Hart’s Brownfield Register fails to meet expectations

 

Brownfield site: vacant offices at Ancells Farm Business Park, Fleet, Hart District, Hampshire.

Brownfield site: vacant offices at Ancells Farm Business Park, Fleet, Hart District, Hampshire.

Hart District Council has at last published its register of brownfield sites in the district. Sadly, the register has failed to live up to expectations. The full register can be downloaded on the link below.

The purpose of the brownfield register is to provide house builders with up-to-date and publicly available information on all brownfield sites available for housing locally. The register is supposed to help housebuilders identify suitable sites quickly, speeding up the construction of new homes. Hart Council was one of the pilot local authorities participating in the national brownfield register scheme as announced back in March 2016.

At first glance, the register identifies 3,542 potential units on brownfield sites, which might be considered good news.  However, closer inspection of the register reveals:

  • All but two of the sites already have planning permission, indeed a number of them have already been built (e.g. Queen Elizabeth Barracks at Church Crookham, Landata House in Hook, and Monachus House in Hartley Wintney).
  • Some of the sites are not even brownfield sites, for example Rifle Range Farm in Hartley Wintney.
  • None of the sites that Hart Council itself identified as brownfield sites in the recent consultation are recorded in the register.
  • None of the other potential sites that have not yet been permitted on Ancells Farm or along Fleet Road have made it on to the register.
  • Very few, if any, of the brownfield sites in the SHLAA that we identified in our brownfield solution, most particularly sites like the former police college at Bramshill have made it into the register.
  • Over 2,000 of the units in the register have already been granted planning permission, with 1,500 units at Hartland Village (aka Pyestock) and 16 at another site yet to be granted permission.

We have contacted the council to find out the reasons why this important opportunity has been botched. We have been told this is a temporary blip due to lack of SANG capacity.  We are far from convinced of this reason as the register itself has a column for constraints.  The purpose of the register should be to identify all of the sites and not miss some out because SANG capacity is not yet available.

We do hope that Hart Council gets to grips with this, because a robust brownfield register will be a significant piece of evidence, as part of the Local Plan, to help fend off the proposals to build at Pale Lane (Elvetham Chase) and Grove Farm (Netherhouse Copse). The register of brownfield sites  becomes a statutory obligation next year.

Hart Council Brownfield Register

Election update: Hook candidates declare their positions

We Love Hart Ballot Box

Hook Action Against Over Development have been in touch with some of the local candidates for Hook ward in the Hart District Council local elections 2016, and managed to get some additional information out of their local candidates and have circulated this in an email to their supporters.

This is reproduced below, with our response where appropriate. The appropriate detailed pages for each party have been updated accordingly as well as our summary page.  The detailed party pages are:

Colin Ive, Liberal Democrat – No election leaflet delivered, local party website has no information on the current elections and no candidate contact details.

Mike Morris, The Conservative Party Candidate:

I joined the council because of the 550 houses that were proposed at NE Hook and out of choice became part of the planning team that is processing that site and others around Hook. As you know none of which I welcomed and said so in front of all that attended the Basingstoke Hotel Hook residents meeting.

I do not support urban extensions as they do not bring forward sufficient new infrastructure capacity but just overload current capacity. Nor do some Brownfield sites under permitted development! However I welcome the proposed development at Hartlands (sic) Park (Pyestock) with its 1000 plus housing which will reduce the housing numbers Hart has to deliver. Nevertheless this hasn’t changed my mind regarding the need for a large settlement site at Winchfield which I support as its deemed the only sustainable and developable site in the district to deliver sufficient housing numbers for the current ( impending ) plan and the future.

As you would expect every District Councillor defends his Ward and therefore some of my Conservative colleagues particularly those serving Wards in and adjacent to Winchfield would naturally be against the proposed Winchfield development. I fully understand their position and I would do the same if it applied to Hook or Rotherwick.

I’m unaware of a party line to vote one way or another on any future development and always intended to vote for and on behalf of Hook and Rotherwick residents within best practice in terms of planning policy.

Our response:

  1. Hart Council has said Hartland Park has capacity for 1,500 homes, not 1,000.  And of course it will not reduce the number of houses Hart has to deliver, but will make a significant contribution to meeting the alleged ‘need’.
  2. All of the sites proposed for the Winchfield new town are classified as “not currently developable” in the SHLAA, so it is misleading to suggest otherwise.  No evidence has been presented to demonstrate that a new town at Winchfield is ‘sustainable’.
  3. Hook is adjacent to Winchfield, and indeed around 1,850 of the proposed 5,000 new houses in the Hartley Winchook new town are actually in Hook parish.  One might hope that Hook councillors would acknowledge this fact and look more closely at our brownfield proposal that would result in fewer new houses in Hook than any of the other proposals.  Now that Pyestock is on the table, this is now self-evident.

