Winchfield Parish Council demolishes the new town idea in their response to the Local Plan Consultation

Hart in Heart of Hart, Winchfield, Hart District, Hampshire

Winchfield Parish Council (WPC) have submitted their response and covering letter (see downloads below) to Hart Council’s Local Plan consultation and effectively demolished all of the arguments supporting Hart’s new town idea.  The response was pulled together with the help of professional planners at John Boyd Planning Associates.

There are four main planks to WPC’s argument:

  1. Lack of evidence to justify the need for a new settlement
  2. Winchfield is not a suitable location for a new settlement
  3. A new settlement is not a viable approach
  4. There should be more of a focus on alternatives such as brownfield development and dispersal

The lack of evidence is demonstrated by the fact that Hart has not yet consulted upon the issues recommended by Peter Village QC namely, employment, retail, transport, and infrastructure. Moreover, it is premature and illogical to be conducting the consultation now when the Strategic Housing Market Assessment (SHMA) is being revised and we don’t know what the Objectively Assessed Need is going to be. They also note the work done by Alan Wenban-Smith that seriously challenged the numbers in the existing SHMA.

The challenge to the suitability of Winchfield as a location is demonstrated by the significant barriers to delivery outlined by Hart themselves such as education, transport and foul water drainage. They also point out that the main argument used in favour of a settlement at Winchfield, the presence of a railway station, is undermined by the suggestion that the station would have to be relocated to support the new town. There are also significant doubts about the capacity of the available sites to accommodate a new settlement of sufficient size to be viable, especially when one considers the environmental constraints such as SSSIs and SINCs as well as the space that will have to be found for SANGs, shops, car-parks, schools and recreational facilities. Not only that, but the disparate nature of the sites will make it very difficult to plan a coherent and compact nuclear settlement.

WPC also challenge the viability of a new settlement by pointing out the massive costs of infrastructure with no evidence being presented to indicate how these costs would be met.  The NPPF (para 47 & 173) calls for housing and infrastructure to be planned together, so if it cannot be demonstrated that the right infrastructure can be funded and built, then the whole new town idea could be rejected by an inspector and the Local Plan found unsound.

WPC’s submission welcomes Hart’s belated focus on brownfield development, but criticises them for ignoring an important study by Stonegate Homes, the further opportunities presented by the changes to permitted development rights and the results of Hart’s own findings of new “Zones of Brownfield Opportunity”.  They also point out that Hart’s ‘Economic Development Strategy’ (2015) identifies that the District Council must direct its resources to urban regeneration, and that focusing growth in and adjacent to Hart’s main settlements would
boost investment in infrastructure and regeneration in the locations where it is needed most and help close the £78m funding gap.

Finally, they say that it would be inappropriate to try and meet the housing needs of our ageing population through a new town option.

All in all, this is an eloquent and devastating attack on the whole idea of a new town and is very much in-line with what We Heart Hart has been saying for months.  We can only hope that the councillors will take heed of such an important report from professional planning consultants and get the Local Plan back on track to being found sound at inspection.


Cover letter:

Winchfield Parish Council Cover Letter

Full response:

Winchfield Parish Council Local Plan Consultation response

response  covering letter

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.


Hart Council’s new consultation still likely to leave it in a hopeless position

Scales of Justice weigh against Hart District Council

Scales of Justice weigh against Hart District Council

It seems likely that Hart Council is about to launch a new consultation on housing options for the district as part of the Local Plan.  We are following this closely, and will publish some additional materials to help residents make up their mind once the full consultation has been made public.

But having reviewed the materials already on Hart’s website (cabinet meeting materials for 18 November 2015), it seems clear that the council have taken no notice of the legal opinion they received from top QC Peter Village, that described their position as “hopeless”.

That opinion said:

…there is no evidence that to date there has been any consideration by the Council of the “reasonable alternative[s]” of providing less than the OAN, on environmental grounds…

There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues. Thus, the Council presently appears to be in a hopeless position if it maintains its current course. Either it will proceed with a plan that does not address fundamental matters (thereby exposing itself on the “soundness” issue), or it will incorporate matters which have indisputably not been the topic of any regulation 18 consultation.

