Challenge the ridiculous housing target in the Local Plan Consultation

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Challenge the ridiculous housing target

Challenge the ridiculous housing target in the Local Plan consultation

The main objection to the draft Local Plan is the ridiculous housing target. We believe the Strategic Housing Market Assessment target of 8,022 is too high. Despite that, Hart have added more than 2,000 houses to this target and plans to build 10,185 houses.

This puts massive pressure on the district and puts many greenfield sites such as Murrell Green, Winchfield, Grove Farm (Netherhouse Copse), and Pale Lane (Elvetham Chase) at risk. Moreover, this rate of housebuilding will be carried forward in future planning periods, making it inevitable we end up with unattractive urban sprawl.

We believe the housing target should be a more reasonable 5,144 which will meet the changes driven by demographic change, immigration and deliver social housing for those who cannot afford to rent or buy their own home. The remaining housing target can be met from brownfield sites alone.

The detail of our analysis is shown below. Please object to this ridiculous housing target by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
Download Now!323 Downloads

There are several lines of argument:

  • Vastly Over-achieves against Government housing policy
  • Strategic Housing Market Assessment target of 8,022 is too high
  • Hart’s decision to increase the target by 2,000 dwellings to the target is inappropriate

Vastly over-achieves against Government housing policy

The 2012-based government projections of population and number of households, points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-170,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

It is worth noting that the DCLG forecasts project forwards the recent high level of inward migration to the UK. Government policy and the impact of Brexit is likely to reduce inward migration so, it is likely the 2014-based projections are too high. Moreover, the DCLG forecasts also assume a reduction in average household size.

The 2016 Strategic Housing Market Assessment (SHMA) has arrived at a ‘need’ of some 8,022 new dwellings over the plan period.

For Hart, the raw 2014-based DCLG forecasts, as opposed to the 2012-based forecasts used in the SHMA,  would result in a starting point for housing need of c. 4,473 new houses (see Figure 6 of the SHMA).  Hart’s overall housing requirement as defined in the SHMA is some 79% above the starting point. The ridiculous housing target of 10,185 used in the Local Plan is some 127% above this basic requirement.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.

There might be some justification if this process had resulted in more house building. But it is clear from a recent House of Lords report that it has not:

Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over 240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.

We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding.

This is borne out by local experience, where, as of 1 April 2016 there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

The unintended consequence of this policy is effectively state-sponsored profiteering on behalf of the major housebuilders. It is plainly ridiculous that the housing target in Hart’s SHMA and the SHMAs of neighbouring areas are massively above the requirement suggested by demographic change, immigration and changes to household size.  Accordingly, the housing target and the Local Plan should be adjusted downwards to more realistic levels.

Strategic Housing Market Assessment results in a ridiculous housing target

Following on from the above, we can now analyse the reasons why the SHMA has arrived at a ridiculous housing target that is too high. We can also arrive at a more realistic figure.

Inappropriate Starting Point

First, the starting point used is the 2012-based DCLG forecasts, or around 5,334 dwellings over the plan period. The starting point should be revised downwards by using the more up to date 2014-based forecasts which would result in a starting point of 4,473 dwellings.

The SHMA then uplifts the starting point in response to market signals to provide more housing for what are termed suppressed households. These are, for instance younger people in the 25-34 age bracket who are still living with their parents and are unable to afford to form their own household. Almost by definition these people cannot afford to rent their own accommodation or buy their own house. The SHMA suggests a 15% uplift on the start-point. Even though some element of household size reduction is included in the DCLG forecasts. We would agree with this and increase the need by 671 units to arrive at a total housing need of 5,144. However, we would insist that these units are delivered as social rented housing. The proposed Hart Development Corporation could be an appropriate vehicle to deliver these homes, or partnerships with local Housing Associations.

