2003 Local Plan Public Inquiry

Key points from our objections:

• EHDC's own landscape assessment supports keeping Causeway Farm undeveloped
• Flawed site selection process
• The site is within an Area of Outstanding Natural Beauty
• Lack of protection for the Hangers Way Footpath
• Effect on Existing Buildings
• The site is a floodplain and contains water meadows
• Loss of agricultural land
• Key parts of the land are NOT available for development
• The homes are not needed for Petersfield workers

2002 Planning Application - the application was refused on June 5th 2002. A wide range of agencies and organisations, together with 284 local residents, objected. Here are extracts of some of the agency and organisations objections:

Planning Policy - Comments: In Petersfield there are a number of possible development sites, including Causeway Farm. Causeway Farm is a viable site but has been allocated as a phased reserve site. The applicants have promoted the current proposal on the basis that it is the best site in Petersfield. However, this is not considered to be the case. The site has potentially significant impact on the wider AONB landscape of Petersfield, an issue to which great weight must be given. The site is also in an area where there has been significant recent development and a major concern of the Council has been that development should be more evenly distributed around the town in order to help assimilate the development into the historic market town fabric. This was also the reason that the site is proposed to be phased. This would help build the town community in compliance with PPG3.

The application is extremely premature to the proper consideration of the issues relating to this and many other sites through the Local Plan process. There is an adequate supply of housing land throughout the county to provide for the regional requirement, whilst in East Hampshire there is adequate supply of housing land shown in the adopted and emerging Local Plans to fulfil the requirement of paragraph 34 of PPG3 that "sufficient sites be shown on the Plan's proposals map to accommodate at least the first five years of housing development proposed in the plan". There is, therefore, no reason why this application should be allowed outside its proper consideration through the local plan process.

The PDL element is a bit of a red herring - the site is essentially greenfield, the minor element of PDL is existing residential curtilage whose redevelopment is constrained by the existence of the Listed Building.

Environment Agency - Objects to the proposal on the following grounds:

CPRE - Comments:"This is a Reserve site in the emerging Local Plan Second Review Second Draft, in relation to which CPRE has objected to the allocation of all the reserve sites. The County Structure Plan 1996-2011 (review) dated September 2000 makes no reference to the potential for urban development on "previously developed land" within the requirements of PPG3 - Housing. Therefore the requirement in the County Structure Plan for reserve sites takes insufficient account of the opportunity to meet all, or part, of the housing provision within the urban areas of the County of Hampshire and the two unitary authorities of Southampton and Portsmouth. Recent urban capacity studies have shown that there IS existing capacity available outside of East Hampshire, and according to PPG3 this must be taken into account. A decision on whether any of the reserve provision within the County Structure Plan should be triggered must await the review and analysis of all the urban capacity studies shortly to be carried out by Hampshire County Council. It is possible that reserve sites may need to be de-allocated as being in excess of requirements. It would be totally wrong to prejudge that very important issue by granting at this stage an application for housing on a reserve site.

Even if reserve sites needed to be triggered, an application at this stage for The Causeway does not even follow the sequential approach set out in the emerging Local Plan Second Review as this site is ranked 6 and 16 (Phases 1 and 2). It should not be released (if at all) until after the site ranked 1 to 5 (and 15 for Phase 2) have been duly developed.

Furthermore, to grant permission for housing on this site would not follow the sequential approach of using previously developed land (which need not be in the Petersfield urban area) before greenfield sites, as required by PPG3.

The site is clearly not needed to meet the baseline provision allocated by the County Structure Plan, for which sites are already allocated in the emerging Local Plan Second Review.

CPRE, therefore, objects to the application on the basis that any permission would be contrary to PPG3, and Policy R4 of the County Structure Plan, and Policy H1 or H2 of the emerging Local Plan Second Review.

PPG3 requires that major development proposals (of which this is one) only be permitted within an AONB if they are justified by a proven national interest and there are no alternative sites outside the AONB. The proposal does not examine either of these issues and CPRE further objects on that basis. CPRE believe that there are alternative sites outside the AONB to meet any proven national interest.

Notwithstanding the above objections, then with regard to The Causeway site, CPRE objects to any development on this AONB greenfield site, which is clearly visible from many places within the AONB. CPRE feels that the same quantity of housing could be met more organically on alternative sites within the Petersfield urban area, by the reallocation of some employment land.

Further, CPRE objects on the grounds that the field concerned is clearly separate from the start of the built-up area, and if built-over would have a significant adverse impact on that approach to the town. The area has already been adversely affected by traffic from the new TESCO store, and would be further affected by such a large development".

Joint Advisory Committee - AONB - comments as follows:"The site has no housing allocation under the existing local plan. In the second deposit draft the site is allocated as a reserve site to be released in two phases, phase one is ranked sixth and is for 175 houses and the second phase ranked 16th for 100 houses. The proposed reserve housing sites are in accordance with Policy H4 of the Hampshire County Structure Plan 1996 - 2011 Review. The timing of and the need to release reserve housing sites will be determined by the strategic and the district planning authorities in the light of monitoring. I am unaware that such monitoring has taken place as yet and therefore this planning application would appear to be premature.

