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Friends of Riverside Established 1989 46, Throop Road, Bournemouth Dorset BH8 0BY 01202 392982 [email protected]

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Friends of Riverside Established 1989 46, Throop Road, Bournemouth Dorset BH8 0BY 01202 392982 Friendsofriverside@Outlook.Com Friends of Riverside Established 1989 46, Throop Road, Bournemouth Dorset BH8 0BY 01202 392982 [email protected] www.bournemouthfriendsofriverside.org 22/01/2019 Dear Secretary of State, We are writing to you to request that you call-in Bournemouth Borough Council’s Regulation 3 application for planning permission (application number 7-2018-9177-DL). This is an application for roads infrastructure that will in theory facilitate business park development (originally submitted as application 7-2017-9177-DH in December 2017). We set out the reasons for our request below. This request accompanies those made by Tobias Ellwood Bournemouth East MP and several other organisations and local representatives. Given the Case Officer’s recommendations report released on Friday 18th January 2019, Bournemouth appears minded to grant itself permission for the above application, also known as the ‘A338-Wessex Fields Link’. The date of 28th January 2019 has been set for a Planning Board decision. This proposal, were it to go ahead, would have significant and damaging consequences both for the immediate area and raise issues of national concern, in that it would damage Green Belt openness and set a disturbing precedent for further development on Green Belt and Conservation Area land. It would indicate that national legislation and regulation, as well as local development plans, could be set aside on the weakest of grounds, when it suited an applicant for this to happen. As we will show, the proposal conflicts with numerous aspects of national legislation and regulation – e.g. as regards Sustainable Development, promotion of sustainable transport, Conservation Areas, protection of Green Belt land, promotion of Biodiversity, and Transport Analysis Guidance -, as well as with many aspects of Bournemouth’s own Local Plan and other relevant documents. It will also have negative consequences for local residents in terms of noise, air and light pollution, in particular for some of the most vulnerable residents i.e. those living at the Retired Nurses National Home. Furthermore, we are extremely concerned as to how Bournemouth Borough Council, as applicant, land-owner and decision-maker has conducted itself throughout the planning process. The appointment of David Innes, Director of Blue Print Planning and Development Ltd., as the Case Officer, is of the utmost relevance. 1 Reference is made throughout this document to the concerns raised by Ms Sophie Edwards, who was Bournemouth Borough Council’s former Senior Planning Officer - and ‘A338- Wessex Fields Link’ Case Officer – until summer 2018. In her letter of 28th March 2018 to Claire Clark (A338-Wessex Fields Project Manager, Bournemouth International Growth (BIG) Programme) she set out her reasons for recommending refusal of the proposals (7-2017 9177-DH). A copy of this letter is attached as an appendix. In addition to quoting her where appropriate – i.e. where her objections to 7-2017-9177-DH are relevant to 7-2018-9177-DL -, more detail is given in: ‘9.5 The former Senior Planning Officer’s letter’, ‘9.6 The appointment of David Innes’ and ‘9.9 David Innes’ recommendations report’. All italics and highlights are my own unless otherwise stated. Policy and statutory considerations The Bournemouth development plan consists of a number of documents, those relevant to this case being the Bournemouth Core Strategy (CS) (2012) and the saved policies of the Bournemouth District Wide Local Plan (2002). Also of relevance is the Christchurch Local Plan 2001 (saved policies) and the Core Strategy (2014): The National Planning Policy Framework and other guidance – e.g. Department of Transport Transport Analysis Guidance - is also of relevance. Emerging local plan In September 2017, Bournemouth Council released its ‘Initial Stakeholder Consultation and Request for Potential Development Sites, Bournemouth Local Plan Review (Regulation 18)’. The next step is for the publication for consultation of a ‘Local Plan and Issues and possible options’ document. By the date of submission of this request, the Council had confirmed that they were currently not able to progress the LPR due to a number of issues, one of which being the upcoming merger with Poole and Christchurch councils. The emerging plan is thus at a very early stage and thus limited weight should be given to any potential changes. Conversely, given the early stage of the Local Plan process, we would argue – for reasons set out below – that if planning permission is granted at all, it should not be granted until the process is complete (or very close to being so). Furthermore, Bournemouth, Poole and Christchurch Councils are in the process of merging and it is far from certain that the application would receive the support of the new authority. 