Hart Council still has no idea

Hart District Council (HDC) still has no idea

Hart Council still has no idea.

Sometimes, truth is stranger than fiction.  And sometimes people who are normally quite sensible and rational as individuals can become delusional and irrational as part of a group, in a phenomenon known as “Groupthink”.

Please bear this in mind as you read about Hart’s plans to embark on a new consultation about the Local Plan.

The Local Elections are to be held on 5 May 2016.  Prior to that, there’s a six week period of ‘purdah’ where the council can make no significant announcements nor take any significant decisions.  This year, purdah starts on 24 March.

The Overview and Scrutiny Committee is examining what went wrong with the abandoned consultation, but won’t report until the end of February at the earliest.

I have been told by someone who spoke to Stephen Parker as Cabinet last night, that the revised Housing Need from the new SHMA is due in late February, with perhaps some highlights being released earlier. Of course, our expectation is that Hart’s (and Rushmoor’s and Surrey Heath’s) housing requirement will be significantly reduced.

However, the Council now plan to start the consultation again, either on 29 January, or a week later and run it for six weeks, taking us to either 11 March or 18 March.  Not only that, they plan to ask those who submitted responses if they want to carry forward their responses to this new consultation, even though the evidence base is going to change mid-way through the consultation. Surely this would be highly irregular.

We think it will take at least two weeks for the results of the consultation to be properly analysed, meaning that they will not be available until after purdah has started, and so will not be able to be released until 6 May at the earliest.

Surely, it would be better for the council to wait until the new housing target is released and they have learned the lessons from the last shambolic consultation before starting the new one.  Interestingly, they could do that, and still be able to publish the results at exactly the same time as if they started the consultation next week, as the graphic below demonstrates.

Hart District Council (HDC) Local Plan Consultation Time Lines

Local Plan Consultation Time Lines

Q. What do you call a blind deer?  A. No idea

Q. What do you call a blind deer with no legs? A. Still no idea.

We suggest that readers who are concerned about this, write to their councillors and see if you can get them to see sense.

7 reasons to oppose a new town in Hart

Which would you rather preserve - derelict eyesore or our wildlife?

Which would you rather preserve – derelict eyesore or our wildlife?

As the consultation on the Hart District Local Plan draws to a close, it is worth reiterating the main reasons why you should oppose a new town and urban extensions in Hart.

  1. They would open us up to 3,000 extra houses from Surrey Heath and Rushmoor, and we would get the worst of all worlds, a new town, urban extensions and green field dispersal.
  2. The rate of building would then be used against us in the next planning period, so the problems we create today would be compounded into the future.
  3. It would be bad strategy to commit to a new town now, when we know that the housing needs assessment is being revised, and in all likelihood it will be revise down
  4. The proposed new town location is simply not suitable, in that there isn’t enough land to create the nirvana of a self contained new settlement promised by some HDC councillors, and would lead to a giant Hartley Winchook conurbation.
  5. The infrastructure costs are astronomical, and the developer contributions will not meet these costs, thus pushing up council taxes in the future
  6. There is an alternative brownfield solution that will meet the actual needs of Hart residents through providing specialist accommodation for the elderly and affordable starter homes for the young people struggling to get on the housing ladder.
  7. Brownfield development is a more sustainable, greener alternative that will be kinder to the environment and provide infrastructure funding for our existing communities.

If you would like to ask Hart to abandon the new town alternative and create a brownfield solution to our housing needs, we urge you to respond to the Hart District Council consultation about the Local Plan and ask them to think again. We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

 

Hartley Wintney residents turn out to oppose Winchfield new town

Hartley Wintney residents turn out to oppose WInchfield new town

Hartley Wintney residents turn out to oppose Winchfield new town

About 150 concerned Hartley Wintney residents came out to hear about Hart Council’s Local Plan consultation this morning at Victoria Hall.  It was very pleasing to see such a large number of people opposing the plans for a new town at Winchfield.

We Heart Hart is very grateful to Hartley Wintney Parish Council for organising the event, and for letting us speak. We had many messages of support and encouragement, before. during and after the meeting.  We only ask that these messages of support are converted into actual votes in the consultation.

We reiterated our main points that:

Hart is being asked to build too many houses. Hart councillors should be thorough in their analysis of the revised Strategic Housing Market Assessment (SHMA), and be robust in challenging the housing numbers and in asking Rushmoor and Surrey Heath to meet their own needs.

