Hart Council starts to identify brownfield opportunities

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

Hart Council starts the process of identifying brownfield opportunities

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

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

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

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

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

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

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

Is the ‘tin-man’ new town plan viable?

Tin Man new town has no heart

Tin Man new town has no heart

The new town, which might be termed Hartley Winchook is Hart District Council’s preferred option to meet our housing needs, but it is not clear whether the proposals are at all viable.

First, if you look at the sites put forward to make up the new town (see below), it is clear they are a mish-mash of disconnected sites bisected by the M3 and the railway, with no clear heart from which to build a successful community. This is recognised by HDC’s planning consultants who have said “It would be challenging to plan a compact nuclear settlement on this site”. In short, this is a ‘tin-man’ proposal for a new town, that Hart Council themselves ruled out back in 2012 and we urge you to oppose it in the consultation.

 

Winchfield and Hook New Town proposal

Winchfield and Hook New Town proposal

Second, there are a large number of significant constraints, many of which will be very difficult to overcome. We have set these out below, pulling the quotes from the official HDC evidence base.

Finally, both Hart and the Government have said that new towns need to be at least 5,000 dwellings. We have taken a look at the housing capacity below, and conclude that it is going to be a struggle to achieve this goal because HDC has not yet taken proper account of the need for SANG, schools, sports facilities, roads, car parks and shops.

We do wonder quite what has been going on inside Hart Planning Department, when last year the new town proposal was the preferred option ‘subject to testing’.  Where are the results of the testing?

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

 

Constraints to housing

The first point to note is that each and every site put forward to be part of the new town is listed as “not currently developable” in all of the SHLAA documentation.  There are many constraints noted for the sites, including:

  • The road infrastructure  has limited capacity for additional traffic.
  • There are a number of significant nature conservation features and designations either adjacent or in close proximity to the site.
  • Some part of the site are subject to area based TPOs, particularly to the north of the site, near to Winchfield House.
  • The Hampshire Minerals and Waste Plan Policies Map indicates that parts of the site contain areas subject to minerals safeguarding
  • Characterised as attractive rolling countryside… The potential for new development within this area to negatively impact on landscape character is considered to be significant.”
  • Potential to cause considerable harm to landscape character.
  • It is possible that the site contains some ʻbest and most versatileʼ (BMV) agricultural land
  • There are a variety of Listed Buildings within and adjacent to the site
  • Significant parts of the site are subject to the risk of groundwater flooding at the surface”.
  • The nature of the site, split, with substantial areas of farmland, as well as Winchfield Station between the two halves is considered to significantly influence how a new settlement could be planned.
  • Development at the north of the site risks leading to settlement coalescence with Hartley Wintney”.
  • Overhead power lines traverse the site and may represent a constraint”.
  • The extent to which environmental noise from the motorway and railway impacts on the site should be ascertained.

Housing Capacity

The capacity put forward for each site by Hart Council for the sites in Winchfield, Hook and Hartley Wintney Parishes is shown below.

Parish/Ref Site Assessment Capacity (Low) Site Assessment Capacity (High)
Hook 1,458 1,458
SHL126 450 450
SHL136 663 663
SHL169 345 345
Winchfield 5,039 6,039
SHL124 500 1,500
SHL133 396 396
SHL135 55 55
SHL167 772 772
SHL168 46 46
SHL182 600 600
SHL183 150 150
SHL184 850 850
SHL185 450 450
SHL186 350 350
SHL187 600 600
SHL188 200 200
SHL83 10 10
SHL84 60 60
Grand Total 6,497 7,497

HDC and the Government have said that the minimum size for a new eco-town is 5,000 dwellings. However, many of these sites have not yet been fully assessed by officers to verify the housing capacity claimed by developers.  Of particular note is that only ~50Ha of land has been assigned to SANG (part of SHL183).  A development of 5,000 houses would require 100Ha of land (minimum of 8Ha per 1,000 people), so a further 50Ha at least is required.  At Hart’s usual planning rule of thumb of 30 dwellings per hectare, this would reduce the available capacity by 1,500 units.

A new settlement would also require space for sports facilities.  Hartley Wintney has three football pitches and a cricket pitch, and it is less than half the size of the proposed new town. So, let’s assume a new town would need 6 football pitches and 2 cricket pitches.  Hartley Wintney FC (with three pitches covers some 3Ha and the cricket pitch some 1.5 Ha) – together say 9 Ha.

HDC say the new town would also need 4 new schools, one secondary and three primary.  Robert Mays’ site is around 5 Ha (measured on Google Maps) and the site of Greenfields School at Hartley Wintney is around 2.5Ha, so the four schools would need around 12Ha between them.

Then of course, there would need to be a new supermarket and other shops, medical facilities and other employment space. Tesco in Hook takes up about 1 Ha, but the new town is to be around twice the size of Hook, so a bigger store would be needed. So let’s say a conservative 10Ha in total for supermarkets, shops, surgeries and car parks.

