Hart Local Plan: Remove brownfield restrictions

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

Hart Local Plan restricting redevelopment of sites like this

This is the third part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains how Hart’s policies are restricting brownfield redevelopment and why they must remove policy ED2, change their SANG policy and remove their Article 4 direction on Permitted Development Rights.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations). A copy can be downloaded here.
  4. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan restricts brownfield development

Policy ED2 relates to safeguarding employment land and Para 297 refers to SANG owned by the council.

Policy ED2 protects essentially every major employment site in the district from redevelopment.

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

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

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

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

We believe this is contrary to Government policy.

Remedy: Consequently policy ED2 should be removed.

Moreover, the Inspector should be aware that the council has implemented a new policy regarding SANG that effectively further obstructs brownfield development. This is already blocking schemes that would provide homes that ordinary people can afford (as distinct from Affordable Homes that ordinary people can’t afford). The schemes affected are a conversion on Ancells Farm and proposals to redevelop the old police station in Fleet town centre. It has been suggested that this SANG policy may be unlawful.

In addition, Hart has commenced work to implement an Article 4 direction to block permitted development on brownfield sites.

In effect they have set some nice sounding objectives about protecting our historic assets and building green infrastructure, but their policies act against their objectives and actively create a worse place to live by leaving decrepit buildings to rot and scar the landscape.

We think the Inspector should also take a view on these policies since they are closely related to the Local Plan, even though they are not contained within it.

Remedy: We believe that the SANG policy and the Article 4 direction should be removed

Hart Local Plan: Amend Policy SS1 to a sensible housing target


This is the second part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains why we are planning to build too many houses and why Policy SS1 needs to be amended to a more sensible target. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations). A copy can be downloaded here.
  4. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry
Policy SS1 deals with the spatial strategy. We disagree with the quantum of new housing proposed in the draft Local Plan.

First, the numbers proposed are far too high and they are unsustainable. Second, the long term effect of planning for too many houses is that the initial effects are compounded, leading to permanent unsustainability.

Proposed numbers in the Hart Local Plan are far too high and unsustainable

They propose 6,208 now homes over the plan period at a rate of 388dpa. This is both unnecessary and undesirable on a number of grounds:

The 2016 SHMA called for 8,022 new dwellings over the period 2011-2032. This was already too many.  For reasons explained in more detail here:

  • The starting point was inappropriate, using 2012 DCLG forecasts instead of the 2014-based figures.
  • The affordable housing uplift was inappropriate because it was proposing to help those already renting but not able to buy. By definition, these people are already housed and therefore do not need an additional house to be built. Any arguments about building more houses increasing supply and thus reducing prices are spurious because any reasonable expectation of building will have only a negligible impact on prices. This is explained by Ian Mulheirn of Oxford Economics here.
  • The jobs growth adjustment was inappropriate, anticipating higher rates of jobs growth than seen in periods of much higher economic growth. The SHMA then acknowledged that most of the extra people brought in by these extra houses will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

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

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

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

Clearly, this uplift was not an expression of the ‘need’ for the district. More importantly, building extra, unnecessary houses will then cause more people to move into the district. Because the employment space is sub-standard and not in a strategic location, these people will commute elsewhere each day to work. This is the very antithesis of sustainable development.

I think these arguments make clear that the target of 8,022 houses over the old plan period of 2011-2032 was unsound and unsustainable. This is further borne out by the analysis of Alan Wenban-Smith.

The current draft Local Plan calls for 6,208 houses to be built over the period 2016-2032. Hart built 1,830 houses over the period 2011-2016. This makes the total target over the comparable period 8,038 houses. This is more than the prior target in the SHMA despite the new Government method for calculating housing need showing a much slower rate of building being required. This is also unsustainable for the same reasons as above.

Hart housing completions for the Hart Local Plan Regulation 19 Consultation

Basically, the council have found a way of arbitrarily adding back unnecessary houses without even the fig leaf of the flawed justifications used in the prior SHMA.

Their current proposal is for 6,208 houses or 388 dpa over the period 2016-2032. This is made up of the Government target of 292dpa. This figure itself is made up of the raw DCLG household projections plus an agreed ‘affordability uplift’ because Hart’s house prices are very high. They then remove the 40% cap on the affordability uplift and add and further 25% uplift to the result.

Hart Housing Numbers

Their justifications for the 25% uplift are:

  • Contingency against increase. I would suggest that adding to the housing target is an inappropriate way of dealing with this issue. It would be more appropriate demonstrate there is flexibility in housing supply to meet potential additional demand, rather than add extra demand without knowing it is there.
  • Affordable housing delivery. This has already been accounted for in the 292dpa Government figure. In any event, as discussed above, building more won’t make a significant difference to house prices, and so won’t make houses any more affordable for people already living here, so it’s a spurious argument.
  • Previously developed land. We have no idea what this means.
  • Buffer against non-delivery. Again this is a spurious argument. The way to deal with this issue is to demonstrate flexibility in supply, not add additional demand.

Taken together their reasons are spurious and do not stand up to any sort of scrutiny.

Faster building doesn’t make prices more affordable

As an aside, the actual rate of building in the period April 2011 to March 2016 is 1,830/5 = 366 dpa. This is well above both the raw demographic change in the Government household forecasts (208dpa) and the 292dpa rate to take account of the affordability uplift. We are constantly being told that we should be building ~250,000 houses per year across the country, and the 292dpa is Hart’s share of that. So, it would appear that Hart’s rate of house-building is also well above the pro-rata rate of house-building in the rest of England and Wales as we are constantly being told that the country isn’t building enough houses. According to the theory, this rate of over-building ought to result in at least a relative reduction in prices compared to the rest of the country.

However, examination of Land Registry data from April 2011 to March 2017 returns an interesting result.


