Fleet Regeneration – Yes we can!

Candidate for Fleet Regeneration: Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Council protecting from redevelopment.

We must deliver Fleet Regeneration

A guest post from Tristram Cary, chairman of the Rural Hart Association, setting out why we must and how we can deliver Fleet Regeneration.

Fleet Regeneration Report

40% of the population of Hart live in Fleet, and yet, in the Local Plan, Fleet is only taking only 21% of the housing development. This massive imbalance puts a huge strain on Hart’s countryside. It is extraordinary that Hart is preventing the regeneration of Fleet when you consider that:

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

  1. Fleet is the most sparsely populated town of its size in Britain (see above)
  2. Hart admits in para 236 of the Local Plan that, without regeneration, “it is unrealistic for Fleet to try to compete” for comparison shopping with neighbouring towns such as Camberley (which is the same size as Fleet)
  3. The new National Planning Policy Framework (para 86) requires districts to “take a positive approach to the development of Town Centres” and to “recognise that residential development often plays an important role in ensuring the vitality of Town Centres”

Hart’s extraordinary lack of ambition for Fleet is explained by Councillor Cockarill’s statement at the 4 January Council Meeting that any serious Fleet regeneration was “a pipedream”. Hart claims that Fleet is full, and that it would not be possible to raise any serious money for its regeneration.

The Rural Hart Association (RHA) commissioned a study from Lambert Smith Hampton (LSH), a leading Town Centre regeneration specialist, to analyse the potential for Fleet regeneration. This study was submitted to Hart in response to the Reg 19 Consultation, and the full document is available on the link above. The key findings of the study are that:

  1. Fleet has ample opportunities for re-generation if only Hart would consider mixed-use (residential and retail) developments
  2. It is hopeless for Fleet to resist the residential conversion of redundant office blocks – there is no realistic prospect of these ever being revived for business use.

It’s worth reading the following summaries provided by directors of LSH.

“As has been widely reported the growth of online retail sales is having a major impact on the retail landscape – online sales are currently circa 16% of all UK sales and growing annually. There is a fundamental structural change in our shopping habits which in turn is having a major impact on retailers and town centres. The retail centres that are thriving tend to be those regional locations offering a high quality experiential mix of retail and leisure or the smaller centres that are able to provide easily accessed, convenience retail facilities in an aesthetically pleasing environment.

Interestingly, we have started to witness retail assets (shopping centres and retail parks) particularly in the South East being acquired or redeveloped for their residential potential.  In some instances, we are seeing retail being proposed above shopping centres and in other instances the complete redevelopment for residential – examples include Forbury Park in Reading which has consent for 765 homes and Whitley’s Shopping Centre in Bayswater which is to be redeveloped for a mixed retail and residential scheme. This trend is likely to continue especially in areas where residential values are high and the retail assets are stagnating.

The Hart Shopping Centre could offer such potential in the future – retaining strong convenience retail facilities at ground floor level with retailers such as Waitrose but with residential accommodation on the upper parts.

What is clear, is that on a national basis we have too many shops and alternative uses, in particular residential, is a desirable way of regenerating our town centres”.

Sean Prigmore, Retail Director, Lambert Smith Hampton

And,

“I have been actively involved in the Fleet office market for more than 30 years.

The office market in Fleet has been in decline for a number of years as larger corporates have vacated to consolidate occupation in larger centers and locations benefitting from more amenity – such as Farnborough Business Park. Key Business centres such as Reading and Basingstoke have prospered whilst the smaller satellite office location such as Fleet are finding it harder to prove their relevance as office locations. M3 HQ, 70,000 sq ft on ABP, has been vacant for many years and is unlikely to be occupied as offices again. There is the potential to enable redevelopment of larger unwanted office stock for residential and to focus B1 provision in locations better served by public transport and amenity and in buildings which will allow business space for the SME sector where what demand there is lies.”

Paul Dowson , Director, Lambert Smith Hampton

Fleet Regeneration Sites

Fleet Regeneration Sites

The Lambert Smith Hampton report identifies eight sites in Fleet Town centre which between them could provide 990 homes in mixed-use developments, and LSH is confident that these sites would attract developer investment. [Personally, I would add the entire civic quarter – ed]. It is shocking that Hart has turned its back on mixed use developments in Fleet without even investigating their potential. We hope that Hart Council will restructure its Local Plan to take account of the LSH report before submitting it for Inspection.

[Note that this is exactly in line with Ranil’s call for regeneration of our urban centres – ed]

Stop Elvetham Chase go Completely Concrete

Stop Elvetham Chase go full completely concrete Hart

Hypocritical Stop Elvetham Chase go Completely Concrete

The Stop Elvetham Chase group have decided to put up a candidate in the Local Elections standing for Community Campaign Completely Concrete Hart.

This smacks to us of hypocrisy as they are rightly vehemently opposed to the Elvetham Chase (Pale Lane) development. However, they now strongly support a new town in Winchfield, part of which is very close to the area where they oppose development. This is shown in the graphic above.

Their candidate, Angela Delaney is fighting the Fleet West ward. Richard Woods, who defected from the Tories in late 2016, currently holds this seat. It appears that Richard is standing down because he isn’t mentioned as a candidate on CCH’s website.

Stop Elvetham Chase’s statement has been placed on their Facebook page. Interestingly, comments have been disabled, so it is clear they are only interested in one-way communication. Not a good start for a budding politician. It is reproduced below with our comments in red.

This group was set up to fight the Elvetham Chase development. Hart council’s strong endorsement of the local plan on the 4th January and subsequent refusal of Wates’ proposal has, for now, protected Pale Lane. We thank all the members of this group for supporting the campaign and objecting so strongly to the development. Stop Elvetham Chase did start with laudable intentions.

