HIRA Objects to Housing Plan 2036
HIRA has officially presented its objections to Havant Borough Council's proposed 550 additional houses for Hayling Island. We have studied past and current technical Reports and consulted with other groups key to Islanders' future well-being, and concluded that not only is the Consultation Period far too short and during a holiday period, but there are serious concerns that Hayling's infrastructure will not cope. Our full Report has been submitted and is copied below but readers MUST write in to policy.design@havant.gov.uk themselves, giving specific practical reasons because sheer numbers of responders count more than than a single representative response!
HIRA Response to Recent Local Housing Plan for the Borough of Havant 2036
1. Introduction
The Local Housing Plan for Havant was published and made available for public consultation in July 2016.
The requirement for additional housing in Havant is claimed to be based on a Central Government document called the Objectively Assessed (housing) Need (OAN) produced by G. L.Hearn. This document addresses the alleged need over a wide area of eastern, southern England based on a top-level view of the need as a result of simple cascading model. This document also extends the planning period by 10 years to 2036 and is based on predictions that are subject to considerable doubt.
As a fundamental point, it seems absurd and perverse that the most densely populated areas of the South e.g. Portsmouth, Havant etc., have to accept the greatest further housing development when adjacent areas such as Winchester and East Hants escape major problems, often placing their developments beside already densely built areas such as Waterlooville.
What legacy are you leaving our descendants other than an ever-reducing quality of life?
In the introduction to the OAN document para. 1.8 clearly states:
The assessment of housing need is policy of calculation. It does not take into account environmental or policy constraints or infrastructure or land capabilities. The OAN figures are therefore NOT development plan targets. …. The Strategic Housing Model Assessment (SHMA) is untested and should NOT automatically be seen as proxy for a housing market assessment in local plans…..councils will need to consider strategic housing market assessment evidence CAREFULLY and take ADEQUATE TIME to consider whether there are environmental or policy constraints, such as greenbelt, which will impact on their final housing requirement.
In the current plan (2011 – 2026) Havant was considered to need 6300 more houses to house a population increase of 3000 – 4000 people. The figure of 6300 assumes a great increase in single occupancy dwellings and the increase in numbers of people over 65.
In the first 4 years of the current planning period (2011 – 2026), Havant has completed some 1100 dwellings, some 5000 below its target of 6300 for that period.
In the extended period to 2036 we are now told that Havant needs to supply a total of 11250 houses, 4800 more. Hayling’s share is to be some 555, in addition to those of the current plan and yet to be built.
Taking into account the caveats of the OAN document quoted above and on the grounds of infrastructure limitations, mainly the grossly sub-standard A3023, we believe the plan is contrary to every tenet of sustainable council management and should be rejected outright.
Our reasons are now detailed.
2. General points
Firstly, we consider that the consultation period granted (to 9th September) is quite inadequate for such an important issue to be reviewed adequately and informed comments made. Further the summer holiday period should not be chosen for such a task. The period should be extended to the end of October.
At the beginning of the current planning period in 2010, the Council was asked to carry out and publish a formal assessment of the infrastructure implications of further housing development on Hayling. This it agreed to do but never carried out the task. (We repeat the OAN entry above “councils will need to consider strategic housing market assessment evidence CAREFULLY and take ADEQUATE TIME”).
Because of the even greater need now for a complete understanding of the issues involved, it is considered essential that the Council now carries out such a study BEFORE the end of the consultation period. (Repeat, OAN entry above “councils will need to consider strategic housing market assessment evidence CAREFULLY and take ADEQUATE TIME”).
In 2010/2011, when the current planning document was being produced it defined sustainable development as ‘meeting the needs of the present without compromising the needs of the future’. It would seem that every aspect of the proposed plan is doing exactly the opposite.
In 2010/2011 when the current plan was being produced, the
document stated, in relation of the inadequacy of the A3023 that, ‘on traffic grounds, future housing development on Hayling should be restricted/curtailed.’ The planning inspector approving the 2011 document concurred with this view. Why is this confirmed and firm statement now apparently being ignored?
In 2010/2011, when the current plan was being produced the estimated 2026 Havant population was predicted to have increased by 3000 – 4000, a figure that seemed credible over that period. Only 5 years after this prediction, we are now being told that, in the additional 10 years to 2036, this figure will increase by a further 12000 – 13000. How can this astronomical increase possibly be true?
We are particularly concerned about the apparent inability of the Authorities to have any real control of the types of housing that may be given planning approval at some time in the future. From the Authorities’ own figures, virtually all of the predicted population increases are due to the rising numbers and proportions of over 65s on the Havant Borough. The mantra always seems to be that we must have mixed developments. When the idea of encouraging developments for particular groups of the population we are told that we can only give approval to schemes that developers offer us. As these schemes are not aimed at groups such as the elderly, they generate more traffic and this results in all the problems we now face only getting worse. Encouragement of retirement communities as exist in most other developed countries seem to be anathema to planners even though these would ease many of the problems they face, especially those of increasing traffic demand.
