Hart Local Plan Examination Update

Posted on July 29, 2018July 28, 2018

It looks like quite a lot has been going on in relation to the Hart Local Plan examination. We have updates on:

Timing of the Hart Local Plan examination hearings
Early stage procedures for the Hart Local Plan examination
National Planning Policy Framework (NPPF) applying to the examination
Impact on Pale Lane (aka Elvetham Chase) appeal

Timing of the Hart Local Plan Examination hearings

Back in June, Hart Council briefed the Parish Councils about the Hart Local Plan examination. The full briefing can be found on the download below. They set the expectation that the Local Plan examination would start in late September and last 2-3 weeks.

Hart Local Plan Examination Briefing 12 June 2018 – Hearing Sessions

We have been in touch with the Programme Officer, a man called Ian Kemp, who can be contacted here. He tells us that he has:

Provisionally scheduled hearings during the weeks of 19/11 and 3/12.

So, the examination is going to be 2 months later than Hart’s estimate.

Early stage procedures for the Hart Local Plan examination

In the June briefing Hart said that the Planning Inspector would issue a note in mid-July explaining the role of the Programme Officer and the status of any modifications to the Local Plan. This note was also to cover the timetable for submitting additional material and how the hearing sessions would work.

Hart Local Plan Examination Briefing 12 June 2018 – Timetable

Ian Kemp tells us that he is:

Required to contact all representors six weeks prior to the start of the Examination to relay the details and arrangements. For the moment, the Inspector is in the early stages of his preparation.

So, it looks like we won’t know more details about how the Examination will be conducted around the beginning of October.

NPPF Framework applying to the Hart Local Plan examination

The revised National Planning Policy Framework has been released recently. Fortunately, it contains clause 214 that says:

Policies in the previous Framework will apply for the purpose of examining plans, where those plans are submitted on or before 24 January 2019.

This means that the Hart Local plan will be examined under the old framework. This might be mixed news. On the plus side, they won’t be examined on policies they didn’t know about when they were preparing the plan. On the negative side, it may well mean that the housing numbers that will apply to the examination will be those in the SHMA (8,022 or 382 dwellings per annum or so over the period 2011-2032), rather than the new figures in the Government consultation.

As a reminder, the Government figures were for 292 dpa, which results in a total of 4,672 over the shorter planning period of 2016-2032. However, Hart decided to increase this to 388dpa over the same period. We suspect the housing numbers will become a big debating point in the examination.

Impact on Pale Lane (Elvetham Chase) Appeal

The Pale Lane (Elvetham Chase) appeal hearing has been scheduled to being on 8 January 2019. This date in contained in a new schedule published on the planning inspectorate website, that can also be found here.

Pale Lane Appeal details APP/N1730/W/18/3204011

On the face of it, this looks like good news as it seems most likely to us that the appeal will not be upheld. Assuming the Local Plan is found to be sound in December 2018, and Pale Lane is not on the list of approved sites, then we cannot see how the inspector can uphold the appeal. However, if the Hart Local Plan examination finds the plan unsound, then Pale Lane may go ahead.

Hart Local Plan Submission Briefing

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Parish Council demolishes Winchfield new town plan

Posted on July 9, 2018July 28, 2018

Figure 6 Winchfield New Town Summary of Key Findings

Winchfield new town area not suitable for large scale development

The Parish Council have demolished plans for the proposed Winchfield new town in their submission to the Hart Local Plan Regulation 19 consultation. The have produced a 690-page report that can be found here. Their main conclusions about Policy SS3 that calls for the new town to be built in the area of search are (our emphasis):

Our review of the available technical evidence, with STR005 released only through a FOI request, demonstrates the highly constrained nature of the AoS, and the significant environmental and infrastructure issues that need to be overcome. A Site Appraisal prepared by Michelle Bolger Expert Landscape Consultancy is provided and this demonstrates that the AoS is significantly constrained and concludes that little land exists within the AoS which could be considered suitable for large scale residential development. We flag up the complete failure of the Draft Plan to identify the key infrastructure necessary for the provision of a new settlement, or indicate how it will be provided, by whom and when. Given the complete lack of any detailed evidence demonstrating that a new settlement is either deliverable or viable, we do not see how provision can be made for it within the Draft Plan.