However this is only a stay of execution. We know Wates have every intention of appealing the decision. The local plan, in its current state, with the new settlement option, gives Hart Council a strong chance of successfully refusing the appeal.  This is because approval of Pale Lane would jeopardise the new settlement – which would ultimately deliver more affordable housing for Hart. The presence or otherwise of the new town in the draft Local Plan will have no bearing on the Pale Lane Appeal. This is because even the council have said the new town is unnecessary, without Pale Lane. The Conservatives will tell you that we don’t need the higher housing targets – they support a local plan with the new settlement removed. We believe this is naive in the extreme, given the housing crisis this country is facing. It’s not just the Conservatives that say this. It was in the Council’s own communication to members (see below) and stated at the January 4th meeting by Councillor Cockarill. The housing numbers in the Local Plan will deliver ~1,500 more houses than the Government mandated figure. The Government figure already includes an affordability uplift.

Pale Lane aside, we believe it is absolutely right to plan for a new settlement that will deliver the infrastructure that Hart desperately needs. CCH were asked at council before Christmas to show their workings on the infrastructure funding gap. They didn’t even allow the question to be asked, let alone answer it. The reason is that they know, the new settlement will increase the funding gap and starve Fleet and Church Crookham of much needed investmentWithout a new settlement we will soon return to a ‘planning by appeal’ situation which has been so disastrous for Hart (ref: Grove Farm and Watery Lane). A sound Local Plan, without a new town and without Pale Lane, will stop this situation. With no long term plan for secondary school places (to meet demand from the 2000 houses at Hartland and Grove Farm), surgery waiting times lengthening and our roads more congested than ever we think this is unacceptable for Hart.  Hampshire County Council have not said we need a new school. The Local Plan contains no proposals for a new school, doesn’t address healthcare and does nothing for roads. A new town will only make things worse. A local plan with the new settlement option removed will also pave the way for Wates to successfully appeal Pale Lane. No it won’t. The Local Plan will be sound without the new town. Indeed, it may even be unsound with the new town.

So, after much consideration we have decided to support Community Campaign Hart (CCH), who we can trust to safeguard the local plan (which is already progressing well and is due for submission to a Govt inspector this month) and by extension, Pale Lane. CCH are committed to taking the politics out of local matters, focusing on putting residents’ needs first. Cough…only if you live in Church Crookham, and even then, the extra traffic from a new town will impact both Fleet and Church Crookham.

We are absolutely delighted to announce that Angela Delaney, one of our group and one of the original four who spearheaded the Stop Elvetham Chase Development campaign, is standing as CCH candidate for Fleet West. Angela has worked tirelessly over the last year to fight Pale Lane and protect Fleet West from the impact this development would have caused. But apparently she doesn’t care at all about the impact that a new town at Winchfield would cause. She’s passionate about supporting a local plan with a new settlement to protect our schools, health service and roads. In fact the Local Plan doesn’t promote a new school, doesn’t address healthcare and won’t fix the roads. In fact it will make matters worse for Fleet, because it will starve it of infrastructure, increase commuter traffic and probably reduce retail traffic. We hope her track record speaks for itself. Cough…not quite in the way she wants us to believe, but let’s wish that she is more successful than CCH have been with Edenbrook, Grove Farm and Watery Lane.

We hope you’ll support Angela but ultimately everyone must make their own decision at the ballot box. Well done for standing for election, which is more than Councillor Woods did when he defected. If you don’t support our position then we thank you for your support so far and understand if you wish to leave our group at this point. I will stay if you don’t mind, just to see what you are up to. You have lost a lot of support from Winchfield residents who also oppose Pale Lane. If you support Angela, we can guarantee that she will work with the same energy she fought Pale Lane, to represent local residents’ interests. Cough.

Why a new settlement debunked predetermination

Hart Housing Numbers

 

Hart Local Plan: Restore strategic gaps

Hart Regulation 18 Strategic gaps

Hart Local Plan Regulation 19 consultation removes the Regulation 18 Strategic Gaps

This is the sixth and final part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart have removed the strategic gaps around Harley Wintney and Hook that were present in the last consultation. We believe they should restore them and policy NBe2 should be amended.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE.
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.

Restore the strategic gaps to the Hart Local Plan Regulation 19 Consultation

The Local Plan identifies strategic gaps between settlements.

Hart Local Plan Regulation 19: Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

Hart Local Plan Regulation 19 Consultation Strategic Gaps

However, no gaps are proposed to the east of Hook, to the north west of Fleet or anywhere around Hartley Wintney. This is contrary to the Regulation 18 consultation (see top), where strategic gaps were included to the east of Hook and the SW of Hartley Wintney. These should be restored and new ones added to give effective gaps between Winchfield and the west of Fleet/Elvetham Heath to avoid coalescence into a Hartley Winchook urban sprawl.

Remedy: This policy needs to be amended to include:

  1. A gap to the west of Hook from the east bank of the River Whitewater to at least the power line between Hook and Hartley Wintney
  2. A gap to the south and west of Hartley Wintney/Phoenix Green. This should be at both sides of the A30, from the existing end of development to the Murrell Green light-industrial estate and from St Mary’s Park to the motorway
  3. A gap from Elvetham Heath/A323 to the River Hart and from Edenbrook/Hitches Lane to the River Hart
  4. A gap from the east of Taplins Farm Lane/The Hurst to the River Hart.

 

Hart Local Plan: No plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

This is the fifth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart haven’t properly planned for infrastructure. In addition, the plans they do have will starve the places that really need it of investment. Policy I1 needs to be changed and policy SS3 needs to be removed. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan Regulation 19 consultation needs to be changed to deal with infrastructure

One leading councillor has gone on the record, calling for an ‘infrastructure led’ Local Plan. Yet, they have not allowed questions to be put to them about infrastructure, let alone answer them.

Back in October 2014, Hart Council produced an infrastructure delivery schedule that set out the current deficit, split by type and area.  This shows a deficit of £78m not including healthcare facilities. The breakdown is shown by type and area in the images below:

Hart Local Plan Regulation 19 consultation: Hart District Estimated Infrastructure costs by type March 2013.

