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

Where is the draft Hart Local Plan?

Hart Local Plan - Keep Calm and Wait until 26 April

Hart Local Plan – Keep Calm and Wait until 26 April

Regular readers maybe wondering what has happened to the Hart Local Plan. On February 9th, Hart Cabinet agreed to a spatial strategy as part of the draft Local Plan that was due to go out to consultation in March. Obviously, there have been further delays. This is what we now understand to be the position:

Hart Local Plan timetable

The draft local plan will be released 26 April for a six-week Reg 18 consultation period after a briefing session with Parish Councillors on the 25th. There will be roadshows at the main settlements. Every house in the district will receive an A5 leaflet advising them of the consultation.

The Reg 19 process will follow in about November with submission of the full plan to the Secretary of State in mid-February 2018. All responses during the Reg 18 will be made public including the names of the individuals but with no contact details.

Hart Local Plan Headlines

Hart Council have decided to build 10,185 houses up to 2032 of which around 50% have already been built or granted permission. Please note that this number is far higher than 8,022 target the recently published Strategic Housing Market Assessment and more than double the requirement generated from demographic change. The numbers are now correct as of 31 January 17 and include all office conversions which have been approved.

Housing Numbers by area

  • Fleet 200 – mostly through office redevelopment
  • Hook was 200 now 10 from office redevelopment plus another 87. However, developers may chance their arm again with Owens Farm (750), and of course around half the Murrell Green site is in Hook Parish.
  • Sun Park 320
  • Hartland Park (Pyestock) 1500. Fleet town council have apparently made the point that the site offers only 20% affordable homes and the density per hectare is up to 97 in places which is equivalent to city centre densities which is of concern to them. OUr view would be to make the most of available brownfield sites.
  • Murrell Green 1800 but with challenges. There are 4 promoters and it will be some 3 to 4 years before planning permission is approved. It includes the site for a secondary school but there won’t be enough developer contributions to pay for it. New school funding rules mean that Hampshire can’t pay for it either.  It’ll probably be an Academy at a cost of circa £36 million. So we get a site for a school, but no money.
  • Crondall 66
  • Crookham Village 100 + 64 predominantly the care village
  • Eversley 124 on two sites
  • Heckfield 86
  • Long Sutton 10
  • Odiham 119 as per NP
  • Hartley Wintney 0. It seems odd that HW’s Neighbourhood Plan will be ignored. It should be noted that Murrell Green directly abuts Hartley Wintney Parish and about half of the proposed Pale Lane (Elvetham Chase) development is in HW parish.
  • South Warnborough 34 on two sites
  • Yateley 88
  • An additional 50 via rural exceptions and a further 290 from windfall.
  • Interestingly, no mention of Winchfield, or their Neighbourhood Plan, but roughly half of Murrell Green is in Winchfield Parish.
  • Apparently, Bramshill will be very difficult to develop because of all the complications with the Grade 1 listed site.

Other news

Apparently East Hants have done such a stellar job on the Local Plan, the Planning Policy team is now back in house at Hart, reduced in size from 8 to 2.

There is a risk that developers will continue to pursue Pale Lane and take it to appeal before the Local Plan is adopted.

We await the results of the Grove Farm (Netherhouse Copse) appeal in June.

Save Rye Common Action Group launch website

save rye common action group. Oppose rye common new village development

Rye Common which is between Odiham and Crondall in Hart District, Hampshire

The Save Rye Common Action Group have launched their website to promote their opposition to the proposed Rye Common New Village development. They have also published a report from Berrys, a leading firm of quantity surveyors that sets out the main reasons for opposing development on this splendid example of the local countryside.

Please do all you can to support them.

Their website can be found here, and the Berrys report can be found here.

More details about the proposals can be found in our earlier article.

Odiham Parish Council to discuss Rye Common Proposals

Rye Common, Odiham, Hart District, Hampshire

The Basingstoke Gazette has run a story about the proposed Rye Common new village development. Odiham Parish Council is going to discuss the proposals for a new village between Odiham and Crondall.  It is clear they are very concerned about the proposals, with chairman saying:

“The parish council are well aware of the consultation being undertaken for a large development at Rye Common, located within the parish of Odiham.

“This has of course created significant interest and indeed concern within our community.”

