); namely ancient replanted woodland (Lawn’s Copse; identified also as a SINC in the Northbrook Park Information Pack) situated at the northern extent of Northbrook Park. To the north-east the site is adjacent to ancient semi-natural woodland (ASNW) parcels (Fishpond Copse and Westland Copse). To the west, the site is adjacent to Ganscombe Copse ASNW. Additional woodland parcels are scattered in the site’s vicinity (ASNW, ancient replanted woodlands, as well as undesignated woodlands). The undesignated woodlands are likely to be of district ecological importance. Ancient woodlands are protected in the National Planning Policy Framework (NPPF). Due to their designation/protection ancient woodlands and woodlands designated as SINCs are considered to be of county ecological importance.
Figure 2.3: Northbrook Park - woodlands within and adjacent to the site. The site is indicated by a red dot. Ancient replanted woodland is indicated by brown hatching, ASNW by green hatching. Image is taken from Magic (accessed on 08.10.2019).
Description of Priority Habitats
2.12. Defra’s Magic website shows priority habitats (see Figure 2.4) are present within the site; namely:
• Coastal and floodplain grazing marsh grassland or rush pasture largely within EA Flood Zone 3; containing network of river channels, ditches or drainage channels; • Deciduous woodland; and • Wood-pasture and parkland Biodiversity Action Plan (BAP) habitat.
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Figure 2.4: Northbrook Park – priority habitats within and adjacent to the site. The site is indicated by a red line. Priority Habitat ‘Wood-pasture and Parkland’ is shown by tree symbols, ‘Deciduous Woodland’ parcels are green, and ‘Coastal and Floodplain Grazing Marsh’ is shown by blue/purple colour.
Description of European Protected Species Licences
Figure 2.5: EPS licences issued by NE. Northbrook Park is indicated by a red dot. Bat, great crested newt, dormouse, and sand lizard licences are shown as blue, green, pink and yellow squares, respectively.
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Site Constraints 2.13. Based on the information provided in the Site Information Pack, due to the potential adverse effects on Thames Heath Basin SPAs (designated due to the presence of ground-nesting birds), there is a need to provide a Suitable Accessible Natural Greenspace (SANG). The Opportunities and Constraints plan in the Site Information Pack states that a 15.4ha SANG in addition to 6.6ha of public open space (POS; including sports pitches) will be provided.
2.14. However, the plan shows the SANG/POS to be situated to the south of the A31; thereby separating them from the new residents which could affect the functionality of the SANG/POS. If SANG/POS is isolated from the development by the A31 (albeit with new pedestrian/vehicular access), therefore the residents may use the habitat and ancient woodland within the development for recreation. Children may use the woodland and retained habitat as they may not be able to use the POS for unsupervised play due to the distances between the development and POS.
2.15. Due to the proposed location of the SANG/POS (and as new employment land/traveller sites are also proposed south of the A31), a new vehicular/pedestrian access route and car park is proposed to the south of the A31. Seeing as the reason for providing a SANG is to reduce recreational pressures on internationally protected sites by walkers/dogs, if the SANG/POS is not easily accessible by the new residents, the proposals could result in the new residents using the nearby SPAs for recreation.
2.16. The SANG is proposed in a flood zone, utilising priority habitats (coastal and floodplain grazing marsh grassland or rush pasture; likely to be of importance to wading/ground nesting birds). In order for the SANG to be functional during the times of the year when the area is likely to be flooded, a raised walkway would have to be provided. Raised boardwalks may not be an attractive/suitable route for dog walkers when the SANG is not flooded and therefore shortcuts/ different routes through sensitive bird nesting habitats may be created.
2.17. Due to the location of the employment land and travellers’ pitches, the area to the south of the A31 will likely be affected by artificial lighting, noise, and disturbance in a previously undisturbed area. The traveller pitches would result in the presence of people in the evening/night-time close to the SANG and it is not clear what kind of employment opportunities would be present within the employment land (i.e. night-time work/access and security lighting may be required). Unmitigated, these effects could have adverse impact on nocturnal species such as bats, as well as nesting birds, and other species.
2.18. The site lies within the IRZ of two SSSIs and a SINC is present within the site, and therefore consultation with Natural England, EHDC, and the Wildlife Trust will likely be required.
2.19. Ancient woodland is included within the development boundary, shown on the plan as protected by 15m buffers. The buffers would have to be agreed with EHDC and potentially with NE. The ancient woodland is also protected by its designation as a SINC. It is not clear whether/how public access will be restricted and whether/how impacts from new artificial lighting would be mitigated. There may be the potential for disturbance and degradation of the retained woodlands from increased recreational use which could occur if access from new residents, and associated trampling, littering, informal play, and fire setting, cannot be controlled.
2.20. It is uncertain how the ancient woodland stand-off buffers would be managed to minimise so- called ‘edge effects’ associated with development (light, noise, introduction of invasive species). The masterplan does not indicate new native planting within the buffers to create a managed woodland ecotone, nor whether the buffers would be fenced to avoid public access. Private
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gardens within some areas adjacent to the woodland seem to back onto the woodland, therefore creating the risk of habitat degradation by public access, dumping rubbish, and lighting.
2.21. In addition to the potential adverse impacts on the ancient woodlands, the Site Information Pack shows that areas with priority habitat such as deciduous woodland and woodpasture/ parkland will be lost to development. The retained priority habitat could potentially be adversely affected by the same increased recreation pressures, as indicated in the constraints relating to ancient woodland above. Mitigation would be required to ensure the development would deliver net biodiversity gain.
2.22. The Site Information Pack shows proposals for a new hotel/spa within the main development area. Additional recreational pressure on the SPAs/SANG may result from the guests using new hotel/ spa facilities.
2.23. The EPS licences issued by NE within the site’s vicinity indicate that a number of protected species may be present at the site. These cannot be evaluated as phase II surveys have not be carried out.
3.0 Conclusion
3.1. A number of constraints exist in relation to the development at Northbrook Park. Mitigation would be required for internationally important protected sites; including SANG provision. The proposed SANG location/new access route shown in the Site Information Pack may adversely affect priority habitat and ground-nesting and wading birds, and due to its isolated location and situation within a flood zone, there is the risk that the SANG may not be functionally suitable to deliver its primary reason; i.e. avoid recreational pressures on the nearby Themes Heaths Basin SPA.
3.2. Areas of priority habitat such as deciduous woodland and woodpasture/ parkland would be lost to development. The retained ancient woodland and priority habitat may be adversely affected by the increased recreational pressures resulting from the new development.
3.3. Mitigation would be required for protected sites and sites protected by planning policy, as well as for loss of priority habitat and impacts on protected species, in order to ensure the development would be in conformity with legislation and planning policy.
3.4. The interim AECOM’s Interim Sustainability Appraisal Report states (para 9.8) “The site allocation identifies the key biodiversity issues in isolation though it is not clear that sufficient regard is given to considering the cumulative challenge of addressing these constraints in combination. There is little consideration of whether the required mitigation measures for one biodiversity designation will be compatible with required mitigation for the others. For example, there could be challenges associated with finding a final scheme design and layout which satisfactorily directs development away from one of the biodiversity designations without directing it towards others. It is recommended that these potential challenges are given consideration.”
The contents of this report are valid at the time of writing. Tyler Grange Group Limited shall not be liable for any use of this report other than for the purposes for which it was produced. Owing to the dynamic nature of ecological, landscape, and arboricultural resources, if more than twelve months have elapsed since the date of this report, further advice must be taken before you rely on the contents of this report. Notwithstanding any provision of the Tyler Grange Group Ltd Terms & Conditions, Tyler Grange Group Ltd shall not be liable for any losses (howsoever incurred) arising as a result of reliance by the client or any third party on this report more than 12 months after the date of this report.
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Technical Paper 3 Dated: 14th October 2019 Version 01
RESPONSE TO REGULATION 18 CONSULTATION TO THE EMERGING EAST HAMPSHIRE DISTRICT COUNCIL LOCAL PLAN 2014-2036
REPRESENTATION MADE IN RELATION TO: LAND AT NEATHAM DOWN, ALTON
1. Introduction
1.1 This representation has been prepared on behalf of Harrow Estates Plc as part of the Regulation 18 consultation process being undertaken in respect of the emerging East Hampshire District Council Local Plan 2014 – 2036.
1.2 This Technical Paper provides our representations in respect of Neatham Down which has informed our position to OBJECT to its proposed allocation within the Plan.
1.3 Indeed, this Paper identifies the proposed allocation at Neatham Down would be contrary to the policy objectives and principles of both national and local policies.
1.4 This Paper is part of a suite of representations that have been submitted as part of the consultation to the emerging Local Plan, as set out below.
• Technical Paper 1: Transport Feasibility Report, October 2019;
• Technical Paper 2: Land at Northbrook Park, October 2019; and
• Technical Paper 3: Land South East of Liphook, October 2019.
1.5 Taken together, the suite of representations provide an evidence-base that will enable the Local Planning Authority, together with future Inspectors acting on behalf of the Secretary of State, to maximise the sustainability and soundness of the emerging East Hants Local Plan in line with the objectives of current policy.
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2. Highway Capacity
2.1 Information prepared in support of the proposed allocation of Neatham Down has not been informed by any technical due diligence, unlike submissions made in support of other proposed allocation. There can thus be no certainty that technical barriers would not preclude or materially hinder delivery of this proposed allocation.
2.2 In fact, there are obvious barriers that require resolution in order to deliver this proposed allocation, not least the capacity operation of the proposed main access to the development via the Montecchio Way / A31 roundabout. This junction sits on one of the County’s most strategically important routes that is crucial to the regional and national economy. The Local Highway Authority give the same level of protection to this route as it would a trunk road.
2.3 Nevertheless, promotional material that has been submitted in support of the proposed allocation fails to acknowledge existing capacity constraint along Montecchio Way during both weekday morning and evening peak periods, which would be worsened by the proposals. Indeed, the existing extent of queuing around the junction is indicated by the below Googlemaps traffic delay maps which broadly mirror on site observations.
Figure 1 – Weekday Queues A31 / Montecchio Way Roundabout
2.4 It is evident from the above that queues extend over 1-kilometre from the junction along Montecchio Way, with associated queuing on London Road of an additional 0.5-kilometres. The addition of traffic associated with the proposed allocation will reduce the opportunity for vehicles to exit from Montecchio Way and thereby materially extend the duration and extent of queues into the town. In this way, there would be harm to the attractiveness of Alton as a shopping destination in contrast to policy which seeks to protect and enhance the town centre.
2.5 Furthermore, any increased queues along Monetecchio Way would be to the detriment of existing bus services that connect Alton to Farnham and Guilford, worsening the opportunity for commuter trips to be undertaken by bus.
2.6 Notwithstanding, the opportunities for mitigation are limited by the fact that the Montecchio Way approach to the junction is already provided as a two-lane entry and there are limited opportunities to widen further without third-party land control. Moreover, as discussed later in this report, the A31 is characterised by give-way junctions and any attempt to implement formal traffic control via signals would be entirely out of character for this network, increase delay and reduce efficiency on this strategic route, and would materially increase the risk of rear-end shunt accidents.
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Section Conclusion
2.7 On the basis of the above, there is significant doubt that the proposed allocation of Neatham Down could resolve the existing highway capacity and safety limitations, and in this way such matters would prejudice delivery of the proposed allocation.
2.8 In this context, the proposal would be contrary to both the NPPF and emerging Local Plan in the following ways:-
NPPF 108 part C In assessing sites that may be allocated for development in plans, or specific application for development, it should be ensured that:
…
c) any significant impacts from the development on the transport network (in terms of capacity and congestions), or on highway safety, can be cost effectively mitigated to an acceptable degree”
NPPF 110 part D “Within this context, application for development should:
…
d) Allow for the efficient delivery of goods, and access by service and emergency vehicles.
Core Objective B part 5 “encourage new developments in places that will reduce the need for people to use their cars. This will help to minimise air pollution, help address climate change by reducing road congestion and carbon emissions, and encourage people to live more healthy lifestyles by facilitating walking and cycling.”
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3. Barriers to Non-Car Access
Introduction
3.1 The NPPF is clear in requiring that “plans should be prepared with the objective of contributing to the achievement of sustainable development” (16a) and they should “be prepared positively, in a way that is aspirational but deliverable” (16b).
3.2 Notwithstanding, it is evident that the proposed allocation at Neatham Down cannot contribute towards the achievement of sustainable development in view that its aspirational strategies are unviable and undeliverable. Consequently, any allocation of the site would run the significant risk of making the Plan unsound.
3.3 The particular issues are covered under thematic headings below, for ease.
Barriers to Walking & Cycling
3.4 The proposed allocation site is separated from the existing built-up areas of Alton by the A31 dual carriageway. Whilst an existing over-bridge across the A31 connects the site to the rear of the established industrial estate at Waterbrook Road, this provides an unattractive and undesirable walk/cycle route that it is considered would materially reduce the propensity to walk/cycle, and would thereby materially impact on the potential sustainability of a new community in this location, contrary to policy.
3.5 Moreover, reliance on the over-bridge is contrary to Section 6.3.7 of Manual for Streets (MfS) which states that “footbridges and subways should be avoided” since “the level changes and increased distances involved are inconvenient”.
3.6 This is further supported by paragraph 3.4 of DMRB Volume 6 Section 2 Part 8 BD29/17 which states that “the position of a footbridge should be chosen to maximise the use of the topography so as to avoid or minimise the need for stairs and ramps”, and in this way seeks to reduce the level change referred to within MfS, it is noted that the A31 does not lie within a cutting in this location and as such pedestrians, cyclists and the mobility impaired shall need to climb to the bridge via ramps and steps.
3.7 Since there are more appropriate development locations under consideration within the Regulation 18 consultation, there is an opportunity to avoid the use of a bridge, not least because the requisite level changes shall reduce the propensity to walk and cycle, and thereby further increase reliance on the use of car travel, contrary to the policies within both the NPPF and the draft Local Plan.
3.8 The Developer’s Information Pack seeks to overcome this issue by provision of safe walking and cycle crossing facilities at the existing Montecchio Way / A31 roundabout. However, no details of a suitable scheme have been submitted as part of the Developer’s Information Pack and the deliverability of a technically acceptable scheme are questioned on the basis that they fail to acknowledge the fact that any proposal would materially reduce the operational efficiency of the A31, which is regionally important for the movement of people and goods.
3.9 Indeed, there would be only two ways in which pedestrian crossing movements could be incorporated around the junction – via informal give-way crossings or via signalisation.
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3.10 In the case of informal crossings, it is noted that the A31 in this location is a high-speed (70mph) and unlit two-lane dual carriageway road. Consequently, pedestrians and cyclists would be required to cross two lanes of high-speed traffic on each carriageway, where visibility would be limited - particularly in hours of darkness and during periods of inclement weather, where spray from vehicles would further inhibit visibility. Thus, any proposal would give rise to unacceptable highway safety risks that should be refused under the NPPF (109).