Hart District Estimated Infrastructure costs by type March 2013.

The breakdown of the costs by area showed the Fleet/Church Crookham and Hook areas had by far the largest deficits.

Hart Local Plan Regulation 19 consultation: Estimated Infrastructure costs by area March 2013

Hart District Estimated Infrastructure costs by area March 2013

Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It should be noted also that SWR has recently put forward proposals to reduce services at Winchfield and Hook, exacerbating the rail capacity problem. The Local Plan doesn’t even mention improvements to the rail network in infrastructure policies.

A more recent estimate from Hampshire County Council has estimated the infrastructure funding gap for Hart as £72m.

Hart Local Plan Regulation 19 consultation: Hart infrastructure funding gap £72m

Hart infrastructure funding gap £72m

Hart’s share of the gap is made up of:

  • Transport, £34m
  • Education: £38m.
  • Countryside: To be Determined.
  • Extra Care places: To be Determined.

No estimate has been made of the requirements or costs of additional healthcare provision.

The infrastructure policies in the Local Plan are insipid and fail to address the funding gap:

  • Policy I1: Infrastructure – weak policy simply requiring developers to deliver adequate infrastructure as part of their developments, when the studies above show that developer contributions won’t be adequate to bridge the gap
  • Policy I2: Green Infrastructure – feeble policy to supposedly protect green infrastructure. Yet they are proposing to build a new town that will destroy the best of our green infrastructure
  • Policy I3: Transport – inadequate policy simply to provide ‘maximum flexibility in the choice of travel modes’, nothing specific to improve road network or put pressure on SWR to improve rail
  • Policy I4: Open space, sport and recreation – policy to support development that improves sporting facilities, but no tangible plans for anything new
  • Policy I5: Community Facilities – a very vague policy to improve childcare facilities, healthcare, police stations, youth provision, libraries, community halls, local shops, meeting places, cultural buildings, public houses, places of worship, and public toilets. But crucially, no specific projects or proposals.

Yet, the National Planning Policy Framework (NPPF) is clear that infrastructure must be planned alongside new housing. Failure to adequately plan for infrastructure requirements and costs could lead to the Local Plan being found unsound. See references to paras 17 and 177 of the NPPF below.

plan to avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

It is clear from this post, that the proposals to build a new town will probably exacerbate the existing funding gap and not deliver any infrastructure in Fleet, Church Crookham and Hook, the very places where funding is most required.

Remedy: We therefore think the remedy to this issue should be that policy SS3 is removed in its entirety (with consequent changes to policy SS1 already outlined elsewhere). The infrastructure policies should be reworked to include as a minimum:

  • Acknowledgement of the existing £72m infrastructure funding gap
  • Quantification of the items missing from the Hampshire County Council assessment such as healthcare, extra-care housing for the elderly and green infrastructure
  • A set of prioritised, costed projects that are required to alleviate the worst of our infrastructure problems in Fleet/Church Crookham and Hook. This should include road improvements, particularly near Fleet station and the bridge over the railway near the end of Elvetham Heath Road. It should also include significant improvements to the cultural facilities, particularly in Fleet.
  • Plans to tackle Network Rail/SWR over rail capacity and services
  • Proposals for raising the necessary funds for delivering the required projects
  • Some external validation that the infrastructure plans in the draft Local Plan are ‘sound’ and will pass inspection

We believe that in preparation for the next review of the plan, a new policy should be created to regenerate our urban centres including attracting private capital so that we create a better place to live and address the existing infrastructure problems before even considering a new town that will only make matters worse.

Hart Local Plan: Missed opportunity to regenerate urban centres

Hart Local Plan Regulation 19 consultation won't regenerate Old Police Station in Fleet, Hart District, Hampshire

Hart Local Plan Regulation 19 consultation: Missed opportunity to regenerate urban centres

This is the fourth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how we are missing the opportunity to regenerate our urban centres and why Policies Policies ED4, 5 and 6 (and SS3) need to be removed for the time being until we come up with a proper regeneration strategy. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here.
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE.
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

Hart Local Plan Regulation 19 Consultation: MIssed regeneration opportunity

Fleet is the lowest density town of its size in the country. The chart below shows that there is significant scope for increasing development density in Fleet.
Hart Local Plan Regulation 19 consultation: Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

The retail offer in Fleet is poor, the cultural facilities (e.g. Harlington Centre) are outdated and there is no proper cinema. We might as well employ botanists to identify the new species of tumbleweed appearing in the Hart Shopping Centre.

Hart Local Plan Regulation 19 consultation: Fleet Health score versus benchmarks

Fleet Health score versus benchmarks

However, Fleet has the highest average earnings per person of comparative towns by quite a large margin (e.g.: 9% more than Camberley). High earnings should give Fleet a significant advantage over the comparison towns.

Hart Local Plan Regulation 19 consultation: Fleet earnings versus competitors

Fleet earnings versus competitors

The Local Plan fails to take advantage of the opportunity to modernise Hart’s urban centres and protect Hart’s countryside.

We believe that the Local Plan should be centred on the proposition that Fleet and other urban centres will be re-generated. With Hart District Council’s full and active support, a plan based on urban regeneration would achieve the following benefits:

  1. An ambitious Hart Urban Re-generation Project (HURP) would attract private investment and thus be affordable
  2. Private investment would allow for Hart’s infrastructure to be upgraded in line with the urban re-generation
  3. Good urban design principles would achieve a higher population density in the urban centres while at the same time providing an improved ‘sense of place’ and making the urban centres more desirable places to live.

A similar approach could be adopted in Yateley to provide a proper retail-led centre and improvements could be made to Blackwater. The requirement for additional retail facilities in Hook, identified in the Reg 18 Local Plan could also be met.

Hart did have a plan to conduct a brownfield study (We Heart Hart helped to write the terms of reference) to evaluate the ‘art of the possible’ in our urban centres. This project has not delivered.

