How to find and comment on a planning application

Commenting on a planning application is a relatively simple process. If you’ve ever written a product review online, then you can certainly do this!

We’ve shown a simple six step process here for first Finding, and then Commenting on a planning application. Normally, if we give you a link to comment on a planning application in one of the website articles, then that link will take you straight to Step 5.

If you just want to see what planning applications there are in the Havant Borough Council area, the first place to go is the Planning Public Access page. Click that link and the following page will open in a new browser tab.

Note, the images shown below are a from a Windows PC, the appearance on a phone will be different but the content will be the same. It is actually much easier to work on this from a PC /Laptop screen if you can

Step 1

Enter your search text in the box next to the green Search button and when you’ve entered the details, press the button. In this example, we’ve entered ‘Market Parade’.

Note, if you already know the Planning Application Reference Number, which will be something like APP/21/0001, then enter that number as your search.

Step 2

You’ll now see a list of planning applications in date order, newest at the top. Find the one you’re interested in and click the blue link text.

Step 3

The next screen shows the summary of the planning application that you’ve selected.

Note that there are a set of ‘tabs’, starting with ‘Details‘ and followed by ‘Comments’, ‘Documents’ and ‘Related Cases’. In the image below, we’ve highlighted the ‘Documents‘ tab and the ‘Make a Comment‘ button.

The Details tab gives a summary of the application, and also allows you to see ‘Further information‘, ‘Contacts‘ and ‘Important Dates‘.

The screen that we’ll show next is the one you’ll see when you select the ‘Documents‘ tab. (Note the count showing how many documents there are).

Note If the application is straightforward, perhaps for a conservatory or to cut down a tree, then there will be just a couple of documents, whereas if the application is for a new housing estate there could easily be 50+ documents covering all aspects of the works. 

Step 4

The Documents page will show you a list of the documents associated with the planning application, the most recent being shown first.

Note that on the right hand side of this image, you will see small icons against each document, circled in red in this example. Click those icons to open and read the documents, which will each open in a separate browser tab.

Note This part much easier on a PC than on a phone!

Once you’ve read the documents that interest you and have decided you want to make a comment, then find the ‘Make a Comment button at the top of the page and press it!

Step 5 – Making a Comment

In this example, we show the screen that will appear when you press the ‘Make a Comment’ button on an application. Please note that you do not have to register with the council to see these and comment, but you will have to give a valid name, address, postcode and email address.

When you select the ‘Commenter’ type drop down, pick ‘Complainant‘ – the selections are not exactly clear!

The other important selection to make, highlighted above in red, is your ‘Stance’ on the application, whether you Object, Support or are ‘Neutral’.

Once you’ve done that, you can write your comments in the big box underneath.

Note that you have a limit of 5000 words and you also have a time limit of 30 minutes. You may find it easier to write your comments in a text editor first, then simply cut and paste them into this box.

Step 6

When you’ve finished filling in your comments, simply press the green Submit button. You do not have to register with the Council if you do not wish to.

Final note, Just like product reviews, there is some checking the Council does before your comment is published, so it may take a couple of days before your comment appears.  You will be able to see the comment you have made and comments made by other people.  

Taking Responsibility for Traffic Management

Updated 15/4/2021 21:00

This is a long read in five related sections. To skip to a section directly, take these links:

  1. HBC – Lack of focus on traffic
  2. Traffic – What’s the problem?
  3. The railway bottlenecksFrom Bedhampton to Bosham
  4. The future of New Lane
  5. Postscript for HBC Councillors

HBC’s lack of focus on traffic

The current planning application for the former Pfizer site at 32 New Lane has raised a storm of objections over the inevitable impact that the development would have on town traffic. Each of those objections stands on its own individual merits but a recurring theme throughout is concern for the increased danger to cyclists and pedestrians, from school age to the elderly, from such a significant increase in traffic movements on residential streets. This additional traffic and its inevitable pollution will directly impact the three primary schools within a mile of the site. Sharps Copse Primary to the north, St Albans Primary to the west and Fairfield Infants to the south.

When the Council announced its new constitution in January, it predicted that it would “make the operation of the council more agile, cost effective and able to respond to the needs of the community.” The Constitution itself defines a role of “Cabinet Member with Portfolio Responsibility for Traffic Management”, but the fact that no Councillor is named in that role in this current Cabinet demonstrates the lack of priority given by HBC to the impact of traffic.

This is not the first time that ‘Consultee Traffic Team’ has failed to recognise that Havant has a problem with traffic. In fact, we’ve seen this exact same response on previous occasions, word for word, right down to the email address which still returns mail as invalid. These consultee responses are sloppy, but they’re not the fault of ‘KRC’, who probably works out of East Hants District Council with objectives that cover little more than parking and closing a few roads for Remembrance Day. Without any clear Cabinet oversight of the job, the ‘Traffic Management Team’ – if they actually exist – clearly flounders.

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So what’s the problem?

Understanding why Havant town has a traffic problem isn’t rocket science. The problem stems from the growth of the town around the fixed railway infrastructure that once formed the town’s transport hub.

The migration of freight from the rail network to the road network over the past sixty years has resulted in the construction of a brand new strategic road transport hub, out of town to the south west at Broadmarsh. New employment areas have been built alongside the A27 and the A3(M), enabling rapid connection between the employment areas and the trunk roads, with minimal impact on the town traffic.

In the 1872 map, below, the railway network is clear, with Havant Station in the top right hand corner. The second image, from Google Earth, overlays the new trunk road infrastructure.

As the area to the north of the railway becomes increasingly residential and personal car ownership continues to increase, the bottlenecks formed by the five railway crossing points present challenges for journeys outbound to, and inbound from, the A27 and the A3(M). With no high volume traffic route between the A3(M) at Horndean and the A27 at Southleigh, the former New Lane industrial estate is now landlocked by residential development and starved of efficient access to the national road network.

