Council Adopts Hart Local Plan

Council Adopts Hart Local Plan

Council Adopts Hart Local Plan

It’s been a long time coming, but Hart Council has finally adopted the Hart Local Plan. This took place at their first virtual meeting that happened at 7pm on 30 April 2020.

The meeting was broadcast on Hart’s live streaming page: https://www.facebook.com/HDCLiveStreaming/

However, these videos are often removed shortly after broadcast.  So we have downloaded it, and uploaded it to YouTube for posterity.

We can all sleep relatively easily now that we have a Local Plan. This plan has had Policy SS3 removed from it. However, we need to remain vigilant that the Council doesn’t seek to bring back the unnecessary Shapley Heath Garden Village at a later point.

 

Breaking News: Inspector approves Hart Local Plan

Breaking News: Planning Inspector approves Hart Local Plan

Inspector approves Hart Local Plan

The planning inspector has approved the Hart Local Plan.

The announcement has been made by Hart District Council and can be found here.

The Inspector has found the Local Plan to be sound and legally compliant, subject to some recommended changes. It will go before the Council for formal adoption in March.

The full Inspector report can be found here.  We will update this story as we digest what the Inspector has said.

The appendix containing the main modifications can be found here.

[Update 1]

  • Policy SS3 has been removed, so further confirmation of no new settlement in Shapley Heath/ Winchfield for the time being.
  • Reiteration in para 181 that future reviews of the Local Plan must look at all options including regeneration:

Nonetheless, the Council will need to ensure that all options for meeting future housing needs are considered fully in future reviews of the Plan, including the potential for regeneration.

  • Emphasis added to MM121 to make clear that all reasonable growth options should be considered and evidenced. This refers to the flawed SA that was submitted to the Examination to try and justify the new settlement:

All reasonable growth options, including the potential for a new settlement, would need to be fully considered and evidenced in a future review of the Plan or a subsequent DPD.

  • Changes to main modifications 70 and 71 to make clear that mixed residential and commercial use properties within town centres will be permitted. This will also help facilitate regeneration.  CCH should take note.
  • In light of recent events, it is also good to see that the vision has been updated to include a reference to flood risk:

New development will have been built to high environmental and design standards. It will have been designed and located so that it is safe from flooding and has not increased the risk of flooding elsewhere and includes measures to meet the challenges of climate change.

[/Update]

Hart Local Plan Immediate Review

Stop Shapley Heath

Stop Shapley Heath – Hart Local Plan Immediate Review

The adoption of the Hart Local Plan is anticipated in February or March 2020. The council has conceded in its main modifications to the need for an early review of the Local Plan in certain circumstances (see MM121). We support an immediate review of the Hart Local Plan, once adopted.

We think the following objectives should be set:

  1. Build what we need, no more, no less.
  2. Avoid any new settlement or large scale green field development. This means we should not build Shapley Heath, Rye Common or West of Hook.
  3. Focus on brownfield development to revitalise our urban centres by delivering better health, community and cultural facilities.
  4. Proportionate development within each parish.

We believe this can be done, and this post explains the first stage of how we do that.

Hart Local Plan Housing Delivery Test

Before we start, we need to acknowledge a weakness in the Local Plan that will shortly be adopted. The Government have imposed the Housing Delivery Test (HDT) on all councils. The HDT aims to maintain a steady supply of housing by forcing councils to keep their rolling 3-year delivery in line with the average required rate. The Hart Local Plan will run into trouble with the Housing Delivery Test (HDT) around 2025/26. This was covered by a question to the full Council meeting in July 2019. This effect might be delayed or reduced if some or all of the large developments underway slip their delivery schedules.

But, if places like Hartland Park and Grove Farm stick to their delivery schedules, we will be running short of housing in 2025/26. To rectify this, pass the HDT at 100% based on the 423 dwellings per annum (dpa) imposed by the Local Plan, we will have to build an extra 1,700 houses over the period to 2032.

Hart Local Plan Immediate Review

Hart Local Plan and the Housing Delivery Test

Some council members may use this as a justification to pursue Shapley Heath Garden Village. We have already shown that Shapley Heath will deliver far more houses than we need, and unnecessarily urbanise the district.

Hart Local Plan versus the Standard Method

However, the Local Plan was examined under the (old) SHMA method. This, together with the alleged unmet need from Surrey Heath, resulted in a housing target of 423dpa. But, under the new standard method Hart’s housing requirement from 2020-2041 is only 251dpa (including a 40% affordability uplift).

Hart Household Requirements 2016-2041

Hart Household Requirements 2016-2041

Hart District Build Requirements under various scenarios

Hart District Build Requirements under various scenarios

This results in a total requirement from 2020-2041 of “only” 5,271 houses.

Hart Local Plan Immediate Review

Hart Local Plan versus the Standard Method

Revised Hart Local Plan to meet the Housing Delivery Test

However, any revised Local Plan would also have to meet the HDT. This would result in a total requirement of 6,783 houses over the period 2020-2041. The Local Plan has already identified 4,012, leaving 2,771 to find.