Second, there is a brownfield solution to our housing needs, even if we accept the current housing numbers.  We showed how a combination of the brownfield SHLAA sites and the disused offices identified by Stonegate, can be used to meet our remaining housing need in full.

Third, there is a lot of misinformation being spread about the supposed infrastructure benefits of a new town.  We currently have a £78m infrastructure funding deficit which a new town will do nothing to address, and of course, Hart Council have not been able to explain how they will fund the £300m costs of a new town.

Finally, a new town won’t meet the needs of the elderly and won’t deliver starter homes for the young.

Councillor Steve Forster did turn up to speak as well, but was politely asked to sit down again after alienating most of the people in the room.  Some interesting insight and support for We Heart Hart ideas was also given by COunty Councillor David Simpson and district councillor Andrew Renshaw.  Tristram Cary of Winchfield Action Group also spoke, setting out four key reasons to oppose the new town, in line with our thinking.

If you would like to join these Hartley Wintney residents in objecting to the new town idea, we urge you to respond to the Hart District Council consultation about the Local Plan and ask them to think again. We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

 

Letter to the Telegraph – conurbation from London to the south coast

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

It seems the Telegraph has picked up on the amount of houses we need to build in Hart, and has published a letter from a Mr Andrew Robinson of Hart District.  The letter and other similar letters from other parts of the country can be found here.

Mr Robinson’s letter reproduced below:

SIR – I see that Hart, in Hampshire, where I happen to live, has come top once again in an annual survey of the best place to live in Britain.

However, its reign will soon end, as the local council is about to plonk 7,500 houses – or more if we are forced to accept a proportion of neighbouring areas’ allocation – in the district over the next 15 years.

The council is simply carrying out the Government’s orders, which go against David Cameron’s pledges on localism and sustainable development.

We in Hart have had over 35 years of urbanisation without infrastructure, mostly imposed via sham public inquiries. Housing and population have grown by around 11 per cent every 10 years, with an additional increase of up to 37 per cent predicted by 2030, by which time Hart’s roads will be almost permanently gridlocked.

This is a small district and these housing impositions should be tailing off by now. Instead we have a Government committed to infinite expansion in a finite land mass. We are going to end up with a Conservative conurbation stretching from London to the south coast.

 

Well said Mr. Robinson.

We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided.  It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

How developers have gained a stranglehold over Local Plans

The new age of crony capitalism

The new age of crony capitalism has gained a hold over our planning system

The latest 2012-based government projections of population and the number of households points to a need of around 215,000 dwellings per annum, compared to recent delivery of around 150,000 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.

However, there is increasing evidence that housebuilders have too strong an influence over the process that is leading to housing market assessments being artificially inflated to a level much higher than that required by the national household projections.

By way of example, in Hart, the only consultees outside of the council in the work to produce the Strategic Housing Market Assessment (SHMA) were housebuilders, their representatives and registered providers. The resulting objectively assessed “need” was nearly 50% above the starting point identified by the DCLG’s 2011-based population projections. A series of adjustments were made to the raw forecasts to take account of inward migration to the area, average household size and a near doubling of the historic job creation rate. Many of these adjustments have been shown to be erroneous by the release of the DCLG 2012-based population forecasts that are much lower than those identified in the needs assessment.

The experience of the Hart, Surrey Heath and Rushmoor SHMA is by no means unique. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the baseline population projections of around 42%.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 305,000 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”. An FOI request has been made to the DCLG to provide the national figures, but this has been refused on the grounds that DCLG “does not hold this information”. Given the importance that is being placed on housing delivery, it is quite staggering that central Government is not monitoring the results of housing needs assessments on a national basis.

As a group of local residents, we looked at the housing needs assessment for Hart and came to the conclusion that many of adjustments and the resulting “need” were inappropriate and challenged the Council. But, as we were lay people and not planning “experts” our views fell on deaf ears. So, we decided to seek the opinion of professional planning consultants to provide an independent challenge to the objectively assessed need. Our experience indicates that many planning consultants are reluctant to get involved in challenging these assessments because they get most of their work from developers and do not wish to bite the hand that feeds them. We approached a number of planning consultants and they either did not reply to us, were conflicted or said they normally act for developers and would be unable to help. Eventually, we found Alan Wenban-Smith.

Once a Local Plan gets to the stage of being examined by the Planning Inspector, the situation gets worse. Because housing needs assessments are usually produced for a combination of planning authorities but Local Plans are examined at the planning authority level, the actual housing need numbers are effectively unchallengeable. The examination focuses on the process for arriving at the housing need and the actual content is immune from challenge. Residents and environmental interests are being crowded out of inspections by the expensive hordes of lawyers, agents and consultants hired by builders and landowners who share an interest in a narrow discussion focused on achieving the maximum possible increase in estimated housing needs.

