Our objection to Bushfield Camp Plans

We object to the proposed development for the following reasons

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 also 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 also contend that Policy WT3 permits the construction of a 100 bedroom hotel and 525bed student village. 

The Applicant has also 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 also 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 also requires development of the site to have a ‘conservation led approach’.  In our view, the proposals, which include a 525bed student village, 100bed 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 even 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. 

Policy WT3 also 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 brought about in building use due to more 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.  Our view is supported by the Local Plan Spatial Strategy, which advises that “any large-scale growth (1000 square metres or more) should generally be concentrated within Winchester town centre”, and Policy DS1 which requires development to take a ‘Town Centre First’ approach. 

Local Plan Policy WT3 also 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 an urban campus scheme will detract from the town centre, the scheme would be better placed within the urban centre where it would stimulate investment and regeneration.  The proposed hotel 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 educational need. 

Access, Transport, and Carparking 

The proposals include 1050 car parking spaces.  Although the proposals state that “sustainable alternatives will be offered, including a private regular shuttle bus service which operated between the Site and Winchester train station, a car club, and electric bikes”, if carparking is available, then out of convenience, most visitors are likely to access the site by car.  Similar claims were made regarding the development of the Winchester Sports and Leisure Park regarding alternative sustainable transport, and now cars queue to access the site from Bar End Road.  In our view this does not comply with Policy WT3 which states that the development should “exploit the site’s proximity to the Winchester South Park and Ride site to access the site without reliance on the private car”. 

At peak times, there is significant queuing on the roundabout and adjacent roads Badger Farm Road and St Cross Road, any increase in traffic is likely to cause a significant impact on the local transport network in terms of congestion and highway safety (with motor vehicles queuing on the motorway).  In our view the proposals are therefore not compliant with Paragraph 110 of the NPPF states that “any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree”.   We also are of the view that the proposals do not comply with Local Plan Policy DM18 the development has not provided appropriate parking and access arrangements. 

The roundabout adjacent to the proposed development site is a danger for pedestrians and cyclists to cross, especially crossing Hockley Link.  We welcome the proposed improvements providing new signalised crossings around the full perimeter of the roundabout, but request that these works are completed prior to development so that construction workers accessing the site can do so safely. 

The proposals state that “Pedestrian and cyclist access to the site is proposed from north and south-east of the site and will be facilitated as part of the development through the construction of shared pedestrian and cycle routes and crossings”.  The proposals also state that a “significant proportion of both pedestrian and cyclists are likely to access the site from the north… the northernmost extremity of the site connects over the footbridge over the railway line to the east”. 

Having the proposed main cycle access to the development, running over a foot bridge, is not acceptable.  Cyclists will have to lug bicycles (including heavy e-bikes) over the bridge meaning that cycle access to the development will be discouraged rather than promoted.  This will also cause major issues for wheelchair users and those with mobility issues.  The rights of way and permissive path network surrounding the development will also need significant improvement, many paths are extremely muddy under current usage and will require surfacing if they are going to be utilised to promote non-vehicular access to the site.  In our view the proposals therefore do not comply with Local Plan Policy WT3 which states that the development should “promote non-vehicular access to and within the site, through the creation of new routes and extensions/diversions of existing routes to ensure that the site integrates with surrounding areas and to minimise and mitigate its impact on the strategic highway network”. 

We note that access is not a reserved matter and public rights of way are therefore a material consideration within this application.  The proposals do not provide any certainty around how the development will link into the rights of way and permissive path network with permissions regarding surfacing of routes and providing new routes over land outside of the Applicant’s landholding still to be agreed.  We therefore do not consider the application to a viable proposal or that the proposal is at the stage where permission can be granted. 

Biodiversity and Ecology 

Winchester City Council have just declared a nature emergency which acknowledges the impact that the climate crisis is having on wildlife and nature. 

Policy WT3 also requires that proposals “include a Sustainability Appraisal and Habitats Regulations Assessment to consider the potential effects on biodiversity, on-site and on the River Itchen, and the possible in-combination effects of the development on nearby sites of national and international importance. The development proposals must meet the tests of the Habitats Regulations and be accompanied by a full set of measures to avoid or mitigate the local and wider impacts of the development”. 

