Fleet News and Mail covers infrastructure costs story

Posted on July 31, 2015August 19, 2015

Fleet News and Mail – £300m cost risk to 5000 houses July 16 2015

We are delighted that Fleet News and Mail has latched on to our story about the massive infrastructure costs of the Local Plan and in particular of a new town in Winchfield. It is interesting that Hart District Council declined to comment on the story, which appears to mean they don’t dispute any of the figures we put forward, so they must acknowledge that the Local Plan project is in a bit of a hole.

The story was covered in the July 16 issue of Fleet N&M, and an image of the full story can be found here (caution large file). Hopefully the story will be placed online soon.

Hart Council on collision course with new Government brownfield planning policies

Posted on July 18, 2015July 18, 2015

Hart Council on Collision Course with Government Brownfield Planning Policy

Hart District Council has written to local Parish Councils setting out its interpretation of the new Government planning policies set out in the new Productivity Plan. However, it doesn’t seem to be following this guidance and is on a collision course with Government policy. Their interpretation is shown below in italics, with our comments in red plain text:

“If you don’t get a Local Plan in place soon the Government will intervene and arrange that they are written for you. We pointed out months ago that the Local Plan project is well behind schedule, but Hart dismissed these concerns. Hart has recently announced it will publish a draft local plan later this year, at least six months behind their original schedule, but it appears set on ignoring our 5-point plan for change. This additional consultation step is welcome, but it does illustrate the weaknesses in project management and governance.

To speed up the Local Plan process the Government will bring forward streamlined processes

The government will strengthen guidance to improve the operation of the duty to cooperate on key housing and planning issues, to ensure that housing and infrastructure needs are identified and planned for. Hampshire as a whole has a £1.9bn funding deficit, Rushmoor £80m and Hart £78m. All of these figures are likely to be under-estimates because many of the numbers were compiled before the latest housing allocations were calculated. Rushmoor has barely mentioned infrastructure in its draft plan and Hart has barely started identifying the infrastructure requirements.

The government will consider how policy can support higher density housing around key commuter hubs. The government will also consider how national policy and guidance can ensure that unneeded commercial land can be released for housing. This is in line with the arguments we have been making about building higher density developments in urban areas, yet Hart is persisting with its new town idea in defiance of government direction. Indeed, we have used the Employment Land Review evidence to demonstrate that at the end of the plan period there’ll be 195 hectares of vacant employment land across the Housing Market Area yet neither Hart nor Rushmoor appear to be taking this seriously.

The government has already committed to legislating for statutory registers of brownfield land suitable for housing in England. The government will go further by legislating to grant automatic permission in principle on brownfield sites identified on those registers, subject to the approval of a limited number of technical details. On brownfield sites, this will give England a ‘zonal’ system, like those seen in many other countries, reducing unnecessary delay and uncertainty for brownfield development. Hart has refused to even take the first step of a ‘brownfield first’ strategy by ruling out creating a register of brownfield sites. Hart risks being lumbered with poorly designed schemes if it doesn’t take a proactive approach to brownfield sites.

The Government intends tighten the planning performance regime, so that local authorities making 50% or fewer of decisions on time are at risk of having decision making taken away from them.

It legislate to extend the performance regime to minor applications, so that local authorities processing those applications too slowly are at risk having decision making taken away from them

The Government will introduce a fast-track certificate process for establishing the principle of development for minor development proposals, and significantly tighten the ‘planning guarantee’ for minor applications

The Government will introduce a dispute resolution mechanism for section 106 agreements, to speed up negotiations and allow housing starts to proceed more quickly

The government will deliver its commitment to get 200,000 Starter Homes built by 2020, at a 20% discount for young first time buyers. The government is bringing forward proposals to help deliver this commitment, which include:

requiring local authorities to plan proactively for the delivery of Starter Homes. Surely, apartments in higher density developments in urban areas will give a much greater opportunity for delivering starter homes. Yet Hart is eschewing this type of development.
extending the current exception site policy, and strengthening the presumption in favour of Starter Home developments, starting with unviable or underused brownfield land for retail, leisure and institutional uses (Good but will be exploited by developers to build on the edges of towns and villages)
enabling communities to allocate land for Starter Home developments, including through neighbourhood plans
bringing forward proposals to ensure every reasonably sized housing site includes a proportion of Starter Homes (
implementing regulations to exempt these developments from the Community Infrastructure Levy, and re-affirming through planning policy that section 106 contributions for other affordable housing, and tariff-style general infrastructure funds, will not be sought for them” We don’t agree with this aspect of Government policy in that all extra housing will create additional demands for infrastructure, so a way needs to be found of funding infrastructure. However, even the contributions to green field development are not sufficient to cover the costs of additional infrastructure partly because 40% of developments that have to be “affordable” do not attract CIL or S106 contributions.

