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 planningpolicy@hart.gov.uk 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

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.

Time to work together to head off new Hart housing threat

Hart Housing threat: sites under consideration

Hart Housing threat: sites under consideration

Overshadowed by our earlier  story of CCH further delaying the Hart Local Plan was the news of the new Hart housing threat of our target being raised from 7,500 to over 10,000 new houses up to 2032. This comes on top of the potential financial costs of delay.

Details of how this has come about are sketchy. It is related to how Hart should respond to Government rules about how to deal with affordable housing. We understand Hart Council is working on a ‘topic paper’ to give a further explanation.

We have analysed the impact of this new target below. Sadly, most of the large, sensitive green field sites are potentially under threat once again.  In addition, it is likely that Hart would no longer have more than five years of land supply. This exposes us to the threat of speculative planning applications. If most of these additional houses end up being ‘affordable’, they won’t attract contributions from developers to fund vital infrastructure.

So, we have come to the conclusion that it is time for all the politicians and pressure groups to work together to fight off this new threat rather than spend their time arguing over where the new houses should go. This level of development will mean that substantially all of the district will be under threat for some time. Moreover, this increased rate of building will be carried forward into the new planning period making things even worse for decades to come. We need to demand three key actions:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. Challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. Pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

Impact of the Hart housing threat on sensitive sites

First we take a look at where we would need to build to meet this new target and compare it to last year’s consultation; the most recent land supply position and our estimate of a ‘fair’ housing target.

Impact of new Hart housing threat on Hart District sites

Impact of new Hart housing threat on sensitive sites

As can be seen above, if the housing target remains around current levels, our remaining housing needs can easily be met from brownfield sites such as Hartland Village (Pyestock), the sites Hart Council identified in the consultation, Bramshill House and some further redevelopment of Ancells Farm and Bartley Wood. Moulsham Lane, Yateley was given the go ahead at appeal over the summer.

For some reason related to the Hop Garden Road appeal, Hart decided to increase our housing requirement up to 8,022 houses.  This is achievable from the 4,000 units we have identified on brownfield sites. But the planners would need to be persuaded to:

  • Redevelop the area around the Harlington and Hart’s offices in Fleet for mixed use.
  • Bring the many other smaller borwnfield sites across the district into the equation.

Failing that, it is inevitable that one of the green field sites is chosen.  For the purposes of this analysis we have used Grove Farm/ Netherhouse Copse as that is up for determination at the moment and the officers have recommended it.

Our estimate of a ‘fair’ housing target is based on the work of Alan Wenban-Smith. This starts with the population projections which on their own would generate a housing need of 5,040 houses over the planning period. A generous allowance is then added for additional economic growth to arrive at a need of 7,140 houses. This is easily achievable on brownfield sites, with some left over for future periods. Note that the new housing target is twice the level of housing required to meet the projected population forecasts.

The new target of 10,177 houses makes it much more difficult to achieve on brownfield. Again, the brownfield capacity could be larger than indicated above if the councillors and planners were to finally deliver on their brownfield study. If they don’t, it is inevitable that most of the sensitive green field sites including Pale Lane (Elvetham Chase), the land west of Hook and one or more of Murrell Green, Winchfield, Lodge Farm or Rye Common come into the equation. As you can see this new housing target will impact everyone.

Impact of Hart housing threat on the land supply

In the absence of the Hart Local Plan and up to date policies, the only defence we have against voracious developers is the five year land supply. This gives some limited control over speculative planning applications. So, we have taken a look at what the new target will mean for our five year land supply.

Impact of new Hart housing threat on 5 year land supply

Impact of new housing target on Hart District 5 year land supply

The left hand columns show the current 5-year land supply that Hart Council use. This shows we are in the relatively comfortable position with over 6 years land supply. If We Heart Hart’s fair housing target was adopted this would rise to 8 years supply.

However, the new housing target would reduce our land supply to below the crucial 5-year threshold leaving Hart very exposed. We would need another 525 additional houses to be granted permission ASAP to bring us back over the threshold.

Conclusion

We are in a very serious position with many of our cherished green fields under grave threat from speculative planning applications. There is no Local Plan and our policies are out of date. Hart is running an infrastructure funding deficit of £78m. The new housing target is double what we need to meet the official Government population forecasts. If the new housing target is adopted, Hart will no longer have a five year land supply. Unless we change tack, all our green fields will be concreted over and lost forever.

To preserve all that makes Hart such a great place to live we need to take serious action:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. We need to challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. We need to pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

This can only be done by everyone with a stake in Hart housing development working together to get the best outcome for Hart.

Rail capacity is significant barrier to Winchfield new town and Hart development

Rail capacity is significant barrier to Winchfield new town and Hart development

A concerned resident has written to South West Trains asking a series of questions about the capacity of the mainline railway that travels through Hart District and the alternative strategies for increasing capacity. The answers are a significant cause for concern and call into question not only the viability of the proposed Winchfield new town, but also further large scale development across Hart District.

In summary the mainline up to London already is 20% over-crowded at peak times and is forecast to have a 60% capacity shortfall by 2043.  There are no plans to have more trains stopping at Winchfield (and by implication no plans for more trains at Hook or Fleet). There are no plans to extend the station at Winchfield (and by implication Hook too) properly to accommodate 12-car trains. There are no plans to increase car-parking capacity at Winchfield. The mooted solution of double-decker trains is a non-starter because of the infrastructure requirements and increased dwell times. Network Rail would not be responsible for the costs of widening the three tunnels under the railway in Winchfield, nobody has estimated the cost, but it is known to be considerable.

All this leaves the proposal for a new town in Winchfield in tatters, but it also calls into question the viability of so many more houses across Hart as there simply is not the rail capacity to accommodate the increased population.

The answers to the questions were produced under the supervision of a senior executive in South West Trains and in consultation with Network Rail’s Wessex Route Strategy team and are reproduced below:

Q1: Is my assertion that the planning authorities should be considering the capacity of the whole Southampton to Waterloo line rather than the capacity of individual stations is correct?