Verd Nabbs, The Labour Party Candidate

From printed election material:

Local councillors have surprisingly limited powers, but they can be held to account, so they represent YOUR views. In particular over the proposed Winchfield development. A new development will prevent the irresponsible expansion of existing towns and will come with essential infrastructure improvements. We need to act now, before a solution is imposed upon us!

Dai Rees, UK Independence Party (UKIP)

Statement from local branch website:

On housing, a UKIP representative would weigh up the merits of any particular project and would decide accordingly. We all understand the results of over-development – schools, doctor’s surgeries, roads etc. simply cannot cope with the additional strain being placed upon them but nothing ever seems to get done to curb the problem. A UKIP councillor would introduce a measure of realism into the debate and could be relied upon to listen to residents and take account of any grievances they may have. We recognise that new dwellings do have to be built to cope with the increase in our population – caused largely by a laissez-faire attitude to immigration by subsequent governments – but accommodating additional persons must be done sensibly and UKIP councillors would concentrate on brown field sites as a priority.

A UKIP councillor would support improved infrastructure measures and would seek to ensure that there are better schooling and medical facilities, more parking places especially where doing so helps local businesses, and an improved transport network.

[Update] the UKIP candidate has now said he will oppose a new town in Hook. [/Update]

 

 

 

Wates Developments seeks Environmental Assessment of Pale Lane site

SHL 52 SHLAA Site - Pale Lane, near Elvetham Heath and Hartley Wintney, Hart District Hampshire

Wates Developments has submitted an application for an Environmental Impact Assessment Scoping Report on the Pale Lane site (known as SHLAA site SHL 52 and strategic site STR009) that straddles Elvetham Heath and Hartley Wintney parishes.

Wates have made a presentation to Elvetham Heath Parish Council, and plan to make further presentations to interested groups.  A copy of the slides used can be found on the download below.

The site lies to the west of the existing Elvetham Heath development, and is bounded to the north by the M3 motorway and to the south by the main railway line to London.

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

As part of their submission, Wates have given an indicative layout of the final scheme (reproduced above), that will, if eventually approved, contain around 700 new houses, a local community centre, a new primary school and be called Elvetham Chase.

We don’t oppose an Environmental Assessment being carried out, but we would be very disappointed if this development went ahead because:

  1. Hart currently has a 6.7 year land supply, based on the existing inflated Strategic Housing Market Assessment
  2. The Housing Market Assessment is currently being reviewed, and the expectations are our housing allocation will be reduced
  3. Hart District Council is participating in a Government pilot scheme to create a register of brownfield sites,
  4. Hart has initiated a study to identify the brownfield capacity of the district and
  5. Our figures suggest there is capacity for around 4,000 homes on brownfield sites (including Pyestock aka Hartland Park) compared to only 2,500 further houses need to be permitted to meet our current housing target up to 2032.

So, we see no need to concrete over any more of our greenfields for decades to come.

We also note that Adams Hendry’s assessment determined that there were significant transport issues with the site and suggested that Pale Lane might have to be closed to vehicular traffic saying:

Primary vehicular site access would almost certainly be provided onto the A323, with a potential secondary access to the south on Pale Lane. However, the Pale Lane access is severely constrained by being a single track lane with a narrow single-track tunnel under the railway and single track bridge over the River Hart. If it were to provide an effective access point for development at the site, all of this infrastructure would need to be upgraded, not least to ensure effective and safe pedestrian and cycle access between the site and the Hitches Lane Country Park to the south of the railway. However widening the tunnel under the railway and the bridge over the river are likely to be very costly. Therefore, it would be sensible to test closing Pale Lane to all vehicular traffic as an alternative that would ensure safe pedestrian and cycle access could be achieved.

 

Wates presentation to Elvetham Heath PC about Pale Lane

link

 

Response to Face IT article in Fleet News and Mail

 

Vacant Block at Ancells Farm, Fleet, Hampshire

FACE IT have been quoted in this week’s Fleet News & Mail, claiming that the “urban extension option may sound like a ‘brownfield’ solution but would actually mean an extra 2,173 homes being built on green fields in Fleet and Hook”.

It does appear that all of the efforts they have put into their campaign around the Hart Council’s Housing Option Consultation has exhausted them to such an extent that they now misunderstand the difference between types of development because nobody is arguing that urban extensions are somehow brownfield development in disguise.