3.11 In this way, the proposed allocation of Neatham Down could not satisfy the requirements of NPPF (104 part d and 108 part b) as it would fail to “provide for high quality walking and cycling networks [emphasis added]”.
3.12 Whilst provision of a signalised crossing would address many of the conflicting issues related to informal crossings, vehicles would be required to stop on the A31 during any activation of the pedestrian/cycle signals. This would reduce the efficient movement of goods along the A31 and create unnecessary delay to the movement of people and goods along this regionally important highway. In this way, the proposals would be contrary to the NPPF (110 part d) which requires proposals to “allow for the efficient movement of goods”.
3.13 It is also noted that the A31 is characterised by give-way junctions, which reflects the need to maintain free flow of goods and people through the region, and thus any proposal to introduce traffic light control on this section of the A31 would be out of character and likely to give rise to rear end shunt type accidents - further degrading the efficiency of the strategic network.
3.14 Consequently, there are no deliverable methods in which to create a safe and efficient crossing of the A31 in this location. By extension therefore, the probability is that the proposed allocation of Neatham Down would become heavily reliant on car use, contrary to the sustainability principals set down within the NPPF and emerging Local Plan.
Barriers to Bus Travel
3.15 The Developer’s Information Pack suggests that a new bus service will be provided from the centre of the proposed allocation into Alton using electric buses. However, it is known that the developer has not consulted with the local bus operator to ascertain the viability of the proposed bus access strategy.
3.16 Notwithstanding, public transport services are highly unlikely to divert from existing routes for the limited quantum of development proposed and any suggestion that the existing Number 65 service could be diverted to the site is improbable. Moreover, viability concerns are heightened since it is known that capital costs of electric buses are around 3x higher than standard diesel fleet and require dedicated and costly recharging infrastructure, and as such the proposed shuttle bus service is unviable.
3.17 These issues have been clarified in correspondence from Stagecoach, the local bus operator, in their email of 14th October 2019 (included at Appendix A) in which they confirm:-
“Firstly, electric bus service operation is as much a matter of depot siting and provision as “buying electric buses”. The technical viability of such vehicles can be in no doubt. However their deployment requires a wide range of criteria to be satisfied. Running a single electric shuttle bus on a solus basis in a small town like Alton with no obvious means of supporting the operation is far from being the simple undertaking that it superficially might appear. We have operating centres in Winchester Basingstoke and Guildford all of which are relatively distant from Alton. Supporting this sort of operation from any of those points would be really quite challenging.
600 dwellings lying off line of any regular bus route would in no way justify a new stand-alone service in 5 the context of EHDC.”
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3.18 Consequently, the proposed allocation could not be served by bus and could not therefore deliver a sustainable new community.
Section Conclusion
3.19 Consequently, an allocation of Neatham Down would be contrary to the requirements of the NPPF to minimise the need to travel (103) and Core Objective B part 5 and Policy S30 if the emerging Local Plan.
Core Objective B part 5 “encourage new developments in places that will reduce the need for people to use their cars. This will help to minimise air pollution, help address climate change by reducing road congestion and carbon emissions, and encourage people to live more healthy lifestyles by facilitating walking and cycling.”
Policy S30 “development should seek to minimise the need to travel, promote opportunities for sustainable transport modes, and improve accessibility to local facilities and linkages with the surrounding pedestrian and cycle network”
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4. Summary & Conclusions
4.1 This Technical Paper has been prepared to support representations under Regulation 18 of the emerging East Hampshire District Council Local Plan.
4.2 The study has considered the salient sustainability credentials of the site’s location together with the potential to adequately mitigate the severance caused by the A31 dual carriageway. Whilst there is an existing overbridge across the A31, such measures are noted should be “avoided” within Government best practice documents.
4.3 The Developer’s Information Pack suggests secondary measures to address this issue by creating a safe crossing over the A31. However, this relies on either an informal arrangement which would give rise to unacceptable safety considerations given exposure to high speed (70mph) traffic with limited visibility, or which would overcome these issues by way of signalisation but which would therefore jeopardise the efficient movement of people and goods on this strategic highway, contrary to policy.
4.4 It has been suggested within the Developer’s Information Pack that an electric shuttle bus service would operate between the site and the centre of Alton. However, the capital expenditure and limited quantum of housing would jeopardise the viability of the service being provided in perpetuity. Moreover, the scale of the proposed development would be insufficient to attract a diversion of existing bus services and these points have been confirmed by the local bus operator.
4.5 Consequently, the proposed allocation could not be served by bus and could not therefore deliver a sustainable new community.
4.6 Any proposal to incorporate Neatham Down as an allocation would make the Plan unsound and vulnerable during public examination.
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Appendix A
Stagecoach Email dated 14th October 2019
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T. 0117 2441 970 [email protected] www.calibro-consultants.com nd Whitefriars Business Centre I 2 Floor I Whitefriars I Lewins Mead I Bristol I BS1 2NT
From:
Subject: Re: EHDC Local Plan REG18 process - [Viable Bus Strategies] Date: 14 October 2019 11:28:02 Attachments: image001.jpg
Dear
Conscious that a number of promotions are being advanced in the District with widely varying degrees to which a relevant bus service could be offered, I would firstly strongly reaffirm that the comments made in our duly made representations remain valid, and equally our separate letter to yourselves.
Firstly, electric bus service operation is as much a matter of depot siting and provision as “buying electric buses”. The technical viability of such vehicles can be in no doubt. However their deployment requires a wide range of criteria to be satisfied. Running a single electric shuttle bus on a solus basis in a small town like Alton with no obvious means of supporting the operation is far from being the simple undertaking that it superficially might appear. We have operating centres in Winchester Basingstoke and Guildford all of which are relatively distant from Alton. Supporting this sort of operation from any of those points would be really quite challenging.
At least as relevant is the matter alluded to in your second question: the relevance, potential revenue and long term commercial viability of such a service. Industry benchmark metrics such as supplied periodically by TAS have established that in larger urban contexts one single bus is generally supported by about 4000 people: something in the order of 1600 dwellings. However this presumes a significant urban network reflecting a significant volume of demand for intra urban journeys. Alton is in no way such a context. Generally I would suggest we would expect a larger development of say 2000 dwellings to start to create a business case for a standalone service; all assuming a policy-compliant affordable housing contribution and broad dwelling mix and a reasonable demand to a town centre venue/railhead. East Anton in Andover starts to exemplify such a scenario.
600 dwellings lying off line of any regular bus route would in no way justify a new stand- alone service in the context of EHDC.
This is why (given the local context) we have strongly urged EHDC to direct significant development towards existing strong inter urban bus corridors, among which our 64 stands out. This is the only spatial strategy that comfortably would maximise the use of public transport in East Hants. Development should relate directly to the routes concerned minimising as far as possible the need to divert, but recognising too that folk will walk further (up to about 900m) or even cycle, to access regular high quality bus services particularly where destinations are further afield.
Better yet, if such proposals also lay within good walking and cycling distance of a wide range of local facilities this further damps demand for car use limiting trip generation in local networks- something we are also very keen to see given the seriousness of the effects of deteriorating congestion on our services.
This is why we have unequivocally supported your client’s promotion at Chawton Park.
I trust the foregoing clarifies the points you raise sufficient for your purposes. Please revert should you need anything further. Yours sincerely
Head of Strategic Development and the Built Environment
Sent from my iPhone
On 8 Oct 2019, at 10:30, @calibro-consultants.com> wrote:
Dear
Thank you for your on-going commitment to engaging with the developers of the large development sites being promoted as part of the EHDC Local Plan REG18 process.
Whilst my expertise in matters of bus operations is far inferior to your own, I am mindful that there are suggestions of running a viable electric bus shuttle service between the Neatham Down proposal at the northern end of Alton (albeit divorced from the Town) to the railway station. In my mind this has a limited catchment that may not be sufficient to maintain a commercially viable service in perpetuity, especially as the proposal suggests the use of electric buses which I know have significantly larger capex costs that are several multiples of the equivalent diesel fleet.
I wonder, are there ways to deliver a suitable frequency and commercially viable service in perpetuity in the way suggested, for a site of 600 dwellings?
On a related point, do Stagecoach recognise a threshold of development that can sustain a new bespoke bus service?
My thanks in advance.
With Best Regards,
Director of Transport
Whitefriars Business Centre I 2nd Floor I Whitefriars I Lewins Mead I Bristol I BS1 2NT
T: M: E: [email protected]
www.calibro-consultants.com
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East Hampshire District Council
Emerging Local Plan 2017-2036
Regulation 18 Consultation
(October 2019)
Technical Note 1:
Transport Feasibility Report
Chawton Park Garden Village, Alton
Job Ref: BR-657-0001 Revision: 01
Issue Date: 14th October 2019 2019
[email protected] www.calibro-consultants.com Whitefriars Business Centre I 2nd Floor I Whitefriars I Lewins Mead I Bristol I BS1 2NT
BR-657-0001 – Chawton Park Garden Village, Alton Technical Paper 1 Transport Feasibility Report
Control Sheet
This report has been prepared by Calibro Consultants Ltd for the sole benefit and use of the Client. Calibro Consultants Ltd offer no liability for the information contained within the report to any third party.
Prepared By: Signature Date
BSc MSc 24/09/2019 Graduate Transport Consultant
Reviewed By: Signature Date
MSc CMILT MCIHT TPP 07/10/2019 Director
Approved for Issue: Signature Date
MSc CMILT MCIHT TPP 14/010/2019 Director
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Table of Contents
1. Executive Summary ...... 1
2. Background ...... 3
3. Policy Context ...... 7
4. Policy Compliance ...... 12
5. Deliverability ...... 26
6. Report Summary & Conclusion ...... 34
Figures
Figure 2-1 Site in Regional Context ...... 4 Figure 2-2 Site in Local Context ...... 5 Figure 4.1 Existing Public Rights of Way (PRoW) ...... 12 Figure 4.2 Modelled Walk Catchment ...... 14 Figure 4.3 Alton Cycle Routes...... 15 Figure 4.4 Sustrans Quality Audit Results ...... 16 Figure 4.4 Existing Trips by Cyclists ...... 17 Figure 4.5 Modelled Cycle Catchment ...... 18 Figure 4.6 Weekday Morning Peak Bus Catchment ...... 20 Figure 4.7 Weekday Evening Peak Bus Catchment ...... 21 Figure 4.8 Weekday Morning Peak Rail Catchment ...... 22 Figure 4.9 Weekday Evening Peak Rail Catchment ...... 23 Figure 5-1 Proposed Access Strategy (Overview) ...... 27 Figure 5-2 Swept-Path Analysis ...... 28 Figure 5-3 Proposed Signalisation of Northfield Lane Railway Bridge ...... 29 Figure 5-4 Potential Widening of Northfield Lane Approach to A31 Roundabout ...... 30 Figure 5-4 Potential Access Strategy ...... 31
Tables
N/A
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Appendices
Appendix A Modelled Walk Catchment Appendix B Sustrans Quality Audit Results Appendix C Modelled Cycle Catchment Appendix D Stagecoach Letter of Support Appendix E Modelled Bus Catchments Appendix F Modelled Rail Catchments Appendix G Proposed Access Strategy Appendix H Swept Path Analysis Appendix I Proposed Signalisation of Northfield Lane Railway Bridge Appendix J Potential Widening of Northfield Lane Approach to A31 Roundabout Appendix K Potential Access Strategy Appendix L Technical Note
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1. Executive Summary
1.1.1 This study has considered the policy context of a proposed residential allocation of ‘Chawton Park Garden Village, Alton’ in response to the emerging East Hampshire District Local Plan. This report is the updated version of the one that was submitted in March 2019 alongside the Regulation 18 consultation and reflects the significant additional technical work that has been undertaken to demonstrate delivery of the site in the context of transport.
1.1.2 The report concludes that the site would meet the objectives of national and local sustainable transport policies, and that there are no significant or abnormal barriers that would preclude the site from coming forward for delivery during the Plan period.
1.1.3 The study has considered the site’s geographical location in the context of the available transport networks and in particular its proximity to key local amenities and with a particular focus on the potential to access job opportunities. Indeed, the site benefits from nationally significant infrastructure that runs through the heart of the development, in the form of Route 224 of the National Cycle Network, which would be upgraded as a result of the proposals – plans for which are supported by Sustrans.
1.1.4 The appraisal of potential access options has been undertaken in consultation with the local bus operator, in line with paragraph 103(b) of the NPPF, and on this basis the currently envisaged access strategy is fully supported by Stagecoach. Moreover, Stagecoach have written in full support of the principal of a residential development of the site, which they consider “stands apart as that which represents one where the fullest possible use can be made of sustainable transport modes. This includes walking, cycling and public transport, all of which support more healthy, lower carbon lifestyles.”
1.1.5 Discussion with the Stagecoach has identified a strong willingness to diver the existing award-winning number 64 bus service to the site, which we are informed has experienced a +15% increase in patronage levels within the last two years since the service was relaunched. There is also the further possibility of overlaying this with the Number 38 service to further increase frequency and destination choice.
1.1.6 In this context, the proposed allocation could be delivered without the need for significant pump-priming of a new bus service and nor could there be any doubt of the long-term, in-perpetuity, viability of the bus solution.
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1.1.7 The report concludes that the site is located where it would afford residents of a future development of the site with an opportunity to access a range of jobs, shops and services by a variety of non-car travel modes, including walking, cycling and bus.
1.1.8 In this respect, a future development of the site would support the social, economic and environmental dimensions of sustainability, as defined within the NPPF.
1.1.9 The report therefore concludes that the site is both deliverable within the plan period and its allocation would be entirely supportive of current planning policy. Indeed, an allocation for residential development is not just warranted but in light of other reasonable alternatives, the site represents one of the most appropriate locations for development in the District.
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2. Background
2.1 Introduction & Purpose
2.1.1 Calibro Consultants Limited (CCL) has been appointed by Harrow Estates Plc to provide a strategic appraisal of the transport, highways and accessibility credentials of a site known as ‘Chawton Park Garden Village, Alton’, with a view to establishing its development potential for residential use.
2.1.2 The appraisal has been undertaken in the context of the emerging East Hampshire District Council Local Plan (2017-2036) and provides the Authority and Inspector with the requisite evidence that demonstrates, with confidence, that the site is both compliant with the objectives and principles of current policy, and that there are no fundamental technical issues that would impact on its delivery.
2.1.3 This report is part of a suite of representations that have been submitted as part of the consultation to the emerging Local Plan, as set out below.
• Technical Paper 2: Land at Northbrook Park - October 2019; and
• Technical Paper 3: Neatham Down, Alton - October 2019.
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2.2 Site Location
2.2.1 This study has been commissioned in respect of the site known as ‘Chawton Park Garden Village’ which comprises some 88.3-hectares of undeveloped land that adjoins the western settlement boundary of Alton and sits within the Chawton Park valley. It lies some 2.0-kilometres northeast of the centre of Four Marks, some 9.7-kilometres northwest of Bordon and 16-kilometres south-west of Farnham.
