Fleet and Crookham groups fail to oppose ridiculous housing target

The Scream - Hart Rushmoor and Surrey Heath SHMA

Fleet and Crookham groups fail to oppose ridiculous housing target

The responses to the draft Local Plan consultation have finally been published and it is clear that groups from Fleet and Church Crookham groups have failed to oppose the ridiculous housing target.

We have looked at the responses from the following groups and can find no mention of their objection to the housing target:

  • Face IT
  • Fleet and Church Crookham Society
  • Church Crookham Parish Council
  • Fleet Town Council

Many of these groups strongly oppose the now withdrawn Cross Farm proposal that was included as a strategic site in the draft Local Plan. Their message seems to be: go ahead and build thousands of houses we don’t need, but don’t put them in Fleet or Church Crookham.

Councillors fail to challenge the ridiculous housing target

Completely Concrete Hart CCH fail to challenge the ridiculous housing target

Community Campaign Hart CCH councillors fail to challenge the ridiculous housing target

Moreover, three Community Campaign Hart councillors have responded to the consultation without opposing the ridiculous housing target of 10,185 in the draft Local Plan:

Between them, these councillors argued for:

  • Fewer homes at the brownfield site Hartland Village (Pyestock), which would add to pressure for green field development
  • Dropping Murrell Green in favour of Winchfield East, even though the Murrell Green sites were in the area of search in the 2015 consultation (see image below)  and the Winchfield East sites fared less well in testing.
  • Removing Cross Farm from the Local Plan. This application for this site has now been withdrawn.

No wonder they are being nicknamed Completely Concrete Hart

Winchfield and Hook New Town proposal

Area of search for Winchfield new settlement opportunity

Brian Blewett of the Liberal Democrats has also responded, supporting the position of Blackwater and Hawley Town Council and Neighbourhood Plan group. Neither of these groups opposed the housing target. As far as we can tell, Hook and Crondall Parish Councils did not oppose the housing target either.

We struggle to understand the logic of this position. We can’t understand why members who purport to stand for the good of the whole of Hart support the ridiculous uplift from the SHMA total of 8,022. The Government consultation is clear, Hart’ new housing need is going to be 6.132 units. The remaining target can be met from brownfield sites alone.

Some councillors and local groups oppose the ridiculous housing target

In better news, Andrew Renshaw, member for Hartley Wintney argued for a lower overall housing target. As did the following groups:

  • Crookham Village Parish Council
  • Dogmersfield Parish Council
  • Eversley Parish Council
  • Hartley Wintney Preservation Society
  • Odiham Society
  • Rotherwick Parish Council
  • Rural Hart Association
  • Whitewater Valley Preservation Society
  • Winchfield Action Group
  • Winchfield Parish Council

Alastair Clarke, chair of the Hart District Association of Parish and Town Councils (HDAPTC), also opposed the housing target in his personal response.

It’s great that such a diverse set of groups has seen the logic of opposing the ridiculous 10,185 housing target.

Conclusion

It is time all parishes and groups within Hart united behind the opportunity that the new Government consultation brings. This will benefit the whole of Hart and help stop the needless playing off of one parish against another.

 

 

 

 

 

 

 

Local Plan Consultation responses to be published 6 November

Local Plan consultation responses are still being hidden by Hart Council

Local Plan consultation responses are still being hidden by Hart Council

The recent Local Plan consultation responses were being hidden by Hart Council. However, thanks to questions at Thursday’s Council meeting and pressure from an open Freedom of Information request, the results will now be published. Hart Council cabinet member, Graham Cockarill announced that the consultation comments will be released on 6 November 2017.

Local Plan Consultation Responses History

The consultation on the draft Local Plan completed on 9 June 2017. The pro-forma response form said:

All valid comments (electronic or written) and the name(s) of the respondent will be made publically (sic) available. Personal contact details will remain confidential.

In answer to a question made at the council meeting held on 29 June asking when the consultation comments would be made public, the answer was:

We hope to be able to publish this information in the next couple of months

One of Hart’s own Code of Corporate Governance principles calls for “Ensuring openness and comprehensive stakeholder engagement”. More than four months have now elapsed since the close of the consultation, and the consultation responses have not yet been published.

