Return of the New Town: Winchfield fights back

We Heart Hart and Winchfield Parish Council (WPC) are fighting back against the decision to award funding for the  new town.

WPC has written to the Secretary of State demanding that the decision to award £150,000 of capacity funding to support the delivery of the Hartley Winchook/ Shapley Heath garden community new town be reversed.   In addition, We Heart Hart has written to MHCLG making a similar request, using slightly different arguments. We understand that the Rural Hart Association will also be making representations to MHCLG.

A summary of the WPC letter is shown below, together with links to the full text. The full text of the WHH letter follows.

Winchfield fights back: WPC Letter

The letter has the support of Hartley Wintney, Dogmersfield, Crondall, Greywell and Long Sutton & Well Parish Councils. The Parish Councils of Eversley, Odiham and South Warnborough have made known to WPC their concerns about the proposed development and will consider adding their full support to the letter when they next meet. WPC’s letter highlights the following concerns:

  1. The Inspector’s findings following the independent examination of the Local Plan rejected the SHGV proposal, which followed HDC’s Garden Village Application in November 2018.
  2. HDC’s ongoing promotion of SHGV is not supported by the Inspector’s findings on the submitted Local Plan and he is quite clear that other options need to be considered in an impartial manner.
  3. The absence of sound justification for bringing forward SHGV (as it is not needed to meet identified housing needs) and the lack of evidence to demonstrate that the proposal is deliverable and sustainable was confirmed by the Inspector’s findings on the submitted Plan.
  4. The numerous shortcomings with HDC’s bid when considered against the Garden Communities prospectus lead us to question how it has been successful.
  5. HDC pre-determined the plan-making process, and failed to provide the evidence to the Inspector to demonstrate that it had impartially assessed reasonable alternatives. If HDC proceed with a Local Plan review as indicated based on SHGV as its chosen long term growth strategy, it will irresponsibly overlook the Inspector’s criticisms of the current Plan’s failure to impartially assess reasonable alternatives, and continue to ignore local opinion. HDC’s bid to be included in the Gardens Community Programme is a further demonstration of their continuation of pre-determine the planning process.
  6. HDC’s ongoing promotion of SHGV is not supported by the local communities directly impacted by this large scale proposal.

The full text of their letter can be found here. And the appendix can be found here.

Winchfield Fights Back: We Heart Hart letter

The full text of our letter is set out below:

Dear Ministers,

 Re: Hart District Shapley Heath Garden Community Funding Award

My name is David Turver. I run a campaign in Hart District called We Heart Hart. We have taken an active role in the Hart Local Plan, and I was invited to speak at the examination hearing. We have successfully campaigned against the new settlement proposal. We believe that urban regeneration and brownfield development is a much more sustainable and better way to deliver Hart’s longer term development needs.

I note that you have recently awarded £150,000 of capacity funding to Hart District Council to support the delivery of the Shapley Heath so-called Garden Village in Winchfield/Murrell Green.

I would like to share with you some extra facts which may cause you to reconsider your decision. The main letter sets out the main points, backed up with links and references in the Appendices. I have copied my local MP, the leader of the Conservatives on Hart Council and your garden communities email address so you can obtain a soft copy of this letter and follow the embedded links if required.

New Settlement Policy SS3 not required and not sound

Hart’s Garden Community bid in November 2018 relied on Policy SS3 being found sound in their Local Plan examination. Policy SS3 proposed a new settlement in the same area of search as the proposed Shapley Heath development. The Local Plan itself acknowledges that the new settlement is not required to meet Hart’s housing needs. The Planning Inspector, Jonathan Manning, found that he had “a number of fundamental concerns with regard to the soundness of Policy SS3”. As a result, Hart Council has removed policy SS3 from the Local Plan to make the plan sound. See Appendix A for more details.

More work required to make new settlement sound leading to a delay of up to five years

The Inspector has said that much more work was required to make the new settlement sound:

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options. Any further SA work would also need to include additional standalone consultation….

I am also mindful that following further work, there can be no guarantee that the evidence would support it as the most appropriate long-term growth strategy or that Policy SS3 would be found sound.

There are several alternative options, including alternative sites and alternative strategies such as urban regeneration. So, it is clear that a new SA would be a considerable undertaking in its own right. In the risk assessment accompanying Hart’s bid they anticipated this outcome. Their mitigation was to press-on regardless with the new settlement DPD, independent of the Local Plan. I am not at all convinced that creating a DPD outside of the Local Plan process is in line with the planning regulations.