Affordable Housing Uplift

The SHMA then makes a further upward adjustment for affordable housing. This is to help those able to afford to rent, but not able to access home ownership. By definition, these people are already housed. It is therefore difficult to see how building more houses will assist these people. If they can afford to rent, then it is very likely that they can afford to service a mortgage, but cannot afford a deposit. The way to help these people is with shared ownership or ‘Help to Buy’ schemes. It is also worth noting that some of these people may be taking an entirely rational decision to rent and not buy because they think property prices are too high and thus represent a poor investment when assessing potential future returns.

The only plausible reason to build more houses to help these people would be that it would lead to a general fall in house prices. This is a false premise as discussed by Ian Mulheirn of Oxford Economics here.

The extent that we do see high house prices as a policy priority in and of themselves (e.g. for wealth distributional reasons), this is not a problem that will be solved by any plausible amount of new supply. Many econometric studies in the UK (see page 43 here for a comparison of results) have concluded that a 1 percent increase in the housing stock per household will only cut prices by at most 2 percent. Consequently, even if we were to add 300k new houses per year (about 150k in excess of household formation, approaching 0.5 percent of current stock), this would only lower prices by about 1 percent per year. This is peanuts in the context of price rises over the past 20 years….

Building many more houses that people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.

Therefore, the affordable housing need should be seen as the proportion of overall housing need that should be built as ‘affordable’ units. The SHMA adds 504 extra affordable units to the total housing requirement. However, this 504 units represents only 11.2% of the 4,473 raw housing need. Hart’s target is to build 40% affordable housing and recent delivery has averaged just over 20%. If this were to continue and the housing target were revised to start at 4,473, then around 900 affordable homes would be delivered in addition to the 671 social rented units identified above.

Jobs Growth Adjustment

Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area, a shortfall of 15-30,000, or almost all the projected job growth.

Second, the projection of 1,200 jobs per annum is far more than the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, the SHMA uses a very circular argument to account for the number of jobs. The argument is: the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs.

They then decide we will need to import some extra people and those people will need houses. The SHMA then acknowledges that most of these people 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 is not an expression of the ‘need’ for the district, nor is it ‘sustainable development’. The SHMA itself recognises that most of these additional people will, in fact, work outside the district. This is against the sustainability principles of the NPPF.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs, that someone thinks might be possible to create in Hart. Then those people will add to the strain on Hart’s infrastructure (roads, schools, healthcare), but work outside the district. This is not ‘sustainable development’ on any reasonable interpretation of the phrase. Moreover, those exporting districts should already be planning to house those people.

Accordingly, there should be no jobs growth uplift in the SHMA.

This leaves us with a housing need for Hart of 5,144 made up of 3,573 open market units, 671 social rented units and 900 affordable homes made available through ‘Help-to-Buy’ or shared ownership.

Hart’s decision to increase the target by 2,000 dwellings results in a ridiculous housing target

It follows from this that Hart’s decision to add a further 2,000 units to the SHMA to establish an alleged ‘policy on’ ridiculous housing target of 10,185 is both specious and unnecessary:

  • The needs of both suppressed households and those who can rent, but can’t buy are already met by the revised housing target identified above
  • The addition of a further 2,000 homes would simply import even more people into Hart, most of whom would work outside the district, again contrary to the sustainability principles of the NPPF.
  • There is no evidence that this level of development would lead to falling house prices. Indeed, with residential land priced £4.1m per hectare (SHMA section 9.12) and a density of 30 dph, land prices alone would amount to £133,000 per dwelling. Build costs, S106 contributions and developer profits would see average house prices around £400,000.
  • It is not at all clear why we must build 2,163 extra houses to meet an alleged additional affordable housing need of 865
  • Rushmoor has already said it can meet its share of the over-inflated housing target. Reducing the overall SHMA targets for the whole Housing Market Area (HMA) will release pressure on both Surrey Heath and Rushmoor, such that ‘additional flexibility’ is not required
  • We are currently living in the most benign conditions for housebuilding in living memory. We are experiencing low absolute interest rates and negative real interest rates. The markets are awash with excess capital thanks to Quantitative Easing and the planning regime is very favourable to developers. As the House of Lords report referred to above indicates, planning permission is being granted at a much faster rate than new homes are being built. The only conclusion one can draw from this is that the market cannot absorb many more houses than are being built without a major fall in house prices. The house builders will not build faster as it will damage their profitability. Simply granting permission for more housing through blighting more of our green fields will not impact house prices nor will it lead to more houses being built.

