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
WAG Regulation 19 guide
HWPS Reg 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
HWPS Reg 19 Guide

 

The Harlington project finances don’t add up

The Harlington Project - financial challenges could Save Gurkha Square in Fleet Hampshire

The Harlington Project – Financial challenges

We have uncovered some financial challenges to the Harlington Project to build a new facility on Gurkha Square in Fleet, Hampshire. Sadly, we have found that Fleet Town Council’s numbers don’t add up.

In summary, it is unlikely the project as currently constituted would meet Government lending criteria, without a significant precept increase. Moreover, Fleet taxpayers are on the hook for further increases in the precept if costs were to increase by even a modest amount.

If you want to do something about this, please respond to the petition that can be found here.

Please also object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Here is detail of the facts as we understand them, that have led us to the conclusions.

First, just to remind you, Fleet Town Council (FTC), is currently proposing to borrow £10,424,200 over 46 years to fund the vast majority of the project cost. The current total cost is estimated at £11,024,200, including a 7.5% estimate of inflation and 5% contingency. They have committed to keeping the annual precept on Fleet residents at £412,000 per year.

The Harlington Project Financial challenges to build on Gurkha Square FTC precept commitment

The Harlington Project – Precept Commitment

Will the Government approve the loan for the Harlington Project?

FTC has stated that it will seek a loan from the Public Works Loan Board (PWLB) to finance the Harlington project to build a replacement building on Gurkha Square.   The PWLB does indeed make such loans, but each loan has to be approved by the Government. Not surprisingly, the Government has set guidelines on how much parish and town councils can borrow.

This leads us to the first challenge. The Government has said:

The amount that an individual council will be allowed to borrow is normally limited to £500,000 in any one financial year.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Government borrowing limit

The Harlington Project – Government borrowing limit

In short, FTC is proposing to borrow more than 20 times the amount that is normally allowed. Therefore, there must be a doubt that the loan will ever be made.

However, there is another challenge. In the current consultation on the prudential framework for capital finance of Local Government, maximum asset lives have been set. Freehold land gets a life of 50 years. Other assets have a maximum asset life of 40 years.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Maximum Asset Life

The Harlington Project – Maximum Asset Life

Eagle eyed readers will have spotted that the maximum term that the Government will allow for buildings is less than the loan term that FTC is proposing. It isn’t even clear that the Government would allow an asset life of 40 years for such a building. This must lead to FTC increasing the precept to finance the reduced loan term (see sensitivity analysis below). Therefore, before any further cost increases, FTC has already broken its commitment to local taxpayers – see below.

Sensitivity of the Harlington Project to Cost Increases

The current proposal from FTC of total project costs of ~£11m, with council needing to borrow £10.4m to fund the build. This project costs figure includes 7.5% provision for inflationary increases and a 5% contingency. Given that stage the project has reached, we think 5% contingency is very low.

Harlington Horror Show: costs escalate to £11m

The Harlington Project costs £11m

This is borne out by FTC’s discussions last year with a Design and Build contractor. This might have been a way of FTC off-loading the risk of cost increases to the private sector. Of course, they would have had to pay a premium to cover this risk. However, the cost estimate put forward by the contractor was ‘unacceptable’, so FTC have decided to go it alone with some support from Rushmoor Borough Council.

The Harlington Project Financial challenges to build on Gurkha Square risk of cost increases

The Harlington Project – risk of cost increases

So, a private company is not willing to risk its own money on there being no further cost increases. We therefore think further cost increases are a virtual certainty. A sensible contingency at this stage of design would be at least 20%. A sensitivity analysis of the costs shows:

The Harlington Project Financial challenges to build on Gurkha Square Sensitivity Analysis

The Harlington Project Financial – Sensitivity Analysis

  • To complete the project at the current cost estimate, with a maximum loan term of 40 years, would require a precept increase of 7.3%
  • If the total project costs increased by 10% (15% over the current baseline), then the precept would need to increase by 18.6%
  • A precept increase of 24.3% would be required if costs increased by 15% (20% over current baseline).

FTC is considering mitigation measures such as seeking a grant from the Arts Council. This would lead to them borrowing £8.5m. They would then have around £1.2m of headroom for cost increases before they would have to consider increasing the precept.

There is of course the risk that the fixed term interest rates that PWLB offer may rise between now and when the loan is offered.

Security of the Loan for the Harlington Project

It is worth pointing out that the loan from the PWLB is different to a mortgage.