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The ‘railway crossing’ bottlenecks

Park Road North road bridgeConstraints: Uninterrupted by train movements – Single lane vehicle approach, two lane exit

In brief: This crossing is heavily congested at peak times, weekends and holidays due to downstream congestion at Langstone Roundabout, Elm Road junction and Solent Road junction. There is increasing congestion associated with home delivery and ‘drive thru’ traffic generated by the four main fast food outlets sited on Park Road South.
Bartons Road road bridge Constraints: Uninterrupted by train movements – Single lane each way

In brief: The nature of the traffic flow over the Bartons Road bridge will change irreversibly once the Southleigh A27 Link is built since it will provide the quickest uninterrupted route to an A27 junction for a large area of Havant. Furthermore, if ‘traffic generating’ businesses continue to be tolerated or are allowed to grow at the New Lane employment area, then this crossing will become the route of choice for access to the A3(M) via the Comley Hill, Whichers Gate, Horndean rat-run and to the A27 via Southleigh.
New Lane level crossingConstraints: Closed for all trains on the London line and Brighton line

In brief: Frequent traffic tailbacks across New Lane/Eastern Road junction to the north, and across the Fairfield Road/Waterloo Road junction to the south.
Southleigh Road level crossingConstraints: Closed for all trains on the Brighton line

In brief: Frequent tailbacks blocking access to residential properties and Warblington School.
With the New Lane / Eastern Road / Elmleigh Road rat run closed , this crossing may now be favoured by LGV traffic heading to A27 E/W at Warblington.
Bedhampton level crossingConstraints: Closed for all trains on the London line and Brighton line

In brief: Extended closure at times due to the short platform when long westbound trains stop at Bedhampton Station. Peak time local hold ups for commuter traffic to and from Southmoor Lane / Harts Farm Lane.

And further east?

Travel on eastward towards Bosham on the A259 and what do you see? All the way from Emsworth, through Southbourne and Nutbourne, a ribbon development of new housing crammed in south of the railway to help Chichester District Council meet its own housing targets. Constrained by the level crossings at Southbourne, Nutborne and Bosham, much of that new population will be driving to and from the first available A259/A27 junction – at Warblington.

Once the Southleigh A27 link (Option 1B) is open, just how well will the Warblington A27 interchange cope? (Answers, on a postcard please, to

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New Lane – Looking to the future

Sixty years ago, New Lane led Havant’s growth with the likes of Kenwood, Goodmans, Colt, Scalextrix and Britax. The quality and reliability of the West Leigh workforce with their famous ‘We’re backing Britain’ campaign encouraged IBM, Plessey, BAe and Siemens to invest in the Borough. As a regenerated employment area providing sustainable jobs within easy reach of the town centre bus and rail hubs, New Lane should have a great future.

Those famous manufacturing brands that were once synonymous with the New Lane estate have mostly moved offshore, with only Kenwood retaining office, shop and warehouse space on the site. Given its increasingly urban context, the site is now far better suited to businesses with sustainable day-time working and commuting patterns, ideally providing the local residential community with the higher skilled employment opportunities promised by Havant’s Regeneration Strategy. Eatons, Kenwood and Dunham Bush are all long established ‘good neighbours’ and with the opening of the corporate headquarters of Anetic Aid and more recently the new UK site for Sartorius, the potential for the right sort of growth is clear.

Businesses that generate traffic movements in excess of normal daily commuting should be actively discouraged and ‘managed out’ by Havant Borough Council, while office-based employment, technology based manufacturing and the type of high value, secure storage opportunities associated with the Solent Freeport should be encouraged. The Spring Business Park under construction on the former Butterick site, with Qvis CCTV and Security a convenient neighbour, could be readily adapted to support Havant’s Freeport opportunity,

A coherent strategy for the management of Havant’s traffic is the key to unlocking the potential of New Lane while at the same time reducing the peak time traffic which chokes the town’s road network. While the real authority on highways and traffic lies with Hampshire County Council’s Highways Authority, much closer liaison between the Borough and County council is required if we are to keep control of our streets and keep the traffic moving. The role of “Cabinet Member with Portfolio Responsibility for Traffic Management” should be recognised for its importance and should be filled with an appointee with vision.

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Postscript for HBC Council Members

The decision on this application is critical to the future of Havant. The wrong decision will simply exacerbate the existing traffic problems, will endanger the safety of residents and their children, and will deny the New Lane employment area the opportunity for the type of regeneration that will secure its future growth. The right employment profile will bring the business opportunities that lift educational standards across the Borough, just as the high tech businesses which followed New Lane’s first wave in the 1960s did.

A great many hours have been spent drilling into the documentation which accompanies application APP/21/00200, in order to arrive at an adequate level of understanding. For those elected representatives in decision making roles, the following paragraph from the Planning Code of Conduct is particularly relevant:

Do come to your decision only after due consideration of all of the information reasonably required upon which to base a decision. If you feel there is insufficient time to digest new information or that there is simply insufficient information before you, request that further information. If necessary, defer or refuse.”

The Transport Statement provided by the applicant is ‘topped and tailed’ with a soft, marketing spin that should not be taken at face value. The language in the ‘Summary and Conclusions’ is loose and the data within the document contains many inconsistencies and selective omissions. It is presented, as might be expected, in a manner supportive of the Applicant’s case so I would urge you to study this in depth.

An exhaustive critique of the document set would be a dry read indeed, so please just consider these two examples from the tables in the main document. This should give enough of a guide to the accuracy of its conclusions.

The first point to note in both of these tables is that the data shown covers a single one hour ‘peak’ in the morning, a one hour peak in the afternoon, and a total daily figure. The application is for ‘3 shift operation’ over a 24 hour day, 7 days a week, therefore the periods selected for these comparisons are not representative of the true impact of the business on the town’s environment.