Average House Price April 2011 Average House Price March 2017

% Increase





England and Wales           172,921







Despite having a very high rate of building, compared to the rest of the country, house prices in Hart have risen much more quickly. This effectively nails the lie that building more will effectively make houses more affordable.

Compounding effect results in permanent unsustainability

The new Government methodology to calculate housing need uses the latest demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings. Overall, they come up with a national target that is in-line with the anticipated future needs. It follows that if councils deviate significantly from these proposals, that overall demand and supply will be out of balance.

We argue that not only is Hart’s proposed housing number unsustainable in its own right, but that this unsustainability will be projected into the future ad infinitum. This is clearly an absurd result that needs to be challenged. This is illustrated below, using figures from the previous Reg 18 consultation, but the concept remains sound.

When the prior Hart Local Plan was calling for 10,185 houses to be built, we carried out some modelling  to work out how the unsustainable rate of growth would be affected by reapplying the Government methodology at five year intervals from 2016.

Essentially, the Government figures work by projecting forwards the trends of the previous five years, to arrive at a household projection estimate. An affordability uplift is then applied to this result to generate the building rate required for the subsequent period. In areas with high house prices, like Hart, because building more will have negligibler impact on prices, the affordability uplift would be essentially compounded at each five year review point.

This could end up leading to massive increases in unnecessary housing requirements towards the end of the plan period. This will apply regardless of the starting point. However, if the starting build rate is artificially inflated, then this too will continue to be compounded into the future. We will be faced with still more housing, more people migrating into Hart and then working elsewhere. This is again the very definition of unsustainability.

An example of how this worked with the prior Local Plan housing target of 10,185 is shown in the chart below.

Hart housing requirement using Local Plan figures

Hart housing requirement using Reg 18 Local Plan figures

Essentially, it resulted in a rate of house-building that was more than double that set at the outset by the Government household projections. The effect will be less severe with the housing numbers proposed in the new Local Plan, but will nevertheless lead to significant, unsustainable over-building.

Therefore we believe that the starting point for the Local Plan should be no more than the Government’s target of 292dpa or 4,672 dwellings in total. Because it isn’t yet clear whether Surrey Heath can meet its requirement, we would be prudent and add a few hundred to this to give a round number total target of 5,100 houses.

Remedy to the Hart Local Plan: We would therefore suggest that policy SS1 be adjusted accordingly:

New Homes

Subject to the availability of deliverable avoidance and mitigation measures in respect of the Thames Basin Heaths Special Protection Area, provision is made for the delivery of at least 6,208 5,100 new homes (388 319 new homes per annum) between 2016 and 2032.

Hart Local Plan: Remove Policy SS3 to build a new town

We have finally pulled together our submission to the Regulation 19 Hart Local Plan consultation. This, the first of a series of article explains some of the reasons why Policy SS3 to build a new town should be removed.

The process for making a submission is as follows:
  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations). A copy can be downloaded here.
  4. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

Why should Policy SS3 for a new town be removed from the Hart Local Plan?

The most egregious part of the draft Local Plan is the proposal to include an unnecessary new town. This should be removed for the following reasons:

  • The new town is not required, even with the inflated housing numbers in Policy SS1
  • The proposal is unsustainable and undeliverable
  • The supposed sweetener of a secondary school is unnecessary and won’t be placed in a viable location
  • Will lead to coalescence with surrounding settlements
  • Breaks a number of the council’s own objectives elsewhere in the plan
  • It will hinder the much needed regeneration of our urban centres, in particular Fleet

The new town is not required

The housing numbers in the draft Local Plan are too high. Even if one assumes the housing numbers are correct, the council itself admits that the new town is not required.

Hart Local Plan Regulation 19: Hart say we don't need a new town

Not only that, the council themselves admit that the housing supply is under-estimated.

Hart Local Plan Regulation 19: Understated housing supply

And even this under-estimate does not include housing supply identified in the Winchfield and Hartley Wintney Neighbourhood plans.

The combination of the over-inflated housing demand numbers and the under-stated housing supply numbers mean that the new town simply is not required.

The new town proposal is unsustainable

The area of search identified in the Local Plan contains a very wide area, consisting of the areas known as Murrell Green and Winchfield.

Hart Local Plan Regulation 19: Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

We don’t need Hartley Winchook new town so why is it in the Local Plan?

The attempts at sustainability appraisals of the Murrell Green and Winchfield sites have been poor, but nevertheless have demonstrated some very significant weaknesses that cannot be overcome.

SHL167 SHLAA Map - Beggars Corner, Winchfield, Hart District, Hampshire

SHL167 SHLAA Map – Beggars Corner, Winchfield, Hart District, Hampshire

Let’s deal with Murrell Green first. Part of the site, known as Beggars Corner was the subject of a planning application for a Solar Farm. This was refused on the grounds that it would spoil the views from Odiham.  It is difficult to see how a 1,800 unit development would be any less intrusive than a solar farm. Moreover, that planning application identified that part of the Beggars Corner location is former landfill and some of it has unknown contents. This does not appear to be a suitable location on which to build new houses, or indeed form part of a SANG.

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

The sustainability appraisal conveniently did not cover this part of the proposed Murrell Green development.

Moreover, the SA did not manage to discover that there is a Major Accident Hazard Pipeline crossing the site.  Not only that, the developer’s proposal included a secondary school sited right on top of the pipeline. After examination of the HSE rules regarding such installations, I conclude that neither houses nor schools will be able to be built within up to 100m of that pipeline. I also understand that roads should not cross such pipelines either. See analysis here.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

When one adds in other constraints such as SINCs, proximity of a high voltage power line, the railway and the M3, it appears as though the Murrell Green part of the area of search is not suitable for large scale development.

