Category Archives: Brownfield Sites

Brownfield sites in Hart District, Hampshire, England available for the Hart Local Plan

Hart Council censors questions about the Local Plan

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In an astonishing move reminiscent of North Korea or Stalinist Russia, Hart Council have decided to censor questions saying they “do not publish speculative views from the public” and that they will “prepare and publish guidelines on the format of questions that will be accepted”.

This arose because we asked three questions about school places, brownfield sites and whether Hart would consider an alternative approach to delivering the Local Plan.  Each question had a preamble to set the context before the short question was asked.  Hart have decided to censor the preamble part of each question so that members of the public can’t see them, although they did say they circulated the full text to councillors.

There is a saying that the flak gets heaviest when you are over the target, so I guess this means that the council are finding the questions we are asking uncomfortable.  But we are astonished by their attempt to stifle democracy and how they seek to infantilise the debate about the best approach to the Local Plan.

We think the Planning Inspector will take a dim view of this approach as NPPF Para 155 says:

“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.”

This clearly places an obligation on Hart Council to consult widely and they seem to be afraid to engage, even though they asked us to make a submission to the Hop Garden Road (Owens Farm) appeal and were pleased to receive our criticism of the Rushmoor Local Plan.

 

 

 

Hart Council in denial about the Local Plan

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Hart Council refuse to acknowledge failings in the Local Plan

Hart Council refuse to acknowledge failings in the Local Plan

Hart Council’s answers to questions put at the council meeting on 30 July reveal a staggering level denial about the status of the Local Plan.  We put some questions to council, but many more questions were put by Winchfield Action Group members.  A lot can be learned from the answers, and in some cases non-answers to the questions put.  The detailed answers can be found here and here, and are summarised below:

  • Hart Council have ruled out again the creation of a register of brownfield sites and have refused to establish a formal “brownfield” option for consideration as part of the Local Plan process.  Hart also refused to consider our proposals for an alternative approach to the Local Plan.
  • They are still working on the project plan for the Local Plan project, and can’t say when the project plan will be available for public scrutiny. Despite not having a project plan, they are hoping the new draft Local Plan will be available by the end of the year.  It is clear that the plan is in some disarray, despite the council insisting as recently as the April meeting that the project was on track.
  • The council is continuing to insist that “many” people in Hart support the new town plan, despite only around 200 people supporting that as their first preference in Hart’s consultation, and over 2,000 people signing the We Heart Hart petition opposing the new town idea.
  • Both Hart and Hampshire Councils have not done any planning for the supply and demand for school places beyond 2018.
  • Hart has no “Plan B” if the new town proposal doesn’t pass testing.
  • The council may allow a further round of consultation on the new draft Local Plan, but have not yet taken a decision on that.

Taken together this is a staggering number of failings and they appear to have no plan to bring the project back on track, even though they still insist that it is imperative the Local Plan is produced quickly.

Hart Council Responds to Rushmoor’s Local Plan

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Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Hart Council has responded to Rushmoor’s Draft Local Plan.  In summary their points are:

  • Rushmoor should look again at the SHLAA to seek out new sites and increase densities
  • Rushmoor should reconsider the scope for using surplus employment sites for housing and also releasing some surplus retail space.
  • Rushmoor should alter its housing target to better reflect its delivery trajectory so that it clarifies that the alleged unmet need comes after 2024, and then commit to a review of the plan to investigate the potential housing shortfall nearer the time.

Hart also suggests that much more dialogue is required between the councils and with the service providers to resolve infrastructure issues.

We Heart Hart broadly welcomes this feedback from Hart Council but believes they could have gone further by asking that the densities on Wellesley be reviewed and even more of the protected 96 Ha of employment land could be released for housing.  Even so, if Rushmoor takes on board Hart’s observations, then Rushmoor will not need to ask Hart to build 1,600 houses for them. This would probably mean a new town at Winchfield is not required.