However, the Inspector makes clear that significant SA work and a standalone consultation ought to precede a new DPD.  Moreover, in Hart’s latest consultation into the modifications required to make the Local Plan sound, they have completely changed their tune. The Sustainability Appraisal Addendum says that “the AoS/DPD process will effectively be replaced by a different process, most likely a new Local Plan” (see Appendix B). The impact of this is that:

  1. The further SA work may conclude that there are better alternatives to delivering longer term growth. I know there are many in the District who support our local MP’s call for urban regeneration.
  2. Even if it is decided that a new settlement is the best long term growth option, the timescales for a new Local Plan process indicate that work on a new DPD will not start for a considerable time; maybe up to five years.

No plans to meet commitments in the Garden Community bid

In their bid, Hart committed to producing a New Settlement DPD in December 2019 if they received the Garden Community funding (see Appendix C). Yet, in response to recent questions at council, they confirmed that they have no current plans to start the additional SA work required by the Inspector; no plans to produce the New Settlement DPD and have not allocated any of the £786K budget set aside for the New Settlement in FY19/20. It might be expected that the wide scope SA work would take at least six months, plus a further 2-3 months for a consultation. It is therefore difficult to see how work can start on a new DPD this financial year. Therefore, it is difficult to see how the Garden Communities grant money can be spent effectively during this financial year.

Deceptive Communications

In addition, I am sorry to report that the Lib Dem/Community Campaign Hart led Hart Council has not been as open and transparent as one would hope in its communications on this matter.  Recently, the council was asked who had been informed that Policy SS3 had been found unsound and removed from the Local Plan. Their answers stated that both Homes England and MHCLG had been kept informed prior to the funding announcement. However, a subsequent release of correspondence shows that the removal of Policy SS3 was a passing comment to an official in Homes England in an email about a different subject. There is no record of MHCLG being contacted directly. I am therefore concerned that MHCLG may not have been aware that the new settlement had been found unsound between Hart Council’s bid and the award of funding in June 2019. It would be a shame if the Government awarded money to fund an unnecessary and unsound white elephant project.

Alternative options

Quite separately, Hart made a recent bid for funds under the Future High Streets scheme and was turned down. Our local MP, Ranil Jayawardena is running a campaign to support urban regeneration within Hart.

The catalyst for this could be the publicly owned civic quarter containing the Hart Council offices and the Harlington Centre. The area is ripe for mixed-use redevelopment including offices, homes, social and retail. If all levels of Government got behind this, it would spark interest in redeveloping the rest of the High Street, including the Hart Shopping Centre.

Conclusions

In conclusion, it is clear that the facts have changed since the bid was submitted.

  • Policy SS3 covering the Shapley Heath new settlement has been found to be unnecessary and unsound and removed from the Hart Local Plan.
  • There are no plans to conduct the wide ranging SA work required that might bring the new settlement back on to the agenda.
  • There is no guarantee that such work will conclude that a new settlement is the best option for long term growth.
  • It is inconceivable that such work could be completed during this financial year, meaning that work on a new settlement DPD could not even start before FY20/21, so the funds you have awarded could be wasted.

Therefore, I would be grateful if you could review your decision in the light of new facts. There are many residents of Hart who would be pleased if the Garden Communities funds were redirected towards regeneration of our decaying urban centres instead of concreting over the very green fields that make Hart such a great place to live.

Thank you for your kind consideration of these points. I understand Hart Council representatives are meeting with Homes England this month, so I hope you have time to re-consider the funding decision before that meeting. I look forward to your prompt reply.

Yours faithfully,

 

David Turver

cc:           Ranil Jayawardena MP (by email)

[email protected] (by email so the embedded links work)

Anne Crampton, leader of Conservative group on Hart Council (by email)

 

Appendix A: – Hart’s Assumptions and Inspector’s Report into Hart Local Plan

Here is Hart’s bid assumption that Policy SS3 would need to be found sound in the Local Plan:

Winchfield Fights Back - Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

The Inspector’s post-hearing letter about the examination of the Hart Local Plan can be found here.

