Local Plan: Brownfield sites protected from redevelopment

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

Brownfield sites protected from redevelopment

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

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

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

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

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

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

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

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

Poor brownfield sites should not be protected from redevelopment

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

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

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

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

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

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

Please respond to the Local Plan Consultation

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to 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

FOI request reveals Winchfield failed testing

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

Flood risk means Winchfield failed testing

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

In summary, the main issues were impact on:

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

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

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

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

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

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

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to 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

Detail of how Winchfield failed testing

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

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

Winchfield Strategic Assessment - Flood Risk 1

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

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

Winchfield Strategic Assessment - Flood Risk 2

Winchfield Strategic Assessment - Flood Risk 3

Winchfield Strategic Assessment - Flood Risk 4

Winchfield fails testing – Strategic Assessment

Conservatives ousted from power at Hart Council

Breaking News: Conservatives ousted from power on Hart Council

Conservatives ousted from power at Hart Council

In a dramatic move the Conservatives have been ousted from power at Hart Council. Even though they are the largest party, they hold only 14 of the 33 seats.

The joint Chief Executive, Patricia Hughes confirm the move in a tweet last night. Liberal Democrat party group leader Dave Neighbour has been elected as leader of the council. He announced the members of his cabinet, but not the respective portfolios. They will be councillors Ambler, Bailey, Cockarill, Collett, Oliver, Kinnell, James Radley. All these councillors are from the Liberal Democrats and CCH. This confirms there will be no places for the Conservatives.

[Update – Portfolio positions announced by Hart Council]

  • Cllr David Neighbour – Leader and Cabinet Member for Finance
  • Cllr James Radley – Deputy Leader and Cabinet Member for Services
  • Cllr Simon Ambler – Cabinet Member for Partnerships
  • Cllr Stuart Bailey – Cabinet Member for Housing
  • Cllr Graham Cockarill – Cabinet Member for Planning
  • Cllr Adrian Collett – Cabinet Member for Regulatory and Community Safety
  • Cllr Sara Kinnell – Cabinet Member for Leisure, Health and Wellbeing
  • Cllr Alan Oliver – Cabinet Member for Contracts

[/Update]

Liberal Democrat, Gerry Crisp will become chairman. The deputy chair position will be taken by Wendy Makepeace-Brown of CCH.

We understand the following people have been elected as chair of the various committees:

  • Chris Axam (CCH) – 5 councils partnership
  • Gill Butler (CCH) – Licensing
  • Graham Cockarill (Lib Dem) – Planning
  • Ken Crookes (Conservative) – Overview and Scrutiny
  • John Kennett (Conservative) – Staffing
  • Wendy Makepeace-Brown (CCH) – Audit

The council coup has been facilitated by the defection of two Tory councillors, Sara Kinnel and Richard Woods to CCH late last year. We do think that changes of party allegiance should lead to by-elections. Where such ‘crossing of the floor’ leads to a change in administration, the case for by-elections is unanswerable in our opinion.

We are yet to see what impact, if any, there will be on the Local Plan.

Hart Draft Local Plan Consultation – Our Response

We Heart Hart Campaign Logo

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

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

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

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

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

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

 

Response to the Hart Draft Local Plan Consultation

 

 

Independent Expert says Hart housing target is too high

Alan Wenban-Smith of Urban and Regional Policy blasts Hart housing target

Independent expert, Alan Wenban-Smith has reviewed the latest Strategic Housing Market Assessment (SHMA) and concluded that the Hart housing target is way too high.

Regular readers may recall that the same expert examined the previous version of the SHMA and came to similar conclusions.

The crux of his arguments are as follows:

  1. The SHMA uses an inappropriate start-point for analysis. It uses the 2012-based population projections instead of the more up to date 2014-based projections. Making this change would knock around 850 houses off the start point
  2. The adjustments made for so-called market signals and affordable housing are inappropriate.
  3. The massive upwards adjustment for alleged jobs growth would result in loads more people moving to Hart. These people would then work elsewhere which is contrary to the sustainability principles of the National Planning Policy Framework

Taken together, his suggested adjustments would reduce the Hart housing target from around 8,000 to around 4,500. We have already built or planned more then 4,500 houses, so the Local Plan would become irrelevant.

