Planning Policy Team East Hampshire District Council Penns Place Petersfield Hampshire GU31 4EX

15 October 2019

Dear Sir / Madam East Hampshire Local Plan 2017-2036 – Large Sites Consultation Thank you for consulting the South Downs National Park Authority (SDNPA) on your large sites consultation which is seeking to gather comments on the potential large development sites being considered, to help inform the identification of the chosen sites in the Proposed Submission East Hampshire Local Plan. As you are aware, the SDNPA and all relevant authorities (including EHDC) are required to have regard to the purposes of the South Downs National Park as set out in Section 62 of the Environment Act 1995. The purposes are ‘to conserve and enhance the natural beauty, wildlife and cultural heritage of the area’ and ‘to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.’ We support East Hampshire’s continuing liaison with neighbouring authorities, including the SDNPA, to ensure cross-boundary strategic priorities are fully addressed. I would take the opportunity to highlight the SDNPA’s strategic cross-boundary priorities which provide a framework for these discussions and are the focus of this consultation response:

 Conserving and enhancing the natural beauty of the area.  Conserving and enhancing the region’s biodiversity (including green infrastructure issues).  The delivery of new homes, particularly affordable homes for local people and pitches for Gypsies, Travellers and Travelling Showpeople.  The promotion of sustainable tourism.  Development of the local economy.  Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Overarching comments We welcome recognition of cross-boundary considerations which may impact the South Downs National Park (SDNP). The table on page 14 of the consultation document is a useful quick reference guide to this. We ask that the South Downs National Park Authority also be included for the Extension of Land East of Horndean (Hazelton Farm). We would also ask that the SDNPA boundary be included on all site maps. We consider that showing the administrative local planning authority boundary would provide useful context when viewing the maps for these sites. Where sites contribute to the setting of the SDNP landscape evidence is necessary to inform capacity and design requirements. We advise that further work would be needed to provide evidence-based

1 numbers and evidence-led design will assist in avoiding and mitigating for adverse impacts on the National Park. To achieve this, settlement expansions which knit into the existing settlement pattern, have an appropriate transition to the countryside, and with characteristic mitigation, will reflect the countryside edge and role as part of the setting of the National Park. Evidence to feed into this work would include the South Downs Viewshed Study, the South Downs Integrated Character Assessment and Historic Landscape Characterisation. Experiential qualities are an important aspect in addition to views as reflected in the Landscape Character Assessment definition – these include tranquillity and dark night skies etc. There are also opportunities for multifunctional green infrastructure improvements, including connections for people and nature to and from the SDNP, which can be informed by landscape evidence. The South Downs National Park is a designated International Dark Skies Reserve. Urban developments are a key determinant in reducing the sky quality and harming Dark Night Skies: this is more a function of the street lighting than spill domestic residences. Due to the proximity of the developments, it would be preferable that those sites closest to the boundary, for example Four Marks South, Liphook, are limited in number. This would limit the overall ambient lighting closer to the SDNP and help to protect the dark skies of the Reserve. We refer you to our Dark Skies Technical Advice Note which includes guidance on how development can avoid, minimise and mitigate to protect dark night skies. We are able to provide guidance on specific development requirements which could be included in policy to protect dark night skies and we would welcome the opportunity to work with you on this. We are concerned that additional traffic arising from development will cause adverse impacts on rural roads; both those which form part of the transition between the built up areas of East Hampshire District and the SDNP, and those rural roads and villages within the SDNP itself. We ask that investigation of this matter on rural roads, including those within the SDNP is undertaken via traffic modelling and is included as part of Transport Assessment work to inform the emerging East Hampshire Local Plan. We would welcome the opportunity to work together in gathering evidence on this matter. The potential provision for gypsy, traveller and travelling show people sites within these sites for consideration is welcomed. Landscape evidence and opportunities for plots and pitches to be well integrated would be welcomed in order to support decisions regarding any allocations. In general the sites present opportunities to link communities with natural green spaces in the National Park, benefitting health and well-being. In line with the SDNPA Cycling and Walking Strategy we seek mainly opportunities to make connections via new or improved routes for walking, cycling and horse riding. In several places these routes already exist or partially exist and the development sites could present opportunities to fill in missing links or create new connections. The benefits include potential to reduce car traffic by providing alternative options for residents to access the National Park, and transport hubs such as railway stations. All evidence base and strategy documents cited are found on the SDNPA website. Whitehill and Bordon The site for consideration in this Large Sites Consultation appears to be an extended version of Site SA11, Bordon Garrison, in the Draft East Hampshire Local Plan (EHLP), published for Regulation 18 consultation earlier this year, in February-March 2019. Comments from the SDNPA were submitted as part of that Regulation 18 consultation and we consider these still stand. We are concerned that significant additional traffic will arise from this site which could impact on rural roads and villages in the SDNP. We request that this matter is also identified as a cross boundary consideration. We would expect the forthcoming transport assessment

