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HEADLEY PARISH COUNCIL
COMMENTS ON EAST HAMPSHIRE DRAFT LOCAL PLAN
S1 QUANTA AND LOCATION OF DEVELOPMENTS
S.2 MANAGING LAND RELEASE VIA PLANNING
S.3 SUSTAINABLE AND VIABLE DEVELOPMENT
S.4 HEALTH AND WELLBEING
DM1 Support. Agree policy but should state area of open space per number of houses all set out in Appendix 4 should be a minimum standard.
DM4 Support – but not always borne out in the past.
DM5 Support in principle, doesn’t explain degree of concerns. How will the impact amenity be assessed?
DM5.2 Weight of each point for ‘regard’?
S5 HOUSING MIX AND TYPE. Support.
S5.3a How will the need for smaller houses be demonstrated? Needs a stronger requirement.
DM6 Support, but surely should apply to all new dwellings, not just over 10?
DM8 (Self-build) – must be genuine self-build and not CIL avoidance.
DM9 (Residential annexes) – should be physically attached to main dwelling as (b) and (c) – NOT (f) detached.
DM10 (Extensions – new ‘H16’). How are ‘modest’ extensions defined? If replacement dwelling is permitted policy must state the original dwelling should be demolished. Would prefer percentage limits to be reinstated in numerical form.
S6 AFFORDABLE HOUSES – Support
S7 RURAL AFFORDABLE HOUSING (Rural Exception Sites)
S7.1 Rural Exception Sites should not be situated in areas of high landscape value, or on land protected by specific habitat regulations.
S7.3 What determines the 30% ‘Low Cost Market Housing’ element? On previous exception sites the open market housing has not been low cost. Prefer 100% affordable housing.
S8 SPECIALIST HOUSING
Must be located in sustainable locations.
S8.3 ‘Will be expected’ is not sufficient – should be a targeted percentage of specialist housing.
S9 GYPSIES, TRAVELLERS AND TRAVELLING SHOWPEOPLE ACCOMMODATION
S9.1 Pitches and plots should use natural screening where possible rather than high wood or metal fencing. The stationing of commercial vehicles, particularly showmen’s vehicles and rides, again require sympathetic screening. External lighting should respect the dark skies of East Hampshire and be for security purposes only.
S9.2 Support. Commercial activities on gypsy sites should be low key in nature, larger enterprises should be located on trading estates. No general commercial businesses should be located on travelling show-people’s sites.
S10 SAFEGUARDING LAND FOR GYPSIES, TRAVELLERS AND SHOWPEOPLE ACCOMMODATION
S11 RESIDENTIAL MOBILE HOME PARKS.
Support. In what way will mobile home parks be safeguarded from alternative development? (S.11.1)
S12 NEW HOMES IN THE COUNTRYSIDE
S12.4 Support – Rural Exception Sites.
DM12 Conversion of agricultural or other rural buildings to domestic use should only be permitted where the building is proven to be structurally sound by a structural engineer’s report. This has not always been the case in the past. Permitted development rights should be removed to provide a selection of smaller dwellings retained in the countryside
DM13 Any new dwellings for defined rural workers should be recorded on a register maintained by the District Council. Residents of such dwellings should confirm that they conform to the residence criteria every five years.
DM13.4 Is not supported.
S13 PLANNING FOR ECONOMIC DEVELOPMENT
Proposals for larger commercial developments, by building size and/or employee numbers, should only be located in sustainable locations with suitable highway access, e.g. not through sunken lanes.
DM14 This policy is supported, provided that the criteria in DM14.2 are observed in every instance.
DM15 Supported. Buildings used for tourism or leisure use should not be converted to residential use.
S14 MAINTAINING AND IMPROVING EMPLOYMENT FLOORSPACE.
Broadly supported. Why is the Broxhead Trading Estate omitted from the Locally Significant Employment Sites, as it should be included.
