a copy of our full letter explaining the reasons for our objection
Bushfield army camp, once an emergency measure in WW2 that returned to the Church Commissioners about 40 years later, has since been rewilding itself for nearly 45 years. There have been multiple attempts for developing this site until the newest proposal.
The application states: The proposed uses are as follows: office (Class E), research and development (Class E), academic uses and academic accommodation (Class F1/Sui Generis) a hotel (Class C1) and other complementary/ancillary uses including a nursery (Use Class E), retail uses including shops (Use Class E) restaurants/cafes/bars (Use Class E), visitor space/exhibition space (Class F1), leisure and sports uses (Use Class F2).
We are very worried about these plans as:
Locals doubt there is a need for these proposals,
Construction and increased traffic from estimated 4000+ car daily car journeys (two multistorey carparks with 1055 parking spaces included) will increase carbon emissions,
The increase in car traffic will make it more difficult to cycle and to cross the road on Badger Farm Road near Sainsbury’s, further along the way including on Romsey Road and St Cross Road,
Threaten this area’s biodiversity, an area that has been left to rewild for longer than it was used as an army camp and that is now a habitat for dormice and valued wildlife,
The visual impact from multistorey buildings may reach far into South Downs NP and impact the surrounding heritage,
Noise and light pollution will impact on nature and locals.
Furthermore, there is concern that an outline planning permission once granted will take control away from local councils when further changes to the plans are made in the future.
It appears that the plans do not conform with the 2013 Local Plan, nor the Carbon Neutrality Action Plan. It is contrary to the WCCs and the Church of England’s Carbon Net Zero 2030 target as well as the UK Government’s Net Zero Development Plan. It also contradicts Winchester’s recently announced Nature Emergency.
You can find the planning application on www.winchester.gov.uk/planning by searching for the reference 23/02507/OUT. This is where you can make any comments and object. Here are some tips on how to give your objection extra impact:
Give clear reasons for your objection
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Who is behind this?
We understand that this land belongs to the Church Commissioners for England. In partnership with Legal & General and Gisborne they have organised several consultations that led to this outline planning application.
Who is this development for?
Locals have been very critical at meetings in the neighbouring Badger Farm parish about this engagement and how the proposed buildings and their function changed over the last 2 years. A petition has gained much attention this year.
The site was allocated in the 2013 Winchester District Local plan (Policy WT3) as an ’employment site’ and has since been included in the Regulation 18 Local Plan – Winchester Town Development Allocations as ‘high quality flexible business and employment space, an innovation/education hub and creative industries’. Student accommodation, a hotel and retail do not fit with this description. This location, isolated from the city centre, is not suitable for student accommodation. Why do we need student accommodation at this site if the Uni of Winchester is not interested in such? Furthermore, there is fear that it would create extra pressures on the Badger Farm surgery and possibly other public services.
Locals claim that there are empty spaces for business available closer to the city centre and in the Winnall business estate. It is highly unlikely that it will attract people from Winchester who commute to London to work in these premises that are planned here. The number of job vacancies in Winchester in comparison to the size of this development suggests that this site would have to attract people to commute from elsewhere which is not of any use for people living in Winchester.
Finally, it appears unlikely to attract businesses outside the Solent Freeport and we can not see that this has been taken into account.
Site Allocation and Emerging Planning Policy
The Bushfield Camp site is allocated in the current adopted Local Plan (LPP1) under Policy WT3 as an employment site. The Applicant has stated that “The Regulation 18 Local Plan includes new policy wording which seeks to recognise the changing nature of employment uses. The draft policy for Bushfield (draft WT5) now supports a high quality flexible business and employment space, an innovation/education hub and creative industries”. In our view the emerging Local Plan does not hold weight or provide ‘direction of travel’ as the Regulation 19 consultation is not due to be published until the second quarter of 2024.
The Applicant has stated that “…the adopted Policy WT3 does not list out specific use classes that the development must align with, nor does it preclude the provision of other uses (supporting hotel accommodation, leisure, or education facilities etc.) which are all employment generating uses”. In our view, the proposed use of the site diverges significantly with the adopted policy. We contend that Policy WT3 permits the construction of a 100 bedroom hotel and 525 bed student village.
