Hart Local Plan Submission details revealed

Hart Local Plan Submission details

Hart Local Plan Submission Details Revealed

Details of the Hart Local Plan submission process and details have been revealed. They are contained in a presentation given to a range of parish, town and district councillors on Tuesday 12 June.

The full presentation is available on the download below.

Key points include:

1. The documents will be submitted to the Secretary of State on 18 June 2018

2. The documents will include:

      • The Proposed Submission Hart Local Plan and Policies Map (unchanged from February (Reg19 version)

      • Schedule of minor modifications

      • Sustainability Appraisal

      • Statement of Community Involvement

      • Consultation Statement

      • Duty to Cooperate Statement

      • Copies of the representations

      • Habitats Regs Assessment

      • Evidence base documents

3. In around mid-July the Inspector will write to all those who submitted representations to outline the procedures and timetable.

4. The inspector will be focused on testing whether the plan is sound

5. The examination in public hearings are expected to start in late September and last for 2-3 weeks

6. Appearance at the hearings will be limited to those people who submitted representations to the consultation and who were seeking to change the plan

7. After the hearings there may be an additional consultation if modifications to the Plan are recommended as part of the examination

We understand that the representations made during the last consultation will be published around the same time as submission to the Secretary of State. Things are certainly hotting up, and it’s all to play for.

Hart Local Plan Submission Briefing

Elvetham Chase Appeal Documents Revealed

Wates Pale Lane aka Elvetham Chase Appeal

Elvetham Chase Appeal Documents

The Pale Lane aka Elvetham Chase appeal documents have been made available. At the time of writing, they haven’t yet been published on the Hart Council website, nor on the Planning Inspectorate website. These documents confirm our story that the Wates have appealed the decision to turn down the proposed development of 700 new houses.

The two documents can be found as downloads at the foot of this article.

The key elements of their statement of case are:

Elvetham Chase Appeal – Policies out of date

Elvetham Chase Appeal Policies out of date

Wates argue that the policies used to refuse the original application are out of date. This argument was successful when the Grove Farm development was approved on appeal.

Elvetham Chase Appeal – Little impact on Fleet

Elvetham Chase Appeal Policies little impact on Fleet

Wates also argue that, contrary to Hart’s refusal decision, the Pale Lane development will have little impact on Fleet. In addition, the policies Hart have used to justify this stance are out of date.

Elvetham Chase Appeal – Local Plan too slow

Elvetham Chase Appeal Policies Local Plan too slow

Wates are also arguing that Hart have not kept to their timetable for the Local Plan. There was supposed to be a presentation to members during May, prior to submission on 18 June. We understand that presentation did not happen, so the 18 June deadline may be at risk.

They also argue that the draft Local Plan and the site allocation may well face legal challenge.

The draft Local Plan doesn’t include Pale Lane in the site allocation. They say the plan is a long way from adoption and that refusal isn’t justified on those grounds. Wates are effectively saying that the draft Local Plan should carry very little weight in the appeal decision.

Elvetham Chase Appeal – Our View

We think the appeal will rest on this issue. If the Inspector believes the draft Local Plan carries significant weight, then he may well refuse the appeal. If however, he believes the opposite, then on the past precedent of Grove Farm, then he will probably allow the development to proceed.

We think Hart’s chances of successfully fighting this appeal are higher than Grove Farm, and it is probably worth the cost and effort of doing so. However, we hear some councillors are much less optimistic about Hart’s chances of success. Let’s hope common sense prevails and the appeal is dismissed.

We will work on what we think are the best arguments for fighting the appeal.

Wates Pale Lane/ Elvetham Chase Appeal Statement
Wates Elvetham Chase/ Pale Lane Appeal Statement of Common Ground

Appeal statement of case that can be found here.

Draft statement of common ground that can be found here.

 

Council announce Hart Local Plan Submission Date

Council announces Hart Local Plan submission date

Council announces Hart Local Plan submission date

The council has announced the submission date for the Hart Local Plan.

The news is contained in papers due to be considered by Cabinet on 7 June. The relevant paper can be found here.

They say the plan will be submitted during week commencing 18 June:

It is anticipated that the Hart Local Plan Strategy and Sites 2016-2032 Submission Version (the Submission Plan) will be submitted to the Secretary of State in the week commencing 18 June 2018. Once submitted the Submission Plan does not supersede the Hart Local Plan 1996 – 2006 (Saved Policies). The saved policies will still comprise the Development Plan for Hart.

