Basingstoke and Deane Borough Council

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Online at www.basingstoke.gov.uk/go/localplan By returning this form to Basingstoke and Deane Borough Council by post to: Planning Policy Team, Civic Offices, London Road, Basingstoke RG21 4AH by email to: [email protected] by fax to: 01256 845200

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

PART A Personal details (If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2) Agent’s details (if applicable) Title Mr Title First name Bruce First name

Last name Batting Last name Job title Parish Councillor Job title (where relevant) (where relevant) Organisation Sherfield-on-Loddon Parish Organisation (where relevant) Council (where relevant) Address Apple Tree Cottage, Who are you Sherfield-on-Loddon, Hook, representing? Hampshire Postcode RG27 0EE Address

Telephone number 01256 883605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph 2.2 b. Policy 2029 Vision & c. Policies Objectives Map

2. Do you think the Local Plan is:

a. Legally Compliant a.Yes (To be ‘legally compliant’ the Local Plan has to be prepared in accordance with the Duty to Co-operate and legal and No procedural requirements. This is required by Government Guidance). If no, please provide further detail overleaf

b. Sound Yes To be ‘sound’, a Local Plan should be positively prepared, justified, effective and consistent with national policy. No This is required by Government Guidance. If no, please select on which test(s) of soundness by ticking the relevant boxes below and provide further detail overleaf.

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

b. Please give details of why you consider the Local Plan is not legally compliant or is unsound. Please be as precise as possible. Alternatively, if you wish to support the legal compliance or soundness of the Local Plan, please also use this box to set out your comments.

Paragraph 2.2 . p.15 states,

“The Vision was prepared through detailed discussions with partners and the community* to represent the type of place that the borough should be in the future. This is a completely correct assertion. The Vision Statement on page 15 took several months to thrash out beginning in or before September 2009. The public and other bodies were much involved and contributed to the final version and rightly expect its principles to be followed in the final document. There are many instances of failure and we explain these under relevant paragraphs and policies. Furthermore the Vision Statement states, “ we create inviting places and communities where people want to live” and “we live and work in harmony with the natural elements and systems on which we depend”. With reference to SS3.9 and SS3.7 we have seen no evidence in any supporting document which shows that any of Basingstoke’s residents, current or future, would want to live close to the Incinerator and the Sewage Treatment Works, which we understand is to be developed to treat solid waste shipped in from outside the Borough. e.g. Guildford plus other authorities. Additionally building 900 homes in the open countryside, on top of a substantial hill, where it will dominate a valley precious to a great many of the Borough’s residents cannot be claimed to be “in harmony with the natural elements and systems”.

The Pre Submission Local Plan is therefore unsound

Continue on a separate sheet if necessary

Please note your representation should cover succinctly all the information necessary to support/justify the representation and the suggested change, as there will not normally be a subsequent opportunity to make further representations based on the original representation at Pre-submission stage. After this stage, further submissions will be only at the request of the planning inspector, based on the matters and issues he/she identifies for examination. d. If your representation is seeking a change, do you consider it necessary to speak at the examination in public?

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

e. If you wish to speak at the examination in public, please outline why you consider this to be necessary. Please note the planning inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination.

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

In complying with the Data Protection Act 1998, Basingstoke and Deane Borough Council confirms that it will process personal data gathered from this form only for the purposes relating to the consultation. It is intended to publish responses to the Pre-Submission Local Plan consultation on the borough council’s website. However, it should be noted that all personal information (with the exception of names and organisation name, where appropriate) will not be published.

Personal information will be added to the council’s Local Plan consultation database and will be used to keep you informed of progress with the Local Plan and in order to consult with you further at each stage of the process to enable you to make further comments.

Personal information will also be shared with the Government appointed planning inspector (from the Planning Inspectorate), who may wish to contact you to discuss your comments and concerns, prior to formal examination of the Local Plan and supporting documents.

a. If you wish to be notified of the Submission of the Local Plan please tick box b. If you wish to be notified of the Inspector’s Report please tick box c. If you wish to be notified of the Adoption of the Local Plan please tick box d. If you do not wish to be contacted at future stages of the preparation of the Local Plan please tick box e. If you do not wish to receive email newsletters keeping you up to date on the next stages of preparation of the Local Plan please tick box

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy EM2 Strategic c. Policies 7d Gaps - Map Sherfield-on- Loddon

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy EM2 Strategic Gaps Map 7d - Sherfield-on-Loddon

Those working on the Neighbourhood Plan have identified the need for a residential development on the west side of the village to cater for those wishing to get onto the housing ladder and for those seeking to down size from larger properties in the village and the plan as drawn does not allow any space for a development of this nature.