2.2.2 The strategic context of the site is shown below.
Figure 2-1 Site in Regional Context
Farnham
Alton Aldershot
Proposed Allocation Winchester
2.2.3 At the local level, the southern boundary of the site broadly is delineated by the Mid- Hants Railway Watercress Line whilst the eastern limits are delineated by Northfield Lane and the rear boundaries of a number of residential cottages. The northern and western extents of the site abut an area of wooded forest and open pasture, respectively.
2.2.4 The Site is also favourably located in respect of the proposed allocation of Policy SA24 – Land Adjoining Northfield Lane where some 5.3-hecatres of employment land are proposed to be allocated. This is broadly equivalent to the creation of some 400 jobs on the approach of Chawton Park and thereby maximising the opportunity to create a new sustainable community.
2.2.5 The site is shown in its local context in the below Figure.
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Figure 2-2 Site in Local Context
A31 (Towards Guildford)
Policy SA24 - Employment
A31 (Towards Winchester)
2.3 Structure of the Report
2.3.1 This report has been prepared with the purpose of providing the Planning Authority with an evidence base that considers the site’s suitability for residential development, taking into account existing policy objectives and any technical constraints.
2.3.2 The report sets out the various considerations under the following structure:
Section 3. Policy Context This section of the report critiques the relevant national and local sustainable transport policies such that the degree of compliance can be assessed in the subsequent section of the report.
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Section 4. Policy Compliance
The report evaluates the non-car accessibility credentials of the site in this section of the report as a measure of compliance with the locational aspects of sustainable transport policy.
Section 5. Deliverability
By way of assessing whether there are any abnormal barriers to delivery of the site, the opportunities and constraints associated with the creation of a technically compliant vehicular and non-car access are considered within this section of the report.
Section 6. Summary & Conclusions
A summary of the salient findings of the report are provided within this section and these are used to evidence an overarching conclusion regarding the suitability of the site for residential development.
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3. Policy Context
3.1 Introduction
3.1.1 This section of the report critiques the relevant national and local sustainable transport policies such that the degree of compliance can be assessed in the subsequent section of the report.
3.2 National Planning Policy Framework (NPPF), March 2018
3.2.1 The NPPF sets out the Government’s planning policies for England and how it expects these to be applied. The Framework clarifies at Paragraph 7 that “the purpose of the planning system is to contribute to the achievement of sustainable development” and this is the only occasion within entirety of the Framework that the purpose of the planning system is stated.
3.2.2 It is therefore evident that the sole purpose of the planning system is to achieve sustainable development and the achievement of sustainable development is therefore to be given the highest degree of weight in the Local Plan process. Moreover, since the policies within the NPPF must be taken into account in the preparation of Local Plans, there is a requirement for the Local Plan to evaluate with evidence the likely outcomes in the context of achieving sustainable development.
3.2.3 To assist in this purpose, Paragraph 3 of the Framework confirms that “the Framework should be read as a whole (including its footnotes and annexes).” In concise terms, Paragraph 8 identifies that sustainable development is achieved via three mutually dependant dimensions (economic, social and environmental) and which give rise the following overarching objectives:
• “an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;
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• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well- designed and safe built-environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment; including making effective us of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.”
3.2.4 In this respect, sustainability can be thought of as complex and multi-faceted concept where, each of the objectives needs to be pursued in mutually supportive ways to secure net gains in each across each of the objectives (Paragraph 8, NPPF).
3.2.5 In the case of transport-related sustainability, Paragraph 102 of the Framework requires that “transport issues should be considered at the earliest stages [emphasis added] of plan making” so that the “environmental impacts of traffic and transport can be identified and taken into account – including appropriate opportunities of avoiding [emphasis added] and mitigating adverse impacts”. This is supplemented by Paragraph 103 of the Framework which requires that “the planning system should actively manage patterns of growth” and “significant development should be focused in locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”.
3.2.6 To help inform the appropriate pattern of growth, Paragraph 104 (b) requires that planning policies should be “prepared with the active involvement [emphasis added] of local highway authorities, other transport infrastructure providers and operators”.
3.2.7 Taking this together, the NPPF therefore seeks to deliver development in locations and with appropriate strategies that minimise the need to travel, reduce consequential greenhouse gas emissions and help to conserve natural resources effectively.
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3.2.8 It is the case therefore that Government policy is concerned in the significant part with the location of development relative to supporting jobs, shops and local amenities, which create the need to travel. Indeed, Paragraph 103 of the Framework requires that locations that minimise the need to travel should be the focus of future development as these can help to “reduce congestion and emissions, and improve air quality and public health”.
3.2.9 The above policy requires that journey lengths are minimised which is a threshold set at a higher level than reduce and is therefore suggestive of a requirement to decrease journeys to the smallest possible degree. It is therefore fundamental that each allocation demonstrate that it is located where the need to travel can be minimised and non-car travel options maximised.
3.2.10 This requirement is implicitly transposed to paragraph 32 which requires that “significant adverse impacts… should be avoided and, wherever possible, alternative options which reduce or eliminate [emphasis added] such impacts should be pursued”.
3.3 East Hampshire District Council Draft Local Plan 2017-2036 (Regulation 18 – Consultation)
3.3.1 The current Regulation 18 consultation version of the Local Plan sets out what East Hampshire District Council consider is their identified need and location for housing up to 2036. Paragraph 2.3 sets out the over-arching vision of the Local Plan that: -
“by 2036 our communities’ sense of place will have been maintained and reinforced, respecting their unique individual needs. We will have provided a good quality home to meet the differing needs of all our residents, a successful and growing local economy and achieved environmental excellence.”
3.3.2 To this end of providing ‘environmental excellence’, the Local Plan is underpinned by a series of strategic objectives, the most salient of which are listed below.
“Core Objective A (part 1a) – the local plan will identify and maintain a supply of land for housing in the right location.
Core Objective A (part 2b) – the local plan will ensure new residential developments provide employment opportunities for residents.
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Core Objective B (part 5) – the Local Plan will “encourage new developments in places that will reduce the need for people to use their cars. This will help to minimise air pollution, help address climate change by reducing road congestion and carbon emissions, and encourage people to live more healthy lifestyles by facilitating walking and cycling.”
3.3.3 Whilst the objectives of the Plan incorporate a consistent theme of sustainability which broadly correlates with the thrust of the NPPF, it is noted that Core Objective B Part 5 seeks only to reduce rather than minimise the need for people to use their cars. In this context, the objective does not go far enough.
3.3.4 However, in contrast, Policy S30: Transport of the emerging Local Plan deals with transport matters in a comprehensive manner. Its over-riding requirement is that “development should seek to minimise the need to travel, promote opportunities for sustainable transport modes, and improve accessibility to local facilities and linkages with the surrounding pedestrian and cycle network” (S30.1).
3.3.5 In this regard, the proposed policy chimes with the NPPF in so much that it sets a threshold of minimising the need to travel, rather than the lower threshold of reducing. In this context, the proposed policy implicitly requires that the opportunities and constraints afforded by the juxtaposition of Sites relative to jobs, shops and services should be exploited.
3.3.6 However, as this study concludes, the proposed spatial strategy has failed to translate this policy into practice and there are consequently risks of the Plan being found unsound.
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3.4 Section Conclusion
3.4.1 It is evident from the above that the underlying requirement in determining site allocations is to ensure that they are located close to relevant amenities and job opportunities (to minimise the need to travel and reduce public transport journey times where required) and to provide a choice of non-car travel options (to minimise emissions and other costs of private car use).
3.4.2 The subsequent section of this report will therefore consider the non-car credentials of Chawton Park in the context of measuring compliance with the requisite policies, although it should be noted again that this report ought to be read alongside the Comparative Study prepared by CCL.
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4. Policy Compliance
4.1 Introduction
4.1.1 This section of the report considers the non-car accessibility credentials of the site and its associated compliance with the aforementioned policies.
4.2 Access by Foot
4.2.1 The Site does not currently benefit from any dedicated formal pedestrian infrastructure, albeit that two Bridleways run through the development and provide connectivity to the nearby settlements of Medstead and Four Marks to the west. The Bridlepath running along the southern part of the site also routes towards a Public Right of Way (PRoW) that runs from Chawton Park Road to the nearby residential area of Beech.
4.2.2 The location of the existing public rights of way are included in the Hampshire Definitive Map, an extract of which is provided below for context.
Figure 4.1 Existing Public Rights of Way (PRoW)
Alton
Beech
Medstead
Site Location Policy SA24 – Employment Allocation
Four Marks
4.2.3 Allied to the above, opportunities exist to create connections onto the existing formal pedestrian network along Chawton Park Road to connect at the existing Leisure Centre. Indeed, the feasibility of creating a new connection along Chawton Park Road is considered at Section 5 of this report wherein proposals for a shared surface
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footway/cycleway are shown, on the basis of topographical mapping and highway records, to be incorporated within existing highway verge that exists either side of the carriageway.
4.2.4 With such infrastructure, the Site would be serviced from a well-formed network of pedestrian footpaths that would provide future residents with an opportunity to access a plethora of local amenities and employment opportunities.
4.2.5 Indeed, the Site is located immediately opposite Alton Cricket Club and some 650-metres west of Alton Sports Centre, which boasts a range of facilities including a 25-metre swimming pool, teaching and diving pools, a well-equipped gym, astroturf football pitches, a creche, indoor climbing wall and a soft-play centre.
4.2.6 Allied to the above, the nearest GP Surgery is Chawton Park Surgery which is within a 1.2-kilometre walk of the Site and which sits alongside a local pharmacy. Butts Primary School is also located within an acceptable walk distance, although it is noted that a new school could be developed within the Site.
4.2.7 On the basis that the above amenities are all within the maximum desirable distances, as advocated the Institute of Highways & Transportation (IHT) guidance entitled Guidelines for Providing for Journeys on Foot (refer below), it is evident that Chawton Park is located where it would afford future residents with the opportunity to walk to key local facilities.
4.2.8 The accessible areas within these thresholds have been identified by way of a GIS-based accessibility model which has been constructed with reference to the available travel infrastructure.
4.2.9 The results are provided below and at a larger scale at Appendix A.
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Figure 4.2 Modelled Walk Catchment
4.2.10 Based on the above, it is evident that the application site is in a location that would afford various opportunities to travel by foot, in line with the various local and national sustainable transport policies.
4.3 Access by Bicycle
4.3.1 The industry-standard distance over which cycling is considered to be feasible for most of the population is 5-kilometres, although it is noted that there will always be a part of the population that have a natural propensity to cycle and will therefore be willing and able to travel further by bike.
4.3.2 The site benefits from nationally significant infrastructure that runs through the heart of the site, in the form of Route 224 of the National Cycle Network (NCN). As a national asset, this infrastructure implicitly forms a significant opportunity to underpin the cycle strategy and wider non-car strategy for the development of sustainable community in this location.
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4.3.3 Route 224 of the NCN runs from Farnham to Medstead via Alton using a mix of off-road and on-road provision.
4.3.4 The Alton Cycle Network is shown in the below Figure.
Figure 4.3 Alton Cycle Routes
Site Location
Route 224 of the NCN
4.3.5 The cycling charity responsible for the maintenance of the NCN is Sustrans who have been approached in line with the duties of the NPPF (103b) for Local Plans to be made with the active participation of key stakeholders. In this way, Sustrans have provided the results of a quality audit that was undertaken in 2017 for the local section of Route 224 which is copied below and provided at a larger scale at Appendix B.
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Figure 4.4 Sustrans Quality Audit Results
4.3.6 The results of the audit identify several sections of the route that are classified as “poor” and “very poor” and the proposed allocation of Chawton Park Garden Village would provide an opportunity target upgrades of the route to achieve either “good” or “very good” status.
4.3.7 The proposed infrastructure is continuing to be refined to maximise the currently proposed upgrades. The currently proposed upgrades are set out at Section 5 of this report.
4.3.8 Sustrans have been consulted on the proposals which are set out at Section 5 of this report, and are continuing to offer advice to further refine the proposals such that participation of cycling of future residents of the new community, as well as to enhance access to the surrounding countryside for existing residents of Alton, can be maximised.
4.3.9 Notwithstanding the on-going work, Sustrans have confirmed that “your proposals do look like they improve access along Chawton Park Road in particular and it’s great to see a traffic free route at the northern end of Northfield Lane. Its fantastic that you are aiming to provide this well needed missing link [emphasis added]”. A copy of the email correspondence is provided at Appendix B. Rev 00 | Copyright © 2019 Calibro Consultants Ltd P a g e | 16
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4.3.10 On a related point, it is known that Sustrans has been contacted recently with the purpose of exploring the potential to hold a Cycling Festival along Route 224 of the NCN and around the proposed allocation at Chawton Park Garden Village. This is entirely supported by the promoters of the site and represents a further exciting opportunity to underpin the non-car strategy for the work, and would form a major part of any Travel Plan for the site.
4.3.11 Notwithstanding the existing deficiencies that would be addressed as part of the proposed allocation, it is noted that informal cycling can be undertaken within the carriageway of many of the surrounding roads, without detriment to safety. Indeed, the STRAVA Global Heatmap, which illustrates the intensity of the use of surrounding roads for recorded cycle journeys, clearly evidences the relative use of the surrounding road network and demonstrates that cycling is already a viable and well-used mode of travel in the local area.
Figure 4.5 Existing Trips by Cyclists
Alton
Site Location
Medstead
Four Marks
4.3.12 The above infrastructure and viable cycle routes have been incorporated within a GIS- based accessibility model to evaluate the geographical catchment that is accessible from the Chawton Park Site, by bike.
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4.3.13 Based on the model results shown in the below Figure (and to a larger scale at Appendix C), residents of the proposed development would be able to access a significant geographical area by bike. Within this area are numerous local amenities and job opportunities, and indeed the previously submitted Comparative Assessment undertaken by CCL indicates that almost 10,000 jobs would be accessible within the 5-kilometre catchment.
4.3.14 Consequently, the Site would afford a significant opportunity for journeys to and from the site to be undertaken by bike, in line with current local and national sustainable transport policy objectives.
Figure 4.6 Modelled Cycle Catchment
4.4 Access by Bus
4.4.1 It is accepted that public transport accessibility comprises two principal aspects:
1. Access to public transport which is concerned with how far the development is from the public transport network and the level of service on that network; and
2. Access by public transport which takes account of where the services go and the opportunities to access amenities located within the catchment areas served.
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4.4.2 Detailed discussions have been undertaken with the local bus operator (Stagecoach) to identify an appropriate strategy for the Chawton Park site. This includes a nominal diversion of the Number 38 and 64 services to a central hub located within the heart of the development. The hub will be located where the on-site traffic-free greenways/cycleways converge around the proposed neighbourhood centre, thereby maximising the integrity of the bus offer.
4.4.3 Discussion with the bus operator also confirm that the Number 64 bus service is an award-winning service which has experienced a +15% increase in patronage levels in the most recent two-year period, since its relaunch with new double decked vehicles in 2017.
