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EHDC Large Development Site Consultation - Northbrook Park

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EHDC Large Development Site Consultation - Northbrook Park 11/4/2019 Mail - Woodgate, Jenny - Outlook EHDC Large Development Site Consultation - Northbrook Park David Beaman <[email protected]> Sun 13/10/2019 10:45 To: EHDC - Local Plan <[email protected]> Cc: averley.gov.uk>; farnham.gov.uk @farnham.gov.uk>; @waverley.gov.uk>; @waverley.gov.uk> For the attention of East Hampshire District Council - Large Development Site Consultation I write as an elected member representing Farnham Castle ward on both Farnham Town and Waverley Borough Councils and wish to make the following submission to the current consultation that is being undertaken by East Hampshire District Council into proposed Large Development Sites. The ward that I represent (Farnham Castle) adjoins East Hampshire along the A31 corridor and this submission relates to the proposals for possible development at Northbrook Park. The proposal to develop Northbrook Park envisages a development of 800 dwellings over a period of 16 years that the developers clearly accept would generate additional journeys to and from Farnham. Farnham is a Georgian market town with a population of just over 40,000 which already suffers high levels of traffic congestion (with associated air pollution) with; apart from the A31 which bisects the town in two also has two other “A” roads (A287 and A325) which pass through the town centre. Given the historic nature of Farnham with a significant number of listed buildings there is no easy solution to resolve Farnham’s traffic and air pollution problems unless there is significant expenditure on new road construction resulting in building either a Wrecclesham bypass and / or Western Relief Road which would take a significant proportion of existing through traffic which passes through Farnham away from the town centre. Farnham is itself facing demand to provide additional housing to meet required need – the Town Council’s Neighbourhood Plan which was approved by an 88% YES vote at referendum has allocated up to 350 dwellings at Coxbridge Farm (adjacent to the A31 roundabout). Although an outline planning application (WA/2019/0770) for development at this site has been submitted has already attracted an objection from Natural England as follows : - OBJECTION – Further information required to determine impacts on designated sites Natural England disagrees with the conclusions of the Appropriate Assessment which has now been submitted with this application. We refer to our previous advice below: As submitted, the application could have potential significant effects on nearby European designated sites, such as the Thames Basin Heaths Special Protection Area (SPA). Natural England advise that this application could contribute additional road traffic movements to roads in close proximity to European designated sites, causing potential impacts particularly though increased nitrogen oxide (NOx) emissions. The application does not show any investigation of emissions in these areas and therefore we cannot conclude that either alone, or in combination with other plans and projects in the area, that the proposal will not have a likely significant effect. Please re-consult Natural England once the above further information has been provided. https://outlook.office.com/mail/none/id/AAMkADIxNjE3NWJlLTMxYmEtNDEwZC1iOGM4LTYxOTllYjNmN2MzZQBGAAAAAABrEkrzGtHSSpsf0nN… 1/4 11/4/2019 Mail - Woodgate, Jenny - Outlook It should be noted that this objection which is dated 31st July 2019 has been maintained despite additional information that had been provided by Waverley Borough Council to an original objection that had been submitted by Natural England dated 12th June. As far as I am aware no further information has been submitted for consideration by Natural England that will result in this objection being withdrawn. It follows that any further planning application such as any proposed for development at Northbrook Park which would inevitably increase road traffic in the Coxbridge area that would result in increased NOx emissions would have a significant environmental effect on the designated Thames Basin Heaths Special Protection Area (SPA) that would need further mitigation measures being implemented. Although the agents for development at Northbrook Park are obviously aware of the impact of any development at Northbrook Park and have a Village Charter that includes a number of proposals to make such a community being as self-sustaining as possible with provision of various services and facilities in the early (Years 1 to 3) of the proposed 16 year development including provision of a footpath and cycleway to Farnham (although only I understand as far as the Coxbridge roundabout) and the provision of a bus service “in perpetuity” to Farnham Town Centre and Farnham Railway station operating every 30 minutes in addition to the existing hourly daytime bus service (but with no evening or Sunday or Public Holiday service currently operated) the supporting proposed financial budget attached to the Village Charter dies not show how either provision of the footpath and cycleway or the provision of a bus service “in perpetuity” would actually be funded. The provision of bus services from an early stage of development whilst obviously desirable involves significant costs and with an end development after 16 years of 800 dwellings may never become financially commercial on fares revenue alone and would require ongoing financial subsidies to guarantee continue operation “in perpetuity”. It should be noted that when planning permission was granted to development of the Coxbridge Business Park in 2013 it was a planning condition that finance was provided to operate a bus service from when a certain number of units were occupied to Farnham Town Centre and Railway Station for a minimum period of 3 years in the expectation that over the 3 year period passenger use and revenue would increase to the point where it would become commercial. Although the bus service was operated it failed to become commercial and was withdrawn when the 3 year period of funding ended. Should it be decided that Northbrook Park be chosen as one of the Large Development Sites that should proceed then the provision of public transport to and from Farnham needs to be reviewed and consideration given to assist funding provision of a park and ride site in the vicinity of Coxbridge Farm with a bus service operated to Farnham Town Centre and Railway Station that could also serve Coxbridge Business Park, any residential development at Coxbridge Farm and other residential development East of Wrecclesham and Farnham such as Bordon and Whitehill. There are also a number of other factors that need to be taken into account when considered Northbrook Park as a potential Large Development site viz : - No account has been taken of the ability of the railway service provided by South Western Railway between Farnham and London Waterloo to accommodate any additional passengers that would be generated by any development at Northbrook Park. The rail service although not as yet operating at full capacity (at least from https://outlook.office.com/mail/none/id/AAMkADIxNjE3NWJlLTMxYmEtNDEwZC1iOGM4LTYxOTllYjNmN2MzZQBGAAAAAABrEkrzGtHSSpsf0nN… 2/4 11/4/2019 Mail - Woodgate, Jenny - Outlook Farnham although peak hour trains most of which are already operated by 12 car trains which are he maximum length that can be accommodated at most stations currently have to carry standing passengers from stations further down the line. Passenger demand from Farnham will increase further from residential developments already given planning permission in the Farnham area and other sites designated in the Farnham Neighbourhood Plan for residential development. Indeed increasing passenger demand has already required provision of a second deck to the railway car park; It is noted that the proposal for Northbrook Park includes provision in of SANG “across the boundary” in the area administered by Waverley Borough Council. This would require a separate planning application to be submitted to Waverley Borough Council and it should not be assumed that such an application would necessarily be approved. Indeed when there was a call for sites for residential development for inclusion in the Farnham Neighbourhood Plan an application for residential development on the Waverley Borough side of the proposed of the proposed Northbrook Park was rejected as being unsuitable; No account appears to have been taken of the requirement for mitigation measures that would need to be taken to avoid the possibility for flooding further downstream in the Farnham area arising from the development of an employment site on the south side of the A31 which would remove the ability of the ground to absorb any rain in the area which would increase water flow further downstream on the River Way; and No account appears to have been taken of the need to provide adequate facilities to deal with sewerage and waste water that would be generated by any residential and employment development at Northbrook Park. If it is envisaged that all sewerage and waste water would be dealt with by facilities provided by Thames Water then it should be noted that the facilities in the Farnham area provided by Thames Water are already operating close to full capacity and indeed with further residential development proposed in area designated by the Farnham Neighbourhood Plan significant capital investment would be needed in sewerage and waste water treatment facilities. Indeed in its submission to the outline planning application that has
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