It would be appropriate for the Inspector to express an opinion on the ridiculous housing target in the SHMA and the extra 2,000+ houses. Hart should set out a ranking of sites it wishes to take forward, such that the spatial strategy can be easily adjusted depending upon the final housing target that is agreed.

Draft Local Plan has no infrastructure plans or costings

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Hart Local Plan contains no infrastructure plans or costings

Local Plan contains no infrastructure plans or costings

The draft Local Plan contains no infrastructure plans or costings. We think this is a massive error by the council that makes the draft Local Plan unsound.

If you agree, please download from the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
Download Now!323 Downloads

Here is our analysis of the infrastructure weaknesses in the Local Plan

Local Plan contains no infrastructure plans

Paragraphs 7, 17 and 177 of the NPPF/NPPG make clear that infrastructure should be planned alongside housing. Para 395 of the draft Local Plan says there’s a Draft Infrastructure Delivery Plan (IDP) available for viewing alongside the Local Plan. However, no IDP has been made available.

Given that back in 2013, a £78m infrastructure funding deficit was identified, this is a critical omission. In particular, we think Hart Council should focus on:

  1. The requirement for a new secondary school. The Murrell Green proposal includes a site for a new school, albeit on top of a high-pressure gas main. However, no evidence has been presented to demonstrate a new secondary school is required. WeHeart Hart research shows that a new secondary school may not be required, and the sustainability assessment for Murrell Green mentions a 9% surplus of places.
  2. Railways. SW Trains have indicated that the mainline rail route to London is 20% over-crowded at present and is forecast to be 60% overcrowded by 2043. Para 58 of the Local Plan makes no mention of this, and there is no apparent plan to improve capacity.
  3. Our roads are becoming increasingly congested and generally in a poor state of repair. There is no sign that the council has carried out an overall road transport assessment to establish the level of investment required to improve our roads so they can cope with the scale of development that is being proposed
  4. Paras 65 & 66 make no mention of groundwater and surface water flood risk in Winchfield, which was identified in the Sustainability Assessment
  5. Para 68 provides no plan to fix the acknowledged wastewater capacity issues
  6. None of the plans for the strategic sites include proper plans for sports and community facilities such as allotments.

Local Plan contains no cost analysis for infrastructure requirements

Neither the Local Plan nor the Sustainability Assessment contain a financial assessment of the alternative means of providing the housing need. We think this is a very significant omission.

We already have a £78m infrastructure deficit, so this is a critical issue. The financial analysis should include:

  1. An assessment of the major infrastructure requirements generated by each of the approaches you have considered. These include new roads; road improvements such as roundabouts; railway station and parking improvement; railway line capacity improvements; schools; healthcare; fixed and mobile telecommunications, flood prevention, wastewater disposal and social infrastructure. A high level cost of each item should be provided.
  2. An analysis of the likely contribution that could be expected from developers and other providers to meet these requirements.
  3. An estimate of the likely contributions from Government such as New Homes bonus and grants to support brownfield development.
  4. A calculation of the gap between the requirement and the contributions for each development scenario

Residents should then be able to see the financial impact of the proposals and make decisions based on that.

Local Plan: Brownfield sites protected from redevelopment

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

Brownfield sites protected from redevelopment

The draft Local Plan put forward by Hart Council includes proposals to make brownfield sites protected from redevelopment. We think this proposal is bonkers and should be challenged in the consultation.