With a mortgage, the bank takes security over the property. This means it takes the future value of the property seriously. The bank needs to ensure there will be value in the property if the borrower defaults on the loan.

The Harlington Project Financial challenges to build on Gurkha Square Fleet Security over local tax

The Harlington Project financial challenges – Security over local tax

However, the PWLB takes a charge directly over the taxes raised by the town council, so it has no need to worry about the future value of the building being constructed. This means that if the building were to deteriorate over say, a 30 year period, Fleet taxpayers would still be on the hook to repay the loan, even though the building might be useless by then.

Be careful what you wish for.

See earlier posts:

Save Gurkha Square

The Harlington Horror Show

 

The Harlington Horror Show – public sector value destruction

The Harlington Fleet Horror Show of a Deal to replace it with a new building on Gurkha Square

The Harlington Horror Show in Fleet, Hampshire

We have done more digging into the plans to replace the Harlington in Fleet by building a new facility on Gurkha Square. We have uncovered the Harlington Horror Show. We believe these plans represent a massive destruction of value for taxpayers.

  • Hart taxpayers lose around £140K per year, and lose at least £1.2m of value in Gurkha Square. They might get some of the Views in return, but have to fork out maybe up to £500K to replace the lost parking spaces.
  • Fleet taxpayers gain Gurkha Square and a brand new £9.9m £11m building, that will cost them at least £26.6m £34.3m over a 45 58 year repayment period and they lose part of The Views. They might also gain parking revenue from the remaining car park. ***Stop Press: Costs now escalated to £11m***
  • Everybody gains another decaying building in the form of the old Harlington blighting the town centre for years into the future, with no plan and no money to do anything about it
  • There are no plans for the much needed wider regeneration of Fleet, and there are no plans to raise any private money to back the scheme.

It is difficult to see how these arrangements pass any sensible application of Government Value for Money principles. This is truly the Harlington Horror Show.

If you want to do something about this, please respond to the petition that can be found here.

Please also object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Here is detail of the facts as we understand them, that have led us to the conclusions:

The Harlington Centre Consultation

In 2017, Fleet Town Council (FTC) consulted on 3 options for the Harlington Fleet. The options were Repair, Refurbish, or Replace. The Replace option mean building a new facility on Gurkha Square car park. Of the 1,481 people who responded to the survey, 86% or 1,274 were Fleet residents. Of those Fleet residents, 53% or 675 people chose the ‘Replace’ option. FTC has taken this as a mandate to spend approximately £10 million to be raised from Fleet Council Tax payers.

The main issue with the consultation is that at the time, FTC did not even have a lease to operate within the existing Harlington and nor does it own the Gurkha Square car park. So, it held a consultation about two options that were not within its gift to deliver. It might as well have had a consultation about how many fairies we would like at the bottom of the garden.

Current position of the Harlington, Fleet

Currently the Harlington generates an operating loss of around £180,000 per year and this is expected to continue with the new facility.

Operating loss of Harlington Centre Fleet £180,000 per year. Harlington Horror Show

It was resolved earlier this year that the Joint Chief Executive in consultation with the Portfolio Holder for Services be authorised to enter into an interim short term ‘two year rolling’ lease for the Harlington with FTC. We don’t know the details of that lease.

HDC FTC short term rolling lease for Harlington Centre. Harlington Horror Show

Current position of Gurkha Square

It is understood that HDC own the freehold for Gurkha Square. Currently it generates between £108,000 and £130,000 of parking revenue. As an average, let’s assume £120,000 per annum.

Parking revenue for Gurkha Square. Harlington Horror Show

Back at the March 2017 Cabinet meeting the car park was worth between £750K and £1.3m.

March 2017 cabinet value of Gurkha Square £750K-£1.3m. Harlington Horror Show

More recently, at Overview and Scrutiny Committee the value was set at £575K. The reason for this mysterious loss of value hasn’t been explained.

New Gurkha Square value £575K. Harlington Horror Show

We think the valuation is on the low side. A continuing stream of parking income, which is likely to be rise in line with inflation each year, might be valued at a multiple of 16 or above. This would value the car park at nearly £2m.

An alternative approach might be to value it as development land with planning permission. The SHMA suggested development land in Hart is worth £4m per hectare. The site is approximately 0.3Ha. This would value the site at £1.2m. This might be considered conservative as it is a prime site in one of the most affluent towns in the UK.

