Hart Council makes more errors in new local plan consultation

Hart District Council (HDC) keep getting it wrong

Hart Council keep getting it wrong

Hart Council have relaunched the consultation about the Local Plan and we are sad to report that there still appear to be errors and anomalies in the materials.

In summary, there are discrepancies between the number of houses proposed for each parish in the table on page 48 of the main consultation document and those proposed in the New Homes Booklet. In addition, not all of the settlements that will be affected by the dispersal option are named in the revised Question 4.

This comes despite the council saying in its announcement of the new consultation (our emphasis):

The earlier consultation which started in November was stopped on 14 January 2016 because it became apparent, following feedback from local residents, that not all the settlements that were anticipated to be included within one of the key questions had been correctly captured.

Leader of Hart District Council, Cllr Stephen Parker, said: “We have been working hard over the past weeks to identify and rectify our consultation material. This has been completed and we are now confident that the new consultation is robust.”

The fact that these errors were there in the first place is bad enough, but as they’ve now spent three weeks supposedly going through the material with a fine tooth comb and the errors are still there is beyond belief.  Surely now it is clear to all that we cannot continue like this and that those running this project are totally incompetent. We urge everyone to contact their councillors to ask them to intervene to replace the Local Plan Steering Group.  We also suggest that nobody responds to this new consultation until we know the new housing allocation from the revised Strategic Housing Market Assessment (SHMA), which is expected in late February.

The detail of the errors are shown below:

First, the new wording of Question 4 does not include Long Sutton or Odiham parishes even though both of those parishes are shown in the table on p48 of the main document, the New Homes Booklet and they are identified for comment in Q6 of the online consultation. Elvetham Heath is shown in Q4, the New Homes Booklet and opinion is sought in Q6 of the consultation, but it does not appear in the table.  South Warnborough is not in Q4, but it is in the table on p48, the New Homes Booklet and our opinion is sought in Q6 of the consultation.

[Update 1: We have been told that Approach 1, to which Q4 relates is supposed only to cover settlements outside the SPA zone of influence and that is why Long Sutton, Odiham and South Warnborough don’t appear.  We think this is confusing, especially considering Q6 is a question about all of the non-strategic sites and does include those parishes.]

[Update 2: Please also note that the description of Approach 1 changes depending upon which document you read, as the images below illustrate.

Summary Booklet Approach 1

Summary Booklet Approach 1

Main Document Approach 1

Main Document Approach 1

 

 

Hart District Council (HDC) new Local plan consultation Q4

New Local plan consultation Q4

Hart District Council (HDC) New Local Plan consultation p48 table

New Local plan consultation p48 table

Second, here is a summary of the different impacts on the each parish in the different parts of the main consultation document, the new homes booklet and the SHLAA, with the differences highlighted in red:

Hart District Council (HDC) New Local Plan consultation errors and discrepancies.

New Local Plan consultation errors and discrepancies.

The main errors are with the following parishes:

Blackwater and Hawley, where the table says the impact will be 60 homes, but the New Homes Booklet (and Question 6) shows a total of 276 dwellings in sites SHL100 & SHL153.  Even worse, the same sites show a capacity of 380 in the official SHLAA.

Crookham Village, where there is a discrepancy between the capacities in the table in the main document and the capacities for the same sites in the New Homes Booklet, Q6 and SHLAA.

Elvetham Heath, where the table in the main document shows no impact, but the New Homes Booklet (and Question 6) shows 40 dwellings from SHL104 and the SHLAA shows a capacity of 45 dwellings for the same site.

Fleet, where the main document shows 30 dwellings, but the New Homes Booklet (and Question 6) show 73 dwellings from sites SHL320, 322, 338 & 357. The SHLAA shows a capacity of 217 dwellings for the same sites.

Hartley Wintney, where the main document and the New Homes booklet show a capacity of 290, whereas similar sites in the SHLAA have a capacity of only 180 units.  The main discrepancy being site SHL19 in the SHLAA showing a capacity of 80 dwellings on 32Ha, whereas in the New Homes Booklet, two smaller sites, SHL19a and SHL19b are shown with 150 and 90 dwellings respectively, or a total of 190 units.  It beggars belief that a sub-set of site SHL19 should have a larger capacity than the entire site.

Odiham, where the capacity shown in the main document is shown as 384 units, but the total of the shortlisted sites (and Neighbourhood Plan sites) is shown as 389 in the New Homes Booklet and the SHLAA for Odiham has a capacity of 434 for the same sites.