Then of course, we need space for new roads, a sewage works and the new railway station.  Fleet station is around 2 Ha, and the old sewage works at Branshott Farm was around 2 Ha.  New roads and a motorway junction will further reduce capacity.

That brings the total up to around 35 Ha.  That takes off space for a further 1,050 dwellings.

As can be seen, when you take into account the need for SANG, schools, shops, sports facilities, new station and sewage works, the available capacity drops by around 2,550 units, taking the low end estimate of housing capacity to ~4,000, well below the minimum 5,000 and the high end just below the boundary of viability.

A number of the sites are unlikely to ever be suitable for housing, and other sites have very real issues with the potential for groundwater flooding which would further reduce capacity. For example, site SHL167 has just been refused permission for even a solar farm, and SHL133 is borders two SSSI’s and a significant part of it is subject to flooding. And sites such as SHL182, 184, 186, 187 and 188 do not yet appear to have had their capacities factored down by officers to take account of the constraints.

And of course, Dr Anne Crampton has called for a 500m exclusion zone around the motorway, which would render the whole scheme unviable.

 

Bravehart answers question posed to We Heart Hart

Bravehart - We Heart Hart Mascot

We Heart Hart’s mascot, Bravehart

As has become the style of Parliamentary questions, I have been posed a question by Steve of Fleet West.  It’s a long and complicated question, but I will do my best to answer it.

The question put to me was:

Question for you. Because Hart already has more SHLAA sites than needed, the duty to cooperate under the localism act required us to use them to deliver neighbouring districts excess needs regardless of whether a new settlement is selected as an option. Some of the SHLAA sites used would inevitably be those in And around Winchfield, but without the master planning and infrastructure provision possible with a planned settlement. And many would be urban extensions causing a burden on existing towns causing further local issues. Do you not think this is the case, and if so why?

First, my understanding is that the “duty to cooperate” is not a “duty to agree” (as we were told by Peter Village QC) and Hart should be robust on two fronts:

  • They should challenge the alleged “need” in the SHMA.  We’ve already established it is based on out of date population forecasts and calls for an “aspirational” level of employment growth that is simply unrealistic.  If these arguments are taken on board, the whole issue of having t meet the needs of neighbouring districts falls away.
  • Hart DC should be robustly challenging Rushmoor in particular who could build more by increasing the density at Wellesley and by releasing some or all of the 96 Ha of employment land they are protecting that it not needed to meet even the inflated employment forecasts.  Rushmoor could even meet some of Surrey Heath’s unmet need.

Second, with or without a new settlement, I simply do not believe the infrastructure numbers add up, and I believe we are being sold a pig in a poke.  £300m costs, versus £50m of developer contribution against an existing £78m infrastructure funding black hole.

Third, it is extremely unlikely that individual Winchfield sites will be picked off (outside those recommended in the Winchfield Neighbourhood Plan) because they simply do not meet the criteria as suitable places for development.  Let’s run through some of the constraints identified in the official evidence base:

SHL 83: The area of the site which is a SINC should not be developed and should be protected from any development, as should those other SINCs nearby. A contribution towards SPA mitigation would be required. Policy would need to be changed for this development to be permitted by way of allocating a settlement boundary to Winchfield which includes this site (however this seems unlikely given that the site is on the other side of the M3 from the rest of Winchfield. The constraint relating to the location, remote from settlements with a boundary seems unlikely to be overcome therefore the site may not be considered suitable or achievable in future.

SHL 133: The fact that the site does not relate to any existing settlement boundary cannot be overcome. Policy would need to be changed for development to be permitted at this location by way of a broader strategic allocation.

SHL182: Site is not related to any settlement; Southern boundary edge within flood zones 2 and 3. Mostly high, but partly medium potential likelihood of groundwater flooding.

SHL183: Site is not related to any settlement; North eastern corner in flood zone 2 and 3; High potential likelihood of groundwater flooding.

SHL184: Site is not related to any settlement; Mostly medium, but some high potential likelihood of surface water flooding.

And then of course we have the Adams Hendry assessment of the combined strategic site:

