Eastleigh Local Plan 2016 -2036 1. Submission version 2. Strategic Environmental Appraisal

Objections by Twyford Parish Council August 2018

1. Introduction

The Parish of Twyford is within the National Park. Twyford is included in the South Downs National Park because of the quality of its heritage, ecology and landscape. Because the whole parish is part of the National Park, its environment is given national importance with the obligation to protect its natural beauty. The National Park status gives it the highest level of protection from most development.

The purposes and duty of the National Park are to:

1. Conserve and enhance the natural beauty, wildlife and cultural heritage of the area

2. To promote opportunities for the understanding and enjoyment of the special qualities of the National Park by the public

All authorities have a duty when carrying out their statutory duties to have regards to these purposes, and where there is an irreconcilable conflict between these statutory purposes, statutory requires the Sandford Principle to be applied, and the first purpose of the national park will be given priority. See Section 62 environment Act 1995.

As Twyford will be affected by the proposals of the Eastleigh Local Plan, Eastleigh Council itself must have regard to the Statutory Duty.

Twyford Parish Council (TPC) objects to the EBLP in respect the proposals growth to the north and east of Fair oak and the North of Bishopstoke.

This objection is both to the Eastleigh Local Plan policies and the Strategic Appraisal (SEA) Twyford has been preparing a Neighbourhood Plan for the last 4 years, and has accumulated a significant evidence base which is used to support these objections. This is set out in www.twyfordneighbourhoodplan.com. which also includes links to a series of reports commissioned to inform the TNP. Strategic environmental appraisal (SA) has been carried out on the draft Twyford Neighbourhood Plan. The final version is awaited, and will be submitted when published.

In addition TPC has had the benefit of seeing the objections of City Council (of which Twyford is part) and of Parish Council which is our neighbouring parish and with which Twyford has strong community ties and shared interests. TPC endorses both objections and, where appropriate, relies on their evidence.

2. Twyford: description

2.1 General

The 2011 census gives Twyford a population of 1595 which is an increase of 139 from the 2001 census. 744 of inhabitants are male and 851 female. 23% of households contain someone with a long term illness or disability. The proportion of population over 65 is relatively higher than for the Winchester area where the increase has been 50% over the past 20 years.

The 2017 Population estimate of HCC shows a population increase of 51 since 2011 (i.e.to 1646), and a further significant increase in percentage of people over 60.

The 2011 census shows about 674 households within the parish, an increase from 628 in 2001. Twyford has about 50% more detached houses than the South East generally and more than Winchester. Twyford’s houses are larger than average too and the population skewed to higher earners. Over the last 14 years, Twyford has experienced nearly 10% growth in housing, most of which has been at Northfields and Bournefields with infilling elsewhere. The facilities in the village are: • Shop with Post Office and cafe • Hairdressers x 2 • Pharmacy • Doctors Surgery • Dentist • Chiropractor • Physio • Two pubs .one with restaurant • Social Club • Village hall • Two Churches • Sports ground with football cricket tennis and pavilion • Allotments • 2 Play areas • Old people’s home • Businesses which sell directly to the public • Golf club • Stables and livery

There are two schools - a flourishing C of E village school (approx 160 pupils) and a private Prep School for about 400 pupils. There is a business park/ industrial estate employing about 200 people in about 25 separate firms with consent to expand and for a 130 bed care home. Twyford acts as a service centre for neighbouring settlements in respect of its doctor’s surgery, extensive employment base, primary school, private school, shop, cafe, golf club and pubs.

2.2 Historical

The history of Twyford is astonishingly rich, varied and ancient; this is evident in its historic landscape. It enjoys important natural benefits like the ample and constant water of the Itchen River and the fertile soil and natural woodland. These are the basic ingredients of a settled agricultural life and a key foundation for the prosperity of Twyford over the centuries.

The village also sits astride lines of communication. The east-west axis was created first, via the fords of the Itchen leading to the ridgeways. Later, north-south routes became important, connecting the interior of the country with the south coast and its many ports. A number of roads, the river navigation and the railway line still run in a narrow 500 m corridor through the parish and remain dominant features of the landscape.