May I draw particular attention to paras 17-39. A summary of his findings with respect to the Sustainability Appraisal and the New Settlement are shown below:

  • The ranking of Option 1b (the new settlement) “as the best performing under heritage is not justified”.
  • For land and other resources, the ranking of Option 1b “is also therefore not, in my view, robust”.
  • The Inspector decided that “the decision not to rank the options in terms of flood risk to be very questionable”.
  • On landscape issues the Inspector concluded:

Option 1b was ranked joint highest with Option 1a. However, it is unclear why this is the case, given that the proposed new settlement would result in the development of large areas of open countryside and Option 1a already benefits from planning permission and is largely previously developed land. Further, the post submission SA notes that Pale Lane is ‘relatively unconstrained’, but despite this and it being a smaller site / potential development, Option 3a is ranked lower than Option 1b.

  • The Inspector has this to say on the climate change ranking:

Option 1b has been ranked the highest under the category climate change. This is as a result of the potential for the proposed new settlement to deliver a district heating system. However, there is little evidence to suggest that this is a feasible or realistic option that is being actively pursued by the site promoters. I consider this raises doubt about the appropriateness of such a ranking.

  • The ranking for the impact on water was also criticised by the Inspector.

In conclusion on the SA the Inspector said:

In my judgement the scoring of Option 1b above or equal to other options is not justified by the evidence. As a result, I consider that Policy SS3 and its supporting text are not justified, as, on the currently available evidence, it cannot be determined that it represents the most appropriate long-term growth strategy.

I consider that the post submission SA is therefore not robust and should not be relied upon in support of the Plan.

In addition, the Inspector clearly states:

Given my earlier findings in terms of the housing requirement, Policy SS3 is not required for the Plan to be sound and, in light of my comments above, I consider that the most appropriate course of action would be to remove it (along with any other necessary subsequent changes) from the Plan through Main Modifications (MMs). This would allow the Plan to progress towards adoption without any significant delay to the examination process…

I consider that it would not be unsound for the Plan to retain the Council’s aspirations to plan for long-term needs beyond the Plan period, which could include the delivery of a new settlement. But, the Plan should clearly state that this, as a growth option, would need to be fully considered and evidenced in a future (potentially early or immediate) review of the Plan or a subsequent DPD…

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options…

I am also mindful that following further work, there can be no guarantee that the evidence would support it as the most appropriate long-term growth strategy or that Policy SS3 would be found sound.

 

 

Appendix B: Local Plan Modifications and Sustainability Appraisal Addendum

The main modification related to removing Policy SS3, New Settlement from the Hart Local Plan can be found below. The full consultation can be found here.

Winchfield Fights Back - Shapley Heath Policy SS3 removed from Hart Local Plan

Winchfield Fights Back – Shapley Heath Policy SS3 removed from Hart Local Plan

The Sustainability Appraisal Addendum accompanying the consultation into the Main Modifications to the Local Plan can be found here.

I draw your attention to page 2:

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

 

Appendix C: Bid Commitments and Lack of Current Plans

No doubt you already have a copy of their bid commitment. Here is the commitment to produce a New Settlement DPD for consultation by December 2019.

Winchfield Fights Back: Shapley Heath New Town Bid Timeline for DPD

New Settlement Bid Timeline for DPD

The draft minutes from the Hart Council meeting held on 25 July 2019 can be found here. I refer you to Q&A in Appendix A.

Here is the response that shows no plans to carry out the additional SA work required by the Inspector:

Winchfield fights back: No plan for SA work

Winchfield fights back: No plan for SA work

No plans to allocate budget:

Hart Council has no idea how it will spend £786K winchfield new town money

Hart Council Knows Nothing: No idea how much of £786K will be spent or when

No plans for a New Settlement DPD.

Hart Council has no plan for Winchfield New Town proposals

Hart Council Knows Nothing: No plan for New Settlement DPD

 

Appendix D – Deceptive Communications

Statement at Hart Cabinet in July that both Homes England and MHCLG were informed:

Winchfield fights back: Chairman Announcement MHCLG kept informed

Winchfield fights back: Chairman Announcement MHCLG kept informed

Question asking how MHCLG and Homes England were kept informed of the changing status of the New Settlement in Policy SS3 in the Hart Local Plan.

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

 

The subsequent release of correspondence shows only one email to Kevin Bourner informing him in passing of the removal of Policy SS3. This can be found here.

Key passage:

Winchfield fights back: HDC email to Homes England

Winchfield fights back: HDC email to Homes England

The only correspondence with MHCLG prior to the announcement is asking for an update on the announcement timetable. This email is not addressed to Simon Ridley who made the award.