There are two different types of protection proposed in the Local Plan. The first identifies “Strategic Employment Areas”:

  • Bartley Wood, Hook
  • Bartley Point, Hook
  • Cody Park, Farnborough
  • Meadows Business Park, Blackwater
  • Osborne Way, Hook
  • Waterfront Business Park, Fleet

These sites are “given the highest protection and safeguarding against loss to non-B-class employment uses by protecting them for B-class uses”. We would agree that some of these sites should be given some protection. But some of the sites, particularly in Hook suffer from high vacancy rates. Indeed, some of the sites have already been converted to domestic use.  Recently the owners of the Virgin Media offices at Bartley Wood have sought advice on whether planning permission would be required to convert some of those buildings to housing. This demonstrates that there is little demand for offices on even the sites of alleged ‘strategic’ importance.

The trouble with this policy is that it cannot stop conversion of offices to apartments. These types of development require no planing permission. Nor do they bring any S106 or CIL contributions to infrastructure. Moreover, they don’t provide an attractive sense of place. By preventing proper redevelopment Hart is cutting off vital infrastructure funding. This makes no sense whatsoever.

The second type of protection is to “Locally Important Employment Areas”:

  • Ancells Business Park, Fleet
  • Blackbushe Business Park
  • Eversley Haulage Yard
  • Eversley Storage
  • Finn’s Business Park, Crondall
  • Fleet Business Park, Church Crookham
  • Grove Farm Barn, Crookham Village
  • Lodge Farm, North Warnborough
  • Murrell Green Business Park
  • Potters Industrial Park, Church Crookham
  • Rawlings Depot, Hook
  • Redfields Business Park, Church Crookham
  • Optrex Business Park, Rotherwick

These sites are offered a lower level of protection, but nevertheless the council is putting in place barriers to redevelopment.

Poor brownfield sites should not be protected from redevelopment

The reason this is a bad policy is that 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 policy should be reversed, particularly as it is a direct contravention of a statement made by the council leader, who said there were no plans to restrict the development of brownfield sites at a council meeting in September 2016:

https://www.hart.gov.uk/sites/default/files/4_The_Council/Council_meetings/M_Archive/16%2009%20Council.pdf )

Please respond to the Local Plan Consultation

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
Download Now!323 Downloads

FOI request reveals Winchfield failed testing

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Flood Taplins Farm Lane 28 March 2016 shows why Winchfield failed testing

Flood risk means Winchfield failed testing

The documents that reveal why Winchfield failed testing have been revealed by persistent efforts from Winchfield Action Group. A Freedom of Information request has revealed the results of a new testing document. The full document can be downloaded on the link below.

In summary, the main issues were impact on:

  1. Historic Environment
  2. Bio-diversity
  3. Landscape
  4. Water Quality
  5. Flood risk

However, in our opinion, the impact of flood risk was massively downplayed in the report. More detail is given in the analysis below. Moreover, some of the alleged positives in the report are also complete nonsense.

For instance, they claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is expanded upon in the Sustainability Assessment – they mean 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.

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 completely ignore research that shows higher density development in urban areas is much more sustainable than green field development.

This leaves the Local Plan in something of a pickle. Their preferred green field site of Murrell Green has been severely impaired by the presence of a Major Accident Hazard pipeline and their obvious second choice is not viable.

This puts at risk the other green field sites in the district, namely Pale Lane (Elvetham Chase) and Netherhouse Copse (Grove Farm). At the same time, Hart Council is seeking to protect our brownfield sites from redevelopment. These problems arise because they are proposing a ridiculous housing target of over 10,000 dwellings.

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
Download Now!323 Downloads

Detail of how Winchfield failed testing

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

First, they 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. The image at the top of this post documents just one of those events. The posts 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).

They seem to gloss over the flood risk being over 55 on a 74 point scale for five of the eight SHLAA sites they consider.

Winchfield Strategic Assessment - Flood Risk 2

Winchfield Strategic Assessment - Flood Risk 3

Winchfield Strategic Assessment - Flood Risk 4

Winchfield fails testing – Strategic Assessment
Winchfield fails testing – Strategic Assessment
Download Now!340 Downloads

Conservatives ousted from power at Hart Council

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Breaking News: Conservatives ousted from power on Hart Council

Conservatives ousted from power at Hart Council

In a dramatic move the Conservatives have been ousted from power at Hart Council. Even though they are the largest party, they hold only 14 of the 33 seats.