4.4.4 In September 2019, 91% of services were classified as being ‘on time’ and this relates to average punctuality ratings of 81.6% to 88.3% for regional services, as identified in the Annual bus statistics: England 2017/18 report prepared by the Department for Transport; this being the most recent version.
4.4.5 This is reflected in the comments of Stagecoach as the local bus operator, who state in their letter of 5th February 2019 (copied at Appendix D) that:
“the relevance and effectiveness of route 64 in providing a sustainable transport choice is well reflected in its recent history. Patronage on this service has strong and steady growth for some years…[and] it should also be pointed out that your promotion offers substantial synergistic effects with committed development immediately to the east at the Former Lord Mayor Treloar Hospital, and at Borovere Farm, both also on or very close to the 64 Route…we are therefore pleased to unequivocally endorse your promotion…”
4.4.6 The position is also reaffirmed in an email from Stagecoach of 14th October 2019, also included at Appendix D.
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4.4.7 Consequently, the proposed allocation of Chawton Park Garden Village would not be burdened by costly investment in pump-priming bus services – only relatively minor investment may be required. Moreover, in view of the increasing year-on-year patronage level increases, the bus routes that would service the proposed allocation are already commercially viable and there can thus be no question on their long-term availability, in- perpetuity.
4.4.8 These facts have been supplemented by accessibility modelling which has been used to identify geographical areas that would be accessible within a bus journey of 39-minutes, which reflects the average duration of a bus journey for commuting trips in the South of England.
4.4.9 The results are provided in the following Figures which represent the accessible catchments during a weekday morning and evening peak. Larger scale copies of the plans are available at Appendix E.
Figure 4.7 Weekday Morning Peak Bus Catchment
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Figure 4.8 Weekday Evening Peak Bus Catchment
4.4.10 On the basis of the evidence above, the location of the proposed allocation of Chawton Park Garden Village affords more than adequate opportunities to travel by bus. Indeed, Chawton Park would facilitate peak hour return journeys to a catchment that would provide access to over 10,000 jobs.
4.5 Access by Rail
4.5.1 The Site is located broadly within 3-kilometres from Alton Railway Station which is accessible within a 17-minute cycle ride of the site. The site would also be accessible using the interconnecting Number 64 bus service which are to be diverted into the central area of the Site.
4.5.2 Rail services from Alton provide connections to Farnham, Aldershot, Woking, West Byfleet and London Waterloo, as well as the wider national rail network. In this context, rail journeys have the potential to unlock access to significant employment opportunities and this has been modelled within the accessibility model on the basis of an assumed 40-minute travel time (including the interconnecting part of the journey).
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4.5.3 The results are provided in the following Figure whilst larger scale copies of the plans are available at Appendix F.
4.5.4 The results indicate that the location of the Site affords adequate opportunities to travel by rail and indeed, Chawton Park would facilitate access to a catchment containing some 5,000 jobs.
Figure 4.9 Weekday Morning Peak Rail Catchment
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Figure 4.10 Weekday Evening Peak Rail Catchment
4.6 Transport-Related Sustainability
4.6.1 The previously submitted Comparative Study undertaken by CCL in March 2019 considered the relative accessibility to amenities and jobs for each non-car mode of travel for the Draft Strategic Allocations at that time. It undertook this exercise with the use of a scoring system that reflected journey times and attractiveness of each amenity and mode, as well as the number of jobs accessible within each of the various catchments.
4.6.2 Full details concerning the model are available within the previously submitted Comparative Study, but it is useful to acknowledge the results of Graph 5-1 therein (extracted below), which shows that the Chawton Park site was amongst the very best sites in respect of its transport-related sustainability credentials, only bettered by the proposed allocation of Whitehill & Bordon.
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Graph 4-1 Non-Car Access to Local Amenities
4.6.3 That study reinforces the merits of the proposed allocation of Chawton Park Garden Village as the optimum location to create a sustainable community, only bettered by the opportunity at Whitehill & Bordon.
4.7 Section Conclusion
4.7.1 The analysis presented above confirms that the proposed allocation of Chawton Park Garden Village would afford future residents with the opportunity to access a range of amenities by a number of non-car travel modes, in line with the objectives of sustainable travel policies. These opportunities would also be extended to existing residents of Alton, who would, through improved infrastructure, be provided with greater access to the countryside, which could be optimised by incorporation of existing plans to create a Cycling Festival within the site.
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4.7.2 The proposed enhancements to cycle infrastructure have the support of Sustrans whilst the principle of development in this location, together with proposals to service the site with the existing Number 64 bus service, are fully endorsed by the local bus operator.
4.7.3 Indeed, the non-car travel opportunities support directly the objectives of the NPPF where the aim is to minimise car travel, emissions and congestion. Moreover, the scale of the opportunity puts the Site ahead many of the currently proposed draft strategic allocations.
4.7.4 On this basis, policy suggests that the Authority’s site selection criteria be revisited in order to fully comply with the principals of the NPPF and indeed their own Local Plan objectives.
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5. Deliverability
5.1 Introduction
5.1.1 Paragraph 16(b) of the NPPF requires that Local Plans should “be prepared positively, in a way that is aspirational but deliverable [emphasis added]”.
5.1.2 In order to assist in these duties and to demonstrate that there are no undue obstacles that may affect the deliverability of the site within the plan period, this section of the report sets out opportunities to gain vehicular and pedestrian access.
5.2 Means of Vehicular Access
Overview of Proposals
5.2.1 Chawton Park is uniquely placed where it can deliver a vehicular access strategy that not only accommodates the requirements of residual car-borne traffic but where it can also provide meaningful benefits to the wider community, including local bus services.
5.2.2 In this way, it is proposed to realign Northfield Lane north of the existing railway under- bridge such that traffic flows are diverted towards the Site. The new road shall be 6.5- metres wide to accommodate two-way bus traffic. Once within the site, the road will turn to connect to an improved Chawton Park Road which would also be widened to a minimum of 6.0-metres to facilitate two-way traffic.
5.2.3 This has the effect of removing the existing 90-degree bend that is created where Northfield Lane connects onto Chawton Park road, which suffers both from substandard forward visibility and constrained geometry and which causes significant friction between opposing traffic movements, including bus traffic. This has been recognised by discussions with the local bus operator.
5.2.4 The proposed access strategy is shown in the Figure below and to a larger scale at Appendix G, for context.
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Figure 5-1 Proposed Access Strategy (Overview)
5.2.5 Consideration has been given to the technical feasibility of providing the local realignment of Northfield Lane with regard to geometry, swept-path requirements of buses and forward visibility.
5.2.6 The results are shown in the Figure below and to a larger scale at Appendix H. The results demonstrate that the proposals are capable of accommodating the two passing movements of rigid goods vehicles and double decker buses. It is noted that Chawton Park Road serves land-uses which do not require visits by articulated vehicles and nor should such traffic be encouraged. Consequently, the road has not been designed to accommodate two passing articulated vehicles although, together with the provision of provision of intervisibility, as shown in the above drawing, it would be quite reasonable for an articulated vehicle to negotiate the bends.
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Figure 5-2 Swept-Path Analysis
Chawton Park Road
5.2.7 Allied to this, a shared-surface footway/cycleway would be provided within the northern verge of Chawton Park Road to connect to the established footway network that commences in vicinity of the Leisure Centre, some 375-metres to the northeast of the site. This is shown in Figure 5-1 above and at a larger scale at Appendix G.
5.2.8 The northern section of Northfield Lane that would become redundant as a result of the realignment of Northfield Lane into the site would be upgraded to become a high-quality traffic-free section of the National Cycle Network. These proposals are endorsed by Sustrans, the relevant body responsible for the maintenance of the National Cycle Network who state:-
“your proposals do look like they improve access along Chawton Park Road in particular and it’s great to see a traffic free route at the northern end of Northfield Lane. Its fantastic that you are aiming to provide this well needed missing link [emphasis added]”.
5.2.9 A copy of the email correspondence in provided at Appendix B.
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Northfield Lane Railway Bridge
5.2.10 As part of this proposal, traffic lights will be introduced to create formal shuttle-working through the existing railway bridge on Northfield Lane. Incorporated within this would be loop detectors installed within the carriageway of Northfield Lane as part of MOVA optimisation to ensure that green time is allocated in real-time to the arm that is experiencing the demand. This works well in this location given that traffic flows are relatively tidal, in so much that they are primarily towards the A31 in the morning peak and the reverse in the evening peak.
5.2.11 A separate queue detector would be installed on the southern approach which would activate the northbound green signal in the event that queues extended over it. In this respect, the loop detector would act as a fail-safe to protect the operation of the A31.
5.2.12 Pole mounted radar detectors would also be used at either entry to the railway bridge to ensure that intergreen periods were extended until equestrians cleared the junction.
5.2.13 The proposed enhancements in the vicinity of the Northfield Lane railway bridge are shown in the below Figure and to a larger scale at Appendix I.
Figure 5-3 Proposed Signalisation of Northfield Lane Railway Bridge
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5.2.14 The proposals to signalise the railway bridge and to bring traffic to the centre of the arch creates an opportunity to construct a contiguous footway that would provide a physical connection between the site and Policy SA24 of the emerging Local Plan which proposes employment use adjoining Northfield Lane. In this context, the proposed allocation of Chawton Park Garden Village enhances the sustainability credentials of the proposed employment allocation which would, without Chawton Park Garden Village, be car dependant and potentially fail to meet the sustainability principles of the NPPF.
5.2.15 Details of the footway, including a cross-section through the railway bridge, are shown above at Figure 5-3 and to a larger scale at Appendix I.
Northfield Lane / A31 Roundabout
5.2.16 Consideration has also been given to the potential requirements at the A31 / Northfield Lane roundabout to the south, and capacity analyses undertaken in the subsequent section of this report indicates a base requirement to widen the Northfield Lane from one lane to two.
5.2.17 This is shown in the below Figure and to a larger scale at Appendix J.
Figure 5-4 Potential Widening of Northfield Lane Approach to A31 Roundabout
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5.2.18 Notwithstanding the results of the capacity analyses presented in the subsequent section of this report, the availability of highway land around the A31 Roundabout enables a wide variety of larger improvements to be undertaken should they be required. Indeed, as shown in the below Figures and to a large scale at Appendix K, there is the potential to accommodate a left-turn filter lane onto the A31 northbound carriageway from Northfield Lane. This would have the effect of reducing some 45% of traffic approaching the junction from Northfield Lane.
5.2.19 This could also be complimented by an additional third lane on the A31 southbound approach which would be signed to accommodate Alton-bound traffic only. In this context, the proposed enhanced are expected to offer an opportunity to have nil detriment to the operation of the junction. The below Figure also shows how the proposals can be adapted to facilitate access to the proposed employment allocation under Policy SA24.
Figure 5-5 Potential Access Strategy
5.2.20 On this basis, it is evident that there is an unencumbered access solution to service the proposed allocation of Chawton Park Garden Village, whilst there remains an opportunity to create further capacity in the network should the need be required during the detailed planning application stage.
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5.3 Highway Capacity
5.3.1 Notwithstanding the relatively early stage of the Local Plan and the promotion of Chawton Park Garden Village, a significant amount of technical work has been undertaken to demonstrate the technical delivery of the requisite infrastructure and to evidence how this might operate in capacity terms.
5.3.2 In this context, a technical assessment of traffic demand has been undertaken using the best available data available at the time of preparing this representation; regrettably it has not been possible to capture updated traffic demand owing to the on-going highway works associated with the replacement Butts Bridge. Whilst this has necessitated the need to utilise base 2013 traffic flow data, robust assumption of traffic growth have been applied to that data using factors derived from the industry standard tool, TEMPRO, in combination with an allowance of committed development to provide an indication of baseline traffic demand at completion of the development. In this way, there is likely to be an element of double counting since TEMPRO figures are partially based on anticipated housing growth in the area.
5.3.3 The full analyses are set out in the Technical Note contained at Appendix L, which also used traffic generation rates given by Hampshire County Council in respect of the nearby and now approved Lord Mayor Treloar development. In this context, the analyses have been undertaken on an impartial basis.
5.3.4 Notwithstanding, in an effort to provide further confidence, the traffic generation potential of the development of Chawton Park Garden Village was tested in increments of +10% above the approved trip generation rates. The resultants traffic demand scenarios were input to a capacity model that tested the in-combination operation of the proposed signalised railway junction and the A31 Roundabout.
5.3.5 The results indicated that the traffic generation of Chawton Park Garden Village would need to be around 160% of the approved rates before the capacity of the A31 roundabout became stressed. Note that the capacity limitations were identified to arise in respect of the roundabout rather than the signalised junction through the railway bridge.
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5.3.6 Nevertheless, the capacity modelling was based on a limited improvement of the A31 roundabout to provide a two-lane approach, whereas the potential to create a left-turn filter lane in combination with additional lane on the A31 southbound approach would create significant additional capacity beyond the modelled scenario.
5.4 Section Conclusion
5.4.1 It is evident from the above that the access to the site, by both vehicular and non- motorised means, could be secured with relative ease and in this regard, it is concluded that there are no abnormal risks associated with the on-going promotion of the site for residential development.
5.4.2 Indeed, despite technical evidence suggesting that there is significant headroom to accommodate any change in trip generation rates, above and beyond rates that were provided independently, by the Local Highway Authority, there remains ample opportunity to deliver cost-effective solutions that would create significant additional capacity in the highway network.
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6. Report Summary & Conclusion
6.1 Report Summary
6.1.1 This report has been prepared on behalf of Harrow Estates Plc to support the promotion of a site known as ‘Chawton Park Garden Village’ within the emerging East Hampshire District Local Plan. The report has been undertaken as an appraisal of the opportunities and constraints related to the development of the site, and the findings of the report may be summarised as follows: -
a) The report has considered the site’s location to the existing non-car travel networks and the type of amenities that would be accessible within a reasonable journey of the site. In this regard, the evidence concludes that the site would provide residents of a future residential development of the site with an opportunity to access an array of local amenities, including jobs, amenities and services, by a range of non-car travel modes.
b) The report therefore concludes that a residential development of the site would support the social, economic and environmental strands of sustainability, as defined by the NPPF. In this regard, development of the site for residential uses would be in compliance with the NPPF.
c) Deliverability has been considered in the context of ensuring that options exist to create vehicular and non-car access to the site. In this respect, the report identifies a technically suitable access to the site can be secured via localised upgrading of Northfield Lane and Chawton Park Road in combination with introduction of signal- control through the existing railway underbridge.
d) Non-car access could be secured via new contiguous footways and cycleways, together with enhancements to nationally significant infrastructure via Route 224 of the National Cycle Network, which has the endorsement of Sustrans.
e) The local bus operator has been consulted in the development of the proposals and they have offered their “unequivocal endorsements of the proposals”. Moreover, the proposed bus access strategy is premised on an existing award-winning bus service that requires minimal short-term investment (if at all) and which therefore has no question regarding its long-term viability.