Turning to the Winchfield part of the area of search, it should be noted that the Winchfield sustainability assessment had to be extracted from HDC by FOI request. It can be found here.

The first point to note is that much of land in the Winchfield area of search is not in fact for sale. This comprises the central swathe known as Talbothay’s Farm plus other areas. Immediately, this leads to the conclusion that it won’t be possible to plan for a coherent settlement if the central part is not available.

In addition, the main areas considered to be constraints in the SA report were:

  • Historic Environment
  • Bio-diversity
  • Landscape
  • Water Quality
  • Flood risk

More detail on this can be found here. Other spurious claims were made in the SA, such as the claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is building a wood-burning power station utilising locally sourced timber (p74). Such a plant would be extremely undesirable since burning wood produces more CO2 than burning coal, and none of the proposed master plans include such space for such a plant. Plus, of course, I don’t think many people would support chopping down Bramshill forest to fuel such a plant. This claim was used to indicate that Winchfield was somehow more sustainable than other potential locations.

They also claim that building 3,000 new houses, with associated traffic will somehow “reduce the
emissions of greenhouse gases and manage the impacts of climate change”. Again, complete and utter nonsense.

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

Winchfield Strategic Assessment - Flood Risk 1

This is of course complete nonsense. The detailed assessment also says there’s only a one in 30 year chance of surface water flooding. The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone. Evidence documenting the flood events can be found here (4 Jan) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie). I also understand that a similar area has flooded again in January 2018. These are obviously more than one in 30 year events.

The area east of Winchfield fared less well than Murrell Green in the sustainability assessment even with the grossly understated the flood risk. And of course there were other issues with Historic Environment, Bio-diversity, Landscape and Water Quality. It is difficult to see how this could deliver a significant number of houses.

The area west of Winchfield was ruled out of the sustainability assessment, because it is a more peripheral location relative to the train station, does not offer a central focus and is in close proximity to Odiham SSSI. It therefore offers little prospect of significant housing development.

It is clear that there are very considerable constraints even before considering the infrastructure problems.

Hart has not put together proper estimates of the costs of infrastructure; despite saying it would do so.

Hart Testing Commitment January 2015

We have made several estimates that can be found here, here and here. Essentially, if a new motorway junction is required, the costs will be in excess of £300m. If the new junction is not required, the costs will be at least £200m. A rough schedule of requirements includes:

  • Secondary school and three primary schools
  • New sewage works
  • Power station (as per SA)
  • Improved drainage
  • Re-routing or burying of electricity power lines
  • Railway station upgrade to extend platforms and car park (or relocate)
  • The bridges that carry the railway over Station Road, Taplins Farm Lane and Pale Lane will all need to be upgraded in some way
  • New big roundabouts at either end of the B3016
  • New smaller roundabouts from B3016 and A30 to the new town, new roundabout to join Pale Lane and the A323, new roundabout on A287/Crondall Road and at Pilcot Road/Hitches Lane
  • New or widened roads at Bagwell Lane, Taplins Farm Lane/Church Lane, Station Road, Pale Lane and Chatter Alley/Pilcot Road. Plus many ancient hedgerows will have to be relocated.
  • Potentially widening the A30 around Phoenix Green on the approach to artHHartley Wintney
  • New healthcare facilities
  • New sports and community facilities

If this is a 5,000 dwelling new town, with 40% ‘affordable’, the remaining market houses might be expected to generate £15-20K per unit of S106/CIL. This would amount to around £45-60m. This is well short of the funding requirement and therefore might be expected to make the existing infrastructure funding gap worse.

Taken together, it is difficult to see how such a new town could be either sustainable or viable. Indeed, it is notable that in the three years of this saga, with many Hart Council members being supportive and apparently developers becoming anxious, no planning application has been made. Perhaps that’s because the developers also realise this is a pipedream.

Secondary school unnecessary and not in a suitable location

A number of councillors have made a fuss about a new settlement bringing a new secondary school. The trouble with this is that they have yet to provide a shred of evidence that a new secondary school is in fact required.

Back in 2015, Hampshire’s forecast went as far as 2018 and they were predicting a surplus of places up to 2018. They also forecast a falling birth rate and a significant number of existing pupils attending Hart schools from outside the district.

In 2017, HCC published a new school place plan that showed an overall surplus of places in both secondary and primary schools up to 2021.

A recent letter from a Hampshire Councillor shows that 98% of Hampshire secondary pupils have been allocated a place at a school of their choice for the next academic year.

Hampshire schools keep up with demand

So, having established that a new school is probably not required, we must now address the proposals that have been put forward over the past three years for the sites of new secondary schools.

First, we had Barratts in 2014 putting up a proposal to place a new school right next door to an institution housing sex offenders.

Mildmay Oaks Hospital next door to proposed school

Proposed school next door to Mildmay Oaks Hospital that held escaped child sex offender

Then we had the proposal, described above to build a secondary school right on top of the high-pressure gas main running through the Murrell Green site.

More recently we have had another proposal from promoters of Winchfield which placed the secondary school directly under the high-voltage power lines.

Winchfield Garden Community Master Plan with pylons and powerline

Winchfield Garden Community Master Plan with pylons and powerline

If after three years of trying, they cannot find a suitable location for a secondary school, one does have to come to the conclusion that they never will.

In conclusion, it is apparent that we don’t need a secondary school, and none of the developers involved have managed to find a suitable location.


The area of search is very wide. It borders Hook to the west, Hartley Wintney/Phoenix Green to the north east and comes very close to the Edenbrook development and the proposed Pale Lane development to the east. The bulk of the proposal also comes very close to Dogmersfield.