Twyford is, of course, close to Winchester, a city for nearly 2000 years and capital of from around 900 to 1200. In its day (and before the Black Death), Winchester was one of the largest and most prosperous cities in Europe. For much of that time Winchester was dependent on the produce of its surrounding villages, of which Twyford was always among the most productive. Twyford was a valuable manor of the Bishop of Winchester from Saxon times to 1552; the detailed records of its management from 1108 onwards are recorded in the Pipe Rolls and from 1553 in the papers of the Mildmay family, all in the Record Office.

Twyford shows evidence of continuous occupation, perhaps as far back as the Bronze Age (2000 BC). The church is thought to stand on a ritual place of the Iron Age (1200 BC). There is a Roman villa in Park Lane and recent excavations in the grounds of Twyford School revealed an early Saxon cemetery.

There are seven ancient monuments within the parish, including a Bronze Age barrow, a Roman villa and a 20th century pumping station, with around 70 listed buildings dating from the 14th to the 19th Centuries. There are several mansions and grand houses with grounds, dating from the 1600s to the present day.

The village is Saxon in origin; it is in two parts: North Twyford is probably the earlier part whilst South Twyford was probably established later but before the Norman Conquest. The village runs north-south, parallel to the Itchen but generally above the valley floor except for some 19th century building in what is now the village centre. The ground rises steeply to the east of the village with some more modern building on higher ground.

There is an extensive Conservation Area which incorporates the older parts of the village, both north and south, and the surrounds of the fords of which there are three.

The character of the village is immensely varied

2.3 Ecology Twyford’s ecology is of national and international importance in its own right, both for the species it supports and for their habitats.

The River Itchen is a chalk stream of exceptional quality; (SAC); it is a salmon river, otters live along it and it is home to specialized and rare insects and plant communities. Because of this, the water courses and much of the water meadows are subject to European and national designations.

Twyford has several areas of biologically rich downland, where the chalk downland turf has survived without ploughing and is nutrient poor; it supports a much more diverse and numerous floras than cultivated land. This in turn is the habitat of many types of rare butterfly. In the parish the best areas are the SSSIs of Twyford Down (a nature reserve with St Catherine’s Hill) and the dongas on the Road and Hockley Golf Course and Watley Down.

There are ancient woodlands at Gabriel’s Copse, Cockscomb Hill Copse, Roundbushes Copse and Hazeley Copse, all of which are designated as Sites of Nature Conservation Interest.

The small fields, open spaces and large gardens around and in the village provide additional habitat and form buffers with human activity.

There are several schemes for the protection and enhancement of key existing habitats in the parish. These are mostly the initiative of the Environment Agency (where water is involved) and DEFRA working through Natural England. Both Agencies grant aid to landowners and the local communities, and are assisted in land management by Hampshire and IOW Wildlife Trust and the South Downs National Park. Twyford Parish Council is directly involved in this effort through their ownership of the Meads and of Berry Meadow which are part of the Itchen floodplain.

The Twyford Waterworks and Hockley Golf Course websites, to which links are given below, provide useful information on some of the heritage and important wildlife in these areas.

2.4 Landscape

The protection and enhancement of Twyford’s landscape is a primary objective of the Neighbourhood Plan, taking its lead from the South Downs National Park.

Twyford is included in the national park because its topography and historic landscape exhibit the key features of the South Downs - extensive farmed chalk hills with long horizons and small intimate valleys with the village low down close to the river.

Twyford is at the extreme western end of the South Downs National Park and acts a gateway to it. It also forms, with other land outside the National Park, the setting of the historic city of Winchester at its most sensitive southern end. The western and south-western parts of the parish separate the village from the neighbouring but distinct settlements of Colden Common and Shawford and Compton.

The landscape of Twyford is seen and enjoyed by many thousands of people daily as they pass through on the exceptionally busy roads and by those using the train. This is in addition to those living and working in Twyford and the surrounding villages. It is also seen from the extensive and well used footpath network which provides views into the parish from many vantage points. The Parish Council has commissioned a full study of the landscape of the Parish and the suitability of sites for housing as key pieces of evidence for the Neighbourhood Plan. The reports by Terra Firma build on earlier studies by Winchester City Council and by and others, and by Land Use Consultants for the National Park Authority.