In effect, the whole process of assessing housing need through to inspecting the resulting Local Plans has been hijacked by the development industry and their narrow interests. This is in direct contravention of the NPPF which states that local people should be empowered to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of their area.

The consequence of this is that local planning authorities are being bounced into allocating green field sites for development because they are easier to develop than brownfield sites. This will result in an over-supply of land and lead to land-banking by the developers, who will only build at a rate consistent with maximising their profits. If they supplied new housing at a rate that meant house prices fell, they would immediately reduce output because their business model and in particular the price they pay for land is predicated on steadily increasing house prices. So, in effect we are being asked to allocate too much of our most valuable green field land for housing, but will not actually increase the supply of housing to meet the needs of our neighbourhoods and we leave acres of vacant and derelict brownfield sites.

We need to take action now to remove the stranglehold of developers have on this process, put more power back in the hands of local people and take further measures to mandate the development of brownfield sites and protect our countryside. This might involve increasing the powers of local authorities to compulsorily purchase derelict sites and use the profits to invest in our creaking infrastructure.

We must stiffen the resolve of our local representatives to resist the self-interest of developers and work instead for their electorate.  We must also stand up and fight for brownfield only development to protect our countryside from urbanisation. We must vote against a new town.

We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided.  It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Impact of a new town on Fleet and Church Crookham

Fleet and Church Crookham

Impact of new town on Fleet and Church Crookham

I have a great deal of sympathy for residents of Fleet and Church Crookham who have suffered a great deal of development in recent years with insufficient investment in infrastructure.  However, a new town in Winchfield, Hook and Hartley Wintney parishes is not the panacea for Fleet residents that that many of the Hart Councillors would have you believe.
There will be negative impacts in 4 main ways:

  • Starvation of infrastructure funding
  • Extra traffic and congestion
  • Lack of affordable homes
  • Destruction of amenity space

Infrastructure Funding

Hart Council currently has a £78m infrastructure funding deficit, much of it in Fleet, Church Crookham and Hook. This does not include healthcare where there is a forecast £47m funding deficit in five years time.  A new town will need about £300m of infrastructure spending to make it work, but a realistic assessment of developer contributions is £40-50m.  This leaves a further gap of ~£250m.  There are already complaints about long waiting lists at doctors and lack of other amenities.  It is clear that a new town will be under-funded with consequent impact on other parts of Hart District, where there will be no spare money to address the deficit that already exists in all areas of Hart including Fleet and Church Crookham.

 

Congestion

Where Hart Residents Work

Where Hart Residents Work, SHMA Figure 13

Let’s have a look at where Hart residents work, using the evidence of the Strategic Housing Market Assessment (SHMA).

A bit less than half of them work in Hart – 45%. So of the 12,500 new people in a new town, 45% of those of working age will work in Hart. The biggest employment centres are in Fleet and Hook. So a significant proportion of the new town workers will go to work in Fleet. They are not all going to work in a new supermarket in the new town.

A significant proportion will also work in Rushmoor (Farnborough and Aldershot), Surrey Heath (Camberley) and Waverley (Farnham) – some 18% in total.

The most obvious travel to work route for many of these people will be along Pale Lane, through Elvetham Heath/Fleet or along Chatter Alley, through Dogmersfield, Crookham Village and Church Crookham.  But these roads are narrow and a difficult to upgrade due to bridge constraints, so maybe a new road out of the new town on to Hitches Lane will be required.

A big portion – 6.2%, will use the train to go up to London from a station that is already full, on a line that is operating at or above design capacity.

Another group will go to Hook directly, or through Hook and/or Hartley Wintney to get to Reading or Bracknell adding to existing peak time congestion on the A30.

Pretending a new town will have no impact on congestion in Fleet and the Crookhams is plainly wrong.

Surely much better and more sustainable to direct housing development to the east of Fleet at Ancells Farm, Bramshott Farm and Pyestock (some of them brownfield sites) with a cycle route to Fleet station and a cycle route to the Cody Tech centre or the Farnborough airport complex.