  • “The road infrastructure in the Winchfield area reflects the areas rural character and has limited capacity for additional traffic. Therefore a key infrastructure issue for developing any significant level of housing at Winchfield is how the road infrastructure can be upgraded to meet the projected levels of demand and how traffic to/from the new development would access the M3 Motorway.”
  • “There are a number of significant nature conservation features and designations either adjacent or in close proximity to the site.
  • “Some part of the site are subject to area based TPOs, particularly to the north of the site, near to Winchfield House”.
  • “The Hampshire Minerals and Waste Plan Policies Map indicates that parts of the site contain areas subject to minerals safeguarding for sharp sand and gravel… The extent to which this might constrain development will need to be assessed, including through engagement with Hampshire County Council.”
  • “The two halves of the site differ in landscape terms with the western half being characterised by the mosaic pattern of generally medium-sized fields interspersed by numerous wooded copses and heavily wooded field boundaries… Most of this part of the site could reasonable be characterised as attractive rolling countryside… The potential for new development within this area to negatively impact on landscape character is considered to be significant.”
  • “The eastern half of the site is much more open, except for the southern portion near to the Basingstoke Canal… The countryside in this area is less attractive than the western part of the site, although its lack of current development and open nature means that significant development in this area has the potential to cause considerable harm to landscape character.
  • “It is possible that the site contains some ʻbest and most versatileʼ (BMV) agricultural land, but this would need to be confirmed through a survey.”
  • “There are a variety of Listed Buildings within and adjacent to the site… The most significant heritage features impacting on the site are as follows:-
    • The Basingstoke Canal Conservation Area… there is considered to be a risk that development towards the south of the site will negatively impact on the setting of the Canal;
    • Dogmersfield Park (Historic Park and Garden)
    • Winchfield House (Grade II*) and its extensive grounds
    • St Mary’s Winchfield if a Listed Norman Church (Grade I)… it is considered that development close to the southeast boundary could have a negative impact on the currently very rural and sparsely developed setting of the church.”
  • “Significant parts of the site are subject to the risk of groundwater flooding at the surface”.
  • “The nature of the site, split, with substantial areas of farmland, as well as Winchfield Station between the two halves is considered to significantly influence how a new settlement could be planned. It would be challenging to plan a compact nuclear settlement on this site and the shape of the site lends itself more to a linear or ʻlinked polycentricʼ approach.”
  • “Development at the north of the site risks leading to settlement coalescence with Hartley Wintney”.
  • Overhead power lines traverse the site and may represent a constraint”.
  • “The extent to which environmental noise from the motorway and railway impacts on the site should be ascertained”.

So, it seems that Winchfield is a bad location for a new settlement, and an even worse location for individual developments.  I would hope we can avoid urban extensions on green fields too, and would like to see significant regeneration of existing towns and investment in infrastructure in those places.

 

New town plan transforms Winchfield into a concrete jungle

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

The combination of the sites put forward for the Winchfield new town will put more than half of the beautiful countryside at the Heart of Hart under concrete with devastating impacts on the ecology and environment.  But readers should also note that around a quarter of the planned houses will be in Hook parish, with some of it in Hartley Wintney next to the Dilly Lane development, many houses on the boundary with Odiham Parish and of course the eastern boundary of the site will directly abut Fleet and be very close to the Edenbrook estate.

The notion that this is in any way “sustainable development” is total nonsense and the notion that there will be limited impact on other areas of the district is also nonsense.

If you want to protect our countryside you must vote for Approach 1, a dispersal strategy in the Local Plan consultation and ask Hart Council to find again the 1,400 sites they lost.  Our remaining needs can be met from brownfield sites alone.

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

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

Winchfield and Hook New Town proposal

Hartley Winchook New Town proposal for Hart District in Hampshire

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

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

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

Hartley Wintney SHLAA sites in Hart District

Hartley Wintney SHLAA sites in Hart District, Hampshire

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

Now, let’s take a look at Hook:

Hook SHLAA sites in Hart District

Hook SHLAA sites in Hart District, Hampshire

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

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

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

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

Hook facing 1,850 new houses from “Winchfield” new town proposal

Winchfield and Hook New Town proposal

Winchfield and Hook New Town proposal from Hart District Council in Hampshire

Hart District Council’s proposals for a new town in “Winchfield” will in fact lead to another 1,458 houses being built in Hook Parish.  This is more than the 730 new homes proposed in the “Urban Extension” approach put forwards in the Local Plan consultation documents.

This apparent paradox arises because three of the proposed sites in the consultation document are sites SHL126, 136 and 169 which are actually in Hook Parish according to the SHLAA documents.  The combined total capacity of these sites recorded in the SHLAA is 1,458 units.

[update]

I should also note that more than half of SHL167 – Beggars Corner – is also in Hook Parish, with a total capacity of 772 units according to the SHLAA.  This would put a further ~400 or so houses in Hook Parish, bringing the total to around 1,850.

[/update]

The consultation also makes clear that according to Hart DC, (we disagree), that more than one approach will be needed to meet our housing needs.  Hook could end up with both urban extensions and a new town partly in their own parish with devastating consequences.  In fact from the map, we will end up with a single large conurbation that might end up being called Hartley Winchook.

We urge Hook residents to think carefully about how they cast their votes in the consultation. If they end up voting for a new town as their first preference as suggested by some Hook pressure groups, they may well end up with far more than they bargained for.

In our view, Hook residents would be better voting for a brownfield and dispersal strategy (Approach 1) and adding to pressure to reduce Hart’s housing allocation by challenging the SHMA that is based on out of date Government population projections.