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy EM2 Strategic Gaps Map 7d - Sherfield-on-Loddon Sherfield-on-Loddon Parish Council requests that the edge of the strategic gap, and indeed the settlement policy boundary, should run roughly north-south from the rear of 15 Bullsdown Close in the north to Goddards Lane in the south.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy EM2 Strategic c. Policies 7e Gaps - Tadley Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

EM2 Strategic Gaps Tadley Map 7e

The policy is not sound as the lack of development at Tadley results in a significant negative impact on the Sustainability Appraisal housing objective, both in terms of the provision of housing to meet local needs and to meet the wider Borough needs. This may have adverse implications on the economic objectives ( particularly within Tadley) which seek to ensure sustainable communities. [ Pre-Submission Local Plan Sustainability Appraisal Report. Paras 9.14 & 9.15, pp76&77 ]

The policy is also likely to have a number of secondary impacts on the Tadley and Burghfield areas as a consequence. A lack of investment in the area is one such effect that could have consequences for residents and affect the services,amenities and facilities they need. Natural growth in Tadley will be stifled,, with families growing up and unable to live in the same area. The mix of housing stock will remain the same and any deficiencies or imbalances in the housing stock will not be addressed. [ Pre-Submission Local Plan Sustainability Appraisal Report. Paras. 9.14 & 9.15, pp 76 &77 ]

Whilst the Pre-Submission Core Strategy dated Feb.2012 stated that the ONR would advise against nearly all residential development within the inner planning zone defined on the proposals map, and that during the plan period a less restrictive approach may be taken resulting from changes to inputs to their model, it was subsequently agreed at a meeting between Borough Officers and the ONR that the ONR would consider development on a case by case basis. However this policy is not reflected in the Draft Local Plan documentation, and there is no evidence of any site by site considerations. .

The fundamental problem with development at Tadley is that the ONR are content to focus on the Radiation Emergency Preparedness and Public Information Regulations (REPPIR) which they concede is consequence based rather than risk based. With a 2008 review of AWE fault sequences concluding that the probability of an incident at AWE which would cause a materially harmful radiation dose to the general public of 1 in 100,000 years and possibly 1 in 1,000,000 years, it is inconceivable that risk should not be a material consideration.

Further more the ONR case for objecting to development at Tadley is based largely on the regulations applicable to Nuclear Power Stations. These regulations bear no relation to the technology at AWE, and the ONR accept that there is no specific policy dealing with a site such as AWE.

There are also questions arising from the ONR view that a radiation dose of 30 m Sieverts (mSv) is significantly harmful and very hazardous to health when the annual allowable dose for AWE workers is 20mSv, US regulatory commission limits are 50mSv per year, and the short term allowable dose at the Fukushima emergency was 250mSv.

It is considered that the Borough Council are placing undue weight on the views of the ONR, views which the the Secretary of State for Communities and Local Government did not accept when approving development at Boundary Hall Tadley, and with the probability of a significant incident at AWE being extremely remote and the risk acceptable to Government, the officers view that to include the Tadley sites may render the Local Plan unsound is itself unsound. There is the potential for some 1800 houses at Tadley and some sites should be included in the Local Plan.

Sherfield-on-Loddon Parish Council OBJECTS to this Strategic Gap which is not strategic as its only purpose is to prevent development, and REQUEST its removal.

There is the potential for some 1800 houses at Tadley and some sites should be included in the Local Plan.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy EM5 Green c. Policies Infrastructure Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy EM5 Green Infrastructure

" Implementation and Monitoring" p88 states that implementation etc, will be specifically through GIS. An important and basic part of GIS concerns the two Biodiversity Priority Areas (BPA) Rivers Loddon and Test shown on plans 26 & 27, which are to be researched and assessed as Biodiversity Opportunity Areas (BOA).

Sherfield-on-Loddon Parish Council objects to that part of river Loddon in Plan 26 east of Policy SS3.9 because the northern boundary of the BPA is drawn far too tightly against the river whereas the catchment area should include the currently undeveloped part of the watershed starting at Park Pale and A33. The purpose of the BPA is to focus attention on areas of highest priority for opportunities to improve Biodiversity. While SS3.9 is geographically within the Loddon catchment, it is not within the BOA. It is, however close to the boundary of the BPA and as such will play an important function in supporting the native habitats of the BPA. The inclusion of SS3.9 in this valley will compromise the proposals for green infrastructure, e.g. to promote perhaps as a priority the creation of a BPA and be likely to disrupt and alter the character of the only corridor /link between the valley and Chineham.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy EM6 Water c. Policies Quality & SS4 Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy EM6 Water Quality & Policy SS4