We have been through the consultation materials in some detail, and we can find no reference to the council considering providing fewer houses on environmental grounds, and no sign of consulting us residents on employment, retail, transport or infrastructure.

Coupled with the issues we raised to the council on Friday, it is looking like this consultation is going to be an expensive waste of time and taxpayers’ money because we are still not being offered a proper consultation on all the issues that matter. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Hart District is being asked to build too many houses

Housing Market Area Migration and housing capacity

Figure 1: Housing Market Area Migration and housing capacity

Hart District is being asked to build 7,534 houses in the planning period up to 2032 (now 9,134 as Hart is starting to plan for an additional 1,600 houses from Rushmoor).  This target is based on the Objectively Assessed Housing Need (OAHN) contained in the Strategic Housing Market Assessment (SHMA) carried out by Hart District and Rushmoor and Surrey Heath Boroughs. We believe this target is too high because the SHMA is based on a number of flawed assumptions:

  • Inward migration assumptions unrealistic
  • Average household size unreasonable
  • Jobs growth forecasts not credible
  • Overall adjustments lead to building rate higher than national requirement

These are set out in more detail below and in the submission to the Owens Farm (Hop Garden Road), Hook appeal. The overall impact of correcting these errors would be to reduce Hart District’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone and won’t need a new town at Winchfield or anywhere else.

Inward Migration Assumptions Unrealistic

Inward migration to this or any other district represents a “want” of people living elsewhere to live in Hart and not a “need”.  Many people may desire to live in Hart because it is one of the best places to live in the country, but no-one “needs” to move to live here in the strict sense of the word.  Indeed inward migration to Hart represents the unmet needs of other districts.  If Government policy is followed, then the housing, employment, education and other “needs” of the people “wanting” to move to Hart should be met by the local authorities where they currently live and thus the apparent need for housing in Hart arising from inward migration should substantially reduce.  There is no evidence presented in the SHMA to evaluate the impact of reduced inward migration to Hart from other districts as a result of those districts now being forced to meet their own needs, nor the impact of the implementation of the Northern Powerhouse.  Indeed London has now agreed to meet its own housing need in full, which should reduce the scale of inward migration to the HMA.

Notwithstanding the above, the SHMA makes a subjective judgement to cherry pick inward migration data from 2005-2010 as being the “most realistic” approach to take to future demographic modelling.  Moreover, it uses spurious statistical analysis to try to infer causation from a weak correlation (R2=~0.65) between housing completions and inward migration.  This is inherently flawed for a number of reasons outlined below.

First, of course it is self-evident that the period during which the HMA delivered most housing was when inward migration was highest.  However, as was argued above, this scale of inward migration represents unmet needs of other districts rather than the unmet needs of Hart.

Second, the period when we were building most and attracting most inward migration was during one of the longest uninterrupted periods of economic growth in history, supported by a large structural deficit in the national accounts and the biggest credit binge of all time.  Of course it ended in a spectacular bust and can in no way be described as a “normal” or “sustainable” set of economic conditions.  The economic conditions we are seeing now with more moderate growth linked to the need for the Government, companies and people to live within their means and reduce debt will be the situation for the foreseeable future and thus represent a more “normal” situation.

The period 2007-2012 includes the final year of the boom, the recession and the now more moderate pace of economic growth that surely more closely represents future conditions.  Indeed, as Figure 1 shows (data taken from Fig. 7.4 of the SHMA on p71) taking the period 2007-2012, the HMA delivered 2,942 new dwellings which at an average of 2.5 people per dwelling created capacity for an extra 7,355 people to live in the area.  Despite that, the HMA experienced an overall outward migration of 1,824 people.  It surely cannot be considered sound to base the future housing “need” on increasing inward migration projections when recent data shows that in fact the HMA is undergoing net outward migration despite creating significant capacity for more people to live here.