Hart Local Plan Immediate Review

Hart Local Plan versus the proposed Revised Plan

Hart Local Plan Immediate Review

So, the challenge from a Hart Local Plan immediate review is during 2020 develop a vision for Hart in 2040 to:

  • Deliver the 2,771 houses we need at a steady rate
  • Revitalise our urban centres
  • Proportionate development across remaining parishes to make up the difference
  • Protect the green spaces that make Hart an attractive place to live
Hart Local Plan Immediate Review - 2020 Vision for Hart 2040

2020 Vision for Hart 2040

We believe this can be done. We will work on how this might be done in subsequent posts.

This is another of our posts showing:

  • What is Shapley Heath, explaining its location and scale?
  • All the reasons why Shapley Heath Garden Village is a bad idea
  • An outline of an alternative approach to long term planning in Hart

The master page containing all of these posts can be found here. A link is also provided in the navigation at the top of the page.  Please do keep an eye out for further updates and share them with your friends.

 

 

Winchfield Flooding Returns with #StormBrendan

Winchfield Flooding returned on 15 January 2020 with #StormBrendan.

It does appear as though these one in 30 year events are turning into 1 in 30 day events. The video above is of flooding on Taplins Farm Lane.

The Winchfield flooding also affected Bagwell Lane, which relatively recently had new drainage installed.  It doesn’t seem to be working.

Of course this is not the first time it has flooded on Taplins Farm Lane. We have recorded flood events on 20 December 20194 February 2019,  in April 2018 and three times in 2016 alone. Evidence documenting the 2016 flood events can be found here (4 Jan) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie).

It seems that the actual weather is stubbornly refusing to comply with the flood assessment carried out for Hart Council as part of its evidence base for the Local Plan. The sustainability assessment claimed:

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

Winchfield Strategic Assessment - Flood Risk 1

The detailed assessment also said there’s only a one in 30 year chance of surface water flooding.

Winchfield Strategic Assessment - Flood Risk 3

Taplins Farm Lane and Bagwell Lane are in the middle of the proposed Shapley Heath development. The proposal to spend £150-650K of taxpayer funds does not include any work to assess or mitigate flood risk.

Shapley Heath work-plan doesn’t look at flood risk

Let us hope for a more sensible approach prevails. We are working on a revision to the Hart Local Plan. These will mean we avoid a new settlement anywhere in Hart, and won’t need large urban extensions either to at least 2041. Plus we get improved facilities in our urban centres.

 

 

 

Shapley Heath increases housing target

Stop Shapley Heath

Shapley Heath increases housing target

Building Shapley Heath will increases Hart’s housing target. This is quite a complex argument, but please bear with us. First let’s dispel some myths.

The CCH/Lib Dem coalition claim that Hart’s housing target is bound to increase, so we must plan for Shapley Heath. But nothing could be further from the truth.

The Hart Local Plan is being examined under the old SHMA method, plus we have been asked to build 731 extra houses for Surrey Heath. This results in an average 423 dwellings per annum (dpa) over the plan period to 2032 (see main modification 19). The SHMA is the Strategic Housing Market Assessment, where the councils concerned pay consultants to make up numbers about our housing need. If we had been assessed under the new standard method, the housing need for Hart would have been 282 dpa.

In various documents Hart has suggested it will pursue an early review of the Local Plan once adopted. This early review will be carried out using the standard method. According to the latest ONS projections, this will see our annual average requirement fall to around 251 dpa for the period 2020-2041.

Hart District Build Requirements under various scenarios

Hart District Build Requirements under various scenarios

Moreover, Surrey Heath will be examined under the standard method. They have already ‘promised’ to build 4,901 houses on their own patch in the plan period 2016-2032 (see Objective A on page 13) . Under the standard method, their requirement will fall to 3,720. They already have more than enough sites identified to meet this need. It is likely that there will be no need for Hart to take any extra for Surrey Heath.

In summary, all the evidence points to Hart’s housing need falling, not increasing. Having dispelled the Lib Dem/CCH myth, let’s have a look at the impact of their proposals. In fact, building Shapley Heath will bake in over-building for decades to come.

Shapley Heath Garden Village impact on housing need

In recent years, we have built at a faster rate than is required by the Local Plan. This is the result of ‘planning by appeal’, where we have had a number of large developments forced upon us. This is forecast to continue out to around 2023. The Shapley Heath housing trajectory submitted to the Government adds to the build rate, starting in 2023.

Nightmare in Winchfield - Shapley Heath Winchfield New Town Housing trajectory

Shapley Heath/Winchfield New Town Housing trajectory

However, under the standard method, our requirement falls to 251 dpa over the period 2020-2041. The steady-state build rate for Shapley Heath is 360 dpa, far higher than the requirement. If we add Shapley Heath (at only 5,000 total houses) to the existing Local Plan commitments, and compare it to the 2020-2041 requirement, then we will end up building 3,225 extra unnecessary houses out to 2039. If Shapley Heath expands to 10,000 houses, then this excess build rate will continue for many more years.