Considering now the position across the Borough, we feel that the overall plan will ruin what is left of, what was once, a pleasant place to live. Being forced to fill the jealously guarded green spaces between Farlington and Bedhampton, as well as Havant and Emsworth will be the final nail in the coffin. It is hard to see how any Councillor or Council Official could countenance such decisions.
3. Traffic Review
Hayling has only a single access road for some 17000 permanent residents, let alone summer visitors, Hayling has levels of traffic at which serious instability and congestion already occur. This causes considerable difficulties for residents, businesses, public transport and the tourism industry on which the Island and, to some extent, the Borough of Havant depends.
Any incident on the A3023 accentuates the risk to people’s lives due to the Island then being almost completely separated from essential emergency services. Such events occur frequently. We have great doubts about the Authorities’ ability to deal with a major incident resulting in closure of or extensive damage to the Langstone bridge.
It is far too dangerous to recommend that people should cycle on this road in spite of official encouragement to do so. Only radical changes can alter this.
The only safe north south cycle route is the Hayling Billy Trail but that does not have an all weather surface and it is crisis managed when parts of it fall into the sea.
Even minor incidents, drain clearing, roadworks or collisions cause disproportionate traffic hold-ups as there are few places to pass or to avoid them.
For many years traffic on the A 3023 on Hayling has exceeded all stated criteria of the Highways Agency (DoT) recommendations for a road such as the present, sub-standard A3023.
To permit the development of additional houses will greatly exacerbate this situation and thus any such proposals should be rejected. It is absurd, when ‘sustainability’ calls for a reduction in traffic, that new houses are positioned in locations (in southern Hayling) that lead to the greatest possible additional travel distances.
All the above suggests an inability by the appropriate Authorities to have any concern for the people they claim to represent. Without exception, when challenged about their roles they say ‘we have to implement national Government policy’. Why? Have they not read the caveats of the OAN pre-amble quoted earlier?
Evidence to support our assertions that more building on Hayling should be stopped or severely curtailed is presented below. Most points are based on DoT design criteria contained within the Highways Agency ‘Design Manual for Roads and Bridges’ (DMRB) and from County and Borough sources
Specific reasons, on traffic grounds, for stating that Hayling housing development must be severely curtailed are:
A. Letter from Havant BC to HIRA dated 12/2/1985 stating that:”this narrow over-long cul-de-sac (A3023) is carrying about two and a half times its theoretical capacity of traffic…..in the last ten years traffic has increased by 50%..... growth to 2020 is predicted to be 78%”.
B. The A3023 current Annual Average Daily Traffic (AADT) flow is 25000 vehicles/day (Hampshire CC, July 2016). Individual days in August 2016 (HCC) have exceeded 30000. This has resulted in saturation flows for periods of many hours.
C. DMRB indicates that, for the A3023 (designated S2/UAP2), an AADT of over 13000/day should be met by a two-lane dual-carriageway road. 200m out of the A3023’s 4Km are to this standard. Even a wide S2 road should not have an AADT of more than 21000 vehicles/day. G below suggests that if the current policy is not changed, the AADT for the A3023 will be approaching 27500 vehicles/day, a ridiculous figure for the grossly sub-standard only road into Hayling.
D. The remaining parts of the A3023 on Hayling meet NONE of the DMRB current design criteria for such a road, mainly because it is up to 2.5m narrower than it should be over much of its length.
E. In the Havant Borough Core Strategy document of 2011, (covering the current development period 2011 – 2026), it is stated that “on traffic grounds, future housing development on Hayling should be restricted/curtailed”, a view concurred with by the Planning Inspector approving the overall document.
F. What should be of major concern to both Councils is that difficulties of access to Hayling can quickly lead to gridlock on the Langstone roundabout and this immediately affects the whole of central Havant. This has been greatly exacerbated by the opening of M & S and NEXT in Solent Road. The centre of Havant is now congested on numerous occasions and any increase in traffic going to and from Hayling will become impossible to manage. Removing the bollards in Brockhampton Lane would help north-going traffic and ease the central Havant problem a little.
Similar problems arise at the A3(M)/A27 Bedhampton roundabout.
G. An estimate of AADT if the proposed houses are built can easily be made. The recent figures show an AADT of c. 25000 vehicles/day. If 800 further houses are built (550 proposed plus the additional ones being built), these represent an increase of 10% on the present Hayling housing stock. On a pro-rata basis this will lead to an AADT of some 27500 vehicles/day. Such a figure is consistent with extrapolating those presented at the Goldring Close inquiry and will definitely lead to totally unacceptable traffic congestion for up to several hours/day.
Thus again, the accepted definition of sustainable development is being completely rejected by the Authorities.
