There is a brownfield solution to Hart’s housing needs

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

Vacant Office at Ancells Farm, Fleet, Hampshire

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

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

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

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

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

So, how have we arrived at our conclusion?

Brownfield sites in the SHLAA

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

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

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

Sites not in the SHLAA

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

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

Conclusions

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

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

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

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

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

Lock, stock and two smoking barrels

lock stock and two smoking barrels

Lock, stock and two smoking barrels

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

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

Dear Messrs Daryl Phillips and Stephen Parker,

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

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

There are a number of components to this:

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

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

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

 

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

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

  1. Deliverable and developable sites not included

[updated with this note]

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

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

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

  1. Sites missing from NHB but in the SHLAA

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

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

 

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

 

  1. Discrepancies between capacity in NHB and SHLAA

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

 

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

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

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

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

  1. Range of meanings of “not currently developable”

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

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

  1. Lack of discussion about economics

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

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

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

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

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

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

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

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

See more at our consultation page:

link

Is housing capacity in Fleet really only 30 dwellings?

Housing Capacity of 30 units in Fleet Hampshire

Housing Capacity of 30 units in Fleet Hampshire

Hart Council has published a booklet as part of its forthcoming consultation setting out its estimate of housing capacity for each parish in the district.  There are a number of strange anomalies in that booklet, including stating the capacity of Bramshill to be zero, when there is the old Police College ripe for redevelopment and Elvetham Heath, again set to zero when Hart even identify a capacity of 45 homes in their main consultation document.

But the most egregious anomaly is the estimate of only 30 units in Fleet itself.  This misses out many brownfield sites that are ripe for redevelopment such as:

  1. The complex of offices that includes Admiral House, Flagship House, Hart Council Offices and the Harlington Centre that were identified and promoted by Fleet Future:
Vacant Office Admiral House, Harlington Way, Fleet, Hart District, Hampshire

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

Harlington Centre, Fleet, Hart District, Hampshire

Harlington Centre, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Hart District Council Offices

Hart District Council Offices

2. The derelict offices on Fleet Road, again identified by Fleet Future:

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

3. Fleet Police Station:

Old Police Station in Fleet, Hart District, Hampshire

Old Police Station in Fleet, Hampshire

4. The still vacant units on Ancells Farm that have not yet been taken up by Stonegate:

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

Vacant Office at Ancells Farm, Fleet, Hampshire

5. The 119-acre Pyestock (aka Hartland Park), which has capacity for thousands of homes and where development of a new warehouse has stalled:

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

 

It is ridiculous, and some might say negligent, that Hart Council should be promoting a new town at Winchfield and/or urban extensions in Fleet or Hook for the Local Plan when there is plenty of vacant and derelict land that could form a more sustainable solution. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Hart Council missing out key information about housing options

Hart District Council Offices

Hart District Council issuing misleading information about housing options

Hart Council has just published its new Housing Options paper in relation to the Local Plan, in preparation for running a consultation from November 23 2015 to January 15 2016. We believe the information contained in that paper is misleading for a number of reasons and have some suggestions on how you might respond to the consultation.  In summary the issues are:

  1. The SHMA is currently being revised and likely to reduce the housing need, so why are we being consulted on a housing requirement that is no longer valid?
  2. The SHMA has been challenged by an independent expert who says we don’t need so many houses.
  3. Hart’s estimate of brownfield capacity is way too low, and far lower than they said as recently as October 1 2015.
  4. Government rules have been changed to encourage more brownfield development and this paper makes no mention of this.
  5. The infrastructure costs of a new town are enormous, but the paper doesn’t clearly set out the economic consequences of the choices we make on housing options.

Housing allocation out of date

The housing need assessment is based on the current version of the Strategic Housing Market Assessment (SHMA), and they do not mention in the paper that the SHMA is currently being revised to take account of new Government population and household projections.  These new projections show a big reduction in forecast population from 322K used in the SHMA to 289K for the whole housing market area and a reduction of 1,602 in Hart household projections.  It seems reasonable to assume that Hart’s housing allocation will therefore fall, but this is not mentioned at all in the consultation paper.

SHMA is invalid

The Housing Options paper does not take account of the opinion of independent expert, Alan Wenban-Smith that the SHMA says we are being asked to build too many houses.  This means that the paper is asking us to consider how we might build houses that aren’t needed and is therefore invalid.