Shapley Heath Garden Village Excess Building

Shapley Heath Garden Village Excess Building

But it gets worse. The housing target is derived from population and household projections. The population projections are based upon trends from the previous ten years extrapolated forwards. If we continue to build more than we need to, this over-build is baked into our future housing targets, affecting us for decades to come. This will add extra pressure to build even more settlements or urban extensions such as Rye Common or West of Hook. So we must try and build at a steady rate to match no more than our annual housing target.

In conclusion, the rationale for investigating Shapley Heath is built on (at best) a misconception about future housing targets. Continuing to build this monstrosity will add even more pressure to build even more. It is a reckless policy that must be stopped.

Let’s hold our politicians to their word:

If the Government don’t force any more houses on us, this development is not needed, it will never go ahead.

If we don’t need the houses, then it won’t get done.

Well, we don’t need the houses, so it’s time to save £650K and  abandon the project now.

This is another of our posts showing:

  • What is Shapley Heath, explaining its location and scale?
  • All the reasons why Shapley Heath Garden Village is a bad idea
  • An outline of an alternative approach to long term planning in Hart

The master page containing all of these posts can be found here. A link is also provided in the navigation at the top of the page.  Please do keep an eye out for further updates and share them with your friends.

Shapley Heath not required and doubts about deliverability

Stop Shapley Heath

Shapley Heath not required

Shapley Heath is not required to meet our housing targets to 2032. Indeed we believe that our housing needs up to at least 2041 can be met without any new settlement or urban extension anywhere in Hart. Here is our evidence to support our claims.

The Local Plan submitted for examination said it wasn’t required (footnote 7 on page 29).

Shapley Heath not required

Shapley Heath Garden Village not required

The Inspector’s initial report agreed (para 37). Even the council’s own bid document (page 2) said:

As part of this we have identified a new settlement within the Local Plan. However, we did not need to do this as delivery from the new settlement is not required to meet the identified Local Plan housing target of 6,208 homes but is provided ‘in addition’ to this.

No evidence Shapley Heath Garden Village is deliverable or viable

In addition, the Inspector raised grave concerns about the soundness, viability and deliverability of the plan.

Shapley Heath not viable or deliverable

No evidence that Shapley Heath is viable or deliverable

At para 18 he said:

I have a number of fundamental concerns with regard to the soundness of Policy SS3.

Despite over 4 years of effort, the Inspector also found:

In addition, to my above concerns, there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership within the identified AoS…

There is consequently some doubt, at this time, whether a comprehensive and inclusive new community can be delivered as required by Policy SS3 and its supporting text. Given all of this, I am not sufficiently content based on the evidence available to the examination that Policy SS3 is deliverable and is therefore not effective.

The Inspector did leave open the door to a new settlement in the future. However, this would need to be backed with proper evidence and:

I am also mindful that following further work, there can be no guarantee that the evidence would support it as the most appropriate long-term growth strategy or that Policy SS3 would be found sound.

Even the viability assessment submitted as part of the bid for Garden Communities funding had serious flaws.

Work programme not addressing the key issues

Work programme not addressing the key issues

Hart Council’s new work programme is not even trying to address the key issues. It is focusing on “visioning” to start with. Then using consultants to create a project plan and land equalisation issues. Finally, it is hiring some admin support.

There are natural constraints in the shape of SSSIs, ancient woodland SINCs and TPOs.

Shapley Heath Garden Village Key constraints Natural.

Shapley Heath Garden Village Key constraints Natural.

There are also physical constraints including conservation areas, pylons, high pressure gas main, former landfill, flood risks and of course a big land ownership gap.

Shapley Heath Key constraints Physical.

Shapley Heath Garden Village Key constraints Physical

In summary, Shapley Heath is not required and there’s no evidence that it will ever be deliverable. None of the money the council is spending will even attempt to address these issues. Why is this project happening at all when the council’s finances are constrained?

Remember what the councillors said when discussing this at Cabinet:

If the houses aren’t needed, it won’t get done.

If Shapley Heath doesn’t work, it won’t get done.

This is another of our posts showing:

  • What is Shapley Heath, explaining its location and scale?
  • All the reasons why Shapley Heath Garden Village is a bad idea
  • An outline of an alternative approach to long term planning in Hart

The master page containing all of these posts can be found here. A link is also provided in the navigation at the top of the page.  Please do keep an eye out for further updates and share them with your friends.

 

CCH defy QC opinion and pass Shapley Heath plan

Lib Dem & CCH cabinet pass Shapley Heath Plan

The CCH members of cabinet defied a QC’s opinion voted to pass the Shapley Heath plan at Cabinet on 7 November. Despite strong opposition from members of the public, NE Hants CPRE and some councillors, the plan was passed unanimously by all members of Cabinet in attendance. Sponsor of the plan, Lib Dem Cabinet member for Place, Graham Cockarill wasn’t there as he is now standing for election to Parliament. The plan proposes to spend the £150K grant from the Government and looks to allocate up to a further £500K from reserves in the next financial year as part of the budget process.

Regular readers may recall CCH had written a letter to Ranil stating that 5,000 houses had been “secured for the next planning period”. The QC’s opinion that said that because this statement was manifestly untrue, that it demonstrated CCH councillors had closed their minds to a proper consideration of Shapley Heath and alternatives. In Andrew Tabachnik QC’s opinion, this amounted to predetermination.