Hart solidifies plans for a new town at Winchfield in defiance of Government preference for brownfield development

Posted on July 12, 2015July 12, 2015

Cows in Winchfield, Hart District, Hampshire

Cows in Winchfield under threat

In a new report to Parish Councils, Hart District Council has apparently taken the next step towards solidifying its policy of building a new town at Winchfield. In the report Hart suggests wording of a draft policy to reflect its current thinking if its strategy survives the testing process:

The Council will work with its housing market area partners to deliver 24,413 new homes across the Hart/Rushmoor/Surrey Heath Housing Market Area over the period 2011-2032. Hart’s proportion of that number is 7,534 [these figures may be subject to change if/when the SHMA is revised].

The Council has identified and allocated sufficient land to meet its needs up until 2024/2025. Thereafter, the bulk of Hart’s housing needs will be met through the development of a new settlement centered on the area that comprises Winchfield. The vision for the new settlement will be developed through a master planning exercise and will be the subject of a separate Development Plan Document.

The Council, though it’s allocations policy, will give priority to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures (i.e. those areas that lie beyond the Thames Basins Heaths Special Protection Area zone of influence [this is a Policy required of Policy NRM6 of the South East Plan.].

To deliver its housing needs the Council will seek to maximise the potential for brownfield land development where that development is appropriate to the existing character of the area, demonstrates that there is sufficient infrastructure in place to meet the needs arising from that development, and where it does not compromises other objectives, such as protecting amenity, achieving good design, the protection of important heritage assets etc.

Elsewhere, development will be strictly controlled and new development will only allowed on green field sites where the land has been allocated for development and where it enhances the sustainability of the location, demonstrates that sufficient infrastructure is, or can be put in place, to meet the needs arising from the development, and where the form and pattern of development is integrated into, and is compatible with, its surroundings.

If through Local Plan examination, and subsequent housing delivery monitoring it is demonstrated that Hart’s housing market area partners cannot reasonably meet their respective housing needs, the Council will seek to cooperate with its partners to help meet any unmet needs. This will be done through a review of the Local Plan which will assess the potential for accelerated growth of the new settlement centered on Winchfield, or the release of strategic urban extensions at **** or *****. [Options yet to be determined]

This is clearly bad news for those of us who oppose a new town and is strange given the new report highlighting the massive costs and significant barriers to delivery of a new town and new Government guidance indicating a preference for brownfield development. But in better news, Hart says it is revising the timetable for the Local Plan, saying it is planning to publish a “fully worked up draft Plan later this summer”. Hopefully, this will give an opportunity to respond to a new consultation.

If you would like to ask the council to think again, please sign and share our petition:

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Infrastructure costs of over £300m put Winchfield new town plans in doubt

Posted on July 11, 2015August 19, 2015

Construction Workers

A new study by Hart District Council has highlighted significant barriers to future housing delivery in the district. We estimate that the high level costs of meeting these infrastructure gaps might be over £300m.

The study covered 4 areas:

Education
Transport
Utilities
Flood Risk

Education was highlighted as having significant barriers to delivery, with a high level cost estimate of £80-100m (higher than the £62m estimate we put together back in February).

Transport was also highlighted as a significant barrier to delivery, but no cost estimate was given. However, the possibility of needing a new junction on the M3 was discussed. It is difficult to see how a brand new junction will give much change from £100m, given a new junction at Birmingham airport will cost £250m. Of course other roads and bridges in the area will also need to be upgraded that we estimate at £35-40m.

The report also discussed railway provision and suggested that the existing railway bridges over the roads in Winchfield would need to be upgraded and that Winchfield station itself may need to be replaced with a new station at Murrell Green. The report made no mention of the fact that these bridges and Winchfield station itself are now listed on Hampshire’s Archaeology and Historic Buildings Record. Amazingly, railways were not considered to be a significant barrier to housing delivery even though no site for a new station has been identified and the costs of such a construction and the new roads that would be needed have not been evaluated. The recent improvements to Fleet station cost >£8m, it is difficult to see how a totally new station, including platforms, buildings, signalling, car parks and new road access would cost less than £25m. The recent Network Rail funding debacle puts such an investment in grave doubt.

Provision of foul water capacity was identified as a significant barrier to housing delivery although no costs were identified.

The potential need to put the existing high voltage electricity lines that cross Winchfield underground was raised. This costs around £20/km, so would probably cost round £50m. This was not considered to be a significant barrier.