In other areas of the Local Plan, the council have been quite assiduous in defining strategic gaps. They have produced no such gaps around the new area of search, nor to the east of Hook or anywhere around Hartley Wintney. Nor are any gaps proposed to the north west of Fleet.

Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

If they are allowed to go ahead with this area of search, unconstrained by strategic gaps, there is a strong risk that they will come up with proposals that lead to coalescence of our proud villages.

Breaks the Objectives elsewhere in the Hart Local Plan

Elsewhere in the Local Plan, Hart have come up with a number of objectives. These are reproduced below with my comments in bold on how these proposals break those objectives.

  1. To support the vitality and viability of the District’s town and village centres to serve the needs of residents. Adding a new settlement will draw retail traffic away from our existing urban centres, most notably Fleet, and lead to even faster degeneration of Fleet as a retail destination. This can hardly be described as supporting vitality and viability.
  2. To conserve and enhance the distinctive built and historic environment in the District including the protection of heritage assets and their settings. The proposed area of search includes a Norman church dating back to the Domesday Book and several SSSI’s including at Odiham and Basingstoke Canal. There are numerous other distinctive and historic buildings. Building a new settlement right next door to these valuable assets with neither conserve nor enhance the environment.
  3. To protect and enhance the District’s natural environment, landscape character, water environment and biodiversity, including ensuring appropriate mitigation is in place for new development to avoid adverse impacts on the Thames Basin Heaths Special Protection Area (TBHSPA).Building a new settlement in one of the most attractive parts of the district, containing many woodlands and hedgerows supporting much wildlife such as deer and kingfishers, used by many for leisure and recreation will actively damage the landscape and biodiversity.
  4. To provide measures for adapting to the impacts of climate change and minimising the contribution of new development to the causes of climate change, including reducing the risk of flooding by directing development away from areas at risk of flooding, and using opportunities offered by new development to reduce the causes and impacts of flooding from all sources. We have already established that the SA grossly under-stated the flood risk in the area known as Winchfield East, yet they are proposing to build on this area, directly against their stated objective.
  5. To promote healthy and sustainable local communities through protecting and enhancing community, sport, health, cultural, recreation and leisure facilities, and through the delivery of a multi-functional green infrastructure network across the District. We already have a multi-functional green infrastructure network in Winchfield used for recreation and leisure. Building on it will destroy it, again directly contravening their own objective.
  6. To maintain the separate character and identity of settlements by avoiding development that would result in their physical or visual coalescence. Again, we established the risk of coalescence earlier. This proposal, if implemented would effectively create a single urban conurbation from Hartland Park in the east, across Fleet and Hartley Wintney to Hook in the west. This is an appalling prospect, again directly breaking their own objective.

Remedy:  I would propose that Policy SS3 is removed entirely from the Hart Local Plan, and consequent amendments are made to SS1.

Local Plan: Is the new town an example of predetermination?

Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

Is the new town plan an example of predetermination?

Our research for the Hart Local Plan Regulation 19 consultation has thrown up the possibility that the inclusion of the new town is an example of predetermination. We hope to publish our response in full in the next few days, however, we thought readers might be interested in this analysis which is shown below.

If you are keen to get your submission completed, then you might find inspiration in the work of Hartley Wintney Preservation Society or the Winchfield Action Group. These can be found on the downloads below:

WAG Regulation 19 guide
HWPS Reg 19 Guide

The consultation runs from 9 February 2018 to 4pm on 26 March 2018. The whole suite of documents can be found here.

Now on to our Predetermination research.

Events in November 2014 that indicate Predetermination

Back in 2014, HDC conducted a consultation on housing distribution. This was a non-site specific consultation, with no reference to Winchfield in the Housing Development Options Consultation paper. The council then moved with undue haste to put a paper to Cabinet on 6 November and Council on 27 November where Winchfield was identified as the only option to be tested for a new settlement.

This process was challenged at the time, by amongst others by Hartley Wintney Parish Council. See here.

At the subsequent Cabinet and Council meetings, attempts were made to remove the words “at Winchfield” from the proposed Housing Distribution Strategy.

Housing Distribution Strategy November 2014

It is important to note that the removal of these words would not have precluded the testing of Winchfield. They would merely have opened up the possibility of testing other sites. Failure to remove those words amounted to a strong signal that the council were not open to considering suitable alternatives. Indeed, there was no attempt to even identify suitable brownfield sites that might meet some or all of our housing requirement.

The minutes of both Cabinet and Council show that amendments intended to open up other sites for testing failed.

Much debate happened at council. One councillor remarked that the “only option is Winchfield” and removing the words “in Winchfield” would give residents “false hope”.

This is backed up by contemporaneous email exchanges with councillors such as:

Winchfield is the only option - predetermination

Winchfield is the only option

Options running out imminently. Predetermination

Options running out imminently

Note that although they say they will look at other sites if they come up, they actually vote to exclude that possibility. Indeed some councillors seemed concerned that options to purchase the land may have been due to expire. Maybe this explains their haste to predetermine Winchfield as the sole option for testing.

2016: Draft Local Plan with no new settlement disappears and housing target increases

We understand that in December 2016, a draft Local Plan was produced that did not include a new town at Winchfield or anywhere else. The main reason for this is that despite earlier assertions that there just wasn’t enough brownfield capacity in the district, a planning application for 1,500 new homes on the former Pyestock site had been made. Moreover, a number of office conversions had appeared using Permitted Development Rights. This draft document was rejected by the Community Campaign Hart group and never saw the light of day. The Inspector may wish to request a copy of this document.

This draft was intended to meet the then current SHMA target of 8,022 new dwellings.

Shortly afterwards, it became apparent that the housing target would be increased by more than 2,000 houses. Many people thought the rationale for increasing the housing target by a further 2,000 units was spurious to say the least. However, this meant that it was no longer possible to meet our remaining needs through brownfield development alone.