Accordingly, the additional 1,210 houses postulated in the SHMA arising from inward migration should be removed from the housing “need”.

Average Household Size Forecasts Unreasonable

Average Houshold Size projections for Housing Market Area

Figure 2: Average Household Size projections for Housing Market Area


Figure 7.7 of the SHMA (reproduced as Figure 2 above) shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. This is in direct contradiction to both the 2008-based and 2011-based CLG projections.  Yet the forward projections used in the SHMA reverse the trend shown in actual data in the census and persist with the inaccurate forecasts of a continuing fall in the average household size.

Part of the justification for this is given as “at the time of the 2011 Census, the British economy was still in recession”.  This is factually incorrect as a cursory examination of the GDP numbers on the BBC website shows that the economy came out of recession in mid-2009.  It seems the forecasting “experts” are at a loss to properly explain this reversal of trend.

Moreover, given that the starting point for the SHMA projections is DCLG sourced figures, it would be somewhat odd for the DCLG forward projections not to include its own forecasts for household size.  There is therefore a significant risk that this part of the SHMA has double counted erroneous household size projections.

It is therefore inappropriate continue to assume a continuing downward trend in household size.  Surely a more prudent assumption would be to assume that the current household size is maintained and update that assumption and the SHMA as more real data comes to light.

Accordingly, the 1,500 additional houses in the SHMA related to the flawed household size assumption should be removed.

Jobs Growth Forecasts not Credible

The SHMA uses a set of jobs growth assumptions that are based on forecasts that are vastly in excess of what has been achieved in the most recent economic cycle.

The SHMA contains data on the historic rates of job growth for the HMA.  This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data.  This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%.  Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum for the 3 years in question or a CAGR of 0.05%.

Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3: Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3 shows a comparison of the BRES data and the ABI data that demonstrates the discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data.

Taking this 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum.

However, the SHMA uses as its central assumption that future jobs growth of 1,130 per annum will be achieved, equating to a CAGR of ~0.79%, nearly double what was achieved over the most recent economic cycle and far higher than that achieved during the unsustainable boom of 1998-2008.  Given the constraints on Government spending and tighter credit conditions that are likely to persist for some time due to tighter bank regulation, it is inconceivable that we will achieve an economic growth rate nearly twice that achieved during the last economic cycle. Figure 4 shows the comparison of these growth rates.

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

Figure 4: Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Little justification for this is given other than it is based on Experian forecasts. The recent job creation history (2009-2012) showed jobs growth of 67 per annum as we came out of the recession.  67 jobs per annum equates to less than 6% of the jobs that the SHMA assumes we will create. Revised figures for 2013 demonstrate a CAGR of jobs growth from 2009-2013 at 0.52%, still well below the SHMA projections at a time the UK as a whole is creating more jobs than the rest of the EU put together.  This demonstrates that the Experian forecasts are pie in the sky and it beggars belief that such unproven Experian forecasts should take precedence over the actual real world achievement.

A further illustration of the outlandish nature of the Experian forecasts is given in para 7.70 of the SHMA.  In its forecast published in 2013, Experian assumes there were 145,000 jobs in the HMA in 2011.  Whereas the 2011 Census says there were only 122,300 and the BRES data says 125,000.  How can we trust Experian to forecast the future when it can’t even get the the past right?

Even the Employment Land Review produced by Rushmoor Borough Council described the Experian forecasts as:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”

The SHMA also says at para 7.85:

“…there are many ways labour markets can adjust to an increase in demand for labour that do not require an increase in the resident workforce. In summary these are:

  • A reduction in unemployment
  • A rise in economic activity rates
  • A shift away from part time working to full time working
  • An increase in double jobbing
  • A reduction in out-commuting
  • An increase in in-commuting

None of these changes require an increase in resident population, and all of them will be stimulated if
wage and salary levels increase.