Our guidance for responding to the consultation is available on the download below:

 

Responses to Local Plan Consultation

There is a brownfield solution to Hart’s housing needs

Vacant brownfield Block at Ancells Farm, Fleet, Hart District, Hampshire

Vacant Office at Ancells Farm, Fleet, Hampshire

We have done some further analysis on Hart’s Strategic Housing Land Availability Assessment (SHLAA) and come to the conclusion that Hart’s housing needs can be met from brownfield sites alone.  We believe this is a potentially viable solution that should form part of the forthcoming Housing Options consultation as part of the Local Plan.  Instead Hart Council have ignored the wishes of 2,130 people who signed the WeHeartHart petition and only put forward solutions that involve concreting over vast swathes of our countryside.

Created using the Donation Thermometer plugin https://wordpress.org/plugins/donation-thermometer/.2,350Hart District Brownfield Development Target3,993Hart District Brownfield Development Target170%

[Updated 2 March 2016 to add in the new brownfield SHLAA sites as described here]

[Updated 31 March 2016 to include Pyestock (aka Hartland Park)]

[Updated 30 August 2016 to re-set target to 2,350 now that Moulsham Lane, Yateley has been given the go ahead]

So, how have we arrived at our conclusion?

Brownfield sites in the SHLAA

We have been through the SHLAA and identified those sites that are mostly or wholly brownfield in nature, and added up total capacity as recorded in the SHLAA.  Pyestock (aka Hartland Park), is now also an official SHLAA site.  In total, these sites amount to between 3,208 and 3,250 homes at an average density of a relatively modest 28 dwellings per hectare (dph). The detail is shown in the table below:

ParishRef.NameBrownfield Capacity in Table 1 in DLPSite Assessment Capacity (Low)Site Assessment Capacity (High)Size (Ha.)Low Density (dpa)
Blackwater and HawleySHL21Linkwater Cottages, Blackwater12120.6418.75
Blackwater and HawleySHL100Sun Park, Guillemont Park North3003203201226.66
BramshillSHL106Bramshill (Police Training Centre)2502501025
Church CrookhamSHL2826/32 Bowenhurst Road8660.4214.28
Crookham VillageSHL158Crondall House, Fleet27271.1323.89
DogmersfieldSHL39Fermoy, Farnham Road5102.232.24
DogmersfieldSHL55Land at Church Lane, Dogmersfield20200.8224.39
Elvetham HeathSHL104Land at Elvetham Heath4545452.2520
EversleySHL127Land at Paul’s Field, Eversley70702.825
EversleySHL140Land off Warbrook Lane53531.7630.11
EwshotSHL36Dachs Lodge, Redfields, Church Crookham29291.224.16
EwshotSHL80Tanglewood, Ewshot770.3122.58
EwshotSHL174Peacocks Nursery Garden Centre1051053.530
EwshotSHL235Land at Willow Croft, Church Crookham50502.7518.18
FleetSHL41Imac Systems, Fleet6660.05120
FleetSHL42Camden Walk, Fleet9880.2433.33
FleetSHL50Waterfront Business Park, Fleet60601.4641.09
FleetSHL6918 Church Road, Fleet10100.07142.85
FleetSHL102Land at Bramshot Lane45451.825
FleetSHL113Thurlston House1712120.6817.64
FleetSHL245Land at 154-158 Albert Street & Fleet Road14880.1844.44
FleetSHL275Land at Little Mead, Fleet12171.0611.32
FleetSHL320Fleet Town Centre Zone 2201501501.883.33
FleetSHL322Fleet Town Centre Police Station1737370.6160.65
FleetSHL357Land at Sankey Lane, Fleet20200.6431.25
FleetTBAPyestock (aka Hartland Park)1,5001,50048.238.1
Hartley WintneySHL95Nero Brewery, Hartley Wintney660.1540
Hartley WintneySHL216Land adj. to James Farm Cottages, Hartley
Wintney
660.2920.68
HookSHL111Hook Garden Centre, Reading Road, Nr. Hook57574.4712.75
Long SuttonSHL296Old Dairy, Long Sutton550.225
OdihamSHL29Land at Butts End660.415
OdihamSHL66Rear garden of 4 Western Lane, Odiham16160.6425
OdihamSHL119Land at the rear of Longwood, Odiham990.3129.03
South WarnboroughSHL70Stables at Lees Cottage, South
Warnborough
550.2520
South WarnboroughSHL172Granary Court, South Warnborough16160.6923.18
WinchfieldSHL34Land adjoining Winchfield Court18251.0616.98
WinchfieldSHL84Land at Winchfield Lodge60603.815.78
WinchfieldSHL114Trimmers Cottage, Winchfield Hurst12120.4924.48
Church CrookhamSHL81Vertu, Beacon Hill Road, Church Crookham65701.7636.93
Blackwater and HawleySHL176Hawley House, Hawley8100.326.66
CrondallSHL178Broden Stables & Stable Yard, Crondall14271.410
CrondallSHL179Bowenhurst Lane, Crondall30351.520
Hartley WintneySHL189Land at James Farm, Hartley Wintney880.3125.8
Total3,2083,25011727.9

A number of these sites are “not currently developable” according to Hart.  But most of the green field sites they have put forward are also not currently developable.  We believe that the issues surrounding brownfield sites should capable of being resolved more easily than those for green field sites.