A1: Network Rail would always look at the capacity of the whole line, particularly in relation to additional services. This is because the impact of increasing capacity through additional services does not just affect an individual station. Additional stops for existing services will have an impact on journey times owing to the time taken to accelerate/ decelerate and dwell time at the platform all adding in time. Those existing services may also be close to capacity and adding extra stops would impact upon the ability for passengers further down the line to get on to the train. Network Rail would encourage a joined up approach between local authorities to ensure that capacity is looked at across the whole line.

Q2: If I am correct, is the line under, at or over capacity? If it is over capacity by how much and when you plan to bring it down to safe levels?

A2: The Wessex Route Study, published in August 2015 (http://www.networkrail.co.uk/long-term-planning-process/wessex-route-study/), states that there is currently 20% overcrowding on Main Line services and that growth to 2043 will see an additional 40% capacity being required. Therefore in the period to 2043 we expect to be required to accommodate 60% extra capacity. The Wessex Route Study sets out the strategy for meeting this growth and mitigating overcrowding. Unfortunately there is no quick fix for what is needed and therefore there are a number of incremental steps that will be taken, including a flyover at Woking, track reconfiguration works between Clapham Junction and London Waterloo, and a major infrastructure such as Crossrail 2. The summary Chapter 6 sets out what is required and Chapter 5 has a bit more of the detail.

Q3: Do you have plans to increase the frequency of trains stopping at Winchfield to soak up additional passengers? It has been suggested that some of the fast trains from Southampton might stop there. If this is not the case are there impediments to so doing?

A3: There are presently no plans to increase the frequency of stopping trains at Winchfield as there is insufficient route capacity and no physical capacity on trains which would take the additional calls. Furthermore to have the faster services calling at Winchfield would be detrimental to journey time from longer distance locations to London such as Salisbury, Winchester and Southampton.

Q4. Are any plans to extend the station at Winchfield? If this did occur would this be the responsibility of SW Trains, Network Rail or the Local Council? Have you any indicative costs for such an activity?

A4: Network Rail currently have no plans to lengthen the platforms at Winchfield. Automatic Selective Door Opening (ASDO) is employed at some stations where the platforms are not long enough to accommodate all carriages of a train; Winchfield is an example. ASDO allows for only some of the doors to open at stations with short platforms negating the need for expensive platform extensions. This is only employed where it is deemed safe to do so. Where platform pedestrian capacity is a problem then ASDO may not be the correct solution because it wouldn’t allow passengers to spread along the platform to spread a crowd waiting for a train.

Q5. Are there any plans to increase the car parking capacity at Winchfield? Again, if this were to occur where would the costs lie and how much would they be?

A5: There are no plans in the present franchise to increase car park capacity at Winchfield.

Q6: Are double-decker trains a serious option to overcome the overcrowding on this line? If they are not please can you tell me if there are any single major obstacles that will preclude their adoption on this line?

A6: Double Decker Trains were investigated as part of the Wessex Route Study. The study looked at Waterloo to Basingstoke as the scope area. This was decided upon as there are relatively few limited clearance structures on this stretch of line and therefore if it wasn’t feasible here, then it wouldn’t work on other parts of the network such as between Basingstoke on Southampton where there are a number of tunnels. In short, the Route Study concluded that the combination of needing to operate bespoke rolling stock (as no rolling stock operated elsewhere in the world would work on our infrastructure), the cost of modifying the infrastructure to accommodate the trains (track lowering, bridge rebuilding, platform adjustments and lineside infrastructure moves and adjustments), the impact on dwell times and the fact that double deck services would only be necessary in the peak mean that the business case was not strong enough to warrant such investment.

Q7: There is an embankment running east of Winchfield Station pierced by three road tunnels. Should road widening be deemed necessary for any or all of these tunnels, what would your reaction be? Who would pay for such works? What would be the indicative costs please?

A7: Network Rail would need to assess the impact of widening the tunnels on the embankment and if it was deemed safe. The Network Rail Asset Protection team would need to be satisfied that Network Rail’s assets were not damaged or compromised in anyway. We do not have foresight of costs for such a scheme and this would not be a cost that Network Rail would expect to be accountable for.

Election update: Hook candidates declare their positions

We Love Hart Ballot Box

Hook Action Against Over Development have been in touch with some of the local candidates for Hook ward in the Hart District Council local elections 2016, and managed to get some additional information out of their local candidates and have circulated this in an email to their supporters.

This is reproduced below, with our response where appropriate. The appropriate detailed pages for each party have been updated accordingly as well as our summary page.  The detailed party pages are:

Colin Ive, Liberal Democrat – No election leaflet delivered, local party website has no information on the current elections and no candidate contact details.

Mike Morris, The Conservative Party Candidate:

I joined the council because of the 550 houses that were proposed at NE Hook and out of choice became part of the planning team that is processing that site and others around Hook. As you know none of which I welcomed and said so in front of all that attended the Basingstoke Hotel Hook residents meeting.

I do not support urban extensions as they do not bring forward sufficient new infrastructure capacity but just overload current capacity. Nor do some Brownfield sites under permitted development! However I welcome the proposed development at Hartlands (sic) Park (Pyestock) with its 1000 plus housing which will reduce the housing numbers Hart has to deliver. Nevertheless this hasn’t changed my mind regarding the need for a large settlement site at Winchfield which I support as its deemed the only sustainable and developable site in the district to deliver sufficient housing numbers for the current ( impending ) plan and the future.

As you would expect every District Councillor defends his Ward and therefore some of my Conservative colleagues particularly those serving Wards in and adjacent to Winchfield would naturally be against the proposed Winchfield development. I fully understand their position and I would do the same if it applied to Hook or Rotherwick.

I’m unaware of a party line to vote one way or another on any future development and always intended to vote for and on behalf of Hook and Rotherwick residents within best practice in terms of planning policy.

Our response:

  1. Hart Council has said Hartland Park has capacity for 1,500 homes, not 1,000.  And of course it will not reduce the number of houses Hart has to deliver, but will make a significant contribution to meeting the alleged ‘need’.
  2. All of the sites proposed for the Winchfield new town are classified as “not currently developable” in the SHLAA, so it is misleading to suggest otherwise.  No evidence has been presented to demonstrate that a new town at Winchfield is ‘sustainable’.
  3. Hook is adjacent to Winchfield, and indeed around 1,850 of the proposed 5,000 new houses in the Hartley Winchook new town are actually in Hook parish.  One might hope that Hook councillors would acknowledge this fact and look more closely at our brownfield proposal that would result in fewer new houses in Hook than any of the other proposals.  Now that Pyestock is on the table, this is now self-evident.