In the modelling, allowance has been made for only one of these effects…”

No explanation is given for not taking into account the other ways in which the labour market can adjust.

In addition, if one compares the jobs forecasts to the population forecasts, the overall forecasts imply a massive, unrealistic increase in the percentage of people of working age in employment as can be seen in the 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%

This shows an increase from around 70% of working age people in employment to 86-88%.  No justification for this increase is given anywhere.

From the above, it is clear that the employment forecasts are outlandishly large and the SHMA does not even take into account most of the ways in which jobs can increase without leading to a need for more housing.  It is clear we should not be basing our housing requirement on such forecasts.

Figure 4.1 of the SHMA demonstrates that Hart in particular and the whole HMA enjoy high levels of employment and unemployment levels that are below the regional and national averages.

Therefore, the number of jobs to be created in the future should at least partially be a matter of “want” rather than “need”.  The future employment targets should be based on a realistic assessment of the capacity of the economy to create jobs in the private sector as it is these jobs that will support the largely state sector jobs in education and health that will be required to support the increased population.

As noted above para 7 of the NPPG states that local communities should be involved

“from the earliest stages of plan preparation, which includes the preparation of the evidence base in relation to development needs”.

Moreover, a recent legal opinion from Peter Village QC has said:

“There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues.”

It therefore follows that the local community should be consulted upon the employment targets it wishes to set and the related scale of development required to meet that target.  No such consultation has taken place, nor is it planned which represents a significant flaw in the Local Plan process. The evidence from the petition indicates that local people are more likely to express a preference for a lower level of development.

Finally, despite enjoying high levels of employment, it is clear that we need to change the way we forecast jobs growth in the area as past methods have resulted in vast amounts of unused employment land and vacant retail outlets with examples illustrated here and here.

It is clear that past employment forecasts have been erroneous; that the future employment forecasts in the SHMA are spurious and do not represent a realistic assessment of future economic or employment growth rates; and the local communities have not been consulted upon this key issue.  Nevertheless, we can achieve enviable growth and employment rates in line with the requirement to “plan positively” without having to resort to such over-development.

Accordingly, the 5,100 additional houses in the SHMA related to the flawed employment forecasts should be removed.

Overall adjustments lead to building rate higher than national requirement

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 5: Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Evidence presented at the examination of the Vale of the White Horse Local Plan has demonstrated that if the adjustments made to the baseline DCLG housing projections were applied on a national basis, they would increase the national output of housing to double the DCLG estimate of what is needed and triple the recent output of housing.

Applying a similar approach to the Hart, Rushmoor and Surrey Heath SHMA shows that on a national basis, we would be delivering 54% more housing than we need on a national basis, see Figure 5 above.  Surely it cannot be right that we are being asked to build at a rate that would lead to a surplus of housing.

England housing delivery actuals and projected 1946-2031

Figure 6: England housing delivery actuals and projected 1946-2031

The baseline DCLG projections for the combination of Hart, Surrey Heath and Rushmoor call for 790 houses per annum (SHMA Figure 7.3).  This equates to the DCLG projection of 220,000 houses per annum nationally (see figure 6 above).  This compares to recent performance of around 150,000 houses per annum.

The final SHMA, after taking into account past under-delivery, amount to a total of 24,413 houses (see table below), or an increase of 54.6% over the DCLG baseline figures.  The duty to cooperate might mean that Hart District has to build more houses than either Surrey Heath or Rushmoor as part of our Local Plan.

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

If the same 54.6% uplift were applied to the DCLG projection, we would be building over 340,000 houses per annum nationally, more than double recent performance.

In recent years Hart has built more houses than it has been required to do and built at a rate above regional and national averages (SHMA Table 5.11).  It is beginning to look like the total of the local SHMAs are much larger than the overall requirement as defined by the DCLG. Surely it cannot be right that we are being asked to build at rate more than 50% higher than the DCLG suggests we need to meet overall demand.


The overall impact of removing these errors would be to reduce the overall housing target for the combined area by around 7,800 units.  This would reduce Hart’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone.