Hart’s website says:
It is our intention to publish all the responses received when we publish a Pre-Submission Local Plan for comments in Winter 2017.
 Hart Council to publish Local Plan Consultation responsesHowever, at September Cabinet, they said that the next round of consultation would not start until January 2018:
It was confirmed that the next stage on the Reg 19 consultation is expected to start in January
We have now submitted a Freedom of Information request to get these comments out in the public domain. The deadline they have set themselves for response is 16 November 2017.
Let’s see if they now stick by their commitments.

 

Gallagher propose schools under power lines

Gallagher propose schools under power lines

Gallagher propose schools under power lines

In a desperate attempt to influence the Local Plan Consultation, a ‘newsletter’ has been issued in which Gallagher propose new schools under power lines. This is a last minute attempt to try and shoehorn a new settlement at Winchfield into the draft Local Plan. Apparently, the newsletter has only been issued to residents of Fleet and Church Crookham.

We have seen the newsletter and compared the schematic to the local OS map. As far as we can tell, the high voltage power line goes directly over the school grounds. Moreover, there is a pylon directly on top of the sports pitches. Our best attempt at showing the location of the school, and powerline is shown in the graphic above. Aside from the obvious electrocution risk, overhead power lines have been linked to increased risk of childhood cancers such as leukaemia. The secondary school is also right next to the mainline railway line.

The document has been issued by Curtin & Co on behalf of Gallagher. They apparently specialise in the ‘Politics of Planning’. The contact given is David Scane, who can be reached at [email protected]. We deplore this crony corporatism. We recommend that WeHeartHart supporters email this man. We should let him know that we don’t approve of these shabby tactics and how ridiculous it is to propose schools in such an unsafe location.

Of course, no evidence has been produced in the Local Plan to show a new school is required. Even if such evidence is produced, it isn’t clear why we can’t simply allocate land for a school without the hundreds of acres for housing.

We have updated our guidance with this new information in our suggested response to the consultation that can be found on the download link below. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

CPRE slams Hart Local Plan

CPRE Murrell Green has slammed the draft Hart Local Plan

CPRE slams Hart Local Plan

The local CPRE has slammed the draft Hart Local Plan, saying it is incoherent and lacks regard for the countryside.

They say:

CPRE’s District Group for North East Hampshire are concerned that the Local Plan has no coherent strategy but is instead a series of tactics to deliver a housing and development supply without any recognition of the role of countryside and the value of the natural environment.

The rural areas seem to have been completely missed in that there is no recognition of the role or function of the countryside and rural communities in this part of the county. Hart’s Vision ignores landscape value, the value of historic or heritage assets, as well as the social and health value the countryside provides for recreation.

Employment site assessment and policies appear to be ill-considered, especially in the rural areas. There are no criteria to support the policies and this results in some sites that employ few people being designated as important for jobs yet other vibrant employment sites in the villages are allocated for housing. This is in direct conflict with the Plan’s aim to protect employment sites particularly in the rural areas.

Murrell Green, which lies close to Hartley Wintney, Winchfield and Hook, is a potential greenfield settlement for 1,800 houses and a secondary school. The site contains endangered woodland, ancient lanes and hedgerows, and lakes and ponds. The proposals show no regard for these natural features and there are concerns about water supply for the high level of proposed housing

We agree with the CPRE, and many of their ideas are incorporated in our suggested response to the draft Local Plan consultation. Please ask the council to think again  by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

Local Plan misses opportunity to regenerate urban centres

Hart Local Plan to regenerate urban centres

Hart Local Plan to regenerate urban centres

The consultation on the Draft Local Plan misses an opportunity to regenerate urban centres in Hart District.

This is contrary to Para 131 of the Plan that says “The delivery of town centre redevelopment opportunities must be a priority”. The National Planning Policy Framework (NPPF) indicates (paragraph 23) that planning policies should promote competitive town centre environments and set out policies for the management and growth of centres over the plan period.

This can be best illustrated by using Fleet as an example.

Fleet is the lowest density town of its size in the country. The chart below that there is significant scope for increasing development density in Fleet.