S15 RURAL ECONOMY
Supported in principle, however not all farm buildings are suitable for conversion for other employment uses, either because of the environmental impact, or because the building is not suitable for the use proposed. Suitable road access is also important – many farms are situated down rural lanes.
S15f Supported in principle, the loss of village amenities including shops, post offices and public houses should be resisted and the onus should be on the applicant to demonstrate levels of use.
DM16.1 The criteria in (a) to (d) must be deserved in each case. Often diversification is ‘creeping’ rather than planned. These criteria should be enforceable.
DM17.1 The criteria listed must be observed – this has not always been the case in the past.
DM18.1 Horse related developments. The criteria listed are supported but there is no differentiation between a small yard with a couple of boxes used by the owner, and a full-blown commercial riding stables or school, which must be judged by a criteria relevant to the scale of the operation. Agreed that some yards are very untidy with derelict buildings or vehicles.
DM19.1 Broadly supported other than the construction of new buildings within the residential curtilage, this criteria should be defined as to the size of the building, i.e. a two-person garden office might be acceptable, but not a larger outbuilding. The number of ‘white van’ deliveries of small packages will be hard to control.
S16 RETAIL HIERARCHY AND NETWORK
Noted. We are not sure what defines and ‘other established retailing location’. Country Market was a single small garage where one paid for PYO fruit and vegetables. It has since been permitted to become a multiple retail business in the countryside. Forest Lodge, adjoining Birdworld is of similar size, albeit under one ownership. Similarly, Applegarth in the local gap between settlement boundaries was a small shed and greenhouse selling vegetables and has since become a multiple retail unit with restaurant and 80 dwelling housing estate. We are uncertain why The Square at Liphook (a few small shops) is a district centre, whereas ‘The Station Area’ is a Local Area.
S17 DEVELOPMENT IN THE COUNTRYSIDE
Broadly supported – but what does ‘will not be undermined’ (S17.2) actually mean in this context?
DM24 GAPS BETWEEN SETTLEMENTS
We support the first paragraph of ‘Why we need the policy’. We consider that not defining specific gaps, existing or proposed, is a retrograde step and will allow the erosion of the protection against coalescence that the existing delineated gap policy gives. So whilst DM24.1 is supported without having a defined gap it is totally overturned by DM24.2. As proposed all land between settlements is now effectively ‘a gap’ but have not been delineated. N.B. See comments under S16
In principle we support this policy. We are impressed by the ‘East Hampshire Landscape Capacity Study, September 2018’. We are concerned that integrating landscape proposals are not being requested by the Policy, including EIA’s.
S19 BIODIVERSITY, GEODIVERSITY AND NATURE
We support this policy but suggest (for S19.2) it must be clearly demonstrated by a report to the council to demonstrate the claimed overriding public need.
S20 WEALDEN HEATH PHASE II SPECIAL PROTECTION AREA.
S20.1 (Within 400m of the SPA) supported.
S20.2 As all of Headley Down is within 400m to 5km of the SPA, as is much of Whitehill Parish, we are concerned that all future development must be supported by a Habitats Regulation Assessment. Does this apply to extensions as well as new dwellings? This should be clarified.
S23 GREEN INFRASTRUCTURE
S24 PLANNING FOR CLIMATE CHANGE
DM27.3 Add ‘including acoustic tests to ensure no excessive noise pollution’.
DM27.6 After species, insert and ‘local residents’
S25 MANAGING FLOOD RISKS
Strongly support. Any development with areas of known or potential flood risks should be refused, not solely residential development.
S25.1(b) No development should be permitted in vulnerable areas.
S26 PROTECTION OF NATURAL RESOURCES
Strongly support – particularly protection of groundwater resources and aquifers
S27 DESIGN AND LOCAL CHARACTER
S27.1g Minimum 10m back gardens, with 6m frontage garden.
DM30.1a ‘…set back from the road’ insert, ‘min 6m unless otherwise agreed.’
DM32 Residential garden development. This is a very sensitive policy and although (a) – (e) are generally supported, any permissions must be carefully considered to relate to adjoining development, to the rear and sides of the donor dwelling. Single buildings to the rear should normally be refused, i.e. tandem dwellings.