Estimate of brownfield capacity is too low

Back in November 2014, Hart Council said we had capacity for 750 dwellings on brownfield sites. Very few or none of those sites have been granted permission since then. At cabinet on October 1 2015, the joint-CEO of Hart Council said that he thought the brownfield capacity had increased to around 1,800 units. We said at the time we thought this was a low estimate and it could be in the range of 2,400-3,688. However, the new paper says that brownfield capacity is now only 400 units.  The paper pours cold water on the notion that the former police college at Bramshill can be re-developed, but who in their right mind would want to see a Grade 1 listed building start to decay, and who would want to preserve the hideous 1970’s accommodation blocks?  This is clearly a site ripe for redevelopment, and the environmental impacts should be low compared to the prior use of the site.  So, the question remains, what has happened to the other 1,400+ units and why aren’t Hart taking account of them?

Government has made brownfield development more attractive

The Government has also just relaxed the rules about building on brownfield sites to make it more attractive.  This makes it more likely that the brownfield capacity identified in the Stonegate report can be delivered.  The Hart paper fails to mention this. The paper also fails to mention that Hart has kicked off a process to identify even more brownfield sites across the district, but the results of that study won’t be known for some time.  It does seem odd to be so definitive about the so-called lack of brownfield capacity when there are so many positive developments underway.

Astronomical Infrastructure Costs

Hart have published some analysis to show the infrastructure requirements of a new settlement.  They haven’t been definitive about how much this would cost, but it would include a new motorway junction, significant changes to existing roads and bridges, a new sewage works, 4 new schools and a new railway station.  Our estimate of the cost of this infrastructure is £300m+.  A realistic expectation of the developer contribution for 4,000-5,000 houses would be £40-50m.  Hart already have an infrastructure funding deficit of £78m.  It is clear that we cannot afford the infrastructure costs of a new town, and that existing settlements would be starved of investment if it went ahead. The new housing options paper makes very little reference to the economics of development for any of the approaches it identifies.  Surely, we should know about the economic consequences of the housing options choices we make?

It is becoming increasingly clear that the housing options paper and the associated consultation is a pig-in-a-poke, but nevertheless as it is there we must respond to it.  It looks increasingly like a faction of the council is hellbent on concreting over large swathes of our countryside, despite all the evidence that we don’t need to.

We urge you to Vote against Approach 3 (a new settlement at Winchfield).  But when asked for any other comments, use this article to ask them to think again about brownfield. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Hart Council planners “lose” 1,400 homes from brownfield sites

Let's just make up the brownfield numbers

Let’s just make up the brownfield numbers

Back in October 2014, Hart District Council said we had capacity for around 750 new dwellings on brownfield sites.  Since then, a number of new sites were identified through the Stonegate Report and other sites such as Bramshill and Fleet police station came up.  This led the Council to say as recently as October 1, that there was capacity for 1,800 homes on brownfield sites.

However, Hart Council have now published a draft housing options paper on their website that says brownfield capacity is now only 400 units [Update: a later version of the same document now states brownfield capacity as 450 units, although this is lower than the official SHLAA estimates for the same sites].  It seems that over the past six weeks, it seems the planners have “lost” 1,400 houses.

As far as we know very few, if any, of the initial 750 units have been given planning permission since October last year.  We have made a FOI request to get to the bottom of it.

It remains a mystery where they have gone to, but one can only assume that there is a cabal of concrete campaigners in Hart who are determined to build on our beautiful countryside at the same time as they protect vacant and derelict office blocks In Hook, Fleet and all across the district. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

 

Community Campaign Hart takes aim at the Heart of Hart

Hart District Council takes aim at the Heart of Hart

Community Campaign Hart takes aim at the Heart of Hart

Community Campaign Hart (CCH) have published a new newsletter on their website that calls for a new settlement to destroy the Heart of Hart in Winchfield.

In their article they make criticism of We Heart Hart and the good residents of Winchfield, and come to the conclusion that the only viable option for delivering the housing we need is a new settlement of 3,000-5,000 houses in Winchfield.  In their article they make a number of assertions that we believe are false, and will now seek to correct them, point by point.  But first, it is important that we start with the areas where we agree with CCH.