The overall impact is that the table on p48 gives a total of 2,896 dwellings on dispersal sites, whereas the total for the same sites in the New Homes Booklet is 3,227 and the total for the same sites in the SHLAA is 3,415.

 

Hart Council starts to identify brownfield opportunities

Hart District Council (HDC) starts the process of identifying brownfield opportunities

Hart Council starts the process of identifying brownfield opportunities

In a welcome development, it appears as though Hart Council has started the process of identifying brownfield opportunity areas.

These include Pyestock (aka Hartland Park), Ancells Farm and part of Redfields Business Park.  This is an important development as Hart had previously ruled out Pyestock as a location.

They also identify a wide range of other brownfield sites, from the SHLAA that were deemed to have a capacity of 592 units, at an average density of 32.5 dwellings per hectare.

Parish/Ref Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High) Sum of Size (Ha.) Average of Low Density (dpa)
Blackwater and Hawley 320 320 12.00 26.7
SHL100 320 320 12.00 26.7
Church Crookham 6 6 0.42 14.3
SHL28 6 6 0.42 14.3
Elvetham Heath 45 45 2.25 20.0
SHL104 45 45 2.25 20.0
Fleet 221 221 3.56 62.1
SHL113 12 12 0.68 17.6
SHL245 8 8 0.18 44.4
SHL320 150 150 1.80 83.3
SHL322 37 37 0.61 60.7
SHL41 6 6 0.05 120.0
SHL42 8 8 0.24 33.3
Grand Total 592 592 18.23 32.5

Whilst this is a welcome development, it is clear that work is yet to start on the rest of the district outside the environs of Fleet and Church Crookham.

We do call into question the assertions in the consultation that there is only capacity for 450 units on brownfield sites and the timing of the consultation, as it seems clear that brownfield capacity is going to rise significantly, so we will not need a new town, nor urban extensions.

If you would like to ask Hart to redouble its efforts to build the case for 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 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
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
Total34170373369.3

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]

Impact of a new town on Fleet and Church Crookham

Fleet and Church Crookham

Impact of new town on Fleet and Church Crookham

I have a great deal of sympathy for residents of Fleet and Church Crookham who have suffered a great deal of development in recent years with insufficient investment in infrastructure.  However, a new town in Winchfield, Hook and Hartley Wintney parishes is not the panacea for Fleet residents that that many of the Hart Councillors would have you believe.
There will be negative impacts in 4 main ways:

  • Starvation of infrastructure funding
  • Extra traffic and congestion
  • Lack of affordable homes
  • Destruction of amenity space

Infrastructure Funding

Hart Council currently has a £78m infrastructure funding deficit, much of it in Fleet, Church Crookham and Hook. This does not include healthcare where there is a forecast £47m funding deficit in five years time.  A new town will need about £300m of infrastructure spending to make it work, but a realistic assessment of developer contributions is £40-50m.  This leaves a further gap of ~£250m.  There are already complaints about long waiting lists at doctors and lack of other amenities.  It is clear that a new town will be under-funded with consequent impact on other parts of Hart District, where there will be no spare money to address the deficit that already exists in all areas of Hart including Fleet and Church Crookham.

 

Congestion

Where Hart Residents Work

Where Hart Residents Work, SHMA Figure 13

Let’s have a look at where Hart residents work, using the evidence of the Strategic Housing Market Assessment (SHMA).

A bit less than half of them work in Hart – 45%. So of the 12,500 new people in a new town, 45% of those of working age will work in Hart. The biggest employment centres are in Fleet and Hook. So a significant proportion of the new town workers will go to work in Fleet. They are not all going to work in a new supermarket in the new town.

A significant proportion will also work in Rushmoor (Farnborough and Aldershot), Surrey Heath (Camberley) and Waverley (Farnham) – some 18% in total.

The most obvious travel to work route for many of these people will be along Pale Lane, through Elvetham Heath/Fleet or along Chatter Alley, through Dogmersfield, Crookham Village and Church Crookham.  But these roads are narrow and a difficult to upgrade due to bridge constraints, so maybe a new road out of the new town on to Hitches Lane will be required.

A big portion – 6.2%, will use the train to go up to London from a station that is already full, on a line that is operating at or above design capacity.

Another group will go to Hook directly, or through Hook and/or Hartley Wintney to get to Reading or Bracknell adding to existing peak time congestion on the A30.

Pretending a new town will have no impact on congestion in Fleet and the Crookhams is plainly wrong.