We believe that Hart wants to replace the lost parking revenue. We understand that it has been proposed that there be a ‘land swap’ where HDC give Gurkha Square to FTC and in return, FTC give HDC part of The Views. Hart would then use that land to build new parking spaces. The Views are one of the last remaining green spaces in Fleet town centre. As green space, the land has essentially zero economic value, and probably comes with maintenance costs attached.

The Harlington Proposal

As we understand it, FTC is proposing to build the new facility on Ghurka Square car park at a cost of £9.9m. ***Stop Press: Costs now escalated to £11m***. There are no plans for what happens to the existing Harlington centre, and apparently no money either. It has to be presumed that Hart taxpayers will shoulder the costs of maintenance and security, meanwhile Hart residents gain another decaying building in Fleet.

Harlington Horror Show: costs escalate to £11m

Harlington costs escalate to £11m

It is envisaged they will take loan to cover the cost from the Public Works Loan Board. Under this arrangement, monthly payments would remain fixed, but the term of the loan might vary depending upon changes in interest rates or cost escalations. The current plan is that the repayment period would be 45 years. 58 years based on the new £11m cost. Would the building even last that long?

Harlington costs and repayment £9.9m and 45 years. Harlington Horror Show

FTC has committed not to increase the precept levied to fund this project above £412,000 per annum.

Harlington precept £412000 per year. Harlington Horror Show

It is not clear what will happen if costs or interest rates rise so that the monthly payments don’t cover the interest. A quick sensitivity analysis shows that if the interest rate increases to 4.3% or above, and/or costs escalate to £13.6m or above, then the precept will not be sufficient to repay the interest, let alone repay any of the principal. We know that interest rates are rising, and construction costs only go up between project idea and completion.

Harlington Gurkha Square Sensitivity Analysis. Harlington Horror Show

Taken together, FTC is commiting to spend the continuing operating loss of £180,000 per annum plus the loan repayments of at least £412,000 per annum for the next 45 58 years. This totals at least £26.6m £34.4m over the term, assuming no further cost overruns and no interest rate increases.

The Harlington Horror Show Deal

Putting this all together, we believe this proposal is a lose-lose deal for Hart and Fleet residents. Let’s take a look at the position of Hart and Fleet taxpayers.

Hart Taxpayers

On the revenue side, they lose approximately £120K in parking income each year from Gurkha Square. They also lose the costs of maintaining and securing the decaying Harlington building. This might amount to a total of around £140K per year.

On the capital side of the account they lose Gurkha Square at a value of at least £1.2m. However, they gain part of The Views, at an unknown value. Essentially, this has no economic value as greenspace, and will probably come with maintenance costs attached.

The revenue costs could be mitigated by building more parking spaces on The Views. It is unlikely that the costs, once additional roadworks and machines are included will give much change from £500K. The resulting spaces will then be in an inconvenient position and unlikely to generate much income.

Fleet Taxpayers

On the revenue side Fleet taxpayers commit to paying at least £412K per annum for at least 45 58 years, plus £180K per year subsidy, for a total cost of at least £26.6m £34.3m. They might also gain parking revenue from the remaining car park.

On the capital side, they gain Gurkha Square at a value of £1.2m. However, they lose part of The Views at unknown value. Of course they gain a brand new building at a value of £9.9m £11m.

Taken together, this is the Harlington Horror Show.

 

 

Save Gurkha Square

Save Gurkha Square in Fleet Hampshire

Save Gurkha Square

The purpose of this post is to alert you to the plans to build on the much-loved Gurkha Square car-park and support the petition calling for a referendum of Hart residents before planning permission is granted.

Save Gurkha Square Petition

The petition can be found here.

Gurkha Square proposal

Fleet Town Council has made a controversial planning application to build a new facility on Gurkha Square car-park. This can be found here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ ). This new facility is currently expected to cost around £9.9m to build.

This is to replace the aging Harlington centre that currently costs £178,300 to support each year. It is envisaged that this support cost will continue for the new centre. Additionally, Fleet residents will be asked to continue paying the £412,000 Harlington precept for 45 years to repay the loan. This assumes there is no escalation in building costs and no increase in interest rates. Hardly sensible assumptions.

At the time of writing, there have been 12 comments on the planning application and all of them are opposed to the proposal. One Hart resident has written:

When I found out about this and how little others living in Fleet knew about it I wanted to ensure that as Fleet residents you were made aware & could have a say in the future

Why is the Gurkha Square proposal a bad idea?