In addition, Yateley lacks a defined centre, Blackwater is indistinct and Hook lacks good quality restaurants and shopping facilities.

The council should be setting out a bold plan to improve the retail, cultural and recreational amenities in the district. We should also develop plans for a theatre and cinema in Fleet as part of an attractive mixed-use redevelopment. There will be significant cash available from developers to fund such an ambitious plan.

Instead of creating a proper masterplan,  Fleet Town Council are pursuing an ill-thought out plan for a new theatre that will leave the existing Harlington Centre to rot. This is not regeneration in any meaningful sense of the word.

Our local MP, Ranil Jaywardena, has launched a campaign to regenerate our urban centres. He said:

Looking to some of our local, district and town centres, however, it is clear to see that Fleet, Yateley and Hook are all in real need of revitalisation and regeneration. I’ve been spending time speaking to your local Councillors about this and taking a look at the work that needs to be done.

I am more convinced than ever that all three places have great potential – be that simply as shopping destinations or, with the right infrastructure improvements, as great places for our young people to get their foot on the housing ladder.

The trouble is that there is no ‘masterplan’ for any of these places. I will be raising this with Hart District Council personally – but I need your help. If you want smart new shops, some new flats for local young people to buy above them and better car parking, then act now.

The BBC has recently interviewed a number of people in Fleet about what it is like to live there. Everybody loves it, but they think there’s been too much housing and not enough infrastructure. The draft Local Plan won’t fix either of those issues, because they’re insisting on building too many houses and aren’t addressing infrastructure.

However, policies ED4, 5 and 6 effectively cast the existing centres in aspic and preclude significant redevelopment. I do not have the resources available to me to completely re-write these policies.

Remedy:  Policies ED4, 5 and 6 should be removed for the time being and a proper community team put together to work with our local councillors and MP to come up with a master plan to regenerate our town centres. Policy SS3 (together with the consequent changes to SS1 already outlined) should also be removed, so that time and energy can be freed up to address the fundamental problem of our urban centres.

Hart Local Plan: Remove brownfield restrictions

Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Local Plan protecting from redevelopment.

Hart Local Plan restricting redevelopment of sites like this

This is the third part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains how Hart’s policies are restricting brownfield redevelopment and why they must remove policy ED2, change their SANG policy and remove their Article 4 direction on Permitted Development Rights.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan restricts brownfield development

Policy ED2 relates to safeguarding employment land and Para 297 refers to SANG owned by the council.

Policy ED2 protects essentially every major employment site in the district from redevelopment.

The reason this is a bad policy is that the prior version of the Local Plan itself, as well as the Employment Land Review (ELR), acknowledges that there is an over-supply of low grade office space (para 125). The ELR states that investment in this stock is unviable (para 6.17):

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Owners of these sites have three choices. First they can keep the wasting asset and collect no rent, which is not an attractive commercial proposition. Second, they can convert the offices into flats. By and large, they need no planning permission for this. However, these types of development carry no obligation for S106 or CIL payments to councils. Nor do they deliver a good ‘sense of place’. Finally, they could apply for planning permission to properly redevelop these sites into attractive homes, with a particular focus on affordable homes for the young. These types of development will be high-density, but with a good sense of place, and will attract some funding for infrastructure.

The consequences of this policy will be to discourage redevelopment of sites and either lead to more sites being simply converted or worse, sitting idle as eyesores.

We believe this is contrary to Government policy.

Remedy: Consequently policy ED2 should be removed.

Moreover, the Inspector should be aware that the council has implemented a new policy regarding SANG that effectively further obstructs brownfield development. This is already blocking schemes that would provide homes that ordinary people can afford (as distinct from Affordable Homes that ordinary people can’t afford). The schemes affected are a conversion on Ancells Farm and proposals to redevelop the old police station in Fleet town centre. It has been suggested that this SANG policy may be unlawful.

In addition, Hart has commenced work to implement an Article 4 direction to block permitted development on brownfield sites.

In effect they have set some nice sounding objectives about protecting our historic assets and building green infrastructure, but their policies act against their objectives and actively create a worse place to live by leaving decrepit buildings to rot and scar the landscape.

We think the Inspector should also take a view on these policies since they are closely related to the Local Plan, even though they are not contained within it.

Remedy: We believe that the SANG policy and the Article 4 direction should be removed

Hart Local Plan: Amend Policy SS1 to a sensible housing target

 

This is the second part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains why we are planning to build too many houses and why Policy SS1 needs to be amended to a more sensible target. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry
Policy SS1 deals with the spatial strategy. We disagree with the quantum of new housing proposed in the draft Local Plan.

First, the numbers proposed are far too high and they are unsustainable. Second, the long term effect of planning for too many houses is that the initial effects are compounded, leading to permanent unsustainability.

Proposed numbers in the Hart Local Plan are far too high and unsustainable

They propose 6,208 now homes over the plan period at a rate of 388dpa. This is both unnecessary and undesirable on a number of grounds:

The 2016 SHMA called for 8,022 new dwellings over the period 2011-2032. This was already too many.  For reasons explained in more detail here:

  • The starting point was inappropriate, using 2012 DCLG forecasts instead of the 2014-based figures.
  • The affordable housing uplift was inappropriate because it was proposing to help those already renting but not able to buy. By definition, these people are already housed and therefore do not need an additional house to be built. Any arguments about building more houses increasing supply and thus reducing prices are spurious because any reasonable expectation of building will have only a negligible impact on prices. This is explained by Ian Mulheirn of Oxford Economics here.
  • The jobs growth adjustment was inappropriate, anticipating higher rates of jobs growth than seen in periods of much higher economic growth. The SHMA then acknowledged that most of the extra people brought in by these extra houses will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.

Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Clearly, this uplift was not an expression of the ‘need’ for the district. More importantly, building extra, unnecessary houses will then cause more people to move into the district. Because the employment space is sub-standard and not in a strategic location, these people will commute elsewhere each day to work. This is the very antithesis of sustainable development.

I think these arguments make clear that the target of 8,022 houses over the old plan period of 2011-2032 was unsound and unsustainable. This is further borne out by the analysis of Alan Wenban-Smith.

The current draft Local Plan calls for 6,208 houses to be built over the period 2016-2032. Hart built 1,830 houses over the period 2011-2016. This makes the total target over the comparable period 8,038 houses. This is more than the prior target in the SHMA despite the new Government method for calculating housing need showing a much slower rate of building being required. This is also unsustainable for the same reasons as above.

Hart housing completions for the Hart Local Plan Regulation 19 Consultation

Basically, the council have found a way of arbitrarily adding back unnecessary houses without even the fig leaf of the flawed justifications used in the prior SHMA.

Their current proposal is for 6,208 houses or 388 dpa over the period 2016-2032. This is made up of the Government target of 292dpa. This figure itself is made up of the raw DCLG household projections plus an agreed ‘affordability uplift’ because Hart’s house prices are very high. They then remove the 40% cap on the affordability uplift and add and further 25% uplift to the result.

Hart Housing Numbers

Their justifications for the 25% uplift are:

  • Contingency against increase. I would suggest that adding to the housing target is an inappropriate way of dealing with this issue. It would be more appropriate demonstrate there is flexibility in housing supply to meet potential additional demand, rather than add extra demand without knowing it is there.
  • Affordable housing delivery. This has already been accounted for in the 292dpa Government figure. In any event, as discussed above, building more won’t make a significant difference to house prices, and so won’t make houses any more affordable for people already living here, so it’s a spurious argument.
  • Previously developed land. We have no idea what this means.
  • Buffer against non-delivery. Again this is a spurious argument. The way to deal with this issue is to demonstrate flexibility in supply, not add additional demand.

Taken together their reasons are spurious and do not stand up to any sort of scrutiny.

Faster building doesn’t make prices more affordable

As an aside, the actual rate of building in the period April 2011 to March 2016 is 1,830/5 = 366 dpa. This is well above both the raw demographic change in the Government household forecasts (208dpa) and the 292dpa rate to take account of the affordability uplift. We are constantly being told that we should be building ~250,000 houses per year across the country, and the 292dpa is Hart’s share of that. So, it would appear that Hart’s rate of house-building is also well above the pro-rata rate of house-building in the rest of England and Wales as we are constantly being told that the country isn’t building enough houses. According to the theory, this rate of over-building ought to result in at least a relative reduction in prices compared to the rest of the country.

However, examination of Land Registry data from April 2011 to March 2017 returns an interesting result.

Region

Average House Price April 2011 Average House Price March 2017

% Increase

England

        175,490

 231,826

32.1%

England and Wales           172,921

        226,860

31.2%

Hart

         275,859

         397,632

44.1%

Despite having a very high rate of building, compared to the rest of the country, house prices in Hart have risen much more quickly. This effectively nails the lie that building more will effectively make houses more affordable.

Compounding effect results in permanent unsustainability

The new Government methodology to calculate housing need uses the latest demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings. Overall, they come up with a national target that is in-line with the anticipated future needs. It follows that if councils deviate significantly from these proposals, that overall demand and supply will be out of balance.

We argue that not only is Hart’s proposed housing number unsustainable in its own right, but that this unsustainability will be projected into the future ad infinitum. This is clearly an absurd result that needs to be challenged. This is illustrated below, using figures from the previous Reg 18 consultation, but the concept remains sound.

When the prior Hart Local Plan was calling for 10,185 houses to be built, we carried out some modelling  to work out how the unsustainable rate of growth would be affected by reapplying the Government methodology at five year intervals from 2016.

Essentially, the Government figures work by projecting forwards the trends of the previous five years, to arrive at a household projection estimate. An affordability uplift is then applied to this result to generate the building rate required for the subsequent period. In areas with high house prices, like Hart, because building more will have negligibler impact on prices, the affordability uplift would be essentially compounded at each five year review point.

This could end up leading to massive increases in unnecessary housing requirements towards the end of the plan period. This will apply regardless of the starting point. However, if the starting build rate is artificially inflated, then this too will continue to be compounded into the future. We will be faced with still more housing, more people migrating into Hart and then working elsewhere. This is again the very definition of unsustainability.

An example of how this worked with the prior Local Plan housing target of 10,185 is shown in the chart below.

Hart housing requirement using Local Plan figures

Hart housing requirement using Reg 18 Local Plan figures

Essentially, it resulted in a rate of house-building that was more than double that set at the outset by the Government household projections. The effect will be less severe with the housing numbers proposed in the new Local Plan, but will nevertheless lead to significant, unsustainable over-building.

Therefore we believe that the starting point for the Local Plan should be no more than the Government’s target of 292dpa or 4,672 dwellings in total. Because it isn’t yet clear whether Surrey Heath can meet its requirement, we would be prudent and add a few hundred to this to give a round number total target of 5,100 houses.

Remedy to the Hart Local Plan: We would therefore suggest that policy SS1 be adjusted accordingly:

New Homes

Subject to the availability of deliverable avoidance and mitigation measures in respect of the Thames Basin Heaths Special Protection Area, provision is made for the delivery of at least 6,208 5,100 new homes (388 319 new homes per annum) between 2016 and 2032.

Hart Local Plan: Remove Policy SS3 to build a new town

We have finally pulled together our submission to the Regulation 19 Hart Local Plan consultation. This, the first of a series of article explains some of the reasons why Policy SS3 to build a new town should be removed.

The process for making a submission is as follows:
  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

Why should Policy SS3 for a new town be removed from the Hart Local Plan?