This is in line with earlier commentary from the Joint Chief Executive at an earlier council meeting.

Impact of submitting the Hart Local Plan

Although the submitted plan doesn’t yet form the development plan for Hart, it should have some weight in determining planning applications (and one hopes, planning appeals):

The Submission Plan gains some weight in decision-making. Paragraph 216 of the National Planning Policy Framework (NPPF)) states that decision-takers may also give weight (unless material considerations indicate otherwise) to relevant policies in emerging plans according to:

  • The stage of preparation of the emerging plan (the more advanced the preparation, the greater the weight that may be given).

  • The extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given).

  • The degree of consistency of the relevant policies in the emerging plan to the policies in NPPF (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given).

The council’s comentary says:

The Submission Plan is at an advanced stage of preparation. Therefore, it should be given weight in the decision-making process and so upon submission to the Secretary of State it should be used in the determination of planning applications. Furthermore, as it reflects approved Council policy, applications that are determined in accordance with the Submission Plan should not be considered as representing “departures” where approval would otherwise require referral to Council for determination.

We can only hope that the submission of the Local Plan helps in fending off the unwelcome appeal against the decision to refuse planning permission for 700 new houses at Pale Lane.

Wates launch Elvetham Chase aka Pale Lane appeal

Wates launch Elvetham Chase aka Pale Lane appeal

Elvetham Chase aka Pale Lane appeal

[Update 1: 29/5/2018: We understand that the developers have stated they intend to appeal, but have not yet submitted the appeal documentation]

[Update 2: 6/6/2018: Story now confirmed by Fleet News and Mail. Copy here.]

[Update 2: 8/6/2018: Appeal documents published here.]

We understand that the agents for the developers have submitted a Pale Lane appeal. The site, also known as Elvetham Chase was, quite rightly in our view, turned down for development of 700 new houses by Hart Council back in February. The developers, Wates, were apparently quite angry.

The Pale Lane appeal comes despite the recent Hart Local Plan Regulation 19 consultation. Of course, the draft Local Plan doesn’t include Pale Lane in the housing plans. We understand that Hart plan to submit the Local Plan to the inspector on 18 June. The plan published as part of the consultation has some weight to fend off this unwelcome development. That weight should increase when the plan is submitted to the Inspector. But it won’t have the same weight as a plan declared sound by the Inspector.

We don’t yet know the timeline for the Local Plan inspection hearing. Nor do we know the timeline for the Pale Lane (Elvetham Chase) appeal.

Impact of Pale Lane Appeal

So, this move sets in train some complex legal and procedural manoeuvres and a race agaisnt time for both Hart and Wates. Clearly, Wates believe they can win or they wouldn’t be spending the money on the appeal. They are clearly hoping their appeal will be heard prior to the Local Plan being inspected and declared sound.

Despite opposing the development, we think the grounds for rejecting the proposed development were quite weak. The grounds for the decision can be found here. Unfortunately, Hart doesn’t have a good track record in defending appeals.

We have to hope that the current state of the Local Plan will provide stronger defence that the Council’s current outdated policies.

Fleet Regeneration – Yes we can!

Candidate for Fleet Regeneration: Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Council protecting from redevelopment.

We must deliver Fleet Regeneration

A guest post from Tristram Cary, chairman of the Rural Hart Association, setting out why we must and how we can deliver Fleet Regeneration.

Fleet Regeneration Report

40% of the population of Hart live in Fleet, and yet, in the Local Plan, Fleet is only taking only 21% of the housing development. This massive imbalance puts a huge strain on Hart’s countryside. It is extraordinary that Hart is preventing the regeneration of Fleet when you consider that:

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

  1. Fleet is the most sparsely populated town of its size in Britain (see above)
  2. Hart admits in para 236 of the Local Plan that, without regeneration, “it is unrealistic for Fleet to try to compete” for comparison shopping with neighbouring towns such as Camberley (which is the same size as Fleet)
  3. The new National Planning Policy Framework (para 86) requires districts to “take a positive approach to the development of Town Centres” and to “recognise that residential development often plays an important role in ensuring the vitality of Town Centres”

Hart’s extraordinary lack of ambition for Fleet is explained by Councillor Cockarill’s statement at the 4 January Council Meeting that any serious Fleet regeneration was “a pipedream”. Hart claims that Fleet is full, and that it would not be possible to raise any serious money for its regeneration.