2 Sophie Edwards had the following to say as regards the upcoming restructuring of local authorities: “Need for the right solution for long term It is noted that the business case includes other options to a road bridge, such as linking with the existing Blackwater Junction. It would seem sensible to further investigate the wider options and work together with neighbouring authorities (potentially under the new merged authority) to get the right long term solution for Bournemouth and the wider area; as opposed to rushing ahead with something that doesn’t even have full funding”. As far as this is concerned, nothing has changed between application 7-2017-9177-DH and 7-2018-9177-DL. David Innes does not address this issue in his recommendations report. Main issues 1. Green Belt The Secretary of State’s right to ‘call-in’ as regards Green Belt matters is confirmed in the Town and Country Planning (Consultation) (England) Direction 2009. At 133. the NPPF says: “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and permanence.” At Paragraph 134. it states that Green Belt serves five purposes: “to check the unrestricted sprawl of large, built up areas; to assist in safeguarding the countryside from encroachment; to prevent neighbouring towns merging into one another; to preserve the setting and special character of historic towns; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land”. Paragraph 141. highlights the fact that “local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged or derelict land.” Paragraph 144. makes it very clear that “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt.” 3 Paragraph 146. allows for local transport infrastructure developments in the Green Belt “provided they preserve the openness of the Green Belt...” These stipulations are reflected in Policy CS37 ‘Green Belt’ of the Bournemouth Core Strategy, which also goes on to say that at ‘4.5.19’: “It” (i.e. the Green Belt) “will also continue to protect the identities of the villages of Throop and Holdenhurst”. The policy itself states: “inappropriate development will include any development which does not maintain the openness of the land...” In developing these proposals, the Council has shown itself to be entirely indifferent to the inherent value of Green Belt (the ‘five principal purposes’ as given above). A review of the plan’s development to date shows just how little value the Council placed on Green Belt. The Council’s ‘A338 information pages’ at www.bournemouth.gov.uk/A338info give both it and the Holdenhurst Village Conservation Area only cursory mention. The public exhibitions on the original application held in March 2017 and February 2018 did not highlight these designations at all (no public exhibitions have been held for the new application). The Planning Statements released with both the original and new planning applications, show no indication that the Council recognises the seriousness of damaging Green Belt. In an attempt to justify the scheme’s location, the Planning Statements list the five principal purposes of Green Belt, then going on to state with no justification: “The scheme will not lead to the unrestricted sprawl of large built-up areas, will not lead to neighbouring towns merging into one another, will assist in safeguarding the countryside from encroachment and will not adversely affect the setting or special character of historic towns. The scheme will assist in urban regeneration, by encouraging the recycling of urban land and as such it is considered that the proposed scheme does not conflict with the Green Belt purposes.” It is hardly surprising they do this perhaps, since the proposals actually fail on at least four of the five principals i.e. ● they clearly contribute to urban sprawl on the edge of Bournemouth. They consist of large-scale roads infrastructure placed on farmland between Townsend Housing Estate and Holdenhurst Village on the west side of the A338 and farmland between Royal Bournemouth Hospital and fields leading to Play Golf Bournemouth on the east side. The land to the west is both Green Belt and conservation area land, whilst the land to the east is, in part, Green Belt land. The road scheme in itself will add to urban sprawl and it should be remembered that the primary purpose of the scheme is to facilitate business park development on the east side of the A338, which would further add to such sprawl. 4 ● they encroach on the countryside and, having set a precedent, could potentially allow for further development in the Green Belt and Holdenhurst Village Conservation Area to the west of the A338; ● they cut through the Holdenhurst Village Conservation area, damaging the character of this historic place, mentioned in the Domesday Book; ● they are not indicative of a Council attempting to find urban sites to recycle.
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