We do not quite agree with all of his conclusions. If it were up to us, we would add some extra social rented housing to help those who cannot afford to even rent their own home.

But nevertheless, it is astonishing that Hart Council has decided to add a further 2,000 houses on to the already inflated SHMA. Hart’s approach is putting unnecessary pressure on our valuable green fields.

We will be compiling our suggested responses to the Local Plan consultation over the next few days. Please do keep checking in as we add further content.

The full report from Alan Wenban-Smith on the Hart housing target can be downloaded from the button below.

Independent Expert critique of Hart SHMA

Motion of No Confidence in Hart District Council submitted

Breaking News: Motion of No Confidence submitted in Hart District Council

Motion of No Confidence submitted in Hart District Council

A motion of no confidence in Hart District Council has been submitted by Community Campaign Hart (CCH), (or as some call them Completely Concrete Hart) and the Liberal Democrats.

Apparently, they are unhappy that a new settlement at Winchfield has not been included in the Local Plan. They plan to push for Winchfield to be re-included if they manage to take over.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

We think this is a bad idea for a number of reasons:

  1. This will add extra delay to the Local Plan process, adding to the risk that sites like Grove Farm (Netherhouse Copse) and Pale Lane (Elvetham Chase) will be given the go ahead at appeal before the Local Plan can be put in place
  2. Winchfield has failed testing. The main issues with the proposal are:
    • groundwater and surface water flooding,
    • Cost of new road infrastructure and the need to travel to Fleet for main services
    • requirement for new wastewater treatment works
    • too much delivery risk concentrated in one site
    • impact on landscape
    • impact on heritage assets and SSSIs
  3. CCH have completely failed to oppose the main issue: we are being asked to build too many houses. Hart Council have arbitrarily added an extra 2,000 houses to the already inflated SHMA figure of 8,000, giving a total over 10,000 houses. Tackling this would mean we don’t need a new settlement at Winchfield or Murrell Green, nor would we need Pale Lane or Grove Farm
  4. A new settlement at Winchfield will likely have a major impact on congestion in Church Crookham and the western edge of Fleet.

We predict a stormy council meeting on 25 May.

[Update  – Statement from Conservative Council Leader]

Conservative Council Leader Stephen Parker commented:

We have a clear track record of success in running Hart Council. Despite cuts to Hart’s government funding we used Conservative ministerial contacts to reduce the cuts, froze Council tax for 6 years and made minimum increases for the last two years. At the same time we made innovative partnerships to make sure that no cuts were made to our services or to our support to the voluntary sector. We delivered the new Hart Leisure Centre, a superb facility which pays for itself with no increases to Hart’s Council tax. We listened to residents in making our Local Plan which maximises use of brownfield sites and protects our towns and villages from unwanted expansion. At no time in the last eight years of Conservative leadership have they challenged any of these successes. Residents will no doubt look forward to reading their joint manifesto.

[/Update]

[Update 2 – statement from CCH]

Statement about motion to bring about a vote for Council Leader

Until fairly recently Hart District Council had a democratic process of electing the council Leader every year at the AGM. This right was taken away by the then Conservative administration, presumably because they realised that as is the case now there would be times when they did not have a majority on the council.

The Conservatives forced through the instigation of a 4 year term for the council Leader, the maximum period they could have gone for without falling foul of legislation.

Out of 33 councillors there are 14 Conservative, 10 Community Campaign, 8 Lib Dems and 1 Hook Independent. No one party have the 17 councillors required to hold a majority on the council.

The Community Campaign have asked the current Leader if he’d be willing to continue as Leader with a proportional Cabinet made up of 3 Conservatives, 2 Lib Dems and 2 Community Campaign members. Given the proportionality of such a Cabinet it does not seem to be an unreasonable request.

We await his response. However, should the Conservatives not wish to work with a cross party partnership then we believe that the Council should have the right to elect a new Leader.