 

 

 

 

Urban Areas not taking their fair share of homes part 2

Proposed percentage increase in dwellings by parish in Hart District New Town

Proposed percentage increase in dwellings by parish in Hart District New Town

Further to our post of yesterday, that showed the impact by parish of following a dispersal strategy, we have now created graphs to show the impact by parish of urban extensions and a new town.  In each case, it shows that the urban areas of the district are not taking their fair share of housing.

This demonstrates to us the need to step up efforts to follow a brownfield strategy and re-find the 1,400 units on brownfield sites that Hart lost after saying that 1,800 units on brownfield land could be readily quantified back in September 2015.

First, let’s take at the new town strategy.  The chart showing the %-age increase in dwellings by parish from 2011 to 2032 if we followed a new town strategy to meet the remaining need from now on is shown above.  The table showing how this has been calculated is shown below:

Proposed percentage increase in dwellings by parish in Hart District New Town Table

Proposed percentage increase in dwellings by parish in Hart District New Town Table

Of course, only 2,000 of the full 5,000 will be delivered before 2032.  We have distributed these across Winchfield (in others) and Hook parish in the same ratio of the overall delivery shown in the SHLAA.  However, the secret plan from the Winchfield Consortium showed the Murrell Green sites would be developed first, so this may understate the impact on Hook.

Now, let’s take a look at the Urban Extension option.  he chart showing the %-age increase in dwellings by parish from 2011 to 2032 if we followed an urban extension strategy to meet the remaining need from now, together with the table showing how this has been calculated are shown below:

[Update: The West of Fleet urban extension is actually in Crookham Village Parish so chart and table updated to show that]

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions 201-2032

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions 201-2032

 

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions Table 2001-2032

Proposed percentage increase in dwellings by parish in Hart District Urban Extensions Table 2001-2032

The urban extensions are at Pale Lane which is split across Elvetham Heath and Hartley Wintney parishes, west of Hook which is in Hook parish and west of Fleet (in Crookham Village Parish].

Finally, let’s re-look at the dispersal strategy, we covered in yesterday’s post:

Proposed percentage increase in dwellings by parish in Hart District - dispersal strategy

Proposed percentage increase in dwellings by parish in Hart District – dispersal strategy

Parish  2011 Census Dwellings 2011-2015 % of total  2011-2015 Number 2011-2015 % increase  Dispersal Proposal 2011-2032 % Increase
Crookham Village 1,630 7% 322 19.8% 177 31%
Elvetham Heath, Fleet, Church Crookham, Ewshot 14,879 45% 2,070 13.9% 466 17%
Hartley Wintney 2,222 10% 460 20.7% 290 34%
Hook 3,111 19% 874 28.1% 204 35%
Odiham/Long Sutton/ South Warnborough 3,142 5% 230 7.3% 583 26%
Yateley/ Blackwater 9,826 11% 506 5.1% 480 10%
Others 2,526 3% 138 5.5% 1,027 46%
Total 37,336 100% 4,600 12.3% 3,227 21%

If you would like to ask Hart to abandon the new town and urban extension ideas and create a brownfield solution to our housing needs, we urge you to respond to the Hart District Council consultation about the Local Plan and ask them to think again. We have created a dedicated consultation page and updated our two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation
Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes
Respond to Local Plan Consultation in 2 minutes

 

Fleet, Elvetham Heath, Crookham Village, Yateley, Blackwater and Ewshot not taking their fair share of housing

Proposed percentage increase in dwellings by parish in Hart District

Proposed percentage increase in dwellings by parish in Hart District.

Hart Council has published a lot of data related to the new consultation.  We have taken a look at it, come to the conclusion that the combination of the houses built or permitted since 2011, plus the proposals for dispersal show that our urban areas are not taking their fair share of housing. We think that Hart District should be trying harder to find brownfield sites in Fleet, Yateley and Blackwater to redress the balance and save our countryside (see slider of sites below).

Which would you rather preserve - derelict eyesore or our wildlife?

Which would you rather preserve – derelict eyesore or our wildlife?

The chart above shows the %-age increase in dwellings by parish by combining the data shown in the table in para 30 of the main consultation document. This gives the distribution of dwellings built or permitted since 2011:

Split of dwellings built or permitted since 2011 by Parish

Split of dwellings built or permitted since 2011 by Parish

It did look odd to us that the parishes of Elvetham Heath, Fleet, Church Crookham and Ewshot should be grouped together like they were to give the impression that these parishes had already taken a lot of housing.  Of course if you combine a number of parishes together, then it is obvious that their combined contribution is going to be larger than the individual parishes to which they are compared.