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f) The report has considered the effect of the proposals on highway capacity and has proposed mitigation in the form of signalisation of the Northfield Lane railway bridge in combination with localised widening to create an additional lane on the approach to the A31 roundabout from Northfield Lane.
g) Capacity analyses using independently derived figures suggests that the traffic generation potential of the site would need to increase by +60% in order to begin to stress the network. This represents significant headroom in the operation of the network.
h) Notwithstanding, the capacity modelling identifies that it is the A31 roundabout that nears capacity under the extreme modelling scenario of +60% trip generation. However, opportunities to significantly increase capacity of the A31 have been shown to exist and can be delivered cost-effectively, should any future evidence suggest there is a need to do so.
i) The report therefore concludes that there are no abnormal deliverability issues related to the on-going promotion of the site for residential purposes.
6.2 Report Conclusion
6.2.1 The overarching conclusion of this report is that a future residential development of the site would be entirely supportive of the policies within the NPPF and would thus constitute sustainable development.
6.2.2 There are no abnormal issues related to the delivery of the site and thus is should be considered for adoption within the emerging Local Plan.
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Appendix A Modelled Walk Catchment
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Appendix B Sustrans Quality Audit Results
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From: To: t Subject: RE: Chawto Park, Alton Date: 10 October 2019 10:04:23 Attachments: image002.jpg image003.png image004.png image005.png image006.jpg
Hi
Please find a cleaned up version of my previous comments to your proposals. This is all I can provide at this time, in terms of time and support to your scheme.
From your plan, your proposals do look like they improve access along Chawton Park Road in particular and it’s great to see a traffic free route at the northern end of Northfield Lane. It’s fantastic that you are aiming to provide this well needed missing link and upgrade poor & very poor sections. Please find below a few points for consideration to upgrade the route as you wish to, from very poor to very good:
· How does the access to/from the traffic free section on Northfield Lane connect to the route through the playing fields and is the type of crossing to the shared use path on Chawton Park Road? · Use of in the design and reference the London Cycling Design Standards and Paths for Everyone Design Principles (Appendix 1: p46), in terms of minimum standards of shared use paths and on road provision. · Could the bridge over the walkway incorporate cycle provision as well as a footway? · The traffic calming along Chawton Park Road, in terms of the build outs, could these leave a gap for cyclists to travel straight through the traffic calming? Many cyclists (commuters in particular) prefer to use the road rather than a shared use path. · There is no cycling provision travelling south west along Chawton Park Road and how do cyclists access the shared use path on the north side safely?
Best wishes ---
Network Development Manager | Central South | Sustrans Please note I do not work on Tuesdays
Sustrans | 17 Great George Street | Bristol | BS1 5QT
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Appendix C Modelled Cycle Catchment
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Appendix D Stagecoach Letter of Support
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From: To: Cc: Subject: Re: EHDC Local Plan REG18 process - [Viable Bus Strategies] Date: 14 October 2019 11:28:02 Attachments: image001.jpg
Dear
Conscious that a number of promotions are being advanced in the District with widely varying degrees to which a relevant bus service could be offered, I would firstly strongly reaffirm that the comments made in our duly made representations remain valid, and equally our separate letter to yourselves.
Firstly, electric bus service operation is as much a matter of depot siting and provision as “buying electric buses”. The technical viability of such vehicles can be in no doubt. However their deployment requires a wide range of criteria to be satisfied. Running a single electric shuttle bus on a solus basis in a small town like Alton with no obvious means of supporting the operation is far from being the simple undertaking that it superficially might appear. We have operating centres in Winchester Basingstoke and Guildford all of which are relatively distant from Alton. Supporting this sort of operation from any of those points would be really quite challenging.
At least as relevant is the matter alluded to in your second question: the relevance, potential revenue and long term commercial viability of such a service. Industry benchmark metrics such as supplied periodically by TAS have established that in larger urban contexts one single bus is generally supported by about 4000 people: something in the order of 1600 dwellings. However this presumes a significant urban network reflecting a significant volume of demand for intra urban journeys. Alton is in no way such a context. Generally I would suggest we would expect a larger development of say 2000 dwellings to start to create a business case for a standalone service; all assuming a policy-compliant affordable housing contribution and broad dwelling mix and a reasonable demand to a town centre venue/railhead. East Anton in Andover starts to exemplify such a scenario.
600 dwellings lying off line of any regular bus route would in no way justify a new stand- alone service in the context of EHDC.
This is why (given the local context) we have strongly urged EHDC to direct significant development towards existing strong inter urban bus corridors, among which our 64 stands out. This is the only spatial strategy that comfortably would maximise the use of public transport in East Hants. Development should relate directly to the routes concerned minimising as far as possible the need to divert, but recognising too that folk will walk further (up to about 900m) or even cycle, to access regular high quality bus services particularly where destinations are further afield.
Better yet, if such proposals also lay within good walking and cycling distance of a wide range of local facilities this further damps demand for car use limiting trip generation in local networks- something we are also very keen to see given the seriousness of the effects of deteriorating congestion on our services.
This is why we have unequivocally supported your client’s promotion at Chawton Park.
I trust the foregoing clarifies the points you raise sufficient for your purposes. Please revert should you need anything further. Yours sincerely
Head of Strategic Development and the Built Environment
Sent from my iPhone
On 8 Oct 2019, at 10:30, [email protected]> wrote:
Dear
Thank you for your on-going commitment to engaging with the developers of the large development sites being promoted as part of the EHDC Local Plan REG18 process.
Whilst my expertise in matters of bus operations is far inferior to your own, I am mindful that there are suggestions of running a viable electric bus shuttle service between the Neatham Down proposal at the northern end of Alton (albeit divorced from the Town) to the railway station. In my mind this has a limited catchment that may not be sufficient to maintain a commercially viable service in perpetuity, especially as the proposal suggests the use of electric buses which I know have significantly larger capex costs that are several multiples of the equivalent diesel fleet.
I wonder, are there ways to deliver a suitable frequency and commercially viable service in perpetuity in the way suggested, for a site of 600 dwellings?
On a related point, do Stagecoach recognise a threshold of development that can sustain a new bespoke bus service?
My thanks in advance.
With Best Regards,
Director of Transport
Whitefriars Business Centre I 2nd Floor I Whitefriars I Lewins Mead I Bristol I BS1 2NT
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Appendix E Modelled Bus Catchments
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Appendix F Modelled Rail Catchments
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Appendix G Proposed Access Strategy
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119.62 119.38 LC 119.48 119.38 119.53 GY 119.65 Bushes and Trees 119.37 121m Chawton Park Road 119.58 119.50 119.58 Boundary Fence Tree Canopy Tree Canopy 119.67
119.79 LC 119.68 120m 120m 119.61 119.70
121.07 121m
Bushes and Trees 120.00 END 119.80 119.83 119.92 Grass 119.73 TS 121.90 SNP 122.25 120.23 119.79 MH 121.58 121.13 TS 120.25 122.33 119.92 119.89 120.95 120.02 121.83 119.83
119.92 120.64 121.42 121.89 120.03 119.89 Boundary Fence 120.28 119.95
120.35 Footpath
120.12 120.77 121.36 120.53 120m
120.00 120.05 120.12 Bushes and Trees 120.14 120.00 119.99 120.01 120.85 120.10 120.20 120.33 Asphalt 120.23 120.39 120.26 SNP 120.17 Grass 120.28 120.18 120.04 120.35NB6 120.32 120.47 120.13 120.13 120.41 Footpath 120.38 120.08 120.40 2m 120.58 120.28 120.17 120.44 120.46
120.26 120.12 120.48 120.48 GY 120.22 120.63 120.13 120.51 Chestnut Pailing Ht=1.1m TS 120.51 Access to approved Lord 120.39 120.53 LC 120.36 120.18 120.66 120.26
120.58 120.60 120.28 120.57 120.54 120.37 120.48 120.62 Bushes and Trees 120.79 120.36 Grass 120.68 120.64 120.60 120.53 120.44 120.45 120.66 120.39 120.70 120.79 LC 120.46 120.58 120.83 120.72 Mayor Treloar development 121.11 120.78 120.53 120.56 120.71 120.73 120.48 Footpath 120.64 120.65 120.58
120.43 120.50 120.88 120.57 120.69 120.60 Asphalt 120.61 120.77 120.74 120.70 120.70 120.67 120.75 121.09 120.66 121.10 120.66 120.89 120.74 TS Grass 120.71 121.17 120.95 120.93 120.83 120.94
121.11 120.89 121.07 120.91 120.76 120.81 Bushes 121.11 120.76 121.10 NB5 120.78
121.16 120.96 120.93 120.81 120.91 Drainage Ditch 6m
121.11 120.98 120.89 120.85 120.95
121.10 120.98 121.31 121m 120.85
121.03 120.93 121.03 Post
120.95
121.10 121.38121.28 120.92 121.05
120.99
121.44 121.13 121.06 120.94 121.13 121.61 SK01 121.61
121.04 121.61 121.49 Bushes and Trees 121.36 121.20 120.96
121.25 121.10 121.21
121.35Bushes
121.30
121.08 121.30
121.09 121.44 121.25
Drainage Ditch
121.38
121.18 121.27 121.55 121.29
121.25 121.46 121.34 121.34
121.37 121.30 121.75 121.44 121.27 121.42 121.33 121.75 121.65 121.49 121.29
121.87 Post & Wire Fence Ht=1.2m
Post 121.40 121.39
Post
121.49 121.43
121.65
Post
Post
121.65
121.57 121.51 121.30
Bushes and Trees 121.09
121.44 121.59 125m 121.51 Post 121.72 121.25
125.01 Bushes
121.73 Drainage Ditch INSET 1 122.00 121.65 125.39 TS INSET 3 121.38
121.69 125.02 121.61
121.72
121.75 121.90 121.18 121.27
121.69 3 121.55 0 0 121.29 121.88 3
121.25 121.46 Bushes and Trees 121.34 121.34
121.97
121.75 Post 2m
1m 121.30 121.37 121.70 121.75 121.44 Post 121.75 121.79 122.16 121.27
121.42 121.33 121.75 121.65 121.49 121.94 121.29 121.77 LEGEND: 125.20
121.79 121.73
121.87 125.15 122.04 125.35 121.87 Post & Wire Fence Ht=1.2m Tree Canopy 122.38 122.11
121.83
125.45 NB4 125.32 121.86 121.86 122.01 Post 125.21 121.40 125.32 121.39
Block paving used to 122.13 121.88
125.73 Post
125.48 121.93 121.90 125.35 6m CARRIAGEWAY Bushes and Trees 122.15 121.43 Bushes 122.25 121.49 emphasise crossing 125.52 122m 121.65 125.42 Tree Canopy Bushes
125.31 125.42 Post
122.35 point of NCN Route 224 122.13
122.41 125.53 125.35 125.45 122.27 122.16 122.08 125.45 122.09 122.29 125.45 122.99 Post 122.33 122.29 122.86
122.64
125.39 TS 125.47 125.57 123.06 122.65
122.26 Bushes and Trees 125.49
122.35 122.29 125.43 125.49 122.52
121.65
125.52
Tree Canopy
125.55 123.01 122.81
122.43
125.48 125.51 121.57 FOOTWAY 125.57 121.51 122.46 122.45 125.56 125.52 125.51 123.05
125.62
Bushes and Trees 125.64
123.02 Bushes and Trees 125.62 125.65 125.57 122.48
FH 121.59 CF03 122.59 122.57 123.14 121.51
121.72 Bushes Post 125.63 SV Bushes 125.70 125.55 125.68
125.64 123.18
122.65
Tree Canopy FORWARD VISIBILITY MH 125.73
122.71 125.63 126.26 122.71 126.13 123.38 125.78 125.74
125.71 123.31 122.72 Bushes 32m, MfS (speed reduction from 125.71 126.32 125.83 125.72 125.77 122.78 122.78 125.72 125.78 122.92 123.59 121.73 MK-FH 125.84 125.76 125.78 126.08 123.34 121.65 6m 126.40 125.77 122.87 122.00 126.43 125.85 30 mph to 25 mph due to 125.70 126.36 125.82 123.05 125.72 125.90 NB3 126.22 122.90 Bushes and Trees 122.89 123.14 123.65 3m 125.79 TS 125.95 123.09
125.61 125.70 126m bends) 123.33 126m 121.69
125.73 126.50 122.92
126m 121.61 123m
121.72 Post 125.94 121.90 123.04 122.97 121.75 123.42
WM 123.69 121.69 123.00 123.94
Bushes and Trees 126.48 Tree Canopy 3 125.85 0 0 125.69 123.11 3 126.05 123.07 121.88 Proposed transition between 123.46 125.83 TS 123.96
125.95 126.15 123.57 125.89 126.06 3m 123.11 126.29 shared-use cycleway to Bushes and Trees 125.96 123.28 123.22
123.74
124.02 126m 126.22 Bushes 125.74 IC 127.19