The QC Opinion can be downloaded using the button below:

QC Opinion: CCH Predetermination of Shapley Heath

The Shapley Heath section of the meeting was quite long and stormy at times. The complete videos of the item can be found at the bottom of this article. The key points as we see them with video excerpts are set out below.

Argument about Shapley Heath QC Opinion

The first part of the public engagement started with a statement from the Rural Hart Association (RHA). The full statement is reproduced below:

For some years the Rural Hart Association has been frustrated by what we see as the bias of the Council in pushing for a new settlement near Winchfield without properly analysing the scope for alternative strategies, including urban regeneration.

Our frustration led us last month to commission an opinion from leading counsel about a letter sent to our MP by eleven CCH councillors in July. This letter asserts that “… 5000 more homes [have been] secured for the next planning period through Shapley Heath”. The opinion has been delivered to the Council with this statement, but in summary the QC concludes that:

  1. CCH’s assertion is totally misleading
  2. All CCH councillors must publicly retract their statement and must ensure that their future conduct demonstrates a genuine willingness to consider matters with an open mind
  3. Councillors who are unwilling to retract their statement must recuse themselves from decision-making relating to Shapley Heath

We therefore request that the councillors concerned recuse themselves from discussion and voting on Item 11.

In addition, we expect CCH councillors to take the following steps to comply with the QC’s opinion that they must in future demonstrate a genuine willingness to act with an open mind:

  1. Abandon the current plans which focus exclusively on Shapley Heath

  2. Implement an alternative work plan to examine objectively and impartially all reasonable alternative options to Shapley Heath, in line with the Planning Inspector’s recommendations. This should include brownfield development and urban regeneration.

  3. Undertake in depth work to build a more robust policy to regenerate our urban centres in Fleet, Blackwater, Hook and Yateley.  This work should in particular address policy ED5 (Fleet town centre) to tackle the growing outflow of retail and leisure expenditure from the district caused by under-investment in Fleet. It is essential to develop a new and comprehensive strategy for Fleet along the lines of neighbouring towns like Camberley and Farnham.

  4. Undertake thorough master-planning for the main towns in Hart without which no proper assessment can be made of the true scope of town centre mixed-use regeneration

  5. Meet the two developers who expressed interest in regenerating the Hart Shopping Centre to explore their proposals

  6. Refrain from allocating Hart’s reserve funds to Shapley Heath unless and until it is reinstated into the Local Plan as the result of the necessary comparative assessment work called for by the Inspector.

Here is a video of the statement:

This led to a response to the QC’s opinion from CCH’s James Radley. Astonishingly, he stated that the letter to Ranil was just political rhetoric and implied it shouldn’t be taken at face value. How do we know when he’s just spouting rhetoric and when he really means what he says?

This then led to a row about the validity of the RHA QC’s opinion. The joint chief executive said that HDC had taken legal advice and were convinced that CCH’s actions did not amount to pre-determination.  However, HDC’s advice did not address the key point that CCH had made untrue statements in their letter to Ranil. That was the key point that showed a “closed mind” and hence predetermination. In the end the Cabinet chose to ignore the QC’s opinion and the CCH councillors continued to participate in the debate and voted on the Shapley Heath Plan. According to the QC they should have either retracted or recused themselves. They did neither.

Substantive debate on Shapley Heath Plan

The meat of the public arguments against pursuing this plan now were made by RHA and CPRE NE Hants. RHA made further points setting out clearly that HDC should at least look at the option of urban regeneration.

And CPRE challenged the logic of looking at a new village that would deliver housing over and above what we need to build. Their initial statement can be found here, and their powerful supplementary statement can be seen on the video below:

Sadly, these arguments were ignored by Cabinet and they pressed on regardless. On the plus side, this builds the case that they have closed minds on the matter.

CCH inconsistencies on the Shapley Heath Plan

During the meeting CCH made a series of statements that contradicted what they had previously said. For instance, during the Cabinet meeting, Councillor James “it’s only rhetoric” Radley emphasised that this Shapley Heath plan was very different to the new town presented in the Local Plan.

But in the Shapley Heath Q&A on their Facebook page, they say that the two things are the same. So, which is it?

Q3. Is Shapley Heath the same as the New Settlement that was previously included in Hart’s Local Plan?

A3. Yes, they are the same. Whilst the Local Plan Inspector suggested HDC remove the New Settlement from our LP, this was not because he thought it an inappropriate solution to our future housing needs. Hart were keen to get the LP in place ASAP to avoid anymore developer led applications being successful at appeal. The Inspector recommended removal of the New Settlement to enable the LP to be adopted quickly. The New Settlement, evaluated together with other options for future housing, needed more detailed work and would have delayed the LP, leaving doors open for developers.

Secondly, Councillor Radley said that the Shapley Heath proposal won’t go forward if it is found that it isn’t viable.

However, the Inspector found (in para 33):

In addition, to my above concerns, there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership within the identified AoS.