Lo and behold, later in 2017, a new Regulation 18 consultation was published which included a new settlement at Murrell Green (much of which is in Winchfield Parish boundaries). The Sustainability Assessment test results for Winchfield had to be dragged out of the council using a Freedom of Information request. The SA results for Murrell Green conveniently overlooked the fact that a Major Accident Hazard Pipeline in the form of a high pressure gas main runs through the site. The site schematics included a school built right on top of the gas pipe.

Recent Developments that suggest predetermination

Since the 2017 Regulation 18 consultation, the Government have come up with new proposals to calculate housing need. These reflect much of the criticism we made of the previous attempts at the SHMA. These can be found here, here, here and here. These new targets result in a build rate required of 292dpa over the plan period from 2016-2032 and include an ‘affordability uplift’. Adopting this target would mean that Hart had already granted permission for more houses than is required over the plan period.

Yet, inexplicably, the council has decided to remove the 40% cap on the affordability uplift and introduce a further 25% uplift to give a resultant 388 dpa. Even this inflated target could be easily met without a new settlement. However, policy SS3 has included a new town area of search, even though even the Council admit it is not required (See here, slide 9).

Why a new settlement debunked predetermination

Given all of the history outlined here, it is difficult to come to any other conclusion than certain members of the council had predetermined that they wanted a new settlement and they wanted it at Winchfield. In summary, certain members of the council have frustrated all attempts to test other locations; they have even derailed versions of the Local Plan without a new settlement at Winchfield and ignored all opportunities to avoid concreting over many of the best parts of the district even though even they admit a new town is not required.

It is difficult to avoid the conclusion that certain members of the council had predetermined the outcome from the outset.


Hartley Wintney Preservation Society criticise new town in Hart Local Plan

Hartley Wintney Preservation Society blast new town proposal in Hart Local Plan

Hartley Wintney Preservation Society blast new town proposal in Hart Local Plan Regulation 19 Consultation

Hartley Wintney Preservation Society have criticised the proposals for a new town contained in the draft Hart Local Plan. Their full comments can be found in the download below.

They are concerned about the threat to Hartley Wintney represented by Policy SS3 New Settlement at the Murrell Green/Winchfield. This could lead to 3,000 homes at Winchfield and 1,800 homes at Murrell Green.

A summary of their arguments follows:

  1. The prior consultations about the Hart Local Plan that resulted in a preference for a new town are invalid because they were predicated upon much higher housing numbers that we now don’t need to achieve
  2. The proposed housing numbers are far too high, containing arbitrary uplifts to the new Government figures that simply are not required
  3. Even using the inflated housing numbers in the draft Hart Local Plan, the new town simply is not required, and the plan itself makes that clear
  4. The alleged funding for infrastructure for the new town will not materialise and won’t be enough to cover the costs
  5. Significant parts of the area of search are not suitable for housing, such as Murrell Green (gas main) and Beggars Corner (former landfill and planning permission for a solar farm already turned down)
  6. Lead to inevitable coalescence of Hartley Wintney with Murrell Green, Hook and the three hamlets that make up Winchfield
  7.  The new town proposals will starve Fleet of much needed funding and focus on regeneration

Please use these words as guidance for your own response, but try to rephrase the comments.

We will be publishing our own objections to the Hart Local Plan in the coming days. Stay tuned.

The consultation runs from 9 February 2018 to 4pm on 26 March 2018. The whole suite of documents can be found here.

HWPS Reg 19 Guide


The Harlington project finances don’t add up

The Harlington Project - financial challenges could Save Gurkha Square in Fleet Hampshire

The Harlington Project – Financial challenges

We have uncovered some financial challenges to the Harlington Project to build a new facility on Gurkha Square in Fleet, Hampshire. Sadly, we have found that Fleet Town Council’s numbers don’t add up.

In summary, it is unlikely the project as currently constituted would meet Government lending criteria, without a significant precept increase. Moreover, Fleet taxpayers are on the hook for further increases in the precept if costs were to increase by even a modest amount.

If you want to do something about this, please respond to the petition that can be found here.

Please also object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Here is detail of the facts as we understand them, that have led us to the conclusions.

First, just to remind you, Fleet Town Council (FTC), is currently proposing to borrow £10,424,200 over 46 years to fund the vast majority of the project cost. The current total cost is estimated at £11,024,200, including a 7.5% estimate of inflation and 5% contingency. They have committed to keeping the annual precept on Fleet residents at £412,000 per year.

The Harlington Project Financial challenges to build on Gurkha Square FTC precept commitment

The Harlington Project – Precept Commitment

Will the Government approve the loan for the Harlington Project?

FTC has stated that it will seek a loan from the Public Works Loan Board (PWLB) to finance the Harlington project to build a replacement building on Gurkha Square.   The PWLB does indeed make such loans, but each loan has to be approved by the Government. Not surprisingly, the Government has set guidelines on how much parish and town councils can borrow.

This leads us to the first challenge. The Government has said:

The amount that an individual council will be allowed to borrow is normally limited to £500,000 in any one financial year.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Government borrowing limit

The Harlington Project – Government borrowing limit

In short, FTC is proposing to borrow more than 20 times the amount that is normally allowed. Therefore, there must be a doubt that the loan will ever be made.

However, there is another challenge. In the current consultation on the prudential framework for capital finance of Local Government, maximum asset lives have been set. Freehold land gets a life of 50 years. Other assets have a maximum asset life of 40 years.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Maximum Asset Life

The Harlington Project – Maximum Asset Life

Eagle eyed readers will have spotted that the maximum term that the Government will allow for buildings is less than the loan term that FTC is proposing. It isn’t even clear that the Government would allow an asset life of 40 years for such a building. This must lead to FTC increasing the precept to finance the reduced loan term (see sensitivity analysis below). Therefore, before any further cost increases, FTC has already broken its commitment to local taxpayers – see below.