Points of Agreement

CCH say:

Until Hart have an LDP which meets the approval of a Government-appointed inspector, developers are in effect able to build on almost any greenfield site they choose

We broadly agree with this, although as in the case of Hop Garden Road in Hook, sometimes common sense can prevail especially now that Hart has more than 5 years of land supply.  However, if CCH are so concerned about the lack of a Local Plan, they should work more closely with We Heart Hart and others to ensure that Hart Council takes proper steps to improve the management of the Local Plan project that has slipped its timescale by two years within two years.  They would do better to use their time at council meetings to ask questions about the local plan rather than seek to stifle difficult questions.

Points of Difference

1. CCH say:

There just isn’t enough brownfield land available to accommodate that number of new homes, unless we are going to build high-rise tenement blocks along the length of Fleet Road.

This is simply not true on a number of levels.  First, the council hasn’t even created a proper register of brownfield sites so it hasn’t properly assessed capacity.  Second, our own work has shown there’s capacity for between 2,438 and 3,688 units, compared to the remaining unsatisfied “need” of 2,900 given at the last cabinet.

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

Third, parts of Fleet Road are a disgrace to the district and should be redeveloped, not with tenements, but with mid-rise (say 3-4 storey) high quality apartments to help young people get on the housing ladder.  Finally, there is brownfield capacity all over the district including Ancell’s Farm, Bartley Wood, Pyestock, Bramshill and Guillemont Park.  They really should get out more and see all of the vacant offices around the district.

2. CCH say:

With a mainline railway station far closer to it than to any other new development in Fleet; with the option to integrate new roads onto the A30 and through to the M3; together with sufficient scale to fund three new primary schools and a new secondary school, Winchfield strikes many as being the best compromise

This is economic incompetence of the highest order.  The council’s own assessment of infrastructure needs points to costs of over £300m for a new town including the schools, but not including improvements to healthcare.  The ballpark estimate for developer contributions made by a senior Hart Councillor is around £40m.  There’s already a £78m infrastructure funding deficit in the district and £1.9bn across Hampshire.  Not only would a new town at Winchfield destroy green fields, it would destroy ancient hedgerows and put at risk SSSI’s and SINCs, but it would no doubt further increase congestion in Fleet and Church Crookham.

3, CCH say:

Consequently they have resorted to social media and other marketing techniques to promote the ‘wehearthart’ message.

However, their messaging is incomplete. They point to the council wishing to build a new town at Winchfield and seek to demonize anyone who may have reached the conclusion, however reluctantly, that a new town at Winchfield is the least worst solution out of an abhorrent set of options. They do not explain what the alternatives are, as the National Planning Policy Framework (NPPF) mandates that this level of housing must go somewhere within Hart’s borders

We do not see what is wrong with communicating with the public using social media on the serious issue of the Local Plan, particularly when the council gets its own facts wrong.  However, We Heart Hart has explained what the alternatives are at some length, and the CCH Chairman of the council sought to have questions that we raised to indicate a different path censored at council meetings.  The alternatives are:

a) Reduce the alleged housing need by challenging the SHMA, particularly taking into account the latest DCLG population forecasts that indicate a lower population in 2031 than assumed in the SHMA and the reducing ridiculous jobs forecasts.  CCH would do well to engage with this debate instead of seeking to censor it.

b) Explore the options for reducing the assessed housing need by exploring so called “policy on” options to protect the environment and ecology.  Note that Winchfield is beautiful countryside in its own right, but is also within the 5km zone of influence of the Thames Valley Heath SPA.

c) Properly get to grips with brownfield options by establishing a brownfield register, actively encouraging landlords to redevelop their derelict sites and exploring the use of Compulsory Purchase Orders on sites that have sat vacant for years with no apparent signs of progress (e.g. Hartland Park aka Pyestock).

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

CCH need to wake up, smell the coffee, listen to Ranil Jaywardena and use their talents to establish a different vision to protect the countryside they profess to love rather than coming out with incomplete, inaccurate nonsense.  Be careful who you vote for in next year’s local elections.

This story now covered in the local press, see here.