DM32.1b For instance new building inserted into gardens should not have their frontages overlooking the existing back gardens.
S28 HERITAGE ASSETS
By definition, heritage assets deserve the highest protection and unacceptable development proposals must be refused. We support the criteria listed subject to this reservation.
S28.3 and S28.4 Change first line to: Where ‘in the planning officers and committee’s opinion’ development etc.
DM33 Conservation areas. This policy is supported. EHDC has traditionally treated development proposals within its conservation areas with due weight and respect.
DM35.5 Listed Buildings extensions to be subordinate in scale to the listed building.
DM37.3 Change – it should be achieved by ‘a separate spotlight(s) focused on the signage.’
DM42 The principle of short-term power generation and storage is supported, however the tests required in (a) to (e) must be satisfied. There are only a limited number of sites which are acceptable for these two types of facility.
DM41 Telecoms and digital, sections a, b, c, d and e supported
DM42 Short term power generation and storage, a, b, c, d and e supported.
The intent of this policy is supported, however this is a very difficult policy to implement in a scattered rural district, with few major roads and only two railway lines, one of which finishes at the Alton terminus. The few (and reducing) bus services make use of the private car obligatory in most of the District.
4 PLANNING FOR PLACES – THE NORTH-EAST AREA, HEADLEY PARISH
COMMENTS ON PROPOSED SITE ALLOCATIONS
SA5 Headley Nurseries, Glayshers Hill.
We support this allocation for about 12 dwellings, of a ‘high quality design and layout’. It is important that satisfactory sight lines are provided onto this steep hill, near a road junction.
SA6 Land Adjacent to Hillside Close (and Alder Road)
This site is not supported. It is on the edge of a former uncontrolled landfill tip. It has been previously refused for this reason. The land is heavily contaminated and on a steep slope. A totally unhealthy and unsatisfactory location.
SA7 Land at Middle Common, Grayshott Road, Headley Down.
In principle this is the final extension to the existing show-people’s site fronting Grayshott Road and continuing to a north westerly direction behind woodland. We note the ‘Site Constraints and mitigation’ proposed, however the aspiration of a ‘a greater opportunity for good design, layout and amenity facilities’, is not borne out by the adjoining site (27016/004) where various buildings have been constructed without planning permission. SA7 has a public footpath running alongside its northern boundary and is therefore a high-profile location in otherwise undeveloped countryside. The AECOM Sustainability Appraisal states that part of the site is susceptible to surface water flooding.
SA8 Land off Hollywater Road and Whitehill Road.
This was previously allocated as a third SANG for Whitehill and Bordon. It was subsequently found that there was sufficient SANG provision in the Bordon Inclosure and the Hogmoor Inclosure, and this farm (Standford Grange Farm) was deleted as a SANG. If it is to be a specific allocation, we would require that the ‘100 and 360 dwellings (surely between 100 and 360 dwellings), ‘be situated’ on the northern part of the site closes to the Mill Chase Road’. The southern part of the HCC farm (possibly to the south of the road to the Cemetery) should be a SANG. We would, (i), request that the ancient woodland, Eveley Wood, be not part of the SANG open to public access, and, (ii), that public access, including car parking to the proposed SANG, is the subject of public consultation. N.B. AECOM Sustainability Assessment says ‘circa 360 dwellings ‘subject to further work’.
OTHER LAA SITES IN HEALDEY
HEA-013 Land at Beech Hill Road
The Parish Council are relieved that this site was not granted Allocation status. The ‘Four Acre Field’ is a most important area preventing the coalescence of Headley Down and Arford. It breaks up the mainly post-war ribbon development on the southern side of Beech Hill Road, thus protecting the current delineated Local Gap. It is the first bulwark to the Headley Down SPB
Appendix 3 – Some of the minimum marketing periods are too short. Suggest 24 months for B Classes.
Appendix 5 – Vehicle Parking Standards, supported.