Hazel Dormouse  

The figures that the ‘Chapter F Ecology’ document uses to quantify the ecological importance of Hazel Dormouse appear to be cherry-picked and are out-of-date, this gives a misleading account of the vulnerability of the species and of their decline.  For example, the document references The Conservation Handbook 2006, the information provided was published 17years age and is out of date. For example, the document states that “dormouse are widespread within Hampshire and all southern counties” and that “they are known in 32 English counties” and that “dormice are considered ‘common’ in Hampshire”.  The State of Dormice Report 2023 confirms provides 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 ‘Chapter F Ecology’ document also references The State of Britain’s Dormice Report 2016 stating that the total adult population of dormouse in the UK is approximately 930,000, however 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”.  Natural England in their paper Definition of Favourable Conservation Status for Hazel or Common dormouse states that the population in 2018 was 757,000 individuals.   

A separate more recent study detailed in Shifting Baselines for Species in Chronic Decline and Assessment of Conservation Status, using data up to 2021, has shown a decline greater than 50% in ten years and suggests that the species should be classified as endangered. 

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. 

The proposed development is likely to have a detrimental impact on the suitability of the existing dormouse habitat.  The development is likely to cause increased human activity and noise pollution within the dormouse habitat, which is of particular concern due to the high-density accommodation proposed and as the existing habitat is not often visited by people.  The development is also likely to cause increased use by dog walkers, dogs are likely to disturb hibernating dormice and may also predate on individuals.  The increase in human activity is also likely to cause an upsurge in populations of species which thrive in these conditions such as rats, mice, squirrels, and birds such as rooks and magpies.  This upsurge is likely to be exacerbated in summer months when dormice are feeding in preparation for hibernation due to the expectation that there will be 500+ people picnicking on site.  These species are likely to predate on dormice and cause habitat loss due to competition.  The development is also likely to increase light pollution this is of particular concern as dormice are nocturnal. 

Natural England have stated in the paper ‘Definition of Favourable Conservation Status for Hazel or Common Dormouse’ have stated that 12-13% increase in mixed deciduous woodland is required for the species to gain favourable conservation status.  In our view a conservation led approach should propose to increase suitable dormouse habitat on site to these levels which would mean increasing the existing habitat by 4.36ha.  We request that the developer is required to 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 fact that the new habitat will not be deemed suitable habitat immediately 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 enabling ecology works are proposed for phase 0 and other enabling works in phase 2.  It is likely that there will need to be several years between planting and habitat removal so that the new habitat has developed enough to compensate for the loss. 

The proposals state that vegetation removal will be carried out under ecological supervision and take place outside of the sensitive peak breeding season (June to August).  We also request that vegetation removal takes place outside of the peak bird nesting season (March to July). 

Dormice are also known as a ‘flagship’ species, meaning that where they are found the habitat is usually very suitable for a wide range of other species too.  This is very true for Bushfield Camp, which is a vital sanctuary for wildlife, hosting species such as common lizard, slow worm, badger, warblers, fieldfare, tawny and little owl, woodpecker. 

River Itchen SAC and SSSI and St Catherines Hill SSSI 

The river Itchen is designated as a Special Area for Conservation (‘SAC’) and Site of Special Scientific Interest (SSSI). St Catherines Hill is also designated a SSSI.  The proposals suggest that the occupants of the hotel will not present additional recreational pressure as they are unlikely to leave the development site.  The proposals also state regarding the academic accommodation, that a small number of individuals may wish to undertake recreational activities such as walks or cycles to this area.  We disagree with this assessment. 

St Catherine’s Hill can be viewed from the development site and a walk up the hill is very popular for those vising Winchester, it is currently no 8 of 68 things to do in Winchester on Trip Advisor.  Walking and cycling along the Itchen navigation, Viaduct Way, and National Cyle Network Route 23 is also very popular.  In our view this will also form a more attractive alternative transport route into the city centre than the rights of way network to the north of the development due to the topography and unless significant investment is put into surfacing and providing adequate crossing of the railway. In our view students and hotel occupants are likely to venture off site and are likely to increase recreational impact on the River Itchen SAC and SSSI, and St Catherines Hill SSSI. 

Recreational pressure on these sites is already very high, this was highlighted by the Wildlife Trust and other conservation authorities within the application to build the Handlebar Café.  We request that further modelling is completed, and that mitigation is provided to ensure that these protected habitats are preserved and that species such as otter are adequately protected. 