Leaflet campaign doubles size of We Heart Hart petition

A big thank you to all the volunteers who have helped with the We Heart Hart leafleting campaign.  Just before we started leafleting we had 923 signatories.  Today, the number is 1,846; meaning the petition has doubled in size in just three weeks.  This is more than three times the number of people who responded to Hart District Council’s consultation and more than 8 times the number of people who expressed a preference for a new town.

Support for our cause has increased after we published the legal opinion from Peter Village QC that said that Hart was in a “hopeless position” with the Local Plan.  Surely it is time for Hart to think again and adopt our 5-point plan to bring the Local Plan back on track which is summarised below:

  • Create a medium growth scenario with a lower housing requirement than the current high growth scenario to give an option to reduce the environmental impact of development.
  • Create a formal brownfield option and invite a competition to design the best way of using our brownfield land.
  • Do the work and consult upon the additional elements of a proper Local Plan such as employment, education, transport, retail and other infrastructure.
  • Consider the Environment and Landscape by carrying out proper habitat studies and landscape character assessments.
  • Fix the management and governance problems within Hart Council that have resulted in the past failure and current hopeless position.

If you would like to support our position, then please sign and share our petition.


Go to Petition

Top QC says Hart Council’s position on the Local Plan is “hopeless”

Scales of Justice weigh against Hart District Council

Scales of Justice weigh against Hart District Council


Top planning QC, Peter Village has produced a devastating legal opinion on Hart District Council’s Local Plan process and pronounced that they are in a “hopeless position“.  Hart Council have received this opinion, but have refused a meeting to discuss ways of improving the plan.  In fact, at last night’s council meeting, council leader Stephen Parker dismissed the report as “just one opinion among many”.

It is imperative that Hart gets a high quality local plan in place quickly and fends off the demands from Surrey Heath and Rushmoor Borough Councils to build an extra 3,100 houses in Hart.  The council’s attitude displays a staggering level of arrogance and complacency that can only lead to more delays and extra costs to get the plan right.  We urge all voters to press their council candidates to push to get the Local Plan process back on track by adopting our 5-point plan and dropping all ideas of a new town in Hart District.

The essence of the opinion is:

  • The Regulation 18 public consultation in the autumn of 2014 addressed housing options and did not consider other vital issues such as employment, retail, transport and infrastructure.
  • Hart District Council said in April 2014 that they would conduct a second Reg 18 consultation in March 2015, which they have since dropped and now intend to proceed directly to a Regulation 19 consultation on the Draft Plan for Final Inspection.  This plan is likely to fail because either the Local Plan will not contain all the elements it should, or they will not have consulted on all of the things they should consult upon.
  • Hart have not consulted upon the demands from Surrey Heath and Rushmoor that Hart build 3,100 houses for them.
  • Hart have not considered a medium growth “policy on” scenario of not meeting the full housing need on environmental grounds.
  • Hart have not properly considered the brownfield capacity of the district, highlighting that the capacity could be up to 3,500 dwellings, far more than the 750 dwellings Hart is still insisting upon.

Reader may recall that set out a 5-point plan to address these issues and this is summarised below:

  • Create a medium growth scenario with a lower housing requirement than the current high growth scenario to give an option to reduce the environmental impact of development.
  • Create a formal brownfield option and invite a competition to design the best way of using our brownfield land.
  • Do the work and consult upon the additional elements of a proper Local Plan such as employment, education, transport, retail and other infrastructure.
  • Consider the Environment and Landscape by carrying out proper habitat studies and landscape character assessments.
  • Fix the management and governance problems within Hart Council that have resulted in the past failure and current hopeless position.

If you want to press for change, please sign our petition:


Go to Petition


The full Legal Opinion and our latest Press Release can be found below:

Peter Village QC Legal Opinion
We Heart Hart Press Release 1 May 2015

This has been covered in the Basingstoke Gazette.


QC Opinion

Press Release