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

 

The retail offer in Fleet is poor, the cultural facilities (e.g. Harlington Centre) are outdated and there is no proper cinema.

Fleet Health score versus benchmarks

Fleet Health score versus benchmarks

 

However, Fleet has the highest average earnings per person of comparative towns by quite a large margin (eg 9% more than Camberley). High earnings should give Fleet a significant advantage over the comparison towns.

 

Fleet earnings versus competitors

Fleet earnings versus competitors

The Local Plan Vision and Objectives fail to take advantage of the opportunity to modernise Hart’s urban centres while at the same time protecting Hart’s countryside.

We believe that the Vision for the Local Plan should be centered on the proposition that Fleet and other urban centres will be re-generated. With Hart District Council’s full and active support, a plan based on urban regeneration would achieve the following benefits:

  1. An ambitious Hart Urban Re-generation Project (HURP) would attract private investment and thus be affordable
  2. Private investment would allow for Hart’s infrastructure to be upgraded in line with the urban re-generation
  3. Good urban design principles would achieve a higher population density in the urban centres while at the same time providing an improved ‘sense of place’ and making the urban centres more desirable places to live.

A similar approach could be adopted in Yateley to provide a proper retail-led centre and improvements could be made to Blackwater. The requirement for additional retail facilities in Hook, identified in the Local Plan could also be met.

Apparently, Hart did have a plan to conduct a brownfield study to evaluate the ‘art of the possible’ in our urban centres. This project has not delivered.

 

In addition, Yateley lacks a defined centre, Blackwater is indistinct and Hook lacks good quality restaurants and shopping facilities.

The council should be setting out a bold plan to improve the retail, cultural and recreational amenities in the district. We should also develop plans for a theatre and cinema in Fleet as part of an attractive mixed-use redevelopment. There will be significant cash available from developers to fund such an ambitious plan.

Moreover, the council should work collaboratively with developers to regenerate other urban areas such as Blackwater and redevelop the centres of Yateley and Hook.

Please ask the council to think again  by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

Challenge the ridiculous housing target in the Local Plan Consultation

Challenge the ridiculous housing target

Challenge the ridiculous housing target in the Local Plan consultation

The main objection to the draft Local Plan is the ridiculous housing target. We believe the Strategic Housing Market Assessment target of 8,022 is too high. Despite that, Hart have added more than 2,000 houses to this target and plans to build 10,185 houses.

This puts massive pressure on the district and puts many greenfield sites such as Murrell Green, Winchfield, Grove Farm (Netherhouse Copse), and Pale Lane (Elvetham Chase) at risk. Moreover, this rate of housebuilding will be carried forward in future planning periods, making it inevitable we end up with unattractive urban sprawl.

We believe the housing target should be a more reasonable 5,144 which will meet the changes driven by demographic change, immigration and deliver social housing for those who cannot afford to rent or buy their own home. The remaining housing target can be met from brownfield sites alone.

The detail of our analysis is shown below. Please object to this ridiculous housing target by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

There are several lines of argument:

  • Vastly Over-achieves against Government housing policy
  • Strategic Housing Market Assessment target of 8,022 is too high
  • Hart’s decision to increase the target by 2,000 dwellings to the target is inappropriate

Vastly over-achieves against Government housing policy

The 2012-based government projections of population and number of households, points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-170,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

It is worth noting that the DCLG forecasts project forwards the recent high level of inward migration to the UK. Government policy and the impact of Brexit is likely to reduce inward migration so, it is likely the 2014-based projections are too high. Moreover, the DCLG forecasts also assume a reduction in average household size.

The 2016 Strategic Housing Market Assessment (SHMA) has arrived at a ‘need’ of some 8,022 new dwellings over the plan period.

For Hart, the raw 2014-based DCLG forecasts, as opposed to the 2012-based forecasts used in the SHMA,  would result in a starting point for housing need of c. 4,473 new houses (see Figure 6 of the SHMA).  Hart’s overall housing requirement as defined in the SHMA is some 79% above the starting point. The ridiculous housing target of 10,185 used in the Local Plan is some 127% above this basic requirement.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.