He added: “While the parish council are required to review all proposals with an open mind, I have heard no local enthusiasm for the scheme and would want to understand how this volume of houses proposed works against HDC’s revised Strategic Housing Market Assessment.”

“It is hard to see any value to our existing community and in my view would significantly impact the character of Odiham and the surrounding of communities.”

We Heart Hart is quoted in the article saying:

“The Rye Common development is simply not required because our housing targets are reducing and there are plenty of brownfield sites available that can meet our housing needs for decades to come.”

More details about the proposals and how to respond to the consultation can be found here.

Please oppose the consultation about the Rye Common new village development

Rye Common new village proposal, Odiham, Hart District, Hampshire

Rye Common new village proposal near Odiham and Crondall in Hart District Hampshire

Bell Cornwell have launched a consultation on proposals to build a 1,600-1,900 new houses on around 140 hectares to form the so-called Rye Common New Village to the south of the A287 between Odiham and Crondall. We urge all We Heart Hart supporters to oppose the proposals by responding to the consultation that can be found here, on the grounds that it is not needed as there are plenty of brownfield sites available and Hart’s declared strategy is to prioritise brownfield development ahead of green field development.

More details about the plans can be found in Bell Cornwell’s consultation microsite,  leaflet and vision document.

We suggest you utilise some of the following arguments in your answer to the first question:

This development is not required as there are plenty of brownfield sites available, as can be seen here:

http://wehearthart.co.uk/2015/11/there-is-a-brownfield-solution-to-harts-housing-needs/

There are at most 2,350 more homes to be granted permission in the plan period (and according to a recent press release from Hart DC this may be further reduced by 1,500), and close to 4,000 dwellings that could be built on brownfield sites.

Hart’s declared strategy is to prioritise brownfield development before green field development as can be seen on page 2 of the recent Refined Housing Options paper.

Thank you for your help.

 

James Farm Nursery Hartley Wintney, Hart District, Hampshire

New SHLAA sites mean our remaining housing need can be met from brownfield sites alone

James Farm Nursery Hartley Wintney, Hart District, Hampshire

James Farm Nursery Hartley Wintney

Hart Council has added a number of new sites to its SHLAA evidence base.  There is a mix of brownfield and green field sites, as we explore below, but the overall impact is to increase the brownfield capacity  to 2,493-2,535 units which is now enough to meet the remaining need of 2,500.

The sites are:

SHL25 Land attached to Brook House, Crondall, green field
SHL81 Vertu, Beacon Hill Road, Church Crookham, brownfield site, 65-70 units
SHL176 Hawley House, Hawley, in Blackwater and Hawley Parish, brownfield site, WHH estimate 8-10 units
SHL177 Land at Croft Lane, Hartley Wintney, green field site, WHH estimate
SHL178 Broden Stables & Stable Yard, Crondall, brownfield site 14-27 units
SHL179 Bowenhurst Lane, Crondall, brownfield site, 30-35 units
SHL180 Crondall Bee Farm, green field site
SHL181 Land south of Little Rye Farm, greenfield site
SHL189 Land at James Farm, Hartley Wintney, brownfield site, 8 units

We have been through each document and some have not yet been fully assessed by Hart’s Planners, so we have had to estimate the size of sites SHL176 and SHL177 using Google Maps and the capacity. Hart Council have not estimated the size of SHL180 either, but that site looks so remote and so close to Basingstoke Canal, that we feel it unlikely ever to be permitted so we have not bothered to estimate a size or capacity for it.

The total capacity of these new brownfield sites is 125-150 units, bringing our total estimate of brownfield capacity up to 2,493-2,535 units.

We have updated our table of brownfield sites and our brownfield thermometer accordingly.

Hart District Brownfield Development Target

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Urban Areas not taking their fair share of homes part 2

Proposed percentage increase in dwellings by parish in Hart District New Town

Proposed percentage increase in dwellings by parish in Hart District New Town

Further to our post of yesterday, that showed the impact by parish of following a dispersal strategy, we have now created graphs to show the impact by parish of urban extensions and a new town.  In each case, it shows that the urban areas of the district are not taking their fair share of housing.

This demonstrates to us the need to step up efforts to follow a brownfield strategy and re-find the 1,400 units on brownfield sites that Hart lost after saying that 1,800 units on brownfield land could be readily quantified back in September 2015.

