R35_Appendix1 - Consultations

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Draft Petersfield Neighbourhood Plan
Hampshire County Council Response – March 2015
Paragraph /
Object/ Support /
Policy Number
Comment
HP3 – Older
Object
Persons Housing
Reasons (Including Proposed Changes / Amendments)
HP 7 – Custom
and Self-Build
Dwellings
Comment
The relationship between affordable housing and self build is unclear. Annex C highlights that
self/custom build can be more affordable (cheaper to build) than conventional housing. The Plan also
sets that self build will only be available to people with a local connection. Therefore it should be
made clear that self build dwellings/sites will be exempt from affordable housing contributions (HP6)
as this would be both double counting and outside the model used to inform viability in Annex A.
HP9 – Quality
and layout of
housing
developments
Comment &
suggested text
Hampshire County Council would suggest that the text in this policy is amended to also conform with
paragraphs 95 and 94 of the National Planning Policy Framework (NPPF). Paragraph 95 of the
NPPF states: “to support the move to a low carbon future, local planning authorities should plan for
new development in locations and ways which reduce greenhouse gas emissions.”
Hampshire County Council as landowner supports the reference to Bulmer House for older persons
housing. This forms part of the County Council’s ‘Project Extra Care’ programme. However the
County Council objects to the current wording in reference to affordable housing. Project Extra Care
was agreed by HCC Cabinet on 9th December 2013 and is a programme to develop new 1 and 2 bed
C3 residential units of affordable tenure (100%). Therefore the County Council requests that the
policy wording should allow on-site provision or off-site financial contribution. The wording should
state of the last sentence of the policy should state; “…on site affordable housing. If not provided on
site the developer will be required…..”
Paragraph 96 of the NPPF where Local Planning Authorities should expect new development to:
“take account of landform, layout, building orientation, massing and landscaping to minimise energy
consumption.”
Hampshire County Council therefore suggests the following additional wording is incorporated into
Housing Policy 9 - Quality and layout of housing developments as set out below:
“Proposals for new housing on the allocated sites will be expected to be of high standard of design,
layout and construction which reflect Petersfield’s character, identity and distinctive setting in the
South Downs National Park. Applicants of the allocated sites must demonstrate how their proposals
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meet the specific site design briefs as laid out in this plan. In particular, the housing layout shall
include adequate parking areas, green space, landscaping and access for disabled people.
Proposals should also demonstrate how they have taken account of landform, layout, building
orientation, massing and landscaping to minimise energy consumption.”
H2 – Buckmore
Farm
Object
The County Council as landowner is supportive in principle of the provision of housing including self
or custom build units on this site subject to Member approval. However, concerns remain regarding
the delivery of such a scheme. The County Council is concerned that the proposed allocation of the
site for self-build or custom-build housing only will not be viable or deliverable unless there is a
mechanism to secure the comprehensive masterplanning and delivery of the necessary
infrastructure. It is suggested that this form of development would be better suited to small scale sites
where the necessary infrastructure can be more readily delivered, or a portion of the site allocated for
such provision. A more robust and sustainable approach would be to seek an element of self-build
dwellings across the wider range of sites rather than all on a limited number of sites
H9 – Land off
Paddock Way
Comment
H12 – Bulmer
House
Object
This is currently operational and occupied by County Council Highways staff and leased to the
Highways Term Maintenance Contractor Amey LG Ltd and therefore not currently available for
development. Any disposal of the depot site would require a suitable alternative depot site to be
provided in order to release the land for development. This therefore does not appear to be
‘deliverable’ as defined in the NPPF but could come forward as a windfall site during the Plan period
Hampshire County Council as landowner supports reference to Bulmer House for older persons
housing. As set out in the comments for Housing Policy 3, this site forms part of the County Council’s
‘Project Extra Care’ programme. However there is an objection to the current wording in reference to
affordable housing. Project Extra Care was agreed by HCC Cabinet on 9th December 2013 and is a
programme to develop new 1 and 2 bed C3 residential units of affordable tenure (100%).
Therefore the policy wording should allow on-site provision or off-site financial contribution.
In addition there is an objection to the indicative capacity provided (and therefore the associated
density). Given that the development will be flats, and from the County Council’s experience of
developing other schemes within Project Extra Care, it is likely that the capacity will be approximately
55 (indicative) given the site area. This should therefore be updated in the Design Framework section
and housing projections.
BE02
BEP7 –
Comment &
suggested text
Hampshire County Council would suggest that the text in this policy is amended to also conform with
paragraph 97 of the National Planning Policy Framework (NPPF). Paragraph 97 of the NPPF states:
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Sustainable and
adaptable
buildings
To help increase the use and supply of renewable and low carbon energy, local planning authorities
should recognise the responsibility on all communities to contribute to energy generation from
renewable or low carbon sources. They should:
● have a positive strategy to promote energy from renewable and low carbon sources;
● design their policies to maximise renewable and low carbon energy development while ensuring
that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts;
● consider identifying suitable areas for renewable and low carbon energy sources, and supporting
infrastructure, where this would help secure the development of such sources;
● support community-led initiatives for renewable and low carbon energy, including developments
outside such areas being taken forward through neighbourhood planning; and
● identify opportunities where development can draw its energy supply from decentralised, renewable
or low carbon energy supply systems and for co-locating potential heat customers and suppliers.
