We believe the document has an unfortunate title as it is not a plan and it certainly does not reflect what local communities want. It is a document that arbitrarily assigns housing development targets to areas, with little of no justification or evidence. Indeed the overall district target is not justified in anyway and seems to be developed from 10-year-old studies, which have been extrapolated without any reference to the current environment or proposals for future policies.
We are also disappointed that WCC are attempting to lead responses by asking direct questions which we believe is a cynical attempt to get overall agreement to a poor document. This is similar to the original approach made by WCC when the original LDF consultation took place when ‘Options for development areas' was presented to the community but firmly rejected.
WCC has chosen to use this document to present two major changes:
• The extension to the planning period from 2025 to 2031
• The change from a Central Government target to a locally derived housing need number. This target figure is now slightly less but covers a different time span.
Whilst we do not necessarily disagree with this it seems to have been done with little explanation or comment on the effect that it might have on the Core Strategy.
The figures contained in Tables 1 and 2 seem to be extrapolations from a base established in 2001 but there is no indication whatsoever to even begin to justify why they are correct, e.g. have they been done on a basis of National, Regional or County trends. (WCC Housing Technical Paper 2011). Also there is no indication as to whether they include migration movements, although Section 4.16, of the Technical Paper, suggests they will make up a large proportion, and whether these migrations are beneficial overall. In other words are people migrating to Winchester because it's a good place to live and houses are provided or because there is an absolute need in which case what is that need? The paper suggests that there would be a net fall in population if migration is excluded but some migration would be beneficial to compensate for the increase in the ageing population, provided that migration is not equally aged.
The document is right to distinguish between the PUSH area and the rest of the district as the PUSH area has far more in common with the south Hampshire conurbations than it does with Winchester and its environs but we think it is incorrect to lump the whole district together and apply the same assumptions to both. In other words people migrate to South Hampshire for totally different reasons than they migrate to the rest of the district. It is difficult to analyse this as no statistics have been provided that relate to the PUSH area although the priority in this area is economic growth, which would suggest it is job driven.
We believe the assumptions made from these statistics are seriously flawed and in some cases actually incorrect. For example Section 4.13 states that New Alresford and Bishops Waltham are the two largest settlements, whereas, in fact, Denmead is bigger than New Alresford in population, dwellings and land area.
This leads on to the arbitrary breakdown, which is made, between the Spatial Areas in Table 3 where it quotes the source of these targets as ‘WCC Housing Technical Paper 2011'. However, this paper does not provide any justification for the arbitrary nature of the targets although there is some logic to the allocation of 4000 units to Winchester Town. In fact the paper demonstrates it is very difficult to justify the target allocation to the Market Towns and Rural spatial area let alone justify allocations below that level. The 1500 dwelling target is merely a balancing figure to the 11,000 district target, which in itself is questionable and not justified.
Within the Market Towns and Rural area the process seems even more random with no logic or rational being applied to the distribution of new dwellings. There is a random allocation of 500 units each to Bishops Waltham and Alresford (the market towns) and 1200 units to the remainder. This in itself is illogical as these figures total 2200 against a supposed need of 1500 so they are already over-stated by nearly 50% (700 units). The population of the market towns is less than half of the settlements in the rural area but they are being asked to absorb approximately the same number of new dwellings, which is totally opposite to the rational being applied to Winchester Town. Overall a target of 1500 houses is a percentage increase of approximately 11% and we believe that it is more logical approach to apply this percentage increase to all places within the spatial area.
Applying this approach would give targets as follows:
Bishops Waltham |
305 |
New Alresford |
268 |
Rural Areas |
945 |
Total |
1518 |
This approach delivers the necessary target over the plan period although as stated above we see no evidence to justify this figure. It also reflects that the settlement areas are not dissimilar with a population ranging from 3114 in Swanmore to 6745 in Denmead including the market towns, which fall within this range.
