Deputation on Local Plan by Dave Parham
How does our Local Authority justify transforming the Borough’s major leisure and holiday destination into an engine for open-ended housing growth?
The HBC Local Plan intends to load this small, vulnerable holiday island with a massive housing programme beginning with the 1300 units (a 15% increment) in this document. This is an act of cultural violence against a defenceless community.
This is just the beginning, and this initial 1300 is in no way a ceiling or limit.
The Local Plan does not follow Government advice or conform to the NPPF requirements in many key areas including:
· The NPPF requirement that suitable developments are backed up with a sustainable infrastructure for the normal lifecycle of the programme (60 years minimum.) The Local Plan infrastructure programme covers only the next 15 years.
· The Hayling Island Transport Assessment Addendum (a document still in dispute with the Hayling Island Councillors, the Scrutiny Board and members of the Hayling Island Infrastructure Advisory Group) does not recognise the A3023 single road/bridge access as a major constraint. The A3023 is the sole access to Hayling Island and has a finite flow capacity which is already running at 85%. It is misleading to intimate in the Transport Assessment Addendum that increasing housing by 15% will have little effect on the traffic volumes. There is no economic action possible to increase the road’s capacity. The only way to determine the future of the road network is to undertake a flow/capacity analysis of the A3023 through the lifecycle of the Local Plan – 60-100 years – not 15. This analysis can be accomplished with the data already available. What’s missing is the will to do it ! Failure to undertake a flow/capacity analysis means that the future loading of this fixed capacity lifeline will remain unknown!
· Spending £10.5 million on road junction changes makes no economic sense as they further reduce the performance and capacity of the only route to the Island.
· Hayling Island is extremely vulnerable to sea flooding and coastal erosion, and the Local Plan does not attempt to address this major threat. The Eastern Solent Coastal Partnership Hayling Island Coastal Strategy Project will not report until 2022. Only then will we understand the risks and options regarding the future of the Island.
80% of the Island’s coast does not conform to the Government’s 8:1 cost benefit funding ratio, and 50% of the Island is Cat 3 flood risk. It is very unlikely that an overarching sea defence building programme will result. As an example, see the West Beach Erosion Proposals which will allow the destruction of leisure facilities in the area.
· Nutrient Neutrality is not adequately resolved in the Local Plan. The paper exercise on modelling has no credence unless accompanied by the essential components and guarantees:
o Mitigation areas should only relate to the relevant Fluvial Catchment area. It is not clear that this is being adhered to.
o Any plan must be accompanied by detailed and regular monitoring at source. The majority of surface water runoff is through the rivers and streams, and hundreds of one-way valves in the seawalls draining the low-lying land, as well as the regular and numerous legal discharges of untreated waste water from the Southern Water network. HBC must not claim to prove and maintain compliance in Nutrient Neutrality without this monitoring in place.
o The proposed control of fresh water to 110ltrs pppd is understated by 29%. Water UK have recently stated that the average usage is 142ltrs pppd. This is a significant difference and must be resolved.
· The majority of existing and in-progress housing proposals for Hayling are sub-standard and do not follow Government and NPPF recommendations. The deficiencies are too numerous to list here.
What authority is claimed to dismiss the needs and fears of the residents in the short-sighted obsession to “leave no stone unturned” and just build, build, build?
The plan for Hayling should be delayed until the outstanding issues are resolved and the Coastal Strategy is concluded in 2022. Only then can the correct type and volume of development be determined.
The White Paper PLANNING for the FUTURE is intended as a response to the inadequate standards and processes used by Local Authorities and Builders today, and identifies the significant changes required to establish a sustainable, elegant and worthy future for our community. It also guides you – the only Planning Authority we’ve got – to the changes required. This should be reflected in your thinking now.
Please don’t wait until it is too late.
Dave Parham Save Our Island