Sites not in the SHLAA

There are a number of sites not in the SHLAA that nevertheless should be considered that amount to around 785 additional homes.  These include the parts of Ancells Farm, Bartley Wood and Fleet High Street that have not already been permitted or counted elsewhere. We have also counted the complex of under-utilised offices that include Admiral House, Flagship House, Hart Offices and Harlington centre in Fleet.  Much of this site was recommended by Fleet Future, but for some reason Hart Council have ignored it.  But we can think of no reason why a council that was truly committed to a brownfield first strategy would not offer up its own under-utilised offices to be part of new, mixed use development and move to one of the other vacant office blocks in the district.  These sites, with an allowance for parts of sites that have already been permitted, are shown in the table below.

ParishSite DescriptionEstimated capacityNote
FleetAdmiral House, Flagship House, Hart Offices and Harlington centre350Paper by Gareth Price identified 775 units on a larger site incorporating much of this area
FleetAncells Farm370From Stonegate report
FleetFleet vacant offices220From Stonegate report
HookBartley Wood200From Stonegate report
Less units already granted permission or already counted-355Part of Ancells Farm and Barley Wood already granted. SHL 320 already counted
Total785

Conclusions

Drawing this together, there’s capacity for between 3,993 and 4,035 units on brownfield sites, without increasing the density on any of the SHLAA sites.

Now, according to Hart, we have to find space for a further 2,350 homes (now that 150 houses have been approved at Moulsham Lane, Yateley), according to the current Strategic Housing Market Assessment (SHMA).  This shows that we have now more than met our remaining needs from brownfield sites alone. We certainly do not need a new town at Winchfield or any new urban extensions in Hook, Fleet or Elvetham Heath.

However, we also know that Alan Wenban-Smith has challenged the SHMA and said that we need around 2,000 fewer houses.  If this were accepted by the inspector, we would have an even bigger surplus of brownfield capacity to take into the next planning period.

We also know that the SHMA is being revised, and the Government has published revised population and household forecasts earlier this year and these showed much lower figures for Hart.  Again, this should result in a lower housing allocation, and we would end up with a surplus of brownfield sites until the next planning period.

This begs the question why Hart Council is not including a formal brownfield option in its forthcoming consultation, when that was the clear view of the 2,130 people who signed the WeHeartHart petition.  Persisting with new town and urban extension solutions is untenable.  Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Lock, stock and two smoking barrels

lock stock and two smoking barrels

Lock, stock and two smoking barrels

I present without further comment the contents of a letter I sent to Hart District Council yesterday (Friday 20 November 2015). Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Errors, omissions and anomalies in the (Strategic Housing Land Availability Assessment) SHLAA and consultation materials

Dear Messrs Daryl Phillips and Stephen Parker,

It is clear that Hart Council has been very busy, publishing a vast array of new material about the SHLAA and the materials to be used in the forthcoming consultation about Housing Options.  I have burned a considerable amount of midnight oil going through those materials in some detail, and I have identified material errors, omissions and anomalies that give me serious cause for concern that I would like to share with you.  The Excel workbook containing the amalgamation of the SHLAA Master List, the NHB data and the SHLAA detail is attached for reference. These fall into several broad categories:

  • Assessment of brownfield site capacity and delivery
  • Deliverable and developable sites not included in the Developing a Local Plan for Hart paper (DLP) nor the New Homes Sites Booklet (NHB)
  • Sites missing from NHB but in the SHLAA
  • Discrepancies between capacity shown in NHB compared to SHLAA detail
  • Sites shown in detailed assessment but not in master list
  • Sites assessed as “not currently developable”, but have been granted planning permission
  • Range of meanings of “not currently developable”
  • Lack of consideration of the economic aspects of housing options 
  1. Assessment of brownfield site capacity and delivery.

There are a number of components to this:

In Hart News in September, and again at cabinet on 1 October, it was said that brownfield capacity had increased to 1,800 units. Now, this has miraculously fallen by 75% to 450 units on some dubious grounds. First, para 41 of the DLP states correctly that years 6-10 need only “developable” sites to be included, beyond that you can be more vague about sites.  We are already 4 years into the plan period and, according to the land supply calculation based on the current inflated SHMA, we have 5.7 years of land supply.  Yet, you are only selecting sites to be included in your calculations that meet the most onerous criterion of being “deliverable”.  As you know I have two FOI requests outstanding with you, the first is inquiring about the disposition of the 750 brownfield units that we were told were achievable back on November 2014, and the second asking for the analysis to support the 1,800 figure.  It seems to me you have inappropriately applied criteria that are too onerous in order to artificially reduce the potential brownfield capacity.  An example of this would be excluding Bramshill, when everyone knows it will be preferable for this site to undergo some sort of redevelopment to stop the Grade 1 listed building decaying and of course the hideous 1970’s accommodation blocks need replacing too.