The Rural Hart Association (RHA) commissioned a study from Lambert Smith Hampton (LSH), a leading Town Centre regeneration specialist, to analyse the potential for Fleet regeneration. This study was submitted to Hart in response to the Reg 19 Consultation, and the full document is available on the link above. The key findings of the study are that:

  1. Fleet has ample opportunities for re-generation if only Hart would consider mixed-use (residential and retail) developments
  2. It is hopeless for Fleet to resist the residential conversion of redundant office blocks – there is no realistic prospect of these ever being revived for business use.

It’s worth reading the following summaries provided by directors of LSH.

“As has been widely reported the growth of online retail sales is having a major impact on the retail landscape – online sales are currently circa 16% of all UK sales and growing annually. There is a fundamental structural change in our shopping habits which in turn is having a major impact on retailers and town centres. The retail centres that are thriving tend to be those regional locations offering a high quality experiential mix of retail and leisure or the smaller centres that are able to provide easily accessed, convenience retail facilities in an aesthetically pleasing environment.

Interestingly, we have started to witness retail assets (shopping centres and retail parks) particularly in the South East being acquired or redeveloped for their residential potential.  In some instances, we are seeing retail being proposed above shopping centres and in other instances the complete redevelopment for residential – examples include Forbury Park in Reading which has consent for 765 homes and Whitley’s Shopping Centre in Bayswater which is to be redeveloped for a mixed retail and residential scheme. This trend is likely to continue especially in areas where residential values are high and the retail assets are stagnating.

The Hart Shopping Centre could offer such potential in the future – retaining strong convenience retail facilities at ground floor level with retailers such as Waitrose but with residential accommodation on the upper parts.

What is clear, is that on a national basis we have too many shops and alternative uses, in particular residential, is a desirable way of regenerating our town centres”.

Sean Prigmore, Retail Director, Lambert Smith Hampton

And,

“I have been actively involved in the Fleet office market for more than 30 years.

The office market in Fleet has been in decline for a number of years as larger corporates have vacated to consolidate occupation in larger centers and locations benefitting from more amenity – such as Farnborough Business Park. Key Business centres such as Reading and Basingstoke have prospered whilst the smaller satellite office location such as Fleet are finding it harder to prove their relevance as office locations. M3 HQ, 70,000 sq ft on ABP, has been vacant for many years and is unlikely to be occupied as offices again. There is the potential to enable redevelopment of larger unwanted office stock for residential and to focus B1 provision in locations better served by public transport and amenity and in buildings which will allow business space for the SME sector where what demand there is lies.”

Paul Dowson , Director, Lambert Smith Hampton

Fleet Regeneration Sites

Fleet Regeneration Sites

The Lambert Smith Hampton report identifies eight sites in Fleet Town centre which between them could provide 990 homes in mixed-use developments, and LSH is confident that these sites would attract developer investment. [Personally, I would add the entire civic quarter – ed]. It is shocking that Hart has turned its back on mixed use developments in Fleet without even investigating their potential. We hope that Hart Council will restructure its Local Plan to take account of the LSH report before submitting it for Inspection.

[Note that this is exactly in line with Ranil’s call for regeneration of our urban centres – ed]

Hart Local Plan: Restore strategic gaps

Hart Regulation 18 Strategic gaps

Hart Local Plan Regulation 19 consultation removes the Regulation 18 Strategic Gaps

This is the sixth and final part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart have removed the strategic gaps around Harley Wintney and Hook that were present in the last consultation. We believe they should restore them and policy NBe2 should be amended.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE.
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.

Restore the strategic gaps to the Hart Local Plan Regulation 19 Consultation

The Local Plan identifies strategic gaps between settlements.

Hart Local Plan Regulation 19: Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

Hart Local Plan Regulation 19 Consultation Strategic Gaps

However, no gaps are proposed to the east of Hook, to the north west of Fleet or anywhere around Hartley Wintney. This is contrary to the Regulation 18 consultation (see top), where strategic gaps were included to the east of Hook and the SW of Hartley Wintney. These should be restored and new ones added to give effective gaps between Winchfield and the west of Fleet/Elvetham Heath to avoid coalescence into a Hartley Winchook urban sprawl.