Remaining Hart District housing target can be met from brownfield sites alone

Vacant block at Bartley Wood in Hook, Hampshire

Bartley Wood Estate in Hook

New facts have come to light since Hart Council planning department put together their estimate of brownfield capacity which show that Hart’s remaining housing target can be met from brownfield development alone. Please support us in getting a brownfield only option included in the forthcoming consultation by attending the Hart Cabinet on 1 October where Hart’s response to the We Heart Hart petition will be agreed.

Last November, the council’s estimate of brownfield capacity over the entire plan period was around 750 units (taken from parts 1 and 3 of the SHLAA as per the FOI request we made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.

Since then, a number of interesting things have happened:

  • An important study by Stonegate Homes has shown that brownfield capacity is much larger
  • Planning permission has been applied for or granted on other sites that were either not in the SHLAA or were not counted as brownfield sites.
  • New potential sites have come to light that were not included in the SHLAA
LocationNumber of Dwellings
Guillemont Park Phase 1 (not included as brownfield site in SHLAA) 150
Guillemont Park Phase 2320
Ancells Farm, Fleet370
Bartley Wood, Hook200
Fleet Road, Fleet220
Bramshill House350
Fleet Police Station50
Extra dwellings at Landata House28
Total1,688

All of the dwellings above were not included as brownfield sites in the SHLAA.  Guillemont Park (Sun Park) was in the SHLAA but for a smaller number of units, and was shown in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House, Hook for 28 more dwellings than were included in the 5 year land supply calculation.

The Bramshill House and Fleet Police station sites were not included in the SHLAA.

The Stonegate report identified 370 units at Ancell’s Farm in Fleet, 200 units at Bartley Wood in Hook and a further 220 units on Fleet Road in Fleet.

Derelict Offices in Fleet, Hampshire

Derelict Offices in Fleet, Hampshire

However, the proposals for Ancells Farm cover only 7 of the 23 office buildings in the business park which shows that there is additional capacity there.  Moreover, there are even more vacant office blocks in Hook so there is more capacity there too.  Of course, across Hart, Surrey Heath and Rushmoor, there is currently 500,000 sq m of vacant office space, and forecasts for even more vacancies, so there is no danger of restricting jobs growth by redeveloping offices.

If the original 750 units were to be added to the 1,688 units identified above, then that amounts to a total of 2,438 potential units on brownfield.  If it were possible to increase the density (from 30dph to a still reasonable 80dph in urban areas) on the original 750 units, the total identified capacity would rise to some 3,688 units.

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Moreover, these figures do not include the massive potential of the 119 acre Hartland Park (or Pyestock) site where planning permission for a big warehouse was given years ago, but no activity is visible.  Surely, the developers of this site want to earn some return on their investment and would change to residential.

The remaining requirement of 4,000 has of course been reduced by the unfortunate decisions to allow development at Watery Lane (300 units) and Hawley Park Farm (126 units) leaving the remaining allocation of at most 3,574.

It is clear that it is easily possible to meet the entire remaining of 3,574 from brownfield alone.  It will take some creativity and energy, but a combination of increasing density and allocating more vacant offices is easily within reach, so we don’t need a new town and can protect our countryside.

We have put proposals to Hart Council to include a formal brownfield option in their forthcoming consultation on the Hart Local Plan.  Please support us by coming along to the Hart Cabinet on 1 October where Hart’s response to the We Heart Hart petition will be agreed.

Petition Response: Make the most of brownfield land

Old Police Station in Fleet, Hart District, Hampshire

Old Police Station in Fleet, Hampshire

As we posted earlier, we have submitted the We  Hart petition with 2,130 responses to Hart District Council and the council have set out the process by which they will consider the petition.

We have drafted some suggestions as to how the council should respond  and sent them to Council leader, Stephen Parker.  We have a chance to put these ideas to Cabinet on 1 October at 7pm.  Please tell us if you are coming along to give us your support and please e-mail your councillors to ask them to support these proposals and incorporate them into the forthcoming consultation about the Local Plan.

The full set of suggestions can be found here.

The suggestions in this post relate to making the most of the brownfield opportunity.