The Council accepts that the South East is `water stressed' and that the River Loddon currently fails to meet `good' status under the Water Framework Directive. There is biological evidence, beside physiochemical, of deterioration of the water quality. Over past years of Town expansion fears have been expressed by Thames Water and the House of Lords Science and Technology Committee 2005- 6 that there was insufficient river flow past the Sewage Treatment Works (STW) to dilute the effluent. Surveys by the Environment Agency have shown a high proportion of nutrient tolerant plants above and below the STW which show that at both monitoring sites the river is being impacted by nutrients such as phosphates. Also, the Loddon is a chalk stream depending on aquifers in the chalk. Any development which would require further abstraction would therefore impact on the current high levels of phosphates. But there has been no monitoring of the river flow downstream of the STW since 2003. New meters are being installed but will not be in action until the end of the financial year 2013 / 2014. - It is understood that present day technology cannot improve the river status, and that actions by the Environment Agency might only be deliverable between 2016 and 2021. - These facts show that there must be considerable doubts as to the ability of the Waste Water Infrastructure to protect the river environment. It is not enough to rely on the hopes expressed in this policy and SS4 Ensuring a Supply of Deliverable Sites that monitoring will protect it. Sherfield-on-Loddon Parish Council believes that action needs to be proactive before development is committed, not reactive after the event, particularly where the quality of the London needs to be enhanced and maintained as it becomes a main feeder to the Thames which itself is the main supply for Loddon. Principle 15 of the 1992 Rio Summit states ` In order to protect the environment the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversable damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degredation' Policy EM6 second paragraph passes the duty to control development affecting water quality to Policy SS4. But SS4 second paragraph merely states ` the council will resist granting further planning applications - - -', whereas Policy CN5 Infrastructure third and fourth paragraphs seek to make it clear that ` New infrastructure should be provided prior to occupation of the development'. - For the above reasons Sherfield-on-Loddon Parish Council OBJECTS to Policy EM6 second paragraph because it is weak and complacent and at odds with Policy CN5.

No development should be permitted unless it can be clearly shown that there will be no deterioration in the status of the River Loddon or rivers in the Borough. An essential prerequisite should be that any necessary work to the STW should be identified, funding agreed, and completed before permission for any major development be granted. Sherfield-on-Loddon Parish Council therefore REQUESTS that the wording of Policies EM6 and SS4 should be altered to match the strength of Policy CN5.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy EM - Sequential c. Policies Flood Test Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy EM7 - Sequential Flood Test

Site SS3.9 has been selected in direct contravention of the Sequential Test based on flood risk as defined in the glossary p143, and which is National Policy as required by the National Planning Policy Framework. SS3.9 is listed as the highest risk area (band8) in the list of selected sites whereas there are other sites which are reasonably available namely BAS 133 Hounsome Fields (1000 houses), BAS 099 Scrapps Farm (80 houses), BAS 141 Land at Worting Road (280 houses), and numerous sites at Tadley (1800 houses, with 620 not identified in the consultation zone), with a lower risk that have not been selected. The selection of SS3.9 for development is therefore not sound.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

PART A Personal details (If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2) Agent‟s details (if applicable) Title Mr Title First name Bruce First name

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy SS3.3 Razor's c. Policies Farm Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

SS3.3. Razors Farm

1. Selecting Razors Farm for 420 dwellings fails the Vision, which states “• we enrich the different characters of and links between towns, villages and the countryside, …. and the River Loddon area*” because it sets out to create a new community, unrelated to either Taylors Farm or the Chineham Business Park. It is effectively cut off from and disassociated from Taylors Farm by the Basingstoke-Reading railway line, and it is not a business park. In both respects it cannot be said to be „enriching‟ any link with either. Furthermore if built there will be around 950 new residents who are likely to add to the pressures, especially human pressures, on the natural heritage of the Loddon Valley.

2. These pressures will result in an additional burden on the Biodiversity value of the Loddon Valley, which is required to be protected and enhanced by the Natural Environment and Rural Communities Act and National Planning Policy Guidance. Consequently the Policy will be ineffective, thus unsound, and not in accordance with National Policy.

3. Furthermore there will be an additional impact on the River Loddon itself whereby it cannot be demonstrated that the objectives of the Water Framework Directive (WFD) can be met, in a river which is currently failing to meet the good ecological status as required by the WFD.

