PLANNING ARGUMENTS

Planning Arguments

Bentley Action Group is not against housing development for its own sake. Bentley itself has doubled in size over the past 40 years with the addition of approx. 250 new houses, including 65 in the past 4 years. We very much support the local consensus reflected in the latest draft Bentley Neighbourhood Plan, which recognises the need for and favours a continuing level of development, including in-fill and brownfield, preferably with groups of no more than 5 new houses at a time.

Bentley Action Group feels very strongly that the proposed Northbrook development at 800+ houses, only 1 mile away, with associated employment land and amenities, is a completely disproportionate proposal in a rural landscape of great beauty which dwarfs the historic local communities of the Northern Wey Valley. Professional consultancy advice from Carter Jonas confirms that the Northbrook proposal also breaks technical planning guidelines in many ways and is therefore very open to challenge.

 

Carter Jonas has produced two reports for the Bentley Action Group. The latest (dated October 2019) is in response to the EHDC Reg 18 Local Plan Major Site Consultation where Northbrook is one of ten potential major development sites (each capable of providing 600+ houses) under assessment by EHDC in order to identify two sites for inclusion in the Local Plan. The latest Carter Jonas report is summarised below and can be downloaded in full

October Consultation 2019  - Major Sites
  1. Character & Landscape

 

  • The new settlement at Northbrook in open countryside in the Northern Wey Valley would significantly change the pattern of development in the area - contrary to NPPF (para 170). 

  • CPRE (Hants) considers it would spoil “valued landscape” and  would adversely affect views to and from the South Downs National Park NPPF (para 172)

  • It could lead to ribbon development from the Coxbridge roundabout to Bentley along the “A31 Corridor”. 

 

2. Suitability 

  • The constraints at Northbrook which raise particular concern were detailed in the Bentley Action Group’s submission to EHDC in March .  They include the need to improve traffic infrastructure (A31), flood risk (includes flood zones 2/3), impact on sites of importance for Nature Conservation (SINCs) and on ancient woodland, need for suitable alternative green space (SANG), effect on heritage Listed Buildings, evidence of late Bronze Age ringwork of potential national significance and total lack of sewerage capacity

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3.  Sustainability 

  • The indicative facilities proposed at Northbrook would be entirely inadequate to enable the new community to be ‘sustainable’, for example the vast majority of journeys to work, school and shops would be made by car.

  • There is currently very little access to public transport and little practical provision proposed. 

 

4.  Duty to co-operate

  • There is no evidence of any co-operation from neighbouring Waverley whose input to the earlier Consultation set out their significant concerns about the already stretched A31 transport infrastructure and the risk of flooding.  

  • The latest Northbrook plan is dependent on the designation and approval of a new SANG in Waverley.

  • Similar Northbrook proposals (on Waverley land) were rejected comprehensively by Waverley as part of its site assessment work for its recently adopted Local Plan Part 1: Strategic Policies and Sites.

Conclusion

EHDC has assessed the 10 major settlement sites against 15 key constraint criteria using a ‘traffic light’ system - see Table 8 in the Background Paper https://easthants.oc2.uk/  .  Northbrook has the most ‘reds’  (9), the most ‘red/ambers’ (12) and the least ‘greens’  (3) of all 10 sites. Based on EHDC’s own site assessment criteria, Northbrook is the most constrained and therefore the least suitable option.  There are better and more appropriate alternatives.

 

EHDC should be encouraged:

  • To select Whitehill and Bordon (part of a major town regeneration scheme) as a large site option with strong potential. 

  • To remove Northbrook Park from the list and to select a more appropriate alternative from among those which have fewer constraints and better mitigation prospects.

March Consultation 2019 - Local Plan

The first Carter Jonas report for the Bentley Action Group (dated March 2019) was in response to the initial EHDC Reg 18 Local Plan Consultation where Northbrook was recommended by EHDC as one of only two large development sites for inclusion in the Local Plan. The first Carter Jonas report is summarised below and can be downloaded in full. The Carter Jonas reports are both consistent and complementary to each other.  Please download here: 

1. Character and Landscape

  • The new settlement in open countryside in the Northern Wey Valley will significantly change the pattern of development in the area – contrary to NPPF para 170

  • It will adversely affect views to and from the South Downs National park (NPPF 172)

  • It could lead to ribbon development between Northbrook and Bentley along A31 

2. Sustainability

  • The facilities proposed are entirely inadequate to enable the new community to be “sustainable” for example, the vast majority of journeys to work, to school and to shops will be made by car.   

  • The scale of the site is likely to be further constrained to deal with the flood risk and the proper protection of heritage assets and ancient woodlands

  • On this car dependent site, there is currently very little practical access to public transport and no provision proposed.    

  • There will be loss of rural tranquillity and the development would be highly visible from the South Downs National Park

3. Deliverability

  • It is questionable whether there is sufficient land available especially given the constraints (flood risk etc).  Also the site has not been tested through an Interim Local Plan Viability Assessment and the cost of infrastructure development has not been fully understood (NPPF, paras 57 and 67). Is the site viable and deliverable?

4. Suitability

  • The impact on the limited local transport infrastructure has not been properly assessed

  • Flood risk appears to rule out around a third of the draft land allocation

  • The cumulative impact on Biodiversity/Habitats Regulations in the area has not been assessed, especially relating to developments in neighbouring Waverley

  • There are 4 woodlands (including ancient woodlands) on the site which is included in a Local Ecological Network and Biodiversity Opportunity Area. The settlement is in the “blue and green corridor” established by EHDC’s Green Infrastructure Strategy

  • There are grade 2 listed buildings on the site which would be comprised by the new settlement

5. Reasonable Alternatives

  • EHDC has assessed 5 alternative sites for a new settlement against 13 objectives and set out the results in a traffic light table which seems to show that Northbrook Park with 7 reds and 3 ambers is the worst performing alternative. Why has it been chosen? 

6. Duty to cooperate

  • There is no evidence of any cooperation from Waverley whose already stretched infrastructure will be further challenged by a major new settlement on its boundary.  Waverley has already officially turned the project down.