Verd Nabbs, The Labour Party Candidate

From printed election material:

Local councillors have surprisingly limited powers, but they can be held to account, so they represent YOUR views. In particular over the proposed Winchfield development. A new development will prevent the irresponsible expansion of existing towns and will come with essential infrastructure improvements. We need to act now, before a solution is imposed upon us!

Dai Rees, UK Independence Party (UKIP)

Statement from local branch website:

On housing, a UKIP representative would weigh up the merits of any particular project and would decide accordingly. We all understand the results of over-development – schools, doctor’s surgeries, roads etc. simply cannot cope with the additional strain being placed upon them but nothing ever seems to get done to curb the problem. A UKIP councillor would introduce a measure of realism into the debate and could be relied upon to listen to residents and take account of any grievances they may have. We recognise that new dwellings do have to be built to cope with the increase in our population – caused largely by a laissez-faire attitude to immigration by subsequent governments – but accommodating additional persons must be done sensibly and UKIP councillors would concentrate on brown field sites as a priority.

A UKIP councillor would support improved infrastructure measures and would seek to ensure that there are better schooling and medical facilities, more parking places especially where doing so helps local businesses, and an improved transport network.

[Update] the UKIP candidate has now said he will oppose a new town in Hook. [/Update]

 

 

 

Greens set out their position on Winchfield, Pyestock and housing policy

Green Party Logo

The local Green Party have been in touch, setting out their position on the key planning issues impacting the Hart Local Plan and some ideas on broader housing policy.  In short, all of the candidates oppose Winchfield New Town and support redeveloping the brownfield site at Pyestock (aka Hartland Park). This is an important issue for the Hart Local Elections 2016.

We have updated our summary page, and table of candidates accordingly.  The detail of their response is reproduced below.

In brief I can confirm that the local [Green] party, and all its candidates in these elections are opposed to the Winchfield new town, but support the latest proposal for redevelopment of housing in Pyestock.
1. Winchfield – No. It is not required to meet Hart’s own housing targets and  by concreting over such swathes of green space, would be the destruction of Hart as we know it for generations to come. In addition, Winchfield simply does not have the infrastructure to support a New Town – it would put strain on GPs, schools, roads and quality of life – not just in Winchfield but also in Hook, Fleet, Hartley Wintney, etc.
2. Pyestock for housing – Yes. By developing brownfield sites such as Pyestock, Hart’s housing targets can be met through dispersal of home building, and lessen the burden on roads and facilities in a concentrated area. Additionally, such developments are eligible for central Government grants towards infrastructure and do not leave HDC at the mercy of council tax hikes and s106-shy developers.
Our more detailed response will include demands for any new housing to be zero- or negative-carbon and high density, and any new roads to incorporate cycle lanes. But more importantly, we don’t see this as being just about whether or not to build the Winchfield development and need to address the broader policy – how the housing need projections are worked out and allocated. If this area continues to be put under pressure to build new houses, taking in allocations from outside the area, other beautiful rural areas will be hit.
We need to emphasise the importance of rural, countryside for everyone, not just those of us lucky enough to live in villages/ rural areas. There are genuine benefits for non residents too – loads of research on mental health benefits, conservation, getting children engaged with nature, air quality etc.
And we  need to be offering alternatives, and to acknowledge the problems lots of people have in getting onto the property ladder. Is continuing to build in the over-developed South East really the answer? Should we be pushing for a more equal distribution of investment, for example, promoting business growth and sustainable development in northern England?
Consequently we are developing a vision starting with what the area should look like in 2030, and then how to get there.
We Heart Hart welcomes the stance of the Green Party on the local development issues in Hart and broadly accept many of their ideas on wider housing policy.

Winchfield Parish Council demolishes the new town idea in their response to the Local Plan Consultation

Hart in Heart of Hart, Winchfield, Hart District, Hampshire

Winchfield Parish Council (WPC) have submitted their response and covering letter (see downloads below) to Hart Council’s Local Plan consultation and effectively demolished all of the arguments supporting Hart’s new town idea.  The response was pulled together with the help of professional planners at John Boyd Planning Associates.

There are four main planks to WPC’s argument:

  1. Lack of evidence to justify the need for a new settlement
  2. Winchfield is not a suitable location for a new settlement
  3. A new settlement is not a viable approach
  4. There should be more of a focus on alternatives such as brownfield development and dispersal

The lack of evidence is demonstrated by the fact that Hart has not yet consulted upon the issues recommended by Peter Village QC namely, employment, retail, transport, and infrastructure. Moreover, it is premature and illogical to be conducting the consultation now when the Strategic Housing Market Assessment (SHMA) is being revised and we don’t know what the Objectively Assessed Need is going to be. They also note the work done by Alan Wenban-Smith that seriously challenged the numbers in the existing SHMA.

The challenge to the suitability of Winchfield as a location is demonstrated by the significant barriers to delivery outlined by Hart themselves such as education, transport and foul water drainage. They also point out that the main argument used in favour of a settlement at Winchfield, the presence of a railway station, is undermined by the suggestion that the station would have to be relocated to support the new town. There are also significant doubts about the capacity of the available sites to accommodate a new settlement of sufficient size to be viable, especially when one considers the environmental constraints such as SSSIs and SINCs as well as the space that will have to be found for SANGs, shops, car-parks, schools and recreational facilities. Not only that, but the disparate nature of the sites will make it very difficult to plan a coherent and compact nuclear settlement.

WPC also challenge the viability of a new settlement by pointing out the massive costs of infrastructure with no evidence being presented to indicate how these costs would be met.  The NPPF (para 47 & 173) calls for housing and infrastructure to be planned together, so if it cannot be demonstrated that the right infrastructure can be funded and built, then the whole new town idea could be rejected by an inspector and the Local Plan found unsound.