Table 5.4 is used to demonstrate that, compared “to the previous maximum usage of the site the proposed development would generate less traffic both during peak hours and across the day”. That’s very convenient but also rather misleading since the ‘Previous Maximum’ numbers are theoretical, assuming the traffic that might be generated if the site were used to the maximum extent allowed under the planning permissions currently in place. This theoretical decrease of just 90 daily vehicle movements is referred to in the document as “significantly less vehicle movements”.

Table 5.4 is then used to demonstrate that the proposal would result in a decrease in both morning and afternoon peak hours of the existing site traffic, while only adding “an uplift of movements” to the overall daily total. This increase of 466 vehicle movements is referred to in the document as “slightly more traffic”. The residents of New Lane, who have lived with the operation of ‘the existing site’ for many years, question the veracity of the ‘existing site’ numbers quoted since they bear no resemblance to observed reality.

Not only are the authors of the Transport Statement creative in their use of English, but their basic mathematics is also equally loose. A nit, repeated too many times to be a typo, is their constant quoting of 2,415 vehicle daily movements. According to us, that’s slightly at odds with the source numbers for the proposed use provided in Appendix F, ‘Occupier Traffic Data’. That data source is a simple table that predicts actual movements arriving and departing from the site over a 24 hours period, based on the intended occupier’s existing sites across Europe (listed in appendix H).

We can safely assume that this data source represents just the HGV and LGV movements since there is no evidence in the data for the three shift staff commuting patterns the intended occupant proposes. Staff arriving for, and leaving at a midnight shift changeover will not be using public transport.

We looked at the occupier data and drew up a rather different picture:

The blue data is taken directly from Appendix F and shown for each hour of the day. The grey data includes the additional movements of the van drivers, arriving in their own cars in the morning to pick up a van and leaving at the end of their shift having dropped their van back in the vehicle storage unit. The yellow data assumes that there are 208 staff on site at any one time in the 24 hour day, with three shifts changing over at midnight, 08:00 and 16:00. Since the employee numbers, while clearly available, are not given, we’ve made an assumption that the parking spaces allocated in the design are used by the warehouse work force. We know from elsewhere in the document that the van drivers will be parking their personal vehicles on the ‘van storage decks’.

In summary, the Transport Statement supplied in support of the application is at best, creatively misleading.

Please read deeply and consider the much wider implications of this application. The right decision will open the opportunities for regeneration that the town needs. The wrong decision will be remembered for a generation.

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32 New Lane – The full story on traffic and jobs?

Updated – 03-4-2021:
Read the main story here
Read our media comment here
Read our ‘Fact check’ post here

Consultation on this plan officially closes on Tuesday but comments can still be made online after that date. If you feel strongly about this, please do make your views known. Full details are given in the ‘Main story’ post, see the link above.

So far, neither the applicant – Havant Property Investment LLP, better known as Kingsbridge Estates with Bridges Fund Management – nor their Agent – Luken Beck – has come clean about the name of the ‘intended occupant’ they’re proposing to install at the former Pfizer Cold Chain Warehouse site.

Nor have they come clean about the real impact of traffic generated by the site, submitting a Transport Assessment (aka Transport Statement) which is riddled with inconsistencies and misses significant detail which would clearly be inconvenient to them.

We were recently encouraged to find that Hampshire County Council Highways share some of our misgivings but we’re not yet convinced that HCCH fully understand the nature of Havant’s rat run traffic issues.

Nor has the applicant come clean about the number of proposed employees, having deliberately left section 18 of the Application Form blank. Of course it’s quite possible that they just don’t know how to fill the numbers in given the type of business proposed.

Maybe a change to the form would help here:

We took a deeper look at the likely number and quality of the employment opportunities that a site of that nature and scale would generate. Only after doing this could we predict the real impact of the traffic with any degree of accuracy.

There will be jobs, for sure. Not all current employees of the unnamed company will be consolidated on this site. But let’s just think for a moment about the quality of those jobs. Half of them will likely be self-employed drivers on target-driven pay, with deductions for rental of the vans they’re using, while most of the remainder will be low paid, low skilled warehouse opportunities working in three shifts, round the clock, seven days a week. If you’ve forgotten that Scottish Daily Record undercover report on Amazon’s Last Mile hub in Lanarkshire, it’s worth reading again. Click the link.

Having taken a look at the quality of those jobs, let’s first look at the scale of the traffic. Previously, we were considering ‘just’ the HGV and LGV movements from the site, totalling near 2,500 vehicle movements per day. As if that wasn’t bad enough given the dreadful state of Havant’s traffic in normal times, you can now multiply that figure by 220% to get the real figures once you add in the impact of staff and driver commuting.

Operations in the warehouse will be running 24 hours a day, on a three shift basis, with a midnight shift changeover which would potentially generate another 400+ traffic movements through the local residential streets between 11:30pm and 01:00am.

Let’s have a look at the traffic movements in and out of the site:

With almost 800 vehicle movements at the site in the peak morning hour, it’s no wonder that they’re seeking planning permission for a new, third exit onto New Lane.

We’ll be able to confirm those figures once the Applicant completes the missing details and we can be certain that when they’ve figured out the best way to spin the ’employment’ data, the number will be sold as the headline grabber. At the end of the day, however, the real headline grabbing number is this one:

Vehicle movements

each day.

All of them using the well known rat-runs.

The real losers?

While the whole town loses out here because of the traffic impact, it’s the young and the unemployed who actually stand to lose the most. This is hardly ‘levelling up’ the local economy to use a fashionably meaningless term.

When the full Havant Borough Council Council signed off the Regeneration Strategy on November 7th, 2018, they committed to the following actions on ‘Skill levels’ and ‘Earnings’:

To work in partnership with business to boost employment within higher value roles – managerial, technical and professional occupations to increase local spending power.