Remedy: This policy needs to be amended to include:

  1. A gap to the west of Hook from the east bank of the River Whitewater to at least the power line between Hook and Hartley Wintney
  2. A gap to the south and west of Hartley Wintney/Phoenix Green. This should be at both sides of the A30, from the existing end of development to the Murrell Green light-industrial estate and from St Mary’s Park to the motorway
  3. A gap from Elvetham Heath/A323 to the River Hart and from Edenbrook/Hitches Lane to the River Hart
  4. A gap from the east of Taplins Farm Lane/The Hurst to the River Hart.

 

Hart Local Plan: No plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

This is the fifth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart haven’t properly planned for infrastructure. In addition, the plans they do have will starve the places that really need it of investment. Policy I1 needs to be changed and policy SS3 needs to be removed. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan Regulation 19 consultation needs to be changed to deal with infrastructure

One leading councillor has gone on the record, calling for an ‘infrastructure led’ Local Plan. Yet, they have not allowed questions to be put to them about infrastructure, let alone answer them.

Back in October 2014, Hart Council produced an infrastructure delivery schedule that set out the current deficit, split by type and area.  This shows a deficit of £78m not including healthcare facilities. The breakdown is shown by type and area in the images below:

Hart Local Plan Regulation 19 consultation: Hart District Estimated Infrastructure costs by type March 2013.

Hart District Estimated Infrastructure costs by type March 2013.

The breakdown of the costs by area showed the Fleet/Church Crookham and Hook areas had by far the largest deficits.

Hart Local Plan Regulation 19 consultation: Estimated Infrastructure costs by area March 2013

Hart District Estimated Infrastructure costs by area March 2013

Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It should be noted also that SWR has recently put forward proposals to reduce services at Winchfield and Hook, exacerbating the rail capacity problem. The Local Plan doesn’t even mention improvements to the rail network in infrastructure policies.

A more recent estimate from Hampshire County Council has estimated the infrastructure funding gap for Hart as £72m.

Hart Local Plan Regulation 19 consultation: Hart infrastructure funding gap £72m

Hart infrastructure funding gap £72m

Hart’s share of the gap is made up of:

  • Transport, £34m
  • Education: £38m.
  • Countryside: To be Determined.
  • Extra Care places: To be Determined.

No estimate has been made of the requirements or costs of additional healthcare provision.

The infrastructure policies in the Local Plan are insipid and fail to address the funding gap:

  • Policy I1: Infrastructure – weak policy simply requiring developers to deliver adequate infrastructure as part of their developments, when the studies above show that developer contributions won’t be adequate to bridge the gap
  • Policy I2: Green Infrastructure – feeble policy to supposedly protect green infrastructure. Yet they are proposing to build a new town that will destroy the best of our green infrastructure
  • Policy I3: Transport – inadequate policy simply to provide ‘maximum flexibility in the choice of travel modes’, nothing specific to improve road network or put pressure on SWR to improve rail
  • Policy I4: Open space, sport and recreation – policy to support development that improves sporting facilities, but no tangible plans for anything new
  • Policy I5: Community Facilities – a very vague policy to improve childcare facilities, healthcare, police stations, youth provision, libraries, community halls, local shops, meeting places, cultural buildings, public houses, places of worship, and public toilets. But crucially, no specific projects or proposals.

Yet, the National Planning Policy Framework (NPPF) is clear that infrastructure must be planned alongside new housing. Failure to adequately plan for infrastructure requirements and costs could lead to the Local Plan being found unsound. See references to paras 17 and 177 of the NPPF below.

plan to avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

It is clear from this post, that the proposals to build a new town will probably exacerbate the existing funding gap and not deliver any infrastructure in Fleet, Church Crookham and Hook, the very places where funding is most required.

Remedy: We therefore think the remedy to this issue should be that policy SS3 is removed in its entirety (with consequent changes to policy SS1 already outlined elsewhere). The infrastructure policies should be reworked to include as a minimum:

  • Acknowledgement of the existing £72m infrastructure funding gap
  • Quantification of the items missing from the Hampshire County Council assessment such as healthcare, extra-care housing for the elderly and green infrastructure
  • A set of prioritised, costed projects that are required to alleviate the worst of our infrastructure problems in Fleet/Church Crookham and Hook. This should include road improvements, particularly near Fleet station and the bridge over the railway near the end of Elvetham Heath Road. It should also include significant improvements to the cultural facilities, particularly in Fleet.
  • Plans to tackle Network Rail/SWR over rail capacity and services
  • Proposals for raising the necessary funds for delivering the required projects
  • Some external validation that the infrastructure plans in the draft Local Plan are ‘sound’ and will pass inspection

We believe that in preparation for the next review of the plan, a new policy should be created to regenerate our urban centres including attracting private capital so that we create a better place to live and address the existing infrastructure problems before even considering a new town that will only make matters worse.