WPC’s submission welcomes Hart’s belated focus on brownfield development, but criticises them for ignoring an important study by Stonegate Homes, the further opportunities presented by the changes to permitted development rights and the results of Hart’s own findings of new “Zones of Brownfield Opportunity”.  They also point out that Hart’s ‘Economic Development Strategy’ (2015) identifies that the District Council must direct its resources to urban regeneration, and that focusing growth in and adjacent to Hart’s main settlements would
boost investment in infrastructure and regeneration in the locations where it is needed most and help close the £78m funding gap.

Finally, they say that it would be inappropriate to try and meet the housing needs of our ageing population through a new town option.

All in all, this is an eloquent and devastating attack on the whole idea of a new town and is very much in-line with what We Heart Hart has been saying for months.  We can only hope that the councillors will take heed of such an important report from professional planning consultants and get the Local Plan back on track to being found sound at inspection.

 

Cover letter:

Winchfield Parish Council Cover Letter

Full response:

Winchfield Parish Council Local Plan Consultation response

response  covering letter

Response to Hook Action Against Over Development

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

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

Hook Action Against Over Development have written an article on their website which has been shared on Facebook, criticising both our support of a brownfield solution to our housing needs and the statement from the CPRE saying that the Winchfield New Town proposal was the worst site and the worst option for development.

We re-produce their article below, together with our responses in blue:

There has been a lot of talk about brownfield development and some claims that a new settlement is not necessary because brownfield housing development can provide for all of Hart’s housing needs. Brownfield housing development is the reuse of property or land for residential use where it was previously used for something else, for example office space, industrial land, military use or farm buildings.

Yes, we do believe that all of Hart’s remaining housing need can be met from brownfield sites, and we have set out the case and our plan here and here.  This draws on sites in the SHLAA at only ~26 dwellings per hectare (dph) and the work of the Stonegate Report, plus we have added the civic area that Fleet Future recommended for redevelopment and Fleet Town Council have raised their council tax to fund the costs of preparing a redevelopment plan.

One group in particular from outside of Hook is putting forward the suggestion that the Hart consultation is a simple choice between brownfield and greenfield development. But no matter how much they repeat it does not make it any more true. The CPRE, an organisation with laudable aims, appears to have now fallen for this fiction and hijacking of the term “sustainable development”.

We believe they are referring to We Heart Hart.  We believe the CPRE have not put forward an actual plan, but have clearly stated that they think that a new town at Winchfield is the worst site and worst option for development in Hart.  Sustainable development was defined by the Sustainable Development Commission as:

“Sustainable development is development that meets the needs of the present, without compromising the ability of future generations to meet their own needs.”

The concept of sustainable development can be interpreted in many different ways, but at its core is an approach to development that looks to balance different, and often competing, needs against an awareness of the environmental, social and economic limitations we face as a society.

We believe that sustainable development does not include concreting over the equivalent of 25 football pitches per year of green fields and leaving untouched, vacant, decaying office blocks. A new settlement would compromise future generations by needlessly concreting over hundreds of hectares of green fields, depriving future generations of the health benefits of the countryside. The economics of the proposals don’t stack up, requiring ~£350m of infrastructure spending, money that neither Hart nor Hampshire County Council have, especially now that HCC is facing an £81m per annum funding deficit. 

Hart’s housing strategy is brownfield first, but Hart cannot propose development on sites that are in commercial use or that have not been put forward for housing. If they were to do so then the Local Plan would fail inspection again at the first hurdle and this would be a disaster. Even hypothetically utilising these unavailable brownfield sites would demand construction at inner city density in order to meet Hart’s objectively assessed housing need. We cannot believe that CPRE are promoting building at such a density in Hart. That would not be sustainable.

We agree that sites need to be developable and eventually deliverable and nobody wants to see the Local Plan fail. Back in September, Hart Council said that they thought the brownfield capacity was 1,800 units.  Miraculously, this has fallen by 75% to only 450 units in the consultation. However, as described above, most of the sites we have put forward are in the SHLAA and in no worse state of deliverability than those put forward for consultation. The other sites are in the Stonegate report and we understand Stonegate are working hard to secure these sites.  The average density for the SHLAA sites is less than Hart’s planning rule of thumb at 26dph, and the Stonegate sites are at no higher density than developments that Hart has granted permission for such as the McCarthy & Stone’s recent development on Fleet Road which many people think is an attractive building.

Hart are actually consulting on which of Hart’s green fields should be selected for housing in the event that there is insufficient brownfield land to meet the housing need. Given the vast expansion of the existing towns and villages in Hart already, with Hook alone having a 25% expansion approved for this Local Plan period, the only suitable and truly sustainable option is a new settlement to allow for a planned increase in infrastructure. Just expanding existing towns and villages either piecemeal or with “urban extensions” is still building on green fields, but in a way that will not provide the opportunity to build extra schools, roads and health facilities that the thousands of new Hart residents will require. That would not be sustainable.

The proposed new town will in fact deliver over 1,800 houses in Hook Parish, which is more than the proposed urban extension and more than the undeveloped brownfield sites.  To be clear, we do not support urban extensions either because we believe all of the remaining need can be met on brownfield sites. The infrastructure costs for a new town do not stack up and a new town will do nothing to close the large £12.2m existing infrastructure funding gap in Hook, and £20.7m gap in Fleet and Church Crookham. No evidence has been presented that we need a new secondary school and the funding for a new town will not address existing road bottlenecks, nor will there be sufficient funding to address the roads requirements of a new town. We repeat, we do not believe concreting over 25 football pitches each year is at all sustainable.

Elimination of all potential commercial property space in Hart is in fact extremely short-sighted. Even the Enterprise M3 Local Enterprise Partnership which is urging more housing would not want to see commercial space becoming rare and expensive. There is already an acknowledged shortage within Hart of small business units and light industrial space. Larger available office space provides options for small local businesses to grow without leaving the area. A thriving local economy needs a balance of housing and business to provide employment opportunities locally and avoid all of these new residents having to take to the roads and railways to commute out of the area for work on already busy transport links. That would not be sustainable.