There might be some justification if this process had resulted in more house building. But it is clear from a recent House of Lords report that it has not:

Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over 240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.

We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding.

This is borne out by local experience, where, as of 1 April 2016 there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

The unintended consequence of this policy is effectively state-sponsored profiteering on behalf of the major housebuilders. It is plainly ridiculous that the housing target in Hart’s SHMA and the SHMAs of neighbouring areas are massively above the requirement suggested by demographic change, immigration and changes to household size.  Accordingly, the housing target and the Local Plan should be adjusted downwards to more realistic levels.

Strategic Housing Market Assessment results in a ridiculous housing target

Following on from the above, we can now analyse the reasons why the SHMA has arrived at a ridiculous housing target that is too high. We can also arrive at a more realistic figure.

Inappropriate Starting Point

First, the starting point used is the 2012-based DCLG forecasts, or around 5,334 dwellings over the plan period. The starting point should be revised downwards by using the more up to date 2014-based forecasts which would result in a starting point of 4,473 dwellings.

The SHMA then uplifts the starting point in response to market signals to provide more housing for what are termed suppressed households. These are, for instance younger people in the 25-34 age bracket who are still living with their parents and are unable to afford to form their own household. Almost by definition these people cannot afford to rent their own accommodation or buy their own house. The SHMA suggests a 15% uplift on the start-point. Even though some element of household size reduction is included in the DCLG forecasts. We would agree with this and increase the need by 671 units to arrive at a total housing need of 5,144. However, we would insist that these units are delivered as social rented housing. The proposed Hart Development Corporation could be an appropriate vehicle to deliver these homes, or partnerships with local Housing Associations.

Affordable Housing Uplift

The SHMA then makes a further upward adjustment for affordable housing. This is to help those able to afford to rent, but not able to access home ownership. By definition, these people are already housed. It is therefore difficult to see how building more houses will assist these people. If they can afford to rent, then it is very likely that they can afford to service a mortgage, but cannot afford a deposit. The way to help these people is with shared ownership or ‘Help to Buy’ schemes. It is also worth noting that some of these people may be taking an entirely rational decision to rent and not buy because they think property prices are too high and thus represent a poor investment when assessing potential future returns.

The only plausible reason to build more houses to help these people would be that it would lead to a general fall in house prices. This is a false premise as discussed by Ian Mulheirn of Oxford Economics here.

The extent that we do see high house prices as a policy priority in and of themselves (e.g. for wealth distributional reasons), this is not a problem that will be solved by any plausible amount of new supply. Many econometric studies in the UK (see page 43 here for a comparison of results) have concluded that a 1 percent increase in the housing stock per household will only cut prices by at most 2 percent. Consequently, even if we were to add 300k new houses per year (about 150k in excess of household formation, approaching 0.5 percent of current stock), this would only lower prices by about 1 percent per year. This is peanuts in the context of price rises over the past 20 years….

Building many more houses that people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.

Therefore, the affordable housing need should be seen as the proportion of overall housing need that should be built as ‘affordable’ units. The SHMA adds 504 extra affordable units to the total housing requirement. However, this 504 units represents only 11.2% of the 4,473 raw housing need. Hart’s target is to build 40% affordable housing and recent delivery has averaged just over 20%. If this were to continue and the housing target were revised to start at 4,473, then around 900 affordable homes would be delivered in addition to the 671 social rented units identified above.

Jobs Growth Adjustment

Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area, a shortfall of 15-30,000, or almost all the projected job growth.

Second, the projection of 1,200 jobs per annum is far more than the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, the SHMA uses a very circular argument to account for the number of jobs. The argument is: the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs.

They then decide we will need to import some extra people and those people will need houses. The SHMA then acknowledges that most of these people will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.

Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Clearly, this uplift is not an expression of the ‘need’ for the district, nor is it ‘sustainable development’. The SHMA itself recognises that most of these additional people will, in fact, work outside the district. This is against the sustainability principles of the NPPF.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs, that someone thinks might be possible to create in Hart. Then those people will add to the strain on Hart’s infrastructure (roads, schools, healthcare), but work outside the district. This is not ‘sustainable development’ on any reasonable interpretation of the phrase. Moreover, those exporting districts should already be planning to house those people.