Winchfield Parish Council’s representations to the Inspector showed there were big issues on land ownership and other significant planning constraints. Moreover, in 2016, the Tory administration had dropped plans for the Winchfield new town due to concerns about flooding and infrastructure costs. Similar plans for a new town were dropped in 2012 after concerns about viability. How many times do they need to look at it and how much of our money do they need to spend before they listen?

It also appears as though CCH can’t make their mind up about the importance of rail infrastructure. Councillor James “it’s only rhetoric” Radley didn’t mention rail as part of his infrastructure shopping list. But then made great play of there being a railway station at Winchfield.

He seemed to be blissfully unaware of the parking chaos at Winchfield station on Thursday.  This was exceptional, but it is by no means unusual for the car park to be full before 8am. Of course prior studies have shown that the railway station may well need to be moved to Murrell Green accommodate a further 5-10,000 houses.

Winchfield Station Parking Chaos

Version Control Shenanigans

At the beginning of the meeting there was considerable confusion about the version of the document they were supposed to be reviewing. The joint Chief Executive insisted that the version they were reviewing had been in the public domain for the requisite 28 days on the “key decision” part of the website. But we downloaded it this morning and found that the document was created in the early afternoon on Thursday, so could not have been available to the public for the required amount of time. In fact, it seems as though multiple versions were available and it isn’t clear how we are supposed to know which one to review. This is just another example of Hart’s incompetence.

This is the video of the exchange:

The full videos of the Shapley Heath discussion can be found on the links below. Thanks to Councillor Steve Forster for making them available on his Facebook page.

Part 1

Part 2.

 

 

 

Pale Lane Appeal Quashed

Wates Homes Elvetham Chase (Pale Lane) Development Proposal, near Elvetham Heath and Hartley Wintney, Hart District, Hampshire.

Elvetham Chase aka Pale Lane Appeal Quashed

Some great news emerged on Monday afternoon. The Pale Lane Appeal has been quashed by the Secretary of State. This means there won’t be any development in that location at least up until 2032. The complete decision document can be found here.

The Secretary of State examined a number of of issues in coming to his decision.

The issue that carried the strongest weight was the Hartley Wintney Neighbourhood Plan (HWNP). The Pale Lane site falls partially within the Hartley Wintney Parish. It was not allocated for development within the HWNP and this carried “significant weight”. So, we must thank Hartley Wintney Parish Council on their efforts that saw the Neightbourhood Plan “made” only last month.

Other issues considered included:

  • The emerging Hart Local Plan, which also does not allocate Pale Lane. However, despite being close to being approved only carried “moderate weight”.
  • He also considered that even if Pale Lane were refused, there would still be more than five years land supply.
  • The potential loss of Best and Most Versatile agricultural land was considered “moderate weight”.
  • Sadly, the highways, health, education and quality of life issues raised by the Stop Elvetham Chase group carried no weight.

The now infamous letter from CCH to Ranil wasn’t even mentioned in the report. So, it seems that the fight against Pale Lane was won irrespective of their efforts. However, the letter they wrote has caused them predetermination problems with their pet Shapley Heath project.

It seems the lesson here is to focus on the real planning issues and get Neighbourhood Plans in place if we want to combat further unnecessary and undesirable greenfield development.

Our local MP, Ranil Jayawardena has now come out unequivocally against large scale green field development. This  includes Shapley Heath, Rye Common and West of Hook. He has produced a constituency charter. We ask that you consider signing his charter that can be found here. This complements his call for bold regeneration plans.

 

Proposal for £500K Shapley Heath Slush Fund

Proposal for £500K Shapley Heath Slush Fund

Proposal for £500K Shapley Heath Slush Fund

A paper will be put to Overview and Scrutiny next week, asking for a multi-year £500K Shapley Heath slush fund. It is clear that Hart Council are intending to press ahead with the Shapley Heath/Winchfield new town despite removing it from the Local Plan. This builds upon the £150K of funding recently allocated by the Government.

There are a number of issues with this proposal:

  1. Goes against the recommendations of the Inspector
  2. Trojan horse approach
  3. Flawed Governance
  4. Lax financial control

These points are explored below. The full report to O&S can be found here and more details about the meeting can be found here.

 Shapley Heath Slush Fund goes against the Inspector recommendations

The O&S paper clearly doesn’t follow all of the recommendations of the Planning Inspector. The paper only partially acknowledges the findings of the Inspector.

No mention of Inspector request for more SA work

It doesn’t include mention of one of the key recommendations that said:

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options.

The council are clearly not carrying out the wide ranging site assessments, viability testing and SA work and they explicitly rule out considering alternative locations.

No intention to look at alternative locations to Shapley Heath/Winchfield

In addition, the council acknowledges that what they are doing falls outside the normal planning process:

Shapley Heath work outside of planning process

This is simply riding roughshod over the planning process and the Local Plan Examination findings. It is not acceptable.

Shapley Heath Trojan Horse

It is clear that this proposal is a Trojan Horse to be used to push through the unnecessary new town. In the main body of the report they use soft words like “test the Garden Community opportunity as a possible future growth option”. However, the detail of the Terms of Reference for the Garden Community Board shows that they are intending to deliver the Shapley Heath new town.