You have under-stated the brownfield capacity in the DLP, compared to the assessed capacity in the SHLAA documents. This is shown in the table below:

Parish/Ref Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High) Sum of Brownfield Capacity in Table 1 in DLP doc
Blackwater and Hawley 320 320 300
SHL100 320 320 300
Church Crookham 6 6 8
SHL28 6 6 8
Elvetham Heath 45 45 45
SHL104 45 45 45
Fleet 221 221 83
SHL113 12 12 17
SHL245 8 8 14
SHL320 150 150 20
SHL322 37 37 17
SHL41 6 6 6
SHL42 8 8 9
Grand Total 592 592 436

 

This shows that the capacity shown in the DLP (excluding the 20 units from the sites with planning permission) is some 156 units lower than your own assessments in the SHLAA documents with most of the discrepancy arising from sites SHL320 & 322.  Correcting this would reduce the net requirement by 156 units.

In Figure 2 of the DLP, you assert that 52% of the development completed or where permission has been granted since 2011 is on brownfield sites. Yet at September Council, a question was asked along similar lines and the response was “these figures exclude brownfield sites that require planning permission, because those are not currently split between greenfield and brownfield developments”.  This leads one to conclude either that you have simply made up the figures in the DLP, or you knowingly misled the Council and the public in September.  Which is it?

  1. Deliverable and developable sites not included

[updated with this note]

There’s a large number of deliverable and developable sites that are in the SHLAA but not apparently referred to in the DLP or the NHB.  A list if these is shown in the table below (some of which are in the NHB):

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 320 320
SHL100 320 320
Church Crookham 6 6
SHL28 6 6
Elvetham Heath 45 45
SHL104 45 45
Fleet 25 243 248
SHL113 12 12
SHL245 8 8
SHL275 25 12 17
SHL320 150 150
SHL322 37 37
SHL41 6 6
SHL42 8 8
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Hook 550 550
SHL1&2 550 550
South Warnborough 16 16 16
SHL172 16 16 16
Grand Total 41 1,186 1,191

The land supply document shows a total of 3,878 units built, permitted or deliverable up until 1 April 2015, some 722 below the 4,600 figure you assert in the DLP.  I accept that 340 units from SHL1 & 2 and 10 from SHL69 are included in the land supply.  But the land supply does not include 300 units from Watery Lane.  Netting all of this off, then there are around 5,000 units already accounted for by being completed, permitted or deliverable, which would reduce the current net requirement by ~400 units compared to what you assert in the DLP.

  1. Sites missing from NHB but in the SHLAA

There are 76 units on sites in the SHLAA that are not already on the brownfield list and not strategic sites that do not appear in the NHB.  These are shown in the table below:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Fleet 10 10
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Heckfield 5 5
SHL157 5 5
Mattingley 48 48
SHL160 48 48
Yateley 7 7
SHL18 7 7
Grand Total 76 76

 

This raises the question as to why these sites have not been included in the NHB process either as selected or rejected sites.

 

  1. Discrepancies between capacity in NHB and SHLAA

There are material discrepancies between the site capacities shown in the NHB and those in the SHLAA.  Sometimes the NHB can be above the SHLAA figures and sometimes below.  But overall, adding up all of the sites where the NHB capacity is outside the range of SHLAA lower and upper limits, the NHB shows a lower capacity of some 1,500 units.  This demonstrates that the potential capacity of dispersal sites is being materially under-stated.  These sites are shown in the table in Appendix 1.

 

  1. Sites present in the detail of the SHLAA but not on the master list, and hence not in the NHB, nor mentioned in the DLP.

There are three sites, SHL167, 168 and 169 appear in the detailed assessments of sites, but not on the master list.

  1. Sites shown as “not currently developable” but have in fact been granted planning permission

Sites SHL68 and SHL117 are listed in the detail SHLAA documents as “not currently developable”, but according to the master list of sites have been granted planning permission.

  1. Range of meanings of “not currently developable”

It is clear from the above that the term “not currently developable” is a somewhat elastic phrase that can include sites that are just an administrative stroke of the pen away from deliverability as well as sites that face very significant challenges.  Many sites in the NHB and of course many of the strategic sites face very significant challenges that it is difficult to see how they can be remedied, such as proximity to flood zones, SSSI’s, SINCs, TPOs and the SPA and lack of proximity to existing settlements whereas others are much closer to deliverability.

However, the main materials being circulated for the consultation do not make this distinction clear.

  1. Lack of discussion about economics

The discussion about infrastructure costs in the DLP, with the only mention of costs being the woefully [inadequate] £30m for a new motorway junction – I would think there is little chance of change out of £100m.  But even so this misses out other important infrastructure items like the local road system, new or upgraded railway station, widening of the railway bridges over the local roads, new sewage farm, burying overhead power lines, new schools and new healthcare facilities to name but a few.  Hart currently has a £78m infrastructure funding deficit, Hampshire as a whole £1.9bn and the local NHS is predicted to have a large annual funding deficit.

