Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure
This is the fifth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart haven’t properly planned for infrastructure. In addition, the plans they do have will starve the places that really need it of investment. Policy I1 needs to be changed and policy SS3 needs to be removed. The process for making a submission is as follows:
- Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
- From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
- Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
- Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
- Once you have filled in Part A and Part B, please email them to [email protected] or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE.
How the Hart Local Plan Regulation 19 consultation needs to be changed to deal with infrastructure
One leading councillor has gone on the record, calling for an ‘infrastructure led’ Local Plan. Yet, they have not allowed questions to be put to them about infrastructure, let alone answer them.
Back in October 2014, Hart Council produced an infrastructure delivery schedule that set out the current deficit, split by type and area. This shows a deficit of £78m not including healthcare facilities. The breakdown is shown by type and area in the images below:
Hart District Estimated Infrastructure costs by type March 2013.
The breakdown of the costs by area showed the Fleet/Church Crookham and Hook areas had by far the largest deficits.
Hart District Estimated Infrastructure costs by area March 2013
Key quotes from the document include:
“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”
“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”
“The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”
It should be noted also that SWR has recently put forward proposals to reduce services at Winchfield and Hook, exacerbating the rail capacity problem. The Local Plan doesn’t even mention improvements to the rail network in infrastructure policies.
A more recent estimate from Hampshire County Council has estimated the infrastructure funding gap for Hart as £72m.
Hart infrastructure funding gap £72m
Hart’s share of the gap is made up of:
- Transport, £34m
- Education: £38m.
- Countryside: To be Determined.
- Extra Care places: To be Determined.
No estimate has been made of the requirements or costs of additional healthcare provision.
The infrastructure policies in the Local Plan are insipid and fail to address the funding gap:
- Policy I1: Infrastructure – weak policy simply requiring developers to deliver adequate infrastructure as part of their developments, when the studies above show that developer contributions won’t be adequate to bridge the gap
- Policy I2: Green Infrastructure – feeble policy to supposedly protect green infrastructure. Yet they are proposing to build a new town that will destroy the best of our green infrastructure
- Policy I3: Transport – inadequate policy simply to provide ‘maximum flexibility in the choice of travel modes’, nothing specific to improve road network or put pressure on SWR to improve rail
- Policy I4: Open space, sport and recreation – policy to support development that improves sporting facilities, but no tangible plans for anything new
- Policy I5: Community Facilities – a very vague policy to improve childcare facilities, healthcare, police stations, youth provision, libraries, community halls, local shops, meeting places, cultural buildings, public houses, places of worship, and public toilets. But crucially, no specific projects or proposals.
Yet, the National Planning Policy Framework (NPPF) is clear that infrastructure must be planned alongside new housing. Failure to adequately plan for infrastructure requirements and costs could lead to the Local Plan being found unsound. See references to paras 17 and 177 of the NPPF below.
It is clear from this post, that the proposals to build a new town will probably exacerbate the existing funding gap and not deliver any infrastructure in Fleet, Church Crookham and Hook, the very places where funding is most required.
Remedy: We therefore think the remedy to this issue should be that policy SS3 is removed in its entirety (with consequent changes to policy SS1 already outlined elsewhere). The infrastructure policies should be reworked to include as a minimum:
- Acknowledgement of the existing £72m infrastructure funding gap
- Quantification of the items missing from the Hampshire County Council assessment such as healthcare, extra-care housing for the elderly and green infrastructure
- A set of prioritised, costed projects that are required to alleviate the worst of our infrastructure problems in Fleet/Church Crookham and Hook. This should include road improvements, particularly near Fleet station and the bridge over the railway near the end of Elvetham Heath Road. It should also include significant improvements to the cultural facilities, particularly in Fleet.
- Plans to tackle Network Rail/SWR over rail capacity and services
- Proposals for raising the necessary funds for delivering the required projects
- Some external validation that the infrastructure plans in the draft Local Plan are ‘sound’ and will pass inspection
We believe that in preparation for the next review of the plan, a new policy should be created to regenerate our urban centres including attracting private capital so that we create a better place to live and address the existing infrastructure problems before even considering a new town that will only make matters worse.
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