Accordingly, there should be no jobs growth uplift in the SHMA.

This leaves us with a housing need for Hart of 5,144 made up of 3,573 open market units, 671 social rented units and 900 affordable homes made available through ‘Help-to-Buy’ or shared ownership.

Hart’s decision to increase the target by 2,000 dwellings results in a ridiculous housing target

It follows from this that Hart’s decision to add a further 2,000 units to the SHMA to establish an alleged ‘policy on’ ridiculous housing target of 10,185 is both specious and unnecessary:

  • The needs of both suppressed households and those who can rent, but can’t buy are already met by the revised housing target identified above
  • The addition of a further 2,000 homes would simply import even more people into Hart, most of whom would work outside the district, again contrary to the sustainability principles of the NPPF.
  • There is no evidence that this level of development would lead to falling house prices. Indeed, with residential land priced £4.1m per hectare (SHMA section 9.12) and a density of 30 dph, land prices alone would amount to £133,000 per dwelling. Build costs, S106 contributions and developer profits would see average house prices around £400,000.
  • It is not at all clear why we must build 2,163 extra houses to meet an alleged additional affordable housing need of 865
  • Rushmoor has already said it can meet its share of the over-inflated housing target. Reducing the overall SHMA targets for the whole Housing Market Area (HMA) will release pressure on both Surrey Heath and Rushmoor, such that ‘additional flexibility’ is not required
  • We are currently living in the most benign conditions for housebuilding in living memory. We are experiencing low absolute interest rates and negative real interest rates. The markets are awash with excess capital thanks to Quantitative Easing and the planning regime is very favourable to developers. As the House of Lords report referred to above indicates, planning permission is being granted at a much faster rate than new homes are being built. The only conclusion one can draw from this is that the market cannot absorb many more houses than are being built without a major fall in house prices. The house builders will not build faster as it will damage their profitability. Simply granting permission for more housing through blighting more of our green fields will not impact house prices nor will it lead to more houses being built.

It would be appropriate for the Inspector to express an opinion on the ridiculous housing target in the SHMA and the extra 2,000+ houses. Hart should set out a ranking of sites it wishes to take forward, such that the spatial strategy can be easily adjusted depending upon the final housing target that is agreed.

Draft Local Plan has no infrastructure plans or costings

 

Hart Local Plan contains no infrastructure plans or costings

Local Plan contains no infrastructure plans or costings

The draft Local Plan contains no infrastructure plans or costings. We think this is a massive error by the council that makes the draft Local Plan unsound.

If you agree, please download from the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

Here is our analysis of the infrastructure weaknesses in the Local Plan

Local Plan contains no infrastructure plans

Paragraphs 7, 17 and 177 of the NPPF/NPPG make clear that infrastructure should be planned alongside housing. Para 395 of the draft Local Plan says there’s a Draft Infrastructure Delivery Plan (IDP) available for viewing alongside the Local Plan. However, no IDP has been made available.

Given that back in 2013, a £78m infrastructure funding deficit was identified, this is a critical omission. In particular, we think Hart Council should focus on:

  1. The requirement for a new secondary school. The Murrell Green proposal includes a site for a new school, albeit on top of a high-pressure gas main. However, no evidence has been presented to demonstrate a new secondary school is required. WeHeart Hart research shows that a new secondary school may not be required, and the sustainability assessment for Murrell Green mentions a 9% surplus of places.
  2. Railways. SW Trains have indicated that the mainline rail route to London is 20% over-crowded at present and is forecast to be 60% overcrowded by 2043. Para 58 of the Local Plan makes no mention of this, and there is no apparent plan to improve capacity.
  3. Our roads are becoming increasingly congested and generally in a poor state of repair. There is no sign that the council has carried out an overall road transport assessment to establish the level of investment required to improve our roads so they can cope with the scale of development that is being proposed
  4. Paras 65 & 66 make no mention of groundwater and surface water flood risk in Winchfield, which was identified in the Sustainability Assessment
  5. Para 68 provides no plan to fix the acknowledged wastewater capacity issues
  6. None of the plans for the strategic sites include proper plans for sports and community facilities such as allotments.

