March 18th is the deadline for public comments on Havant Borough Council’s Pre-Submission Local Plan to 2036. HIRA has published information to help its members and the public to understand the legal jargon and to navigate their way to the important Evidence Base page on the Local Plan’s website.
However, members of Havant Borough’s Residents’ Associations express real concern about the difficulties even internet savvy individuals experienced in completing the HBC designed Form online. Worryingly, HBC publications emphasize this method but, in contrast, other Councils nationally make clear the choice of submitting responses by email, letter or by the form provided. An HBC Officer admitted that, for cost reasons including the need to, potentially, employ more staff, they have not emphasized alternatives nor the fact that people can phone to request a paper copy be sent to them. At one of the HBC run information sessions a keen, experienced resident had to ask for a paper form as these were neither openly available nor advertised as such. It is even stranger that, despite emphasizing the need for online submission, HBC’s online exemplar response form has been completed by hand; but not everyone has printing facilities at home. HBC Planning Officers have however confirmed to us that an email can be acceptable if all the content required on the form is clearly set out in the email. Council staff have to assemble and process all submissions so that they are acceptable to the Inspector.
It is vital that everyone try to submit their comments. Go to www.haylingresidentsassociation.co.uk click on Latest News then Consultation Guidance. You will probably need to access other documents referenced, and of course the Council’s Evidence Base page, but at least you are working towards an acceptable statement. Those who attended our February 27th Public Meeting will also have had clear guidance and support in submitting their responses.
Residents’ Associations members are finding that, in its haste to draft its Local Plan to 2036, HBC has not kept important documents up to date. For example the Statement of Community Involvement (SCI) should guide the creation of the Local Plan but its revised, corrected, content was not published until February 2019. The previous SCI document of 2013 was not even published on the Local Plan website. The Council’s previous Biodiversity Assessment was also not updated and there is concern that HBC may be in breach of the EU Habitats Directive Article 2(2) which requires all Local Plans to be subject to a Habitat Regulations Assessment. The purpose of the Directive is to maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest; a Regulations Assessment must provide cumulative evidence of this.
For those concerned about how particularly our winter visiting coastal birds move between sites, the Solent Waders and Brent Goose Strategy mapping of Hayling’s sites might also be usefully viewed in connection with the Habitats Directive concerning buffer zones for Sites of Special Scientific Interest. Furthermore, simply assigning previous ‘tips’ or waste dumping sites as suitable for birds requiring either grassland or crops, may not in fact comply with ‘mitigating’ wildfowl sites that have been allocated for housing or other development. The Government’s all-important National Policy and Planning Framework (NPPF) available online, is a starting point for grasping such contradictory requirements as a Local Plan’s need to provide ‘mitigation’ strategies for wildlife dispossessed of foraging ground whilst simultaneously creating a presumption in favour of development. However NPPF Para 177 states “The presumption in favour of sustainable development does not apply where development requiring appropriate assessment because of its potential impact on a habitats site is being planned or determined.”
Those who think that Hayling’s prospective developments will solve Havant’s housing needs should reflect on two things: developers can ‘buy’ their way out of providing the Council’s recommended affordable housing; pleasant greenfield sites provide maximum profit regardless of their subsequent impact on already congested restricted road networks. Arguably Havant’s nearly 1800 social housing need, should be provided nearest to readily accessible town facilities. Affordable housing on Hayling requires accessible employment which in turn requires, from the Council’s own summation, assured commuting outside the Borough. Hayling’s Transport Assessment (Local Plan, Evidence Base) not only fails to factor in the impact of the road network further north but also states that its ‘mitigation’ strategies will not solve the A3023’s restricted network. This Assessment – for Industry standard reasons - doesn’t even factor in peak season traffic flows. Existing A3023 Hayling studies illustrate that our road already experiences gridlock and proposed developments combined with ongoing windfall sites, will inevitably make such events more frequent.
Contact HIRA firstname.lastname@example.org or drop boxes: Hayling Community Centre, West Town; Morris Dibben, Mengham; The Terracotta Pot and Gift Shop, Eastoke; Library, Elm Grove. www.haylingresidentsassociation.co.uk