Havant Borough Pre-Submission Draft Local Plan 2036
How to submit your comments to the Government Inspector
Comments to be received by 5pm Monday 18 March 2019
If you wish to make your own Consultation Response to the Local Plan, feel free to do this. What we are providing in this document are links to the key Infrastructure issues in the Local Plan. We would advise you to focus on Soundness rather than Legality in your responses, unless you have a legal background. The advice that we have received from HBC is that it is preferable from the Inspector’s point of view that each response is short, concise and limited to a single subject. You can of course generate as many subjects and responses as you like. You aren’t limited to one submission.
If you choose not to undertake the research yourself we have provided 17 nearly-complete pro forma responses for your use. All 17 are based on soundness, and include all of the words, references and answers required. The subject of each is shown below (the information shown refers to point 7 on the form i.e. “Please give the reason(s) why you do or do not consider the Local Plan document to be sound," and if you click on your chosen subject/s, you will be presented with the 12-page pro forma HBC document. If you have an Adobe Reader on your pc, you will be able to complete the form on your pc by just filling in your personal details on page 4 and entering the date on page 10. Feel free to add/alter the wording to better suit you if you feel it necessary and to make your comment more your own.
You can download Adobe for free https://get.adobe.com/uk/reader/ or you can print a copy and complete it by hand.
Paper copies of the Comment Form are available on request from the Council.
On an iPad you will have to download the pdf into the Books App in order to fill it in.
Don’t forget to save the .pdf as you go along. Once completed, you can either email it to or mail it to Planning Policy Team, Public Service Plaza, Civic Centre Road, Havant, Hampshire, PO9 2AX
Select a number and format as each is linked to the relevant form.
The Hayling Island Infrastructure Committee has been excluded for the A3023 Transport Assessment parameter setting and model process. This has prevented the Committee from discharging its accountability and resulted in contested parameters driving the review.
The A3023 has a fixed flow capacity of 1489 vehicles per hour. This will remain as a fixed limit for all time (there are no economic expansions possible.) This unique limitation is not recognised in the model evaluation and therefore is not addressed as an issue.
The A3023 Traffic Assessment review smoothes the peak hour traffic flow over 3 hours. This presents an unrealistic lower picture and does not reflect the actual peaks experienced. Also the southbound AM and northbound PM peaks resulting from the leisure use of the Hayling Island facilities are not identified or evaluated.
The A3023 Traffic Assessment focuses on the Intra Island flows, not the main issues of the loading and capacity of the single access route to the mainland which is the limiting constraint for the whole network.
The Systra trunk road modeling may be OK for the mainland where future road development is possible, but not for Hayling Island where the A3023 capacity is fixed for all time.
The three mitigation packages identified in the A3023 Traffic Assessment all degrade the performance of the A3023 and in fact reduce its capacity. The impact of this reduction is not evaluated in the Local Plan.
The three mitigation packages all reduce the capacity of the A3023 and there is no cost/benefit or SWOT analysis to judge their benefits.
The southbound flow on the A3023 is completely controlled by the 3 access routes - A27 East & West and Havant Road. The Hayling Island Transport Assessment completely ignores this - the major and only controlling factor.
The issues with the A3023 are mainly influenced by the traffic flows and the capacity constraints. This is fairly identified in the Hayling Island Traffic Assessment. However, there it ends - there is no recognition of the problem's magnitude or an impact assessment included in the Plan.
Unlike Portsmouth (the next Island) where 100s of millions of pounds are being spent on sea defences, Hayling Island has neither strategy nor plan and are unlikely to gain any funding based on the 'asset value protected' any time in the future. HBC seem to be surreptitiously trying to establish a new norm that flooding is acceptable because we (they) have an emergency response process (as yet untested.) This is unsound - HBC are required to focus on flood protection for the Island. Accepting high flood risk to 50% of the residents displays an assumed
controlling power which they do NOT have.
There is no recognition in the Hayling Island section of the Local Plan to address the constraints and issues relating to the continuing dependence on the ancient open ditch and 130 one-way valves in the sea wall for the
Island's surface water drainage. An oversight and strategy is required.
The Hayling Island residents, HBC and the Environment Agency are not happy with Southern Water's performance in supporting the Hayling Island Wastewater Network. Multiple failures in 2018 of the Hayling Island network and Budds Farm are currently being investigated by the Environment Agency. These failures resulted in unauthorised flooding and harbour discharge events.
With the housing growth and degrading performance of the A3023, there is no risk assessment of the impact on the Emergency Services - all of which are based on the mainland.
The previous Barratt development (Oysters on Station Road) was built to legal minimums and the cheapest low carbon solutions. This is not acceptable for the future.
All of the flood risk statements in the Strategic Flood Risk Assessments do not, 'as stated', manage anything except the aftermath of a flood catastrophe. HBC have decided not to fund any flood protection for the Island, and the Environment Agency's 2115 map projection shows 50% of the Island is at risk.
There is a strong case for a new Policy to be established covering all aspects of the Hayling Island infrastructure in light of the high number of outstanding deficiencies recognised in their consultation response. The Consultation Statement does not address this strategic issue.
The largest category of housing growth on Hayling Island is windfall. In fact all of the development approvals (running at 100 per year) in the past three years were windfall, including the Hayling Billy, Oysters and Station Road sites, and Seafront Road. These sites individually are considered to have an insignificant impact on the infrastructure, however together they constitute the major impact on the Island's infrastructure resources. The HBC failure to plan this major growth category results in a weak and significant under-estimate of the infrastructure requirements. This windfall growth is expected to continue for years to come.
LINKS TO ESSENTIAL HAYLING ISLAND INFORMATION LOCAL PLAN 2036 Click here
Development Allocations: Hayling Island – Page 27
Brent Goose & Wader Feeding & Roosting Sites – Page 162
Key Sites Hayling Island – Page 44
EVIDENCE BASE Click here
Strategic Flood Risk Assessments Click here
Site Review Summary Table – Page 7
Hayling Island Sites – Page 24
Detailed Site Reviews – Page 26
Hayling North Policies Map Click here
Hayling South Policies Map Click here
Hayling Seafront Regeneration Click here
Consultation Statement – Pages 114 on Click here
STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT
11TH EDITION Click here
Hayling Island Sites – Pages 18-19
Hayling Island Map Click here
HAYLING ISLAND TRANSPORT ASSESSSMENT Click here
SOUNDNESS SELF-APPRAISAL CHECKLIST Click here
CLICK FOR A LINK TO THE FORM YOU HAVE TO FILL IN Click here
READ THIS – GUIDANCE FROM HBC ON HOW TO FILL THE FORM IN Click here
Phone: 023 9244 6539
Mail to: Public Service Plaza, Civic Centre Road, Havant, Hampshire, PO9 2AX
Mike Owens shares the following PDFs
Dave Parham – Save Our Island Group
Save Our Island Hayling
Anne Skennerton – Hayling Island Residents’ Association