Sites of Importance for Nature Conservation (SINC) 

Bushfield Camp B SINC is situated in the north of the site, it has been selected due to being calcareous grassland, although parts of this have now succeeded into scrub habitat.  Bushfield Camp C SINC is situated in the south of the site.  It has also been selected as a SINC due to being calcareous grassland.  Calcareous grassland is important for nature conservation due to being a species rich habitat for flora and fauna, this site is also home to a rare species of bee. 

The loss of calcareous grassland has rapidly accelerated since the 1960s. Known ecological impacts include reduction in the extent and variety of plant and animal-rich assemblages managed by grazing; reduction in the species rich plant communities through impacts such as atmospheric nitrogen deposition and fertiliser overspread, and extinction ‘debt’; and reduction in the populations of specialist species due to grazing abandonment, insufficient habitat area to maintain viable populations and eutrophication of soils. 

The proposals include the permanent loss of 2.54ha of this habitat which is of high conservation status.  In mitigation for the major adverse effect on the SINCs, the proposed mitigation will be to create 6.25ha of new calcareous grassland habitat, this will also provide an additional area of chalk grassland for the reptiles displaced through construction.  The proposals aim to achieve SINC status on only 2.54ha to compensate for the habitat removed by the proposed development. 

The creation of calcareous grassland is a slow process and would take approximately 10years to restore.  Creation/restoration will be inhibited by previous use of land for agricultural purposes which may cause imbalanced nitrogen and phosphorous composition but may benefit from being located directly adjacent due to seed dispersal from the current SINCs.  The proposals will need to start the enabling ecology works many years in advance of any habitat removal.  It is also our view that the proposals should aim to ensure that full 6.25ha of created calcareous grassland meets county SINC status and favourable conservation status. 

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. 

Landscape and Strategic Gap 

The proposals state that this is a “low-rise scheme”, however this is a major development which includes high density multi-storey buildings. Due to the topography of the site is likely that the proposed development will have a detrimental impact on a landscape scale and will create a new urban centre within strategic gap and nature rich surroundings.  Due to the vibrant night-time uses that are proposed the development is also likely to have a significant impact on the landscape at night.  The development is also likely to have a major detrimental impact on the views from the local rights of way network, South Downs National Park, and St Catherines Hill. 

The development does propose green roofs, but this is only indicative and may not be secured through reserved matters applications.  In our view, the development does not comply with Policy WT3 which requires that the development “be of exemplary design and configuration so as to have an acceptable impact on the setting of Winchester, the South Downs National Park and the wider area, retain key views, and take into account its unique gateway location and the various designations that affect the site and its surroundings”. 

The development also does not comply with Local Plan Policy CP18 (Settlement Gaps) which requires the proposals to “retain the generally open and undeveloped nature of the defined settlement gap between Winchester and Compton Street” and states that “within these areas, only development that does not physically or visually diminish the gap will be allowed”; and CP19 (SDNP) which requires new development to be “in keeping with the context and setting of the landscape... within the SDNP”; and CP20 – Heritage and Landscape Character which requires the development to give particular emphasis to conserving “local distinctiveness, especially in terms of characteristic materials, trees, built form and layout, tranquillity, sense of place and setting”. 

Climate Change 

Winchester City council declared a climate emergency in 2019 which is aimed at ensuring that the wider district is carbon neutral by 2030.  The proposals state that the development is likely to take approximately 11years to complete and therefore will not be completed until 2036, the plans should therefore provide a development that achieves a net zero carbon footprint. 

The proposals include an “all-electric (no gas) approach” with an “intent to maximise solar PV” and state that “further energy demand will be met from low or zero carbon energy sources on or off-site.  Heating demand will be achieved via low or zero carbon technologies such as heat pumps”.  However, this is only indicative and may not be secured through reserved matters applications.  For example, the proposals give an example of another project that L&G have overseen, the Newcastle Helix, the proposals stated that the site would be heated entirely with geothermal energy, however this was dropped to gas powered turbine. 

To achieve a net zero carbon footprint by 2030, the development will also need to achieve net zero transport emissions, meaning that access to the site will need to be by walking, cycling, and BEV public transport.  As the development will not be completed until 2036 there should be a zero-emissions transport zone designed into the site. 

In our view the development does not comply with Local Plan Policy CP11 - Sustainable Low and Zero Carbon Built Development.  The development, which will not be built until after 2030 must be designed to have a net zero carbon footprint and must use renewable energy technologies to produce all required energy on-site.