Nobody is saying that all of the vacant commercial space be handed over to housing.  But even the Employment Land Review, based as it is on the inflated Strategic Housing Market Assessment (SHMA) and the inflated jobs forecasts, suggests that there will be around 600,000 sq m of vacant employment space across the Housing Market Area at the end of the plan period and Rushmoor was planning to “protect” 96 Ha of vacant brownfield sites that simply are not needed. If there was such a shortage of offices or of light industrial space, places like the Murrell Green Estate would not have the big vacancies they currently have. Of course it would be more sustainable to free up some of these spaces and redevelop them for residential use rather than leave them to rot and decay.

There is very little brownfield land in Hart but there is an amusing “brownfield site slideshow”, made available by campaigners whose aim is to push development away from their village, to supposedly “demonstrate” how much brownfield land is available for housing. If you happen to see it, do bear in mind that:

  • Several of the sites are already being developed for housing (and therefore counted in existing housing build numbers!) such as Landata House and Greenwell in Hook, Sun Park and others.
  • Several of the sites are being converted to other commercial uses, e.g. Warehousing at Pyestock and retail development on Fleet Road where M&S are looking to move to an expanded new store.
  • Several of the sites are in fact just one vacant floor(or even a partial floor) in an otherwise occupied office building!

Now perhaps the future really is an office building with some adjacent floorspace being residential, but can anyone imagine this being attractive to either residential or commercial tenants?!

The fact that some of the sites have already been taken up for redevelopment simply proves our case and shows it can be done.  Our brownfield solution has taken account of the sites that are already underway. Work at Hartland Park (aka Pyestock) stopped years ago, and there is no sign of it re-starting.  The owners will not wish to keep an expensive site forever generating no returns. Of course if M&S moves into another Fleet Road site, then they will leave behind a different vacant block to go with the many other vacant units in the Hart Centre.

There are plenty of examples of mixed residential and commercial use, both in this country and on the continent.  Nobody is suggesting this should happen without comprehensive redevelopment.

This current consultation is clearly not about a choice between brownfield and greenfield development, it is about the best way to provide Hart’s required housing with essential supporting infrastructure and only a new settlement can achieve that. For more, please refer to our previous article hookdevaction.org.uk/hart-housing-consultation-restarted-your-action-needed.

The Hartley Winchook new town is not required, it not viable because of the flood risks and the massive, unfunded infrastructure costs, and will not be sustainable in any sense of the word. There is a brownfield alternative, and we should seize that opportunity.

 

 

Here are the slideshows of vacant brownfield sites we have found in Hart and Rushmoor:

 

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

 

If you would like to ask Hart to abandon the new town and urban extension ideas 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, updated our two guides to responding to the consultation and they 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

Through the infrastructure looking glass

Comparison of infrastructure costs and contributions of different development scenarios

Comparison of infrastructure costs and contributions of different development scenarios

We had a surreal moment today debating with one of our district councillors revealed that she was strongly in favour of a new town because it would deliver some infrastructure funding, and other development approaches would deliver no funding.  Here is the Facebook post in question:

Wendy Makepeace-Brown No infrastructure from infill

There are a number of issues with this.

First, it is factually incorrect to state that either urban extensions or brownfield development will deliver no funding, as is described here.

Second, it seems very odd to us that councillors are ignoring basic economics and clearly are not looking at the big picture.  Surely the best way to look at this is to compare the incremental infrastructure costs of any particular development approach and the expected incremental developer contributions and, given we have an existing £78m infrastructure funding deficit, seek to minimise the gap.

In questions to the council last March we asked about the level of funding that might be attached to each development option and what the expected level of spending might be. There were no answers of substance.

It is very troubling that a councillor should seek to promote the idea of a new town because of the alleged funding contributions it might deliver, but ignore the overall costs that would be involved.

In the image above, we have shown our estimates of the impact of a new town on the infrastructure funding gap – the £78m deficit increases to £378m.  The costs are so high because the road network in Winchfield was designed for a small settlement, currently only 250 houses, which is clearly very different to that required for a settlement of 5,000 houses, plus there is no mains sewage or mains gas, overhead power lines will need to be moved or buried and a new sewage works will be needed. There is no reliable data on dispersal, brownfield or urban extensions, but we have created two hypothetical scenarios.

Scenario A looks at what the overall gap might be if, for sake of argument, £250m of funding was required to create infrastructure on brownfield sites that were converted, rather than properly redeveloped, so no S106/CIL funding was forthcoming from developers.  We would still be better off than with a new town. And remember it is self evident that the infrastructure requirement for a brownfield solution will be very much lower than for a brand new settlement.

Scenario B looks at what the overall gap might be if, for sake of argument, there was mixed brownfield development, with a more realistic infrastructure estimate of £150m and developer contributions of £40m.  The overall funding gap would be £188m.

Of course, a £188m funding gap would be bad news, but it would be much better news than the new town idea, especially as most of the existing gap is in Fleet, Church Crookham and Hook.

Estimated Infrastructure costs by area March 2013

Hart District Estimated Infrastructure costs by area March 2013

If you would like to ask Hart to abandon the new town and urban extension ideas 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, updated our two guides to responding to the consultation and they 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

 

Hart Council: Keep Calm and Hide the Facts

Hart District Council (HDC) Keep Calm and Hide the Facts 2

Hart Council Keep Calm and Hide the Facts

Readers will recall that at the Hart Council Meeting last week, senior councillors refused to answer some questions and gave vague and unsatisfactory answers to those questions.  The council has now published the full exchange on their website.  We give our view on what they really meant below.  We ask readers to bear in mind Hart’s Code of Corporate Governance which has as its four key principles:

  • Openness: openness is required to ensure stakeholders can have confidence in the decision making and management processes of the Council.
  • Inclusiveness: an inclusive approach ensures that all stakeholders and have the opportunity to engage effectively in the decision-making processes and actions of the Council.
  • Integrity: is based upon honesty, selflessness and objectivity, and high standards of propriety and probity in the stewardship of public funds and management of the Council’s affairs.
  • Accountability: accountability is the process whereby the Council, members and staff are responsible for their decisions and actions regarding all aspects of the Council’s work

Here is the full set of questions and answers, abridged and with our interpretation below in blue:

Question 1: Given that a) in October 2013, you were quoted as saying we would submit a new version of the Local Plan to the Inspector in Autumn 2014 and b) in each subsequent year this has slipped by a further year, with the current LDS indicating a local plan ready for submission in Winter 2016, will you now publish the detailed project plan to support this target, so we can be assured that project management processes have improved?