Local Plan contains no cost analysis for infrastructure requirements

Neither the Local Plan nor the Sustainability Assessment contain a financial assessment of the alternative means of providing the housing need. We think this is a very significant omission.

We already have a £78m infrastructure deficit, so this is a critical issue. The financial analysis should include:

  1. An assessment of the major infrastructure requirements generated by each of the approaches you have considered. These include new roads; road improvements such as roundabouts; railway station and parking improvement; railway line capacity improvements; schools; healthcare; fixed and mobile telecommunications, flood prevention, wastewater disposal and social infrastructure. A high level cost of each item should be provided.
  2. An analysis of the likely contribution that could be expected from developers and other providers to meet these requirements.
  3. An estimate of the likely contributions from Government such as New Homes bonus and grants to support brownfield development.
  4. A calculation of the gap between the requirement and the contributions for each development scenario

Residents should then be able to see the financial impact of the proposals and make decisions based on that.

Local Plan: Brownfield sites protected from redevelopment

Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Council protecting from redevelopment.

Brownfield sites protected from redevelopment

The draft Local Plan put forward by Hart Council includes proposals to make brownfield sites protected from redevelopment. We think this proposal is bonkers and should be challenged in the consultation.

There are two different types of protection proposed in the Local Plan. The first identifies “Strategic Employment Areas”:

  • Bartley Wood, Hook
  • Bartley Point, Hook
  • Cody Park, Farnborough
  • Meadows Business Park, Blackwater
  • Osborne Way, Hook
  • Waterfront Business Park, Fleet

These sites are “given the highest protection and safeguarding against loss to non-B-class employment uses by protecting them for B-class uses”. We would agree that some of these sites should be given some protection. But some of the sites, particularly in Hook suffer from high vacancy rates. Indeed, some of the sites have already been converted to domestic use.  Recently the owners of the Virgin Media offices at Bartley Wood have sought advice on whether planning permission would be required to convert some of those buildings to housing. This demonstrates that there is little demand for offices on even the sites of alleged ‘strategic’ importance.

The trouble with this policy is that it cannot stop conversion of offices to apartments. These types of development require no planing permission. Nor do they bring any S106 or CIL contributions to infrastructure. Moreover, they don’t provide an attractive sense of place. By preventing proper redevelopment Hart is cutting off vital infrastructure funding. This makes no sense whatsoever.

The second type of protection is to “Locally Important Employment Areas”:

  • Ancells Business Park, Fleet
  • Blackbushe Business Park
  • Eversley Haulage Yard
  • Eversley Storage
  • Finn’s Business Park, Crondall
  • Fleet Business Park, Church Crookham
  • Grove Farm Barn, Crookham Village
  • Lodge Farm, North Warnborough
  • Murrell Green Business Park
  • Potters Industrial Park, Church Crookham
  • Rawlings Depot, Hook
  • Redfields Business Park, Church Crookham
  • Optrex Business Park, Rotherwick

These sites are offered a lower level of protection, but nevertheless the council is putting in place barriers to redevelopment.

Poor brownfield sites should not be protected from redevelopment

The reason this is a bad policy is that the Local Plan itself, as well as the Employment Land Review (ELR), acknowledges that there is an over-supply of low grade office space (para 125). The ELR states that investment in this stock is unviable (para 6.17):

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Owners of these sites have three choices. First they can keep the wasting asset and collect no rent, which is not an attractive commercial proposition. Second, they can convert the offices into flats. By and large, they need no planning permission for this. However, these types of development carry no obligation for S106 or CIL payments to councils. Nor do they deliver a good ‘sense of place’. Finally, they could apply for planning permission to properly redevelop these sites into attractive homes, with a particular focus on affordable homes for the young. These types of development will be high-density, but with a good sense of place, and will attract some funding for infrastructure.

The consequences of this policy will be to discourage redevelopment of sites and either lead to more sites being simply converted or worse, sitting idle as eyesores.