Affordable Housing

 

Vacant Office Admiral House, Harlington Way, Fleet, Hart District, Hampshire

Admiral House, Harlington Way, Fleet, Hart District, Hampshire

As of 26/11/15, the cheapest 1-bed and 2-bed new homes available within 1 mile of Fleet are available at prices of £215,000 and £235,000 (Rightmove). Median household incomes for Hart are £40,200 per Figure 4.8 of the SHMA. This means that the cheapest new homes are between 5.3 and 5.8 times median incomes and out of reach for the average household, so something should be done.

The SHMA calls for 60-70% of new build to be 1 and 2-bed properties across the Housing Market Area.  The developers are going to want to do what they always do, that is to build 3-5 bedroom detached houses in the new town which will be no doubt attractive to those moving from London, but will do nothing to meet the needs of ordinary people living in Hart.

Surely, it would be better to build smaller, starter properties on brownfield sites such as Ancells Farm, Fleet Road, Harlington Way in Fleet and Bartley Wood in Hook to give younger people a more affordable first step on the housing ladder.  This iwll do far more to meet the actual need outlined in the SHMA, and be more sustainable for our environment.

Destruction of amenity space

The Heart of Hart, the area around Winchfield, is used as an amenity area for walking, cycling, watching wildlife and other recreation. Concreting it over and joining together Hartley Wintney, Winchfield and Hook into a giant Hartley Winchook conurbation will lead to lack of amenity for everyone.  Hart Council is yet to report on the consultation it ran earlier this year on how we value our amenity space.

If you are concerned about the impact of a new town, we have created two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided.  It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2-minute version:

Respond to Local Plan Consultation in 2 minutes

There is a brownfield solution to Hart’s housing needs

Vacant brownfield Block at Ancells Farm, Fleet, Hart District, Hampshire

Vacant Office at Ancells Farm, Fleet, Hampshire

We have done some further analysis on Hart’s Strategic Housing Land Availability Assessment (SHLAA) and come to the conclusion that Hart’s housing needs can be met from brownfield sites alone.  We believe this is a potentially viable solution that should form part of the forthcoming Housing Options consultation as part of the Local Plan.  Instead Hart Council have ignored the wishes of 2,130 people who signed the WeHeartHart petition and only put forward solutions that involve concreting over vast swathes of our countryside.

Created using the Donation Thermometer plugin https://wordpress.org/plugins/donation-thermometer/.2,350Hart District Brownfield Development Target3,993Hart District Brownfield Development Target170%

[Updated 2 March 2016 to add in the new brownfield SHLAA sites as described here]

[Updated 31 March 2016 to include Pyestock (aka Hartland Park)]

[Updated 30 August 2016 to re-set target to 2,350 now that Moulsham Lane, Yateley has been given the go ahead]

So, how have we arrived at our conclusion?

Brownfield sites in the SHLAA

We have been through the SHLAA and identified those sites that are mostly or wholly brownfield in nature, and added up total capacity as recorded in the SHLAA.  Pyestock (aka Hartland Park), is now also an official SHLAA site.  In total, these sites amount to between 3,208 and 3,250 homes at an average density of a relatively modest 28 dwellings per hectare (dph). The detail is shown in the table below:

ParishRef.NameBrownfield Capacity in Table 1 in DLPSite Assessment Capacity (Low)Site Assessment Capacity (High)Size (Ha.)Low Density (dpa)
Blackwater and HawleySHL21Linkwater Cottages, Blackwater12120.6418.75
Blackwater and HawleySHL100Sun Park, Guillemont Park North3003203201226.66
BramshillSHL106Bramshill (Police Training Centre)2502501025
Church CrookhamSHL2826/32 Bowenhurst Road8660.4214.28
Crookham VillageSHL158Crondall House, Fleet27271.1323.89
DogmersfieldSHL39Fermoy, Farnham Road5102.232.24
DogmersfieldSHL55Land at Church Lane, Dogmersfield20200.8224.39
Elvetham HeathSHL104Land at Elvetham Heath4545452.2520
EversleySHL127Land at Paul’s Field, Eversley70702.825
EversleySHL140Land off Warbrook Lane53531.7630.11
EwshotSHL36Dachs Lodge, Redfields, Church Crookham29291.224.16
EwshotSHL80Tanglewood, Ewshot770.3122.58
EwshotSHL174Peacocks Nursery Garden Centre1051053.530
EwshotSHL235Land at Willow Croft, Church Crookham50502.7518.18
FleetSHL41Imac Systems, Fleet6660.05120
FleetSHL42Camden Walk, Fleet9880.2433.33
FleetSHL50Waterfront Business Park, Fleet60601.4641.09
FleetSHL6918 Church Road, Fleet10100.07142.85
FleetSHL102Land at Bramshot Lane45451.825
FleetSHL113Thurlston House1712120.6817.64
FleetSHL245Land at 154-158 Albert Street & Fleet Road14880.1844.44
FleetSHL275Land at Little Mead, Fleet12171.0611.32
FleetSHL320Fleet Town Centre Zone 2201501501.883.33
FleetSHL322Fleet Town Centre Police Station1737370.6160.65
FleetSHL357Land at Sankey Lane, Fleet20200.6431.25
FleetTBAPyestock (aka Hartland Park)1,5001,50048.238.1
Hartley WintneySHL95Nero Brewery, Hartley Wintney660.1540
Hartley WintneySHL216Land adj. to James Farm Cottages, Hartley
Wintney
660.2920.68
HookSHL111Hook Garden Centre, Reading Road, Nr. Hook57574.4712.75
Long SuttonSHL296Old Dairy, Long Sutton550.225
OdihamSHL29Land at Butts End660.415
OdihamSHL66Rear garden of 4 Western Lane, Odiham16160.6425
OdihamSHL119Land at the rear of Longwood, Odiham990.3129.03
South WarnboroughSHL70Stables at Lees Cottage, South
Warnborough
550.2520
South WarnboroughSHL172Granary Court, South Warnborough16160.6923.18
WinchfieldSHL34Land adjoining Winchfield Court18251.0616.98
WinchfieldSHL84Land at Winchfield Lodge60603.815.78
WinchfieldSHL114Trimmers Cottage, Winchfield Hurst12120.4924.48
Church CrookhamSHL81Vertu, Beacon Hill Road, Church Crookham65701.7636.93
Blackwater and HawleySHL176Hawley House, Hawley8100.326.66
CrondallSHL178Broden Stables & Stable Yard, Crondall14271.410
CrondallSHL179Bowenhurst Lane, Crondall30351.520
Hartley WintneySHL189Land at James Farm, Hartley Wintney880.3125.8
Total3,2083,25011727.9

A number of these sites are “not currently developable” according to Hart.  But most of the green field sites they have put forward are also not currently developable.  We believe that the issues surrounding brownfield sites should capable of being resolved more easily than those for green field sites.

Sites not in the SHLAA

There are a number of sites not in the SHLAA that nevertheless should be considered that amount to around 785 additional homes.  These include the parts of Ancells Farm, Bartley Wood and Fleet High Street that have not already been permitted or counted elsewhere. We have also counted the complex of under-utilised offices that include Admiral House, Flagship House, Hart Offices and Harlington centre in Fleet.  Much of this site was recommended by Fleet Future, but for some reason Hart Council have ignored it.  But we can think of no reason why a council that was truly committed to a brownfield first strategy would not offer up its own under-utilised offices to be part of new, mixed use development and move to one of the other vacant office blocks in the district.  These sites, with an allowance for parts of sites that have already been permitted, are shown in the table below.

ParishSite DescriptionEstimated capacityNote
FleetAdmiral House, Flagship House, Hart Offices and Harlington centre350Paper by Gareth Price identified 775 units on a larger site incorporating much of this area
FleetAncells Farm370From Stonegate report
FleetFleet vacant offices220From Stonegate report
HookBartley Wood200From Stonegate report
Less units already granted permission or already counted-355Part of Ancells Farm and Barley Wood already granted. SHL 320 already counted
Total785

Conclusions

Drawing this together, there’s capacity for between 3,993 and 4,035 units on brownfield sites, without increasing the density on any of the SHLAA sites.

Now, according to Hart, we have to find space for a further 2,350 homes (now that 150 houses have been approved at Moulsham Lane, Yateley), according to the current Strategic Housing Market Assessment (SHMA).  This shows that we have now more than met our remaining needs from brownfield sites alone. We certainly do not need a new town at Winchfield or any new urban extensions in Hook, Fleet or Elvetham Heath.

However, we also know that Alan Wenban-Smith has challenged the SHMA and said that we need around 2,000 fewer houses.  If this were accepted by the inspector, we would have an even bigger surplus of brownfield capacity to take into the next planning period.

We also know that the SHMA is being revised, and the Government has published revised population and household forecasts earlier this year and these showed much lower figures for Hart.  Again, this should result in a lower housing allocation, and we would end up with a surplus of brownfield sites until the next planning period.