2.5. Flooding and aquifers

The centre of Twyford floods when the winterbourne rises in the Hazeley Valley and springs emerge along the line of the Hazeley road and Finches lane. The line of the Bourne is zoned as a flood zone 3, a high risk area by the Environment Agency. The flood affects property, key services, sewers and local roads which have to be closed. See TNP Environment.

The chalk aquifer underlying and fed by the high ground to the east of the village is an important regionally as a source of drinking water; there are several extraction well pumping significant volumes of water for Eastleigh and .

3. Roads and traffic.... Description continued

3.1 Strategic role of B3335

Twyford Village is bisected by the B3335 which carries approx 18000 vpd and is a major link in the highway system of this part of South Hampshire. At its northern end it joins the M3 motorway in a complex all-moves configuration; it links to the A3090, and the Otterbourne Road (C class but heavily trafficked and of higher capacity than B3335). It continues into Winchester as B3335 (St Cross Road.) To the south the B3335 continues as the Brambridge Road and under the Allbrook rail arch into Eastleigh where it becomes the A335; to the south east it links firstly to B 2177 to Colden Common and Fair oak and B2177 to Bishops Waltham and Wickham and Fareham. It is a diversion route if M3 and/or M27 are closed.

3.2 B3335 as bottleneck through Twyford

The Village of Twyford lies astride the B3335 at its most heavily trafficked and strategic point. The only way round is either the motorway or rural lanes or, to the east, by long and tortuous routes using rural lanes.

The bottleneck at Twyford has been recognised for at least 40 years; it was thought that it would be relieved by M3 and M27, but this has proved not to be the case. The combination of traffic lights and inadequate road space causes daily and severe congestion. There are no plans to increase this capacity.

3.3. Configuration through Twyford

The configuration of B3335 as it passes through the centre of Twyford is a series of bends, with short steep hills on either side of the central traffic lights. The hill sections are sunken lanes with embankments

The B3335 through the built up part of the village is 1.2 km; it is wholly within the Twyford Conservation area. On either side of the road are houses, tight up against the pavement and in some cases forming the highway edge. There are multiple accesses to individual properties. The configuration of the B3335 through Twyford is that of a mediaeval road, parts of which were widened in the 1920’s but parts are as they were in the 1870’s and earlier. The details of the carriageway widths can be supplied if required but should be inspected.

In one key section, the road is so narrow that two HGV’s cannot pass

The congestion associated with the B3335, and multiple other causes, have increased the usage of the other through roads in Twyford in particular the Shawford Road and the Hazeley Road. The capacity of the roads in the village centre where all these heavily used roads converge is further diminished by residents and business parking.

3.4 Bus route

The B3335 through Twyford is the principle bus route serving the settlements to the south. The current hourly service is from Fareham to Winchester via Hedge End, Fair Oak and Botley . This is a double decker.

School buses , also double deckers, take Twyford and Colden Common children to and from the secondary schools in Winchester particularly the Westgate School.

3.5. Pedestrian movement along B3335 and other roads

Pavement widths are almost all sub-standard and some as little as 300mm width; in two places there is no path on one side. Yet the B3335 forms the main pedestrian spine of the village functionally, linking all the principle services in the village; as a result there is significant foot traffic along it, including school children and the elderly.

The second pedestrian route is from Twyford to Shawford where there is a main Line station with direct trains to Waterloo every hour and more at peaks. This is heavily used by villagers and others from a very wide catchment with significant parking problems. The pedestrian route along the Shawford road has no footways in its busiest and narrowest point, with the additional hazard of accesses and parked cars and sharp bends.

3.6. Cycle route

The B3335 forms the only through route for cyclists to the east of the Itchen between Fairoak/Bishopstoke and Winchester. There is no special provision for cyclists who have to share the carriageway with vehicles with no space for passing cannot use the footways a have to use the highway not the there is no room

3.7. Highway danger.

There is high risk in several categories of potential danger through the centre of Twyford ,- vehicle to vehicle; vehicle to pedestrian; vehicle to cyclist. There has been no recent formal assessment .

