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 Page 1 of 6 1 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: Page 2 of 6 2 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 Page 3 of 6 3 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 Page 4 of 6 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: Page 5 of 6 5 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 Page 6 of 6 6