Winchfield New Town Expert Evidence

The expert evidence from Michelle Bolger is a joy to behold. Her much shorter report can be downloaded from the link below, together with the appendix that contains the wonderful graphics depicting all of the constraints on the area of search.

The final summary is shown on the image above. This summarises the findings of the whole report in relation to the various sites that have been put forward, concluding (emphasis mine):

All of the sites are significantly constrained and the vast majority of the area of search (AoS) south of the M3/Railway is considered to be unsuitable for large scale development (i.e. it would cause severe landscape harm that would be difficult to remedy or mitigate)…

Land within the north-western parts of the AoS…are also significantly constrained. Development here could not occur without harm to the local countryside character and this would also impact upon the character and enjoyment of the Public Right of Way network. Development may also result in visual coalescence between Hartley Wintney and Hook.

Overall this appraisal finds that the AoS identifies a landscape that is highly unsuitable for large scale residential development. The new settlement envisaged by draft policy SS3 would result in significant landscape and visual harm and be at risk of harming components within the landscape which hold high landscape, amenity, ecological and heritage value.

The build up to the final conclusion starts with the area of search:

Figure 1 Winchfield new town Area of Search and Context

It then goes on to show Hart’s own landscape capacity study which shows that most of the area has low or low/medium capacity. The only area with medium/high capacity is the proposed Elvetham Chase (Pale Lane) site and it’s westward extension towards Winchfield. The Murrell Green area is shown as Medium capacity. However, this was decided before the Major Accident Hazard gas pipeline was discovered by Hart Council.

Figure 2 Winchfield New Town Landscape Capacity Study

Figure 2 Winchfield Landscape Capacity Study

The paper then goes on to identify the constraints in the area of search, starting with areas designated as SSSI’s, SINCs, tree preservation orders, ancient woodland, and listed buildings.

Figure 3 Winchfield New Town Key Constraints Designations

Then other constraints such as visual sensitivity, flooding, footpaths, unavailable land, landfill, narrow bridges, high voltage transmission lines and the gas pipeline are added:

Figure 4 Winchfield New Town Key Constraints Assessment

Figure 4 Winchfield Key Constraints Assessment

Then all of the constraints are brought together on one diagram, showing just how little land exists within the AoS that could be considered suitable for large scale residential development.

Figure 5 Winchfield New Town Key Constraints Composite

Figure 5 Winchfield Key Constraints Composite

All of this report is drawn from pre-existing material. One wonders why Hart Council is continuing to promote such a daft idea. Certainly, £50K is not going to cover costs of putting together a robust Winchfield new town master-plan to fulfill all of their magical promises to turn horses into unicorns. We shall see what the inspector makes of this.

The report and appendix can be downloaded here:

Winchfield Site Appraisal

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Winchfield Site Appraisal Appendix

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Hart Council budgets only £50K for Winchfield new town plan

Posted on June 30, 2018July 28, 2018

Hart District Council sets aside laughable budget for Winchfield new town plan

Hart District Council budgets only £50K for Winchfield new town plan

Questions put to Hart Council earlier this week have revealed they have set aside a budget of only £50,000 to create the detailed development plan for the Winchfield new town. Apparently, they are hoping for additional contributions from developers.

This is quite astonishing. There have been numerous statements made by councillors saying they want the plan to be council lead and not developer led. They’ve also made statements about the amount of infrastructure that will be delivered.

We suggest that the council has set aside barely a tenth of the money that will be required to:

Conduct sustainability assessments
Infrastructure studies
Habitat assessments
Flood assessments
Master-planning

This revelation shows the councillors were either lying through their teeth or were completely incompetent (or both). They are clearly going to rely on funding from developers so the developers are going to be in the driving seat.