4.0. Environmental threats to Twyford from existing and from committed developments

4.1 Heritage: Heritage England’s “At risk” register identify Twyford Conservation area as being at risk and deteriorating. 4.2 Ecology: Natural England Both the Itchen river (SAC) and the SSSI on the valley floor are identified as having deteriorated

4.3 Landscape: under threat from:

• continuing building for both housing and employment in the village; to the north in Winchester (employment at Bushfield and 2000 houses at Barton farm) and to south in Colden Common (300 houses).

• M3 Twyford Down widening for Smart Motorway

4.4 Air Pollution: on B 3335 in the centre of Twyford, the air pollution levels were surveyed in 2016 and were found to be significantly above the legal limit for nitrogen dioxide. Other forms of air pollution have not yet been measured.

4.5 Vibration and Noise Pollution . Both effects of traffic, particularly HGV’s

Conclusion on Sections 2, 3 and 4

Sections 2, 3 and 4 set out the base position against which the proposal of the Eastleigh Borough Local plan are to be assessed whether against NPPF or SA.

In summary, the status of Twyford’s multiple assets is recognised by NPPF as of prime importance and material considerations in plan preparation and to be protected by strategic policies ...as they are in the South Downs Plan now submitted for Public examination.

These assets are currently under multiple threats. The proposals of the EBLP and their impact on Twyford are to be judged cumulatively and not in isolation.

5. Eastleigh’s proposals : Twyford’s objection to the effects.

The Submission version of the Eastleigh Borough Local Plan 2016-3036 ( EBLP) contains a proposal (Policy S3) to construct up to 5300 dwellings on land described as ‘north of Bishopstoke and north and east of Fair Oak’ and described more fully in Policy S5.. This includes the need to provide a new road link between Allbrook, Bishopstoke and Fair Oak (the ‘Link road’) approximately half of which will lie outside Eastleigh Borough Council but within Winchester CC jurisdiction.

Twyford village is approx 3 km to the north of the proposed dwellings and all northerly movements to the motorway and Winchester will pass through the village until such time as the link road is constructed.

The location proposed for the 5,300 houses is to be in the least sustainable of those available in Eastleigh but was justified on the basis of the east west link and greater internal sustainability than the alternatives.

This objection relates mainly to EBLP Policies S3, S5 and S6 and S13 and are primarily concerned with the impact of the traffic on Twyford

The basic objection to Policy S.5 is that the location of the housing is in an unsustainable location and the required infrastructure improvements (i.e. Policy S6) will have an unacceptable impact on the area and on Twyford in particular and that the likely transport benefits are overstated. For instance the Use of the link road will add between 2.5 km and 6 km to the 7.2 km journey to Winchester . To the M3 junction 11 the distance is approximately double .

There is also great concern that the likely phasing of this expensive Link Road is such that even greater impact will be suffered by adjoining villages before its completion and by the time it is completed travel patterns from the new settlements will have been established.

In particular there is no control over where residents will work. There is no evidence that the provision of employment close to new houses results in local people taking those jobs. Evidence is generally to the contrary. The major employment provision close to the new houses put forward by the EBLP is the Chickenhall/ Airport Zone. As the Hants Chamber of Commerce have said in their objection to the economic policies of the Plan , the level of investment required to open up this site has prevented its development for the last 20 years. There is little chance of this happening in this plan period .

Additional employment already planned in both Twyford and Winchester will attract in commuters; Winchester City Council has allocated Bushfield Camp for a business park in its Local Plan; this is at the head of the B3335 and will when developed attract commuters from the SGO at fair Oak and Bishopstoke.

The impacts of the SGO upon the Parish of Twyford

Policy S5 development will result in more vehicular traffic through Twyford and Colden Common. At peak times the proposed route via the new Link Road onto the M3 at Junction 12 will be slow moving and congested and longer at several junctions and the M-way itself. Drivers will all have Apps to inform them of journey times and congestion. Cars will continue to drive north along the B3354. At off-peak times drivers will take the shorter, quicker route as they do at present when coming from Eastleigh. HGV and other high-sided vehicles will be unable to pass under the 3.7m high (12’ 3”) Allbrook railway bridge. The restricted headroom bridge means that HGV’s associated with this development (i.e. construction vehicles , deliveries to shops and the proposed new industrial sites) will continue to use the B3354 / B3335 roads northwards through Colden Common and Twyford to access the M3 at J.11 instead of travelling east to J.12. The Transport Assessment shows that even with the development and the Link Road the delay per vehicle through Twyford will double in the AM peak and increase by 50% in the PM peak. [Section 7.2 and pages 112 and 113 of Part 2 of the Systra Transport Assessment]. The 2-way traffic flows through Twyford remain virtually unchanged even with the Link Road

The Transport Assessment Part 2 (Systra May 2018) summarises the situation in Twyford and Colden Common as: 1.6.4 The B3335 corridor through Twyford will be approaching capacity in all test scenarios, with other sections of the corridor operating within capacity.