The joint Chief Executive, Patricia Hughes confirm the move in a tweet last night. Liberal Democrat party group leader Dave Neighbour has been elected as leader of the council. He announced the members of his cabinet, but not the respective portfolios. They will be councillors Ambler, Bailey, Cockarill, Collett, Oliver, Kinnell, James Radley. All these councillors are from the Liberal Democrats and CCH. This confirms there will be no places for the Conservatives.

[Update – Portfolio positions announced by Hart Council]

  • Cllr David Neighbour – Leader and Cabinet Member for Finance
  • Cllr James Radley – Deputy Leader and Cabinet Member for Services
  • Cllr Simon Ambler – Cabinet Member for Partnerships
  • Cllr Stuart Bailey – Cabinet Member for Housing
  • Cllr Graham Cockarill – Cabinet Member for Planning
  • Cllr Adrian Collett – Cabinet Member for Regulatory and Community Safety
  • Cllr Sara Kinnell – Cabinet Member for Leisure, Health and Wellbeing
  • Cllr Alan Oliver – Cabinet Member for Contracts

[/Update]

Liberal Democrat, Gerry Crisp will become chairman. The deputy chair position will be taken by Wendy Makepeace-Brown of CCH.

We understand the following people have been elected as chair of the various committees:

  • Chris Axam (CCH) – 5 councils partnership
  • Gill Butler (CCH) – Licensing
  • Graham Cockarill (Lib Dem) – Planning
  • Ken Crookes (Conservative) – Overview and Scrutiny
  • John Kennett (Conservative) – Staffing
  • Wendy Makepeace-Brown (CCH) – Audit

The council coup has been facilitated by the defection of two Tory councillors, Sara Kinnel and Richard Woods to CCH late last year. We do think that changes of party allegiance should lead to by-elections. Where such ‘crossing of the floor’ leads to a change in administration, the case for by-elections is unanswerable in our opinion.

We are yet to see what impact, if any, there will be on the Local Plan.

Hart Draft Local Plan Consultation – Our Response

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We Heart Hart Campaign Logo

We have been working hard to produce our response to the Hart Draft Local Plan Consultation. It has taken hours of work to go through the Local Plan document and the associated evidence base. And still more work to formulate what we think is a sensible response.

This is our last chance to shape our district for decades to come. So please do take the trouble to engage and respond.

A great deal of work has gone into the draft Local Plan, but there is much to comment upon and challenge. We have framed our response around several themes:

  1. The outrageous 10,185 housing target, 2,000 houses over the over-inflated 8,022 target outlined in the Strategic Housing Market Assessment.
  2. It is simply wrong to protect our derelict vacant offices from redevelopment
  3. The missed opportunity to regenerate our urban areas, most notably Fleet
  4. The lack of an infrastructure plan
  5. The absence of any financial analysis of the alternative ways of meeting our housing needs
  6. The unnecessary allocation of green field sites to the plan, in particular Murrell Green
  7. Challenge the sustainability assessment that ranks Winchfield as the next best green field option.

Over the coming days and weeks, we will be adding further detail to our comments. But for now, we have produced a summary version of our response. This is available for download below. Please do download it and review it. Please do make amendments into your own words and submit it to [email protected] before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

The document we have provided is in the Council’s ‘Word’ format, ready for you to add your personal details on the first pages, edit the comments provided and add your demographic details in the last pages.

 

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
Download Now!323 Downloads

 

 

Independent Expert says Hart housing target is too high

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Alan Wenban-Smith of Urban and Regional Policy blasts Hart housing target

Independent expert, Alan Wenban-Smith has reviewed the latest Strategic Housing Market Assessment (SHMA) and concluded that the Hart housing target is way too high.

Regular readers may recall that the same expert examined the previous version of the SHMA and came to similar conclusions.

