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1 Planning Policy Team East Hampshire District Council Penns 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.
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