4. Development of site SS3.3 would increase the traffic on the A33, which is already overloaded, beyond its capacity.

5. SS3.9 (h) The assumed site access is from A33. Queuing, delays, congestion already occur along A33. Transport Assessment August 2013 Fourth issue pp42/43. Table 3.20 includes junctions A33/Gaiger Av, Binfields roundabout, Crockford roundabout, and Thornhill Way/A33 with the prediction that each and every junction could not cope if the Local Plan scenarios were implemented. Para. 4.3.9. p55 of the report states " An ideal solution is to widen the A33 to two lanes but this is not explored in this study....". Policies SS3.9 (h) and SS3.7 (c) require development to " include measures to mitigate the impact of development on the local road network including improvements to..." three of these junctions. Yet Appendix A Infrastructure Delivery Plan (IDP) indicates that no funding has been identified. The IDP also indicates the total cost at £8m - which increases to £9.5m when the consequential and necessary A33/339 roundabout works are included. Also, trip rates in Table 8.26 of the Transport Assessment for SS3.9/7 are inconsistent with other town areas,which combined with dubious reliance on employment and bus timetables would have produced an underestimate of the impact on the relevant junction analyses.

6. Sherfield-on-Loddon Parish Council supports the objections to Policy SS3.3 raised by Chineham Parish Council.

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy SS3.3 Razor's Farm Sherfield-on-Loddon Parish Council believes that Razor's Farm should be taken out of the Local Plan Submission and that further development should be concentrated on the Manydown land, which was puchased for residential development by the Borough and County Councils on the west side of Basingstoke

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

a. If you wish to be notified of the Submission of the Local Plan please tick box b. If you wish to be notified of the Inspector‟s Report please tick box c. If you wish to be notified of the Adoption of the Local Plan please tick box d. If you do not wish to be contacted at future stages of the preparation of the Local Plan please tick box e. If you do not wish to receive email newsletters keeping you up to date on the next stages of preparation of the Local Plan please tick box

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy SS3.7 Redlands c. Policies Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy SS3.7. Redlands.

The Council accepts that if SS3.7 was a stand alone site in the countryside without SS3.9 it could not be justified as an allocation. The council requires the two sites SS3.7 and SS3.9 to be master planned in combination, and as Sherfield-on-Loddon Parish Council's representations for both sites considerably overlap, please consider points 1 to 8 incl and 11 & 12 of our response to SS3.9 East of Basingstoke in so far that they relate to SS3.7.

Sherfield-on-Loddon Parish Council OBJECTS to SS3.7 and REQUESTS deletion of Policy SS3.7 and the site from Policy Map 1b.

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy SS3.7 Redlands Sherfield-on-Loddon Parish Council acknowledges that in the 2011 to 2029 Plan period greenfield sites will need to be developed in order to meet house building targets, but believes for the above reasons that both SS3.9 and SS3.7 are insecurely located and should be deleted as unsound. Sherfield-on-Loddon Parish Council believes that an alternative and better choice would be BAS 133 Hounsome Fields in the south west corner of the town.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy SS3.8 Cufaude c. Policies Farm Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy SS3.8 Cufaude Farm

1. Selecting Cufaude Farm for 390 dwellings fails the Vision, which states “• we enrich the different characters of and links between towns, villages and the countryside, …. and the River Loddon area*” because it sets out, together with SS3.3 Razors Farm, to create a new community unrelated to either Taylors Farm or the Chineham Business Park. It cannot be said to be „enriching‟ any link with either. Furthermore if built there will be around 730 new residents who are likely to add to the pressures, especially human pressures, on the natural heritage of the Loddon Valley.

4.Development of site SS3.8 would increase the traffic on the A33, which is already overloaded, beyond its capacity. It would also require significant changes to Cufaude Lane which in turn would result in further congestion at Chineham

5. Queuing, delays, congestion already occur along A33. Transport Assessment August 2013 Fourth issue pp42/43. Table 3.20 includes Binfields roundabout, and Crockford Lane roundabout, and Local Plan scenarios predict each junction could not cope. Para. 4.3.9. p55 of the report states " An ideal solution is to widen the A33 to two lanes but this is not explored in this study....". Policy SS3.8 requires development to " include measures to mitigate the impact of development on the local road network including improvements to..." these two junctions. Yet Appendix A Infrastructure Delivery Plan (IDP) indicates that no funding has been identified. Also, trip rates in Table 8.26 of the Transport Assessment for SS3.8 are inconsistent with other town areas,which combined with dubious reliance on employment and bus timetables would have produced an underestimate of the impact on the relevant junction analyses

6. Development of SS3.8 would be the start of expansion to the North with no natural boundary before reaching Bramley.

7. Sherfield-on-Loddon parish Council supports the objections to Policy SS3.8 raised by Chineham Parish Council.

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy SS3.8 Cufaude Farm Sherfield-on-Loddon Parish Council believes that Cufaude Farm should be taken out of the Local Plan Submission and that further development should be concentrated on the Manydown land, which was puchased for residential development by the Borough and County Councils on the west side of Basingstoke

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy SS3.9 East of c. Policies Basingstoke Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy SS3.9. East of Basingstoke.