 

Hart Council on collision course with new Government brownfield planning policies

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Hart Council on Collision Course with Government Brownfield Planning Policy

Hart Council on Collision Course with Government Brownfield Planning Policy

Hart District Council has written to local Parish Councils setting out its interpretation of the new Government planning policies set out in the new Productivity Plan.  However, it doesn’t seem to be following this guidance and is on a collision course with Government policy.  Their interpretation is shown below in italics, with our comments in red plain text:

“If you don’t get a Local Plan in place soon the Government will intervene and arrange that they are written for you. We pointed out months ago that the Local Plan project is well behind schedule, but Hart dismissed these concerns. Hart has recently announced it will publish a draft local plan later this year, at least six months behind their original schedule, but it appears set on ignoring our 5-point plan for change.  This additional consultation step is welcome, but it does illustrate the weaknesses in project management and governance.

To speed up the Local Plan process the Government will bring forward streamlined processes

The government will strengthen guidance to improve the operation of the duty to cooperate on key housing and planning issues, to ensure that housing and infrastructure needs are identified and planned for. Hampshire as a whole has a £1.9bn funding deficit, Rushmoor £80m and Hart £78m.  All of these figures are likely to be under-estimates because many of the numbers were compiled before the latest housing allocations were calculated.  Rushmoor has barely mentioned infrastructure in its draft plan and Hart has barely started identifying the infrastructure requirements.

The government will consider how policy can support higher density housing around key commuter hubs. The government will also consider how national policy and guidance can ensure that unneeded commercial land can be released for housing. This is in line with the arguments we have been making about building higher density developments in urban areas, yet Hart is persisting with its new town idea in defiance of government direction.  Indeed, we have used the Employment Land Review evidence to demonstrate that at the end of the plan period there’ll be 195 hectares of vacant employment land across the Housing Market Area yet neither Hart nor Rushmoor appear to be taking this seriously.

The government has already committed to legislating for statutory registers of brownfield land suitable for housing in England. The government will go further by legislating to grant automatic permission in principle on brownfield sites identified on those registers, subject to the approval of a limited number of technical details. On brownfield sites, this will give England a ‘zonal’ system, like those seen in many other countries, reducing unnecessary delay and uncertainty for brownfield development. Hart has refused to even take the first step of a ‘brownfield first’ strategy by ruling out creating a register of brownfield sites. Hart risks being lumbered with poorly designed schemes if it doesn’t take a proactive approach to brownfield sites.

The Government intends tighten the planning performance regime, so that local authorities making 50% or fewer of decisions on time are at risk of having decision making taken away from them.

It legislate to extend the performance regime to minor applications, so that local authorities processing those applications too slowly are at risk having decision making taken away from them

The Government will introduce a fast-track certificate process for establishing the principle of development for minor development proposals, and significantly tighten the ‘planning guarantee’ for minor applications

The Government will introduce a dispute resolution mechanism for section 106 agreements, to speed up negotiations and allow housing starts to proceed more quickly

The government will deliver its commitment to get 200,000 Starter Homes built by 2020, at a 20% discount for young first time buyers. The government is bringing forward proposals to help deliver this commitment, which include:

  • requiring local authorities to plan proactively for the delivery of Starter Homes. Surely, apartments in higher density developments in urban areas will give a much greater opportunity for delivering starter homes.  Yet Hart is eschewing this type of development.

  • extending the current exception site policy, and strengthening the presumption in favour of Starter Home developments, starting with unviable or underused brownfield land for retail, leisure and institutional uses (Good but will be exploited by developers to build on the edges of towns and villages)

  • enabling communities to allocate land for Starter Home developments, including through neighbourhood plans

  • bringing forward proposals to ensure every reasonably sized housing site includes a proportion of Starter Homes (

  • implementing regulations to exempt these developments from the Community Infrastructure Levy, and re-affirming through planning policy that section 106 contributions for other affordable housing, and tariff-style general infrastructure funds, will not be sought for them” We don’t agree with this aspect of Government policy in that all extra housing will create additional demands for infrastructure, so a way needs to be found of funding infrastructure.  However, even the contributions to green field development are not sufficient to cover the costs of additional infrastructure partly because 40% of developments that have to be “affordable” do not attract CIL or S106 contributions.

 

Additional response to Rushmoor Local Plan

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Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

We have made an additional submission to the Rushmoor Borough Council Local Plan consultation pointing out the absurdity of seeking to protect 96 Ha of employment land when there’s going to be a surplus of 195 Ha of employment land across the Housing Market Area of Hart District, Surrey Heath and Rushmoor Boroughs at the end of the plan period.