To work in partnership with business to drive up the skill profile of the resident workforce to take advantage of higher value roles created within the Borough.

To increase wage levels of Havant residents by driving up the resident skills profile and creating higher value job opportunities in key sectors

We expect Havant Borough Council to make the right decisions for the future of the town and its kids. Please don’t let them down. Above all, don’t throw away a site that is perfect for the kind of employment that would satisfy those actions.

This application should be welcomed, but only if appropriately sited south of the A27 or alongside the A3(M), sites which would also be in the best commercial interests of the unnamed ‘intended occupant’.

You can turn this into a win-win, don’t ruin the real opportunity you have with New Lane.


End of the line for the last town Gasholder

Do you remember the days when you could watch the local gasholders sink down as the nation cooked their Sunday lunchtime roast dinners? Well those memories have long become history.

In another small step in what we would like to think would be the intelligent regeneration of the New Lane employment area, a planning application has been submitted on behalf of SGN (formerly Scotia Gas Networks) “to determine whether prior approval is required for the method of demolition of one gasholder and associated structures”.

The old town gasholder sits just to the north of the Spring Business Park, currently under construction on the site of the former Buttericks factory which is still visible on this current Google Earth image.

It’s a small, but useful piece of real estate and we wouldn’t be at all surprised if Kingsbridge Estates were looking to add this to their New Lane portfolio. If they are, then we really hope that they have an eye to the future and would be looking to capitalise on the potential benefits to Havant from the Solent Freeport initiative.

Other New Lane business owners will be taking a keen interest in the opportunities presented by a Solent freeport, including the now Danish owned Eaton Hydraulics and the Yantai Moon Group, the Chinese conglomerate who now hold a controlling shareholding in Dunham Bush. With much of the DeLonghi Group‘s production coming from China and destined for export to Europe and beyond, their Italian owners will also be paying close attention to the opportunities presented by the freeport initiative for the DeLonghi, Kenwood and Braun brands.

Meanwhile, the New Lane heavyweights, Kattenhorn and Marsh Plant, will no doubt be looking at the potential ‘freeport bonus’ increase in the value of their land assets. Both own sites in the ‘land-locked’ New Lane estate, with business uses well past their sell-by-dates .

We’re living in interesting times and it would be extremely short sighted to waste a large potential freeport opportunity on a purely UK internal warehousing and distribution business like the one proposed for 32 New Lane.


Solent Freeport – What’s in it for Havant?

A few weeks ago, the Leader of the Council addressed a Havant Borough Council Cabinet meeting and expressed enthusiasm for the opportunities that the Solent Freeport would bring to Havant. In the absence of anything published since, I thought I’d take a closer look at what this might mean. (Warning, this is a longish read, particularly if you open the two documents which accompany it. You might want to put the kettle on first).

The Freeport bidding process

In the March Budget, the Solent was ‘shortlisted’ as the site for one of eight Freeports to be set up in the United Kingdom. In this article, I’ll try to explain what a ‘Solent Freeport’ might mean to our area, drawing from the detail content of the two documents shown below.

The three high level objectives set out in the Government’s ‘Bidding Prospectus’ were, at best, woolly:

  1. Establishing national hubs for global trade and investment across the UK
  2. Regeneration and levelling up
  3. Creating hotbeds of innovation

In their Response, the Solent Local Enterprise Partnership answered the ‘exam questions’ set in the Bidding Prospectus and concentrated on the opportunities.

The two source documents for this article, the government’s Bidding Prospectus and the Solent LEP’s response, are both available here: click the images and they will open in separate browser tabs. At less than 50 pages each, they’re fairly digestible to anyone with experience of reading or writing commercial engagement documents. I’ve put a few hours into reading them both and this article summarises my personal thoughts.

The UK Government’s Freeports ‘Bidding Prospectus’
The Solent Local Enterprise Partnership’s Response

The first document, the ‘Bidding Prospectus’, set out the government’s ambition for Freeports, the core Freeport objectives, and how they expected bidders to respond. The document set out the format in which the response should be written, and explained the marking scheme by which ‘competing bids’ would be judged. It provided additional detail on the UK’s Freeports model, including clear geographic guidelines on site design and size, and how ‘Freeport economic levers’ relating to customs, tax, planning, regeneration and innovation would work. The first three of these are discussed briefly at the end of this post.)

The ‘Response’ by Solent LEP covered all points in the required format, while identifying differentiators unique to the Solent – i.e. selling the reasons why the reviewer should choose their ‘proposal’.

In reality, the first document was a ‘Request for Information’ which simply painted a vision of what a Freeport might be, giving some high level technical ideas which might be applicable, but containing a number of questions aimed at soliciting more realistic solution ideas from potential freeport teams; an opportunity to put some meat on the bare bones of what is little more than an idea. The real competitive bid process will be some way down the line once the government have taken on board all the free consulting that the eight freeport bid submissions have provided.

Just where would the Solent Freeport be?

In summary, the UK Government document sets out the overall scale of a Freeport and demonstrates for a ‘multi-port’ model how the maximum outer boundary could fit with the local geography of the port facilities, regeneration sites, existing storage facilities and the motorway infrastructure that services them.

The bidders were required to “set out on a map the area where they propose the Freeport tax measures should apply in compliance with the government’s requirements”. This presumably is in an appendix to the Solent LEP response still deemed ‘commercially sensitive’ since it’s not yet been made public.

An interpretation of a possible ‘Freeport outer boundary’, drawn using the rules set out in the ‘Bidding Prospectus’, is shown below. It might be out by a mile or two in either direction, but would certainly take in the Havant Borough employment areas.

So what is a Solent Freeport?

The Solent Freeport would be an area designated by the government where companies associated with the freeport have distinct tax advantages. Companies that operate within freeports don’t have to pay import taxes (tariffs) on products until they move them outside the circle and into the full UK market. They can avoid paying certain taxes altogether if they bring in goods through the ports and airports to store or manufacture on sites within the circle before they export them again.