Sensitivity of the Harlington Project to Cost Increases

The current proposal from FTC of total project costs of ~£11m, with council needing to borrow £10.4m to fund the build. This project costs figure includes 7.5% provision for inflationary increases and a 5% contingency. Given that stage the project has reached, we think 5% contingency is very low.

Harlington Horror Show: costs escalate to £11m

The Harlington Project costs £11m

This is borne out by FTC’s discussions last year with a Design and Build contractor. This might have been a way of FTC off-loading the risk of cost increases to the private sector. Of course, they would have had to pay a premium to cover this risk. However, the cost estimate put forward by the contractor was ‘unacceptable’, so FTC have decided to go it alone with some support from Rushmoor Borough Council.

The Harlington Project Financial challenges to build on Gurkha Square risk of cost increases

The Harlington Project – risk of cost increases

So, a private company is not willing to risk its own money on there being no further cost increases. We therefore think further cost increases are a virtual certainty. A sensible contingency at this stage of design would be at least 20%. A sensitivity analysis of the costs shows:

The Harlington Project Financial challenges to build on Gurkha Square Sensitivity Analysis

The Harlington Project Financial – Sensitivity Analysis

  • To complete the project at the current cost estimate, with a maximum loan term of 40 years, would require a precept increase of 7.3%
  • If the total project costs increased by 10% (15% over the current baseline), then the precept would need to increase by 18.6%
  • A precept increase of 24.3% would be required if costs increased by 15% (20% over current baseline).

FTC is considering mitigation measures such as seeking a grant from the Arts Council. This would lead to them borrowing £8.5m. They would then have around £1.2m of headroom for cost increases before they would have to consider increasing the precept.

There is of course the risk that the fixed term interest rates that PWLB offer may rise between now and when the loan is offered.

Security of the Loan for the Harlington Project

It is worth pointing out that the loan from the PWLB is different to a mortgage.

With a mortgage, the bank takes security over the property. This means it takes the future value of the property seriously. The bank needs to ensure there will be value in the property if the borrower defaults on the loan.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Security over local tax

The Harlington Project financial challenges – Security over local tax

However, the PWLB takes a charge directly over the taxes raised by the town council, so it has no need to worry about the future value of the building being constructed. This means that if the building were to deteriorate over say, a 30 year period, Fleet taxpayers would still be on the hook to repay the loan, even though the building might be useless by then.

Be careful what you wish for.

See earlier posts:

Save Gurkha Square

The Harlington Horror Show


The Harlington Horror Show – public sector value destruction

The Harlington Fleet Horror Show of a Deal to replace it with a new building on Gurkha Square

The Harlington Horror Show in Fleet, Hampshire

We have done more digging into the plans to replace the Harlington in Fleet by building a new facility on Gurkha Square. We have uncovered the Harlington Horror Show. We believe these plans represent a massive destruction of value for taxpayers.

  • Hart taxpayers lose around £140K per year, and lose at least £1.2m of value in Gurkha Square. They might get some of the Views in return, but have to fork out maybe up to £500K to replace the lost parking spaces.
  • Fleet taxpayers gain Gurkha Square and a brand new £9.9m £11m building, that will cost them at least £26.6m £34.3m over a 45 58 year repayment period and they lose part of The Views. They might also gain parking revenue from the remaining car park. ***Stop Press: Costs now escalated to £11m***
  • Everybody gains another decaying building in the form of the old Harlington blighting the town centre for years into the future, with no plan and no money to do anything about it
  • There are no plans for the much needed wider regeneration of Fleet, and there are no plans to raise any private money to back the scheme.

It is difficult to see how these arrangements pass any sensible application of Government Value for Money principles. This is truly the Harlington Horror Show.

If you want to do something about this, please respond to the petition that can be found here.

Please also object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Here is detail of the facts as we understand them, that have led us to the conclusions:

The Harlington Centre Consultation

In 2017, Fleet Town Council (FTC) consulted on 3 options for the Harlington Fleet. The options were Repair, Refurbish, or Replace. The Replace option mean building a new facility on Gurkha Square car park. Of the 1,481 people who responded to the survey, 86% or 1,274 were Fleet residents. Of those Fleet residents, 53% or 675 people chose the ‘Replace’ option. FTC has taken this as a mandate to spend approximately £10 million to be raised from Fleet Council Tax payers.

The main issue with the consultation is that at the time, FTC did not even have a lease to operate within the existing Harlington and nor does it own the Gurkha Square car park. So, it held a consultation about two options that were not within its gift to deliver. It might as well have had a consultation about how many fairies we would like at the bottom of the garden.

Current position of the Harlington, Fleet

Currently the Harlington generates an operating loss of around £180,000 per year and this is expected to continue with the new facility.

Operating loss of Harlington Centre Fleet £180,000 per year. Harlington Horror Show

It was resolved earlier this year that the Joint Chief Executive in consultation with the Portfolio Holder for Services be authorised to enter into an interim short term ‘two year rolling’ lease for the Harlington with FTC. We don’t know the details of that lease.

HDC FTC short term rolling lease for Harlington Centre. Harlington Horror Show

Current position of Gurkha Square

It is understood that HDC own the freehold for Gurkha Square. Currently it generates between £108,000 and £130,000 of parking revenue. As an average, let’s assume £120,000 per annum.

Parking revenue for Gurkha Square. Harlington Horror Show

Back at the March 2017 Cabinet meeting the car park was worth between £750K and £1.3m.

March 2017 cabinet value of Gurkha Square £750K-£1.3m. Harlington Horror Show

More recently, at Overview and Scrutiny Committee the value was set at £575K. The reason for this mysterious loss of value hasn’t been explained.

