Deputation to Cabinet 01-7-20
Deputation: Havant Borough Local Plan (revised Pre-submission Local Plan)
1. One purpose of Havant Borough Local Plan (HBLP) is to legally protect Solent
Waders and Brent Geese (SWBG), yet proposed refuges are either in Flood Zone 3
or in the Coastal Change Management Area (CCMA) - despite the need to
‘function in perpetuity’.
For example, policy IN1 (previously E26) is in flood zone 3 and the Land North of
Sinah Lane (H29) onsite refuge is in a CCMA.
Erosion and degradation of these sites will result in a ‘net loss of available winter
foraging’ and therefore this mitigation for loss of SWBG grazing land is not fit for
purpose. Simultaneously, this also contradicts other HBLP statements that claim
that loss of a part of a Primary Support Site or Core Site will not be accepted.
2. Creating bird refuges along the West coast of Hayling Island will worsen
nutrient neutrality issues. Currently, crop rotation is used on this land which
reduces the amount of fertiliser and pesticides required. Changing the land-use to
a bird refuge will require the same or similar crops each year, requiring increased
use of fertiliser and pesticides. This will increase nutrient runoff into the harbour.
In conjunction with increased nutrients, the structure of the soil will deteriorate
due to mono-cropping, making runoff much worse.
This water will drain (unmanaged) into Langstone Harbour, ancient drainage
ditches and even the underground fresh water aquifers; unleashing decades of
fertiliser and pesticide build-up into these important waterways, in conflict with
HBLP policy.
3. HBLP states planning which will result in the loss of any SWBG Core or Primary
Support Sites will be refused – glaringly there are 3 allocations that are singled out
as exemptions to this policy: Land North of Sinah Lane; Rook Farm; and
Campdown.
What is the point of creating a rule book in the shape of a Local Plan if crucial
rules and policies are deliberately not applied when relevant and necessary?
It is scandalous that Hayling sites are allocated when such complex constraints are
already recognised, such as:-
- SWBG core/primary support sites
- currently greenfield
- best and most versatile good grade 2-3a agricultural land
- severe groundwater flooding (usually coupled with tide locking, further
complicating any SuDS plans)
- severe impact on Transport Network
- foul water infrastructure capacity already reached
These constraints demonstrate that these sites should instead be protected by
policies in this Local Plan, not allocated for development.
If a site is inconveniently constrained by a policy, either the policy is poorly
formed or the site should not be allocated – sites should not be given a ‘
Cummings ’ style exemption. On top of this, as illustrated above, the mitigation
supposedly exempting these sites from particular policies is both inadequate and
unsustainable.
4. The 5 yr old Oysters Development has not been included – the development is
instead shown as a SWBG support site. It was even left off FOI lists for housing
development provided by HBC.
There could be errors when calculating recent housing development and
subsequent infrastructure demand from this omission, not to mention that it
contains legally binding SWBG mitigation. This was highlighted at previous
deputations and meetings which acknowledged the lack of follow up on SWBG
mitigation requirements.
For loss of SWBG grazing area, Land North of Sinah Lane (H29) was to be kept as
mitigation for SWBG – ironically a site that itself is now being allocated for
development. It is stated in the HBLP that this allocation only requires an ‘onsite’
refuge yet consultees have asked that the IN1 (previously E26) refuge be ‘run
alongside’ this development. The onsite refuge of 5.7ha on its own is NOT enough
to replace lost SWBG habitat. Another 9.2ha is needed.
5. The cost and disruption of the Hayling Island transport network mitigation is
bad enough before taking into account that the proposals will not even reduce
the strain on the A3023 caused by Hayling development. Expensive tinkering of
traffic systems south of the bridge will not reduce the amount of vehicles crossing
the bridge. The potential for developments to increase the strain on bridge traffic
poses a real threat to the feasibility of emergency service provision and
commuting off the island.
Despite the ecological and environmental measures outlined in the HBLP, the use
of exceptions, exemptions and poor quality, unsustainable mitigation used to
overcome constraints, again and again undermines the policies, coherence and
spirit of the HBLP.