This begs the question why Hart Council is not including a formal brownfield option in its forthcoming consultation, when that was the clear view of the 2,130 people who signed the WeHeartHart petition.  Persisting with new town and urban extension solutions is untenable.  Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Hart Council’s new consultation still likely to leave it in a hopeless position

Scales of Justice weigh against Hart District Council

Scales of Justice weigh against Hart District Council

It seems likely that Hart Council is about to launch a new consultation on housing options for the district as part of the Local Plan.  We are following this closely, and will publish some additional materials to help residents make up their mind once the full consultation has been made public.

But having reviewed the materials already on Hart’s website (cabinet meeting materials for 18 November 2015), it seems clear that the council have taken no notice of the legal opinion they received from top QC Peter Village, that described their position as “hopeless”.

That opinion said:

…there is no evidence that to date there has been any consideration by the Council of the “reasonable alternative[s]” of providing less than the OAN, on environmental grounds…

There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues. Thus, the Council presently appears to be in a hopeless position if it maintains its current course. Either it will proceed with a plan that does not address fundamental matters (thereby exposing itself on the “soundness” issue), or it will incorporate matters which have indisputably not been the topic of any regulation 18 consultation.

We have been through the consultation materials in some detail, and we can find no reference to the council considering providing fewer houses on environmental grounds, and no sign of consulting us residents on employment, retail, transport or infrastructure.

Coupled with the issues we raised to the council on Friday, it is looking like this consultation is going to be an expensive waste of time and taxpayers’ money because we are still not being offered a proper consultation on all the issues that matter. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Lock, stock and two smoking barrels

lock stock and two smoking barrels

Lock, stock and two smoking barrels

I present without further comment the contents of a letter I sent to Hart District Council yesterday (Friday 20 November 2015). Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Errors, omissions and anomalies in the (Strategic Housing Land Availability Assessment) SHLAA and consultation materials

Dear Messrs Daryl Phillips and Stephen Parker,

It is clear that Hart Council has been very busy, publishing a vast array of new material about the SHLAA and the materials to be used in the forthcoming consultation about Housing Options.  I have burned a considerable amount of midnight oil going through those materials in some detail, and I have identified material errors, omissions and anomalies that give me serious cause for concern that I would like to share with you.  The Excel workbook containing the amalgamation of the SHLAA Master List, the NHB data and the SHLAA detail is attached for reference. These fall into several broad categories:

  • Assessment of brownfield site capacity and delivery
  • Deliverable and developable sites not included in the Developing a Local Plan for Hart paper (DLP) nor the New Homes Sites Booklet (NHB)
  • Sites missing from NHB but in the SHLAA
  • Discrepancies between capacity shown in NHB compared to SHLAA detail
  • Sites shown in detailed assessment but not in master list
  • Sites assessed as “not currently developable”, but have been granted planning permission
  • Range of meanings of “not currently developable”
  • Lack of consideration of the economic aspects of housing options 
  1. Assessment of brownfield site capacity and delivery.

There are a number of components to this:

In Hart News in September, and again at cabinet on 1 October, it was said that brownfield capacity had increased to 1,800 units. Now, this has miraculously fallen by 75% to 450 units on some dubious grounds. First, para 41 of the DLP states correctly that years 6-10 need only “developable” sites to be included, beyond that you can be more vague about sites.  We are already 4 years into the plan period and, according to the land supply calculation based on the current inflated SHMA, we have 5.7 years of land supply.  Yet, you are only selecting sites to be included in your calculations that meet the most onerous criterion of being “deliverable”.  As you know I have two FOI requests outstanding with you, the first is inquiring about the disposition of the 750 brownfield units that we were told were achievable back on November 2014, and the second asking for the analysis to support the 1,800 figure.  It seems to me you have inappropriately applied criteria that are too onerous in order to artificially reduce the potential brownfield capacity.  An example of this would be excluding Bramshill, when everyone knows it will be preferable for this site to undergo some sort of redevelopment to stop the Grade 1 listed building decaying and of course the hideous 1970’s accommodation blocks need replacing too.

You have under-stated the brownfield capacity in the DLP, compared to the assessed capacity in the SHLAA documents. This is shown in the table below:

Parish/Ref Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High) Sum of Brownfield Capacity in Table 1 in DLP doc
Blackwater and Hawley 320 320 300
SHL100 320 320 300
Church Crookham 6 6 8
SHL28 6 6 8
Elvetham Heath 45 45 45
SHL104 45 45 45
Fleet 221 221 83
SHL113 12 12 17
SHL245 8 8 14
SHL320 150 150 20
SHL322 37 37 17
SHL41 6 6 6
SHL42 8 8 9
Grand Total 592 592 436

 

This shows that the capacity shown in the DLP (excluding the 20 units from the sites with planning permission) is some 156 units lower than your own assessments in the SHLAA documents with most of the discrepancy arising from sites SHL320 & 322.  Correcting this would reduce the net requirement by 156 units.