These issues associated with a new town should be spelled out in detail, and I would think many of the same issues will arise with urban extensions.

It is certainly true that these issues will need to be resolved before the Local Plan can be found sound at examination.

So, what are we to conclude from the above?  First, the discrepancies outlined above, once corrected will make a very material difference to the calculation of how many more houses we need to build on green field sites (if any) and the capacity of each parish to deliver them.  I do not wish to subscribe to conspiracy theories.  However, the sum-total of the above, coupled with the obvious single-minded desire on the part of some members to push through a new town at all costs, leads me to conclude that either the people who created these consultation documents were incompetent or they are by their omission or intent about to mislead the public.   It is also clear that whatever systems and processes you are using to plan, manage, monitor and control the SHLAA are completely inadequate with such large discrepancies between different views of the same data.

It is clear to me that the forthcoming consultation should be postponed until these discrepancies are ironed out.

I would like you to treat this letter as a formal complaint and respond according to LGO guidelines.  I might also add that I will copy this letter to the chairman of the Standards Committee to ask him to set up an investigation and to our Local MP.  You might expect this letter and your response to be presented as evidence in any examination of the Local Plan.

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 15 12 12
SHL21 15 12 12
Bramshill 300 250 250
SHL106 300 250 250
Crondall 112 130 130
SHL159 65 100 100
SHL72 16 18 18
SHL76 31 12 12
Crookham Village 70 100 100
SHL53 70 100 100
Dogmersfield 40 5 10
SHL39 40 5 10
Eversley 91 123 123
SHL127 50 70 70
SHL140 41 53 53
Ewshot 120 187 187
SHL174 63 105 105
SHL355 48 75 75
SHL80 9 7 7
Fleet 706 881 886
SHL102 43 45 45
SHL275 25 12 17
SHL333 500 750 750
SHL50 46 60 60
SHL51 92 14 14
Hartley Wintney 208 287 301
SHL155 117 194 194
SHL216 8 6 6
SHL35 34 3 17
SHL45 25 51 51
SHL91 10 11 11
SHL97 12 10 10
SHL99 2 12 12
Heckfield 169 45 65
SHL109 44 5 5
SHL257 62 20 30
SHL259 63 20 30
Hook 2,090 3,849 3,849
SHL123 13 20 20
SHL3 543 1,000 1,000
SHL4 458 1,800 1,800
SHL5 1,065 1,000 1,000
SHL6 11 29 29
Long Sutton 63 65 65
SHL296 6 5 5
SHL335 34 35 35
SHL336 23 25 25
Mattingley 130 40 60
SHL239 55 20 30
SHL240 75 20 30
Odiham 3,308 2,894 2,904
SHL108 387 160 160
SHL110 2,160 1,900 1,900
SHL138 204 261 261
SHL228 48 75 75
SHL29 10 6 6
SHL328 25 30 30
SHL329 44 30 30
SHL57 47 75 75
SHL59 115 175 175
SHL60 11 12 12
SHL65 36 50 50
SHL67 53 80 80
SHL78 168 40 50
Rotherwick 130 200 200
SHL86 130 200 200
South Warnborough 36 20 25
SHL70 7 5 5
SHL75 29 15 20
Winchfield 119 32 42
SHL114 11 12 12
SHL262 108 20 30
Yateley 9 60 60
SHL13 0 8 8
SHL149 0 10 10
SHL17 0 30 30
SHL303 9 12 12
Grand Total 7,716 9,180 9,269

See more at our consultation page:

link

Questions for Hart Council meeting on 29 October 2015

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Hart District Council meets again on 29 October at 7pm.  We have been busy preparing some questions for them on brownfield capacity; the impact of the new Government announcements about brownfield sites; Ranil’s statement about protecting our green fields; when they might use Compulsory Purchase Orders to acquire vacant sites; the inaccurate assumptions in the SHMA and the slippage in the timetable for the Hart Local Plan.

The questions can be downloaded from the button, and are re-produced below:

Questions to Hart Council on 29 October 2015

To Daryl Phillips

  1. Please provide an analysis, including SHLAA ref, site name and description, site area in hectares, and expected yield, of the sites that have been used to build up the estimate provided at cabinet on 1 October 2015, when you asserted that the ‘guesstimated’ capacity for brownfield development in the district up to 2031 was now 1,800 dwellings (up from the 750 dwelling estimate of a year ago and compared to the 2,438 units estimated by WeHeartHart).
  1. How will the recent Government announcement extending permitted development rights indefinitely and allowing automatic planning permission in principle on brownfield sites impact your assessment of brownfield capacity?