1. The site is large and in the open countryside and not within a SPB. Development proposals for the greater part of SS3.9 included in a comprehensive scheme were rejected in previous local plans.It has landscape scale and is essentially part of the Loddon River valley character with a south and east facing slope flanking the north side of the Loddon. It can be seen over varying distances clearly from public footpaths and highways from most directions, with total exposure to south and east where the east boundary does not follow any distinct physical boundary within the landscape or appear to be based on any ecological reasoning. As such it is difficult to accept how it has been justified or can be defended. The "Vision and Objectives " in the Pre Submission Local Plan (PSLP) and the Green Infrastructure Strategy (GIS) make it clear that the two river valleys Loddon and Test are key features in the Borough.

2. In principle this development proposal and linked to SS3.7 conflicts with " Basingstoke and Deane Context" para. 1.23. Also with " 2029 Vision and Objectives "- " A connected and vibrant place" para.2.5 bullet points 5,9,10,11,12 together with para. 2.6 bullet points 8,15,21,23,25 - the development would urbanise the valley and defeat the intention to maintain and enhance the distinctive place and character of the valley. The Landscape Capacity Study does not recommend area "B" for development.

3. Approval of this site, with or without SS3.7, would undoubtedly create a precedent to attract more development proposals further south and east across the River Loddon to the A30. A previous comprehensive scheme for Basingstoke East for that entire area of up to 5000 dwellings was rejected in 2005 following a Public Inquiry. Housing estimates in the final version 7 SHLAA for SS3.9 + BAS 102 Lodge Farm + BAS 103 Poors Farm total some 3150 dwellings. Any major development consuming that area would need to be subject to master-planning - a comprehensive scheme, which Sherfield-on-Loddon Parish Council believes would, in the light of Manydown, not be allocated. Sherfield-on-Loddon Parish Council supports the fact that a major area on the west town perimeter using land actively purchased several years ago by HCC and BDBC specifically for housing and facilitates up to about 7000 dwellings is the most appropriate direction of growth. Therefore, Sherfield-on-Loddon Parish Council believes that SS3.9 + SS3.7 represent a piecemeal housing estate divorced f rom Chineham by the A33, which would seriously damage a key feature of the Borough.

4. SS3.9 and S3.7 are bounded by public footpaths which are well used. The combination of the Loddon, the pastoral character, and the open valley side produce a marked tranquillity which is notable as soon as walkers leave the edge of the town and Old Basing village to enter the valley. Park Pale Ancient Monument and A33 well define that sensitive change; clearly the further down the valley one goes the greater the sense of solitude. The "Vision" values the above characteristics which are rare so close to urban areas. The development would eliminate a natural and unique attribute by deliberately forcing the building of over a thousand dwellings, with over two thousand people, with the attendant disturbance and potential pollution at such a critical location.

5. Parts of SS3.9 and SS3.7 suffer from sudden emissions of foul odour from the Sewage Treatment Works (STW) and Incinerator site on Whitmarsh Lane nearby to the east. The vagaries of wind direction and unpredictable times spread the impact over varying areas. Whereas that impact could probably be reduced by design inside the buildings, it could not be entirely prevented from irritating and upsetting residents. The impact would certainly be experienced and be especially undesirable in and around the social, community,and educational facilities required under SS3.9(c). The PSLP does not appear to contain any proposal to prevent emission of odours from the STW. Nor does it take account of a Thames Water proposal to build another Incinerator at the STW site to burn partially treated sewage including transporting waste into that site from four other towns, Newbury, Fleet, Farnham and Guildford. Sherfield-on-Loddon Parish Council believes that any suggested `cordon sanitaire' within SS3.9 would be almost impossible to generate a solution to the impact because of wind change, etc. The STW/Incinerator site was chosen in the 1960s to be deliberately located far enough from the expanding town and village to avoid the effects of such pollution, since when Chineham has been much developed. Fortunately the river valley remains, but SS3.9 is too close to the pollution source. For these reasons Sherfield-on- Loddon Parish Council believes the proposed development falls foul of the principles of Policy EM12 - Pollution, which among other things includes prevention of `pollution' which is detrimental to Quality of life with footnotes 23,24,25 and paras. 6.92/6.93 Air Quality.

6. SS3.9 and SS3.7 conflict with the recommendations in the Evidence Base Landscape Capacity Study November 2010 that land in SS3.9 north of Whitmarsh lane be not developed and that SS3.7 preferably be not developed. Whitmarsh Lane east-west across SS3.9 with combined trees, footpath, access road to STW/Incinerator, Pettys Brook, land liable to flood and SINC, forms a clear and substantial break line. The land rises from it northwards to high ground in SS3.7 and development would accentuate an undesirable feeling of ribbon development creeping towards Sherfield on Loddon. Were it necessary to place any dwellings on any part of SS3.9, Whitmarsh Lane should become the northern boundary. It is noted that the previous rejected East of Basingstoke comprehensive scheme did not propose development north of Whitmarsh Lane.

