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Presentment: Our Objections to Local Plans

New Forest District Council’s Local Plan aims to build 10,500 homes over ten years. In their own summary they admit this is 3 to 4 times their current development rate.  13 of 20 of their proposed strategic development sites are on Green Belt.

This will increase the population in the district and park by roughly 7 times that of Lyndhurst.  One of these “Lyndhurst”s will be an entire new village at Fawley, which will increase the population of the park by 10 %, at the wrong end of the already stressed A326 transport corridor.  This would have a severe recreational impact on the Forest with disturbance to habitat and livestock, and would further urbanize the already saturated Waterside Area, requiring upgrades to the roads that due to that saturation would necessarily encroach onto the highly protected Crown Lands within the National Park, and would increase traffic westward across the Park on roads already animal accident blackspots.

The New Forest National Park Authority and NFDC share a viability study that accepts the developer’s contention that in order to develop 1500 homes at Fawley, they must build 120 as premium homes on a Site of Importance to Nature Conservation in the National Park.  Adjacent to the Power Station site, Tom Tiddler’s Ground is a young coastal grazing marsh that could easily qualify for SSSI status if it were grazed by commoners livestock[1].  [see addendum below for alternatives offered]

The National Park is failing its statutory purposes to conserve and enhance by adopting the poor logic and questionable feasibility behind the NFDC support for the Waterside development, and lack of objection to the scale of NFDC’s 10,500 home plan.  The Park Authority and District Council should be working together to fulfil their legal obligation to protect the Forest, not to undermine that protection for the sake of NFDC’s political objectives.

The Friends of the New Forest / NFA are objecting to the NFNPA Local Plan under examination in November, before your next court, because if accepted as it is, it lays the groundwork for NFDC’s Local Plan which presumes the need and scale of the NFDC objectives, including the destruction of Tom Tiddler’s Ground.

The Government 25 Year Environment Plan promises greater protection for National Parks and both designated and undesignated habitats, and a review for possible expansion of the boundaries of National Parks.  The Park’s own policy should only allow major development under exceptional circumstances.  10,500 homes in the ostensible buffer around the Park, the intentional destruction of Important habitat, and the decimation of Green Belt flies in the face of any presumption that the National Park provides the Forest with any protection.

We ask the Verderers, in their role as a statutory consultee to support our objections, particularly when the NFDC Local Plan is considered.  This is a generational threat to the Forest, and hope that all present in both official and private capacities will join us in this fight.


[1] Indeed previous attempts to do just that failed only due to unreasonable demands from the Power Station management.

ADDENDUM:
The current proposals range from 1500 homes on both the site and onto the SP25 land, or 4000 homes on the site alone (that profitability in the viability study equates 120 homes on the Park’s area with 2500 homes difference, is an example of the nonsense that the viability study purports, and a veiled threat to make an even more unacceptable development).  Even within the Power Station site, the proposals are not limited as they should be to just the former industrial area.  There is also an entirely cracked logic that if these homes must be built to fund the Power Station site development, that they must be built there, and not anywhere else in the country, and they must be built first, but with no guarantee that the industrial site would be developed subsequently.

The current proposals for the Power Station site, which do not demonstrate exceptional circumstances required for major development within the Park, should either be abandoned, scaled down to minor settlement, or mixed use for recreation or perhaps most fittingly for its industrial heritage sustainable power generation in the form of a solar array, all of which should be confined wholly to the industrial area alone, and outside the 400m zone of any future and very likely SPA designation.

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Gasp! NFDC and Southampton Clean Air Zone Consultation

The World Health Organization named Southampton amongst the worst cities for air pollution in UK. Here’s our response to the consultation run by NFDC and Southampton on Southampton’s Clean Air Zone.  From 1 June – 13 September 2018 NFDC and Southampton have run a consultation on Southampton’s Clean Air Zone.

As is often the case, we’ve sidestepped the constraints of the online survey, which narrowly addressed a congestion charge type proposal, and prompted levels of agree / disagree to various elements. To its credit, the survey did take pains to explain its proposals within the survey (unlike the two recent National Park Recreation surveys). We did feel the need to comment beyond the proposals in the survey, particularly on the role of the New Forest District Council.

Our Response

Consultation Limitations  

Whilst clearly the policies and conditions which have triggered this Clean Air Zone consultation demand a pro forma consideration of options which include the DEFRA Charging Clean Air Zone classes and how measures related to the proposed options could be implemented – this unhelpfully limits discussion of the clean air issue to vehicle journeys that may be limited or mined for potential mitigation by a congestion charging model.  By structuring this consultation almost entirely around these narrow solutions, and there circumscribing response to levels of approval or disapproval, the consultation is skewed towards a rubber stamping exercise.

Southampton should also be considering how other industrial sources of pollution, including port activities and cruise liners running engines for generation in dock.  Broadly speaking we’d favour measures that Southampton might take, including the charging options in the consultation, but we’d consider further comment on this outside our remit.

However, New Forest District Council should have a broader scope in this, as many of their plans to allow development in the District will negatively impact air quality by increasing housing provision with its influx of cars, and allowing growth and creation of ports with an obvious uptick of HGV traffic.  Neither the NFDC, nor Southampton are taking into account their duties to the National Park, which should garner higher levels of protection.

Wider View of Clean Air for the District 

There needs to be joined up thinking here.  To have this consultation about air quality at the local city and district level, and a Government launching its 25 Year Environment Plan, promising greater protection to National Parks and both designated and undesignated habitats, is well and good, BUT to have that same Government dictating housing targets to the District and Park where more strategic planning should abide to achieve the Park’s Statutory aims, is senseless and inconsistent.

NFDC plans for housing targets set to 10,500 homes in the next ten years, including the Fawley Development proposed to provide 1500 homes (within NFDC and the National Park) at the bottom of the A326, as well as the ongoing developments at the ports at Eling, Marchwood Military, and the ABP proposal for a deepwater container port at Dibden Bay, all of which the NFDC local plan welcomes with no quibbles for impacts.

10,500 new homes will produce a minimum of 13,650 more cars in the district, each making daily journeys.  The growth and establishment of a new port will have a significant impact on HGV movements.  All of this severely compromising the A326, with knock ons to the A35 and other local trunk roads. The additional traffic on the already congested A326 would lead to demand for extending dual carriage way for much of its length, however, as NFDC have allowed a hard edge of development against the road from Marchwood to Blackfield, the only room for widening would encroach onto the Crown Lands and the New Forest SSSI which should be unacceptable.

NFDC should not duck their responsibilities for clean air by limiting, as this consultation does, their part in it to merely improving the stretch from Rushington to Redbridge.  Their responsibility and remit is wider, and they should ensure their plans do not damage or undo any strides made in the narrow tranche of congestion charge consideration within this initiative.

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