The Applicant has referenced emerging Local Plan Policy H9 (Purpose Built Student Accommodation (PBSA)). We contend that this policy also does not hold weight regarding this application. The policy is not applicable as the proposed student village is not PBSA and the application has not demonstrated a shortfall in accommodation from an existing education provider.
As the proposed development does not comply with policy and site allocation requirements and represents a significant departure from the Local Plan. It is our view that the LPA must notify the Office of the Deputy Prime Minister of this departure if it intends to approve the application.Proposed Site Use
The Spatial Strategy within the Local Plan states that the allocation of land at Bushfield Camp is provided to realise the aspiration for Winchester to “diversify its economy through the promotion of its creative and cultural industries, linked to its Universities”. In our view the proposals, which are for a large-scale major development, do not align with this aspiration, or what could be classed creative and cultural industries and rather than evidencing links with local universities, the plans propose global affiliations with leading corporations.
Policy WT3 requires that “any development should deliver necessary social, economic or environmental development which could not otherwise be accommodated within or around Winchester…”. We contend that due to the contraction of the public sector, changes due to increasing numbers of people working from home, and sites needing redevelopment, that the proposed development would be better located within the city centre, and not a Site of Importance for Nature Conservation and within proximity of the Compton Street Local Settlement Gap.
Local Plan Policy WT3 requires that the development “does not compete or detract from the town centre, is compatible with the provision made elsewhere through this strategy, and reflects other policy statements prepared by the Council including the Vision for Winchester”. In our view, the development will detract from the city centre, especially the proposed hotel, which is likely to compete with hotels in the town centre. Our view is supported by the NPPF and Policy DM7 – “hotels should normally be directed towards the town centre in the first instance”. Neither Policy WT3 nor emerging draft Policy WT5 permits the development of a hotel.
The Applicant has stated that the “NPPF seeks to ensure a sufficient choice of education places are available ‘to meet the needs of existing and new communities'”. In our view, the NPPF is not applicable as the development is not aimed at meeting local education needs
Increased car traffic
The application fails to address the scale of transport Greenhouse Gas (GHG) emissions it will cause. The reference to CP10 is meaningless without more practical proposals that address more usefully the growing urgency of climate policies. Many key policies are overlooked and their implications ignored.
WCC must reduce all emissions sharply to achieve net zero by 2030 and transport emissions are nearly half of these.
Compared with 2022, the modelling suggests traffic volumes will increase by between 17% to 37% on roads around the development by 2039. The application does not attempt to show how the increase due to the development itself can be limited neither to help achieve the WCC net zero target by 2030, nor even to achieve the government’s Net Zero Development Plan target of reducing 2022 emissions by 76% to 85% by 2039.
No attempt has been made to quantify the extent transport emissions associated with this development will undermine Winchester’s Carbon Neutrality Action Plan (CNAP). Using government conversion factors we calculate that the modelled increase in traffic will produce 6.15 KtCO2e extra emissions annually. To achieve net zero emissions by 2030 there will have to be overall cumulative reductions of 67 KtCO2e in Winchester District transport emissions each year until 2030. As this proposal increases traffic related carbon emissions, further reduction would need to be found elsewhere.
The Sustainability Statement makes a number of vague proposals that are relatively unformed and weak about mitigating the damage caused by increased transport emissions but does not demonstrate satisfactorily the extent to which these proposals will contribute to emissions reduction.
The framework travel plan has no targets for increasing the share of EVs. The proposals include plans for a “…minimum of 3kW chargers for at least a quarter of total car parking spaces, with an aspiration to provide 100% EV charging capacity in the future.” Parking for 8 hours on site would only charge the average EV by less than half of its battery capacity. This is clearly not in line with government plans to increase EV use.
The traffic modelling suggests there will be about 4500 daily journeys to and from the site. There are plans for 1050 parking spaces. It is difficult to reconcile these two figures. The proposals do not appear to be coherent.