This is available as a download for those wishing to add their voice to the consultation.

 

Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan
Download Now!273 Downloads

 

Our first submission and reasoning can be found here and here.

Link

Questions for Hart District Council July Meeting

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Protect our green fields

Protect our green fields

There’s another Hart District Council meeting next week on 30 July.  We Heart Hart has tabled some questions about school places and brownfield sites.  This includes asking Hart to consider our 5 point plan for change.

Please feel free to use our questions as inspiration for your own.

Update: I have added two further questions:

  • It appears Hart is now proposing to publish a draft Local Plan prior to the pre-submission version.  Will publication of this draft be accompanied by a Reg 18 consultation and when will the LDS be updated to reflect this change?

HBF calls for Hart to meet Rushmoor’s unmet housing need

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Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

The Home Builders Federation (HBF) has responded to Rushmoor’s Local Plan consultation and called for Hart to concrete over its green fields to build all of Rushmoor’s unmet housing need.

Hart is the solution

To ensure that the Council is doing what it can to maximise the effectiveness of the duty to cooperate the Council must approach Hart Council to make sure that it provides land to meet the shortfall arising in Rushmoor. We note in paragraph 4.6 of Topic Paper 2: Housing Delivery that the Council asserts that the duty is not a duty to agree. This suggests a lack of zeal on the part of the Council to ensure that the unmet housing need of Rushmoor is addressed. Even if Hart and Surrey Heath are unable to provide land the three HMA authorities should engage with authorities elsewhere to persuade them to provide land to accommodate the shortfall.

It then goes on to make the silly suggestion that Hart to review its Green Belt, when in fact Hart doesn’t have any Green Belt land.

Reviewing the Green Belt in Hart

The Council must work with Hart to remove land from the Green Belt if this is what is necessary to accommodate the housing shortfall.

The HBF then call on Rushmoor to increase their housing allocation by an arbitrary 10% because the HBF believe more affordable housing should be built.

We consider that a 10% adjustment upwards should be made to the baseline demographic need.

They do not seem to consider the option of house-builders reducing their prices, nor do they mention that part of the reason house prices are so high is because interest rates have remained at 0.5% for around 6 years.

Amazingly, the HBF make no mention at all of brownfield land in their submission, despite Rushmoor seeking to protect 96 Ha of land even though there will be a surplus of around 195 Ha of employment land across the Housing Market Area at the end of the plan period.

It is simply unacceptable for an unelected industry body to seek to override the wishes of local people by asking Hart to concrete over green fields, whilst at the same time ignoring the vast opportunity presented by brownfield sites.

If you would like to make your own submission to then please download the pre-prepared feedback forms below, fill in your details and send them off to [email protected].  The consultation closes on 20 July 2015.

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!267 Downloads
Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan
Download Now!273 Downloads

 

Hart solidifies plans for a new town at Winchfield in defiance of Government preference for brownfield development

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Cows in Winchfield, Hart District, Hampshire

Cows in Winchfield under threat

In a new report to Parish Councils, Hart District Council has apparently taken the next step towards solidifying its policy of building a new town at Winchfield.  In the report Hart suggests wording of a draft policy to reflect its current thinking if its strategy survives the testing process:

The Council will work with its housing market area partners to deliver 24,413 new homes across the Hart/Rushmoor/Surrey Heath Housing Market Area over the period 2011-2032. Hart’s proportion of that number is 7,534 [these figures may be subject to change if/when the SHMA is revised].

The Council has identified and allocated sufficient land to meet its needs up until 2024/2025. Thereafter, the bulk of Hart’s housing needs will be met through the development of a new settlement centered on the area that comprises Winchfield. The vision for the new settlement will be developed through a master planning exercise and will be the subject of a separate Development Plan Document.

The Council, though it’s allocations policy, will give priority to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures (i.e. those areas that lie beyond the Thames Basins Heaths Special Protection Area zone of influence [this is a Policy required of Policy NRM6 of the South East Plan.].

