How Hart Council should respond to the We Heart Hart petition

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

Vacant Office at Ancells Farm, Fleet, Hampshire

As we posted earlier, we have submitted the We  Hart petition to Hart District Council and the council have set out the process by which they will consider the petition.

We have drafted some suggestions as to how the council should respond  and sent them to Council leader, Stephen Parker and they are shown below.  We have a chance to put these ideas to Cabinet on 1 October at 7pm.  Please tell us if you are coming along to give us your support.

Please e-mail your councillors to ask them to support these proposals.

 

Dear Stephen,

Thank you very much for your email.

As you know the petition is from 2,130 signatories, nearly four times the number that responded to Hart Council’s consultation last year and more than ten times the number of people who expressed a first preference for a new town and is therefore a very significant expression of local opinion.

I welcome your approach to treat the petition seriously.  My understanding is that a petition of over 1,000 signatories would trigger an automatic debate at full council.  However, I do believe a debate at Cabinet is more likely to be more productive, so I support the approach you suggest.

As you might expect, I have my own suggestions as to what the appropriate responses to the petition should be and I set them out below for your consideration, interwoven with the petition objectives:

  1. To reduce the overall housing allocation for Hart District

 I think there are two broad approaches to this.  First, challenge the SHMA to reduce the overall housing allocation for the whole HMA.  If this is successful, then it will have a two-fold effect of reducing Hart’s own need and also reducing the risk of overflow from Surrey Heath and Rushmoor.  I believe the key arguments are around inward migration assumptions; average household size and in particular jobs growth assumptions which are at a rate nearly double what was achieved over the economic cycle from 1998-2012 and will result in unprecedented levels of participation in the labour market (rising from around 70% to around 86%) for those of employment age.  I gave more detail on these arguments at both the Hop Garden Road appeal and in my response to the Rushmoor Local Plan.  More detail can be found here. However, I do recognise it is difficult for the council to challenge its own document and I await Rushmoor’s response to my strong challenge, but I do understand that the SHMA may be re-visited and it would be helpful if the council would commit to challenging the assumptions set out above as part of that process.

Second, in conversation with a number of professionals in the planning sector, I have been told a number of times, that it is uncommon for councils to explore fully their “policy on” options with regard to environmental and other constraints.  One of the main attractions of Hart as a district is its rural environment with associated SPA, SSSI’s, SINCs, green space and wildlife.  May I suggest that a proper environmental study is carried out to set out the value of Hart’s environment and ecology to build an argument for not meeting the full requirement of the SHMA?  I know that WAG is working on some proposals in this area with some of the rural parishes and would be keen to discuss the matter with you and offer to share the costs of preparation. 

  1. Demand that the Council develops a vision and strategy for Hart that retains its role as a rural, green hinterland for NE Hampshire that respects the separate character and identity of Hart’s settlements and landscapes and preserves the green spaces as amenity space for the urban settlements.

You may recognise the words above as taken from the withdrawn 2013 Core Strategy.  This was, and remains a good vision.  I would ask that as a minimum, the forthcoming Regulation 18 consultation sets out at least one potential “vision” for the district, and that one of the “vision” options includes words to this effect.

  1. To require that the housing need is met by building on brownfield sites and increasing density in our existing urban areas

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 I made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.  Since then considerable progress has been made in identifying and in some cases granting permission on additional brownfield sites:

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 lower number of units, and in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House for 28 more dwellings than were included in the 5 year land supply calculation.

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.

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 at 3,574.

It is clear that with some creativity and energy, the gap between the remaining allocation of 3,574 and the currently identified brownfield capacity can be closed by working on a combination of reducing the overall allocation by reducing the SHMA or applying environmental “policy on” considerations, increasing density and finding more brownfield sites.

In the light of this, I welcome the paper that is to be put before Cabinet next week, signalling the more positive approach that the council proposes towards building housing on previously developed land.

I would ask though, that you consider some further steps:

  • Creating a new, formal “reasonable suitable alternative” option of meeting the remaining housing allocation solely through brownfield development.  This option should appear in the consultation paper.
  • Creating a complete database of all of the potential brownfield sites in the district, including those not in the October 2014 SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock (aka Hartland Park), Sun Park, Ancells Farm, Bartley Wood, Fleet High St, Fleet Police Station and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).
  • Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.
  • Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.
  • This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor, particularly given the massive amount of current and forecast vacant employment land and Rushmoor seeking to protect 96 Ha.
  1. To request that future housing stock reflects the needs of the changing demographics of the district.

I set out in a question to council earlier this year that Hart will need to deliver around 2,500 housing units to meet the needs of the ageing population.  I contend that a new town will simply build the wrong type of accommodation in the wrong place to meet those needs.  It would be far better if these were built on brownfield sites in more urban areas, close to amenities such as doctors, post offices, shops and so on.  When the elderly move into these types of development, their well-being improves and of course, they free up conventional housing stock for families.  Could I therefore ask that the forthcoming consultation paper contains specific proposals on how the needs of the ageing population will be met?

  1. To demand the council and government do not plan for any new settlement in Hart that will act as a sink for the unmet housing need in neighbouring areas.

Addressing points 1, 2, 3 & 4 will render a new town unnecessary particularly when you consider the:

I do hope you find these suggestions helpful.  I would be grateful if you could circulate them to planning officers and Cabinet members for their consideration.

Call for Hart Council to work with Winchfield Action Group and We Heart Hart

Cooperation between Hart District Council and We Heart Hart and Winchfield Action Group

Call for Hart District Council to work with We Heart Hart and Winchfield Action Group

Tristram Cary, spokesperson for Winchfield Action Group (WAG) has called for Hart District Council to work with groups like We Heart Hart and WAG in the preparation of the Local Plan instead of refusing to meet and seeking to suppress questions.

Tristram’s call came in an excellent email to the Standards Committee of Hart District Council, asking them to reject the proposals that seek to restrict the questions that can be put and limiting the petitions that can be served upon the Council.  We Heart Hart fully endorse Tristram’s stance which is re-produced in full below:

I wish to register my very strong objection to the proposal to restrict questions and petitions which are to be debated at the Standards Committee on Thursday.

I can understand that it is tiresome for Hart to have to deal with so many questions from the public, and I can understand the view that the questions are being used as a platform to state opinions of groups such as WAG and WeHeartHart. But so what? Isn’t the point of public participation at Council Meetings to allow opinions to be heard, and questions to be asked? Surely an hour a month isn’t a big price to pay for public involvement in the debate?

I would also like to point out that Mr Parker has said in his proposal that “the proper way to deal with such matters [ie planning matters] is to participate in the consultation exercise”. But Hart has decided (illegally in the view of Peter Village QC) to remove the Public Consultation on the Local Plan from the planning process.

As well as objecting to the proposal to restrict questions, I would like to make a more general point.I think that Hart’s attitude to the work of WAG and WeHeartHart has been dismissive. For instance Hart refuses to have a meeting with us to discuss the legal opinion, and the answers given to our questions and suggestions have been on the whole incomplete and unhelpful. Hart’s message appears to be “we have decided what we want to do and we are going to ignore your views to the greatest extent possible”. I suggest that Hart would do well to regard WAG and WeHeartHart as allies in the attempt to arrive at the best possible Local Plan for Hart, backed up by the strongest possible evidence base. WAG and WeHeartHart have got access to funds and expertise, and I see no reason why these resources should not be used in collaboration with Hart DC to do work that is in the common interest of the whole community. I am thinking of work packages such as a study of Brownfield site capacity in Hart and Rushmoor and an ecological/environmental study of Hart to better understand the value of the countryside.

The NPPF (para 155) requires councils to “engage in early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses…A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made”. I think that Hart has so far failed dismally to live up to the spirit of the NPPF. Hart’s engagement with WAG and WeHeartHart has been the exact opposite of proactive, and I think that a change of attitude is long overdue.

I would welcome a meeting between Hart DC and WAG/WeHeartHart to discuss how we might engage together in a more productive way.

Let us hope that Hart Council respond positively to this suggestion and build on the work we did to support the council with the Hop Garden Road (Owens Farm) Hook, appeal and the response to the Rushmoor Local Plan.

Hart Council censors questions about the Local Plan

Hart Council so ronery it has to censor questions

Hart Council so ronery it has to censor questions

In an astonishing move reminiscent of North Korea or Stalinist Russia, Hart Council have decided to censor questions saying they “do not publish speculative views from the public” and that they will “prepare and publish guidelines on the format of questions that will be accepted”.

This arose because we asked three questions about school places, brownfield sites and whether Hart would consider an alternative approach to delivering the Local Plan.  Each question had a preamble to set the context before the short question was asked.  Hart have decided to censor the preamble part of each question so that members of the public can’t see them, although they did say they circulated the full text to councillors.

There is a saying that the flak gets heaviest when you are over the target, so I guess this means that the council are finding the questions we are asking uncomfortable.  But we are astonished by their attempt to stifle democracy and how they seek to infantilise the debate about the best approach to the Local Plan.

We think the Planning Inspector will take a dim view of this approach as NPPF Para 155 says:

“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.”

This clearly places an obligation on Hart Council to consult widely and they seem to be afraid to engage, even though they asked us to make a submission to the Hop Garden Road (Owens Farm) appeal and were pleased to receive our criticism of the Rushmoor Local Plan.

 

 

 

Hart Council Responds to Rushmoor’s Local Plan

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Hart Council has responded to Rushmoor’s Draft Local Plan.  In summary their points are:

  • Rushmoor should look again at the SHLAA to seek out new sites and increase densities
  • Rushmoor should reconsider the scope for using surplus employment sites for housing and also releasing some surplus retail space.
  • Rushmoor should alter its housing target to better reflect its delivery trajectory so that it clarifies that the alleged unmet need comes after 2024, and then commit to a review of the plan to investigate the potential housing shortfall nearer the time.

Hart also suggests that much more dialogue is required between the councils and with the service providers to resolve infrastructure issues.

We Heart Hart broadly welcomes this feedback from Hart Council but believes they could have gone further by asking that the densities on Wellesley be reviewed and even more of the protected 96 Ha of employment land could be released for housing.  Even so, if Rushmoor takes on board Hart’s observations, then Rushmoor will not need to ask Hart to build 1,600 houses for them. This would probably mean a new town at Winchfield is not required.

 

Additional response to Rushmoor Local Plan

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

We have made an additional submission to the Rushmoor Borough Council Local Plan consultation pointing out the absurdity of seeking to protect 96 Ha of employment land when there’s going to be a surplus of 195 Ha of employment land across the Housing Market Area of Hart District, Surrey Heath and Rushmoor Boroughs at the end of the plan period.

This is available as a download for those wishing to add their voice to the consultation.

 

Additional Response to Rushmoor Local Plan

 

Our first submission and reasoning can be found here and here.

Link

HBF calls for Hart to meet Rushmoor’s unmet housing need

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

The Home Builders Federation (HBF) has responded to Rushmoor’s Local Plan consultation and called for Hart to concrete over its green fields to build all of Rushmoor’s unmet housing need.

Hart is the solution

To ensure that the Council is doing what it can to maximise the effectiveness of the duty to cooperate the Council must approach Hart Council to make sure that it provides land to meet the shortfall arising in Rushmoor. We note in paragraph 4.6 of Topic Paper 2: Housing Delivery that the Council asserts that the duty is not a duty to agree. This suggests a lack of zeal on the part of the Council to ensure that the unmet housing need of Rushmoor is addressed. Even if Hart and Surrey Heath are unable to provide land the three HMA authorities should engage with authorities elsewhere to persuade them to provide land to accommodate the shortfall.

It then goes on to make the silly suggestion that Hart to review its Green Belt, when in fact Hart doesn’t have any Green Belt land.

Reviewing the Green Belt in Hart

The Council must work with Hart to remove land from the Green Belt if this is what is necessary to accommodate the housing shortfall.

The HBF then call on Rushmoor to increase their housing allocation by an arbitrary 10% because the HBF believe more affordable housing should be built.

We consider that a 10% adjustment upwards should be made to the baseline demographic need.

They do not seem to consider the option of house-builders reducing their prices, nor do they mention that part of the reason house prices are so high is because interest rates have remained at 0.5% for around 6 years.

Amazingly, the HBF make no mention at all of brownfield land in their submission, despite Rushmoor seeking to protect 96 Ha of land even though there will be a surplus of around 195 Ha of employment land across the Housing Market Area at the end of the plan period.

It is simply unacceptable for an unelected industry body to seek to override the wishes of local people by asking Hart to concrete over green fields, whilst at the same time ignoring the vast opportunity presented by brownfield sites.

If you would like to make your own submission to then please download the pre-prepared feedback forms below, fill in your details and send them off to plan@rushmoor.gov.uk.  The consultation closes on 20 July 2015.

Rushmoor Local Plan Response Form
Additional Response to Rushmoor Local Plan

 

Government and CPRE call for more building on brownfield sites

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

In response to the Government’s Productivity Plan, announced today, the Campaign for the Protection of Rural England (CPRE) has called for the Government to implement a ‘brownfield first’ rule.

The Government will introduce a new zonal system which will effectively give automatic permission on suitable brownfield sites.  This was welcomed by the CPRE in their statement, but they asked the Government to go further saying:

“To achieve the development we want and need on brownfield land, the Government should implement a ‘brownfield first’ rule at the heart of planning to prioritise urban redevelopment and leave behind the unsustainable status quo – where developers cherry pick green fields for development. Communities must also be involved from the start to ensure good design, and it is desperately important that new developments include a significant amount of affordable housing.”

We Heart Hart wholeheartedly agrees with this approach, and would like to see the combined boroughs of Hart, Surrey Heath and Rushmoor implement these ideas by prioritising building on the 196 hectares of vacant employment land that will remain in the Housing Market Area at the end of the plan period.  In particular, Rushmoor is protecting 96 hectares of employment land, whilst at the same time asking Hart to build 1,600 houses on beautiful green fields.  We think this is madness and it forms one of our arguments opposing the Rushmoor Local Plan.  If you would like to put in your objection, please see our post here and please use the pre-prepared form on the link below.

 

Rushmoor Local Plan Response Form

 

There are certainly plenty of brownfield sites to be considered:

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

 

Why is it important for Hart residents to oppose the Rushmoor Local Plan?

 

Example of Urban Sprawl

Example of Urban Sprawl

We have received some feedback questioning why Hart District residents should contribute to Rushmoor Borough Council’s consultation on its Draft Local Plan.

The main reasons are:

  1. Help fend off the extra 1,600 houses Rushmoor wants Hart to build for them and avoid urban sprawl like that shown above.
  2. Challenge the Strategic Housing Market Assessment (SHMA) that has led to the combined Hart, Surrey Heath and Rushmoor housing requirement being set so high.  If we are successful in this, then Surrey Heath and Rushmoor don’t need to foist houses on Hart and the whole need for a new town at Winchfield or anywhere else goes away
  3. Push for more of the housing requirement to be built on the 196 hectares of surplus brownfield employment land.
  4. Point out the fundamental flaw of the combined £158m infrastructure funding deficit across Rushmoor and Hart (and £1.9bn funding deficit across Hampshire) that will mean we will get all of the houses but none of the infrastructure spending we need to build the healthcare facilities, expand rail capacity, fix broken roads and build the schools we need.

Please download the pre-prepared feedback forms, fill in your details and send off to plan@rushmoor.gov.uk.  The consultation closes on 20 July 2015.

 

Rushmoor Local Plan Response Form

 

Additional Response to Rushmoor Local Plan

link link

Rushmoor seeking to protect 96 hectares of brownfield sites but asking Hart to concrete over green fields

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Rushmoor have released more details about their Land Assessment (SHLAA) that reveal they are seeking to protect over 96 hectares of brownfield sites for employment use even though there is a massive glut of employment space across Hart, Rushmoor, Surrey Heath and surrounding districts.

Rushmoor Protected Employment Sites

Rushmoor Protected Employment Sites

If even half of this was used for housing at 100 dwelling per hectare, it would yield 4,800 houses for people in Rushmoor and would mean that Rushmoor could meet its own housing need and even take some of Hart and Surrey Heath’s allocation.

If you would like to ask Rushmoor to revise their Local Plan and make better use of the brownfield sites they have, then please follow the simple process below:

  1. Download the Local Plan response form from the link below.
  2. On page 3, fill in your name and contact details and type your name and date in the boxes at the bottom of the page.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to plan@rushmoor.gov.uk
  5. Share a link to this page to all your friends and family as well as any sports clubs or community groups you belong to via word of mouth, email, Facebook and Twitter and ask them to put in a response and share this page again.
  6. If you have not already done so, please sign and share our petition too

 

Rushmoor Local Plan Response Form

 

Massive surplus of brownfield employment land but Rushmoor wants Hart to concrete over green fields

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

The Employment Land Review (ELR) shows there is a massive surplus of around 600K sq m employment space occupying around 195 Ha of land across the combined area of Hart District, Surrey Heath and Rushmoor Boroughs. Yet, Rushmoor is seeking to protect 96 hectares of this land whilst at the same time trying to force Hart to build 1,600 houses for them on our beautiful green fields.

 Employment Space (sq m)
Overall Requirement to 2032 (a)266,368
Current vacant space (b)527,840
Sites with planning permission (c)338,187
Surplus in 2032 (b+c-a)599,659

If you would like to ask Rushmoor to revise its draft local plan, please download our pre-prepared response form and send it to plan@rushmoor.gov.uk.

 

Rushmoor Local Plan Response Form

 

The analysis to support the conclusion is shown below.  We posted earlier that the ELR is based on the same flawed jobs forecasts as the housing market assessment that predict a near doubling of the job creation rate we achieved in the period 1998-2012.  However, even if you accept these flawed forecasts and the unnecessary increase in housing it will lead to, the requirement for employment land in the combined economic area is 266K sq m using Rushmoor’s preferred Scenario 3.

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

However, as of December 2014, over 527K sq m of employment floorspace was lying vacant.

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Moreover, there is a glut of employment space all across neighbouring districts with very high levels of vacant office space (note that there are also high vacancy rates on industrial land):

Office vacancy rates in neighbouring districts

Office vacancy rates in neighbouring districts

In addition to the vacant units shown above, there is currently 388K sq m of floorspace on 110 Ha of land that currently has planning permission but is not yet being built:

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Drawing this together, there is a need for 266,000 sq m of space to meet the inflated employment forecasts, there’s currently 527,000 sq m lying vacant, with a further 338,000 sq m with planning permission, but not yet built.  This would leave a surplus of nearly 600,000 sq m of employment space that might occupy around 195 Ha of land, using the same ratio of employment space to land use as the existing planning permissions.

It is clearly ridiculous for all of this land to be protected when even if say 100 Ha is made available, at 100 dwellings per hectare there could be room for 10,000 dwellings, a very large proportion of the overall 24,413 houses that have been allocated to Hart, Surrey Heath and Rushmoor.