First, let’s take at the new town strategy.  The chart showing the %-age increase in dwellings by parish from 2011 to 2032 if we followed a new town strategy to meet the remaining need from now on is shown above.  The table showing how this has been calculated is shown below:

Proposed percentage increase in dwellings by parish in Hart District New Town Table

Proposed percentage increase in dwellings by parish in Hart District New Town Table

Of course, only 2,000 of the full 5,000 will be delivered before 2032.  We have distributed these across Winchfield (in others) and Hook parish in the same ratio of the overall delivery shown in the SHLAA.  However, the secret plan from the Winchfield Consortium showed the Murrell Green sites would be developed first, so this may understate the impact on Hook.

Now, let’s take a look at the Urban Extension option.  he chart showing the %-age increase in dwellings by parish from 2011 to 2032 if we followed an urban extension strategy to meet the remaining need from now, together with the table showing how this has been calculated are shown below:

[Update: The West of Fleet urban extension is actually in Crookham Village Parish so chart and table updated to show that]

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions 201-2032

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions 201-2032

 

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions Table 2001-2032

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions Table 2001-2032

The urban extensions are at Pale Lane which is split across Elvetham Heath and Hartley Wintney parishes, west of Hook which is in Hook parish and west of Fleet (in Crookham Village Parish].

Finally, let’s re-look at the dispersal strategy, we covered in yesterday’s post:

Proposed percentage increase in dwellings by parish in Hart District - dispersal strategy

Proposed percentage increase in dwellings by parish in Hart District – dispersal strategy

Parish  2011 Census Dwellings 2011-2015 % of total  2011-2015 Number 2011-2015 % increase  Dispersal Proposal 2011-2032 % Increase
Crookham Village 1,630 7% 322 19.8% 177 31%
Elvetham Heath, Fleet, Church Crookham, Ewshot 14,879 45% 2,070 13.9% 466 17%
Hartley Wintney 2,222 10% 460 20.7% 290 34%
Hook 3,111 19% 874 28.1% 204 35%
Odiham/Long Sutton/ South Warnborough 3,142 5% 230 7.3% 583 26%
Yateley/ Blackwater 9,826 11% 506 5.1% 480 10%
Others 2,526 3% 138 5.5% 1,027 46%
Total 37,336 100% 4,600 12.3% 3,227 21%

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Fleet, Elvetham Heath, Crookham Village, Yateley, Blackwater and Ewshot not taking their fair share of housing

Proposed percentage increase in dwellings by parish in Hart District

Proposed percentage increase in dwellings by parish in Hart District.

Hart Council has published a lot of data related to the new consultation.  We have taken a look at it, come to the conclusion that the combination of the houses built or permitted since 2011, plus the proposals for dispersal show that our urban areas are not taking their fair share of housing. We think that Hart District should be trying harder to find brownfield sites in Fleet, Yateley and Blackwater to redress the balance and save our countryside (see slider of sites below).

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

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

The chart above shows the %-age increase in dwellings by parish by combining the data shown in the table in para 30 of the main consultation document. This gives the distribution of dwellings built or permitted since 2011:

Split of dwellings built or permitted since 2011 by Parish

Split of dwellings built or permitted since 2011 by Parish

It did look odd to us that the parishes of Elvetham Heath, Fleet, Church Crookham and Ewshot should be grouped together like they were to give the impression that these parishes had already taken a lot of housing.  Of course if you combine a number of parishes together, then it is obvious that their combined contribution is going to be larger than the individual parishes to which they are compared.

So, we started with the census data for the number of dwellings by parish, and combined them together in the same way Hart had, then added on the number of houses implied by the figure above, then added the number of houses proposed by the dispersal option and expressed the result as a %-age increase on the number of dwellings that were there in 2011:

Parish  2011 Census Dwellings 2011-2015 % of total  2011-2015 Number 2011-2015 % increase  Dispersal Proposal 2011-2032 % Increase
Crookham Village 1,630 7% 322 19.8% 177 31%
Elvetham Heath, Fleet, Church Crookham, Ewshot 14,879 45% 2,070 13.9% 466 17%
Hartley Wintney 2,222 10% 460 20.7% 290 34%
Hook 3,111 19% 874 28.1% 204 35%
Odiham/Long Sutton/ South Warnborough 3,142 5% 230 7.3% 583 26%
Yateley/ Blackwater 9,826 11% 506 5.1% 480 10%
Others 2,526 3% 138 5.5% 1,027 46%
Total 37,336 100% 4,600 12.3% 3,227 21%

This shows that the urban areas that include Fleet, Yateley and Blackwater will take the lowest %-age increase in housing. Whereas, places like Hook, Hartley Wintney and the other rural parishes  are going to take massive %-age increases in housing.