Once again figures are being presented and assumptions made which are not supported by those figures. One table is presented from ‘2010 Retail Study 2010' but no indication is given as to where or how this document may be referred to. (A search of the Internet reveals nothing). Section 4.15 indicates that Table 4 is an incremental projection but this is not stated in the table. It is impossible to comment as there are no base figures presented and it is not clear whether this is a low or high percentage increase. Also the spatial areas have been changed with no indication as to what areas they comprise. However, on balance we are inclined to think that this projection of 36,000 sq.m is overstated especially in the light of current retail closures.
From a New Alresford perspective there would not appear to be a need for additional retail space but we do believe that it is imperative to retain the retail space we have in the town centre and not allow change of use to dwellings.
Once again it is difficult to draw any conclusions from the figures presented and again we see the figures, as they relate to spatial areas, are presented in a different way with no indication given as to the extent of these areas.
We note the reduction in the B2 requirement, which is not significant, but we are concerned to see an increase, albeit small, in B8 requirements in Rural areas. B8 development invariably results in an increase in HGV movements, which should be discouraged at all costs in Rural areas, as has been demonstrated in Alresford with the Salad Packing industry.
We would also question the B1 requirement in Rural areas as there has been office accommodation un-let in Alresford for two years.
As we have said many times there is a need to re-locate light industrial business out of the town centre of New Alresford, ideally close to the A31. It is important to retain this business type in the Alresford area, to provide a range of employment. Much has been made in the past of the unsustainability of developments away from services; this risks making all rural communities unsustainable unless positive steps are made to increase the diversity of villages.
The current economic situation demonstrates the need for flexibility in planning, any over definitive allocation or centralisation of sites is to be avoided.
The strategic view of Winchester seems to be very short-sighted focussing as it does on what might happen in the next three months not the next 20 years. We also find the document confusing as it makes an excellent and comprehensive case for development at Bartons Farm and yet the City Council has refused planning permission. Even if the Secretary of State refuses planning permission it does not preclude a further application during the 20 year plan period. It would seem that WCC has little alternative but to allow such development if it is to meet the housing needs laid out in the plan.
The predilection for a knowledge park is inadvisable. Now more than ever it is necessary to take jobs to where people live rather than assuming that personal or public transport will take the people to the jobs. It is also necessary to provide a range of job across the district, to meet the employment needs of the range of skills and abilities in our population. To develop such a park before we have mixed business use of existing sites could lead to derelict areas and decay within the existing boundaries.
It is also necessary to develop the range economic activity outside the city, and to target an area to develop for such a specific use will be against that principle.
Hi-tech industry is very attractive to a district and corralling that development seems a good way to attract such businesses. However it does not necessarily meet the needs of the population of that district, in economic, environmental, or employment terms. More flexibility in terms of usage and location is required. It also raises the question whether the provision of such facilities increases inward migration thus putting more strain on housing needs rather than providing jobs for the existing population.
We would question the need for an extra 22,000 sq m of retail in Winchester and the figures supplied again do not justify this but it would seem that car-park re-development would be a good initial starting point if this requirement were proven.
The PUSH area is very different to the rest of Winchester District and is driven by different factors, primarily economic, which means jobs, and provision has to be made in terms of housing. The housing need to support this development has to be derived from this economic strategy and housing development targets should not be established by allocating part of the total district target of 11,000, which has not in itself been justified. The housing development need, because of the very different environment, should be established and implemented totally separately from the rest of the District whatever this need turns out to be.
We would make an observation that pre-school provision seems to be inadequate.
As can be seen from our comments in Section 4 above we do not agree that the housing need allocation for Bishops Waltham and New Alresford is in anyway justified and we believe a more realistic allocation would be 305 and 268 respectively.
We cannot dis-agree with the elements outlined in Question 7b) with the exception of greenfield release which is not necessary to support the planned target numbers proposed for Alresford (268 over 20 years).
As we have said many times in the past New Alresford is the smallest settlement in terms of land area and has very pressing needs with regard to Open Spaces. Development on greenfield areas will be strongly resisted by the residents of the town unless a very real benefit for any such development is demonstrated. As has been recognised in ‘Plans for Places' the need is for 2/3 bedroom dwellings, in the main, to accommodate the ageing population. This group does not wish to be situated on the edge of town with difficult access to the town centre. Also any development here will cause even further pressure on the environment and traffic in the town encouraging even more car movements from the outskirts to the town centre.