Of course another interpretation of this pitiful budget is that they are anticipating the Winchfield new town being knocked out of the Hart Local Plan at examination.

In other news, it is now expected that the Hart Local Plan examination will start in mid-November and last 2-3 weeks.

The questions and contemporaneous account of the questions and answers are shown below:

Questions about Winchfield New Town

Q1: I understand the Local Plan has been submitted and Council “commits to planning for a new settlement at Murrel Green/Winchfield” to “provide a substantial contingency to any increase in the Government figures that could, in theory, result in an unmet need arising elsewhere in the HMA” (para 108).

Accepting that the requirement for the contingency for houses needed in Hart in excess of Government guidelines may or may not materialise, as evidenced by future plan revisions, could Council reassure Hart residents that, in the event it does not, planning permission will not be given for the new settlement?

Answer: No. The Government is keen to have houses in addition to the basic suggested figure and there is therefore a need to boost the numbers [But not apparently on brownfield sites!!]

Supplementary:

If, as the draft local plan suggests, all Hart’s housing needs are already provided for in the current plan period to 2032 without the need for a new settlement, should not the start of any construction of the new settlement be deferred until after 2032 at the earliest?

Answer: No. The lead time for a new settlement is long and the future requirement for housing uncertain – the start of building can’t be left to the last minute.

Q2. The Council committing to planning for a new settlement means Hart residents will be required to fund a substantial sum for the necessary consultants’ reports etc. Can the Council please say 1) How much is budgeted for this and 2) how much of this will be provided by the parties who will benefit financially from the building of the new settlement?

Answer: £50,000 is the sum that has been initially set aside in the budget. Contributions from developers will be welcome [This number is laughable – a proper DPD will surely run into £000,000s]

Supplementary: The area of search for the new settlement includes Murrell Green (possible 2,990 houses) and Winchfield (possible 2,400 houses). The proposals come from separate developers. Is the intention to pursue one or the other development, or rather to combine the two?

Answer: It was not possible to chose between the two originally. Hence the “area of search” idea. The DPD will determine the answer to the question. [Despite 3 years of testing!!]

Q3: The draft plan gives no indication of the size of the proposed new settlement, other than to say it must be “viable”. What approximate size is considered viable, recognising that this will be further examined in the DPD

Answer: The DPD will determine

Supplementary: I am not aware of any consultation with Winchfield residents about the possible shape, size and layout of the proposed new settlement, although Members were shown a four-page artist’s illustration dated August 2017 which I found in the Local Plan examination library. When and how will the Winchfield community be consulted if the new settlement idea survives inspection

Answer: There will be plenty of opportunity through the DPD and the usual consultation process which has already been followed.

Q4. What is the current status and expected number of Surrey Heath’s unmet housing need and what proportion of this unmet need would Hart be expected to meet?

Answer: Currently not known, SH haven’t yet come up with numbers

Hart Local Plan Submission details revealed

Posted on June 14, 2018June 14, 2018

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

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Elvetham Chase Appeal Documents Revealed

Posted on June 8, 2018June 8, 2018

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

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

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

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

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Wates Elvetham Chase/ Pale Lane Appeal Statement of Common Ground

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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

Posted on May 30, 2018May 29, 2018

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

Posted on May 27, 2018June 8, 2018

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!

Posted on April 7, 2018April 6, 2018

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

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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 is the most sparsely populated town of its size in Britain (see above)
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)
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:

Fleet has ample opportunities for re-generation if only Hart would consider mixed-use (residential and retail) developments
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

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

Posted on March 24, 2018March 24, 2018

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:

Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
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.
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).
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:

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
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
A gap from Elvetham Heath/A323 to the River Hart and from Edenbrook/Hitches Lane to the River Hart
A gap from the east of Taplins Farm Lane/The Hurst to the River Hart.

Hart Local Plan: No plans for infrastructure

Posted on March 23, 2018March 24, 2018

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:

Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
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.
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).
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.

WHH Local Plan Reg 19 Guide

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WHH Local Plan Reg 19 Entry

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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 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 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.

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.