Regular readers will be aware that we are broadly in favour of redeveloping Fleet. So, we had to think long and hard about this proposal. We came down against it because:

  1. This removes much needed parking spaces from the town centre.
  2. Puts at risk the market and other community events.
  3. It is a poorly thought through proposal that isn’t part of a proper master plan for Fleet regeneration
  4. There is no plan to do anything with the vacant, decaying Harlington building or the rest of the underutilised complex.
  5. There is a risk that part of the Views will be concreted over to replace the lost parking spaces.
  6. Disrespects the Gurkha community by reducing the space dedicated to their support and sacrifice for the UK.
  7. This proposal has all the hallmarks of a doomed political vanity project.

Opaque financial arrangements for Gurkha Square transfer

The Gurkha Square car-park is currently owned by Hart District Council. In essence it belongs to all Hart residents. The financial arrangements related to the transfer of the car-park to Fleet Town Council are shrouded in mystery. They were discussed at Overview and Scrutiny Committee, but the key debate about finance was conducted in private.

We don’t think it appropriate that the transfer of assets between two public bodies should be conducted in secret. What we do know is that the Cabinet received advice that the value of the car-park is £575,000. Although it is unclear how this figure was determined. The site is approximately 0.3Ha and development land with planning permission is worth around £4m per hectare. One might expect prime development land in the town centre to be worth more. This would equate to a value of at least £1.2m, far in excess of the stated value.

However, we don’t know the basis on which HDC has agreed to transfer the asset. Some people fear they have agreed a much lower capital value, in exchange for a continuing income. But it seems odd they would rely upon an income from a facility that Fleet Town Council say will continue to lose £180,000 per annum. Moreover, the decaying Harlington Centre will revert to HDC, which looks like it will be a liability rather than an asset.

We think Hart residents should be consulted before ‘their’ asset is transferred to Fleet. Moreover, the financial arrangements should be transparent. Indeed, the deal as proposed may well be in breach of the Value for Money rules governing public bodies.

Conclusion

Please respond to the petition that can be found here.

Please object to the planning application here (or search for application 18/00147/OUT on https://publicaccess.hart.gov.uk/ )

Download the leaflet here:

Save Gurkha Square leaflet
Save Gurkha Square leaflet

 

 

Affordable homes blocked by Hart’s restrictive brownfield policies

Affordable homes blocked at Zenith House, 3 Rye Close, Fleet, Hampshire by Hart's restrictive brownfield policies

Affordable homes blocked by Hart’s brownfield policies

The delivery of 36 affordable homes is being blocked by Hart’s restrictive brownfield policies. Magna Group is seeking to convert Zenith House on Rye Close on Ancell’s Farm in Fleet into 36 relatively affordable properties, designed to retail at £175,000 to £300,000. But they are being blocked by Hart’s restrictive SANG policy.

The council has given its prior approval to the development. However, Hart is effectively blocking the development by refusing to allocate any of its SANG.

redevelopment of Old Police Station,Crookham Road, Fleet, Hart District, Hampshire being blocked by restrictive brownfield policies

Proposals to redevelop Fleet Police station being blocked by restrictive brownfield policies

We understand the same developer owns the old Fleet Police station on Crookham Road in Fleet and plans to replace it with 14 new dwellings. However, we understand the council planning officers have been instructed to refuse planning permission for even compliant proposals.

This has the effect of:

  • Restricting the supply of housing that would be affordable for many young people trying to get on the housing ladder
  • Adding extra pressure to build on green field land
  • Stopping the market dealing with the problem of the over-supply of dilapidated office blocks in the district

This policy is also blocking Ranil’s ideas for regenerating Fleet. His petition can be found here.

It transpires that Hart’s SANG policy may well be illegal. We understand that legal representations have been made that cast doubt on Hart’s SANG policy:

First the policy is clearly intended to frustrate the delivery of housing rather than to facilitate development.  The policy confers on the head of the regulatory services absolute discretion to allocate SANG but makes clear that SANG will not be allocated to any development unless the Council considers it to be acceptable.

That means that if Planning Permission is granted on appeal the Council will nevertheless use its powers in relation to SANG to thwart that development.

The policy may result in the Council preventing people from exercising the rights they have been granted by Parliament through the permitted development process. In effect the Council is removing a property right from them in breach of the terms of the Human Rights Act 1998.

Furthermore the Council is in breach of its duty to make proper provision to facilitate the delivery of housing.