Hart Local Plan: Missed opportunity to regenerate urban centres

Hart Local Plan Regulation 19 consultation won't regenerate Old Police Station in Fleet, Hart District, Hampshire

Hart Local Plan Regulation 19 consultation: Missed opportunity to regenerate urban centres

This is the fourth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how we are missing the opportunity to regenerate our urban centres and why Policies Policies ED4, 5 and 6 (and SS3) need to be removed for the time being until we come up with a proper regeneration strategy. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE.
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

Hart Local Plan Regulation 19 Consultation: MIssed regeneration opportunity

Fleet is the lowest density town of its size in the country. The chart below shows that there is significant scope for increasing development density in Fleet.
Hart Local Plan Regulation 19 consultation: Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

The retail offer in Fleet is poor, the cultural facilities (e.g. Harlington Centre) are outdated and there is no proper cinema. We might as well employ botanists to identify the new species of tumbleweed appearing in the Hart Shopping Centre.

Hart Local Plan Regulation 19 consultation: Fleet Health score versus benchmarks

Fleet Health score versus benchmarks

However, Fleet has the highest average earnings per person of comparative towns by quite a large margin (e.g.: 9% more than Camberley). High earnings should give Fleet a significant advantage over the comparison towns.

Hart Local Plan Regulation 19 consultation: Fleet earnings versus competitors

Fleet earnings versus competitors

The Local Plan fails to take advantage of the opportunity to modernise Hart’s urban centres and protect Hart’s countryside.

We believe that the Local Plan should be centred on the proposition that Fleet and other urban centres will be re-generated. With Hart District Council’s full and active support, a plan based on urban regeneration would achieve the following benefits:

  1. An ambitious Hart Urban Re-generation Project (HURP) would attract private investment and thus be affordable
  2. Private investment would allow for Hart’s infrastructure to be upgraded in line with the urban re-generation
  3. Good urban design principles would achieve a higher population density in the urban centres while at the same time providing an improved ‘sense of place’ and making the urban centres more desirable places to live.

A similar approach could be adopted in Yateley to provide a proper retail-led centre and improvements could be made to Blackwater. The requirement for additional retail facilities in Hook, identified in the Reg 18 Local Plan could also be met.

Hart did have a plan to conduct a brownfield study (We Heart Hart helped to write the terms of reference) to evaluate the ‘art of the possible’ in our urban centres. This project has not delivered.

In addition, Yateley lacks a defined centre, Blackwater is indistinct and Hook lacks good quality restaurants and shopping facilities.

The council should be setting out a bold plan to improve the retail, cultural and recreational amenities in the district. We should also develop plans for a theatre and cinema in Fleet as part of an attractive mixed-use redevelopment. There will be significant cash available from developers to fund such an ambitious plan.

Instead of creating a proper masterplan,  Fleet Town Council are pursuing an ill-thought out plan for a new theatre that will leave the existing Harlington Centre to rot. This is not regeneration in any meaningful sense of the word.

Our local MP, Ranil Jaywardena, has launched a campaign to regenerate our urban centres. He said:

Looking to some of our local, district and town centres, however, it is clear to see that Fleet, Yateley and Hook are all in real need of revitalisation and regeneration. I’ve been spending time speaking to your local Councillors about this and taking a look at the work that needs to be done.

I am more convinced than ever that all three places have great potential – be that simply as shopping destinations or, with the right infrastructure improvements, as great places for our young people to get their foot on the housing ladder.

The trouble is that there is no ‘masterplan’ for any of these places. I will be raising this with Hart District Council personally – but I need your help. If you want smart new shops, some new flats for local young people to buy above them and better car parking, then act now.

The BBC has recently interviewed a number of people in Fleet about what it is like to live there. Everybody loves it, but they think there’s been too much housing and not enough infrastructure. The draft Local Plan won’t fix either of those issues, because they’re insisting on building too many houses and aren’t addressing infrastructure.

However, policies ED4, 5 and 6 effectively cast the existing centres in aspic and preclude significant redevelopment. I do not have the resources available to me to completely re-write these policies.