Speed limit reduced to 30 mph throughout 123.69 126.28 123.25 121.97 on-street provision to be TP HIGHWAY WIDENING 125.69 OH=136.48 121.75 127.03 123.36 123.40 126.37 123.89 Post 124.51 126.45 6m 126.04 123.96 continued to Butts Bridge 126.38 Chawton Park Rd & Northfield Ln 123.79 125.74 123.38 Bushes and Trees 125.93 121.70 Post 121.75 121.79 123.51 123.54 122.16 124.06 Tree Canopy
124.09
123.88
123.53
123.67 123.71 124.04
124.17
124.08
123.75
123.890 3 123.84
124.37
Tree Canopy
124.20 30 HIGHWAY BOUNDARY
124.20 123.94 124m
Bushes and Trees 124.05 123.97 124.45
124.41 124.15
124.37 124.12
124.80
124.55 124.55 124.33
124.11 124.27 124.19
124.68 Ditch 124.71124.76 124.83 CF05
124.31 124.30
124.72 124.68 124.43
124.41 Bushes 124.35
124.72 125.24
124.85
124.57
124.64 124.56
124.83 Tree Canopy 125.17 0.5m OFFSET FROM ADOPTED
124.84 124.78
124.85
Bushes and Trees 124.85
124.86 124.89 124.74 HIGHWAY LIMIT
125.03
125.40 125m
125.01 124.93
125.21 125.39 125.63
125.02
125.20
125.15 125.35
125.45 125.32
125.21 125.32
125.73 125.48 125.35 Bushes 125.52 125.42
125.31 125.42
125.53 125.35 125.45 125.45
125.45
125.39 TS 125.47 125.57 Bushes and Trees 125.49
125.43 125.49 122.35
125.52 122.13 125.55
125.48
125.51 125.57
125.56 125.51 125.52
125.62
125.64
125.62 125.65 125.57 Motorised Access to be Restricted via Traffic Regulation Order CF03 FH 122.41
125.63 SV Bushes 125.70 125.55 125.68 125.64
MH 125.73 122.27 125.63 126.26 122.16 126.13 122.08 125.78 125.74 125.71 122.09 125.71 126.32 INSET 2 125.72 125.77 125.83 122.29 125.72 125.78 MK-FH 125.84 125.78 to create traffic-free connection along National Cycle Network 125.76 126.08 126.40 125.77 125.70 126.36 126.43 125.85 122.99 125.82 125.72 125.90 126.22 122.33 125.79
125.95
125.61 125.70 126m 126.50 126m 122.29 125.73
126m 122.86 Post 125.94 WM Bushes and Trees 126.48 125.85 125.69 126.05 125.83 TS
125.95 126.15
126.06 125.89 122.64 126.29
125.96 126m 126.22 125.74 IC 127.19 126.28 127.03 TP 126.33 2H1.3W 125.69 OH=136.48 126.37 127.03
126.37 126.46 126.45 126.38 126.04 125.74 125.93 126.41 126.47 126.44 126.68 126.50 126.86 123.06 126.62 126.05 125.82 126.12 122.65 126.12 126.02 126.41 126.73
125.78 Access to Cricket Club to be retained 122.26 127.12 126.35 127.03 126.96 126.93
125.85 126.01 126.99
3m 126.80 127m
CF04 126.35 127.00
126.37 127.24 126.01 126.29 Bushes and Trees Bushes
125.86 122.35 122.29
126.57 Chawton0 Park Road Tree Top=152.79
128.09 3 3 127.84 0 125.91 127.11 127.80 126.15 127.55 127.71 122.52
Tree Top=148.60 126.40 126.12
R21 127.67
126.23 127m 128.10 128.03 127.69
125.87 126.68 127.86
126m 125.92 128m Bushes and Trees 128.26BL 128.17 R23 126.16 Ridge=132.52
126.00 128.17 126.31 126.41 128.34 126.08 127.63 128.83 127.90 BL Post & Rail Fence Ht=1m 127.34 Tree Canopy Post & Rail Fence Ht=1.2m OH=137.13129.06 3m 128.61 126.56 BL 129.14 128.58 125.96 129.02 TP 123.01 128.66 128.71 128.85
126.69 129.06 126.65 128.31 128.76 122.81 128.60 128.96
126.08 128.19
126.50 126.07 122.43 126.07 6m 128m 129.93
128.75 130.06 129.52 128.97 129.00 128.96 129.33
OH=135.99 129.48 126.04 Tree Top=136.07 CF07 129m
129.60 129m 126.33 129.60
126.82 126.95 126.83 126.80 130.33 126.11 Eaves=132.69 SP 126.13 Ridge=136.29 129.08
Bushes and Trees 129.43 129.58 128.12 129.09 129.65 129.29 IC Post & Rail Fence Ht=1.2m 126.16 129.60 122.46 129.12 SV Eaves=132.71 129.82 129.20 129.74 122.45
129.71 129.38 129.63 126.38 129.51 126.24 129.14 126.22 129.77 123.05 126.49 AF 23/09/19 CF02 129.13 126.31 126.86 A 129.61 127.03 129.24 129.65 129.46 129.62 129.93 126.23 126.31 BL
126.37 127m 126.97 129.64 127.12 129.72 129.29 128.15 126.33 R16 129.82 129.80 127.09 129.77 126.57 Wire Mesh Fence Ht=1m 127.09 129.42 129.48129.66 129.73 129.54 130.02 126.35 129.81 130.14 6,4m TS 129.73 129.53 129.82
127.10 MH 127.38 129.44 129.78 129.88 129.87 Ridge=135.43 129.66 129.91 130.04 126.96 3,5m Bushes and Trees 126.40 130.06 129.94 126.39 127.23 Eaves=131.31 127.09 129.93 Bushes and Trees 126.44 129.85 CF06129.85129.86 Eaves=129.67 127.09 129.89 FIRST ISSUE 129.52 AF 11/09/19 126.64 Ridge=131.43 129.76
130.05 129.89 Eaves=129.67 -
127.12 R30 Conifer 126.77 126.67 127.15 128m 129.92 129.91 129.95 3m 126.65 128.18 R10127m 126.85 127.05 129.90 127.09 129.79 129.96 129.99
127.94 129.93 130m 127m 129.91 126.57 129.99 130.03 130.01 Root Line
126.57 127.10
129.92 123.02 127.06 129.98 129m 127.61 Proposed shared Footway / Cycleway 126.85 Hedge Ht=1.8m 127.26 128.29 Stump 130.13 127.96 122.48
127.12 127.03 130m 129.82 130.25 128.62 126.95 127.21 128.08 127.23
129.94 129.81 R30 127.11 130.08 126.82 Hedge Ht=1.8m 129.94 126.85 127.19 Conifer AV 129.99
127.92 Grass 130.31 129.91 127.02 OH=134.57 127.43 130.06 127.67
128.04 122.57 127.97 122.59 130.12 OH=134.41 128.45 Root Line 127.21 127.12 127.17 127.10 128.28 123.14 127.51 130.89 127.64 128m 130.02 130.48 127.07 128.52 130.11 129.91 130.50 127.16 127.64 NB9 130.03 129.87 128.23 130.45 Post and Rail Ht=1.1m 129.77 127.26 128.22 128.10 TP Electric Fence Ht=1.1m Bushes 127.58 128.22 FOR INFORMATION 128.45
128m OH=138.32
127.40 127.56 130.12 OH=136.87
127.29 CF08 130.45 130.07 130.27 Wire Mesh Fence Ht=1m TP 129.79 130.43 127.26 130.34 Concrete 129.90 127.34 128.24 129.69 128m 130.30 129.90 Hedge Ht=1.8m 127.44 BT 129.59 130.24 127.59
127.66 127.52 128.33 128.58 130.64 Hedge Ht=1.8m 128.79 127.90 127.66 128.48 CF01 128.02 Stump 129.65 Top Of Wall= 127.51 130.42 129.76 129.75 130.92
130.29 128m 123.18 129.43 129.76 Top Of Wall= 128.48 130.92 130.63 127.41 127.48 122.65 130.42 129.48 6,5m 130.32 129.78 Close Boarded Fence Ht=1.8m 127.57 130.44 129.47 128.79 129.00 129.61 129.59
127.82 Bushes and Trees 129m 128.89
Tree Top=150.33 128.85 Tree Canopy 128.17 Bushes and Trees Tree Top=149.69 130.49 127.62 128.88 130.27 129.97 127.96 129.85 127.88 Proposed traffic calming Top Of Wall= Top Of Sloping Wall= 136.46 HARROW ESTATES PLC 128.53 130.74 OH=137.33 127.72 130.89 129.66 129.36 R10 TP Top Of Wall= Top Of Parapet Wall=135.51 130.87 130.42 Spring=131.80 Cabinet 128.78 128.23
129.13
128.16 127.53 128.78 129.11 128m 130.14 129.26 129.38 127.70 129.44 129.32 122.71 127.89 129.11 Soffit=134.80 129.23 127.98 128.82 122.71 130.30 129.51 129.97
128.39 129.46 Spring=131.81 Spring=131.80 Top Of Parapet Wall=136.47
128.06 130.24 Top Of Sloping Wall= 135.54 128.10 130m Bushes and Trees 123.38 127.92 129.00
128m Top Of Parapet Wall=136.50 129m Top Of Sloping Wall= 135.48 128.83 Soffit=134.80 128.99
Grass 129m Grass 129.65 REDROW PLC 127.74 128.99 129.14 130.98 128.98 127.86 128.17 129.70
Proposed Site Access 130.32
Spring=131.79 128.79 129m 130.26 128.07 130.23 128.84 Wire Mesh Fence Ht=1m 128.08 129.51 129.68 129.26 129.51 128.90 129.93 128.99128.80 128.74 128.94 Top Of Wall= Top Of Parapet Wall=136.51 130.00 128.50 130.34 128.29 129.28 Top Of Sloping Wall= 135.52 Top Of Wall= 130.20 130.01 Tree Top=150.22 123.31 130.33 128.54 130.72 128.92128.95 129.11 128.40 129.09 EP
6,5m 130.32 122.72 129m 128.55 128.38 128.43 128.80 128.41 128.28 129.66 130.28
130.11 130.11 130.47 128.40 Tree Canopy 128.45 129.96 128.42 128.18
Top Of Wall= 128.77 128.08 128.26 130.45 128.06
128.37 130.31 130.00 130m 130.36 Top Of Wall= 128.58 CF09 128.09 129.99 Post & Wire Ht=1.5m 129.32 EP
130.07 129.26 OH=137.97 129.77 130.55 127.91
130.63 130m 130.04 130.05 122.78 130.28 6,5m 127.69 129.15 128.00 128.46 130.70 127.66 127.71 122.78
130.24 130.33 128.08 128.35 128m 128.00 122.92 127.29 130.76 127.58 130.17 127.45
127.61
129m 129m 128.85 128.88 128.57 127.98 129.65 129.17 128.37 127.09 123.59 128.75 R25 128.20
Electric Fence Ht=1.1m 129.66 GY 127.26 127.62 128.47 126.70
131.02 128.53 127.17 130.21 127.58 129.83 127.90 127.33 129.24 130.20 127.43 123.34 130.23 127.98127.98 130.85 128.11 127.42 130.53 Drainage Ditch 130.42 128.21
128.76 127.60 122.87
129.31 127.46 130m 127.45 129.38 127.46 127.07 NB2 128.80 130.12 129.87 127.58 EP OH=137.52 130.92 Bushes and Trees
130.46 131m 126.69
Ditch 126.91 125.90 Grass 130.27 130m 127m 126.99 126.56 129.45 130.37 127.11
126.50 126.65
131m 126.91 131.23 130m
130.90 131.44 130.30 130.85 131.40
128.97 Tree Top=149.40 131.33 Proposed130.46 new footway through bridge 129.75 129m Bushes and Trees Tree Canopy 131.08 131.40 130.97 129.91 131.28 125.85 130.57 OH=141.11 126.56 Tree Canopy CHAWTON PARK GARDEN VILLAGE 126.65 126.16 126.40 125.53
125.90 129.47 Post and Rail Ht=1.1m 130.56 131.14 131.10 300mm Pipe 131.31 130.44 130.57 126.16 SL=125.61 130.59 Post & Wire Ht=1.1m 125.99 130.53 126.02 125.95 130.22 130.26 129.12 CF11 TS 131.14 126.03
131.57 OH=138.64 OH=138.68 130.23 EP Grass 126.06 131.83 130.08 126.10 126m 130.34
125.77 130.93 125.44 ALTON 125.37 130.90 131.51 125.34 130.85130.78 131.01 130.38 125.76
Potential Secondary129.63 131m 131m 125.31 131.35 130.76 131.60
NB8 125.44
Drainage Ditch 125.37 130m
130.48 131m Tree Top=150.65 125.32
130.61 131.64 131.56 125.36 125.33 131.32 124.65 131.30 131.30 131m 124.64 130.65 131.57 125.10 131.33 Access (if 129.82 required) 131m 130.73
GY
131.27 124.85 BS 124.67 131.87 132m 124.90 124.84 124.73 Ditch 132.03 125m 131.01 CF10 Tree Top=146.90 124.86 Footpath PROPOSED SITE ACCESS OH=137.50 OH=137.55 GY EP 131.02 124.84 Ditch 130.94 124.82 124.60 131.76 131.81 124.80 131.67 131.59 124.19124.24124.21
124.59
131.49 124.63 132m 132.09 124.49
132.25
132.06 131.65 131m 131.11
131.08
131.14 Post & Wire Ht=1.1m Northfield Lane 132.08 124.31 131.68 132.01 131.20 132.03
131.96 NORTHFIELD LN / CHAWTON PARK RD Proposed signal-controlled crossing to 124.28 132.52 123.86 124.24 131.27 123.73
132.42 124.04 Grass 124.37 124.03 131.99 123.92 124.27600mm Pipe 131.35 132.56 SL=124.19 124m 132.37 TP 131.77 132.24 124.37 123.83 123.72 124.01 131.85 123.78
131.51
132m BS 132m 132.54 123.77 131.58 132.46 Tree Canopy support strategic employment site 123.82
131.42 132.38
Post and Rail Ht=1.1m 132.24 TP
133m 600mm Pipe 132m 123.66 SL=123.60 123.64123.06 132.77 131.68 123.10
123.73 Tree Canopy 131.64 123.81 132.30 Stay 123.07
132.10 Localised132.64 widening 132.08 131.80 Tree Top=150.58 123.15
Electric Fence Ht=1.1m 132.63 123.12 131.80 132.78 123.01 1:1500 11/09/19 AF SC
123.01 132.44 123m
122.97 133m 133.54 133.43 132.93 123.06 122.68 132.53 122.45122.96 122.70 122.45 GY 122.65 132.85 around bends 123.06 122.56 122.53 122.65 Grass 132.88 GY 122.62 122.59 122.62
133.71 122.52 133.04Post & Wire Ht=1.1m 122.15
122.67
133.83 Tree Top=151.07 122.09 Drainage Ditch 122.10
122.07 300mm Pipe 121.97 IL=121.02 121.71 133.95 122.01 121.14
121.70121.14 134m 121.78121.69 122m 121.99 120.79 122.08 BR-657-0001-TP SK01 A 121.62 120.29 120.29
121.83 121.49 121.64BT 119.94 121.94 121.57 121.51 120.79 Tree Canopy 134.13 120.92 119.41 134.13 119.47 119.37 LC 120.90 Drainage Ditch 121.80 118.89 121.34 120.10 119.12 120.16 118.89 121.33 121.25 118.60 121.40 119.37 121.42 120.20 Footpath 118.60 121.07 119.63 Tree Canopy 134.33 119.12 121.38 Grass 121.46 119.65 119.36
120.76 120m 119.34 121.45TS 120.98 121.18 120.90 SNP 121.26
121.09 120.37
121.00 120.64 121.13
120.73 Grass 121m 120.64 Grass IC 119.87 120.50 119.60
120.90 120.96 KI 120.75 120.43 120.44 120.36
120.20 120.88 120.13 119.67 120.69 119.96 120.77 119.73 119.61 119.78 119.56 120.69 119.90 119.67 119.71
120.28 120.65
120.65 120.48
120.44 120m 119.66 120.53
120.41 120.50 120.22 120.30 BL 120.04
120.44 120.50 120.35 120.12 NB1 119.82
120.33 120.01 119.89 120.19 120.18 120.09 LC 119.92 120.31 120.31 Grass
120.30 120.21
120.08
TS 120.07 TS 120.38 119.97
120.13 120.21 120.10 120m TS 120.00
119.97 119.89
120.10 NO.WELLGREENSTIRLINGFK8 +44 682DZT: (0)1786 STIRLING 239900 BUSINESS CENTRE Grass 120.02
120.05
120.13
119.56
119.97 119.97 IC KI 119.87 119.77 120.04
BUROCLUB157/15538028FRANCET: + 33 GRENOBLE 4 COURS 76 70 93 BERRIAT 41CEDEX 1
119.85 119.86 119.78
Drainage Ditch 119.96 119.83
119.88 119.79
STAFFORDSHIREWATERHOUSEUNITSLR7SUITE5THORNCLIFFEGRESLEY2LANE83LONDON DUNDRUMRAVENHILLLINCOLN VICTORIA CONSULTING 77,2, COVE 15, NEWTON POTTERS BRINDLEY2 ROAD CROMAR STREET BUSINESS STREET ROAD8 PARKBUSINESS PARKER BUSINESSTECHNOLOGY QUAYIRELAND COURT WAYESTATE PARK COURT CENTRE CENTRE
PARK,STAFFORDT:F:CHELMSFORDESSEXWINDYDUBLINBELFASTBT6NEWTONCHAPELTOWNSHEFFIELD,T:+44SHIREWORCESTERNEWAUSTRALIASW1H 01245+353-1-2964676+4461+353-1-29646674401785 8DNNORTHERN 2SOUTH(0)203 (0)114 (0)1905(0)280HWBEACONSIDE,BUSINESS9427CM1ARBOUR 14T: 392171241755392170241780 CHAMBERS ST18 IRELAND6919073 S352QE82008100 2455153 WALESWR4 751311751310 58102 2PW OWP2493PARK 9FD 2066 ROAD
119.86 calibro
119.20
119.62 119.89 119.62 119.81 transport, highway & infrastructure consultants
69EXETERDEVONEX1F: +44(0)1392 +44POLSLOE 2NFT: (0)1392 ROAD 495572 490152 119.87 119.77
119.89 119.83 0 30 60m 150 t: 0117 2441 970 www.calibro-consultants.com
Whitefriers Business Centre, 2nd Floor, Whitefriars, Lewins Mead, Bristol, BS1 2NT 8THMEDIACITYUKTRAFFORDMANCHESTERM17T:+44 FLOOR,1HH, (0)161 UK WHARF QUAY872 7564 WESTROAD
Metres 1:1500
Land at Chawton Park Farm, Alton
REF: GS DATE: October 2019
Introduction 1.1 This note considers whether issues relating to built heritage would compromise the deliverability of the proposed Garden Village at Chawton Park Farm, Alton. This specifically considers matters relating to the setting of Chawton Park Farmhouse, which is a Grade II Listed building, as this has been identified as a potential constraint to development in the Sustainability Appraisal of the Emerging Local Plan (Aecom 2018). It should be noted that this was identified as a constraint in the SA due to its presence in the area, rather than on the basis of a full assessment of its significance and setting.