Last November, the council’s estimate of brownfield capacity over the entire plan period was around 750 units (taken from parts 1 and 3 of the SHLAA as per the FOI request we made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.  Since then considerable progress has been made in identifying and in some cases granting permission on additional brownfield sites:

LocationNumber of Dwellings
Guillemont Park Phase 1 (not included as brownfield site in SHLAA) 150
Guillemont Park Phase 2320
Ancells Farm, Fleet370
Bartley Wood, Hook200
Fleet Road, Fleet220
Bramshill House350
Fleet Police Station50
Extra dwellings at Landata House28
Total1,688

All of the dwellings above were not included as brownfield sites in the SHLAA.  Guillemont Park (Sun Park) was in the SHLAA but for a lower number of units, and in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House for 28 more dwellings than were included in the 5 year land supply calculation.

If the original 750 units were to be added to the 1,688 units identified above, then that amounts to a total of 2,438 potential units on brownfield.  If it were possible to increase the density (from 30dph to a still reasonable 80dph in urban areas) on the original 750 units, the total identified capacity would rise to some 3,688 units.

The remaining requirement of 4,000 has of course been reduced by the unfortunate decisions to allow development at Watery Lane (300 units) and Hawley Park Farm (126 units) leaving the remaining allocation at 3,574.

It is clear that with some creativity and energy, the gap between the remaining allocation of 3,574 and the currently identified brownfield capacity can be closed by working on a combination of reducing the overall allocation by reducing the SHMA or applying environmental “policy on” considerations, increasing density and finding more brownfield sites.

In the light of this, we welcome the paper that has been put before Cabinet, signalling the more positive approach that the council proposes towards building housing on previously developed land.

We would ask though, that you consider some further steps from our 5-point plan:

  • Creating a new, formal “reasonable suitable alternative” option of meeting the remaining housing allocation solely through brownfield development.  This option should appear in the consultation paper.
  • Creating a complete database of all of the potential brownfield sites in the district, including those not in the October 2014 SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock, Sun Park, Ancells Farm, Bartley Wood, Fleet High St, Fleet Police Station and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).
  • Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.
  • Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.

 

 Employment Space (sq m)
Overall Requirement to 2032 (a)266,368
Current vacant space (b)527,840
Sites with planning permission (c)338,187
Surplus in 2032 (b+c-a)599,659

 

 

How Hart Council should respond to the We Heart Hart petition

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

Vacant Office at Ancells Farm, Fleet, Hampshire

As we posted earlier, we have submitted the We  Hart petition to Hart District Council and the council have set out the process by which they will consider the petition.

We have drafted some suggestions as to how the council should respond  and sent them to Council leader, Stephen Parker and they are shown below.  We have a chance to put these ideas to Cabinet on 1 October at 7pm.  Please tell us if you are coming along to give us your support.

Please e-mail your councillors to ask them to support these proposals.

 

Dear Stephen,

Thank you very much for your email.

As you know the petition is from 2,130 signatories, nearly four times the number that responded to Hart Council’s consultation last year and more than ten times the number of people who expressed a first preference for a new town and is therefore a very significant expression of local opinion.

I welcome your approach to treat the petition seriously.  My understanding is that a petition of over 1,000 signatories would trigger an automatic debate at full council.  However, I do believe a debate at Cabinet is more likely to be more productive, so I support the approach you suggest.

As you might expect, I have my own suggestions as to what the appropriate responses to the petition should be and I set them out below for your consideration, interwoven with the petition objectives:

  1. To reduce the overall housing allocation for Hart District

 I think there are two broad approaches to this.  First, challenge the SHMA to reduce the overall housing allocation for the whole HMA.  If this is successful, then it will have a two-fold effect of reducing Hart’s own need and also reducing the risk of overflow from Surrey Heath and Rushmoor.  I believe the key arguments are around inward migration assumptions; average household size and in particular jobs growth assumptions which are at a rate nearly double what was achieved over the economic cycle from 1998-2012 and will result in unprecedented levels of participation in the labour market (rising from around 70% to around 86%) for those of employment age.  I gave more detail on these arguments at both the Hop Garden Road appeal and in my response to the Rushmoor Local Plan.  More detail can be found here. However, I do recognise it is difficult for the council to challenge its own document and I await Rushmoor’s response to my strong challenge, but I do understand that the SHMA may be re-visited and it would be helpful if the council would commit to challenging the assumptions set out above as part of that process.