Impact on active travel
The framework travel plan has no targets for achieving modal transfer to increase the share of walking, cycling and public transport access.
It appears that the applicant has not fulfilled the obligation under the Local Plan: “Promotion of non-vehicular access to and within the site, to ensure integration with the surrounding areas and to minimise and mitigate its impact on the strategic highway network.”
Given the very large scale of the development with projected 8399 trips per day (Transport Assessment, section 5.4), the applicant needs to invest more to increase the low number of 212 anticipated daily cycle trips. We agree with Active Travel England that the modal share targets (car/van 79.7%, walking 5.7%, cycling 3.2%, bus 3.6%, and train 2.0%) are unambitious. Instead, the plans should be in line with the government target for 50% of short journeys in towns and cities to be walked, wheeled or cycled by 2030.
Any permission for development of the site must be conditional on meeting LTN 1/20 standards for the main cycle path.
To the North:
The proposed cycle route from the Bushfield roundabout via the site to the north is welcomed but an unsealed surface as suggested would make this less suitable for cycling given the gradient. An unsealed surface makes cycling more dangerous around sharp bends together with a significant gradient due to its terrain. There are concerns that the path will not be wide enough to minimise conflict with pedestrians. A high-quality route would have a sealed surface and environmentally-sensitive lighting (to allow year-round use) and be sufficiently wide to avoid conflict with pedestrians.
The main site cycle path terminates at the northern site boundary, near the railway footbridge to Whiteshute Lane. There are no plans included on how this path will link towards the centre of Winchester. For these plans to be in accordance with the Local Plan funds and agreements should be included to provide these onward links.
To the West (Badger Farm and Olivers Battery):
Plans to link with neighbouring residential areas of Badger Farm and Olivers Battery, including a supermarket, GP and dentist, are not satisfying and at best useful for leisure purposes. These paths become muddy and overgrown and are not suitable for commuting to work by cycle or walking for shopping purposes.
The plans fail to provide for a cycle route as per LTN 1/20 nor a suitable route for pedestrians. A provision of these however would increase active travel.
To the South (Compton and Shawford):
The application fails to include adjustments for Bushfield roundabout to encourage safe cycling as per LTN 1/20 section 10.7 on roundabouts, 5.9 on horizontal curve radii, and Summary principle #18: “Cycle routes must flow, feeling direct and logical. Users should not feel as if they are having to double back on themselves, turn unnecessarily, or go the long way round. Often, cycling schemes – when crossing a main road, for instance – require cyclists to make a series of ninety-degree turns to carry out a movement that a motor vehicle at the same location could do without turning at all. Schemes should be based on a proper understanding of how people actually behave rather than how they might be expected to behave.”
This creates a deterrent to cycling. Instead, the applicants should develop a design that follows state of the art examples from the Netherlands or the Manchester model.
The proposed crossing of Badger Farm road is not safe for cyclists and pedestrians. It includes a refuge island built to “HCC Standard Detail HCC11/C/075 Type 8a” that is only suitable for pedestrians and only on roads with a 40mph speed limit or lower. It is not appropriate for a shared-use crossing that connects a bridleway to a shared-use path (used by cyclists, pedestrians, mobility scooters, wheelchairs, and equestrians), crossing a 60mph road. The crossing is equally unsafe for those who like to reach the bus stop on the other side of this busy road.
We are concerned about the lack of a footway and segregated cycle path along Badger Farm Road, given the high speeds and potential pedestrian traffic to the nearby Sainsbury’s supermarket.
Although there are proposals for a private shuttle bus, it fails to provide details on how this is linked to other bus routes, what frequency there is planned throughout day and night and how it links to the P&R parking, supermarkets, train stations in Winchester and Shawford, schools etc. The design of the bus stops is poor with little or no shelter. Routes to current bus stops are difficult to reach via long and unpleasant routes, i.e. requiring crossing a busy roundabout to reach Otterbourne Road for the Blue Star bus.