It certainly looks like the council is setting itself up for more expensive legal battles.

 

 

 

 

 

Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council is seeking to block development of brownfield sites. It has put forward proposals to be discussed at the Planning meeting later today to implement an Article 4 direction to

Withdraw permitted development rights related to the change of use of offices, light-industrial units, and storage or distribution units to residential use within the Strategic Employment Sites and the Locally Important Employment Sites

This covers substantially all the brownfield sites in the district. We do have some sympathy for the view that simple conversion of office sites to residential is not good for the district. We much prefer complete redevelopment of these sites, so the provide higher quality housing and a better sense of place.

But the council’s approach is heavy-handed and sends a signal that they do not welcome brownfield development. Moreover, this approach will discourage the regeneration that our urban centres badly need.

The proposals call for:

  • Draft Article 4 Direction and supporting documents;
  • Give notice as soon as possible after a Direction has been made by local advertisement, site notice, owners and occupiers (unless reasons to justify not doing so);
  • Send a copy of the direction and the notice to the Secretary of State;
  • Notify the county planning authority;
  • Following the above, take into account any representations received; and
  • Confirm the Direction by giving notice as above and sending a copy of the confirmed direction to the Secretary of State.

They have to give 12 months notice of the implementation of the direction.  They identify as risks that:

  • Developers may make claims for compensation from a local authority
  • The proposals could result in a rush of applications before the rights are withdrawn, it is not
    possible to mitigate against this risk.

A more positive approach would be to put a policy in the draft Local Plan that unequivocally encourages  redevelopment of brownfield sites and give examples of the kinds of scheme the council would encourage.

Hart Brownfield sites in Employment Land Review

The other puzzling thing is that Hart’s own Employment Land Review identifies much of the employment land in the district as:

Lower grade stock for which there is limited demand and a large supply. As a result of limited demand. The poorer quality stock is remaining vacant for prolonged periods.

They say that:

The current over-supply of lower grade office accommodation is limiting investment in the refurbishment of such stock as low rent levels make such investment unviable.

To summarise, Hart is seeking to block the redevelopment of low grade office blocks, and there’s no hope of refurbishing these into high quality office accommodation. So it seems that we are going to be stuck with many of the eyesores in the photo carousel below. They really have gone through the looking glass.

 

Time to oppose silly Hartley Winchook new town in Local Plan

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?

Hart District Council has begun the Regulation 19 consultation on the Local Plan. This is the final version before submission to the Inspector later this year. Unsurprisingly, this still contains Policy SS3, with proposals for the entirely unnecessary Hartley Winchook new town.

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

We will, of course, oppose the new town elements of the Local Plan. However, we have to take great care in opposing the plan, because the worst outcome would be that the whole plan is failed by the Inspector.

Hart says that representations about the Local Plan should relate to legal compliance, duty to cooperate and tests of soundness. Helpfully, the council has provided a guidance note on how to respond.

We beleive there are grounds to challenge the plan on the grounds of soundness. Overall our objective should be to get Policy SS3 removed, together with the necessary grammar changes to Policy SS1 to ensure consistency.

How will the Inspector assess the Local Plan

We understand the Inspector is going to look at seven key areas:

1. Duty to co-operate / legal compliance
2. Spatial strategy
3. Housing numbers
4. New settlement area of search
5. Town centre regeneration
6. Infrastructure
7. Development management policies

We believe the spatial strategy is flawed, because it includes provision for the new town, which is enitrely unnecessary to meet the still inflated housing numbers.

The housing numbers themselves are based on the new Government methodology. However, they have included an arbitrary 25% uplift to the requirement, which we believe is too high.

The new settlement area of search is very wide and covers areas that have already not passed testing:

  • 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.
  • The area east of Winchfield fared less well that Murrell Green and of course the sustainability assessment grossly understated the flood risk. And of course there were other issues with Historic Environment, Bio-diversity, Landscape and Water Quality.
  • The sustainability appraisal famously did not take account of the high-pressure gas main traversing the site.

Moreover, it is highly likely that the costs to deliver the required infrastructure will far exceed any realistic assessment of developer contributions.

Hart acknowledge that Fleet will face a challenge “to secure investment so that it can compete with the comparable towns in neighbouring districts”. Yet, the local plan contains no plans to regenerate our main town centre.

The infrastructure plan is paper thin, and they offer no solutions on how to close the £73m infrastructure funding deficit and no plans in particular to improve healthcare in the district.