Policy H1 goes on to say that before reserve sites can be released that applicants need to satisfy various criteria in particular the first criteria would appear to be relevant in this instance: 1. Demonstrate that there are insufficient previously developed sites and empty or underused buildings suitable for housing use. This criteria does not appear to have been satisfied, and if it had this still does not account for why an application has been made for the full 275 houses when only 175 are allocated in the first place. Equally I am not aware that any of the preceding four sites that are ranked above Causeway Farm have yet been released. This too would indicate that the release of this site is inappropriate at this point in time, particularly as the Second Deposit Draft has yet to be adopted and objections have been raised to the principle of allocating housing on this site at all.

I would therefore like to register strong objections to the planning application".

English Nature comments: It has been brought to our attention that the site does in fact support a badger sett. East Hampshire District Council should possibly have been aware of this given that the presence of badger setts on the site was mentioned in the First Review Local Plan Inspector's Report.

Protected species are a material consideration under PPG9 when a local planning authority is considering a development proposal. If a protected species is suspected or present on a development site, the following information should be requested from the applicant before the planning application is determined:

	What is the species concerned?
	What is the population level at the site, or affected by the proposal?
	What impact is the proposal likely to have upon the species present?
	What can be done to mitigate this impact?
	Is the impact necessary or acceptable?
	Is a licence required from English Nature?

If developers are working closer than 30 metres to a sett, a disturbance license may well be required from English Nature. Such licenses only allow work to take place between the months of July and November inclusively, except in exceptional circumstances".

Principal Landscape Officer – The proposed development site would represent a very large extension of the urban area into open countryside recognised nationally for its natural beauty, in its AONB status. The area is characterised by superb views in virtually all directions and in these views the setting of the town between the South Downs and The Hangers is clearly apparent. The view of the town's Parish Church surrounded by trees against the back cloth of The Hangers is a particular delight. There are two rights of way which cross the site; one is the Hangers Way which is a long distance footpath along the Hangers from Queen Elizabeth Country Park to Alton. From these paths wide views of the wider landscape are a feature. The impact of the development upon the important landscape setting of the town will be critical and represents a sensitive issue which this outline application must address. Inadequate information has been submitted to enable this assessment to be undertaken.

One of the important qualities of this site is that it forms a green lung which penetrates to the town centre and abuts the conservation area. Any development on this site should ensure that this feature is maintained, especially as it forms an important wet land buffer along the stream. In order to properly assess the impact of this proposal upon the stream, it would be desirable to have an ecological and wildlife survey of the stream corridor.

The applicant has undertaken advanced tree and hedgerow planting along the proposed boundaries of this application site to reinforce the local presence of the existing hedgerow. However in order to overcome the potential intrusion of the proposed development upon the wider landscape, this planting will need to be greatly extended, but the actual scope of this can only be properly evaluated when a thorough visual assessment of the site has been undertaken. This still needs to be done. Further information is required to fully evaluate the impact of the development upon this important site.

Arboricultural Officer – This application is outline, however, some details have been supplied and there are some key areas of concern. One is the means of access. I doubt that a road of the standard that would be required would be able to go past on the north side of the important Oak adjacent to the access road from the Causeway. Other details that would need to be looked at again include the proximity of housing and highways to large mature, and very significant Oak trees in the southern and western parts of the site.

Highways The plans do not show enough detail for me to comment in detail but I must also question the ability of the applicants to construct an access onto The Causeway that will meet the County's requirements.

HCC - County Education - Comments: "Whilst this is open to further discussion between ourselves, we still cannot see that the provision of an additional primary school on this site will assist in resolving the pressure on primary school places in Petersfield. We could not contemplate a new primary school of less than one form entry (210 places). Given the substantial investment we are currently putting into Petersfield Infant School (and also at Buriton Primary School), we could not justify this level of additional capacity. On this basis, therefore, we must say that we do not wish to take up the option of providing a new primary school on this site.

Even if we were to change that decision, the site shown in the applicant's brochure does not appear to be satisfactory, for a number of reasons;

HCC Archaeologist - There are no known archaeological sites currently recorded on the county Sites and Monuments Record within the proposal area. However lying immediately to the north east of the development site are the remains of an extensive Bronze Age barrow cemetery on Petersfield Heath which is legally protected a Scheduled Ancient Monument. The cemetery is one of the most extensive and best preserved barrow cemeteries in Hampshire.

In view of its proximity to the site the application area is considered to have considerable archaeological potential and that remains considered nationally important may be preserved. Paragraph 8 of PPG16 states:-

Where nationally important archaeological remains, whether scheduled or not, and their settings, are affected by proposed development there should be a presumption in their physical preservation.

This advice is reflected in Policy E4 of Hampshire County Structure Plan 1996-2011 (review) and policy ENV22 of East Hampshire District Local Plan: First Review 1998 which states:-

Development will not be permitted which adversely affects important archaeological sites, buildings monuments or features whether scheduled or not , or their settings.

There is therefore the potential that should such remains be preserved in the area they may constitute an overriding constraint on development.

Accordingly I would advise that prior to the determination of the application the planning authority should request the prospective developer to arrange for an archaeological field evaluation to be carried out so that an informed and reasonable planning decision can be made. This is in line with paragraphs 21 and 22 of PPG16 and policy ENV22 of East Hampshire District Local Plan: First Review 1998. I should be happy to advise on the scope of the archaeological work required and comment further once the results of the evaluation are known.