Second, in conversation with a number of professionals in the planning sector, I have been told a number of times, that it is uncommon for councils to explore fully their “policy on” options with regard to environmental and other constraints.  One of the main attractions of Hart as a district is its rural environment with associated SPA, SSSI’s, SINCs, green space and wildlife.  May I suggest that a proper environmental study is carried out to set out the value of Hart’s environment and ecology to build an argument for not meeting the full requirement of the SHMA?  I know that WAG is working on some proposals in this area with some of the rural parishes and would be keen to discuss the matter with you and offer to share the costs of preparation. 

  1. Demand that the Council develops a vision and strategy for Hart that retains its role as a rural, green hinterland for NE Hampshire that respects the separate character and identity of Hart’s settlements and landscapes and preserves the green spaces as amenity space for the urban settlements.

You may recognise the words above as taken from the withdrawn 2013 Core Strategy.  This was, and remains a good vision.  I would ask that as a minimum, the forthcoming Regulation 18 consultation sets out at least one potential “vision” for the district, and that one of the “vision” options includes words to this effect.

  1. To require that the housing need is met by building on brownfield sites and increasing density in our existing urban areas

Last November, the council’s estimate of brownfield capacity over the entire plan period was around 750 units (taken from parts 1 and 3 of the SHLAA as per the FOI request I made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.  Since then considerable progress has been made in identifying and in some cases granting permission on additional brownfield sites:

LocationNumber of Dwellings
Guillemont Park Phase 1 (not included as brownfield site in SHLAA) 150
Guillemont Park Phase 2320
Ancells Farm, Fleet370
Bartley Wood, Hook200
Fleet Road, Fleet220
Bramshill House350
Fleet Police Station50
Extra dwellings at Landata House28
Total1,688

All of the dwellings above were not included as brownfield sites in the SHLAA.  Guillemont Park (Sun Park) was in the SHLAA but for a lower number of units, and in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House for 28 more dwellings than were included in the 5 year land supply calculation.

If the original 750 units were to be added to the 1,688 units identified above, then that amounts to a total of 2,438 potential units on brownfield.  If it were possible to increase the density (from 30dph to a still reasonable 80dph in urban areas) on the original 750 units, the total identified capacity would rise to some 3,688 units.

The remaining requirement of 4,000 has of course been reduced by the unfortunate decisions to allow development at Watery Lane (300 units) and Hawley Park Farm (126 units) leaving the remaining allocation at 3,574.

It is clear that with some creativity and energy, the gap between the remaining allocation of 3,574 and the currently identified brownfield capacity can be closed by working on a combination of reducing the overall allocation by reducing the SHMA or applying environmental “policy on” considerations, increasing density and finding more brownfield sites.

In the light of this, I welcome the paper that is to be put before Cabinet next week, signalling the more positive approach that the council proposes towards building housing on previously developed land.

I would ask though, that you consider some further steps:

  • Creating a new, formal “reasonable suitable alternative” option of meeting the remaining housing allocation solely through brownfield development.  This option should appear in the consultation paper.
  • Creating a complete database of all of the potential brownfield sites in the district, including those not in the October 2014 SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock (aka Hartland Park), Sun Park, Ancells Farm, Bartley Wood, Fleet High St, Fleet Police Station and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).
  • Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.
  • Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.
  • This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor, particularly given the massive amount of current and forecast vacant employment land and Rushmoor seeking to protect 96 Ha.
  1. To request that future housing stock reflects the needs of the changing demographics of the district.

I set out in a question to council earlier this year that Hart will need to deliver around 2,500 housing units to meet the needs of the ageing population.  I contend that a new town will simply build the wrong type of accommodation in the wrong place to meet those needs.  It would be far better if these were built on brownfield sites in more urban areas, close to amenities such as doctors, post offices, shops and so on.  When the elderly move into these types of development, their well-being improves and of course, they free up conventional housing stock for families.  Could I therefore ask that the forthcoming consultation paper contains specific proposals on how the needs of the ageing population will be met?

  1. To demand the council and government do not plan for any new settlement in Hart that will act as a sink for the unmet housing need in neighbouring areas.

Addressing points 1, 2, 3 & 4 will render a new town unnecessary particularly when you consider the:

I do hope you find these suggestions helpful.  I would be grateful if you could circulate them to planning officers and Cabinet members for their consideration.