Answer: It was our intention to proceed with a revised Core Strategy after the withdrawal of the 2013 version. However, as many will well know, the Government changed the nature of Local Plans and we also had to address the issue of a new SHMA to overcome the defects blah….blah….blah…

Blah…blah..blah…The Local Development Scheme is the council’s three-year project plan that identifies which local development documents will be produced, in what order, and when. We do not propose to publish more background information on internal workings because that offers no practical advantage to anyone. There is already proper scrutiny of the Local Plan progress with all members of the Council having the opportunity to be actively engaged.

We also last summer enlisted the support of Chris Dorn to lend project management support. His work has been invaluable and he gave positive and independent feedback to the Hart District Association of Parish and Town Councils.

Finally, we have now full project management arrangements from our neighbours at East Hampshire District Council, who have recent and relevant experience of bringing a local plan through Examination to adoption.

What they really meant: Here’s some blather and vague implausible excuses why we haven’t been able to publish a Local Plan when 82% of Local Councils have managed to do it. There’s no way that we are going to publish the project plan, because we don’t want to be held accountable for any future slippage.

Question 2: Given that in January 2015, HDC commissioned work to test the proposed new settlement and urban extensions with the objectives to test the “deliverability of a new settlement and/or urban extension (ie [sic] suitability, availability and achievability)”, including a land use budget; provide “indicative costing of the major infrastructure items needed”; and consider viability including the “infrastructure requirements of sites to identify likely infrastructure impacts, subsequent costs and potential funding sources”, can you explain if these objectives have been met, and say when the results will be published?

Answer: The current position on testing is set out in the Refined Housing Options Paper. It specifically highlights and comments on where we have got to with the issue of testing. As paragraph 12 we say:

“The testing we decided to undertake is still ongoing as is the testing of all other options. The testing will go on in some form or other right up until we finalise the submission Local Plan. There is still much work to be done, but we have reached a point where we can now ask you if we are on the right track”.

We then go on to summarise on pages 9 and 10 what outcomes have been received from the testing that we have carried out so far.

The outcome of the testing will therefore, inform both the draft Local Plan and will inform the submitted Local Plan in that it will comprise part of the evidence base. All these documents will be published at the appropriate time and everyone will have the right to comment upon them when the Local Plan is independently examined by an Inspector appropriated by the Secretary of State.

What they really meant: No, we haven’t met the objectives.  If we actually finished the testing, it would likely show that a new town in Winchfield is not viable and we wouldn’t want to be transparent about that would we?

Supplementary Question: All of the sites identified to make up the new town and urban extensions are listed in the SHLAA as “Not currently developable”, we have no costing of roads, bridges, railway improvements, sewage, sports or community facilities and we have no land use budget that includes SANG, so why are you consulting on a new town that is not deliverable, as well as excluding brownfield sites for the same reason?

Answer: This is part of the consultation. Brownfield sites are only deliverable if the landowner puts them forward for development. Brownfield sites may not be deliverable for other reasons, but once they are put forward as a SHLAA site they can be considered. [Note:  Although not recorded in the minutes Cllr Parker did go on to say words to the effect that many of the green field sites put forward were not currently developable because to do develop them would be contrary to current policies and they would look to change their policies as part of the Local Plan]

What they really meant: How dare you ask me for facts? Of course, we will change our policies to get a new town at all costs, just like we changed the questions in the consultation.

Question 3: Given that an FOI request to elicit the evidence to support the assertion made at cabinet (Paper E 5.2) in September 2015, and in Hart news (p2), that brownfield capacity for the district was 1,800 units has failed, are we to conclude that the council and public were misled in September, or will you now produce the evidence and ensure that any new consultation includes a proper stand-alone option for brownfield sites?

Answer: Nobody was misled by this council. The FOI request did not fail.

The Freedom of Information requests were dealt with blah…blah.blah…

Blah..blah..One key point that seems to be missed in the question is that there can be no standalone option for “brownfield sites” because the evidence suggests that there is not enough deliverable ‘brownfield land’ available to meet all our need for new homes because too few suitable sites are being promoted as being available by developers or landowners. Blah…blah…

[Note: Here is the answer given to the FOI request: “With regards to the first request, we do not hold that information.” and also note that none of the other options put forward were able to meet the remaining needs on their own either.]

What they really meant: Of course, it was a mistake to publish the real brownfield capacity, but we’re not going to publish how we arrived at the figure. We are doing our best to erase that from history and push on for a new town. 

Question 4: You will recall that I wrote to you on 20 November 2015, highlighting discrepancies between the consultation materials and SHLAA, the most important point being point 4 (and appendix) showing the very different site capacities in the New Homes Booklet compared to the official evidence base, the SHLAA; can you now give an explanation of those discrepancies and will they be corrected before any new consultation is carried out?

Answer: I understand from the Council’s Planning Policy Manager that you have already received
an explanation about the differences between the SHLAA and the New Homes Sites Booklet regarding site capacities (email from the Planning Policy Manager sent on 23rd December 2015).

That response explained that:

“In preparing the consultation papers we drew on not only the SHLAA but also more recent information where it was available. Such information includes the high level site assessments prepared by Adams Hendry and the shortlisting exercise work (available at http://www.hart.gov.uk/Evidence-base ), pre-application plans, recent planning permissions, and any recent changes to site boundaries. These can all influence the sites that are shown in the documents. The SHLAA itself will be updated next year.”

The plan is to publish an updated SHLAA in the summer of 2016 to reflect the best information available at that time including data on annual completions which becomes available around June each year. [Note:  I did point out that I had written back to them on 12 January making clear that Point 4, amongst others, had not been answered].

What they really meant: We deliberately make it all very confusing, and who cares if the material we send out to the electorate doesn’t match the official evidence we spent loads of your money to produce and published at the same time as the consultation.