They make spurious claims about school places, after making up their own estimate of how many extra school places might be required without doing a proper population projection.  Note that Hampshire County Council have not put in place any plans beyond 2018, are forecasting a surplus of secondary school places at that time and a reduction in the birth rate as well as admitting that Hart schools are educating many children from outside the district.

They also make some claims about the scale of development that has occurred in Fleet, Church Crookham and Hook and about how many houses would end up being built around Fleet and Hook under each of the options Hart has put forward. It is not clear where they get their numbers from, because they don’t tally with the figures we put together.

However, nobody would dispute that Hook in particular has seen a big rise in housing in both absolute and relative terms. But what we find difficult to understand is why Hook’s Neighbourhood Planning team and Parish Council are advocating the new town option as their first choice which would deliver more than 1,800 houses in Hook Parish and effectively coalesce Hartley Wintney, Winchfield and Hook into a giant conurbation that might be named Hartley Winchook. This is more houses than the urban extension they oppose (730 houses), more than the dispersal option put forward by Hart Council (204 houses) and more than the brownfield solution put forward by We Heart Hart (only 57 new dwellings to be permitted).

FACE IT rightly say that the combination of Fleet, Church Crookham, Elvetham Heath and Ewshot (greater Fleet) has seen a lot of new housing in absolute terms over recent years. However, this is only part of the story as all parts of the district have seen significant development. When you look at the amount of new housing in proportion to size, the percentage increase for greater Fleet over the planning period of 2011-2031 is forecast to be around 17% for the dispersal and urban extension options and 14% with the new town option. This is below the average for the whole district at 21%, 18% and 18% respectively for each option and well below the percentage increases for places like Hartley Wintney which is forecast to see 34%, 39% and 21% increases for each of the options put forward by Hart.

The brownfield option that We Heart Hart has put forward has the potential to meet all of the remaining housing need and results in a more balanced distribution across the district in proportion to the size of existing settlements.  Our solution would result in a 23% increase for the greater Fleet area, 22% for Hartley Wintney and 27% for the smaller parishes that include Winchfield.

The proposed densities in the brownfield option are not at all demanding, with an average density on the SHLAA sites of around 25 dwellings per hectare.  The proposed densities on the vacant office blocks are no different to some developments that Hart has already permitted on Fleet Road, such as the new McCarthy and Stone development.  Our proposals do not include Pyestock (aka Hartland Park), which could deliver even more houses on brownfield sites into the future if Hart Council is successful in reallocating that site for housing.

We do agree with FACE IT, that we need to take a strategic view of the future, but we disagree on what that strategic vision might be.  In our view, continuing to concrete over green fields equivalent to 25 football pitches each year is not at all sustainable and our children and grandchildren would not thank us for doing that.

The advantages of a brownfield solution are:

  • It preserves the very countryside that makes Hart such a great place to live,
  • Produces a greener solution, making better use of existing infrastructure and more efficient housing,
  • Delivers more of the smaller, more affordable housing of the types that we need to meet the needs of our young people aspiring to gain a foothold on the housing ladder,
  • Delivers more specialist accommodation for the elderly in the right places for them as well as freeing up larger properties for growing families,
  • Delivers infrastructure funding to existing communities where there is currently a £78m funding deficit
  • Lower risk of delivery because it is spread across a large number of sites with multiple developers

Of course, the new town proposal that is in the consultation has been undergoing testing for over a year now, and has identified a number of significant barriers including education, transport and foul water drainage.  The costs of the infrastructure required for a new town are astronomical and would never be met by developer contributions. If Hart were to choose the new town option, it runs the risk of not passing inspection because infrastructure delivery could not be guaranteed.

We hope that the new Strategic Housing Market Assessment, (SHMA) when it is eventually delivered in June will result in a lower housing target for Hart, Rushmoor and Surrey Heath. But until then, the threat of Hart having to build 3,000 for those districts is very real.  Support for a new town will create capacity to build these extra houses which will mean we will end up with the worst of all worlds, a new town, urban extensions and dispersal across the district.

So, we urge all residents of Hart to reject a new town, reject urban extensions and get behind a brownfield solution and give Hart Council further encouragement to step up their efforts in this regard by responding to the consultation and putting support for a brownfield solution in the comments.