In Figure 2 of the DLP, you assert that 52% of the development completed or where permission has been granted since 2011 is on brownfield sites. Yet at September Council, a question was asked along similar lines and the response was “these figures exclude brownfield sites that require planning permission, because those are not currently split between greenfield and brownfield developments”.  This leads one to conclude either that you have simply made up the figures in the DLP, or you knowingly misled the Council and the public in September.  Which is it?

  1. Deliverable and developable sites not included

[updated with this note]

There’s a large number of deliverable and developable sites that are in the SHLAA but not apparently referred to in the DLP or the NHB.  A list if these is shown in the table below (some of which are in the NHB):

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 320 320
SHL100 320 320
Church Crookham 6 6
SHL28 6 6
Elvetham Heath 45 45
SHL104 45 45
Fleet 25 243 248
SHL113 12 12
SHL245 8 8
SHL275 25 12 17
SHL320 150 150
SHL322 37 37
SHL41 6 6
SHL42 8 8
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Hook 550 550
SHL1&2 550 550
South Warnborough 16 16 16
SHL172 16 16 16
Grand Total 41 1,186 1,191

The land supply document shows a total of 3,878 units built, permitted or deliverable up until 1 April 2015, some 722 below the 4,600 figure you assert in the DLP.  I accept that 340 units from SHL1 & 2 and 10 from SHL69 are included in the land supply.  But the land supply does not include 300 units from Watery Lane.  Netting all of this off, then there are around 5,000 units already accounted for by being completed, permitted or deliverable, which would reduce the current net requirement by ~400 units compared to what you assert in the DLP.

  1. Sites missing from NHB but in the SHLAA

There are 76 units on sites in the SHLAA that are not already on the brownfield list and not strategic sites that do not appear in the NHB.  These are shown in the table below:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Fleet 10 10
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Heckfield 5 5
SHL157 5 5
Mattingley 48 48
SHL160 48 48
Yateley 7 7
SHL18 7 7
Grand Total 76 76

 

This raises the question as to why these sites have not been included in the NHB process either as selected or rejected sites.

 

  1. Discrepancies between capacity in NHB and SHLAA

There are material discrepancies between the site capacities shown in the NHB and those in the SHLAA.  Sometimes the NHB can be above the SHLAA figures and sometimes below.  But overall, adding up all of the sites where the NHB capacity is outside the range of SHLAA lower and upper limits, the NHB shows a lower capacity of some 1,500 units.  This demonstrates that the potential capacity of dispersal sites is being materially under-stated.  These sites are shown in the table in Appendix 1.

 

  1. Sites present in the detail of the SHLAA but not on the master list, and hence not in the NHB, nor mentioned in the DLP.

There are three sites, SHL167, 168 and 169 appear in the detailed assessments of sites, but not on the master list.

  1. Sites shown as “not currently developable” but have in fact been granted planning permission

Sites SHL68 and SHL117 are listed in the detail SHLAA documents as “not currently developable”, but according to the master list of sites have been granted planning permission.

  1. Range of meanings of “not currently developable”

It is clear from the above that the term “not currently developable” is a somewhat elastic phrase that can include sites that are just an administrative stroke of the pen away from deliverability as well as sites that face very significant challenges.  Many sites in the NHB and of course many of the strategic sites face very significant challenges that it is difficult to see how they can be remedied, such as proximity to flood zones, SSSI’s, SINCs, TPOs and the SPA and lack of proximity to existing settlements whereas others are much closer to deliverability.

However, the main materials being circulated for the consultation do not make this distinction clear.

  1. Lack of discussion about economics

The discussion about infrastructure costs in the DLP, with the only mention of costs being the woefully [inadequate] £30m for a new motorway junction – I would think there is little chance of change out of £100m.  But even so this misses out other important infrastructure items like the local road system, new or upgraded railway station, widening of the railway bridges over the local roads, new sewage farm, burying overhead power lines, new schools and new healthcare facilities to name but a few.  Hart currently has a £78m infrastructure funding deficit, Hampshire as a whole £1.9bn and the local NHS is predicted to have a large annual funding deficit.

These issues associated with a new town should be spelled out in detail, and I would think many of the same issues will arise with urban extensions.