New Gurkha Square value £575K. Harlington Horror Show

We think the valuation is on the low side. A continuing stream of parking income, which is likely to be rise in line with inflation each year, might be valued at a multiple of 16 or above. This would value the car park at nearly £2m.

An alternative approach might be to value it as development land with planning permission. The SHMA suggested development land in Hart is worth £4m per hectare. The site is approximately 0.3Ha. This would value the site at £1.2m. This might be considered conservative as it is a prime site in one of the most affluent towns in the UK.

We believe that Hart wants to replace the lost parking revenue. We understand that it has been proposed that there be a ‘land swap’ where HDC give Gurkha Square to FTC and in return, FTC give HDC part of The Views. Hart would then use that land to build new parking spaces. The Views are one of the last remaining green spaces in Fleet town centre. As green space, the land has essentially zero economic value, and probably comes with maintenance costs attached.

The Harlington Proposal

As we understand it, FTC is proposing to build the new facility on Ghurka Square car park at a cost of £9.9m. ***Stop Press: Costs now escalated to £11m***. There are no plans for what happens to the existing Harlington centre, and apparently no money either. It has to be presumed that Hart taxpayers will shoulder the costs of maintenance and security, meanwhile Hart residents gain another decaying building in Fleet.

Harlington Horror Show: costs escalate to £11m

Harlington costs escalate to £11m

It is envisaged they will take loan to cover the cost from the Public Works Loan Board. Under this arrangement, monthly payments would remain fixed, but the term of the loan might vary depending upon changes in interest rates or cost escalations. The current plan is that the repayment period would be 45 years. 58 years based on the new £11m cost. Would the building even last that long?

Harlington costs and repayment £9.9m and 45 years. Harlington Horror Show

FTC has committed not to increase the precept levied to fund this project above £412,000 per annum.

Harlington precept £412000 per year. Harlington Horror Show

It is not clear what will happen if costs or interest rates rise so that the monthly payments don’t cover the interest. A quick sensitivity analysis shows that if the interest rate increases to 4.3% or above, and/or costs escalate to £13.6m or above, then the precept will not be sufficient to repay the interest, let alone repay any of the principal. We know that interest rates are rising, and construction costs only go up between project idea and completion.

Harlington Gurkha Square Sensitivity Analysis. Harlington Horror Show

Taken together, FTC is commiting to spend the continuing operating loss of £180,000 per annum plus the loan repayments of at least £412,000 per annum for the next 45 58 years. This totals at least £26.6m £34.4m over the term, assuming no further cost overruns and no interest rate increases.

The Harlington Horror Show Deal

Putting this all together, we believe this proposal is a lose-lose deal for Hart and Fleet residents. Let’s take a look at the position of Hart and Fleet taxpayers.

Hart Taxpayers

On the revenue side, they lose approximately £120K in parking income each year from Gurkha Square. They also lose the costs of maintaining and securing the decaying Harlington building. This might amount to a total of around £140K per year.

On the capital side of the account they lose Gurkha Square at a value of at least £1.2m. However, they gain part of The Views, at an unknown value. Essentially, this has no economic value as greenspace, and will probably come with maintenance costs attached.

The revenue costs could be mitigated by building more parking spaces on The Views. It is unlikely that the costs, once additional roadworks and machines are included will give much change from £500K. The resulting spaces will then be in an inconvenient position and unlikely to generate much income.

Fleet Taxpayers

On the revenue side Fleet taxpayers commit to paying at least £412K per annum for at least 45 58 years, plus £180K per year subsidy, for a total cost of at least £26.6m £34.3m. They might also gain parking revenue from the remaining car park.

On the capital side, they gain Gurkha Square at a value of £1.2m. However, they lose part of The Views at unknown value. Of course they gain a brand new building at a value of £9.9m £11m.

Taken together, this is the Harlington Horror Show.



Save Gurkha Square

Save Gurkha Square in Fleet Hampshire

Save Gurkha Square

The purpose of this post is to alert you to the plans to build on the much-loved Gurkha Square car-park and support the petition calling for a referendum of Hart residents before planning permission is granted.

Save Gurkha Square Petition

The petition can be found here.

Gurkha Square proposal

Fleet Town Council has made a controversial planning application to build a new facility on Gurkha Square car-park. This can be found here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ ). This new facility is currently expected to cost around £9.9m to build.

This is to replace the aging Harlington centre that currently costs £178,300 to support each year. It is envisaged that this support cost will continue for the new centre. Additionally, Fleet residents will be asked to continue paying the £412,000 Harlington precept for 45 years to repay the loan. This assumes there is no escalation in building costs and no increase in interest rates. Hardly sensible assumptions.

At the time of writing, there have been 12 comments on the planning application and all of them are opposed to the proposal. One Hart resident has written:

When I found out about this and how little others living in Fleet knew about it I wanted to ensure that as Fleet residents you were made aware & could have a say in the future

Why is the Gurkha Square proposal a bad idea?

Regular readers will be aware that we are broadly in favour of redeveloping Fleet. So, we had to think long and hard about this proposal. We came down against it because:

  1. This removes much needed parking spaces from the town centre.
  2. Puts at risk the market and other community events.
  3. It is a poorly thought through proposal that isn’t part of a proper master plan for Fleet regeneration
  4. There is no plan to do anything with the vacant, decaying Harlington building or the rest of the underutilised complex.
  5. There is a risk that part of the Views will be concreted over to replace the lost parking spaces.
  6. Disrespects the Gurkha community by reducing the space dedicated to their support and sacrifice for the UK.
  7. This proposal has all the hallmarks of a doomed political vanity project.