1.2 This note also considers Chawton House, as this has been raised as an asset that may potentially be sensitive to development during recent consultation events.
1.3 This note has been informed by Historic England data, historic maps, site visits and consultation with the Chief Executive and Trustees of Chawton House.
Chawton Park Farmhouse
Background
1.4 Chawton Park Farmhouse appears to have originated as a farm house in the 17th century, but was greatly expanded in the 20th century to form a gentleman’s residence (Plate 1).
Plate 1 Chawton Park Farmhouse, looking north-west
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1.5 The relatively brief List entry for Chawton Park Farmhouse is as follows:
House. Late C17, with substantial C20 restorations and extension. Brickwork in Flemish bond, 1st floor band, plinth. Plain roof with 3 hipped dormers and C20 'Georgian' panelled stacks. South front 2 storeys; symmetrical 5 window front, with a west side wing (C20) of 2 storeys and attic, 1 window. Mullion and transom windows. C20 brick porch.
1.6 Chawton Park is thought to have been a medieval deer park detached from the Manor House. Extant earthworks within woodland areas are thought to represent the remains of park pales.
1.7 Although the List description states that the house is 17th-century in date, it may be slightly later, possibly constructed in 1720 as part of the Chawton Park Estate.
1.8 Chawton Park Farm was sold out of the estate in 1933, following which the farmhouse was modernised and enlarged through the construction of a large western wing to form a gentleman’s residence. The farm buildings to the south were re-roofed and tidied up.
1.9 Historically, the farmhouse was within the ownership of the wider Chawton Park Estate. The current farm has a landholding which includes the currently proposed development site.
1.10 The farmhouse faces south over a small front garden and trackway, towards the single-storey group of farm buildings that are arranged around three sides of a yard (Plate 2).
Plate 2 Panoramic view of outbuildings to the south of Chawton Park Farmhouse
1.11 Chawton Park Farmhouse also has gardens to the east, west and north.
1.12 The current landholding associated with the farmhouse extends furthest to the west along the valley, but also extends to the north, east and south. The majority of the land is used for the grazing of sheep and deer.
1.13 The Farmhouse is visible from the fields to the north, from where it has a backdrop of the fields to the south, and vice versa. It is likely to have oblique views along the
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valley to the east and west, although views directly west appear to be screened by trees.
Plate 3 Looking north-east to the farmhouse
1.14 The western side of the site does not appear to have intervisibility with the farmhouse.
Significance including Setting
1.15 As a Grade II Listed building, Chawton Park Farmhouse is a designated heritage asset of less then the highest significance as defined by the NPPF.
1.16 The significance of the asset is primarily embodied in its physical fabric, which has evidential, aesthetic and historic illustrative value.
1.17 Setting does contribute to the heritage significance of the asset, but to a lesser degree than the fabric of the building.
1.18 The element of setting that makes the greatest contribution to the heritage significance of the farmhouse are the single-storey buildings arranged around the yard to the south. These have aesthetic value, and also historic illustrative value; as ‘tidied up’ farm buildings they show both the origins of the house as a farmhouse and also illustrate its later change to a gentleman’s residence.
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1.19 The gardens of the current house and the access track also contribute to the significance of the asset through aesthetic and historic illustrative values.
1.20 In addition, the wider landholding makes a contribution to the heritage significance of the asset, through historic illustrative value as to its origin as a farmhouse and its landholding as a gentleman’s residence, and also as an area with views to and from the asset (aesthetic value). However, in the context of the overall significance of the asset, the contribution made by the surrounding landholding is relatively modest; it makes a minor contribution to the overall heritage significance of the asset.
Potential impact
1.21 As mentioned above, the Sustainability Appraisal of the Emerging Local Plan (Aecom 2018) suggested that the Chawton Park Farm site (CHA-005) is constrained by the presence of the Listed building, although this does not appear to have been informed by reference to a draft masterplan.
1.22 The emerging masterplan shows the retention of the farmhouse and the farm buildings to the south that make the greatest contribution to the significance of the asset through setting (and are likely to be considered to be curtilage Listed). These structures will be retained for community uses, allowing public access to, and appreciation of, the structures. The retention of the outbuildings will allow the origins of the Listed building as a farmhouse to remain clearly legible, and also provide an understanding of the gentleman’s residence phase of use.
1.23 Built form is proposed in the vicinity of the farmhouse, and this will undoubtably alter views to and from the asset and change the character of areas that currently make a modest contribution to the heritage significance of the asset. However, in light of the retention of the farm buildings to the south any harm caused to the overall heritage significance of the Listed building would be less than substantial and at the lower end of this range.
Conclusions on Chawton Park Farmhouse
1.24 The analysis above has identified that the emerging masterplan for Chawton Garden Village is likely to result in less than substantial harm at the lower end of the spectrum to one Grade II Listed building, Chawton Park Farmhouse.
1.25 Under paragraph 196 of the NPPF, such harm should be weighed against the public benefits of the proposed scheme. With regards to the setting of the Listed building, the judgement in ‘Mordue’ has clarified that where the principles of the NPPF are applied, this is in keeping with the requirements of the 1990 Planning (Listed Building and Conservation Areas) Act.
1.26 Furthermore, with regards to the harm caused, the less than substantial harm caused to one Grade II Listed building is considered to be a relatively low level of harm for a scheme delivering over a thousand housing units.
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Chawton House
1.27 Chawton House is an Elizabethan and Jacobean mansion with later additions, which is Grade II* Listed. Its most notable historic connection is with Jane Austen, whose brother owned the house in the early 19th century when she lived nearby in the village and who was a frequent visitor to the house.
1.28 Chawton House is set within Chawton House Park, a Grade II Listed Park and Garden, which also contains several other associated Listed buildings. The gardens, parkland and other associated assets are considered to be the primary setting of the house, contributing to its significance through aesthetic and historic illustrative values. With regards to this, it should be noted that the parkland has been subject to alteration following Jane Austen’s death, although elements contemporary with her visits are still present.
1.29 Another element of the setting of the asset that contributes to its heritage significance through setting is the settlement of Chawton, including the former Bailiff’s House where Jane Austen lived.
1.30 Consideration was also made of views from the Chawton House and its vicinity to the wider landscape, specifically the site. A meeting was held at Chawton House with the Chief Executive and two of the trustees of the organisation. During this, the potential visibility of the site in views from the house and garden was discussed, specifically from the Oak Room (where Jane Austen may have tutored her nieces, although it should be noted that this room gives views out to the south-west away from the site too) and from the garden terrace at a high point of the garden, to the south-east of the house.
1.31 As a general point, the site is separated from Chawton House and the parkland by the A31, and this area is largely screened by the topography of the intervening area, which includes a ridge of land.
1.32 With regards to the views from the Oak Room and terrace, the taking of verified views and analysis of views from the site itself and from the ridge between the site and Chawton House has established that views directly north-west from the Oak Room are very largely screened by vegetation (Plate 4).
Plate 4 Looking north-west from the Oak Room at Chawton House
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1.33 With regards to views from the terrace (Plate 5), analysis of the views has demonstrated that the fields visible in conjunction with the house and church (and visible in other views form the house and this part of the park) are not within the site, but rather are located on the intervening ridge.
Plate 5 Looking west-north-west from the garden terrace at Chawton Park to Chawton House and the Church of St Nicholas
1.34 The visibility of the site will be further assessed through site visits and the taking of verified views in the winter months. However, the initial analysis has demonstrated that the fields with clear intervisibilty with Chawton House and its immediate vicinity lie outside of the proposed development site. Should any areas of the site be demonstrated to have intervisibility with the site through further analysis, and it is anticipated that this would be glimpsed or filtered intervisibility at most, then mitigation measures would be employed, such as the strengthening of intervening vegetation or the design of the masterplan to exclude built form from specific areas. As such, it is anticipated that development can be delivered within the site without causing harm to the heritage significance of Chawton House.
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Chawton Park Farm 12147_R04a Landscape Addendum
1.0 Introduction
1.1. This short report is an addendum to the Landscape and Visual Appraisal (LVA) (reference 12147 R03b) produced by Tyler Grange Group Ltd (TG) to undertake an assessment of the potential landscape and visual effects associated with a strategic new neighbourhood on land at Chawton Park (hereby referred to as the “site”).
1.2. East Hampshire District Council launched a number of special consultation events in relation to large development sites for the Local Plan between September and October 2019. Two of the ten sites will be included in the Local Plan, informed by the results of the consultation. The Local Plan provides guidelines for future development in parts of East Hampshire outside of the South Downs National Park (SDNP). This site is one of the ten.
1.3. The LVA was prepared to support the promotion of this “Large Development Site” and to inform the emerging masterplan in accordance with current guidance (“Guidelines for Landscape and Visual Impact Assessment” 2013 (GLVIA3) Landscape Institute and IEMA and “An Approach to Landscape Character Assessment” 2014 Natural England). In this instance, the undertaking of the LVA demonstrates a thread that is woven throughout the masterplanning evolution. The initial consideration of opportunities and constraints has formed part of this process, followed by the production of the LVA and now the subsequent and ongoing engagement that emerges as it arises.
1.4. This addendum has been undertaken by an experienced Chartered Member of the Landscape Institute (1984) who is also author of the LVA.
1.5. During the course of the “Local Plan Large Development Sites Consultation” public events process, representatives from Chawton House have raised a number of concerns (at the Alton public meeting) relating to potential intervisibility between the Grade II* listed Elizabethan Manor House in Chawton and the site. This was the home of the brother of Jane Austen and is now a research centre, museum and popular visitor attraction. The surrounding parkland and gardens are themselves listed Grade II.
1.6. In response to concerns raised by Chawton House, Steven Neal (Head of Planning at Harrow Estates PLC) set up a meeting with Katie Childs, CEO of Chawton House, Louise Ansdell, Chair of Trustees and Richard Knight, representative of the Knight family on the 10 September 2019 (hereafter referred to as the “Trustees”) to understand the concerns relating to intervisibility. The meeting was attended by the above named and by Steven Neal, Jonathan Steele, Planning Director (Savills), Gail Stoten, Heritage Director (Pegasus) and myself, Jennifer Cawood, Landscape Associate at Tyler Grange (Cotswolds) (hereafter referred to as the “Team”).
1.7. The purpose of the meeting was to engage with the Trustees and to locate the specific views that they had identified.
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1.8. Two particular views, one from a window within the house on the first floor and one from the garden terrace were identified by the Trustees. However, a general walk about also assisted in investigating other locations where any intervisibility may occur and to identify further actions in response.
1.9. It is noted in this addendum at this stage that the matter of intervisibility between heritage assets and the site falls largely within the remit of the heritage consultants in the first instance and this is reported separately. However, effects on visual receptors (those people affected by changes to views and visual amenity) are to be taken into account during the iterative design process and also within the scope of the production of the LVA when they occur.
1.10. For the purposes of the LVA, a field verification process was undertaken to define the visual envelope. This included those locations from which the site was evident in views, excluding those that were barely discernible and taking into account vegetation and built form. The identification of views was undertaken from external spaces within the public domain and not from buildings or private spaces. The visual appraisal was undertaken during 2 site visits in February 2019 and photoviewpoint locations are shown on Plan 8 in the LVA. Section 3 of the LVA (para 3.39) noted that Chawton House was not open to the public until March 2019 but viewpoint 11 (attained from the Church) confirmed the containment by parkland trees and intervening vegetation afforded at this time at this location in the park (during winter-time when leaves of deciduous trees were absent). The site did not register in views from viewpoint 11. The House at this time was open from 4 March to 16 December 2019 11am – 4.30pm.
1.11. The assessment of visual effects deals with the effects of change and development on the views available to people and their visual amenity as set out in chapter 6 of GLVIA3.This relates to the character and content of views as the result of change or introduction of new elements.
2.0 Site Visit
2.1. The site visit of the Trustees and the Team was undertaken on 10 September 2019 in fine weather conditions, good visibility and in sunshine and when deciduous trees were in full leaf.
2.2. Chawton House parkland comprises a mixture of formal, informal, wilderness and farmland and contains a substantial number of fine mature large stature parkland trees both evergreen and deciduous. They are represented as plantations, clumps, avenues and groups of trees within the parkland where parkland trees are very much a feature.
2.3. Chawton House stands on the south west slope of rising land centrally within the parkland where landform falls generally from east to west. In relation to Chawton House, the site lies generally to the north west.
2.4. The surrounding landscape context of Chawton House and its parkland is very much one of parkland character that comprises a network of interconnected woodlands, copses and linear woody features that overlay an undulating topography and frame, screen or define views.