Shapley Heath Garden Community Board TOR 1 of 2

Shapley Heath Garden Community Board Terms of Reference 2 of 2.

Here are some examples:

  • The Garden Community Board (the Board) will have overall responsibility for steering the delivery of the Garden Community project
  • The Board will champion the Garden Community project and its delivery
  • To champion the Garden Community and its delivery
  • To facilitate and promote joined-up delivery

Flawed Governance

The Garden Community Board is made up of a vast number of people.

Shapley Heath Garden Community Board members

This includes the Cabinet members for “Place” (aka Planning) and Housing; the group leaders of each political party; the joint Chief executive and the chairman of the Overview and Scrutiny. This is substantially all of the senior member of the council and officers. Their role is to “champion the Garden Community and its delivery”.  Apparently nobody has a role to review and challenge what is going on. Somebody should be checking ongoing compliance with the Planning Inspector’s recommendations, planning law and good governance.  This is a recipe for the project to become a self-serving law unto itself, effectively accountable to nobody, because everyone is tasked with “championing delivery”.

Shapley Heath Slush Fund: Lax Financial Control

On the plus side, the paper returns the previously allocated £786K of funding to reserves.  However, the paper calls for “a £500K budget [to be] allocated to the Joint Chief Executive to utilise for expertise and resources to help the Council make informed choices associated with the Garden Community”. In addition, this money is expected to be spent over a number of years.

Multi-year £500K Shapley Heath Slush Fund

Multi-year £500K Shapley Heath Slush Fund

In other words, a multi-year slush fund.  This is particularly egregious in that the paper only identifies £155K of spending requirement at the moment.

Only £155K of the Multi-year £500K Shapley Heath Slush Fund is required.

Only £155K of the Multi-year £500K Shapley Heath Slush Fund is required.

Surely it would be better for money to be allocated when required to produce a specific deliverables. It is far too lax to grant discretionary powers to spend such a large amount of money over many years without knowing what they are going to get for the money.

Return of the New Town: Winchfield fights back

Return of the New Town - Winchfield fights back

Return of the New Town – Winchfield fights back

We Heart Hart and Winchfield Parish Council (WPC) are fighting back against the decision to award funding for the  new town.

WPC has written to the Secretary of State demanding that the decision to award £150,000 of capacity funding to support the delivery of the Hartley Winchook/ Shapley Heath garden community new town be reversed.   In addition, We Heart Hart has written to MHCLG making a similar request, using slightly different arguments. We understand that the Rural Hart Association will also be making representations to MHCLG.

A summary of the WPC letter is shown below, together with links to the full text. The full text of the WHH letter follows.

Winchfield fights back: WPC Letter

The letter has the support of Hartley Wintney, Dogmersfield, Crondall, Greywell and Long Sutton & Well Parish Councils. The Parish Councils of Eversley, Odiham and South Warnborough have made known to WPC their concerns about the proposed development and will consider adding their full support to the letter when they next meet. WPC’s letter highlights the following concerns:

  1. The Inspector’s findings following the independent examination of the Local Plan rejected the SHGV proposal, which followed HDC’s Garden Village Application in November 2018.
  2. HDC’s ongoing promotion of SHGV is not supported by the Inspector’s findings on the submitted Local Plan and he is quite clear that other options need to be considered in an impartial manner.
  3. The absence of sound justification for bringing forward SHGV (as it is not needed to meet identified housing needs) and the lack of evidence to demonstrate that the proposal is deliverable and sustainable was confirmed by the Inspector’s findings on the submitted Plan.
  4. The numerous shortcomings with HDC’s bid when considered against the Garden Communities prospectus lead us to question how it has been successful.
  5. HDC pre-determined the plan-making process, and failed to provide the evidence to the Inspector to demonstrate that it had impartially assessed reasonable alternatives. If HDC proceed with a Local Plan review as indicated based on SHGV as its chosen long term growth strategy, it will irresponsibly overlook the Inspector’s criticisms of the current Plan’s failure to impartially assess reasonable alternatives, and continue to ignore local opinion. HDC’s bid to be included in the Gardens Community Programme is a further demonstration of their continuation of pre-determine the planning process.
  6. HDC’s ongoing promotion of SHGV is not supported by the local communities directly impacted by this large scale proposal.

The full text of their letter can be found here. And the appendix can be found here.

Winchfield Fights Back: We Heart Hart letter

The full text of our letter is set out below:

Dear Ministers,

 Re: Hart District Shapley Heath Garden Community Funding Award

My name is David Turver. I run a campaign in Hart District called We Heart Hart. We have taken an active role in the Hart Local Plan, and I was invited to speak at the examination hearing. We have successfully campaigned against the new settlement proposal. We believe that urban regeneration and brownfield development is a much more sustainable and better way to deliver Hart’s longer term development needs.

I note that you have recently awarded £150,000 of capacity funding to Hart District Council to support the delivery of the Shapley Heath so-called Garden Village in Winchfield/Murrell Green.