Opaque financial arrangements for Gurkha Square transfer

The Gurkha Square car-park is currently owned by Hart District Council. In essence it belongs to all Hart residents. The financial arrangements related to the transfer of the car-park to Fleet Town Council are shrouded in mystery. They were discussed at Overview and Scrutiny Committee, but the key debate about finance was conducted in private.

We don’t think it appropriate that the transfer of assets between two public bodies should be conducted in secret. What we do know is that the Cabinet received advice that the value of the car-park is £575,000. Although it is unclear how this figure was determined. The site is approximately 0.3Ha and development land with planning permission is worth around £4m per hectare. One might expect prime development land in the town centre to be worth more. This would equate to a value of at least £1.2m, far in excess of the stated value.

However, we don’t know the basis on which HDC has agreed to transfer the asset. Some people fear they have agreed a much lower capital value, in exchange for a continuing income. But it seems odd they would rely upon an income from a facility that Fleet Town Council say will continue to lose £180,000 per annum. Moreover, the decaying Harlington Centre will revert to HDC, which looks like it will be a liability rather than an asset.

We think Hart residents should be consulted before ‘their’ asset is transferred to Fleet. Moreover, the financial arrangements should be transparent. Indeed, the deal as proposed may well be in breach of the Value for Money rules governing public bodies.


Please respond to the petition that can be found here.

Please object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Download the leaflet here:

Save Gurkha Square leaflet



Affordable homes blocked by Hart’s restrictive brownfield policies

Affordable homes blocked at Zenith House, 3 Rye Close, Fleet, Hampshire by Hart's restrictive brownfield policies

Affordable homes blocked by Hart’s brownfield policies

The delivery of 36 affordable homes is being blocked by Hart’s restrictive brownfield policies. Magna Group is seeking to convert Zenith House on Rye Close on Ancell’s Farm in Fleet into 36 relatively affordable properties, designed to retail at £175,000 to £300,000. But they are being blocked by Hart’s restrictive SANG policy.

The council has given its prior approval to the development. However, Hart is effectively blocking the development by refusing to allocate any of its SANG.

redevelopment of Old Police Station,Crookham Road, Fleet, Hart District, Hampshire being blocked by restrictive brownfield policies

Proposals to redevelop Fleet Police station being blocked by restrictive brownfield policies

We understand the same developer owns the old Fleet Police station on Crookham Road in Fleet and plans to replace it with 14 new dwellings. However, we understand the council planning officers have been instructed to refuse planning permission for even compliant proposals.

This has the effect of:

  • Restricting the supply of housing that would be affordable for many young people trying to get on the housing ladder
  • Adding extra pressure to build on green field land
  • Stopping the market dealing with the problem of the over-supply of dilapidated office blocks in the district

This policy is also blocking Ranil’s ideas for regenerating Fleet. His petition can be found here.

It transpires that Hart’s SANG policy may well be illegal. We understand that legal representations have been made that cast doubt on Hart’s SANG policy:

First the policy is clearly intended to frustrate the delivery of housing rather than to facilitate development.  The policy confers on the head of the regulatory services absolute discretion to allocate SANG but makes clear that SANG will not be allocated to any development unless the Council considers it to be acceptable.

That means that if Planning Permission is granted on appeal the Council will nevertheless use its powers in relation to SANG to thwart that development.

The policy may result in the Council preventing people from exercising the rights they have been granted by Parliament through the permitted development process. In effect the Council is removing a property right from them in breach of the terms of the Human Rights Act 1998.

Furthermore the Council is in breach of its duty to make proper provision to facilitate the delivery of housing.

It certainly looks like the council is setting itself up for more expensive legal battles.






Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council is seeking to block development of brownfield sites. It has put forward proposals to be discussed at the Planning meeting later today to implement an Article 4 direction to

Withdraw permitted development rights related to the change of use of offices, light-industrial units, and storage or distribution units to residential use within the Strategic Employment Sites and the Locally Important Employment Sites

This covers substantially all the brownfield sites in the district. We do have some sympathy for the view that simple conversion of office sites to residential is not good for the district. We much prefer complete redevelopment of these sites, so the provide higher quality housing and a better sense of place.

But the council’s approach is heavy-handed and sends a signal that they do not welcome brownfield development. Moreover, this approach will discourage the regeneration that our urban centres badly need.

The proposals call for:

  • Draft Article 4 Direction and supporting documents;
  • Give notice as soon as possible after a Direction has been made by local advertisement, site notice, owners and occupiers (unless reasons to justify not doing so);
  • Send a copy of the direction and the notice to the Secretary of State;
  • Notify the county planning authority;
  • Following the above, take into account any representations received; and
  • Confirm the Direction by giving notice as above and sending a copy of the confirmed direction to the Secretary of State.

They have to give 12 months notice of the implementation of the direction.  They identify as risks that:

  • Developers may make claims for compensation from a local authority
  • The proposals could result in a rush of applications before the rights are withdrawn, it is not
    possible to mitigate against this risk.

A more positive approach would be to put a policy in the draft Local Plan that unequivocally encourages  redevelopment of brownfield sites and give examples of the kinds of scheme the council would encourage.

Hart Brownfield sites in Employment Land Review

The other puzzling thing is that Hart’s own Employment Land Review identifies much of the employment land in the district as:

Lower grade stock for which there is limited demand and a large supply. As a result of limited demand. The poorer quality stock is remaining vacant for prolonged periods.

They say that:

The current over-supply of lower grade office accommodation is limiting investment in the refurbishment of such stock as low rent levels make such investment unviable.

To summarise, Hart is seeking to block the redevelopment of low grade office blocks, and there’s no hope of refurbishing these into high quality office accommodation. So it seems that we are going to be stuck with many of the eyesores in the photo carousel below. They really have gone through the looking glass.