The most egregious part of the draft Local Plan is the proposal to include an unnecessary new town. This should be removed for the following reasons:

  • The new town is not required, even with the inflated housing numbers in Policy SS1
  • The proposal is unsustainable and undeliverable
  • The supposed sweetener of a secondary school is unnecessary and won’t be placed in a viable location
  • Will lead to coalescence with surrounding settlements
  • Breaks a number of the council’s own objectives elsewhere in the plan
  • It will hinder the much needed regeneration of our urban centres, in particular Fleet

The new town is not required

The housing numbers in the draft Local Plan are too high. Even if one assumes the housing numbers are correct, the council itself admits that the new town is not required.

Hart Local Plan Regulation 19: Hart say we don't need a new town

Not only that, the council themselves admit that the housing supply is under-estimated.

Hart Local Plan Regulation 19: Understated housing supply

And even this under-estimate does not include housing supply identified in the Winchfield and Hartley Wintney Neighbourhood plans.

The combination of the over-inflated housing demand numbers and the under-stated housing supply numbers mean that the new town simply is not required.

The new town proposal is unsustainable

The area of search identified in the Local Plan contains a very wide area, consisting of the areas known as Murrell Green and Winchfield.

Hart Local Plan Regulation 19: Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

We don’t need Hartley Winchook new town so why is it in the Local Plan?

The attempts at sustainability appraisals of the Murrell Green and Winchfield sites have been poor, but nevertheless have demonstrated some very significant weaknesses that cannot be overcome.

SHL167 SHLAA Map - Beggars Corner, Winchfield, Hart District, Hampshire

SHL167 SHLAA Map – Beggars Corner, Winchfield, Hart District, Hampshire

Let’s deal with Murrell Green first. Part of the site, known as Beggars Corner was the subject of a planning application for a Solar Farm. This was refused on the grounds that it would spoil the views from Odiham.  It is difficult to see how a 1,800 unit development would be any less intrusive than a solar farm. Moreover, that planning application identified that part of the Beggars Corner location is former landfill and some of it has unknown contents. This does not appear to be a suitable location on which to build new houses, or indeed form part of a SANG.

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

The sustainability appraisal conveniently did not cover this part of the proposed Murrell Green development.

Moreover, the SA did not manage to discover that there is a Major Accident Hazard Pipeline crossing the site.  Not only that, the developer’s proposal included a secondary school sited right on top of the pipeline. After examination of the HSE rules regarding such installations, I conclude that neither houses nor schools will be able to be built within up to 100m of that pipeline. I also understand that roads should not cross such pipelines either. See analysis here.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

When one adds in other constraints such as SINCs, proximity of a high voltage power line, the railway and the M3, it appears as though the Murrell Green part of the area of search is not suitable for large scale development.

Turning to the Winchfield part of the area of search, it should be noted that the Winchfield sustainability assessment had to be extracted from HDC by FOI request. It can be found here.

The first point to note is that much of land in the Winchfield area of search is not in fact for sale. This comprises the central swathe known as Talbothay’s Farm plus other areas. Immediately, this leads to the conclusion that it won’t be possible to plan for a coherent settlement if the central part is not available.

In addition, the main areas considered to be constraints in the SA report were:

  • Historic Environment
  • Bio-diversity
  • Landscape
  • Water Quality
  • Flood risk

More detail on this can be found here. Other spurious claims were made in the SA, such as the claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is building a wood-burning power station utilising locally sourced timber (p74). Such a plant would be extremely undesirable since burning wood produces more CO2 than burning coal, and none of the proposed master plans include such space for such a plant. Plus, of course, I don’t think many people would support chopping down Bramshill forest to fuel such a plant. This claim was used to indicate that Winchfield was somehow more sustainable than other potential locations.

They also claim that building 3,000 new houses, with associated traffic will somehow “reduce the
emissions of greenhouse gases and manage the impacts of climate change”. Again, complete and utter nonsense.

They also say there was some evidence of wet ground at the far east of SHL183, but “no other obvious evidence of current or past flooding”.

Winchfield Strategic Assessment - Flood Risk 1

This is of course complete nonsense. The detailed assessment also says there’s only a one in 30 year chance of surface water flooding. The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone. Evidence documenting the flood events can be found here (4 Jan) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie). I also understand that a similar area has flooded again in January 2018. These are obviously more than one in 30 year events.

The area east of Winchfield fared less well than Murrell Green in the sustainability assessment even with the grossly understated the flood risk. And of course there were other issues with Historic Environment, Bio-diversity, Landscape and Water Quality. It is difficult to see how this could deliver a significant number of houses.

The area west of Winchfield was ruled out of the sustainability assessment, because it is a more peripheral location relative to the train station, does not offer a central focus and is in close proximity to Odiham SSSI. It therefore offers little prospect of significant housing development.

It is clear that there are very considerable constraints even before considering the infrastructure problems.

Hart has not put together proper estimates of the costs of infrastructure; despite saying it would do so.

Hart Testing Commitment January 2015

We have made several estimates that can be found here, here and here. Essentially, if a new motorway junction is required, the costs will be in excess of £300m. If the new junction is not required, the costs will be at least £200m. A rough schedule of requirements includes:

  • Secondary school and three primary schools
  • New sewage works
  • Power station (as per SA)
  • Improved drainage
  • Re-routing or burying of electricity power lines
  • Railway station upgrade to extend platforms and car park (or relocate)
  • The bridges that carry the railway over Station Road, Taplins Farm Lane and Pale Lane will all need to be upgraded in some way
  • New big roundabouts at either end of the B3016
  • New smaller roundabouts from B3016 and A30 to the new town, new roundabout to join Pale Lane and the A323, new roundabout on A287/Crondall Road and at Pilcot Road/Hitches Lane
  • New or widened roads at Bagwell Lane, Taplins Farm Lane/Church Lane, Station Road, Pale Lane and Chatter Alley/Pilcot Road. Plus many ancient hedgerows will have to be relocated.
  • Potentially widening the A30 around Phoenix Green on the approach to artHHartley Wintney
  • New healthcare facilities
  • New sports and community facilities

If this is a 5,000 dwelling new town, with 40% ‘affordable’, the remaining market houses might be expected to generate £15-20K per unit of S106/CIL. This would amount to around £45-60m. This is well short of the funding requirement and therefore might be expected to make the existing infrastructure funding gap worse.