We have created a dedicated consultation page and updated our two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes
James Farm Nursery Hartley Wintney, Hart District, Hampshire

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

James Farm Nursery Hartley Wintney, Hart District, Hampshire

James Farm Nursery Hartley Wintney

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

The sites are:

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

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

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

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

Hart District Brownfield Development Target

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Response to Hook Action Against Over Development

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

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

Hook Action Against Over Development have written an article on their website which has been shared on Facebook, criticising both our support of a brownfield solution to our housing needs and the statement from the CPRE saying that the Winchfield New Town proposal was the worst site and the worst option for development.

We re-produce their article below, together with our responses in blue:

There has been a lot of talk about brownfield development and some claims that a new settlement is not necessary because brownfield housing development can provide for all of Hart’s housing needs. Brownfield housing development is the reuse of property or land for residential use where it was previously used for something else, for example office space, industrial land, military use or farm buildings.

Yes, we do believe that all of Hart’s remaining housing need can be met from brownfield sites, and we have set out the case and our plan here and here.  This draws on sites in the SHLAA at only ~26 dwellings per hectare (dph) and the work of the Stonegate Report, plus we have added the civic area that Fleet Future recommended for redevelopment and Fleet Town Council have raised their council tax to fund the costs of preparing a redevelopment plan.

One group in particular from outside of Hook is putting forward the suggestion that the Hart consultation is a simple choice between brownfield and greenfield development. But no matter how much they repeat it does not make it any more true. The CPRE, an organisation with laudable aims, appears to have now fallen for this fiction and hijacking of the term “sustainable development”.

We believe they are referring to We Heart Hart.  We believe the CPRE have not put forward an actual plan, but have clearly stated that they think that a new town at Winchfield is the worst site and worst option for development in Hart.  Sustainable development was defined by the Sustainable Development Commission as:

“Sustainable development is development that meets the needs of the present, without compromising the ability of future generations to meet their own needs.”

The concept of sustainable development can be interpreted in many different ways, but at its core is an approach to development that looks to balance different, and often competing, needs against an awareness of the environmental, social and economic limitations we face as a society.

We believe that sustainable development does not include concreting over the equivalent of 25 football pitches per year of green fields and leaving untouched, vacant, decaying office blocks. A new settlement would compromise future generations by needlessly concreting over hundreds of hectares of green fields, depriving future generations of the health benefits of the countryside. The economics of the proposals don’t stack up, requiring ~£350m of infrastructure spending, money that neither Hart nor Hampshire County Council have, especially now that HCC is facing an £81m per annum funding deficit. 

Hart’s housing strategy is brownfield first, but Hart cannot propose development on sites that are in commercial use or that have not been put forward for housing. If they were to do so then the Local Plan would fail inspection again at the first hurdle and this would be a disaster. Even hypothetically utilising these unavailable brownfield sites would demand construction at inner city density in order to meet Hart’s objectively assessed housing need. We cannot believe that CPRE are promoting building at such a density in Hart. That would not be sustainable.

We agree that sites need to be developable and eventually deliverable and nobody wants to see the Local Plan fail. Back in September, Hart Council said that they thought the brownfield capacity was 1,800 units.  Miraculously, this has fallen by 75% to only 450 units in the consultation. However, as described above, most of the sites we have put forward are in the SHLAA and in no worse state of deliverability than those put forward for consultation. The other sites are in the Stonegate report and we understand Stonegate are working hard to secure these sites.  The average density for the SHLAA sites is less than Hart’s planning rule of thumb at 26dph, and the Stonegate sites are at no higher density than developments that Hart has granted permission for such as the McCarthy & Stone’s recent development on Fleet Road which many people think is an attractive building.

Hart are actually consulting on which of Hart’s green fields should be selected for housing in the event that there is insufficient brownfield land to meet the housing need. Given the vast expansion of the existing towns and villages in Hart already, with Hook alone having a 25% expansion approved for this Local Plan period, the only suitable and truly sustainable option is a new settlement to allow for a planned increase in infrastructure. Just expanding existing towns and villages either piecemeal or with “urban extensions” is still building on green fields, but in a way that will not provide the opportunity to build extra schools, roads and health facilities that the thousands of new Hart residents will require. That would not be sustainable.

The proposed new town will in fact deliver over 1,800 houses in Hook Parish, which is more than the proposed urban extension and more than the undeveloped brownfield sites.  To be clear, we do not support urban extensions either because we believe all of the remaining need can be met on brownfield sites. The infrastructure costs for a new town do not stack up and a new town will do nothing to close the large £12.2m existing infrastructure funding gap in Hook, and £20.7m gap in Fleet and Church Crookham. No evidence has been presented that we need a new secondary school and the funding for a new town will not address existing road bottlenecks, nor will there be sufficient funding to address the roads requirements of a new town. We repeat, we do not believe concreting over 25 football pitches each year is at all sustainable.