The report did not cover the costs of additional healthcare facilities that would be required to cope with the increased population all these extra houses would create.

Adding all this up, and the total costs will be in excess of £300m. We have reported before that Hart estimates that there is currently a £78m funding gap for infrastructure and Hampshire estimates a funding gap of £1.9bn across the county. All of the costs above will add to that gap. It is simply not credible to believe that such large costs will be funded by developer contributions.

The study recommended that further studies be carried out to examine these issues in greater detail:

Identify potential implications for infrastructure provision of the Preferred Housing Distribution Strategy (June 2015) which broadly set out a higher level of growth than hitherto within existing settlements
Commencement of a full Transport Assessment (TA) potentially utilising the existing HCC North Hampshire Transport Model (NHTM)
Commencement of an Integrated Water Management Strategy (IWMS)
Continued engagement with HCC (particularly with regard to school place provision) and with South West Trains (SWT) and Network Rail (NR)
Consolidation of information into an updated Infrastructure Delivery Schedule (IDS) to support both the emerging local plan and community infrastructure levy (CIL) at public examination
Continued engagement with the Enterprise M3 Local Enterprise Partnership (E3LEP)

None of these tasks appear to be identified in the work plan for the Local Plan, so there is little doubt that the Local Plan project is now massively behind schedule.

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

Posted on July 8, 2015July 21, 2015

Example of Urban Sprawl

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

The main reasons are:

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

Please download the pre-prepared feedback forms, fill in your details and send off to [email protected]. The consultation closes on 20 July 2015.

Rushmoor Local Plan Response Form

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Additional Response to Rushmoor Local Plan

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Please help Hart fend off an extra 1,600 houses from Rushmoor

Posted on June 17, 2015August 30, 2015

Is this what we want Hart to turn into?

Rushmoor Borough Council has published a draft Local Plan where it proposes to build only 8,200 of its assessed need of 9,822 houses over the plan period. It is clear that Rushmoor is seeking to offload the remaining 1,622 houses on to Hart District.

We need to oppose this move and We Heart Heart have produced some materials to help you do this easily. Our voice will have greater weight if we can get more Hart residents to comment on Rushmoor’s plan than Rushmoor residents. Please follow the simple process below:

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

Rushmoor Local Plan Response Form

Download Now!361 Downloads

A summary of the arguments we are putting forwards is outlined below.

Slippery slope to taking more housing than the other districts

The proposal to take an additional 1,622 houses from Rushmoor puts us on the slippery slope to accepting a further 1,400 houses from Surrey Heath such that Hart District ends up having to build the most houses in the Housing Market Area.

	Hart District	Surrey Heath Borough	Rushmoor Borough	Total Housing Market Area
Original SHMA	7,534	7,057	9,822	24,413
Proposed Transfers	3,022	(1,400)	(1,622)	0
New Total	10,556	5,657	8,200	24,413

This will impact all of our districts including Blackwater and Hawley; Bramshill; Church Crookham; Crondall; Crookham Village; Dogmersfield; Elvetham Heath; Eversley; Ewshot; Fleet; Greywell; Hartley Wintney; Heckfield; Hook; Mattingley; North Warnborough; Odiham; Rotherwick; South Warnborough; Winchfield; and Yateley adding additional pressure to an already difficult situation and make it more likely we have to accept both a new town and urban extensions on our beautiful green fields and countryside.

Hart and the rest of Housing Market Area are being asked to build too many houses

The whole Housing Market Area (HMA) should reduce the assessed need by 7,800 units which would reduce the pressure on Hart directly and remove the need for Surrey Heath and Rushmoor to ask us to build >3,000 houses for them. This is discussed in more detail here.

Rushmoor isn’t making best use of its brownfield sites

This is discussed in more detail here and here. As can be seen, if Rushmoor gets more creative with Wellesley and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need. It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build out of this wealth of opportunity. Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries. It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas. Neighbouring districts could be approached to provide SANG capacity if required. Rushmoor should also take a closer look at all the vacant sites in the district and seek to convert them to residential use.

Rushmoor’s Employment Land Review is overblown and seeks to protect more employment land than is necessary.

This is discussed here. It is also clear that past forecasts got it wrong as evidenced by the large number of vacant office blocks and empty shops across Hart District. If the ELR was reduced to more sensible levels they could free up more land for housing.

Indeed, even if you accept the overblown employment forecasts, there will be a surplus of nearly 600K sq m of employment space at the end of the plan period, covering around 195 Ha. Yet Rushmoor seeking to protect 96 Ha of land whilst asking Hart to build 1,600 houses on green fields.