The crux of his arguments are as follows:

  1. The SHMA uses an inappropriate start-point for analysis. It uses the 2012-based population projections instead of the more up to date 2014-based projections. Making this change would knock around 850 houses off the start point
  2. The adjustments made for so-called market signals and affordable housing are inappropriate.
  3. The massive upwards adjustment for alleged jobs growth would result in loads more people moving to Hart. These people would then work elsewhere which is contrary to the sustainability principles of the National Planning Policy Framework

Taken together, his suggested adjustments would reduce the Hart housing target from around 8,000 to around 4,500. We have already built or planned more then 4,500 houses, so the Local Plan would become irrelevant.

We do not quite agree with all of his conclusions. If it were up to us, we would add some extra social rented housing to help those who cannot afford to even rent their own home.

But nevertheless, it is astonishing that Hart Council has decided to add a further 2,000 houses on to the already inflated SHMA. Hart’s approach is putting unnecessary pressure on our valuable green fields.

We will be compiling our suggested responses to the Local Plan consultation over the next few days. Please do keep checking in as we add further content.

The full report from Alan Wenban-Smith on the Hart housing target can be downloaded from the button below.

Independent Expert critique of Hart SHMA
Independent Expert critique of Hart SHMA
Download Now!290 Downloads

Motion of No Confidence in Hart District Council submitted

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Breaking News: Motion of No Confidence submitted in Hart District Council

Motion of No Confidence submitted in Hart District Council

A motion of no confidence in Hart District Council has been submitted by Community Campaign Hart (CCH), (or as some call them Completely Concrete Hart) and the Liberal Democrats.

Apparently, they are unhappy that a new settlement at Winchfield has not been included in the Local Plan. They plan to push for Winchfield to be re-included if they manage to take over.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

We think this is a bad idea for a number of reasons:

  1. This will add extra delay to the Local Plan process, adding to the risk that sites like Grove Farm (Netherhouse Copse) and Pale Lane (Elvetham Chase) will be given the go ahead at appeal before the Local Plan can be put in place
  2. Winchfield has failed testing. The main issues with the proposal are:
    • groundwater and surface water flooding,
    • Cost of new road infrastructure and the need to travel to Fleet for main services
    • requirement for new wastewater treatment works
    • too much delivery risk concentrated in one site
    • impact on landscape
    • impact on heritage assets and SSSIs
  3. CCH have completely failed to oppose the main issue: we are being asked to build too many houses. Hart Council have arbitrarily added an extra 2,000 houses to the already inflated SHMA figure of 8,000, giving a total over 10,000 houses. Tackling this would mean we don’t need a new settlement at Winchfield or Murrell Green, nor would we need Pale Lane or Grove Farm
  4. A new settlement at Winchfield will likely have a major impact on congestion in Church Crookham and the western edge of Fleet.

We predict a stormy council meeting on 25 May.

[Update  – Statement from Conservative Council Leader]

Conservative Council Leader Stephen Parker commented:

We have a clear track record of success in running Hart Council. Despite cuts to Hart’s government funding we used Conservative ministerial contacts to reduce the cuts, froze Council tax for 6 years and made minimum increases for the last two years. At the same time we made innovative partnerships to make sure that no cuts were made to our services or to our support to the voluntary sector. We delivered the new Hart Leisure Centre, a superb facility which pays for itself with no increases to Hart’s Council tax. We listened to residents in making our Local Plan which maximises use of brownfield sites and protects our towns and villages from unwanted expansion. At no time in the last eight years of Conservative leadership have they challenged any of these successes. Residents will no doubt look forward to reading their joint manifesto.

[/Update]

[Update 2 – statement from CCH]

Statement about motion to bring about a vote for Council Leader

Until fairly recently Hart District Council had a democratic process of electing the council Leader every year at the AGM. This right was taken away by the then Conservative administration, presumably because they realised that as is the case now there would be times when they did not have a majority on the council.

The Conservatives forced through the instigation of a 4 year term for the council Leader, the maximum period they could have gone for without falling foul of legislation.

Out of 33 councillors there are 14 Conservative, 10 Community Campaign, 8 Lib Dems and 1 Hook Independent. No one party have the 17 councillors required to hold a majority on the council.