These statements confirm that roads through Twyford and Colden Common are already approaching capacity and fails to recognise that all of the former and part of the latter lie within the South Downs National Park where government policy is to ‘preserve and enhance the environment.’ Great weight is placed by the Transport Assessment and therefore EBLP that the Link Road will remove traffic from these two settlements yet concedes that the western end of the Link road at Junction 12 on the M3 (Pitmore Copse / Eastleigh North) is over capacity even with the proposed improvements [. . . . the location at greatest stress in terms of network performance is the area around M3 J12, para 1.5.5] and is the subject of a separate study by other consultants for Highways England. The effect of this is that with congestion at the western end of the Link Road traffic will continue to travel on the shorter, more direct route through Twyford and Colden Common .

However it also claims 1.6.4. Local Plan growth does not trigger any significant impacts.

1.6.5 The section of the B3354 between Colden Common and Fishers Pond will be over capacity in all three test scenarios. Conditions are worse in the Baseline than in the Do-Something and Do-More tests indicating that the proposed Northern Link Road is having a positive effect in this area.

The claim that local plan growth has no significant impacts is challenged in these respects: • duration of high volumes of traffic on B3335 will be longer as a direct consequence of the greater congestion • higher speeds of traffic, if the B3335 is clear • higher numbers of HGV’s as there will be more of these and they must to use the B3335 • higher levels of pollution and other effects e.g. vibration on listed buildings • greater impact on public transport • higher impact on cyclists • greater pressure on local rural roads

Impacts on other rural in and adjoining Twyford The rural roads Upham. Owslebury, Morestead and Twyford are being used as rat-runs to avoid the congestion on the T wyford Colden Common corridor. Most of these are within the South Downs National Park . The additional impact on these roads has not been properly assessed by the Transport Assessment (TA). A major failing of this study is to refer to traffic flows and compare them to the ‘capacity’ of the road, particularly the rural roads through Upham, Owslebury, Morestead and parts of Twyford. The TA refers to small increases in traffic flow not affecting overall ‘capacity’ and say any increase is ‘against a very low base’. Whilst this may be valid in an urban/suburban area where roads have kerbs, footways and street lighting this is not valid on the rural roads which have none of these and higher vehicle speeds / the comparison should be made against the environmental capacity of the roads not the ultimate traffic capacity. The changes in traffic flow shown on Figures 39 and40 of Systra TA Vol1 are significant on these rural roads and within the South Downs National Park.

Other impacts on Twyford.

6. Will the Local Plan deliver the benefits on which it relies? There are major uncertainties surrounding the link road in respect of • Timing of delivery and phasing • Usage • Viability • Whether the SGA (S2 and S3 proposals) including can satisfy the requirements of the Habitats Regulations and the Environmental assessment, in particular the consideration of alternatives which may be less damaging.

6.1,Timing of delivery and phasing The proposal to locate up to 5300 homes in S5 Policy (approx. 3350 dwellings in the plan period , i.e. prior to 2036) is predicated on the provision of a new Link Road running east-west between J.12 of the M3 at Pitmore and Bishopstoke/Fair Oak. This road is required at the outset not some 15 -20 years down the line. However, despite policy 55 stating that: ‘before the first application . . . . a detailed Master Plan . . . . including delivery and phasing plan which will set out the timing of the infrastructure delivery ‘ there is no indication when the Link Road will be provided.

At least 1000 homes ...and probably more will need to be sold to enable the developer to fund the new road from the proceeds of development. In the period before the new link road is provided all movement to the north will pass through Twyford, including much of the construction traffic. However the modelling set out in the Transport Assessment compares a Baseline situation with the Policy S5 development and the Link Road.. There is no assessment of the likely interim phasing situation where 1000 dwellings or more are constructed before the Link Road is complete.