In the case of the Solent Freeport, this could allow for collaboration between the port areas on both sides of Southampton Water, those within Portsmouth Harbour and those on the north coast of the Isle of Wight. There are also intriguing opportunities for the smaller ports and harbours scattered around the Solent shore, within the ‘magic circle’. Since the northern part of the IoW and parts of Portsmouth already benefit from UK Assisted Area status, the definition of Freeport status would provide further incentive to businesses to locate and expand in those areas.

The key to making a Freeport work across the 1,500 square kilometres is in the strict control of movement of products between the various sites – factories, warehousing, customs points and port areas – using RFID technology and ANPR cameras. While the underlying technologies are well known, RFID tags to control inventory movements in shops and warehouses and ANPR cameras to manage speeding on motorways, there is a significant body of evidence concerning criminal risks in freeports and factors that give rise to those risks. Like other freeports across the world, the new UK freeports could also be used to store – without tax – high-value goods, including art, precious metals and fine wine. Such tax-free perks have transformed some freeports into self-storage units for many of the world’s wealthiest people with Geneva’s freeport alone estimated to house over a million works of art, including 1,000 Picassos.

So how might all this affect Havant?

In their response to the bid, the Solent LEP mention Havant only twice, in the same context as Gosport as a ‘significant pocket of deprivation’. Southampton, by contrast, is mentioned thirty-one times to Portsmouth’s tally of five and the Isle of Wight’s total of three.

But within this heavy Southampton bias, there are still opportunities for Havant Borough:

Dunsbury Park, alongside the A3(M) between Bedhampton and Waterlooville, could provide secure warehousing and distribution space within easily controlled reach of the Portsmouth International Port via the M275/M27 motorways. The main beneficiary of this would be Portsmouth City Council who own both the port and the Dunsbury Park site.

The proposed development of Brockhampton West, might also provide employment for warehousing or secure storage, though since Havant Borough Council decided to sell that gilded goose recently, the only financial beneficiary would be the new owners.

Langstone Technology Park and the New Lane Employment Area, intelligently redeveloped, could also attract secure storage and high end manufacturing businesses which could benefit from the tax advantages of location within the freeport boundary and the ability to import and export through Southampton and Portsmouth ports, or Southampton airport. Existing businesses on these sites, particularly those already in the import / storage / export business like De’Longhi, will also be carefully considering the advantages of the freeport offer. Kingsbridge Estates’ expanding New Lane property portfolio will benefit from careful tenant selection while other New Lane landowners will be carefully monitoring the potential ‘freeport bonus’ their asset values should attract.

The Freeport ‘Economic Levers’

The ‘Freeport levers’ are the changes that will be made by the UK Government to streamline customs rules, tax rules and planning regulations to aid ‘regeneration’ and ‘innovation’.

The customs and tax levers are not for the faint hearted and I’m grateful to our Treasurer for pointing me to this article by BDO, a global accounting organisation, which provides a few pointers to those changes

The subject that probably comes closest to affecting us is planning, where changes to Local Development Orders and Permitted Development Rights will be made at a national level to remove restrictions and delays for associated development within the new freeport outer boundary.

In their response, the Solent Freeport team welcomes the use of Local Development Orders (LDOs) as they “establish a clear framework for development, giving certainty to applicants, businesses and communities”. However, the process for securing an LDO is often “time intensive and requires skills that many Councils do not possess” and also “require the support of a wide range of stakeholders”. The Solent LEP response suggests that the Government improve the Local Development Order process by imposing strict time limits on their delivery. To achieve this, they suggest the establishment of service level agreements between relevant local government authorities committing to a reasonable decision period for various approvals relevant for a given site. Given the large number of local authorities across the Solent freeport region, they go on to propose “the establishment of a special Virtual Planning Authority that is facilitated by a coordinating institution with the cooperation of relevant local authorities.”

The Solent LEP response also proposes extending the permitted development rights accorded to ports to include assembly and manufacturing though they believe this would still not improve the planning environment enough to act as an incentive to potential investors. While the expansion of permitted development rights would simplify development processes on seaport land, it would still not allow for the greater freedoms or coordination in higher-level planning required to ensure Freeport success.

In what might seem to some a worrying threat to environmental standards, the Solent LEP go further, suggesting that “existing environmental regulations along much of the UK coastline supersede Permitted Development Rights, further limiting their additional value as an incentive”.

If you thought that public scrutiny of planning and development is already inadequate and ineffective, it’s liable to get a lot more interesting in the future.

Don’t hold your breath though. Freeports are not a new idea in the UK. The country had a couple of them as recently as 2012 before the government abandoned them for failing to deliver the expected benefits.

Bob Comlay

Fact Checking the New Lane ‘Last mile delivery’ hub application

Let’s just try and ‘fact check’ our post on the planning submission for 32 New Lane.