The nature of the council’s constitution is such that in order to bring about the opportunity to elect a new Leader a motion to withdraw support for the current leadership needs to be lodged 7 clear working days before the council’s AGM.

The full motion moved by Cllr. James Radley of the Community Campaign reads;
The council wishes to use this AGM, as it represents the traditional point in the municipal year, to undertake a vote for the leader of council. To bring about such a vote the constitution requires that a vote to remove the current leader first be tabled. To this end this council retracts support for the current leader and does so as required by the constitution by voting to ‘remove from office the current Leader of the Council and agrees that a new Leader should be elected forthwith’.

[/Update 2]

[Update 3: Lib dems tweet to say they don’t support new settlement at Winchfield]

NE Hants Lib Dems statement about Winchfield

[/Update 3]

Health and Safety Executive criticises Hart Council

Health and Safety Executive (HSE) Logo

Health and Safety Executive (HSE) Logo

The Health and Safety Executive (HSE) has criticised Hart District Council for not clearly marking on a map the Major Accident Hazard pipelines that pass through the district.

Regular readers will recall that the Master Plan for the proposed new settlement at Murrell Green does not refer at all to the high pressure gas main that runs through the site.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

We alerted the HSE to this and invited them to comment on the Draft Local Plan that is currently out for consultation. They have written to Hart Council and identified two further potential issues:

We have concluded that there is the potential for land allocated in your plan to encroach on consultations zones.  The land allocations that could be effected (sic) are as follows

Map 30 – Murrell Green (Proposed Strategic Housing-led Development Policies SC1-SC4)

This allocation encroaches on the Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067 Gaston Wood/Murrell Green(PO65)

It also has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7069 Crockmore Farm/Bramshill(P067)

Map 7 – Eversley Centre – SC5

This allocation has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7083 Bramshill/The Devil’s Highway(P086)

The HSE then go on to spell out their recommendations for how local authorities should identify such hazards in their Local Plans (emphasis ours)

Identifying Consultation Zones in Local Plans

HSE recommends that where there are major hazard establishments and MAHPs within the area of your local plan, that you mark the associated consultation zones on a map. This is an effective way to identify the development proposals that could encroach on consultation zones, and the extent of any encroachment that could occur. The proposal maps in site allocation development planning documents may be suitable for presenting this information. We particularly recommend marking the zones associated with any MAHPs, and HSE advises that you contact the pipeline operator for up-to-date information on pipeline location, as pipelines can be diverted by operators from notified routes. Most incidents involving damage to buried pipelines occur because third parties are not aware of their presence.

Clearly Hart Council has failed to follow Health and Safety Executive Guidelines.

The full letter from the HSE can be found here.

Hart Council launches Local Plan consultation

Hart District Council Logo

Hart Council has launched a Regulation 18 consultation into the draft Local Plan. The consultation will be open until 5pm on 9 June 2017.

Drop in sessions will be running at the following dates and locations:

  • Tuesday 2 May – 2pm to 8pm – Hook Community Centre, RG27 9NN
  • Wednesday 3 May – 2pm to 8pm – The Harlington Centre, Fleet, GU51 4BY
  • Monday 8 May – 2pm to 8pm – Victoria Hall, Hartley Wintney, RG27 8RE
  • Wednesday 10 May – 2pm to 8pm – The Tythings, Yateley, GU46 7RP
  • Thursday 11 May – 2pm to 8pm – Ridley Hall, South Warnborough, RG29 1RQ
  • Monday 15 May – 4.30pm to 8pm – Hawley Leisure Centre, GU17 9BW

The consultation materials can be found here.

Once we have had chance to absorb all the materials, we will be posting our advice on how to respond to the consultation.

Does High Pressure Gas Main scupper Murrell Green proposals?

Murrell Green High Pressure Gas Main

Murrell Green High Pressure Gas Main

As regular readers will know, as part of the Hart Local Plan, the local council is proposing a new settlement at Murrell Green. However, they don’t seem to have taken the high pressure gas main that runs through the site into account in their planning.