Rushmoor’s infrastructure plans are not credible

We posted here that Hampshire as a whole has a £1.9bn infrastructure funding deficit, with Rushmoor’s share of that being £80m. Rushmoor makes no mention of this deficit in its draft Local Plan. Hart’s own numbers show an infrastructure deficit of £78m. All of these numbers are probably an under-statement given they were all produced before the scale of development now proposed was known. This is in contravention of NPPF para 177 that says there must be a “reasonable prospect” of delivering the required infrastructure alongside housing:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan”

Finally, they don’t even attempt to quantify the extra infrastructure Hart would need to build the extra 1,600 houses nor do they make any offer to fund any of that extra cost.

Rushmoor not planning to meet the needs of the ageing population

Figure 10.15 of the SHMA sets out the need for specialist housing and registered care places for the HMA and Rushmoor. This states Rushmoor must build 710 sheltered and extra care units as well as provide an extra 600 registered care places. Their draft Local Plan makes no mention of the extra registered care places and sets no target for the sheltered and extra care units. This is in contravention of NPPF para 50 which states:

“local planning authorities should…plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)”

Therefore the Rushmoor draft Local Plan runs the risk of being found unsound and should be revised.

In conclusion, the Rushmoor draft Local Plan contains many serious flaws and needs to be revised.

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Hampshire has £1.9 billion infrastructure funding gap and Rushmoor faces £80m funding shortfall

Posted on June 11, 2015June 20, 2015

£1.9 billion infrastructure funding deficit in Hampshire

A series of interesting revelations have resulted from the recent publication of Rushmoor Borough Council’s Draft Local Plan. The bottom line is that back in 2013, Hampshire County Council identified an infrastructure funding deficit of £1.91bn out of a total requirement of £2.16bn, or to put it another way more than 88% of the requirement is not funded.

Hampshire Infrastructure Funding deficit of £1.9bn

Of this gap, £80m was attributed to Rushmoor:

“For the infrastructure defined, a total estimated funding shortfall of approx. £80 million has been identified for Rushmoor Borough over the next 15 years.”

All of these figures were compiled before the latest housing requirement was calculated so the up to date figures are likely to be much higher.

In its draft Infrastructure Plan, Rushmoor makes no mention of the costs of the infrastructure needs it has identified nor has it explained where it will get the funding from to meet those needs.

Perhaps this explains why Rushmoor is so keen to offload 1,600 houses on to Hart. Remember Hart already has a £78m funding deficit of its own, and this is probably an under-statement because it doesn’t include any allowance for additional schools, improved railways or better GP surgeries.

The National Planning Policy Framework para 177 says:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.”

It is simply inconceivable that both Rushmoor could have got so far with its Local Plan without addressing how its infrastructure is going to be funded. Surely this must be enough to find its plan unsound. We Heart Hart will work to help Hart residents object to Rushmoor’s draft Local Plan.

Hart Council rolls over and starts to plan for an extra 1,600 houses from Rushmoor

Posted on June 10, 2015August 15, 2015

Do we want Hart District to turn into an urban sprawl?

We Heart Hart understands that at the Local Plan Steering Group last week councillors were told that they will have to start planning for an extra 1,600 houses from Rushmoor. We have previously warned that by planning for a new town, Hart was creating capacity that would force it to take the unmet needs of Surrey Heath and Rushmoor. Indeed the advice from Peter Village QC was that Hart should pursue the duty to cooperate discussions in a “robust and inquisitive manner”.

This would take Hart’s target to 2032 up to 9,134, up from the current (in our view overblown) target of 7,534. This is simply wasting the good work that has identified additional brownfield capacity in the district.

However, Hart Council’s actions are going much further than the advice they received from the Planning Inspector as recently as March 2015:

“Tactically, Hart should show to an inspector that it acknowledges the housing problem, and accept that it is likely to have to take an element of unmet need now. This would show an inspector that Hart is being reasonable in the circumstances. In practice this could mean taking an element of Rushmoor’s need now, but dealing with further shortfalls in Rushmoor and Surrey Heath through an early review once there is more certainty over what those authorities can deliver. Hart would need to quantify the amount of unmet need it is agreeing to take in its plan. It would also need to justify why it’s not taking all the unmet need.”

So, far from taking “an element” of Rushmoor’s need now, they are proposing to plan to take the whole lot. Of course there are no reports yet of how they are going to close the existing £78m funding gap, let alone how to fund the extra infrastructure required to support the extra 1,600 houses we have to build for Rushmoor.

The whole reason why we are being put in this position is that the combined housing market area of Hart and Rushmoor and Surrey Heath Boroughs is being asked to build too many houses because the Strategic Housing Market Assessment (SHMA) is based on some dodgy forecasts. If the SHMA was brought down to more realistic levels, then neither Rushmoor nor Surrey Heath would have a shortfall.