We believe this policy should be reversed, particularly as it is a direct contravention of a statement made by the council leader, who said there were no plans to restrict the development of brownfield sites at a council meeting in September 2016:

https://www.hart.gov.uk/sites/default/files/4_The_Council/Council_meetings/M_Archive/16%2009%20Council.pdf )

Please respond to the Local Plan Consultation

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

FOI request reveals Winchfield failed testing

Flood Taplins Farm Lane 28 March 2016 shows why Winchfield failed testing

Flood risk means Winchfield failed testing

The documents that reveal why Winchfield failed testing have been revealed by persistent efforts from Winchfield Action Group. A Freedom of Information request has revealed the results of a new testing document. The full document can be downloaded on the link below.

In summary, the main issues were impact on:

  1. Historic Environment
  2. Bio-diversity
  3. Landscape
  4. Water Quality
  5. Flood risk

However, in our opinion, the impact of flood risk was massively downplayed in the report. More detail is given in the analysis below. Moreover, some of the alleged positives in the report are also complete nonsense.

For instance, they claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is expanded upon in the Sustainability Assessment – they mean building a wood-burning power station utilising locally sourced timber (p74). Such a plant would be extremely undesirable since burning wood produces more CO2 than burning coal, and none of the proposed master plans include such space for such a plant.

They also claim that building 3,000 new houses, with associated traffic will somehow “reduce the
emissions of greenhouse gases and manage the impacts of climate change”. Again, complete and utter nonsense. They completely ignore research that shows higher density development in urban areas is much more sustainable than green field development.

This leaves the Local Plan in something of a pickle. Their preferred green field site of Murrell Green has been severely impaired by the presence of a Major Accident Hazard pipeline and their obvious second choice is not viable.

This puts at risk the other green field sites in the district, namely Pale Lane (Elvetham Chase) and Netherhouse Copse (Grove Farm). At the same time, Hart Council is seeking to protect our brownfield sites from redevelopment. These problems arise because they are proposing a ridiculous housing target of over 10,000 dwellings.

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation

Detail of how Winchfield failed testing

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

First, they say there was some evidence of wet ground at the far east of SHL183, but “no other obvious evidence of current or past flooding”.

Winchfield Strategic Assessment - Flood Risk 1

This is of course complete nonsense. The detailed assessment also says there’s only a one in 30 year chance of surface water flooding. The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone. The image at the top of this post documents just one of those events. The posts documenting the flood events can be found here (4 Jan) , here (7 Jan), here (9 March on Station Road) and here (28 March due to #StormKatie).

They seem to gloss over the flood risk being over 55 on a 74 point scale for five of the eight SHLAA sites they consider.

Winchfield Strategic Assessment - Flood Risk 2

Winchfield Strategic Assessment - Flood Risk 3

Winchfield Strategic Assessment - Flood Risk 4

Winchfield fails testing – Strategic Assessment
Winchfield fails testing – Strategic Assessment

Hart Draft Local Plan Consultation – Our Response

We Heart Hart Campaign Logo

We have been working hard to produce our response to the Hart Draft Local Plan Consultation. It has taken hours of work to go through the Local Plan document and the associated evidence base. And still more work to formulate what we think is a sensible response.

This is our last chance to shape our district for decades to come. So please do take the trouble to engage and respond.

A great deal of work has gone into the draft Local Plan, but there is much to comment upon and challenge. We have framed our response around several themes:

  1. The outrageous 10,185 housing target, 2,000 houses over the over-inflated 8,022 target outlined in the Strategic Housing Market Assessment.
  2. It is simply wrong to protect our derelict vacant offices from redevelopment
  3. The missed opportunity to regenerate our urban areas, most notably Fleet
  4. The lack of an infrastructure plan
  5. The absence of any financial analysis of the alternative ways of meeting our housing needs
  6. The unnecessary allocation of green field sites to the plan, in particular Murrell Green
  7. Challenge the sustainability assessment that ranks Winchfield as the next best green field option.

Over the coming days and weeks, we will be adding further detail to our comments. But for now, we have produced a summary version of our response. This is available for download below. Please do download it and review it. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

The document we have provided is in the Council’s ‘Word’ format, ready for you to add your personal details on the first pages, edit the comments provided and add your demographic details in the last pages.

 

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation