Community Campaign Hart takes aim at the Heart of Hart

Hart District Council takes aim at the Heart of Hart

Community Campaign Hart takes aim at the Heart of Hart

Community Campaign Hart (CCH) have published a new newsletter on their website that calls for a new settlement to destroy the Heart of Hart in Winchfield.

In their article they make criticism of We Heart Hart and the good residents of Winchfield, and come to the conclusion that the only viable option for delivering the housing we need is a new settlement of 3,000-5,000 houses in Winchfield.  In their article they make a number of assertions that we believe are false, and will now seek to correct them, point by point.  But first, it is important that we start with the areas where we agree with CCH.

Points of Agreement

CCH say:

Until Hart have an LDP which meets the approval of a Government-appointed inspector, developers are in effect able to build on almost any greenfield site they choose

We broadly agree with this, although as in the case of Hop Garden Road in Hook, sometimes common sense can prevail especially now that Hart has more than 5 years of land supply.  However, if CCH are so concerned about the lack of a Local Plan, they should work more closely with We Heart Hart and others to ensure that Hart Council takes proper steps to improve the management of the Local Plan project that has slipped its timescale by two years within two years.  They would do better to use their time at council meetings to ask questions about the local plan rather than seek to stifle difficult questions.

Points of Difference

1. CCH say:

There just isn’t enough brownfield land available to accommodate that number of new homes, unless we are going to build high-rise tenement blocks along the length of Fleet Road.

This is simply not true on a number of levels.  First, the council hasn’t even created a proper register of brownfield sites so it hasn’t properly assessed capacity.  Second, our own work has shown there’s capacity for between 2,438 and 3,688 units, compared to the remaining unsatisfied “need” of 2,900 given at the last cabinet.

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

Third, parts of Fleet Road are a disgrace to the district and should be redeveloped, not with tenements, but with mid-rise (say 3-4 storey) high quality apartments to help young people get on the housing ladder.  Finally, there is brownfield capacity all over the district including Ancell’s Farm, Bartley Wood, Pyestock, Bramshill and Guillemont Park.  They really should get out more and see all of the vacant offices around the district.

2. CCH say:

With a mainline railway station far closer to it than to any other new development in Fleet; with the option to integrate new roads onto the A30 and through to the M3; together with sufficient scale to fund three new primary schools and a new secondary school, Winchfield strikes many as being the best compromise

This is economic incompetence of the highest order.  The council’s own assessment of infrastructure needs points to costs of over £300m for a new town including the schools, but not including improvements to healthcare.  The ballpark estimate for developer contributions made by a senior Hart Councillor is around £40m.  There’s already a £78m infrastructure funding deficit in the district and £1.9bn across Hampshire.  Not only would a new town at Winchfield destroy green fields, it would destroy ancient hedgerows and put at risk SSSI’s and SINCs, but it would no doubt further increase congestion in Fleet and Church Crookham.

3, CCH say:

Consequently they have resorted to social media and other marketing techniques to promote the ‘wehearthart’ message.

However, their messaging is incomplete. They point to the council wishing to build a new town at Winchfield and seek to demonize anyone who may have reached the conclusion, however reluctantly, that a new town at Winchfield is the least worst solution out of an abhorrent set of options. They do not explain what the alternatives are, as the National Planning Policy Framework (NPPF) mandates that this level of housing must go somewhere within Hart’s borders

We do not see what is wrong with communicating with the public using social media on the serious issue of the Local Plan, particularly when the council gets its own facts wrong.  However, We Heart Hart has explained what the alternatives are at some length, and the CCH Chairman of the council sought to have questions that we raised to indicate a different path censored at council meetings.  The alternatives are:

a) Reduce the alleged housing need by challenging the SHMA, particularly taking into account the latest DCLG population forecasts that indicate a lower population in 2031 than assumed in the SHMA and the reducing ridiculous jobs forecasts.  CCH would do well to engage with this debate instead of seeking to censor it.

b) Explore the options for reducing the assessed housing need by exploring so called “policy on” options to protect the environment and ecology.  Note that Winchfield is beautiful countryside in its own right, but is also within the 5km zone of influence of the Thames Valley Heath SPA.

c) Properly get to grips with brownfield options by establishing a brownfield register, actively encouraging landlords to redevelop their derelict sites and exploring the use of Compulsory Purchase Orders on sites that have sat vacant for years with no apparent signs of progress (e.g. Hartland Park aka Pyestock).

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

CCH need to wake up, smell the coffee, listen to Ranil Jaywardena and use their talents to establish a different vision to protect the countryside they profess to love rather than coming out with incomplete, inaccurate nonsense.  Be careful who you vote for in next year’s local elections.

This story now covered in the local press, see here.

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?

Housing allocation for Hart, Rushmoor and Surrey Heath should reduce by 6,560 according to new DCLG figures

Department for Communities and Local Government (DCLG)

Department for Communities and Local Government (DCLG)

The housing allocation for the combined Housing Market Area (HMA) of Hart, Rushmoor and Surrey Heath should be reduced by by 27.7% or 6,560 houses, taking away the risk that Rushmoor and Surrey Heath will ask Hart to build 3,000 houses for them and ensuring Hart’s own requirement can be built on brownfield sites only according to new population projections that have been released by the DCLG.

Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

Figure 1: Hart Rushmoor and Surrey Heath SHMA Appendix F

The SHMA worked by taking as a starting point earlier Government figures that showed the combined population of the HMA would be 307K (PROJ 2 circled in Figure 1 above) and this was inflated by increasing the assumptions on inward migration, average household size and jobs growth to arrive at a final figure of 322K (PROJ 5 circled in Figure 1 above).

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 1

Figure 2: Hart Rushmoor and Surrey Heath SHMA Appendix G

Interestingly, revised population forecasts were published by the Government as the SHMA was being finalised that showed that the start point population forecast should be reduced to 295K (circled in Figure 2 above), but amazingly these changes were not used to reduce the assessed housing need.  If they had been used, the total amount of housing that would be required for the HMA would have reduced by 208 per annum (see Figure 3 below), or a total of 4,160 dwellings out of a total objectively assessed housing need (OAHN) of 23,600.

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 2

Figure 3: Hart Rushmoor and Surrey Heath SHMA Appendix G

Now the latest DCLG figures (Table 426) have reduced the population forecast for 2031 for the whole HMA down to only 289K, a reduction of 6,000 people, which equates to a reduction of a further ~2,400 houses (@2.5 people per property).

Taken together these reductions in population forecasts would reduce the whole housing need for the HMA by 6,560 houses of the 23,600 or a reduction of a stunning 27.7%.

We wonder when Hart Council, Rushmoor and Surrey Heath councils will take these new figures into account in the Local Plan.

 

Hart household projections fall according to new figures from DCLG

Cows in Winchfield, Hart District, Hampshire

Do we want to lose our cows to concrete?

In a piece of good news, revised population projections published by the Department of Communities and Local Government (DCLG) show that Hart will have fewer households in 2031 than were assumed in the Strategic Housing Market Assessment (SHMA).  This should have the effect of reducing the housing requirement being imposed on Hart District as part of the Local Plan.  This might reduce the remaining 2,900 houses left to grant permission for and make it more likely we can meet all of the remaining need from brownfield sites.

 

Local Authority2011 householdsSHMA start point for 2031 using 2011-based population projectionNew projection for 2031 using 2012-based population projectionChange between 2011-based and 2012-based projectionsSHMA end-point for 2031
Hart357574222040618-160243291
Rushmoor365594083042362153246381
Surrey Heath33632381703832115140689
Total10594812122012130181130361

 

However in other news, the same new figures for Rushmoor and Surrey Heath show higher projections for households up to 2031 than were assumed in the SHMA.  This might increase the housing requirement for Surrey Heath and Rushmoor and they may ask that Hart builds those houses for them.

What is clear is that the SHMA then makes several dubious adjustments to the baseline DCLG projections that add a further 9,000 or so houses to the total for the housing market area that need to be challenged.

The DCLG figures can be found here and here.  The SHMA can be found here.

If SHMA adjustments were applied nationally we would be building too many houses

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 1: 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 1 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 2: 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 2 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.

Latest jobs growth figures well short of SHMA estimates

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

The Government have released the revised BRES job numbers for 2013 and these show that the jobs growth rate we have achieved since the recession ended in 2009 is still much lower than the jobs growth rate assumed in the SHMA for the period 2011-2031, during which period it is inevitable we will experience at least one more recession.  This comes at a time when the UK is creating more jobs than the rest of the EU put together, so can hardly be described as a normal set of circumstances.

The flawed jobs growth rate in the SHMA adds 5,100 extra houses to to the overall housing allocation to the combined Housing Market Area of Hart, Surrey Heath and Rushmoor.  The impact of this is that it pushes up Hart’s own allocation and forces Surrey Heath and Rushmoor to ask Hart to become a sink for 3,000 extra houses for them. Furthermore, these jobs forecasts lead to over-estimates of the amount of employment land we need and so constrains the amount of land that might be made available for housing.

Hart becomes Housing Sink for Surrey Heath and Rushmor

Hart becomes sink for 3,100 houses from Surrey Heath and Rushmoor

If these errors in the SHMA growth rate were corrected the threat from Surrey Heath and Rushmoor would evaporate and Hart’s own housing allocation for the Local Plan would come down from 7,534 to around 6,750, which would definitely mean the remaining requirement could be made from brownfield sites alone.

How long before the penny drops with Hart District Council and the other Hampshire boroughs that they need to revise the SHMA to a more realistic number?

Hart Council rejects opinion of 2,130 people who signed the We Heart Hart petition

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

Hart in the Heart of Hart, Winchfield, Hampshire

We went to the Cabinet meeting last night armed with a draft of Hart Council’s response to the petition and unfortunately, the council rejected the three main elements of petition to reduce the overall housing allocation for Hart and our demand that the remaining housing allocation is met from brownfield sites alone.  The council also refused to stop planning to build a new town that would act as a sink for 3,100 houses from Rushmoor and Surrey Heath.

It is outrageous that Hart Council should dismiss the opinion of 2,130 people.  Hart’s own consultation only received 750 replies and only 202 of those expressed a preference for a new town. Given the earlier failure of the Local Plan at inspection, it is simply astonishing that Hart should be basing their planning policy on a “guesstimate” of brownfield capacity. It is unbelievable that they refuse to set up a proper register of brownfield sites and can’t be bothered to track which brownfield sites have been granted planning permission.

We have produced a press release about this that can be downloaded from the link below:

 

We Heart Hart Press Release 2 October 2015

 

Hart becomes Housing Sink for Surrey Heath and Rushmor

Hart becomes sink for 3,100 houses from Surrey Heath and Rushmoor

On a more positive note, the council did say they would consider the vision we put forwards and will include a new vision in the forthcoming consultation.  The council did also say they would try to accommodate the needs of the elderly, but implied they could only do so if they built a new town at Winchfield. It is clear the council has no means of measuring its performance against the SHMA requirement to build 2,500 specialist units for the elderly.

The debate at council raised a number of interesting points, but Cabinet did not resolve to alter anything in the draft response they had put forward and clearly had not fully considered our suggested response to the petition.  In effect, the council are ignoring the views of 2,130 people on several of the key issues raised by the petition.  We will have to mobilise our supporters to put forward their views in the forthcoming consultation.

The detail of the discussion covered a number of topics:

Challenging the SHMA.  The council did concede that they would need to re-visit the SHMA in due course and update the employment forecasts.  We did point out that the jobs forecasts assume a growth rate nearly double that we achieved in the period 1998-2012, and that Cambridge employment forecasts for the South East used in a challenge to the Vale of White Horse Local Plan are similar to historic average growth rates we beleive should be used in the SHMA.

The council refused to undertake a study to quantify the value of Hart’s environment and ecology.  This is a blow as it could enable the council to use environmental constraints as an argument for not building the full housing allocation.

Brownfield sites.  Despite putting evidence in front of council that there is brownfield capacity for at least 2,438 dwellings and possibly over 3,600 units, Hart is still sticking by its current “guesstimate” of only 1,800 units on brownfield sites.  It is quite astonishing that Hart is basing its planning policy on a “guesstimate”. Last week Hart Council did admit that there was a residual requirement of only 2,900 houses.  It is clear to us, that meeting the the remaining need from brownfield only is well within reach.

Some councillors were concerned about our proposed densities in urban areas until we pointed out that they have already approved and are delivering developments at even higher densities.  Other concerns raised were about using up too much employment land until we pointed out that there’s over 500,000 sq m of vacant employment land across the housing market area, and we are in no danger of running out any time soon.

Overall I am afraid I got the impression that they listened, but they had already made their mind up that a new town was the answer to the Local Plan no matter what contrary evidence was put to them.

We must gird our loins for a long campaign to fight against these proposals.

 

 

Housing targets fantasy worthy of Lewis Carroll

Sometimes I've believed as many as six impossible things before breakfast

Sometimes I’ve believed as many as six impossible things before breakfast

This week marks the start of the examination of the Vale of the White Horse District Council Local Plan, as reported in the Oxford Mail, and the housing targets have been branded “worthy of Lewis Carroll”.  It seems Hart District residents are also being asked to believe six impossible things before breakfast.

One of the key issues at White Horse is the credibility of the housing target because it is derived from some very questionable jobs forecasts.  Here is a quote from their article:

“The logic is very simple. The number of jobs which theoretically could be created between now and 2031 was calculated. They then used these figures to estimate how many houses would be needed if these jobs materialised. The problem is that if the jobs projection is fantasy, as many people think it is, then the “objectively assessed” housing number is also fantasy.

A company called GL Hearn was then commissioned by our district councils to estimate housing need, assuming that all of these forecast jobs will actually exist. This is the Oxfordshire Strategic Housing Market Assessment, or SHMA.

There are many who believe that this is a story worthy of Lewis Carroll himself.”

Comparison of Jobs Growth Rates for Housing Market Area

Comparison of Jobs Growth Rates for Housing Market Area

Of course this is a very similar situation to that in which we find our selves in Hart, Rushmoor and Surrey Heath, where the jobs forecasts in the SHMA assume a growth in jobs almost twice that we achieved in the period 1998-2012 and will lead to a massive increase in the proportion of working age people in employment.

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%

The impact of this is that across the whole Housing Market Area, we are forced to build 5,100 extra houses and of course protect even more vacant employment land that could be allocated to housing.

It seems we are being asked to believe in six impossible things before breakfast, just like the Vale of White Horse.  It remains to be seen how the inspector will view the White Horse Housing Market Assessment.

 

We Heart Hart to present to Odiham Parish Council

Odiham High Street, Hart District Hampshire

Odiham High Street, Hampshire

We Heart Hart has been asked to present to Odiham Parish Council about the Rushmoor and Hart Local Plans on Monday 7 September at 7:30pm at The Bury, Odiham. RG29 1NB. The presentation we will give is available for download below:

We Heart Hart presentation to Odiham Parish Council

link

Petition response: Reduce the housing allocation

Discontinuity between ABI and BRES jobs data for Housing Market Area

Discontinuity between ABI and BRES jobs data for Housing Market Area

As we posted earlier, we have submitted the We  Hart petition with 2,130 responses 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.  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 and please e-mail your councillors to ask them to support these proposals and incorporate them into the forthcoming consultation about the Local Plan.

The full set of suggestions can be found here.

The first suggestions relate to challenging the overall housing numbers Hart have to build.

First, challenge the SHMA to reduce the overall housing allocation for the whole HMA.  There is a strong risk that Hart will be asked to build the highest number of houses in the Housing Market Area if we don’t challenge the numbers.

 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 this is successful, then it will have a two-fold effect of reducing Hart’s own need and also reduce the risk of overflow from Surrey Heath and Rushmoor.  We 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.

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%

We 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, we do recognise it is difficult for the council to challenge its own document and await Rushmoor’s response to my strong challenge, but we 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, we 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 we 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?  We 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.