Taken together, it is difficult to see how such a new town could be either sustainable or viable. Indeed, it is notable that in the three years of this saga, with many Hart Council members being supportive and apparently developers becoming anxious, no planning application has been made. Perhaps that’s because the developers also realise this is a pipedream.

Secondary school unnecessary and not in a suitable location

A number of councillors have made a fuss about a new settlement bringing a new secondary school. The trouble with this is that they have yet to provide a shred of evidence that a new secondary school is in fact required.

Back in 2015, Hampshire’s forecast went as far as 2018 and they were predicting a surplus of places up to 2018. They also forecast a falling birth rate and a significant number of existing pupils attending Hart schools from outside the district.

In 2017, HCC published a new school place plan that showed an overall surplus of places in both secondary and primary schools up to 2021.

A recent letter from a Hampshire Councillor shows that 98% of Hampshire secondary pupils have been allocated a place at a school of their choice for the next academic year.

Hampshire schools keep up with demand

So, having established that a new school is probably not required, we must now address the proposals that have been put forward over the past three years for the sites of new secondary schools.

First, we had Barratts in 2014 putting up a proposal to place a new school right next door to an institution housing sex offenders.

Mildmay Oaks Hospital next door to proposed school

Proposed school next door to Mildmay Oaks Hospital that held escaped child sex offender

Then we had the proposal, described above to build a secondary school right on top of the high-pressure gas main running through the Murrell Green site.

More recently we have had another proposal from promoters of Winchfield which placed the secondary school directly under the high-voltage power lines.

Winchfield Garden Community Master Plan with pylons and powerline

Winchfield Garden Community Master Plan with pylons and powerline

If after three years of trying, they cannot find a suitable location for a secondary school, one does have to come to the conclusion that they never will.

In conclusion, it is apparent that we don’t need a secondary school, and none of the developers involved have managed to find a suitable location.

Coalescence

The area of search is very wide. It borders Hook to the west, Hartley Wintney/Phoenix Green to the north east and comes very close to the Edenbrook development and the proposed Pale Lane development to the east. The bulk of the proposal also comes very close to Dogmersfield.

In other areas of the Local Plan, the council have been quite assiduous in defining strategic gaps. They have produced no such gaps around the new area of search, nor to the east of Hook or anywhere around Hartley Wintney. Nor are any gaps proposed to the north west of Fleet.

Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

If they are allowed to go ahead with this area of search, unconstrained by strategic gaps, there is a strong risk that they will come up with proposals that lead to coalescence of our proud villages.

Breaks the Objectives elsewhere in the Hart Local Plan

Elsewhere in the Local Plan, Hart have come up with a number of objectives. These are reproduced below with my comments in bold on how these proposals break those objectives.

  1. To support the vitality and viability of the District’s town and village centres to serve the needs of residents. Adding a new settlement will draw retail traffic away from our existing urban centres, most notably Fleet, and lead to even faster degeneration of Fleet as a retail destination. This can hardly be described as supporting vitality and viability.
  2. To conserve and enhance the distinctive built and historic environment in the District including the protection of heritage assets and their settings. The proposed area of search includes a Norman church dating back to the Domesday Book and several SSSI’s including at Odiham and Basingstoke Canal. There are numerous other distinctive and historic buildings. Building a new settlement right next door to these valuable assets with neither conserve nor enhance the environment.
  3. To protect and enhance the District’s natural environment, landscape character, water environment and biodiversity, including ensuring appropriate mitigation is in place for new development to avoid adverse impacts on the Thames Basin Heaths Special Protection Area (TBHSPA).Building a new settlement in one of the most attractive parts of the district, containing many woodlands and hedgerows supporting much wildlife such as deer and kingfishers, used by many for leisure and recreation will actively damage the landscape and biodiversity.
  4. To provide measures for adapting to the impacts of climate change and minimising the contribution of new development to the causes of climate change, including reducing the risk of flooding by directing development away from areas at risk of flooding, and using opportunities offered by new development to reduce the causes and impacts of flooding from all sources. We have already established that the SA grossly under-stated the flood risk in the area known as Winchfield East, yet they are proposing to build on this area, directly against their stated objective.
  5. To promote healthy and sustainable local communities through protecting and enhancing community, sport, health, cultural, recreation and leisure facilities, and through the delivery of a multi-functional green infrastructure network across the District. We already have a multi-functional green infrastructure network in Winchfield used for recreation and leisure. Building on it will destroy it, again directly contravening their own objective.
  6. To maintain the separate character and identity of settlements by avoiding development that would result in their physical or visual coalescence. Again, we established the risk of coalescence earlier. This proposal, if implemented would effectively create a single urban conurbation from Hartland Park in the east, across Fleet and Hartley Wintney to Hook in the west. This is an appalling prospect, again directly breaking their own objective.

Remedy:  I would propose that Policy SS3 is removed entirely from the Hart Local Plan, and consequent amendments are made to SS1.

Local Plan: Is the new town an example of predetermination?

Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

Is the new town plan an example of predetermination?

Our research for the Hart Local Plan Regulation 19 consultation has thrown up the possibility that the inclusion of the new town is an example of predetermination. We hope to publish our response in full in the next few days, however, we thought readers might be interested in this analysis which is shown below.

If you are keen to get your submission completed, then you might find inspiration in the work of Hartley Wintney Preservation Society or the Winchfield Action Group. These can be found on the downloads below:

WAG Regulation 19 guide
HWPS Reg 19 Guide

The consultation runs from 9 February 2018 to 4pm on 26 March 2018. The whole suite of documents can be found here.