6,2 Uncertainties as to cost and viability The costs of the link road do not seem to have been fully worked out. This is looked at by WCC and Colden Common Parish Council in their submissions . One example is that the Link Road will make use of the existing under-railway bridge at Allbrook that is both deficient in width (sub-standard footway on one side only) and height ( 3.7m or 12’3”) and with no cycleway provision. There is no proposal to improve either the width or headroom of this bridge . The only proposed improvements are a possible realignment on the east side to ‘straighten’ the approach and the relocation of the pedestrian/cycle path elsewhere by means of an additional tunnel.. The former is included in the estimated £47.24m (June 2018) cost for the Link Road , but not the latter . Some £13.7 of this cost represents the cost of the eastern end of the Link Road (between Winchester Rd and Mortimers Lane). The costs of adjusting the approach roads to Junction 12 have yet to be worked out. There is great concern that the cost of this Link Road is not feasible as its cost of £33.54m (i.e. excluding the eastern end) represents a contribution of some £10,000 per dwelling ( i.e. £33.54m divided by 3350 units prior to 2036). This road is required at the outset not some 15 -20 years down the line.

7. Is there an alternative location which is more sustainable solution ?

There are inconsistencies in the Policies; namely Policy S1 is based on sustainable development yet the Policy S5 development is in the most unsustainable part of Eastleigh Borough and remote from employment and any alternative transport facilities to the use of a motor car, and therefore fails to comply with Policy S1( v) . There is little the development can introduce to overcome the fact that the Fair Oak area in particular, and to a lesser extent the area north of Bishopstoke, to improve access by non-car means. The area is remote from the railway, difficult to access by bus (only single deck buses can pass under Allbrook bridge) and so buses will have to use Fair Oak Road through Bishopstoke into Eastleigh. Compared with potential other sites ( Horton Heath, Allington Lane etc.) the site is too remote for significant levels of cycle usage. The alternative solution lies in the central area south of Bishopstoke and Fair Oak adjoining Hedge End and West End. This area has • Existing public transport infrastructure • much greater potential for improving public transport for the benefit of the wider community for instance the two rings of Rail lines (Eastleigh/Botley/ Fareham/Swanwick/St Denys/Eastleigh; and Southampton/ Romsey/Eastleigh/Southampton) have capacity • Better potential for alternative forms of transport ( Cycling and • Closer to existing facilities in adjoining wards of Eastleigh Borough. • Uses land of much lower landscape and ecological importance and diversity • Closer to the proposed employment zones at Chickenhall/Railway works/ Airport

8.0.Would this alternative have a lesser impact on Twyford? Has that alternative been properly considered by the SEA

This location would have less impact on Twyford as all of the benefits listed above would reduce the use of the private car and movements to the north via B3335. It is further away with additional road options and more focussed to the south i.e. Southampton which is the major city with higher level facilities.

the Sustainability Appraisal is not adequate in this respect . The Appraisal initially focuses on a comparison between "do nothing" and "do something" which is "red herring" as "do nothing" is not an option or a reasonable alternative. It then goes on to analyse each small area of potential development in detail and undertakes a comparison between these individual areas. However the Appraisal only superficially undertakes a comparison between the complete development options, namely B/C compared with D/E i.e it "misses the wood for the trees" . A proper comparison between the two main whole development options would seem to be an essential requirement for such an appraisal particularly in view of the large number of objections to the council's Preferred Scheme and its impact on people, villages and environment .

To make the Plan legally compliant, the Sustainability Assessment should provide a detailed comparison of Options B/C and D/E using an appropriate and equal level of evidence for both and only then should a preferred Scheme be selected.

9.0 If the SGO is found sound, what mitigation should be required for Twyford ?

Mitigation measures for the B3335 through Twyford would be justified and necessary to take account of the additional harm caused by the EBLP. These should include:

• Financial provision for N/S cycleway

• Traffic management measures to be agreed with HCC for B3335 and side roads affected especially Shawford Road and provision for implementation

• Compensation for damage to listed buildings

• Anti-pollution measures

• Flood mitigation measures

Further consideration should be given to this when the full information is available .

TPC 8th Aug 2018