The proposals should follow standards as stated in the National Planning Policy Framework (NPPF) 104, 110, 112, 113, as well as the National Design Guide (Paragraph 82, Planning practice guidance for beautiful, enduring and successful places, 2021): “Priority is given to pedestrian and cycle movements, subject to location and the potential to create connections. Prioritising pedestrians and cyclists means creating routes that are safe, direct, convenient and accessible for people of all abilities. These are designed as part of attractive spaces with good sightlines, and well-chosen junctions and crossings, so that people want to use them. Public rights of way are protected, enhanced and well-linked into the wider network of pedestrian and cycle routes.”
It is disappointing that this application concentrates primarily to accommodate access by car, instead of promoting most access by active travel, resulting in a major traffic increase estimated to at least 4500 extra car journeys a day. This is another reason for the planning application to be rejected.Brownfield or Greenfield
The whole site includes primarily greenfield and some brownfield with partially demolished buildings and some tarmacked roads and squares. We like to point out that the smaller brownfield area has rewilded during the last 40-50 years since the closure of the army camp. This is a longer period than the time it was used by the army.
The whole area has attracted locals for its value for walking in the countryside with great views towards St Catherine’s hill, St Cross Hospital and the Cathedral. Without doubt this supports their physical fitness and wellbeing.
Risk to Biodiversity
It is well known that brownfield, if left alone over decades as here, starts rewilding and can host a greater variety of wildlife then farmland which is usually labelled as greenfield. Many invertebrates have complex life cycles, needing different things at different stages, so they often require two or more habitats close to each other – a ‘mosaic’ of habitats. Brownfield sites are one of these precious mosaics in the wider landscape, providing habitat variety that is rare in the agricultural countryside. www.buglife.org.uk/resources/habitat-hub/brownfield-hub
Hazel Dormice, Common Lizards, Invertebrates and many bird species have been spotted on Bushfield land. The construction of this development, with construction ongoing for 11 years, will disturb their habitat and therefore contribute to the decline of threatened species within an ecosystem that has grown over more than 4 decades.
Dormice are known as a ‘flagship’ species, meaning that they are found in a habitat that is usually suitable for a wide range of other species too. The protection of dormice will help to protect species such as the common lizard, slow worm, badger, warblers, fieldfare, tawny and little owl, and woodpecker.
The data to describe the ecological value of Hazel Dormice appears to be out of date as it is based on the 17 year old Conservation Handbook when Hazel Dormice was more common. The State of Dormice Report 2023 however concludes that “dormice are locally extinct in 14 English counties within their historical range; in a further six they are known only from reintroduced populations”. The State of Britain’s Dormice Report 2023 states that “between 2000 and 2022, the National Dormouse Monitoring Programme (NDMP) shows the population has fallen by 70 per cent”.
The development proposals state that there is 33.5ha of suitable dormouse habitat on site which is estimated to accommodate 13 individuals. The proposals include the removal of 7.43ha of confirmed and potential dormouse habitat, however only 2.28ha appears to be provided in compensation, which would cause a loss in habitat of 5.15ha. In addition, the activities linked to the development including noise and light pollution and an increase in human activity will further impact on the Hazel Dormice population as they are active at night.
Natural England have stated in the paper ‘Definition of Favourable Conservation Status for Hazel or Common Dormouse’ that 12-13% increase in mixed deciduous woodland is required for the species to gain favourable conservation status. The developer should provide compensation for lost habitat due to the development (7.43ha), plus the recommended increase in suitable habitat (4.36ha), plus a quantified compensatory area of habitat due to the degradation of suitable existing dormouse habitat.
The habitat will need to replace like for like in terms of species and will need to connect to wider green infrastructure through linear hedgerows. In addition, proposals will need to compensate for the delay of the new habitat to become suitable due to the time it takes for planted shrubs and trees to bear fruits and flowers and for suitable links to grow between upper and lower canopies.
The plans state that vegetation removal will be carried out under ecological supervision and take place outside of the sensitive peak breeding season (June to August). However, it fails to protect the peak bird nesting season (March to July).