Surely much better and more sustainable to direct housing development to the east of Fleet at Ancells Farm, Bramshott Farm and Pyestock (some of them brownfield sites) with a cycle route to Fleet station and a cycle route to the Cody Tech centre or the Farnborough airport complex.

Affordable Housing

 

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

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

As of 26/11/15, the cheapest 1-bed and 2-bed new homes available within 1 mile of Fleet are available at prices of £215,000 and £235,000 (Rightmove). Median household incomes for Hart are £40,200 per Figure 4.8 of the SHMA. This means that the cheapest new homes are between 5.3 and 5.8 times median incomes and out of reach for the average household, so something should be done.

The SHMA calls for 60-70% of new build to be 1 and 2-bed properties across the Housing Market Area.  The developers are going to want to do what they always do, that is to build 3-5 bedroom detached houses in the new town which will be no doubt attractive to those moving from London, but will do nothing to meet the needs of ordinary people living in Hart.

Surely, it would be better to build smaller, starter properties on brownfield sites such as Ancells Farm, Fleet Road, Harlington Way in Fleet and Bartley Wood in Hook to give younger people a more affordable first step on the housing ladder.  This iwll do far more to meet the actual need outlined in the SHMA, and be more sustainable for our environment.

Destruction of amenity space

The Heart of Hart, the area around Winchfield, is used as an amenity area for walking, cycling, watching wildlife and other recreation. Concreting it over and joining together Hartley Wintney, Winchfield and Hook into a giant Hartley Winchook conurbation will lead to lack of amenity for everyone.  Hart Council is yet to report on the consultation it ran earlier this year on how we value our amenity space.

If you are concerned about the impact of a new town, we have created 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

Do we really want to create a giant Hartley Winchook conurbation?

Winchfield and Hook New Town proposal

Hartley Winchook New Town proposal for Hart District in Hampshire

As you may know, Hart District Council has embarked on a new consultation about the Hart Local Plan.  One of the approaches put forward is for a “new settlement at Winchfield”.  However, this is misleading because a number of the sites that form part of the proposal are in the Hook and Hartley Wintney parishes.  This new town proposal is really a plan to create a single conurbation of Hartley Winchook that will damage the distinct identity if each of the existing settlements.

Moreover, there are also sites in the Strategic Housing Land Availability Assessment that further encroach on the parishes of Hartley Wintney and Hook.

Let’s take a look at Hartley Wintney parish first:

Hartley Wintney SHLAA sites in Hart District

Hartley Wintney SHLAA sites in Hart District, Hampshire

As can be seen, many of the proposed new town sites adjoin the Hartley Wintney parish boundary and site SHL 124 actually adjoins what will become phase 2 of the St Mary’s Park Dilly Lane development.  Moreover, the pink rectangle that is bisected by the Hart Parish boundary where it adjoins Fleet and Elvetham Heath is the site of a proposed urban extension to the Elvetham Heath community.

Now, let’s take a look at Hook:

Hook SHLAA sites in Hart District

Hook SHLAA sites in Hart District, Hampshire

As you can see, sites 126, 136 and 169 already make up part of the proposed new town and they are in the Hook Parish and 1,458 houses are proposed.  More than half of SHL167 is also in Hook Parish, delivering a further 400 houses to Hook, giving a total of around 1,850 dwellings.  These are very close to sites 1&2 where Hart Council has already resolved to grant planning permission and to sites SHL 3 & 4, which so far have been rejected, but the capacity is between 1,000 and 2,800 houses.  It is surely only a matter of time before voracious developers start to lobby for sites 3 and 4 to be included in the package to make the whole thing “more sustainable”, as if concreting over our green fields is in any way sustainable.

The only way to combat this urbanisation of our countryside is to vote for Approach 1, dispersal in the current consultation about the Hart Local Plan, and make comments saying you want Hart Council to find again the brownfield sites they said were “readily quantifiable”.

We have created a dedicated consultation page and 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

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.

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

 

Launch of We ♥ Hart Petition

The We Heart Hart Campaign (aka We Love Hart and We ♥ Hart) have now started a campaign on 38 degrees to petition Hart Council to change its approach to the Hart Local Plan. This petition can be found here: https://you.38degrees.org.uk/petitions/we-hart.

Please support this petition by signing it and sharing it with all your friends via e-mail, Facebook and Twitter.

We need to protect all of our parishes 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 from this invidious plan.

We Heart Hart Campaign Logo

We Heart Hart Campaign Logo