Hampshire County Council therefore suggests the following additional wording is incorporated into
Built Environment Policy 7 – Sustainable and adaptable buildings as set out below:
“New development which demonstrates high levels of energy efficiency and sustainability, and which
includes low-carbon, renewable or decentralised energy generation will be strongly encouraged”
Section 12.3
Comment
Hampshire County Council as a Minerals & Waste Planning Authority recognises that the
neighbourhood plan falls within the administrative area of South Downs National Park Authority
(SDNPA). The following response has been prepared on basis of the implementation of the adopted
Hampshire Minerals and Waste Plan (2013) which was prepared by Hampshire County Council in
partnership with the SDNPA and other partners.
Although neighbourhood plans cannot include policies that cover minerals and waste development, it
may be the case that areas covered by a plan contain safeguarded minerals resources or existing
safeguarded or planned minerals or waste sites. It is therefore important that when preparing a
neighbourhood plan these issues are taken into consideration.
Mineral resources as well as safeguarded minerals and waste sites are set out in a Mineral
Consultation Area (MCA) which is issued by the County Council and sits alongside the adopted
Hampshire Minerals & Waste Plan. The MCA helps to ensure that non minerals or waste
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development do not needlessly sterilise viable mineral resources and that development does not
negatively impact the operation of existing minerals or waste sites. More information on this is
available on the HCC website: www3.hants.gov.uk/mineralsandwaste/planning-policyhome/mwsafeguarding.htm. It is important that any neighbourhood plan taken forward to adoption
does not conflict with the adopted HMWP’s policy objectives.
Section 12.3:
A number of site allocations have been identified as having potential to conflict with Policy 15:
Safeguarding – mineral resources and Policy 26: Safeguarding: waste infrastructure of the adopted
HMWP. These policies are put in place with the intention of protecting Hampshire’s mineral
resources from needless sterilisation and inappropriate encroachment of waste facilities which may
jeopardise their operation. With reference to the Draft Petersfield Neighbourhood Plan’s site
allocations, the following table provides more information on potential compliance issues with the
policies of the HMWP.
Site
Ref.
H1
Site Name
H2
Land North of Buckmore
Farm and West of Bell
Hill
Penns Field
N/A
H4
Land South of Larcombe
Road
Policy 15 and
Policy 26
H5
Land South East of the
Causeway
Town Centre
Policy 15
H3
H6
Land at Causeway Farm
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Relevant HMWP
Policy
Policy 15
Policy 15
Policy 15
Further details
Overlies safeguarded soft sand and clay
resources which are safeguarded
through Policy 15.
N/A
Overlies safeguarded sharp sand and
gravel resources which are safeguarded
through Policy 15.
Overlies potential clay resource which is
safeguarded through Policy 15. The site
lies within close proximity to a Household
Waste recycling Centre (EH123) and
Petersfield depot (EH138). Both sites are
safeguarded through Policy 26.
Overlies potential clay resource which is
safeguarded through Policy 15
Overlies potential silica sand resource
4
H7
H8
H9
Redevelopment
Opportunities
Land West of the
Causeway
Land south of Durford
Road
which is safeguarded through Policy 15
Policy 15
N/A
Overlies potential clay resource which is
safeguarded through Policy 15
Overlies potential sand and gravel
resource and lies within close proximity
of Petersfield Waste Water Treatment
Works
Lies within existing waste depot (EH138)
which is safeguarded through Policy 26.
N/A
N/A
N/A
N/A
N/A
Policy 15
Overlies potential soft sand and silica
sand resources resource which are
safeguarded through Policy 15
Lies within close proximity to Petersfield
Waste Water Treatment Works. This site
is safeguarded through Policy 26.
N/A
Policy 15 and
Policy 26
HCC Depot off Paddock
Way
Existing Community
Centre Site
Land North of Reservoir
Lane
Land at Bulmer House
Site, off Ramshill
Land North of Buckmore
Farm
Policy 26
B2
Land at the Domes
Policy 26
B6
Car Park off Frenchmans
Road
N/A
H10
H11
H12
B1
We would like to take this early opportunity to advise that consideration should be given to
addressing impacts of potential development proposals on the capacity of existing strategic waste
infrastructure and potential viable mineral resources if development proposals come forward.
It is recommended that in the event of a developer taking a development proposal forward which
overlays safeguarded minerals resource that a Minerals Assessment Report is produced for the
Mineral Planning Authority. It would be most beneficial to the developer if this was submitted to the
County Council prior to submission of any application to allow for early discussions to take place. The
report should broadly address key issues including:
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



Site setting – Location, access, site description, geology and constraints;
Planning status in respect of minerals safeguarding
Policy context (both national and local), Mineral safeguarding Area;
Constraints upon prior extraction – inter alia previous mineral working, hydrology of
area, utilities and market issues (viability and/or quantity of resource present).
With regards to mitigating the impacts on strategic minerals or waste infrastructure, amongst other
aspects, significant increases in traffic generation as a result of the development proposal should be
addressed since this is a likely way in which strategic waste management infrastructure may be
jeopardised and its operations adversely affected.
Please see the attached map demonstrating the extent of safeguarding areas surrounding the
Petersfield area (See Attached Map)
Draft Petersfield
Neighbourhood Plan.pdf
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