Elimination of all potential commercial property space in Hart is in fact extremely short-sighted. Even the Enterprise M3 Local Enterprise Partnership which is urging more housing would not want to see commercial space becoming rare and expensive. There is already an acknowledged shortage within Hart of small business units and light industrial space. Larger available office space provides options for small local businesses to grow without leaving the area. A thriving local economy needs a balance of housing and business to provide employment opportunities locally and avoid all of these new residents having to take to the roads and railways to commute out of the area for work on already busy transport links. That would not be sustainable.

Nobody is saying that all of the vacant commercial space be handed over to housing.  But even the Employment Land Review, based as it is on the inflated Strategic Housing Market Assessment (SHMA) and the inflated jobs forecasts, suggests that there will be around 600,000 sq m of vacant employment space across the Housing Market Area at the end of the plan period and Rushmoor was planning to “protect” 96 Ha of vacant brownfield sites that simply are not needed. If there was such a shortage of offices or of light industrial space, places like the Murrell Green Estate would not have the big vacancies they currently have. Of course it would be more sustainable to free up some of these spaces and redevelop them for residential use rather than leave them to rot and decay.

There is very little brownfield land in Hart but there is an amusing “brownfield site slideshow”, made available by campaigners whose aim is to push development away from their village, to supposedly “demonstrate” how much brownfield land is available for housing. If you happen to see it, do bear in mind that:

  • Several of the sites are already being developed for housing (and therefore counted in existing housing build numbers!) such as Landata House and Greenwell in Hook, Sun Park and others.
  • Several of the sites are being converted to other commercial uses, e.g. Warehousing at Pyestock and retail development on Fleet Road where M&S are looking to move to an expanded new store.
  • Several of the sites are in fact just one vacant floor(or even a partial floor) in an otherwise occupied office building!

Now perhaps the future really is an office building with some adjacent floorspace being residential, but can anyone imagine this being attractive to either residential or commercial tenants?!

The fact that some of the sites have already been taken up for redevelopment simply proves our case and shows it can be done.  Our brownfield solution has taken account of the sites that are already underway. Work at Hartland Park (aka Pyestock) stopped years ago, and there is no sign of it re-starting.  The owners will not wish to keep an expensive site forever generating no returns. Of course if M&S moves into another Fleet Road site, then they will leave behind a different vacant block to go with the many other vacant units in the Hart Centre.

There are plenty of examples of mixed residential and commercial use, both in this country and on the continent.  Nobody is suggesting this should happen without comprehensive redevelopment.

This current consultation is clearly not about a choice between brownfield and greenfield development, it is about the best way to provide Hart’s required housing with essential supporting infrastructure and only a new settlement can achieve that. For more, please refer to our previous article hookdevaction.org.uk/hart-housing-consultation-restarted-your-action-needed.

The Hartley Winchook new town is not required, it not viable because of the flood risks and the massive, unfunded infrastructure costs, and will not be sustainable in any sense of the word. There is a brownfield alternative, and we should seize that opportunity.

 

 

Here are the slideshows of vacant brownfield sites we have found in Hart and Rushmoor:

 

  • We Heart Hart's Mascot - Bravehart
    We Heart Hart's Mascot - Bravehart

 

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

Hart Council makes more errors in new local plan consultation

Hart District Council (HDC) keep getting it wrong

Hart Council keep getting it wrong

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

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

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

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

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

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

The detail of the errors are shown below:

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

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

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

Summary Booklet Approach 1

Summary Booklet Approach 1

Main Document Approach 1

Main Document Approach 1

 

 

Hart District Council (HDC) new Local plan consultation Q4

New Local plan consultation Q4

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

New Local plan consultation p48 table

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

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

New Local Plan consultation errors and discrepancies.

The main errors are with the following parishes:

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

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

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

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

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

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

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

 

Hart Council: Keep Calm and Hide the Facts

Hart District Council (HDC) Keep Calm and Hide the Facts 2

Hart Council Keep Calm and Hide the Facts

Readers will recall that at the Hart Council Meeting last week, senior councillors refused to answer some questions and gave vague and unsatisfactory answers to those questions.  The council has now published the full exchange on their website.  We give our view on what they really meant below.  We ask readers to bear in mind Hart’s Code of Corporate Governance which has as its four key principles:

  • Openness: openness is required to ensure stakeholders can have confidence in the decision making and management processes of the Council.
  • Inclusiveness: an inclusive approach ensures that all stakeholders and have the opportunity to engage effectively in the decision-making processes and actions of the Council.
  • Integrity: is based upon honesty, selflessness and objectivity, and high standards of propriety and probity in the stewardship of public funds and management of the Council’s affairs.
  • Accountability: accountability is the process whereby the Council, members and staff are responsible for their decisions and actions regarding all aspects of the Council’s work

Here is the full set of questions and answers, abridged and with our interpretation below in blue:

Question 1: Given that a) in October 2013, you were quoted as saying we would submit a new version of the Local Plan to the Inspector in Autumn 2014 and b) in each subsequent year this has slipped by a further year, with the current LDS indicating a local plan ready for submission in Winter 2016, will you now publish the detailed project plan to support this target, so we can be assured that project management processes have improved?

Answer: It was our intention to proceed with a revised Core Strategy after the withdrawal of the 2013 version. However, as many will well know, the Government changed the nature of Local Plans and we also had to address the issue of a new SHMA to overcome the defects blah….blah….blah…

Blah…blah..blah…The Local Development Scheme is the council’s three-year project plan that identifies which local development documents will be produced, in what order, and when. We do not propose to publish more background information on internal workings because that offers no practical advantage to anyone. There is already proper scrutiny of the Local Plan progress with all members of the Council having the opportunity to be actively engaged.

We also last summer enlisted the support of Chris Dorn to lend project management support. His work has been invaluable and he gave positive and independent feedback to the Hart District Association of Parish and Town Councils.

Finally, we have now full project management arrangements from our neighbours at East Hampshire District Council, who have recent and relevant experience of bringing a local plan through Examination to adoption.

What they really meant: Here’s some blather and vague implausible excuses why we haven’t been able to publish a Local Plan when 82% of Local Councils have managed to do it. There’s no way that we are going to publish the project plan, because we don’t want to be held accountable for any future slippage.

Question 2: Given that in January 2015, HDC commissioned work to test the proposed new settlement and urban extensions with the objectives to test the “deliverability of a new settlement and/or urban extension (ie [sic] suitability, availability and achievability)”, including a land use budget; provide “indicative costing of the major infrastructure items needed”; and consider viability including the “infrastructure requirements of sites to identify likely infrastructure impacts, subsequent costs and potential funding sources”, can you explain if these objectives have been met, and say when the results will be published?

Answer: The current position on testing is set out in the Refined Housing Options Paper. It specifically highlights and comments on where we have got to with the issue of testing. As paragraph 12 we say:

“The testing we decided to undertake is still ongoing as is the testing of all other options. The testing will go on in some form or other right up until we finalise the submission Local Plan. There is still much work to be done, but we have reached a point where we can now ask you if we are on the right track”.

We then go on to summarise on pages 9 and 10 what outcomes have been received from the testing that we have carried out so far.

The outcome of the testing will therefore, inform both the draft Local Plan and will inform the submitted Local Plan in that it will comprise part of the evidence base. All these documents will be published at the appropriate time and everyone will have the right to comment upon them when the Local Plan is independently examined by an Inspector appropriated by the Secretary of State.

What they really meant: No, we haven’t met the objectives.  If we actually finished the testing, it would likely show that a new town in Winchfield is not viable and we wouldn’t want to be transparent about that would we?

Supplementary Question: All of the sites identified to make up the new town and urban extensions are listed in the SHLAA as “Not currently developable”, we have no costing of roads, bridges, railway improvements, sewage, sports or community facilities and we have no land use budget that includes SANG, so why are you consulting on a new town that is not deliverable, as well as excluding brownfield sites for the same reason?

Answer: This is part of the consultation. Brownfield sites are only deliverable if the landowner puts them forward for development. Brownfield sites may not be deliverable for other reasons, but once they are put forward as a SHLAA site they can be considered. [Note:  Although not recorded in the minutes Cllr Parker did go on to say words to the effect that many of the green field sites put forward were not currently developable because to do develop them would be contrary to current policies and they would look to change their policies as part of the Local Plan]

What they really meant: How dare you ask me for facts? Of course, we will change our policies to get a new town at all costs, just like we changed the questions in the consultation.

Question 3: Given that an FOI request to elicit the evidence to support the assertion made at cabinet (Paper E 5.2) in September 2015, and in Hart news (p2), that brownfield capacity for the district was 1,800 units has failed, are we to conclude that the council and public were misled in September, or will you now produce the evidence and ensure that any new consultation includes a proper stand-alone option for brownfield sites?

Answer: Nobody was misled by this council. The FOI request did not fail.