2 to address this concern, and for design and mitigation measures put forward to be fully reflected in any final allocation policy. The proposals involve allocation for new development within 5km of the Wealden Heaths Special Protection Area (SPA). It will therefore be essential that any allocations will be able to sufficiently mitigate to avoid harm to the Wealden Heaths SPA, including protection (and no undermining) of any existing Strategic Alternative Natural Greenspace (SANG) provision. There appears to be proposed residential expansion and SANG provision within close proximity (within 1km) of Shortheath Common Site of Special Scientific Interest (SSSI) and Special Area of Conservation (SAC) within the SDNP which has some existing use and pressure for recreation. The impact on this will need to be assessed to avoid adverse impacts. Development in this area should seek the opportunity to deliver multifunctional GI and should seek to incorporate use of the old Bentley-Bordon railway as non-motorised user (NMU) route. The part of this route that falls within the SDNP is safeguarded for potential future use as an NMU route under Policy SD20 of the South Downs Local Plan (SDLP) as such we request that this matter is also identified as a cross boundary consideration. It is noted that the alignment of the railway appears to be just outside the current consultation area and suggest that it could be delivered initially as a standalone route connecting with the existing footpath in part of the Kingsley Quarry area. We are ask that this area should be included in any future allocation of the site. Land South East of Liphook This site for consideration is located for a range of uses, including 600 new homes. It is noted that the site falls partly within the National Park, and the SDNPA in the planning authority within the National Park. The proposed land uses within the National Park are stated to be SANG and flood attenuation as indicated in the list of cross boundary considerations for this site. We are concerned that the scale of the uses being proposed by the site promoter will have significant adverse impacts on the setting of the SDNP. The assessment appears to be reliant on screening and mitigation to account for impacts on the SDNP. In order to achieve this a landscape-led approach, with the associated necessary evidence, would be required which responds to the role of the site as part of the setting of the SDNP and responds to the settlement pattern of Liphook; this is likely to result in lower capacity for development than is currently being promoted. A quantum of development may be achievable on this site, but the scale and density currently promoted is not considered realistic, in particular, there needs to be a sympathetic rural transition/village edge. Reference to improvements in walking and cycling routes to the village and station is supported. Specifically, we have concern that the existing overbridge at Devil’s Lane would see an increase in motorised traffic and putting more vulnerable traffic at risk. A new overbridge for NMU’s maybe needed to provide access into the town. A constraint, and of concern, is the inclusion of part of Shufflesheeps Open Access Land in the development site. Open Access land can’t be developed or put to other uses such as incorporated as part of the green space for the development. It should also be noted that the Sussex Border Path and Serpent Trail are in this location. This site is mentioned in the endorsed Highfield Whole Estate Plan (WEP); the school is the owner of some of this land. The Estate refers to the site delivering a new school and recreational facilities such as sport pitches and green corridors. If this site were to be allocated in the Proposed Submission EHLP, reference should be made to the WEP and how such development can contribute to the Estate fulfilling their action plan, for example improving biodiversity, and supporting children’s’ experience of the ‘outdoors environment’, and improving NMU options to enable better access to the school linked with the school’s wider Travel Plan, as well as supporting the purposes of the National Park.

3

Extension to Land East of Horndean (Hazelton Farm) This site for consideration is an extension to the proposed allocation SA33 Land East of Horndean in the Draft EHLP. It is noted that the SDNP boundary is on the other side of the B2149 road. Reference to views in the list of cross-boundary considerations is supported, however, there are experiential qualities in addition to views which are relevant for this site, including tranquillity and DNS. The land of this site is identified as Blendworth Common, which is characterised by the lack of settlement. This site has a role as part of the setting of the National Park and as such a landscape-led and landscape-evidenced approach would be required which responds to landscape character of the site and its role of the site as part of the setting of the SDNP; this is likely to result in lower capacity for development than is currently being promoted which is not considered realistic. Trees/hedgerow alongside the B2149 should be retained and, consistent with the comments made on SA33, any housing in this part of the site should be of an appropriate scale and density for a rural transition between the built up area of Horndean and the rural area of the SDNP, in order to avoid a hard wall of development. Site SA33 lies immediately to the north and S31 (Havant Thicket) lies immediately to the south. In commenting on these allocation in the Draft EHLP consultation we sought a safe NMU link between the two however there was intervening land in between. If this site were to proceed to allocation, there is opportunity for this link to be realised. The promoters show indicative routes, however if this site were to proceed to allocation, such a route should be formalised to provide full NMU access and confirmed links to Havant Thicket. Other important opportunities for NMU improvements include connectivity to Rowlands Castle Railway Station (preferably by an off highway segregated solution, either adjacent to the B2149 or through the forestry ‘The Holt’), Staunton Country Park and in and around A3M Junction 2. Northbrook Park This site for consideration is of a similar area to that proposed for allocation in SA21 of the draft Local Plan, with notable extension to the north east to the south of the A31. We provided comments on SA21 as part of the previously Regulation 18 consultation and these comments also apply to this iteration of the site area and the site promoters proposals. The list of cross-boundary considerations make no reference to the SDNP which is a significant omission. We have concerns regarding the following potential impacts relevant to the National Park:

 The overall impact on the setting of the SDNP, given proximity to the boundary;  Potential adverse impacts on SDNP landscape setting, for example as experienced from the Alice Holt Forest, surrounding rights of way, and approaches to the SDLP from the north;  Potential to impact on Dark Night Skies, noting that most of Alice Holt Forest is within the Dark Sky Buffer Zone E1(a);  Potential impacts on ancient woodland and riparian ecological systems that lie within the area. Should this site be progressed to an allocation, evidence to address the above will be required to inform policy and design in order to avoid and/or mitigate any adverse effects. To do this, a landscape- led approach would be required. The site has characteristics of designed landscape/historic parkland and as such landscape evidence is likely to suggest a lower landscape capacity for development at this location. Any policy should 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. We strongly recommend that built development is kept away from the southern portion of the site (i.e. the land to the south-east of the A31) in order to retain a landscape/transitional buffer.

4

Development on either side of the A31 would not respond to the settlement pattern and would bisect the new community. This southern area could function as the SANG required to support any housing development. Approximately half of this southern portion of the site is within floodzone 2 and 3 which is a further reason to keep development away from this side of the road. There are opportunities for landscape and access enhancements to the southern area which should be secured by the policy. Sensitive recreation use could be appropriate based on restoring semi-natural habitats. Development of the site should incorporate means of access to Alice Holt/SDNP by means other than private car. There is currently a footpath linking with Holt Pound Lane which should be considered for upgrade to allow for full access by NMU, incorporating a safe crossing of the A31. Reference to a new pedestrian bridge over A31 in the list of infrastructure provision suggested by the promoter is supported. Chawton Park This site for consideration is proposed by the site promoter for a range of uses including 1200 homes. We support reference to landscape setting and views into and out of the National Park in the list of cross-boundary considerations. Whilst the woodland adjacent to the site limits views to some degree, the land of the site rises to the north and there will be visibility from/to the SDNP. The site is located in a historic landscape with historic farmsteads associated with an emparked landscape. Capacity of the site should be informed by landscape evidence. Development at this location risks severing the connectivity between the two areas of Open Access site woodlands to the north and south, especially in the context of the scale of development proposed. If this site were to proceed to allocation, capacity and development requirements would need to address this. There is an area of ancient semi-natural woodland within the site to the south; this should be excluded or its retention appropriately addressed in policy. Improvements to sustainable links to Alton listed as infrastructure being suggested by the site promoter are supported. Regional Cycle Route 224 may be lost as a result of the scheme and any replacement route should be segregated from the new highway, connecting the site to the hospital and beyond to Alton Station. Links to National Park could be via Wickham to Alton disused railway line which is a route safeguarded in Policy SD20 of the adopted South Downs Local Plan, as such this matter is also a cross-boundary consideration. Neatham Down This site for consideration is proposed for a range of use by the site promoter including 600 new homes. We support reference to landscape setting and views into and out of the SDNP listed under cross-boundary considerations. The site is not well related to the existing built up area of Alton and would extend built form over the A31 and encroach into the rural transitional landscape between Alton and the National Park. Views will need to be checked from King John’s Hill and other NP locations, and design should account for these views. There are various wildlife designations (including SAC) nearby within the SNDP which do not appear to have been identified by the site promoter. Four Marks South We support reference to landscape setting and views into and out of the SDNP listed under cross- boundary considerations. Please see overarching comments for further detail on constraints, infrastructure and approaches to address these.

5

Land South of Winchester Road, Four Marks Please see overarching comments. South Medstead Please see overarching comments. West if Lymington Bottom Road, South Medstead Please see overarching comments. Summary The SDNPA has a number of concerns, as set out above, which we consider should be addressed in full where these sites to be taken forward to allocation in order to make sure that the Pre-submission version of the Plan is sound. The SDNPA reserves its final view on whether the proposed development is supportable in principle, pending the outcome of the concerns highlighted above being addressed. We can confirm that we are committed to continued liaison and joint working towards achieving effective outcomes in this respect. Notwithstanding the above concerns and requested changes, we would like to wish you well in the progression of your Local Plan. If you have any questions on the content of this letter, please do not hesitate to contact me. Yours faithfully

Lucy Howard Planning Policy Manager

6