I would like to share with you some extra facts which may cause you to reconsider your decision. The main letter sets out the main points, backed up with links and references in the Appendices. I have copied my local MP, the leader of the Conservatives on Hart Council and your garden communities email address so you can obtain a soft copy of this letter and follow the embedded links if required.

New Settlement Policy SS3 not required and not sound

Hart’s Garden Community bid in November 2018 relied on Policy SS3 being found sound in their Local Plan examination. Policy SS3 proposed a new settlement in the same area of search as the proposed Shapley Heath development. The Local Plan itself acknowledges that the new settlement is not required to meet Hart’s housing needs. The Planning Inspector, Jonathan Manning, found that he had “a number of fundamental concerns with regard to the soundness of Policy SS3”. As a result, Hart Council has removed policy SS3 from the Local Plan to make the plan sound. See Appendix A for more details.

More work required to make new settlement sound leading to a delay of up to five years

The Inspector has said that much more work was required to make the new settlement sound:

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options. Any further SA work would also need to include additional standalone consultation….

I am also mindful that following further work, there can be no guarantee that the evidence would support it as the most appropriate long-term growth strategy or that Policy SS3 would be found sound.

There are several alternative options, including alternative sites and alternative strategies such as urban regeneration. So, it is clear that a new SA would be a considerable undertaking in its own right. In the risk assessment accompanying Hart’s bid they anticipated this outcome. Their mitigation was to press-on regardless with the new settlement DPD, independent of the Local Plan. I am not at all convinced that creating a DPD outside of the Local Plan process is in line with the planning regulations.

However, the Inspector makes clear that significant SA work and a standalone consultation ought to precede a new DPD.  Moreover, in Hart’s latest consultation into the modifications required to make the Local Plan sound, they have completely changed their tune. The Sustainability Appraisal Addendum says that “the AoS/DPD process will effectively be replaced by a different process, most likely a new Local Plan” (see Appendix B). The impact of this is that:

  1. The further SA work may conclude that there are better alternatives to delivering longer term growth. I know there are many in the District who support our local MP’s call for urban regeneration.
  2. Even if it is decided that a new settlement is the best long term growth option, the timescales for a new Local Plan process indicate that work on a new DPD will not start for a considerable time; maybe up to five years.

No plans to meet commitments in the Garden Community bid

In their bid, Hart committed to producing a New Settlement DPD in December 2019 if they received the Garden Community funding (see Appendix C). Yet, in response to recent questions at council, they confirmed that they have no current plans to start the additional SA work required by the Inspector; no plans to produce the New Settlement DPD and have not allocated any of the £786K budget set aside for the New Settlement in FY19/20. It might be expected that the wide scope SA work would take at least six months, plus a further 2-3 months for a consultation. It is therefore difficult to see how work can start on a new DPD this financial year. Therefore, it is difficult to see how the Garden Communities grant money can be spent effectively during this financial year.

Deceptive Communications

In addition, I am sorry to report that the Lib Dem/Community Campaign Hart led Hart Council has not been as open and transparent as one would hope in its communications on this matter.  Recently, the council was asked who had been informed that Policy SS3 had been found unsound and removed from the Local Plan. Their answers stated that both Homes England and MHCLG had been kept informed prior to the funding announcement. However, a subsequent release of correspondence shows that the removal of Policy SS3 was a passing comment to an official in Homes England in an email about a different subject. There is no record of MHCLG being contacted directly. I am therefore concerned that MHCLG may not have been aware that the new settlement had been found unsound between Hart Council’s bid and the award of funding in June 2019. It would be a shame if the Government awarded money to fund an unnecessary and unsound white elephant project.

Alternative options

Quite separately, Hart made a recent bid for funds under the Future High Streets scheme and was turned down. Our local MP, Ranil Jayawardena is running a campaign to support urban regeneration within Hart.

The catalyst for this could be the publicly owned civic quarter containing the Hart Council offices and the Harlington Centre. The area is ripe for mixed-use redevelopment including offices, homes, social and retail. If all levels of Government got behind this, it would spark interest in redeveloping the rest of the High Street, including the Hart Shopping Centre.

Conclusions

In conclusion, it is clear that the facts have changed since the bid was submitted.

  • Policy SS3 covering the Shapley Heath new settlement has been found to be unnecessary and unsound and removed from the Hart Local Plan.
  • There are no plans to conduct the wide ranging SA work required that might bring the new settlement back on to the agenda.
  • There is no guarantee that such work will conclude that a new settlement is the best option for long term growth.
  • It is inconceivable that such work could be completed during this financial year, meaning that work on a new settlement DPD could not even start before FY20/21, so the funds you have awarded could be wasted.

Therefore, I would be grateful if you could review your decision in the light of new facts. There are many residents of Hart who would be pleased if the Garden Communities funds were redirected towards regeneration of our decaying urban centres instead of concreting over the very green fields that make Hart such a great place to live.

Thank you for your kind consideration of these points. I understand Hart Council representatives are meeting with Homes England this month, so I hope you have time to re-consider the funding decision before that meeting. I look forward to your prompt reply.