There is strong evidence to suggest that there is high migration into New Alresford within the Pensioner sector. This is not only from the surrounding villages, from where people move to be closer to the facilities, but also from other areas of Hampshire and beyond because Alresford is seen as a nice place to live and provides the necessary facilities. This migration inevitable causes increases in house prices from a group with a high net disposable income but also benefits the town economically as there is an increase in spending in the town.
Indeed it could be argued that providing more housing for the ‘Pensioner Sector' is of more economic benefit than providing commercial opportunity in the town where 50% of those jobs are filled by people who generate little actual ‘wealth' for the town. It is difficult for a small town to generate ‘high wage' jobs and creating ‘low wage' jobs inevitable increases the demand for affordable housing. That is not to say that there is not a need for businesses and a strong economy in the town, to support local people, but it does suggest that it is not necessary to provide commercial enterprises, that do not support local people, that can be located elsewhere. For example the two largest commercial organisations in the town provide the most jobs, few if any of which, are taken by local people, provide the least economic benefit locally and create the most environmental damage.
Recent successful businesses in Alresford have been innovative – an international cookery school and a baby food producer. These are low impact, and complement existing facilities. Small towns are an effective nursery for such businesses, and should be marketed as such.
Ideally we have to focus on the provision of dwellings for local people (town and village) particularly for the pensioner sector and affordable homes for local people. How we prevent such accommodation being taken by non-local people is difficult but we are in danger of slipping into a variant of the ‘Peter principle' – the more homes we provide the more people will migrate into them. We very much support the principle outlined in Section 7.24 and endorsed in Question 8a) – ‘Promoting development suited to local housing needs, particularly for affordable housing or housing for older people.
It is unreasonable to expect New Alresford to take nearly twice the percentage increase of new dwellings (20.5%) against the average of 11% when it has the least land area of all the settlements. In any event these dwellings should not be on greenfield sites, where such a land grab would severely impact what open space there is in the town.
We support the proposal in Section 7.33, which should be extended, to recognise that many villages wish for small developments of about 5 houses where possible for local people or people obtaining employment in the village. Although negligible on their own, the sum will substantially reduce the overall numbers necessary in the market towns.
Both the section of active communities and high quality environment should include a reference to public transport. There is a danger that by restricting economic development in rural areas and market towns on grounds of lack of transport we are creating a lack of usage problem which in itself will lead to the decline of public transport and therefore of these areas, as they become homes only for the well off, that can afford personal transport.
Many villages already suffer from a surfeit of the elderly. Unless positive steps are taken to restore the age range, the decline will be terminal. Many submissions to Blueprint from the villages stated that more 2-3 bedroom homes should be built, and the tendency to combine existing smaller houses into larger house should be resisted. Some also specified sites for economic development. The sustainability of the villages also affects the health of the market towns such as Alresford.
This is a poor document that does not fulfil the expectations of its title. It is not a plan it arbitrarily assigns a new dwellings target of 11,000 units, which is not justified in the document in any way. It then makes matters worse by arbitrarily assigning targets to Spatial Areas with no justification whatsoever; with the possible exception of Winchester Town, and indeed the target it assigns increases to 11,700 because no thought has gone into the allocation to Market Towns and Rural Areas, which should be set at the mean of 11% across the whole area. This approach gives more realistic targets for Bishops Waltham and New Alresford of 305 and 268 respectively.
Reference to the ‘WCC Housing Technical Paper 2011' suggests that the housing need is predicated on population increase as a result of ‘migration in' to the district but there does not seem to be any indication given as to why this is beneficial. It does lead to a conclusion that if we build more houses more people will migrate into the district because it is a nice place to live and not because there is an actual need for them to do so.
The same casual approach seems to have been applied to Commercial and Retail needs as there is no justification within the document to support the conclusions reached. It is very difficult for somebody, reading this document in isolation, even to comment as, for example, in the case of retail it does not even quote the current Retail occupation and there is a general deficiency in statistics in both these sectors.