Now on to our Predetermination research.

Events in November 2014 that indicate Predetermination

Back in 2014, HDC conducted a consultation on housing distribution. This was a non-site specific consultation, with no reference to Winchfield in the Housing Development Options Consultation paper. The council then moved with undue haste to put a paper to Cabinet on 6 November and Council on 27 November where Winchfield was identified as the only option to be tested for a new settlement.

This process was challenged at the time, by amongst others by Hartley Wintney Parish Council. See here.

At the subsequent Cabinet and Council meetings, attempts were made to remove the words “at Winchfield” from the proposed Housing Distribution Strategy.

Housing Distribution Strategy November 2014

It is important to note that the removal of these words would not have precluded the testing of Winchfield. They would merely have opened up the possibility of testing other sites. Failure to remove those words amounted to a strong signal that the council were not open to considering suitable alternatives. Indeed, there was no attempt to even identify suitable brownfield sites that might meet some or all of our housing requirement.

The minutes of both Cabinet and Council show that amendments intended to open up other sites for testing failed.

Much debate happened at council. One councillor remarked that the “only option is Winchfield” and removing the words “in Winchfield” would give residents “false hope”.

This is backed up by contemporaneous email exchanges with councillors such as:

Winchfield is the only option - predetermination

Winchfield is the only option

Options running out imminently. Predetermination

Options running out imminently

Note that although they say they will look at other sites if they come up, they actually vote to exclude that possibility. Indeed some councillors seemed concerned that options to purchase the land may have been due to expire. Maybe this explains their haste to predetermine Winchfield as the sole option for testing.

2016: Draft Local Plan with no new settlement disappears and housing target increases

We understand that in December 2016, a draft Local Plan was produced that did not include a new town at Winchfield or anywhere else. The main reason for this is that despite earlier assertions that there just wasn’t enough brownfield capacity in the district, a planning application for 1,500 new homes on the former Pyestock site had been made. Moreover, a number of office conversions had appeared using Permitted Development Rights. This draft document was rejected by the Community Campaign Hart group and never saw the light of day. The Inspector may wish to request a copy of this document.

This draft was intended to meet the then current SHMA target of 8,022 new dwellings.

Shortly afterwards, it became apparent that the housing target would be increased by more than 2,000 houses. Many people thought the rationale for increasing the housing target by a further 2,000 units was spurious to say the least. However, this meant that it was no longer possible to meet our remaining needs through brownfield development alone.

Lo and behold, later in 2017, a new Regulation 18 consultation was published which included a new settlement at Murrell Green (much of which is in Winchfield Parish boundaries). The Sustainability Assessment test results for Winchfield had to be dragged out of the council using a Freedom of Information request. The SA results for Murrell Green conveniently overlooked the fact that a Major Accident Hazard Pipeline in the form of a high pressure gas main runs through the site. The site schematics included a school built right on top of the gas pipe.

Recent Developments that suggest predetermination

Since the 2017 Regulation 18 consultation, the Government have come up with new proposals to calculate housing need. These reflect much of the criticism we made of the previous attempts at the SHMA. These can be found here, here, here and here. These new targets result in a build rate required of 292dpa over the plan period from 2016-2032 and include an ‘affordability uplift’. Adopting this target would mean that Hart had already granted permission for more houses than is required over the plan period.

Yet, inexplicably, the council has decided to remove the 40% cap on the affordability uplift and introduce a further 25% uplift to give a resultant 388 dpa. Even this inflated target could be easily met without a new settlement. However, policy SS3 has included a new town area of search, even though even the Council admit it is not required (See here, slide 9).

Why a new settlement debunked predetermination

Given all of the history outlined here, it is difficult to come to any other conclusion than certain members of the council had predetermined that they wanted a new settlement and they wanted it at Winchfield. In summary, certain members of the council have frustrated all attempts to test other locations; they have even derailed versions of the Local Plan without a new settlement at Winchfield and ignored all opportunities to avoid concreting over many of the best parts of the district even though even they admit a new town is not required.

It is difficult to avoid the conclusion that certain members of the council had predetermined the outcome from the outset.

 

Hartley Wintney Preservation Society criticise new town in Hart Local Plan

Hartley Wintney Preservation Society blast new town proposal in Hart Local Plan

Hartley Wintney Preservation Society blast new town proposal in Hart Local Plan Regulation 19 Consultation

Hartley Wintney Preservation Society have criticised the proposals for a new town contained in the draft Hart Local Plan. Their full comments can be found in the download below.

They are concerned about the threat to Hartley Wintney represented by Policy SS3 New Settlement at the Murrell Green/Winchfield. This could lead to 3,000 homes at Winchfield and 1,800 homes at Murrell Green.

A summary of their arguments follows:

  1. The prior consultations about the Hart Local Plan that resulted in a preference for a new town are invalid because they were predicated upon much higher housing numbers that we now don’t need to achieve
  2. The proposed housing numbers are far too high, containing arbitrary uplifts to the new Government figures that simply are not required
  3. Even using the inflated housing numbers in the draft Hart Local Plan, the new town simply is not required, and the plan itself makes that clear
  4. The alleged funding for infrastructure for the new town will not materialise and won’t be enough to cover the costs
  5. Significant parts of the area of search are not suitable for housing, such as Murrell Green (gas main) and Beggars Corner (former landfill and planning permission for a solar farm already turned down)
  6. Lead to inevitable coalescence of Hartley Wintney with Murrell Green, Hook and the three hamlets that make up Winchfield
  7.  The new town proposals will starve Fleet of much needed funding and focus on regeneration

Please use these words as guidance for your own response, but try to rephrase the comments.

We will be publishing our own objections to the Hart Local Plan in the coming days. Stay tuned.

The consultation runs from 9 February 2018 to 4pm on 26 March 2018. The whole suite of documents can be found here.

HWPS Reg 19 Guide