Of course, a new town would disproportionately impact Winchfield, but would also lead to 1,800 further houses in Hook and effectively join those parishes to Hartley Wintney, into a giant Hartley WInchook conurbation.  Even the proposed urban extensions will further increase the pressure on Hartley Wintney and Hook.

One of the proposed extensions, the so-called Pale Lane extension (SHL 52) is largely in Hartley Wintney Parish, and another of the extensions is to the west of Hook (SHL 173).

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Which parishes have seen most development Hart District?

Elvetham Heath near Fleet, Hampshire

Elvetham Heath near Fleet, Hampshire

There has been much controversy about how much development there has been in Hart District over the past few years, so inspired by a post on the Winchfield Action Group site, we thought we’d take a closer look at the data.

We have compiled a list by parish and ward of the number of dwellings in each area in 2001 and 2011, according to the census and the results are shown in the table below:

ParishWard2001 Census (Dwellings)2011 Census (Dwellings)% Increase
Total34170373369.3
Blackwater & Hawley177218675.4
Bramshill9863-35.7
Church Crookham330933280.6
Crondall6887387.2
Crookham Village156316304.3
Dogmersfield1241283.2
Eversley5996508.5
Ewshot2292352.6
FleetCentral2235256514.8
FleetCourtmoor188819282.1
FleetNorth (inc Elvetham Heath)13602947116.7
FleetPondtail182018984.3
FleetWest185719786.5
Fleet Total91601131623.5
Greywell1041040
Hartley Wintney212622224.5
Heckfield137135-1.5
Hook2718311114.5
Mattingley2322382.6
Odiham & Long Sutton271228806.2
Rotherwick2052123.4
South Warnborough21326223
Winchfield2392587.9
Yateley79427959.2

It should be noted that the data only runs up to 2011 and so misses out most or all of certain developments such as QEB in Church Crookham, Dilly Lane and Rifle Range Farm in Hartley Wintney, Edenbrook and the planned new developments at Hawley Park Farm, new development to the North East of Hook and at Watery Lane.

It does show that the area with the largest increase is what was known as Fleet North, which has now been split after incorporating Elvetham Heath.

It is not really for us to point fingers at different areas of the district.  We will let readers make up their own mind and draw their own conclusions from the data.

If anyone finds an error in any of the data, then please do get in touch and we will make any corrections that are needed.

[Update]

I was asked to provide updated data of the permissions and completions since 2011.  There is no easy way to get this data.  This is a copy of what I received:

The majority of the information (with details of location and parish) on housing completions and permissions for the next few years can be found in the following two published documents :

Appendix 2&3
http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/Hart%205%20yr%20supply%20statement%20at%201st%20October%202015.pdf

And http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/Final%20Dwelling%20Completion%20Figures%202014-15_for%20website.xlsx

It’s regrettable  that you only used figures from the superseded five year land supply (2001-2011) calculation in the Interim Housing Delivery Strategy which was superseded by the Five Year Land Supply Position Statement:
Five Year Housing Land Supply Position Statement, 1st October 2015
2014-15, and the Completions list from Hampshire County Council (1st April 2015) both of which were linked on the  council website “Current planning policy and guidance” referring to the local plan consultation, and also discussed at a council meeting.

I’m glad got said you’d incorporate the latest numbers, and look forward to seeing this. I believe you’ll find disproportionate housing allocation to the North and East of the region whilst minimal development in the centre, West or south.

I can confirm that I used neither of the Housing Land Supply documents to produce the table above.  As the original post says, the source for the above is the census.

The link to the pdf just gives a long list of sites in a form that it is impossible to analyse in any meaningful way, least of all by parish.  The spreadsheet contains a list of starts, completions and losses for 2014-2015, a summary of which by Parish is shown below.

Dwellings started completed and lost in Hart District 2014-15

[/Update]

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

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