7. SS3.9 eastern boundary reflects the HCC ownership boundary, cutting across the valley slope for about two thirds of its length, probably to allow for the route / line of a proposed link road between A33 and Black Dam roundabout on Basingstoke Ringway as part of an amendment to Basingstoke Town Map in 1962 which the Secretary of State deleted. That boundary is devoid of any feature such that it could not be successfully screened by trees for many years, including a prolonged construction period - especially if the proposed 900 dwellings were phased into a second Plan period. Even then mature trees would not disguise the intrusion of buildings on the higher slope, together with light pollution from the development.

8. SS3.9 (h) The assumed site access is from A33. Queuing, delays, congestion already occur along A33. Transport Assessment August 2013 Fourth issue pp42/43. Table 3.20 includes junctions A33/Gaiger Av, Binfields roundabout, Crockford roundabout and Thornhill Way/A33 with the prediction that each and every junction could not cope if the Local Plan scenarios were implemented. Para. 4.3.9. p55 of the report states " An ideal solution is to widen the A33 to two lanes but this is not explored in this study....". Policies SS3.9 (h) and SS3.7 (c) require development to " include measures to mitigate the impact of development on the local road network including improvements to..." three of these junctions. Yet Appendix A Infrastructure Delivery Plan (IDP) indicates that no funding has been identified. The IDP also indicates the total cost at £8m - which increases to £9.5m when the consequential and necessary A33/339 roundabout works are included. Also, trip rates in Table 8.26 of the Transport Assessment for SS3.9/7 are inconsistent with other town areas,which combined with dubious reliance on employment and bus timetables would have produced an underestimate of the impact on the relevant junction analyses.

9. Site SS3.9 has been selected in direct contravention of the Sequential Test based on flood risk as defined in the glossary p143, and which is National Policy as required by the National Planning Policy Framework. SS3.9 is listed as the highest risk area (band8) in the list of selected sites whereas there are other sites which are reasonably available namely BAS 133 Hounsome Fields (1000 houses), BAS 099 Scrapps Farm (80 houses), BAS 141 Land at Worting Road (280 houses), and numerous sites at Tadley (1800 houses, with 620 not identified in the consultation zone), with a lower risk that have not been selected. The selection of SS3.9 for development is therefore not sound.

10. The selection of SS3.9 is contrary to the Environment Agency response to the 2008 SHLAA consultation where they identified the site as being inappropriate for development, objected to its inclusion and recommended its removal. In response to the 2010 SHLAA consultation they stated the site continues to be considered `high risk'. It is also contrary to the recommendation by the P&IOSCOM at their meeting in Sept. 2011 and noted by the Cabinet in Feb 2013 that SS3.9 should not be include in the Local Plan.

11. Policies SS3.7 (g) and SS3.9 (o) require joint master planning for SS3.7/SS3.9, and SS3.9 (h) indicates access between the two sites. SS3.9 neither includes a requirement to close existing vehicle access to Pyotts Hill, or to preclude any new vehicular accesses to Pyotts Hill. Pyotts Hill is unclassified, within Old Basing Conservation Area, substandard width with no footpaths in Upper Pyotts Hill, substandard width with part of one footpath in Lower Pyotts Hill,over 20 individual houses and cottages in Upper Pyotts Hill, 40 homes of mixed character and a car breakers yard in Lower Pyotts Hill with a great number of cars parked on the roadside, leading to a single lane river bridge into the main village street, which has two single lane railway bridges, streets blocked on many occasions with parked cars and a second single lane river bridge. Lower Pyotts Hill is used as a "rat run " particularly in the mornings by a great deal of traffic seeking to connect through Lychpit housing area to the town.

The Inspectors report of November 2005 declared that traffic from the then proposed comprehensive development would " harm the character of Old Basing village, residential amenity and highway safety" - and was not to be tolerated.