The Freedom of Information requests were dealt with blah…blah.blah…

Blah..blah..One key point that seems to be missed in the question is that there can be no standalone option for “brownfield sites” because the evidence suggests that there is not enough deliverable ‘brownfield land’ available to meet all our need for new homes because too few suitable sites are being promoted as being available by developers or landowners. Blah…blah…

[Note: Here is the answer given to the FOI request: “With regards to the first request, we do not hold that information.” and also note that none of the other options put forward were able to meet the remaining needs on their own either.]

What they really meant: Of course, it was a mistake to publish the real brownfield capacity, but we’re not going to publish how we arrived at the figure. We are doing our best to erase that from history and push on for a new town. 

Question 4: You will recall that I wrote to you on 20 November 2015, highlighting discrepancies between the consultation materials and SHLAA, the most important point being point 4 (and appendix) showing the very different site capacities in the New Homes Booklet compared to the official evidence base, the SHLAA; can you now give an explanation of those discrepancies and will they be corrected before any new consultation is carried out?

Answer: I understand from the Council’s Planning Policy Manager that you have already received
an explanation about the differences between the SHLAA and the New Homes Sites Booklet regarding site capacities (email from the Planning Policy Manager sent on 23rd December 2015).

That response explained that:

“In preparing the consultation papers we drew on not only the SHLAA but also more recent information where it was available. Such information includes the high level site assessments prepared by Adams Hendry and the shortlisting exercise work (available at http://www.hart.gov.uk/Evidence-base ), pre-application plans, recent planning permissions, and any recent changes to site boundaries. These can all influence the sites that are shown in the documents. The SHLAA itself will be updated next year.”

The plan is to publish an updated SHLAA in the summer of 2016 to reflect the best information available at that time including data on annual completions which becomes available around June each year. [Note:  I did point out that I had written back to them on 12 January making clear that Point 4, amongst others, had not been answered].

What they really meant: We deliberately make it all very confusing, and who cares if the material we send out to the electorate doesn’t match the official evidence we spent loads of your money to produce and published at the same time as the consultation.

Question 5: Given that the SHMA (section 9.33) calls for 60-70% of our 7,534 housing need (or around 4,900) to be met from 1 & 2-bed properties, can you give a breakdown by number of bedrooms, of the 4,500 or so dwellings built or permitted since 2011 and tell us how many more 1 & 2 bed homes need to be built out of the remaining ~3,000 to be permitted to meet the need expressed in the SHMA? [Note: is has subsequently emerged that the preamble to this question did contain a mistake, and the need for 1 & 2-bed properties is ~3,800 units, but that doesn’t take away the need for Hart Council to measure how well it is meeting the need, nor does it stop the question being answered].

Answer by Chairman: This is a technical research question and does not form part of any current Council workstream. This is not the proper forum to be used to elicit the use of Council resources in pursuit of your own personal research. I say this because the information that you seek is already published.

You can obtain the information by accessing all the planning application details of applications submitted and determined which is published on the online Public Access system.

I would also point out that section 9.33 of the SHMA relates to affordable housing and not general housing mix. It may be you have missed out a few words which fundamentally alters the meaning of your question. [Note: I asked by email immediately after the meeting where this information can be found and have received no response].

What they really meant: You just don’t get it do you?  This isn’t about facts or meeting the needs of Hart residents it’s about getting a new town. Of course we’re not going to tell you how well or badly we are meeting the needs of local residents nor information that might suggest that a new town is not the right answer.  Where would we be if we were transparent?

Question 6: Given that the SHMA (Figure 10.15) calls for around 2,500 specialist units for the elderly, split into various categories to be built in Hart under the Local Plan, can you tell us how many of these units have been built or permitted since 2011, how many remain to be permitted and what you consider to be the best types of location for these types of accommodation?

Answer: The part of the question seeking statistics is appropriate to an FOI request and thus specifically outside the scope of a question at council. I have therefore asked that this request is handled under FOI rules. You will thus receive a formal response under that protocol. Blah…blah…

Blah…blah…This approach is exactly in accordance with government policy as set out in Paragraph: 003 Reference ID: 12-003-20140306 of the updated September 2015 National Planning Policy Guidance.

What they really meant: Meeting the needs of the elderly is not our priority and you must be joking if you think we are going to publish any information that shows we’re not meeting their needs.  We want loads more detached houses in the countryside from a new town and urban extensions.

Supplementary: How can the young who need the affordable 1 & 2-bed dwellings and elderly have confidence in the Local Plan process when the leader doesn’t know what we need to build to meet their needs?

Answer: This will be dealt with under the FOI request.