Question 5: Given that the SHMA (section 9.33) calls for 60-70% of our 7,534 housing need (or around 4,900) to be met from 1 & 2-bed properties, can you give a breakdown by number of bedrooms, of the 4,500 or so dwellings built or permitted since 2011 and tell us how many more 1 & 2 bed homes need to be built out of the remaining ~3,000 to be permitted to meet the need expressed in the SHMA? [Note: is has subsequently emerged that the preamble to this question did contain a mistake, and the need for 1 & 2-bed properties is ~3,800 units, but that doesn’t take away the need for Hart Council to measure how well it is meeting the need, nor does it stop the question being answered].

Answer by Chairman: This is a technical research question and does not form part of any current Council workstream. This is not the proper forum to be used to elicit the use of Council resources in pursuit of your own personal research. I say this because the information that you seek is already published.

You can obtain the information by accessing all the planning application details of applications submitted and determined which is published on the online Public Access system.

I would also point out that section 9.33 of the SHMA relates to affordable housing and not general housing mix. It may be you have missed out a few words which fundamentally alters the meaning of your question. [Note: I asked by email immediately after the meeting where this information can be found and have received no response].

What they really meant: You just don’t get it do you?  This isn’t about facts or meeting the needs of Hart residents it’s about getting a new town. Of course we’re not going to tell you how well or badly we are meeting the needs of local residents nor information that might suggest that a new town is not the right answer.  Where would we be if we were transparent?

Question 6: Given that the SHMA (Figure 10.15) calls for around 2,500 specialist units for the elderly, split into various categories to be built in Hart under the Local Plan, can you tell us how many of these units have been built or permitted since 2011, how many remain to be permitted and what you consider to be the best types of location for these types of accommodation?

Answer: The part of the question seeking statistics is appropriate to an FOI request and thus specifically outside the scope of a question at council. I have therefore asked that this request is handled under FOI rules. You will thus receive a formal response under that protocol. Blah…blah…

Blah…blah…This approach is exactly in accordance with government policy as set out in Paragraph: 003 Reference ID: 12-003-20140306 of the updated September 2015 National Planning Policy Guidance.

What they really meant: Meeting the needs of the elderly is not our priority and you must be joking if you think we are going to publish any information that shows we’re not meeting their needs.  We want loads more detached houses in the countryside from a new town and urban extensions.

Supplementary: How can the young who need the affordable 1 & 2-bed dwellings and elderly have confidence in the Local Plan process when the leader doesn’t know what we need to build to meet their needs?

Answer: This will be dealt with under the FOI request.

What they really meant: How many more times do we have to explain, we don’t do facts? This isn’t about meeting the needs of local people.  It’s all about getting a new town at all costs.

Question 7: What are the risks that a second consultation “anticipated to be run again from late January”, will be a further waste of Hart residents’ money, when the revised SHMA is due “early in 2016” and a revised employment land review is also being prepared, thus meaning that the evidence base is likely to change significantly during the consultation, leading to a further consultation being required?

Answer: It would be premature to speculate on the outcome of the refresh of the SHMA. Data sets change all the time and all we are looking at is one single snap shot of a combination of changing data sets…blah…blah…

What they really meant: I don’t care about risks and I don’t care about your money, I want a new town. The new SHMA will likely show a big reduction in the housing need so we won’t need to build 3,000 houses for Surrey Heath and Rushmoor and we’ll be able to meet all Hart’s remaining needs from brownfield sites. If that were put to residents they wouldn’t vote for a new town or urban extensions and where would that leave us?

Question 8: Who instigated, who authorised and who will take responsibility for each decision to repeatedly change the materials in the recent consultation part way through?

Answer by Chairman: I am directing that this question is not to be answered. This is because, as Mr Turver knows, it forms the basis of a separate investigation by Overview and Scrutiny and indeed, Mr Turver has been party to representations made pursuant to that investigation. It would therefore be wholly inappropriate to enter into discussions in public without all the facts surrounding the events that resulted in the early curtailment of the Refined Housing Options consultation having first been investigated by Overview and Scrutiny Committee. [Note: Cllr Bailey did make the point that the O&S work is a review, not an investigation and he did not intend that review to act as block on members of the public asking questions].

What they really meant: How dare you ask us to be open, transparent and accountable for our actions? 

Supplementary: We’ve heard tonight that you have failed with the last consultation, haven’t got a grip on the timeline, project management or the quality and content of the outputs, isn’t it time that you and the rest of the Local Plan Steering Group did the decent thing and resigned?

Answer: I do intend to do the decent thing and deliver the local plan.

What they really meant: We can’t have someone in charge who might actually look at the evidence and try and meet the real needs of Hart residents can we?  

 

We Heart Hart response to the decision to abandon the consultation

Protest at Hart Council's Offices about the omnishambles Consultation.

Protest at Hart Council’s Offices.

After a period of reflection, we have now had time to compose a response to Hart’s astonishing decision to abandon the Local Plan consultation and set out what we think should happen to bring the Local Plan back on track. This has been sent to all councillors.

Readers may wish to copy a link to this page and send it to their ward councillor and add their own ideas on what should be done.  A list of councillor contact details can be found here.

What should we think about Hart Council’s decision to call off the Local Plan consultation with only a day to go before it was due to close?  Well, to misquote Churchill, this consultation has been a farce in a fiasco inside an omnishambles.  Never has so little been achieved by so many with so much of our money.

This is but the latest entry in a catalogue of mismanagement and misjudgement.

Back in April 2015, Peter Village QC described Hart’s position as “hopeless” and precious little has changed since then.  This abandoned consultation has not even covered the areas that he said should have been covered, namely, employment, retail, transport and infrastructure.

Now, let’s look at the timeline:

  • In October, 2013, when the earlier version of the plan was rejected by the Planning Inspector, the council said:

“that while the council operates under the interim strategy, it is working on an updated Local Plan…. We expect to put this out for consultation early next year, and would look to submit it to an inspector next autumn [2014],”

  • In April 2014, the plan was to have a resubmission plan ready for consultation in October 2015.
  • In February 2015, the plan was to have a resubmission plan ready for Autumn 2015.
  • As late as April last year, the council was insisting that they were still on track to deliver a Resubmission Plan by Autumn 2015, despite our warnings that the project was slipping.
  • We are now in a position, according to the latest schedule, where the Resubmission plan is due in Autumn 2016, but this has to be in serious doubt given the failure of this consultation and the fact that the evidence base won’t be revised until Spring 2016 and Hart have to hold a Regulation 18 consultation on the draft Local Plan, and heaven knows why it is planned for the Summer, when many people will be on holiday.