To Stephen Parker

  1. Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?
  1. What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?
  1. How many sites would meet those criteria and how many dwellings might they yield?
  1. Given that the baseline estimate of the number of households in Hart in 2011 and 2031 used in the SHMA was 35,760 and 42,220 respectively, but the new DCLG 2012-based household projections (Table 406) for 2031 show that Hart will have only 40,618 households, a reduction of 1,602, can you confirm that these revised figures will lead to a corresponding reduction in Hart’s assessed housing need?
  1. When will the 6,560 excess housing requirement for the whole HMA be removed from the assessed need in the SHMA given that the new DCLG 2012-based population projections (Table 426) show a population projection of only 289K for the HMA for 2031, compared to the SHMA (Appendix F, Figure 2)
Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

starting assumption of 307K and the final population estimate of 322K used to determine housing need?

  1. What justification is there for assuming the significant social changes implied in the SHMA given that the SHMA increases the number of houses that need to be built based in part on very ambitious jobs forecasts which when combined with the population projections in the SHMA results in a massive increase in the proportion of people of working age who will be in employment (see table below)?

 

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

 

  1. What steps will be taken to adjust the jobs forecasts in the SHMA given that, a) the revised BRES job numbers for 2013 show that the compound annual growth rate in jobs we have achieved since the recession ended in 2009 is ~0.5% which is much lower than the ~0.8% growth rate assumed in the SHMA for the period 2011-2031, b) this comes at a time when the UK is creating more jobs than the rest of the EU put together and c) it is inevitable we will experience at least one more recession during the plan period?
Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Hart, Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

  1. What steps are being taken to accelerate the delivery of the Local Plan given that the recent Government announcement indicated that Local Plans need to be brought into force by 2017 and the current LDS shows the Local Plan being adopted in Summer 2017 and other DPD’s in Autumn 2018 and the track record of past slippage?

Remaining Hart District housing target can be met from brownfield sites alone

Vacant block at Bartley Wood in Hook, Hampshire

Bartley Wood Estate in Hook

New facts have come to light since Hart Council planning department put together their estimate of brownfield capacity which show that Hart’s remaining housing target can be met from brownfield development alone. Please support us in getting a brownfield only option included in the forthcoming consultation by attending the Hart Cabinet on 1 October where Hart’s response to the We Heart Hart petition will be agreed.

Last November, the council’s estimate of brownfield capacity over the entire plan period was around 750 units (taken from parts 1 and 3 of the SHLAA as per the FOI request we made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.

Since then, a number of interesting things have happened:

  • An important study by Stonegate Homes has shown that brownfield capacity is much larger
  • Planning permission has been applied for or granted on other sites that were either not in the SHLAA or were not counted as brownfield sites.
  • New potential sites have come to light that were not included in the SHLAA
LocationNumber of Dwellings
Guillemont Park Phase 1 (not included as brownfield site in SHLAA) 150
Guillemont Park Phase 2320
Ancells Farm, Fleet370
Bartley Wood, Hook200
Fleet Road, Fleet220
Bramshill House350
Fleet Police Station50
Extra dwellings at Landata House28
Total1,688

All of the dwellings above were not included as brownfield sites in the SHLAA.  Guillemont Park (Sun Park) was in the SHLAA but for a smaller number of units, and was shown in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House, Hook for 28 more dwellings than were included in the 5 year land supply calculation.

The Bramshill House and Fleet Police station sites were not included in the SHLAA.

The Stonegate report identified 370 units at Ancell’s Farm in Fleet, 200 units at Bartley Wood in Hook and a further 220 units on Fleet Road in Fleet.

Derelict Offices in Fleet, Hampshire

Derelict Offices in Fleet, Hampshire

However, the proposals for Ancells Farm cover only 7 of the 23 office buildings in the business park which shows that there is additional capacity there.  Moreover, there are even more vacant office blocks in Hook so there is more capacity there too.  Of course, across Hart, Surrey Heath and Rushmoor, there is currently 500,000 sq m of vacant office space, and forecasts for even more vacancies, so there is no danger of restricting jobs growth by redeveloping offices.

If the original 750 units were to be added to the 1,688 units identified above, then that amounts to a total of 2,438 potential units on brownfield.  If it were possible to increase the density (from 30dph to a still reasonable 80dph in urban areas) on the original 750 units, the total identified capacity would rise to some 3,688 units.

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Moreover, these figures do not include the massive potential of the 119 acre Hartland Park (or Pyestock) site where planning permission for a big warehouse was given years ago, but no activity is visible.  Surely, the developers of this site want to earn some return on their investment and would change to residential.

The remaining requirement of 4,000 has of course been reduced by the unfortunate decisions to allow development at Watery Lane (300 units) and Hawley Park Farm (126 units) leaving the remaining allocation of at most 3,574.

It is clear that it is easily possible to meet the entire remaining of 3,574 from brownfield alone.  It will take some creativity and energy, but a combination of increasing density and allocating more vacant offices is easily within reach, so we don’t need a new town and can protect our countryside.

We have put proposals to Hart Council to include a formal brownfield option in their forthcoming consultation on the Hart Local Plan.  Please support us by coming along to the Hart Cabinet on 1 October where Hart’s response to the We Heart Hart petition will be agreed.