It is certainly true that these issues will need to be resolved before the Local Plan can be found sound at examination.

So, what are we to conclude from the above?  First, the discrepancies outlined above, once corrected will make a very material difference to the calculation of how many more houses we need to build on green field sites (if any) and the capacity of each parish to deliver them.  I do not wish to subscribe to conspiracy theories.  However, the sum-total of the above, coupled with the obvious single-minded desire on the part of some members to push through a new town at all costs, leads me to conclude that either the people who created these consultation documents were incompetent or they are by their omission or intent about to mislead the public.   It is also clear that whatever systems and processes you are using to plan, manage, monitor and control the SHLAA are completely inadequate with such large discrepancies between different views of the same data.

It is clear to me that the forthcoming consultation should be postponed until these discrepancies are ironed out.

I would like you to treat this letter as a formal complaint and respond according to LGO guidelines.  I might also add that I will copy this letter to the chairman of the Standards Committee to ask him to set up an investigation and to our Local MP.  You might expect this letter and your response to be presented as evidence in any examination of the Local Plan.

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 15 12 12
SHL21 15 12 12
Bramshill 300 250 250
SHL106 300 250 250
Crondall 112 130 130
SHL159 65 100 100
SHL72 16 18 18
SHL76 31 12 12
Crookham Village 70 100 100
SHL53 70 100 100
Dogmersfield 40 5 10
SHL39 40 5 10
Eversley 91 123 123
SHL127 50 70 70
SHL140 41 53 53
Ewshot 120 187 187
SHL174 63 105 105
SHL355 48 75 75
SHL80 9 7 7
Fleet 706 881 886
SHL102 43 45 45
SHL275 25 12 17
SHL333 500 750 750
SHL50 46 60 60
SHL51 92 14 14
Hartley Wintney 208 287 301
SHL155 117 194 194
SHL216 8 6 6
SHL35 34 3 17
SHL45 25 51 51
SHL91 10 11 11
SHL97 12 10 10
SHL99 2 12 12
Heckfield 169 45 65
SHL109 44 5 5
SHL257 62 20 30
SHL259 63 20 30
Hook 2,090 3,849 3,849
SHL123 13 20 20
SHL3 543 1,000 1,000
SHL4 458 1,800 1,800
SHL5 1,065 1,000 1,000
SHL6 11 29 29
Long Sutton 63 65 65
SHL296 6 5 5
SHL335 34 35 35
SHL336 23 25 25
Mattingley 130 40 60
SHL239 55 20 30
SHL240 75 20 30
Odiham 3,308 2,894 2,904
SHL108 387 160 160
SHL110 2,160 1,900 1,900
SHL138 204 261 261
SHL228 48 75 75
SHL29 10 6 6
SHL328 25 30 30
SHL329 44 30 30
SHL57 47 75 75
SHL59 115 175 175
SHL60 11 12 12
SHL65 36 50 50
SHL67 53 80 80
SHL78 168 40 50
Rotherwick 130 200 200
SHL86 130 200 200
South Warnborough 36 20 25
SHL70 7 5 5
SHL75 29 15 20
Winchfield 119 32 42
SHL114 11 12 12
SHL262 108 20 30
Yateley 9 60 60
SHL13 0 8 8
SHL149 0 10 10
SHL17 0 30 30
SHL303 9 12 12
Grand Total 7,716 9,180 9,269

See more at our consultation page:

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Winchfield Action Group and We Heart Hart submit objections to Hart’s consultation process

Designated area of outstanding natural profitability

Designated area of outstanding natural profitability

As you may know, Hart Council is about to embark upon a new consultation about our housing options as part of the Local Plan process.  We Heart Heart and Winchfield Action Group (WAG) have significant concerns about the way this consultation has been constructed and submitted a number of detailed points to the council.  In addition, WAG will be making a statement at the Cabinet meeting tomorrow. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

The main thrust of the objections is as follows:

  • Overall the consultation is too complicated and the instructions are not clear.  Given that a large number of submissions to the last consultation were invalid, this is a serious concern that needs to be addressed.
  • The Council have not explained why they have reduced the brownfield capacity of the district to 400 units when they said there was 1,800 as recently as October. The consultation also makes no reference to the fact that the Council is currently seeking more brownfield sites across the district.
  • The consultation unfairly biases its whole analysis towards the conclusion that we must build a new town in Winchfield.

There are also a number of other points made in the detail.

The statement and the detailed point can be found on the downloads below.

Statement to Hart Cabinet
 
Detailed feedback on Housing Options Consultation