Statement (Fact)Source
So who actually is it?Until the applicant comes clean and completes the documentation properly, we won’t know. All we’ve said is that based on the information given, the ‘100 sites across Europe’ listed in the documentation link to at least well known one pan-European operator. Rumours abound on social media, but we’d prefer it not to be the outfit who didn’t come off too well in Bathgate and Tilbury.
150 Jobs will be lost, no new jobs created? (Fact)The application document shows 150 existing jobs will be lost at the site, but does not include any figure for new jobs provided. The ‘relocation’ and ‘consolidation’ quotes are attributable.
Source: Application Form – Section 18
Or is that really fake news? Well, to tell the truth, nobody will know until the applicant fills in the missing information on the rather shoddily presented Application Form. Of course, any operation of the size and scale of the one that appears to be described in the documentation needs employees, or perhaps we should say ‘sweatshop labour’. We’ve discussed that a bit further here.
‘Around 2,500 truck movements a day?’ (Fact)The number quoted in the Transport Statement is 2,415 movements of Heavy Goods Vehicles and Light Goods Vehicles per day. The actual source numbers come from the ‘Occupier Traffic Data’, Appendix F, Transport Statement (Part 3)
95 % of the traffic will be heading straight out of, or straight into town through the existing traffic hotspots. (Fact)
Source: Transport Statement, Table 5.6
‘Two thirds of this traffic will be at peak times’. (Fact)We define peak times as 06:00 to 08:59, and 16:00 to 18:59. Using these time intervals, the actual percentage from their own figures is 66.1%.
Source: Appendix F, Transport Statement (Part 3)
This is not a sustainable ‘Last mile delivery’ opportunity. (Fact)Read the UK Government’s position statement on last mile logistics, and then look at the City of London’s recent approval of an Amazon, sustainable ‘last mile delivery’ hub, the scale of which is completely different to that proposed at 32 New Lane. What we have here is simply a proposal for an industrial scale warehousing and distribution operation. The 2,500 diesel powered goods vehicle movements each day from within a town centre residential population is hardly sustainable!

It is at this point where we have to hold our hands up. The next fact was going to be “29% of the traffic will be routed down New Lane towards Eastern Road”. Now we found this figure in a couple of places in the Transport Statement, imbedded in graphics of tables so don’t bother trying to search for them without looking at every page!

What is particularly interesting in this table is that it tells us, given that there are only three ways in and out of the site by road, that 70% of the traffic will be taking off vertically and flying out the site. Most impressive we thought, and then we encountered another chart on the very next page…

Life’s really too short to try and square Table 5.8 with Table 5.7, but the really important thing to take away from this is:

Property Investment Companies hunt for ‘Intended Occupiers’ then employ Developers who employ Agents to contract Specialist Agencies to produce this nonsense. In this whole perpetual game of Chinese whispers, the vast piles of documentation that lands on the overloaded Planning Officer’s desk is simply there to impress by its sheer weight.

It probably even arrived by a courier service along with a DVD containing all the soft copy.

Applying the realistic scenario development trips to the likely route choices results in vehicular trip distribution as shown…


It’s important to understand why large companies throw lots of money at consultants to write their documents for them. Take this example from the Conclusion of the Transport Statement – the only page, we’ll wager, that most officers and Councillors will ever read:

“The occupier proposes to use the site as a ‘last mile’ distribution centre, where parcels are delivered via small vans to customers in the local area. The occupier is looking to consolidate their operations on one site and this has resulted in the current proposal for the van storage deck which would house the van fleet overnight while the drivers are not out on deliveries as opposed to vans being stored in the local area on separate sites.”

Let’s just unpick that paragraph:

parcels are delivered via small vansThese will be large, long wheelbase ‘Transit’ type vehicles, capable of holding a days worth of deliveries
to customers in the local area The deliveries are to customers over the whole of Hampshire, Sussex and Surrey. Only 5% of them will be to the ‘local’ Havant Borough area.
the occupier is looking to consolidate their operations
on one site
Their business plan is to close smaller sites throughout the the three counties to get everything in one place. They will not be making their staff redundant but will be relocating them to New Lane. That’s why they want to be near the station, so some of their current workforce can get here more easily. There are no new jobs associated with this planning application.
house the van fleet overnight while the drivers are not out on deliveriesThe vans have to be onsite overnight since it’s their night shift workers that will fill them up ready for the drivers in the morning!
as opposed to vans being stored in the local area on separate sites.Sounds good? No more vans parked outside houses overnight? No. See the previous line. The vans have to be onsite overnight otherwise their business model doesn’t work.

If the Planning Officer doesn’t have the time to wade through this nonsense, and we know that the Traffic Management Team didn’t, then there’s absolutely no chance that the Councillors who make up the Planning Committee and make the decisions which dictate the future of the town, will be able to make the time either!

Reminder – there are local elections coming up.


The Pfizer site plan – 2,500 extra HGV/LGV and 3,000 extra car movements every day – the 24/7 cost to our residential streets.

Updated – 02-4-2021:
Read our media comment here
Read our ‘Fact check’ post here
Read our update on traffic numbers and jobs

When we first reported on this one, we only had part of the story. To be honest, even now, we have less than three quarters of the story given that the planning application was submitted, probably deliberately, lacking significant information. It makes it hard for the Case Officer in Planning Services and just as hard for us to make sense of it and report on it. Such applications should never really get validated and loaded to the planning portal in that state. However, developers know only too well that we have to spend hours digging through pages of turgid nonsense before we can actually identify the critical stuff that is missing.

The application to build what it calls a ‘last mile’ storage and distribution hub on the former Pfizer site in New Lane is such a proposal. It’s one that, if passed, would generate around 2,500 new daily goods vehicle movements past residential properties and schools. In order to support those deliveries, we estimate that there will be another 3,000 commuting vehicle movements generated by three shifts of sweatshop warehouse staff and a car park full of almost 900 van drivers. These 5,500 vehicle movements will continue outside normal peak hours given the three shift 24/7 operation that’s proposed.

Almost all of the goods vehicle movements and most of the commuting traffic will be heading out to the A27 and A3(M), transporting staff and delivering packages to addresses in Hampshire, Sussex and Surrey while adding an unsustainable volume to the town’s traffic problems, two thirds of it at peak times.

The unnamed occupier plans to ‘consolidate their operations’ at the site, relocating operations, we are led to assume, from other, smaller locations within the three counties. The application states there will be 150 jobs lost at New Lane but remains completely blank as to whether new jobs are being created. In reality, the applicant is leaving the vital information off, just so they can come out with a banner headline like “DHLazon will bring 1,500 jobs to Havant” right at the last minute in an attempt to hold the Council over a barrel.

We remain optimistic that the Planning Committee will take a rather broader view of the pros and cons and not give up on what New Lane ought to be.

The proposal is to demolish the existing Pfizer cold store warehouse in New Lane and replace it by a large warehouse and storage unit with an equally large three floor multi-storey ‘car park’ for up to 866 Light Goods Vehicles – long wheelbase ‘Transit’ type vans.

Inbound deliveries will arrive by 32 daily HGV movements, mostly overnight, for sorting in the warehouse before loading onto vans for doorstep delivery across the three counties at the start of the day. The first vans will leave the site around 6am with the last returning around 11pm and all in all, there will be almost two and a half thousand van movements a day, seven days a week. That is a lot of traffic coming in to and out of the site.

From the the information within the documents which accompany the application, we can deduce a few things about the scale of the operation and so to help brighten up the graphics, we’ve made up a little logo for them:

Where this all starts to get a bit barking is in the choice of the New Lane employment area as a site. Most sensible last mile storage and distribution operators like DPD work from ‘edge-of-town’ sites where they can access the main arterial road network directly.

The New Lane employment site, which sixty years ago was an edge-of-town industrial estate, is now effectively landlocked by extensive residential development. To reach the major arterial roads, any traffic from New Lane must pass through the most congested traffic pinch points in the area:

  • Park Road North
  • New Lane Level crossing
  • Bartons Road/Emsworth Common Road junction
  • Bartons Road/Petersfield Road junction
  • New Road/Bedhampton Hill/The Rusty Cutter roundabout

You can see a few of the problems illustrated in the graphic below. Not only surrounded by houses but also surrounded by those traffic hot-spots and a lot of local schools. To get out to the A27, west or east, the site traffic will simply contribute to the existing traffic hotspots that lie naturally on its route. The same applies to vans trying to head towards the A3(M) via Purbrook Way and Hulbert Road or via the B2149 to Horndean.

That’s 2,500 vehicle movements a day, all generated from within the town, all trying to get out to, and back from, the major road network that’s out there on the edge of town..

DPD will be rubbing their hands with glee. The only time they need to negotiate these hotspots will be when they actually have a doorstep delivery in Havant, that’s just 5% of their journeys. Their competitor, should they unwisely choose the New Lane site, will be stuck in Havant’s traffic for 95% of theirs! (The percentage figures come from their own application, this isn’t rocket science!)

The issue for us all is that to meet their delivery promises and to attempt to buck the traffic, the applicant proposes to route their delivery vans through the most constrained residential streets south of the site, using the New Lane level crossing if they’re heading for the A27 east, New Road if they’re heading for the A27 west, or Park Road North if they’re just feeling lucky. In any event, they’ve indicated that they’ll be ignoring the advisory HGV routing on Crossland Drive as “dictated by local demand and current traffic conditions”.

It would be absolute madness for the Council to approve this application on this particular site and we appeal to them to take a very long hard look at this. The HBC Local Plan and the HBC Regeneration Strategy both very deliberately state an intention for ‘last mile delivery’ operations to be located at the current edge-of-town sites, Dunsbury Farm, where DPD have already set up a similar operation, or the recently sold Brockhampton West for which an appropriate outline planning application currently exists – APP/21/00189.

What should you do next?

Please take the time to read some of the documents that are available. Either on the Council website or on ours.

Where to go next?

New! If you’ve never viewed the detail of a planning application before, or have never submitted a comment against an application, you might like to read our simple illustrated guide which shows you how.

You can go straight to the HBC Planning Application documents for the Pfizer site application by clicking this link.

If you don’t have the time to wade through the application and its documents, you can read a summary of the detail in just seven pages, including an analysis of how it might affect you, by taking this link.

To go straight to the the official online form for making your comments, click this link.

Responses must be in by April 6th.

Sadly, it would appear that Havant Borough Council’s “Traffic Management Team” didn’t bother to read any of the paperwork before submitting their nine word response, circled in red, below.

Is it any wonder why the traffic in the town in normal times is so bad?!


Brockhampton West – Application for Outline Planning

Having called their bluff over the possibility that they might have created another ‘Potash Terrace‘, there are signs that at least part of the HBC Regeneration Strategy might actually be getting somewhere – either by accident or by design. It appears that despite previous concerns held by residents groups and back-bench councillors alike, there actually might be a viable plan coming forward for Brockhampton West.

We’ll reserve judgement, of course, given that landowners around here have a habit of sitting on sites, sometimes for decades, maximising their profits by simply obtaining the outline planning permission which adds value to their investment. This application is just that, an application for outline planning approval. However, this one m-i-g-h-t just be different so since we’re in an upbeat mood today and looking at it in a positive light, let’s take a look at what’s proposed.

The application offers three indicative site layouts as illustrations. These show either one, two or three large three storey sheds, with HGV and car parking, which is in line with the objective for the site set out in the Opportunity Havant Regeneration Strategy. Located with direct access to the major A27/A3(M) junction, this is an application to build a site for letting to distribution / warehousing / ‘last mile’ delivery operations.

The proposed style of the structure would be difficult to reimagine, but the following elevations, which relate to the single large ‘Unit 1’ option above, give an idea of the kind of structure that we might expect in a later planning application.

The company who have acquired the land are Derbyshire-based Clowes Development Ltd. a company with a dozen ‘land development’ projects in the UK, most clustered around their home in Derbyshire and just a couple as far south as London. They’re not the first Derbyshire-based development company to look south, Bloor Homes are also active in this area though on East Hants’ land at Dell Piece East.

Clowes Development make bold claims on their website:

Each of our projects includes a commitment to its neighbouring communities to not only create a better environment but to leave an employment and skills legacy, enabling future generations to prosper. We take our responsibility to do the right thing very seriously. It’s what separates us from our peers. Very few companies can – or will – do what we do.