The Community Campaign have asked the current Leader if he’d be willing to continue as Leader with a proportional Cabinet made up of 3 Conservatives, 2 Lib Dems and 2 Community Campaign members. Given the proportionality of such a Cabinet it does not seem to be an unreasonable request.

We await his response. However, should the Conservatives not wish to work with a cross party partnership then we believe that the Council should have the right to elect a new Leader.

The nature of the council’s constitution is such that in order to bring about the opportunity to elect a new Leader a motion to withdraw support for the current leadership needs to be lodged 7 clear working days before the council’s AGM.
​
The full motion moved by Cllr. James Radley of the Community Campaign reads;
The council wishes to use this AGM, as it represents the traditional point in the municipal year, to undertake a vote for the leader of council. To bring about such a vote the constitution requires that a vote to remove the current leader first be tabled. To this end this council retracts support for the current leader and does so as required by the constitution by voting to ‘remove from office the current Leader of the Council and agrees that a new Leader should be elected forthwith’.

[/Update 2]

[Update 3: Lib dems tweet to say they don’t support new settlement at Winchfield]

NE Hants Lib Dems statement about Winchfield

[/Update 3]

Health and Safety Executive criticises Hart Council

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Health and Safety Executive (HSE) Logo

Health and Safety Executive (HSE) Logo

The Health and Safety Executive (HSE) has criticised Hart District Council for not clearly marking on a map the Major Accident Hazard pipelines that pass through the district.

Regular readers will recall that the Master Plan for the proposed new settlement at Murrell Green does not refer at all to the high pressure gas main that runs through the site.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

We alerted the HSE to this and invited them to comment on the Draft Local Plan that is currently out for consultation. They have written to Hart Council and identified two further potential issues:

We have concluded that there is the potential for land allocated in your plan to encroach on consultations zones.  The land allocations that could be effected (sic) are as follows

Map 30 – Murrell Green (Proposed Strategic Housing-led Development Policies SC1-SC4)

This allocation encroaches on the Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067 Gaston Wood/Murrell Green(PO65)

It also has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7069 Crockmore Farm/Bramshill(P067)

Map 7 – Eversley Centre – SC5

This allocation has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7083 Bramshill/The Devil’s Highway(P086)

The HSE then go on to spell out their recommendations for how local authorities should identify such hazards in their Local Plans (emphasis ours)

Identifying Consultation Zones in Local Plans

HSE recommends that where there are major hazard establishments and MAHPs within the area of your local plan, that you mark the associated consultation zones on a map. This is an effective way to identify the development proposals that could encroach on consultation zones, and the extent of any encroachment that could occur. The proposal maps in site allocation development planning documents may be suitable for presenting this information. We particularly recommend marking the zones associated with any MAHPs, and HSE advises that you contact the pipeline operator for up-to-date information on pipeline location, as pipelines can be diverted by operators from notified routes. Most incidents involving damage to buried pipelines occur because third parties are not aware of their presence.

Clearly Hart Council has failed to follow Health and Safety Executive Guidelines.

The full letter from the HSE can be found here.

Hart Council launches Local Plan consultation

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Hart District Council Logo

Hart Council has launched a Regulation 18 consultation into the draft Local Plan. The consultation will be open until 5pm on 9 June 2017.

Drop in sessions will be running at the following dates and locations:

  • Tuesday 2 May – 2pm to 8pm – Hook Community Centre, RG27 9NN
  • Wednesday 3 May – 2pm to 8pm – The Harlington Centre, Fleet, GU51 4BY
  • Monday 8 May – 2pm to 8pm – Victoria Hall, Hartley Wintney, RG27 8RE
  • Wednesday 10 May – 2pm to 8pm – The Tythings, Yateley, GU46 7RP
  • Thursday 11 May – 2pm to 8pm – Ridley Hall, South Warnborough, RG29 1RQ
  • Monday 15 May – 4.30pm to 8pm – Hawley Leisure Centre, GU17 9BW

The consultation materials can be found here.

Once we have had chance to absorb all the materials, we will be posting our advice on how to respond to the consultation.