SS3.9 (i) requires " the ability to service the site by public transport". Any feeder road for this size of development would in accordance with standards be suitable for bus transport. The possibility of a bus gate is raised in the Evidence Base site assessment January 2013, p112 " there is limited scope to provide additional exits from this site due to a heritage site (Park Pale Ancient Monument), although a bus gate may be feasible to the south". Such an access would :- be in direct conflict with SS3.9 (e) & (f), "e. Respect and provide appropriate buffing to the historic Park Pale feature on the western boundary of the site"; " f. Preserve and enhance the architectural and historic significance of the Old Basing Conservation Area and nearby listed buildings, including the Grade 2 listed Lodge Farm, including their setting, and ensure sufficient mitigation measures are providedwhen required".

breach Park Pale Ancient Monument which inherently rests on its linear character;

require widening and relaying the lane to a minimum width of at least 7.3 metres from the existing 5.2 metres width, plus a footpath or footpaths which altogether would require removal of part of Park Pale Ancient Monument;

interface with and damage the pleasantness of the lane for the many people of Chineham and Lychpit who use it as a friendly walk through the Conservation Area to Basing Common, the historic Tudor Barn / Basing House Ancient Monument and Mill House public house;

would jeopardise the status of Pyotts Hill as part of the National Cycle Network Route 23- "a route that minimises dangers for cyclists, pedestrians, and other users and gives a feeling of security". carry the risk of a future change from a bus gate to a road sign enforced exit as used elsewhere in the borough as there is no restriction in the Local Plan to prevent such a change. A road sign exit is not likely to be enforced which would then become a traffic route through Pyotts Hill and the village with all the upset that would ensue.

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy SS3.9 East of Basingstoke Sherfield-on-Loddon Parish Council acknowledges that in the 2011 to 2029 Plan period greenfield sites will need to be developed in order to meet house building targets, but believes for the above reasons that both SS3.9 and SS3.7 are insecurely located and should be deleted as unsound. Sherfield-on-Loddon Parish Council believes that an alternative and better choice would be BAS 133 Hounsome Fields in the south west corner of the town.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy SS3.9 East of c. Policies Basingstoke Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy SS3.9. East of Basingstoke.

breach Park Pale Ancient Monument which inherently rests on its linear character;

Continue on a separate sheet if necessary c. Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified above where this relates to soundness. You will need to say why this change will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Policy SS3.9 East of Basingstoke Sherfield-on-Loddon Parish Council acknowledges that in the 2011 to 2029 Plan period greenfield sites will need to be developed in order to meet house building targets, but believes for the above reasons that both SS3.9 and SS3.7 are insecurely located and should be deleted as unsound. Sherfield-on-Loddon Parish Council believes that an alternative and better choice would be BAS 133 Hounsome Fields in the south west corner of the town.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement

Ref: (for official use only)

Basingstoke and Deane Borough Council Pre – Submission Local Plan Representation Form Representations should be submitted by no later than 4pm on Friday 4 October 2013:

Further guidance on how to complete the form is contained within the Statement of Procedure, available to download online at www.basingstoke.gov.uk/go/localplan

This form has two parts: Part A – personal details Part B – your representation(s) - please fill in a separate sheet for each representation you wish to make

Telephone number 01256 882605 Postcode Email address [email protected] Telephone number

Preferred method Email Email address of contact Post Preferred method of Email contact Post

Are you responding as:

An individual A town or parish council

A district/borough council A borough councillor/MP

On behalf of an organisation On behalf of a community group

A landowner/developer/agent/architect Other

PART B PLEASE USE A SEPARATE SHEET FOR EACH REPRESENTATION

1. To which part of the Local Plan does this representation relate?

a. Paragraph b. Policy Policy SS3.10 c. Policies Manydown Map

2. Do you think the Local Plan is:

a. Tests of soundness

a. Positively Prepared To be positively prepared the plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

b. Justified To be justified, the plan must be:  Founded on a robust and credible evidence base  The most appropriate strategy when considered against the reasonable alternatives

c. Effective To be effective, the plan must be:-  Deliverable  Flexible  Able to be monitored

d. Consistent with National Policy The plan must be consistent with government guidance, as set out within the National Planning Policy Framework (NPPF)

Policy SS3.10 Manydown

1. The number of houses proposed, 3080, should be increased. Whilst the Officers claim that a maximum of 300 dwellings can be built in a year, this conflicts with the view of the Inspector at the Local Plan Public Inquiry in 2005, viz 360dpa, the data in earlier versions of the SHLAA, viz 350 dpa, and the Tibbalds Manydown report dated Sept. 2012, viz 350 dpa. The figure of 3080 is constrained by the councils estimated rate of yield per year, no evidence has been found showing the potential yield for the areas selected for development. If the Tibbalds figure of 20dph has been used, then using 24dph, as for other sites, would increase the site potential to 3696.

2. The Tibbalds report states they have used " a reasonably conservative gross (which should be net) development density of 20 dwellings per hectare" when calculating the Potential Site Capacity. The average density on the other sites selected in the Local Plan is some 24 dph which accords with the calculations used in the Landscape Capacity Study dated 2010. There is no apparent reason for density at Manydown to be at variance with all the other proposed sites.

3. Sherfield-on-Loddon Parish Council notes that meetings of the EPPOSCOM and MEC held in Sept 2013 recommended to P&IOSCOM that the land south of the railway line within the Manydown allocation SS3.10 for about 400 dwellings be labeled `reserve' on the understanding that the remainder of the Manydown allocation will produce 3080 dwellings.