Our Property Development & Investment Approach | Clowes Developments – (noted!)

They’ve certainly done their homework and there’s a weighty set of documentation that appeared on the DVD that accompanied their cheque for £19,574 to HBC. You can take a look at it all here if you want to get down in the weeds of the detail. Otherwise, read on for a few highlights.

The ‘Preliminary Geo-Environmental Risk Assessment’ is a good place to start if you’re concerned about what’s beneath the surface on that former landfill site. (It’s got a lovely ‘green’ cover and since this staff writer is a sucker for beech leaves it was the obvious place to start.) Click the image to open the document.

The nine appendices are where the detail is, and there’s a lot of it if you really feel like going through it. Refer to the planning application itself and you’ll see them loaded as nine separate documents at the bottom of the list.

For those who just like looking at old maps, Appendix D – Selected Historical Maps is the one to look at and the file which includes the old Soviet military Cold War map we used in our ‘teaser’ post yesterday. Be warned, at 16Mb this appendix is no lightweight file but for map enthusiasts, you can view all 50 pages here.

It’s worth noting that some of the maps used throughout this application show the land as a ‘Playing Field’ and the response from Sport England offers a suggestion for those that consider that this application “involves the loss of any sports facility”. Other documentation includes The Design and Access Statement which is usually worth a quick look. For those looking at the green credentials of the development, the BREEAM Assessment document for the sustainability of new development can be found here.

The Consultee response from Hampshire Archaeology is a little sad. In his letter, David Hopkins, the County Archaeologist, does not object to the application but adds the historical note that “Archaeological sites were recorded when the land was stripped in preparation for land reclamation. It seems very likely that the archaeological potential of the site, which would have been high given the harbour edge location, has been removed or severely compromised.” . This raises an important point with regard to the Campdown site development, for which a new planning application is expected by Persimmon Homes. Campdown has a rich archaeological history, as well as ecological importance, and we will be taking a strong line with that application when it appears.

Clowes Development have also included a comprehensive-looking Ecology Report . In their response, we note that the RSPB as a consultee, have objected to the application on the grounds that it “fails to consider indirect impacts towards adjacent functionally-linked land to internationally designated sites and therefore is not compliant with The Conservation of Habitats and Species Regulations 2017.”

Havant Civic Society do not currently plan to object to the application given the strategic benefits already identified in the Regeneration Strategy. Once developed, or should that be if it gets developed, it will provide much needed employment in a strategic industry sector which could pull through further business opportunity. The location of this employment site should not impact town centre traffic although the loading on the Bedhampton ‘teardrop’ A27/A3(M) interchange may require fine tuning.

We note that HBC are already getting more than a little excited by the ‘opportunities’ which could be offered by last week’s announcement in the budget of the shortlisting of the ‘Solent Freeport’ bid. Cllr. Wilson, Leader of the Council, made reference to HBC’s involvement in the Solent LEP Freeport Bid in a recent Council meeting, though at the time he was citing the Dunsbury Farm employment site on the A3(M) (a site actually owned by Portsmouth City Council). The Brockhampton West site, developed along the lines of this current outline planning application, would be a good fit with the Freeport and we’ll be writing more on that in the next few days.

Some might think it’s rather a shame that Havant Borough Council decided to sell this last major land asset they possessed. With the increased focus from the Freeport ‘opportunity’ and the benefit of outline planning approval, it could be only a matter of months before Clowes simply capitalise on the investment they’ve made in all these documents. It took the original purchaser of Potash Terrace several years.

If you want to comment on this application, please take this link to be taken to the HBC ‘Comments’ page.

Last but not least, the first ‘HCS Comic Sans‘ award of 2021 goes to ‘Shirley’ at the the Health and Safety Executive (HSE). Congratulations Shirley! Yes, it’s the first time that we’ve seen an otherwise professional piece of documentation attached to a planning application using this immature and silly font this year!


Brockhamptonski Westvitch

No. The Russians haven’t landed, but the first preliminary application for Brockhampton West has.

This is probably the first time that any planning application submitted to Havant Borough Council has been supported by a Cold War era map produced by the Soviet military. To save you hunting for the story, we’ll post a more serious update about this tomorrow, but for now, just enjoy the entertainment that this map extract provides.


We kid you not, you really couldn’t make this up. If you really need to know more in a hurry, just click the map and follow the clues…

Another loss to Havant’s declining tree canopy

Stop Press! We’re delighted to see that this application has now been withdrawn, pending the definition of an appropriate replanting strategy.

After the loss of the Fairfield School horse chestnut trees, the next major loss will be the 130 ash trees which line Park Road South beside Bosmere School, all now condemned due to Ash Dieback disease. Detail from the current planning application for tree works is shown below the pictures.

Planning application – APP/21/00143 | Fell all Ash trees, approx. 130 trees, within highlighted area identified on attached plan. Within conservation area of St Faiths. 

Highlighted Area. Fell all Ash trees within highlighted area. Approx 130 trees.

Reasons for felling detailed below.

Re planting of suitable species will be undertaken to replace the felled trees.

“The majority of the Ash trees within this group are infected with Ash Dieback. It is anticipated that by summer 2021, a substantial number of these trees will be dead or in an advanced stage of infection, and within 18 months, most will be dead. With clear safety implications to the adjacent Park Road South to the west of the site and school playground to the east, felling these infected trees at the earliest opportunity is considered to be the most prudent course of action to safely manage the risk these trees present to the busy main road and school pupils.”

To comment on the planning application

Clicking on this link will take you to the ‘Comment’ form within the planning application. Comments must be received by March 12.

Please note that outright objections to this felling are unlikely to have any effect. The most constructive comments will be regarding the nature and scale of the replanting so please consider commenting along those lines. As it stands, there is no detail on the application regarding the replanting.


The sad remains of just one of those Fairfield School horse chestnuts, felled during February 2021.