Yours faithfully,

 

David Turver

cc:           Ranil Jayawardena MP (by email)

gardencommunities@communities.gov.uk (by email so the embedded links work)

Anne Crampton, leader of Conservative group on Hart Council (by email)

 

Appendix A: – Hart’s Assumptions and Inspector’s Report into Hart Local Plan

Here is Hart’s bid assumption that Policy SS3 would need to be found sound in the Local Plan:

Winchfield Fights Back - Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

The Inspector’s post-hearing letter about the examination of the Hart Local Plan can be found here.

May I draw particular attention to paras 17-39. A summary of his findings with respect to the Sustainability Appraisal and the New Settlement are shown below:

  • The ranking of Option 1b (the new settlement) “as the best performing under heritage is not justified”.
  • For land and other resources, the ranking of Option 1b “is also therefore not, in my view, robust”.
  • The Inspector decided that “the decision not to rank the options in terms of flood risk to be very questionable”.
  • On landscape issues the Inspector concluded:

Option 1b was ranked joint highest with Option 1a. However, it is unclear why this is the case, given that the proposed new settlement would result in the development of large areas of open countryside and Option 1a already benefits from planning permission and is largely previously developed land. Further, the post submission SA notes that Pale Lane is ‘relatively unconstrained’, but despite this and it being a smaller site / potential development, Option 3a is ranked lower than Option 1b.

  • The Inspector has this to say on the climate change ranking:

Option 1b has been ranked the highest under the category climate change. This is as a result of the potential for the proposed new settlement to deliver a district heating system. However, there is little evidence to suggest that this is a feasible or realistic option that is being actively pursued by the site promoters. I consider this raises doubt about the appropriateness of such a ranking.

  • The ranking for the impact on water was also criticised by the Inspector.

In conclusion on the SA the Inspector said:

In my judgement the scoring of Option 1b above or equal to other options is not justified by the evidence. As a result, I consider that Policy SS3 and its supporting text are not justified, as, on the currently available evidence, it cannot be determined that it represents the most appropriate long-term growth strategy.

I consider that the post submission SA is therefore not robust and should not be relied upon in support of the Plan.

In addition, the Inspector clearly states:

Given my earlier findings in terms of the housing requirement, Policy SS3 is not required for the Plan to be sound and, in light of my comments above, I consider that the most appropriate course of action would be to remove it (along with any other necessary subsequent changes) from the Plan through Main Modifications (MMs). This would allow the Plan to progress towards adoption without any significant delay to the examination process…

I consider that it would not be unsound for the Plan to retain the Council’s aspirations to plan for long-term needs beyond the Plan period, which could include the delivery of a new settlement. But, the Plan should clearly state that this, as a growth option, would need to be fully considered and evidenced in a future (potentially early or immediate) review of the Plan or a subsequent DPD…

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options…

I am also mindful that following further work, there can be no guarantee that the evidence would support it as the most appropriate long-term growth strategy or that Policy SS3 would be found sound.

 

 

Appendix B: Local Plan Modifications and Sustainability Appraisal Addendum

The main modification related to removing Policy SS3, New Settlement from the Hart Local Plan can be found below. The full consultation can be found here.

Winchfield Fights Back - Shapley Heath Policy SS3 removed from Hart Local Plan

Winchfield Fights Back – Shapley Heath Policy SS3 removed from Hart Local Plan

The Sustainability Appraisal Addendum accompanying the consultation into the Main Modifications to the Local Plan can be found here.

I draw your attention to page 2:

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

 

Appendix C: Bid Commitments and Lack of Current Plans

No doubt you already have a copy of their bid commitment. Here is the commitment to produce a New Settlement DPD for consultation by December 2019.

Winchfield Fights Back: Shapley Heath New Town Bid Timeline for DPD

New Settlement Bid Timeline for DPD

The draft minutes from the Hart Council meeting held on 25 July 2019 can be found here. I refer you to Q&A in Appendix A.

Here is the response that shows no plans to carry out the additional SA work required by the Inspector:

Winchfield fights back: No plan for SA work

Winchfield fights back: No plan for SA work

No plans to allocate budget:

Hart Council has no idea how it will spend £786K winchfield new town money

Hart Council Knows Nothing: No idea how much of £786K will be spent or when

No plans for a New Settlement DPD.

Hart Council has no plan for Winchfield New Town proposals

Hart Council Knows Nothing: No plan for New Settlement DPD

 

Appendix D – Deceptive Communications

Statement at Hart Cabinet in July that both Homes England and MHCLG were informed:

Winchfield fights back: Chairman Announcement MHCLG kept informed

Winchfield fights back: Chairman Announcement MHCLG kept informed

Question asking how MHCLG and Homes England were kept informed of the changing status of the New Settlement in Policy SS3 in the Hart Local Plan.

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

 

The subsequent release of correspondence shows only one email to Kevin Bourner informing him in passing of the removal of Policy SS3. This can be found here.

Key passage:

Winchfield fights back: HDC email to Homes England

Winchfield fights back: HDC email to Homes England

The only correspondence with MHCLG prior to the announcement is asking for an update on the announcement timetable. This email is not addressed to Simon Ridley who made the award.