H. Following the very heavy traffic on the week beginning 22nd August 2016 we requested the traffic data for the Langstone bridge for that week. When this was received, it showed total movements for most of the days of that week to be c. 30000 vehicles, and on one day above that. On asking if HCC could comment on the implication of such flows for the A3023, we received a reply that contained the following:
‘Considering the geography, type of road and its function, 30k vehicles a day is not unexpected. Similar roads such as the A32 into Gosport, and A27 west of Fareham carry comparable volumes of traffic.’
As most of the A27 is dual carriageway and the A32 has had extensive improvements over the years, we find this idea of being comparable to be quite extraordinary.
If this is indeed the view within HCC, we really need to take the matter further.
Over the years numerous attempts have been made by HIRA and others to have the road limitations accepted at ‘official’ levels but usually to no avail. The Authorities always say ‘oh, that will be alright we have done the modelling’. Those Authorities have never demonstrated this claim publicly i.e., that the existing road is adequate. An earlier submission to HCC on this and related matters, has been essentially ignored, any response being perfunctory at best.
However, at the Goldring Close appeal inquiry, modelling data was provided. Unfortunately for the case now being made by the Council, the model only applied to the flow on the A27, the A 3023, not being part of the model except as an input flow. We would argue that modelling the actual flows on Hayling should have been a major part of the input to the model. Modelling the performance of the A 3023 MUST be part of any future study.
Finally, when the Goldring Close planning application was being mooted, HIRA, and others, requested a full infrastructure study be completed before this application, and any similar ones, be considered.
The Council agreed to this but did not meet its promise.
3.1 Related matters
Unusually, during the 1980s the local authorities were of the view that the road off Hayling was inadequate and put forward two main ideas for discussion.
There was a suggestion that a new bridge to the Island was needed, associated with the provision of a dual carriageway down the Island. A short, Stoke bypass had also been proposed. For many reasons these ideas did not get great support and the schemes were abandoned. There is no evidence of any subsequent attempt to resolve matters.
Since then only very minor improvements have been made to the A3023, mainly in the interests of safety.
4. Infrastructure Aspects
4.1 Flooding on Hayling and Sewers
Some flooding issues on Hayling Island are associated with the capacity of the main sewer. One such example is in the Victoria Road and Mill Close area. Southern Water has a history of denying there is a problem with the capacity of the sewer from the island to the mainland.
The cause of flooding of properties in that area is as a result of the pumping station failing with hydraulic overload caused by extreme conditions. The pumping station has the capacity to deal with normal flows but not extreme weather conditions. This was all stated by Southern Water a year ago. As a result, in recent years, several properties in this area have experienced flooding with surface water and sewage. One house has been raised by one foot to counter the problem at the householder’s expense.
Clearly, with an extra 555 houses over and above those already identified, the sewage and surface water drainage will be unable to cope in this area unless considerable improvements in performance are made. Similarly there will be instances in other areas of Hayling as overall demand increases, unless radical improvements are made.
Climate change will also affect the Island and sea level rise may cause backing-up in some surface water outflows.
Another example of what may come is the extension to the sewer in Selsmore Road due to the development of the Halyards housing estate north of Goldring Close. The work here has led to road restrictions to one lane and inconvenience over at least 2 months and so far there is no end is in sight.
Unless serious steps are taken to improve flood control and the sewer system then no large scale development on Hayling can be entertained.
4.2 Medical Services
At a meeting between Hayling’s two medical Practices’ representatives and HIRA Committee members on August 30th 2016, General Practitioners made clear the following:
Their Practices are working to patient capacity and more patients would test their capability to cope.
They have no outside funding for a new building.
There is no scope to expand their existing building.
There has been no Government funding for the requirement effective from 2004 for GPs to manage post Hospital patients although the Practices are taking on more from hospitals to keep patients at home.
Hayling has a disproportionally high demographic in SE Hampshire and Portsmouth of the elderly and patients with chronic disease problems which adds to home visits that impact on surgery workload.
There is already very real concern about Hayling emergency survival rates because of the totally inadequate road provision during any traffic blockages to access an A&E.
The GP Practice is primarily “Primary Care”. Hospital services are “Secondary Care” and as such provide A&E Departments to hospitals. The GP Practices are unable to provide such service to residents of Hayling Island.
There is still no adequate emergency plan in the event that the bridge is damaged.
4.3 Electricity, Gas and Water Supply
No data yet.
5. Conclusion
On the grounds of infrastructure deficiencies and in particular traffic overload, no further significant housing development should take place on Hayling. Forcing the suggested figures to be imposed would seem to be a classic case of mal-administration and is based on ignoring completely and rejecting totally all previous, clearly stated, planning advice and principles as noted in this document.
Hayling Island Residents’ Association Committee Response to Havant Borough Council’s Housing Plan 2036 Dated: September 5th 2016