4. A study of development in Basingstoke since the signing of the Town Development Agreement in 1961 indicates that being able to plan at a large scale can be very beneficial. A comparison between the developments at Chineham and at Brighton Hill/Hatch Warren makes the point.

5. The development at Chineham arose from a major allocation in the Town Map Amendment Map of 1976, which was to provide for about 4000 dwellings and a full range of infrastructure and facilities to support a population then estimated to total 12,000. Brighton Hill/Hatch Warren, with a similar population, was developed following a series of much smaller incremental allocations, and of necessity had to be planned in a more piecemeal manner. The inability to plan Brighton Hill/Hatch Warren comprehensively has resulted in an urban expansion which is arguably visually less cohesive and in which facilities to support the population are more scattered. There is also a much less strong structural landscape framework.

6. The joint purchase of the land at Manydown by the two local authorities provides an opportunity not available for a generation to provide a truly groundbreaking extension to the town. The opportunity should be grasped wholeheartedly, and not just begrudgingly following the High Court’s admonition of the Borough Council for playing party politics with the town’s future. The bigger the development area the more comprehensive the planning can be and the better the chance of securing the finance for the vital infrastructure that will be required.

7. The Pre-Submission Plan at Policy SS3.10 (o) shows the need for some form of western relief road. It is seen to be outside the plan period and merely a matter of route safeguarding for the future. That future is at least 16 years away, which is too long for the town to wait. By maximizing development in the south-west on sites SS3.11 Golf Course, SS3.2 Kennel Farm, and BAS 133 Hounsome Fields, at the expense of less than satisfactory allocations elsewhere, ( e.g. SS3.9), it should be possible to advance the construction of that relief road. We support the route of the Western `Bypass' to be renamed `Link', as defined in the Transport Study issue 4 dated Aug.2013. The alternative is for the south-western sector of Basingstoke to suffer years of further traffic disruption while Brighton Hill Roundabout, Winchester Road Roundabout and Kempshott Roundabout are radically altered in an attempt to cope with increasing traffic. If the anticipated improvements to the Black Dam M3 junction can be carried out it is entirely likely that traffic will begin to use the Motorway, both west/east and east/west, to reach the other side of town out of sheer frustration with the worsening traffic situation. Not a situation to be encouraged, whereas a Western Link road would mitigate this situation.

8. BAS 099 Scrapps Farm and BAS 141 Worting sites should be included in the list of sites to be developed as SHLAA version 7, pages 166 & 199 of 306, states that both sites are achievable should development come forward in this location, - Manydown, and should be undertaken on a comprehensive basis as part of a wider major development area. Sherfield-on-Loddon Parish Council understands that as a result of the EPPOSCM and MEC meetings in Sept.2013 the progress of the overall master plan for Manydown is proceeding well and that the landowners of the areas involved will be kept in touch with the detailed progress of the master plan. This underlines the possibility of sites BAS 099 and BAS 141, assessed in SHLAA v7 as 360 dwellings, being developed well within the plan period.

9. There is no safeguarding map for the link road in the Local Plan but Transport Assessment August 2013 indicates a line on 14 diagrams for traffic modelling from the railway to M3 junction 7, close to BAS 133 Hounsome Fields.

1. The policy wording does not state the basis of calculation for 3080 dwellings. Sherfield-on-Loddon Parish Council REQUESTS that the Policy incorporates at least the proposed density of dwellings per Ha. Please refer to para.2 in section 4 above. We request you to specify the density, which needs to be comparable with other selected sites. 2. Sherfield-on-Loddon Parish Council REQUESTS that the number of houses proposed be increased above the figure of 3,080 stated. 3. Policy SS3.10 on p45 at (n) and (o). - There is no safeguarding map proposed or area of land described to satisfy the requirement for a Western Link road between A339 and M3 junction 7. Sherfield-on-Loddon Parish Council REQUESTS that such a map or descripttion of land, or preferably both, be publisised and the wording of Policies (n) and (o) be modified accordingly, particularly as the progress of a master plan for the whole of the Manydown land is proceeding currently. 4.Sherfield-on-Loddon Parish Council REQUESTS that BAS 099 Scrapps Farm, BAS 141 Worting and BAS 133 Hounsome Fields sites be included in the Local Plan in conjunction with the development of the Manydown site within the Plan period.

Continue on a separate sheet if necessary

a. No, I do not wish to participate at the oral examination

b. Yes, I wish to participate at the oral examination

Continue on a separate sheet if necessary

Signature Bruce J F Batting Date 3rd October 2013 f. Data Protection Statement