It is difficult to come to a conclusion other than the project management is woeful.

We need also to look at the governance of the project.  Power on the Local Plan Steering Group (LPSG) is concentrated in the hands of urban councillors who have presided over this mess.

Role Member
Cabinet Member for Planning (Chairman) Stephen Parker (Con Fleet East)
The Leader of Council Stephen Parker (Con Fleet East)
Cabinet Member for Housing Stephen Gorys (Con – Odiham)
Chairman of Planning Committee Simon Ambler (CCH – Crookham West and Ewshot)
Political Group Leaders David Neighbour (Lib Dem – Yateley East)

James Radley (CCH – Crookham East)

Stephen Parker (Con – Fleet East)

 

Not only that, the quality of the deliverables to date is poor.  By way of example, in January last year Hart commissioned a piece of work to test the new settlement and urban extension options.  The published results of this work have not met the objectives set at the outset.

I have had many people send me Facebook messages, tweets and emails saying what a farce the process has been a shambles and a waste of time and money.  One correspondent has even been moved to write a poem, saying they thought our leader has led us up the garden path and couldn’t even run a bath. In short the council is a laughing stock. Many people have also come to the conclusion, rightly or wrongly, that the reason the consultation has been called off is that the people were giving the ‘wrong answer’. There is no confidence in the council, the credibility of the whole Local Plan process is subterranean, with some complaining of “consultation fatigue”.

If the consultation is re-run at the end of January, it is extremely likely that parts of the new evidence base will be released during the consultation, thus meaning that the consultation will be run on the wrong evidence base, invalidating the results.

The Local Plan process is so far behind schedule that we are running the risk of Central Government stepping in and doing the Local Plan for us.  Moreover, the Government is currently consulting on plans to remove the New Homes Bonus from councils that do not have a Local Plan, so this further failure may result in a hit to services or increases in council tax. So, it is clear we need a good Local Plan and quickly.

But before we can move forwards it is imperative that we fix the management and governance failings that have led us to this unhappy place. It is simply untenable for the current incumbents to carry on as if nothing has happened.

The changes we need are:

  • Resignation of the entire LPSG from their positions to be replaced by a new group of senior councillors from a balance of rural and urban wards.
  • I’m sorry to say it, but the cabinet member for planning and leader’s position is untenable after presiding over such a comedy of errors.
  • Whoever authorised the change to the questions mid-way through the consultation within the “officer” side must at least be severely reprimanded.
  • Hart need to appoint an experienced project manager to run the Local Plan project who should immediately review it and put together a realistic scope, objectives, deliverables, resource requirements, costs and timelines, publish it, and offer it for scrutiny by a recognised project assurance organisation
  • Only when the revised evidence base (SHMA and Employment Land Review) has been published, should Hart run a new Regulation 18 consultation covering employment, retail, transport, infrastructure as well as housing distribution as per the advice from Peter Village QC. The consultation should be put together and run by a competent third party organisation.
  • A standalone brownfield approach, covering all current brownfield sites in the SHLAA, the Stonegate Report and any new zones of opportunity identified in the call for sites should be added to the consultation as per the request of the 2,130 signatories of the WHH petition. It is simply not credible to set a “deliverable” criterion for brownfield sites when almost all of the green field sites subject to consultation were “not currently developable”.  The council can’t have it one way for brownfield and another for greenfield sites. Many brownfield sites in the SHLAA/New Homes Booklet were “rejected” for apparently arbitrary reasons, they certainly did not appear to have more onerous constraints on them compared to those selected for consultation in Q6.
  • The differences between the site capacities shown in the New Homes Booklet compared to those in the official evidence base in the SHLAA (see point 4 in this letter to councillors, dated 20 November 2015 and Appendix) need to be rectified.
  • The process of the consultation needs to be simplified and improved, with the weighting system being resolved and published before the consultation starts.
  • The risks of a new town and urban extensions should be properly laid out (including creating capacity to take 3,000 houses from Rushmoor and Surrey Heath and the infrastructure costs).
  • All of the SHLAA sites should be offered for consultation in Q6, and the ranking approach changed to something more objective and able to be analysed across parishes such as “strongly oppose, oppose, support, strongly support”. It should be possible to pass comment without ranking sites that you don’t agree should be developed. It was particularly odd to see that the NHB rejected sites that had appeared in Neighbourhood plans.
  • You might do well to review my suggested 5-point plan that I tried to put to council in the Summer, but my question was censored.
  • The different infrastructure contribution regimes for different styles of development should be properly explained: a certain cabinet member was spreading misleading information about this during the recent consultation. My understanding is that only office conversions attract no S106/CIL whereas brownfield redevelopment is subject to the same contribution regime as green field development. It should also be explained that new homes in vacant office blocks attract council tax (and new homes bonus), which HDC retains, rather than business rates much of which is surrendered to the Government.
  • There also needs to be more robust processes for verifying the identity of all those participating in the consultation, and proper rules set on who can and cannot comment: theoretically the consultation just abandoned could have been answered by babes in arms in Aberdeen which is clearly ridiculous.

Only root and branch change of process and personnel will restore confidence and give enough credibility to create a sporting chance of getting a good Local Plan on time.

Press release is available for download below, together with a carousel of pictures of our shot demo outside Hart Offices.

Response to Hart’s decision to abandon the consultation

 

 

Protest at Hart Council's Offices about the consultation shambles

Protest at Hart Council’s Offices about the consultation shambles.

Protest at Hart Council's Offices about the omnishambles Consultation

Protest at Hart Council’s Offices about the omnishambles Consultation

Protest at Hart's Offices about the Consultation farce

Protest at Hart’s Offices about the Consultation farce

Protest at Hart Council's Offices about the consultation fiasco

Protest at Hart Council’s Offices about the consultation fiasco

Protest at Hart Council's Offices about the Consultation farce

Protest at Hart Council’s Offices about the omnishambles Consultation.

Protest at Hart Council's Offices about the Consultation shambles

Protest at Hart Council’s Offices about the omnishambles Consultation

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