2.5. When considering the visual relationship between Chawton House and the site, the following are noted:
• The occurrence of parkland trees, clumps, avenues, plantations and scattered trees that include mature large stature trees some of which are evergreen within the Chawton House
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Parkland; • The quantity of tree cover within the settlement of Chawton itself and outside the Chawton House Parkland; • The density of tree cover within and along the A31 dual carriageway corridor; • The presence of tree cover on embankment along the Watercress Line railway corridor; • The large scale of mixed plantations at Chawton Park Wood and Bushy Leaze Woods that occupy skylines; and • The undulating almost hilly nature of the landform and the valley within which the site lies defined by the large mixed woodlands of Chawton Park Wood to the south and Bushy Leaze Woods to the north (both in excess of 200m Above Ordnance Datum (AOD)).
2.6. The visual baseline therefore, with respect to views that are orientated towards the site from Chawton House, is heavily influenced by the effect of the quantum of trees that interleave, combined with the undulating topography. Visibility is notably affected by this combination.
2.7. During the site visit the Trustees identified a number of locations that were visited and all but two were discounted due to the lack of intervisibility with the site when considered in the field, such was the density of intervening vegetation between the viewer and the site.
2.8. There were only two key locations that were identified as having potential intervisibility (others being discounted) for further investigation and detailed analysis:
i. A view from the terrace. Within a wide panorama of views obtained from the terrace area the content included the wooded and undulating topography of the surrounding landscape within which the site sits but is not evident. Mature large stature deciduous and evergreen trees occur within the view. The view comprises the parkland, Chawton House and the Church mid view within a significantly wooded context and with a wooded skyline forming the backdrop. A small part of a green field is noted in the distance and this is a field that is outside of the site boundary. The site is not visible.
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ii. A view from within the house from a first-floor window (the Oak Room). This is a view along the main access road across the parkland and wooded environs of Chawton towards the wooded skyline of Bushy Leaze Woods and the intervening landform and landcover within which the site sits but is not easily evident. Mature large stature deciduous and evergreen trees occur within the view. Such is the density and scale of vegetation that visibility is effectively contained as a result. The site is not evident in the view.
2.9. The area of rising land that was visible from the terrace during the visit was confirmed as a parcel of land outside the site boundary itself, lying within what is known locally as the “Shrave” a linear piece of pasture located between the A31 and the Watercress Line to the south of the site’s southern boundary. For reference refer to the “context plan” at the rear of this report.
2.10. From a different location nearby, another pasture field that was just visible in a small part and occupying a location on higher land was the field directly to the south of Ackender Wood and this also lies outside of the site boundary to the east of the site.
3.0 Comment
3.1 The LVA undertaken by TG concludes that the site benefits from strong containment and Plan 3 (refer to the LVA) identifies the site-specific landscape character where the effect of the interaction of landcover on landform is evident. A sequence of linear woody vegetation interleaves upon undulating landform in views between Chawton House and the site as discussed above. The LVA noted that the “Interim Sustainability Appraisal” of the emerging East Hampshire Local Plan, (Aecom December 2018) when considering potential sites for allocation of which the site was one, identified a number of environmental constraints but did not include any that related to Chawton House with respect to this site. The “Interim Sustainability Appraisal” does conclude that the site benefits from strong containment provided by woodland and other vegetation which along with surrounding topography, limits intervisibility with the SDNP (within which Chawton House lies).
3.2 In order to confirm the visual baseline from the site following the site meeting with the Trustees, a visit was undertaken by the Team to both the “Shrave” and to the elevated parts of the site itself in order to ascertain intervisibility with Chawton House at this time. It was established that the Shrave did afford some limited intervisibility with Chawton House where recent tree thinning had occurred, of parts of the upper windows of Chawton House.
3.3 During this visit, the effect of tree thinning due to Ash Dieback disease recently undertaken in Spring of 2019 was noted at the location on the linear ridge to the south of the site boundary within Baigent’s Copse. This was subject to the approval of the Forestry Commission on 25 January 2019 and in accordance with the Woodland Management Plan. Clearly the loss of mature Ash tree stock at this location has reduced visual screening to some extent. However, the capacity to return to the previous level would be achieved through regeneration or replanting
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where beneficial visual screening density would be effectively restored. The woodlands are mixed species so the overall effect of the Ash loss would be offset by the mix of remaining trees and regeneration occurring.
4.0 Conclusion
4.1 The engagement with the Trustees has provided an opportunity to further analyse the effect of the proposed scheme in terms of visibility from the two identified and agreed locations. Other potential locations have now been scoped out following the site visit due to the lack of intervisibility with the site.
4.2 It was confirmed that it was the “Shrave” and a field outside the site that featured in the views from Charlton House and parkland.
4.3 Further to the site visit, it was agreed that the terrace and Oak Room locations would be revisited to undertake a photographic assessment by professional photographic surveyors to establish visibility at the earliest opportunity in both summer and winter views. This would provide an opportunity to fine tune any mitigation measures if needed in consultation with the Trustees.
4.4 Verified photography has now been undertaken at the 2 locations in summer time and the photographs can be found within this addendum report in section 2 above. Full details and supporting documentation relating to the undertaking of the photography is submitted separately.
4.5 As set out in section 2, the photographs confirm that the site is not apparent in views from either the terrace or the Oak Room.
4.6 Depending on the results of the winter photographic assessment, and if any areas of visibility are established, mitigation measures can be employed. Options may include:
• The removal of development from such locations and replacement with a “green” use such as open space; • The introduction of strategic tree planting to deliver screening on site; and • The restocking and careful woodland management of Baigent’s Copse to re-fill any gaps in canopy spread due to Ash Dieback loss and to manage the regeneration of other species.
4.7 It is anticipated at this stage that such mitigation proposals can be effectively integrated without detriment to the visual amenity of Chawton House, but this will be verified as soon as winter photography is undertaken, and the results analysed.
4.8 In conclusion, this addendum demonstrates a willingness to engage with the Trustees and to continue that engagement in order to address the visual concerns raised to a level of satisfaction that is acceptable to them as the iterative masterplanning process develops.
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The contents of this report are valid at the time of writing. Tyler Grange Group Limited shall not be liable for any use of this report other than for the purposes for which it was produced. Owing to the dynamic nature of ecological, landscape, and arboricultural resources, if more than twelve months have elapsed since the date of this report, further advice must be taken before you rely on the contents of this report. Notwithstanding any provision of the Tyler Grange Group Ltd Terms & Conditions, Tyler Grange Group Ltd shall not be liable for any losses (howsoever incurred) arising as a result of reliance by the client or any third party on this report more than 12 months after the date of this report.
5.0 Plan
Site Context Plan (copyright Bing) Aerial Photograph 1.
12147_F004a_9st October 2019_JC_HB 6 Aerial Photograph extracted from Bing Maps © 2019 Microsoft View from Chawton House Site Boundary
T H E S HR A V E Site Context Plan. Aerial Photograph 1. Chawton House AVR Photography: Technical Methodology
October 2019 The pages in this document should be printed at their intended size and not Lens Selection Criteria Photography Post Processing be scaled to fit smaller page sizes. Technical Methodology pages should be In order to capture appropriate and relevant context, it was agreed that a 50mm RAW files were processed inAdobe Camera Raw after shot approval in Adobe printed on A3 landscape paper (297mmx420mm). lens should be used in combination with a panoramic tripod head. A series of shots Bridge. The processed RAW files were then taken into Adobe Photoshop to be were taken (with the camera in portrait orientation) to form panoramic photographs stitched and saved as full resolution TIF files. The process was as follows: from the house, and a single frame (planar) photograph from the terrace. The Technical Methodology panoramic photographs are intended to be used to demonstrate the baseline - any This section explains in detail the processes f shooting photographs for the AVR subsequently produced will be based on the single frame planar photography. purpose of AVR. The following procedures set out an efficient, consistently Downloading and Reviewing: accurate, robust, repeatable and traceable approach to achieve a high level of On site procedure 1. Downloaded *.CR2 RAW files from CF card using a CF card reader. The files accuracy. 1. Based on the order of viewpoints on the itinerary, each view location was were saved to the appropriate project folder on the network. visited. The tripod was erected and camera attached, along with the 50mm 2. The tripod and marker shots were downloaded to the same location and Verified photomontages, also referred to as Accurate Visual Representations (AVR) lens, shutter release, spirit level and plumb bob. The bob was hung from the depositied in a ‘documentation’ folder. or Visually Verified Montages (VVM), are the ‘top level’ in terms of accuracy and bottom of central tripod assembly after a nodal point adjustment had been 3. Shots were reviewed with Adobe Bridge, and selections were made based on documentation. Verified imagery is relied upon at public inquiry and in support of made. sharpness, composition, suitability for stitching and exposure. contentious planning applications/appeals and must therefore be robust and free 2. The height of the lens’ central axis above ground level was measured and set from erroneous/ambiguous information. From the outset, a project where verified to 1.60m using the tape measure. Processing: photomontages are required MUST be approached with the intention of absolute 3. A spray paint mark was used directly below the plumb bob to mark the location precision and will be based upon a traceable data set. 4. Using Adobe Camera Raw, simple and standard digital photo processing for the surveyor to measure. techniques were applied ie sharpening, noise reduction and chromatic 4. Using a camera phone 4 shots (n,e,s,w) were taken of the assembled tripod, Standards aberration correction. Settings were adjusted as necessary to achieve the best The work fully complies with the following guidance: camera and bob in situ over the marker. A shot of the marker was also captured. exposure, shadow detail and clarity. 1. The Landscape Institute/IEMA Guidelines for Landscape and Visual Impact 5. The following camera settings were used: 5. Using Adobe Photoshop, the processed RAW files were stitched to form a Assessment (3rd edition 2013); • Manual ‘M’ mode panorama of cylindrical projection. 2. The Landscape Institute TGN 9/19 Visual Representation of Development • Bracket set to +/- 0.75 stops 6. The completed panorama was saved as an 8bit tiff file. Proposals • Aperture at f8 to ensure wide depth of field and minimal diffraction. 7. A single RAW (50mm planar photograph) file was also saved out as the AVR • ISO <100 basis image. Preparation • Auto White Balance (AWB) • Following a formal instruction from the client, the scope of the project was agreed. Evaluative metering AVR Control (Survey) The client identified two viewpoints and supplied a map of required view locations. • RAW capture only to avoid loss of dynamic range and image quality degredation associated with 8bit jpeg format The AVR control survey was carried out 0th October 2019. Focal length, image format, required content and context was agreed prior to the • Enabled highlight warning site visit. The photographer was familiar with the scope of the project and read any • Used ‘Live View’ and zoom function to fix and verifiy focus on the site, This also Survey Methodology relevant information that was made available by the client. enables ‘mirror lockup’ and therefore less camera shake. Survey Equipment Required (see Appendix B for specification) • Evaluative metering. • Leica 1200 series GPS Smartnet enabled dual receiver (GPS and GLONASS) Site visit • Leica Total Station (1201 or TS16) 1’ accuracy with 1000m reflectorless laser Troopers Hill visited the site on the 3rd October 2019 to obtain viewpoint Panoramic Shots: 1. A sufficient horizontal field of view was determined to include the site and photography. The view positions were documented using photography of the exact Field Survey Methodology positions. A survey was also performed on the same visit to record the precise co- sufficient relevant context, vertical field of view was also considered based on • Camera locations: where possible, the camera position was used as a setup ordinates of camera and control points that will subsequently be used to produce height of the proposals and proximity to the site. point for the total station, enabling the re-creation of the view as seen in the Accurate Visual Representations (AVR). 2. The tripod was levelled using the tripod mounted level. Following this the panoramic tripod head was levelled using the levelling base. The levelling imagery and reducing the risk of incorrect interpretation of detail. Connection Photography base was microadjusted by partially engaging the clamp. Using the digital was via GPS Smartnet derived control points in OSGB datum and grid. 3-4 The site visit was done on 8th October 2019, and consideration was made to: level built in to the camera, pitch and yaw angles were adjusted to achieve control stations were used, to ensure long distance accuracies and to identify 1. Forecast weather conditions level. Levels were checked at the mid point and each end of the panorama. A possible outliers. 2. Shot itinerary based on sun position/time of day trial sweep of the panorama was performed while checking the digital level to • Reference points visible in the photography were measured with reflectorless 3. Access / distance to site / duration of journey to site and required time on site ensure a perfectly level set of shots. means from the total station. Where long distance views had suitable detail 4. Suitable parking 3. A minimum of 50% shot overlap must was achieved with the camera in portrait too far from the camera station, further setups were used closer to the detail. orientation. The panoramic tripod head assembly was adjusted to rotate Common visible detail points were observed from different setup points to Equipment used (see Appendix B for specification): incrementally at approximately 50% of the total horizontal field of view of the check and increase accuracy achieved. 1. selected lens with the camera is in portrait orientation. Camera, in working order with charged batteries (Canon EOS 5DS R) • Using realtime correction (RTK) accuracies of camera positions are to the low 2. Empty CF cards, at least 3x32Gb cards and 128Gb across additional cards in 4. The panoramic tripod head was adjusted to centre the lens nodal point to the centimetre, while accuracies of surveyed detail vary due to setup geometry and various capacities in case of failure rotational axis of the tripod. It was important to ensure this is set to the correct 3. Battery charger measurement in order to avoid parallax. distance, but will be usually in the low centimetre range and always below 30 4. 50mm lens (Canon EF 50mm f/1.4 USM) 5. With the camera centred on the site, ‘live view’ and x10 magnification was centimetres. 5. Lens cloth enabled and an appropriate point was identified to focus on. 6. Remote cabled shutter release 6. Once focused, and accounting for conditions, the correct exposure was Data Processing & Delivery 7. Tripod with indexed/panoramic head (Manfrotto 303) achieved by adjusting the shutter speed. Data was processed using industry standard software (Leica GeoOffice and 8. Tripod head levelling base (Manfrotto 438) 7. The panorama was shot from left to right, taking three bracketed shots per TerraModel) to create points listings. Digital photos were taken by the survey Total 9. Small magnetic spirit level rotational increment, through the panorama attempting where possible to avoid Station to aid identification of points. All points are to OSGB36 grid and datum, to 10. Plumb bob cars and any other moving objects. allow the use of common Ordnance Survey products and industry standard site 11. Spray paint (upside down street marking paint) 8. Shots were previewed to check the quality, focus, highlight warning surveys. 12. Hilti nails / pegs and hammer and histogram for the shots to ensure that a well exposed usable set of 13. Tape measure photographs had been captured. 9. ETR (expose to the right) method was used to achieve noise free shots - using the histogram and bracketing the shutter speed was adjusted to achieve an over exposed (but not clipped) +0.75 bracket shot.
Date: 11 October 2019 Project title: Chawton House Drawing Number: C200_51/01 Client: Drawn by: MP Checked by: AP Drawing Title: Methodology 1
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Date: 11 October 2019 Project title: Chawton House Drawing Number: C200_51/01 Client: Drawn by: MP Checked by: AP Drawing Title: Viewpoint Locations Date: 11 October 2019 Project title: Chawton House Drawing Number: C200_51/01 Client: Drawn by: MP Checked by: AP Drawing Title: Viewpoint 1 (50mm planar)