Remedy:  Policies ED4, 5 and 6 should be removed for the time being and a proper community team put together to work with our local councillors and MP to come up with a master plan to regenerate our town centres. Policy SS3 (together with the consequent changes to SS1 already outlined) should also be removed, so that time and energy can be freed up to address the fundamental problem of our urban centres.

Hart Local Plan: Remove brownfield restrictions

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

Hart Local Plan restricting redevelopment of sites like this

This is the third part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains how Hart’s policies are restricting brownfield redevelopment and why they must remove policy ED2, change their SANG policy and remove their Article 4 direction on Permitted Development Rights.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan restricts brownfield development

Policy ED2 relates to safeguarding employment land and Para 297 refers to SANG owned by the council.

Policy ED2 protects essentially every major employment site in the district from redevelopment.

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

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

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

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

We believe this is contrary to Government policy.

Remedy: Consequently policy ED2 should be removed.

Moreover, the Inspector should be aware that the council has implemented a new policy regarding SANG that effectively further obstructs brownfield development. This is already blocking schemes that would provide homes that ordinary people can afford (as distinct from Affordable Homes that ordinary people can’t afford). The schemes affected are a conversion on Ancells Farm and proposals to redevelop the old police station in Fleet town centre. It has been suggested that this SANG policy may be unlawful.

In addition, Hart has commenced work to implement an Article 4 direction to block permitted development on brownfield sites.

In effect they have set some nice sounding objectives about protecting our historic assets and building green infrastructure, but their policies act against their objectives and actively create a worse place to live by leaving decrepit buildings to rot and scar the landscape.

We think the Inspector should also take a view on these policies since they are closely related to the Local Plan, even though they are not contained within it.

Remedy: We believe that the SANG policy and the Article 4 direction should be removed

Hart Local Plan: Amend Policy SS1 to a sensible housing target

 

This is the second part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains why we are planning to build too many houses and why Policy SS1 needs to be amended to a more sensible target. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry
Policy SS1 deals with the spatial strategy. We disagree with the quantum of new housing proposed in the draft Local Plan.

First, the numbers proposed are far too high and they are unsustainable. Second, the long term effect of planning for too many houses is that the initial effects are compounded, leading to permanent unsustainability.

Proposed numbers in the Hart Local Plan are far too high and unsustainable

They propose 6,208 now homes over the plan period at a rate of 388dpa. This is both unnecessary and undesirable on a number of grounds:

The 2016 SHMA called for 8,022 new dwellings over the period 2011-2032. This was already too many.  For reasons explained in more detail here:

  • The starting point was inappropriate, using 2012 DCLG forecasts instead of the 2014-based figures.
  • The affordable housing uplift was inappropriate because it was proposing to help those already renting but not able to buy. By definition, these people are already housed and therefore do not need an additional house to be built. Any arguments about building more houses increasing supply and thus reducing prices are spurious because any reasonable expectation of building will have only a negligible impact on prices. This is explained by Ian Mulheirn of Oxford Economics here.
  • The jobs growth adjustment was inappropriate, anticipating higher rates of jobs growth than seen in periods of much higher economic growth. The SHMA then acknowledged that most of the extra people brought in by these extra houses will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.

Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.

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

Clearly, this uplift was not an expression of the ‘need’ for the district. More importantly, building extra, unnecessary houses will then cause more people to move into the district. Because the employment space is sub-standard and not in a strategic location, these people will commute elsewhere each day to work. This is the very antithesis of sustainable development.

I think these arguments make clear that the target of 8,022 houses over the old plan period of 2011-2032 was unsound and unsustainable. This is further borne out by the analysis of Alan Wenban-Smith.

The current draft Local Plan calls for 6,208 houses to be built over the period 2016-2032. Hart built 1,830 houses over the period 2011-2016. This makes the total target over the comparable period 8,038 houses. This is more than the prior target in the SHMA despite the new Government method for calculating housing need showing a much slower rate of building being required. This is also unsustainable for the same reasons as above.

Hart housing completions for the Hart Local Plan Regulation 19 Consultation

Basically, the council have found a way of arbitrarily adding back unnecessary houses without even the fig leaf of the flawed justifications used in the prior SHMA.

Their current proposal is for 6,208 houses or 388 dpa over the period 2016-2032. This is made up of the Government target of 292dpa. This figure itself is made up of the raw DCLG household projections plus an agreed ‘affordability uplift’ because Hart’s house prices are very high. They then remove the 40% cap on the affordability uplift and add and further 25% uplift to the result.