Please help Hart fend off an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

Rushmoor Borough Council has published a draft Local Plan where it proposes to build only 8,200 of its assessed need of 9,822 houses over the plan period.  It is clear that Rushmoor is seeking to offload the remaining 1,622 houses on to Hart District.

We need to oppose this move and We Heart Heart have produced some materials to help you do this easily.  Our voice will have greater weight if we can get more Hart residents to comment on Rushmoor’s plan than Rushmoor residents. Please follow the simple process below:

  1. Download the Local Plan response form from the link below.
  2. On page 3, fill in your name and contact details and type your name and date in the boxes at the bottom of the page.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to plan@rushmoor.gov.uk
  5. Share a link to this page to all your friends and family as well as any sports clubs or community groups you belong to via word of mouth, email, Facebook and Twitter and ask them to put in a response and share this page again.
  6. If you have not already done so, please sign and share our petition too.
Rushmoor Local Plan Response Form

A summary of the arguments we are putting forwards is outlined below.

Slippery slope to taking more housing than the other districts

The proposal to take an additional 1,622 houses from Rushmoor puts us on the slippery slope to accepting a further 1,400 houses from Surrey Heath such that Hart District ends up having to build the most houses in the Housing Market Area.

 

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

 

This will impact all of our districts including Blackwater and Hawley; Bramshill;  Church Crookham; Crondall; Crookham Village; Dogmersfield; Elvetham Heath; Eversley; Ewshot; Fleet; Greywell; Hartley Wintney; Heckfield; Hook; Mattingley; North Warnborough; Odiham; Rotherwick; South Warnborough; Winchfield; and Yateley adding additional pressure to an already difficult situation and make it more likely we have to accept both a new town and urban extensions on our beautiful green fields and countryside.

Hart and the rest of Housing Market Area are being asked to build too many houses

The whole Housing Market Area (HMA) should reduce the assessed need by 7,800 units which would reduce the pressure on Hart directly and remove the need for Surrey Heath and Rushmoor to ask us to build >3,000 houses for them. This is discussed in more detail here.

Rushmoor isn’t making best use of its brownfield sites

This is discussed in more detail here and here. As can be seen, if Rushmoor gets more creative with Wellesley and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need.   It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build out of this wealth of opportunity.  Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries.  It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas.  Neighbouring districts could be approached to provide SANG capacity if required.  Rushmoor should also take a closer look at all the vacant sites in the district and seek to convert them to residential use.

Rushmoor’s Employment Land Review is overblown and seeks to protect more employment land than is necessary.

This is discussed here.  It is also clear that past forecasts got it wrong as evidenced by the large number of vacant office blocks and empty shops across Hart District.  If the ELR was reduced to more sensible levels they could free up more land for housing.

Indeed, even if you accept the overblown employment forecasts, there will be a surplus of nearly 600K sq m of employment space at the end of the plan period, covering around 195 Ha.  Yet Rushmoor seeking to protect 96 Ha of land whilst asking Hart to build 1,600 houses on green fields.

Rushmoor’s infrastructure plans are not credible

We posted here that Hampshire as a whole has a £1.9bn infrastructure funding deficit, with Rushmoor’s share of that being £80m.  Rushmoor makes no mention of this deficit in its draft Local Plan.  Hart’s own numbers show an infrastructure deficit of £78m.  All of these numbers are probably an under-statement given they were all produced before the scale of development now proposed was known.  This is in contravention of NPPF para 177 that says there must be a “reasonable prospect” of delivering the required infrastructure alongside housing:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan”

Finally, they don’t even attempt to quantify the extra infrastructure Hart would need to build the extra 1,600 houses nor do they make any offer to fund any of that extra cost.

Rushmoor not planning to meet the needs of the ageing population

Figure 10.15 of the SHMA sets out the need for specialist housing and registered care places for the HMA and Rushmoor.  This states Rushmoor must build 710 sheltered and extra care units as well as provide an extra 600 registered care places. Their draft Local Plan makes no mention of the extra registered care places and sets no target for the sheltered and extra care units.  This is in contravention of NPPF para 50 which states:

“local planning authorities should…plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)”

Therefore the Rushmoor draft Local Plan runs the risk of being found unsound and should be revised.

 

In conclusion, the Rushmoor draft Local Plan contains many serious flaws and needs to be revised.

Link