What they really meant: How many more times do we have to explain, we don’t do facts? This isn’t about meeting the needs of local people.  It’s all about getting a new town at all costs.

Question 7: What are the risks that a second consultation “anticipated to be run again from late January”, will be a further waste of Hart residents’ money, when the revised SHMA is due “early in 2016” and a revised employment land review is also being prepared, thus meaning that the evidence base is likely to change significantly during the consultation, leading to a further consultation being required?

Answer: It would be premature to speculate on the outcome of the refresh of the SHMA. Data sets change all the time and all we are looking at is one single snap shot of a combination of changing data sets…blah…blah…

What they really meant: I don’t care about risks and I don’t care about your money, I want a new town. The new SHMA will likely show a big reduction in the housing need so we won’t need to build 3,000 houses for Surrey Heath and Rushmoor and we’ll be able to meet all Hart’s remaining needs from brownfield sites. If that were put to residents they wouldn’t vote for a new town or urban extensions and where would that leave us?

Question 8: Who instigated, who authorised and who will take responsibility for each decision to repeatedly change the materials in the recent consultation part way through?

Answer by Chairman: I am directing that this question is not to be answered. This is because, as Mr Turver knows, it forms the basis of a separate investigation by Overview and Scrutiny and indeed, Mr Turver has been party to representations made pursuant to that investigation. It would therefore be wholly inappropriate to enter into discussions in public without all the facts surrounding the events that resulted in the early curtailment of the Refined Housing Options consultation having first been investigated by Overview and Scrutiny Committee. [Note: Cllr Bailey did make the point that the O&S work is a review, not an investigation and he did not intend that review to act as block on members of the public asking questions].

What they really meant: How dare you ask us to be open, transparent and accountable for our actions? 

Supplementary: We’ve heard tonight that you have failed with the last consultation, haven’t got a grip on the timeline, project management or the quality and content of the outputs, isn’t it time that you and the rest of the Local Plan Steering Group did the decent thing and resigned?

Answer: I do intend to do the decent thing and deliver the local plan.

What they really meant: We can’t have someone in charge who might actually look at the evidence and try and meet the real needs of Hart residents can we?  

 

Questions to Hart Council 28 January 2016

Hart District Council Offices, We Heart Hart. We Love Hart

Hart District Council Offices in Fleet, Hampshire.

After the Local Plan consultation debacle, we have put a series of questions to Hart Council that will be answered at their meeting on 28 January 2016.  Please do come along if you can.

The full questions can be found on the download below, and cover whether Hart Council has a project plan we can believe in; the progress (or otherwise) made in testing the Winchfield new town proposals; what happened to the 1,800 dwellings that Hart said in September could be built on brownfield sites; discrepancies between the consultation documents and the official SHLAA; how well we are meeting the needs of the young and elderly; the risks of re-running the consultation now, given the housing target (SHMA) is about to change and of course, seeking clarity on who instigated and authorised the fateful changes to the consultation materials part way through.

Questions for Council 28 Jan 16

link

Rushmoor responds to criticism by revising evidence base and delaying its Local Plan

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire

While all of our eyes have been on the Hart Consultation about the Local Plan, Rushmoor has also been busy on its own Local Plan.  The most important point is that Rushmoor is revising the SHMA and the Employment Land Review which will:

be beneficial in assisting with a response to a number of comments received through the consultation, which challenged elements of the evidence base, and in particular, raised objection to the fact that the potential shortfall in housing supply in Rushmoor should be accommodated in Hart.

We might add that it was largely We Heart Hart supporters who made these comments – so thank you very much for your contributions.  It does show that reasoned analysis of the evidence base can lead to real change, at least in Rushmoor.

In addition, as well as making reference to the Government’s lower population and household forecasts, Rushmoor say that “all of the three major forecasting houses that produce employment forecasts at local authority level have updated forecasts since those used in the SHMA and the ELR”.  We Heart Hart have strongly challenged the previous jobs forecasts, so we can only hope that these forecasting houses have come up with something more reasonable.

Rushmoor is also revising its land bank database (SHLAA), and this should be available in early 2016.

Interestingly, Rushmoor has also delayed its Local Plan by up to a year in total to cater for these revisions to the evidence base.  Rushmoor’s next consultation, built upon the new evidence base will be in October 2016.

We find it difficult to see how Hart is going to manage to produce a full draft Local Plan by the Summer of this year, when the updated evidence base is not going to be available until the Spring, and it is going to take Rushmoor at least 6 months to process that information and produce the next draft of its Plan.

Rushmoor has also provided a response to Hart’s Housing Options consultation that we will cover in another post.