Hart Housing Numbers

Their justifications for the 25% uplift are:

  • Contingency against increase. I would suggest that adding to the housing target is an inappropriate way of dealing with this issue. It would be more appropriate demonstrate there is flexibility in housing supply to meet potential additional demand, rather than add extra demand without knowing it is there.
  • Affordable housing delivery. This has already been accounted for in the 292dpa Government figure. In any event, as discussed above, building more won’t make a significant difference to house prices, and so won’t make houses any more affordable for people already living here, so it’s a spurious argument.
  • Previously developed land. We have no idea what this means.
  • Buffer against non-delivery. Again this is a spurious argument. The way to deal with this issue is to demonstrate flexibility in supply, not add additional demand.

Taken together their reasons are spurious and do not stand up to any sort of scrutiny.

Faster building doesn’t make prices more affordable

As an aside, the actual rate of building in the period April 2011 to March 2016 is 1,830/5 = 366 dpa. This is well above both the raw demographic change in the Government household forecasts (208dpa) and the 292dpa rate to take account of the affordability uplift. We are constantly being told that we should be building ~250,000 houses per year across the country, and the 292dpa is Hart’s share of that. So, it would appear that Hart’s rate of house-building is also well above the pro-rata rate of house-building in the rest of England and Wales as we are constantly being told that the country isn’t building enough houses. According to the theory, this rate of over-building ought to result in at least a relative reduction in prices compared to the rest of the country.

However, examination of Land Registry data from April 2011 to March 2017 returns an interesting result.

Region

Average House Price April 2011 Average House Price March 2017

% Increase

England

        175,490

 231,826

32.1%

England and Wales           172,921

        226,860

31.2%

Hart

         275,859

         397,632

44.1%

Despite having a very high rate of building, compared to the rest of the country, house prices in Hart have risen much more quickly. This effectively nails the lie that building more will effectively make houses more affordable.

Compounding effect results in permanent unsustainability

The new Government methodology to calculate housing need uses the latest demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings. Overall, they come up with a national target that is in-line with the anticipated future needs. It follows that if councils deviate significantly from these proposals, that overall demand and supply will be out of balance.

We argue that not only is Hart’s proposed housing number unsustainable in its own right, but that this unsustainability will be projected into the future ad infinitum. This is clearly an absurd result that needs to be challenged. This is illustrated below, using figures from the previous Reg 18 consultation, but the concept remains sound.

When the prior Hart Local Plan was calling for 10,185 houses to be built, we carried out some modelling  to work out how the unsustainable rate of growth would be affected by reapplying the Government methodology at five year intervals from 2016.

Essentially, the Government figures work by projecting forwards the trends of the previous five years, to arrive at a household projection estimate. An affordability uplift is then applied to this result to generate the building rate required for the subsequent period. In areas with high house prices, like Hart, because building more will have negligibler impact on prices, the affordability uplift would be essentially compounded at each five year review point.

This could end up leading to massive increases in unnecessary housing requirements towards the end of the plan period. This will apply regardless of the starting point. However, if the starting build rate is artificially inflated, then this too will continue to be compounded into the future. We will be faced with still more housing, more people migrating into Hart and then working elsewhere. This is again the very definition of unsustainability.

An example of how this worked with the prior Local Plan housing target of 10,185 is shown in the chart below.

Hart housing requirement using Local Plan figures

Hart housing requirement using Reg 18 Local Plan figures

Essentially, it resulted in a rate of house-building that was more than double that set at the outset by the Government household projections. The effect will be less severe with the housing numbers proposed in the new Local Plan, but will nevertheless lead to significant, unsustainable over-building.

Therefore we believe that the starting point for the Local Plan should be no more than the Government’s target of 292dpa or 4,672 dwellings in total. Because it isn’t yet clear whether Surrey Heath can meet its requirement, we would be prudent and add a few hundred to this to give a round number total target of 5,100 houses.

Remedy to the Hart Local Plan: We would therefore suggest that policy SS1 be adjusted accordingly:

New Homes

Subject to the availability of deliverable avoidance and mitigation measures in respect of the Thames Basin Heaths Special Protection Area, provision is made for the delivery of at least 6,208 5,100 new homes (388 319 new homes per annum) between 2016 and 2032.