In our view the proposals do not comply with Section 15 of the NPPF (conserving and enhancing the natural environment), or Local Plan Policy CP16 or WT3, as the proposals fail to adequately protect or enhance or restore the Hazel Dormouse Habitat, or the onsite Sites of Importance for Nature Conservation. There is also likely to be significant recreational pressure on the River Itchen SAC and SSSI and St Catherines Hill SSSI from the proposed development. The proposed phasing also does not comply with Policy CP15 (Green Infrastructure) which requires that green infrastructure is provided at “the earliest feasible stage”, in our view the mitigated woodland and grassland habitat needs to be created years in advance of the habitat removal.
Policy WT3 requires development of the site to have a ‘conservation led approach’. In our view, the proposals, which include a 525 bed student village, 100 bed hotel, sports facilities, shops, cafés, and bars, which are to be built on land that is currently designated as a Site of importance for Nature Conservation, cannot be said to be a conservation led approach. The development is clearly too ambitious for the fragile ecology located on the site and is led purely by economic interests. The application admits that “Bushfield is an employment-led, mixed use development…” and that the applicant is seeking to get the “best possible return” on the site.
Finally, WCC unanimously voted to support a motion to declare a Nature Emergency in September 2023 which underlines that this application should be rejected.Climate Change
Winchester City council declared a climate emergency in 2019 with the aim for the wider district to be carbon neutral by 2030. The proposals in this application, however, are not in line with these plans. Construction and life cycle as well as all the impacts including traffic should be carbon neutral.
Visual impact on South Downs NP
The planned development will be visible from the South Downs NP.
Noise and light pollution
The plans will undoubtedly increase noise and light pollution during construction and afterwards. This would have a negative impact on locals. It will also change the habitat of sensitive wildlife. This is of particular concern to nocturnal animals like dormice.
Water Supply and Wastewater
We worry that this development will put further strain on the overstretched water supply for Winchester. Water extraction from chalk aquifers is already at a limit that led Southern Waters to plan to recycle wastewater and revert it back from Waterlooville to Winchester. These plans fail to outline where the extra water for this development can be sourced from.
Despite the possible inclusion of a water treatment works there remain concerns on where the water will be drained to. The extra volume of water, even if it was cleaner, would put extra strain on the mains sewer at Morestead WwTW which would increase the likelihood of so-called storm overspills.
There are details missing on the design of a Sustainable Drainage System (SuDS) including evidence and reassurance that the proposed SuDS does not lead to deterioration in water quality affecting the Itchen and groundwater.
Objection to Bushfield Development Application 23/02507/OUT
We like to see reassurance according to the motion unanimously supported by WCC in July 2022 “To protect our local rivers & waterways by taking account of the cumulative impact of pollution including sewage discharge”.Outline planning application
We are concerned that an outline planning application limits opportunities for the council and local people to participate in more detailed plans. The application seeks to exclude Access from the Reserved Matters, meaning that, if the application were accepted, there would be very limited scope for correcting errors and inadequacies introduced at this early stage.
Furthermore, we reject that this application gives too little time for people to study the application in detail to be able to respond fully.
Alternatives
We appreciate that the Church Commissioners as the owners of this land have a duty to look after the land and to get a return for their pension funds. However, they also follow an ethical policy which includes safeguarding God’s creation. The Church of England has agreed an ambitious goal to become carbon neutral by 2030.
Therefore, this land could offer a prime opportunity to use the land as a carbon sink. This could include further rewilding and tree planting. The small brownfield land could be used for an installation of a combined solar and wind farm with combined energy storage while encouraging biodiversity.
The land could be used for educational purposes to observe and measure the rewilding process. Pupils from surrounding schools could learn about biodiversity, renewable energy etc. in a study centre like in Minstead in the New Forest.
The land could also offer room for a ‘Wild Church’ in the open.
These alternatives would benefit locals, be in keeping with church and local policies and provide an annual financial return for the Church Commissioners.
Summary
This planning application should be rejected by WCC as it is in the wrong place, lacks benefits for the local community, contradicts recent plans to reduce carbon emissions, destroys habitat for species that are threatened by decline, fails to promote active travel modes, increases traffic congestion and will change the South of Winchester with its heritage sites forever.