The development plan policies contain a number of strategic gaps around the district, but leave Hartley Wintney totally exposed with no strategic gaps planned.

 

 

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

We will pull together a more detailed response in the coming weeks.

Elvetham Chase refused, Wates on the warpath

Wates image Elvetham Chase aka Pale Lane

Wates image of Elvetham Chase (Pale Lane)

Thankfully, last week Hart District Council decided to refuse the Elvetham Chase (Pale Lane) proposal. Whilst this is good news, it is clear from Wates’ press release that they are very disappointed. They are likely to be on the warpath and launch an appeal.

Here is their statement in full, my emphasis:

Wates Developments today expressed disappointment at Hart District Council’s decision to refuse planning permission for its Elvetham Chase proposal without giving it the chance for proper consideration at Committee.

Emma Gruenbaum from Wates Developments said, ‘Housing in Hart is in crisis, with the District Council relying on 22 year old Local Plan, and the emerging Plan remaining untested and therefore a long way off adoption.  With homes costing 12 times average household income, the simple fact is Hart needs more homes now.  This decision prevents 280 new affordable homes being delivered to help the 1,300 families currently registered on the housing waiting list. The Council’s decision to refuse this sustainable, high quality, proposal offering a total of 700 homes, delivering an outstanding new community, is simply astonishing.’

The proposal which has no technical constraints and no statutory objections would have provided a vast array of community benefits including;

  • £10 million of investment to local primary and secondary schools
  • Facilitation of a new on-site primary school for 420 children
  • A new on-site 60 place pre-school nursery
  • £600k of investment to existing medical facilities
  • £6 million to essential local highway improvements as well as physical works across many local road, cycle and footpath routes, improving safety and easing congestion to address local concerns
  • A new community bus servicing both the new and existing communities of Elvetham Chase and Elvetham Heath to Fleet railway station and other local destinations
  • 82 acres of public open space including; on-site SANG, areas of play, woodland walks and informal space

Emma added, ‘this exemplar landscape led scheme would, we believe, become as loved locally as its predecessor Elvetham Heath. We remain 100% committed to the site and are reviewing our next steps.

They are obviously less than complimentary about Hart Council. We think that it is inevitable that Wates will appeal this decision. The full statement can be downloaded here.

Impact of Local Plan timetable on Elvetham Chase (Pale Lane)

Separately, we understand that the Government has postponed its planned publication of the new National Planning Policy Framework (NPPF) indefinitely. The new NPPF and associated new approach to calculating housing need was supposed to have been finalised by the end of January.

We understand that Hart District Council will press ahead with the consultation on the draft Local Plan. This will run from 9 February until 26 March 2018. This will be to test the soundness, legal compliance and the duty to cooperate.

This means that is is unlikely that the Plan will be examined by the Inspector until September 2018, or later.

This may well be enough time for Wates to lodge an appeal, for it to be heard and decided before the Local Plan is examined. There may not be sufficient grounds for the appeal to be rejected.

We have to hope that the right planning reasons can be found to overturn the appeal. And of course get the Local Plan in place on time, without the unnecessary new town.

Fleet resident calls for plans to regenerate Fleet

Plea to regenerate Fleet and Hart urban areas. Old Police Station in Fleet, Hart District, Hampshire

Plea to regenerate Fleet and Hart urban areas

An important letter has been published in Fleet News and Mail, pleading for the Hart Local Plan to be altered to include plans to regenerate Fleet and our other urban areas.

The author of the letter first sympathises with the plight of councillor Parker who voted reluctantly for the Local Plan. Councillor Parker said ‘an appalling plan is better than no plan at all’.

However, he goes onto criticise the CCH/Lib Dem leadership of the current administration, in particular calling out the two councillors who defected from Conservative to Community Campaign Hart without calling by-elections.

The main plea from the letter though is:

..our dysfunctional cabinet has ignored pleas for the [Local] plan to deliver regeneration of the urban areas (especially Fleet) and has favoured unnecessary greenfield development….

Since the change in administration last year, HDC has become less transparent, and does not encourage engagement with the electorate.

Meetings in public do not welcome participation from the public, and the bureaucracy is weighted in favour of councillors and officers.

Interestingly, the author comes from Fleet.

We could not agree more.  The disastrous policy SS3 setting out plans for an unnecessary new town should be dropped from the Local Plan. In the fullness of time, this policy should be replaced by plans to regenerate Fleet and other urban areas. Please join us in delivering this message when the consultation is launched.