The site appraisal makes no mention of the gas main. However, the schematic above, obtained from SGN, who manage the gas mains in this area, shows a high pressure gas main, of 24″ diameter. It is described by the Health and Safety Executive (HSE) as a Major Accident Hazard Pipeline. It appears to cut a swathe through the proposed housing and the site of the proposed school shown in the schematic below.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

After reviewing the HSE guidelines we have come to the conclusion that major housing and a school will not be allowed to be built within approximately 100m of the pipeline. This would put a major question mark over the viability of the proposed scheme.

Murrell Green High Pressure Gas Main size 24"

Murrell Green Gas Pipeline size 24″

Full analysis below. This new information comes on top of the environmental, infrastructure and coalescence issues we raised here before.

We have had a response from Hart Council:

Head of Planning at East Hants, confirms that that the pipeline was considered alongside a number of other constraints to development. It is a known constraint which will need to be taken in to account in any master plan for the new settlement along side other constraints which have been identified in the consideration of all the sites through the SHLAA process and after. It is not however seen as any form of ‘show stopper’.

It does seem odd that planning to build a school and significant housing right on top of a 24″ high pressure gas main is not considered a ‘show-stopper’. However, we can find no mention of the pipeline in the latest assessment of rural sites covering SHL136, 167 and 186.

HSE guidelines on building near gas pipelines

The HSE has special guidelines for planning near to such installations.

First, various zones around the pipeline are established. An inner, middle and outer zone.

Consultation Distance for pipelines

We don’t know the exact size of the zones for the Murrell Green pipeline, but by way of example, the zones at Upchurch were established as:

  • Inner Zone: 9m
  • Middle Zone: 95m
  • Outer zone: 110m

According to the letter from SGN, the inner zone for the Murrell Green pipeline is 8m.

SGN Letter regarding Murrell Green High Pressure Gas Main

SGN Letter regarding Murrell Green High Pressure Gas Main

So, it is reasonable to assume the middle and outer zones will be roughly the same as those at Upchurch.

The next stage is to look at the type of development and assign a sensitivity. Housing developments over 30 units are assigned level 3.

Housing Sensitivity to gas pipelines

Housing Sensitivity

Schools, with a development size of more than 1.4Ha are assigned a sensitivity of 4.

School sensitivity zones

School sensitivity

Then a decision on whether development of various sensitivities is allowed in the various zones is made according to a matrix:

PAHDI Sensitivity and decision matrix

PAHDI Sensitivity and decision matrix

It is clear that major housing would not be allowed in the Middle Zone and a large school would not even be allowed in the Outer Zone.

Conclusion about Murrell Green High Pressure Gas Main

Our conclusion from this is that the school would not be allowed within around 100m of the pipeline, and so would have to be moved from the proposed position. It is highly likely housing would not be allowed within about 90m of the pipeline. This would create a no-go zone right through the centre of the proposed development and probably render it unviable.

Time to think again Hart Council.

 

Hartland Village Planning application submitted by St Edward homes

Hartland Village (Pyestock) Master Plan

Hartland Village (Pyestock) Master Plan

A planning application for Hartland Village has been submitted by St Edward Homes.

Details can be found at Hart’s public access system using reference 17/00471/OUT.

We are broadly supportive of this application, but would echo a number of the objections that have been made:

  1. There should be greater provision for affordable homes. The application is for 1,500 new homes in total. Provision has been made for 195 social rented units and 105 intermediate units. Given the council has increased our housing allocation to 10,000 on the basis of needing more affordable housing, the application should not go ahead unless at least 600 units are affordable or starter homes.
  2. There should be more provision for cycling and walking to Fleet station and the town centre. It would be helpful if a new bus service was also provided, perhaps along the lines of the Hartley Wintney Community bus.
  3. More investment will be required in the local road network to make this development work. We would suggest Kennels Lane needs a significant upgrade.
  4. Specific provision needs to be made for a local health centre and dental practice.
  5. We need a definitive answer from Hampshire County Council on whether a new secondary school is required in Hart or not. If so, it should be provided on this site, which is where the bulk of new children will live.
  6. As is the case with any new development in Hart, the mainline train route to London needs to be significantly upgraded, including stations and parking.

We would urge everyone to make their voice heard in this important consultation.