We need to challenge Rushmoor’s plan now. We have created a template letter, together with an up to date distribution list of all of the Hart District Councillors and it is available for download below. Please download it, and all you need to do is cut and past the contents into an email; choose your local councillor email adresses; add your name and address; alter the contents as you see fit and send it off. We have also created a template document for challenging Rushmoor’s plan.

Letter to Hart Councillors rejecting proposal to take 1,600 houses from Rushmoor

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Rushmoor Local Plan Response Form

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Please sign and share our petition and support our 5-point plan to change course:

Go to Petition

This story has been covered in Get Hampshire.

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We Heart Hart Petition breaks 2,000 barrier

Posted on June 2, 2015August 19, 2015

We Heart Hart Campaign Logo

The We Heart Hart petition is now really taking off, breaking through the 2,000 barrier over the weekend. This is approaching four times the number of valid responses to Hart Council’s consultation that took place in Autumn 2014 and more than 9 times the number of people (220) of said they favoured a new settlement.

It seems that the people of Hart are backing our 5-point plan for change and waking up to the reality that the Council’s plans will:

Force Hart to build an extra 3,100 houses for Rushmoor and Surrey Heath

Turn the northern part of Hart will turn into a single urban sprawl when there is an alternative of building higher density in urban areas to help rejuvenate our high streets

Lead to more congestion and traffic all over the district, particularly in Fleet and Church Crookham

Ignore many brownfield sites untouched all over the district where we could build housing

Create intolerable pressure on our local services such as doctors, schools, roads, sewage, electricity and railways because their infrastructure plans are under-funded by at least £78m

Destroy our environment and the very nature of Hart’s unique appeal – the reason we all love living here.

If you would like to join our campaign, please sign and share our petition:

Go to Petition

Surely it is now time for Hart Council to think again, act on the legal opinion describing their position as “hopeless”, focus on brownfield first and listen to the people.

Revised submission to Owens Farm (Hop Garden Road) Appeal

Posted on May 29, 2015August 19, 2015

The slot we thought we had been allocated to the first part of the Hop Garden Road (Owens Farm), Hook appeal (APP/N1730/W/14/2226609) unfortunately didn’t happen due to some administrative hiccough. However, we have now been allocated a slot at 10am on 9 June 2015. This has presented an opportunity to improve further our submission and make it stronger.

The full details of the submission can be found here:

Revised submission to Hop Garden Road Appeal

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The summary of the submission is presented below and the main challenge to the SHMA here:

This purpose of this submission by the We ♥ Hart Campaign is to oppose the specific unnecessary development proposed at Hop Garden Road in Hook and demonstrate to other developers who may wish to put forward speculative proposals for the over-development of the district that they will face formidable opposition to their plans. Hart District is facing a scale of development that is against the wishes of its residents and in contradiction to stated Government policy to place planning decisions in the hands of local people.

Let me remind you of the Prime Minister’s words in 2012, taken from this Telegraph article:

He said: “I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control. The fear people have in villages is the great big housing estate being plonked down from above.

“Our reforms will make it easier for communities to say ‘we are not going to have big plonking housing estate landing next to the village, but we would like 10, 20, 30 extra houses and we would like them built in this way, to be built for local people’.”

Mr Cameron, who was being interviewed in his Oxfordshire constituency, denied that the reforms would lead to large swathes of the countryside being built on.

He told BBC1’s Countryfile programme: “Here we are in west Oxfordshire one of the most beautiful parts of our country, set in some of England’s finest countryside. I would no more put that at risk than I would put at risk my own family.

“I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control.”

We ♥ Hart object to this proposed development and any future speculative proposals on the grounds summarised below:

The SHMA and OAN are not objective and represent a “need” that is far too high.
Understated brownfield capacity means green field development is not necessary
This proposed development will not contribute towards meeting the needs of the changing demographics of the district
The proposed development will make the current infrastructure funding gap worse
Lack of consideration of the environment

As shown in section 8, the combined effects of reducing the OAN as assessed in the SHMA to a more realistic level and taking account of brownfield development in the pipeline that is not included in the Land Supply calculation would increase the land supply to 11.7 years.

The only reasonable conclusion from this analysis is that the Hop Garden Road application should be refused as it is not required; would build the wrong type of housing in the wrong place to meet the changing demographics of the district; would make the already difficult infrastructure funding position worse and needlessly concrete over our valuable green fields and damage the environment.

We ♥ Hart respectfully requests that this application is turned down.

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