To deliver its housing needs the Council will seek to maximise the potential for brownfield land development where that development is appropriate to the existing character of the area, demonstrates that there is sufficient infrastructure in place to meet the needs arising from that development, and where it does not compromises other objectives, such as protecting amenity, achieving good design, the protection of important heritage assets etc.

Elsewhere, development will be strictly controlled and new development will only allowed on green field sites where the land has been allocated for development and where it enhances the sustainability of the location, demonstrates that sufficient infrastructure is, or can be put in place, to meet the needs arising from the development, and where the form and pattern of development is integrated into, and is compatible with, its surroundings.

If through Local Plan examination, and subsequent housing delivery monitoring it is demonstrated that Hart’s housing market area partners cannot reasonably meet their respective housing needs, the Council will seek to cooperate with its partners to help meet any unmet needs. This will be done through a review of the Local Plan which will assess the potential for accelerated growth of the new settlement centered on Winchfield, or the release of strategic urban extensions at **** or *****. [Options yet to be determined]

This is clearly bad news for those of us who oppose a new town and is strange given the new report highlighting the massive costs and significant barriers to delivery of a new town and new Government guidance indicating a preference for brownfield development. But in better news, Hart says it is revising the timetable for the Local Plan, saying it is planning to publish a “fully worked up draft Plan later this summer”. Hopefully, this will give an opportunity to respond to a new consultation.

If you would like to ask the council to think again, please sign and share our petition:

 

Go to Petition

 

Government and CPRE call for more building on brownfield sites

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Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

In response to the Government’s Productivity Plan, announced today, the Campaign for the Protection of Rural England (CPRE) has called for the Government to implement a ‘brownfield first’ rule.

The Government will introduce a new zonal system which will effectively give automatic permission on suitable brownfield sites.  This was welcomed by the CPRE in their statement, but they asked the Government to go further saying:

“To achieve the development we want and need on brownfield land, the Government should implement a ‘brownfield first’ rule at the heart of planning to prioritise urban redevelopment and leave behind the unsustainable status quo – where developers cherry pick green fields for development. Communities must also be involved from the start to ensure good design, and it is desperately important that new developments include a significant amount of affordable housing.”

We Heart Hart wholeheartedly agrees with this approach, and would like to see the combined boroughs of Hart, Surrey Heath and Rushmoor implement these ideas by prioritising building on the 196 hectares of vacant employment land that will remain in the Housing Market Area at the end of the plan period.  In particular, Rushmoor is protecting 96 hectares of employment land, whilst at the same time asking Hart to build 1,600 houses on beautiful green fields.  We think this is madness and it forms one of our arguments opposing the Rushmoor Local Plan.  If you would like to put in your objection, please see our post here and please use the pre-prepared form on the link below.

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!267 Downloads

 

There are certainly plenty of brownfield sites to be considered:

  • We Heart Hart's Mascot - Bravehart
    We Heart Hart's Mascot - Bravehart

 

Why is it important for Hart residents to oppose the Rushmoor Local Plan?

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Example of Urban Sprawl

Example of Urban Sprawl

We have received some feedback questioning why Hart District residents should contribute to Rushmoor Borough Council’s consultation on its Draft Local Plan.

The main reasons are:

  1. Help fend off the extra 1,600 houses Rushmoor wants Hart to build for them and avoid urban sprawl like that shown above.
  2. Challenge the Strategic Housing Market Assessment (SHMA) that has led to the combined Hart, Surrey Heath and Rushmoor housing requirement being set so high.  If we are successful in this, then Surrey Heath and Rushmoor don’t need to foist houses on Hart and the whole need for a new town at Winchfield or anywhere else goes away
  3. Push for more of the housing requirement to be built on the 196 hectares of surplus brownfield employment land.
  4. Point out the fundamental flaw of the combined £158m infrastructure funding deficit across Rushmoor and Hart (and £1.9bn funding deficit across Hampshire) that will mean we will get all of the houses but none of the infrastructure spending we need to build the healthcare facilities, expand rail capacity, fix broken roads and build the schools we need.

Please download the pre-prepared feedback forms, fill in your details and send off to [email protected].  The consultation closes on 20 July 2015.

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!267 Downloads

 

Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan
Download Now!273 Downloads

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