So, we started with the census data for the number of dwellings by parish, and combined them together in the same way Hart had, then added on the number of houses implied by the figure above, then added the number of houses proposed by the dispersal option and expressed the result as a %-age increase on the number of dwellings that were there in 2011:

Parish  2011 Census Dwellings 2011-2015 % of total  2011-2015 Number 2011-2015 % increase  Dispersal Proposal 2011-2032 % Increase
Crookham Village 1,630 7% 322 19.8% 177 31%
Elvetham Heath, Fleet, Church Crookham, Ewshot 14,879 45% 2,070 13.9% 466 17%
Hartley Wintney 2,222 10% 460 20.7% 290 34%
Hook 3,111 19% 874 28.1% 204 35%
Odiham/Long Sutton/ South Warnborough 3,142 5% 230 7.3% 583 26%
Yateley/ Blackwater 9,826 11% 506 5.1% 480 10%
Others 2,526 3% 138 5.5% 1,027 46%
Total 37,336 100% 4,600 12.3% 3,227 21%

This shows that the urban areas that include Fleet, Yateley and Blackwater will take the lowest %-age increase in housing. Whereas, places like Hook, Hartley Wintney and the other rural parishes  are going to take massive %-age increases in housing.

Of course, a new town would disproportionately impact Winchfield, but would also lead to 1,800 further houses in Hook and effectively join those parishes to Hartley Wintney, into a giant Hartley WInchook conurbation.  Even the proposed urban extensions will further increase the pressure on Hartley Wintney and Hook.

One of the proposed extensions, the so-called Pale Lane extension (SHL 52) is largely in Hartley Wintney Parish, and another of the extensions is to the west of Hook (SHL 173).

If you would like to ask Hart to abandon the new town and urban extension ideas and create a brownfield solution to our housing needs, we urge you to respond to the Hart District Council consultation about the Local Plan and ask them to think again. We have created a dedicated consultation page and updated our two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation
Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes
Respond to Local Plan Consultation in 2 minutes

 

Whitewater Valley Preservation Society Oppose Winchfield/Hook new town

River Whitewater Preservation Society 300x222

River Whitewater

The Whitewater Valley Preservation Society (WVPS) have struck a blow for common sense and advised their members to vote against the proposed Hartley Winchook new settlement in Winchfield and Hook parishes.

Their full advice can be found here.  The key quotes from their document are:

“The potential impact of 5,000 houses said to be at Winchfield, but especially those either side of the A30 at Murrell Green, upon the river and its valley will be significant. One other site which will have a significant impact on the river and valley is in Odiham parish at North Warnborough / Greywell”…

…”If, on looking at the table above, you are not convinced of the benefits of a new town, then in question 4 you
should rank Approach 3 last; and in question 5 you should rank Approach 4 first (this being the only one which
excludes the Winchfield new town)”…

…”The Hook sites at Murrell Green listed in the table above are all in the proposed Winchfield new settlement, and the Odiham site “COM004” would see the open fields between Greywell and North Warnborough developed with houses and sports pitches”…

…”And the second pair of questions asks to what extent you agree with the draft vision and whether you have any comments on the Vision. You may wish to point out, in response to either of these two pairs of questions that the level and location of the developments proposed will clearly make it very difficult to realise the vision.”

If you agree with WVPS and would like to make your voice heard and object to the new town idea, we urge you to respond to the Hart District Council consultation about the Local Plan and ask Hart to think again. We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside and our rivers.

Full version:

Responses to Local Plan Consultation
Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes
Respond to Local Plan Consultation in 2 minutes

 

Which parishes have seen most development Hart District?

Elvetham Heath near Fleet, Hampshire

Elvetham Heath near Fleet, Hampshire

There has been much controversy about how much development there has been in Hart District over the past few years, so inspired by a post on the Winchfield Action Group site, we thought we’d take a closer look at the data.

We have compiled a list by parish and ward of the number of dwellings in each area in 2001 and 2011, according to the census and the results are shown in the table below:

ParishWard2001 Census (Dwellings)2011 Census (Dwellings)% Increase
Blackwater & Hawley177218675.4
Bramshill9863-35.7
Church Crookham330933280.6
Crondall6887387.2
Crookham Village156316304.3
Dogmersfield1241283.2
Eversley5996508.5
Ewshot2292352.6
FleetCentral2235256514.8
FleetCourtmoor188819282.1
FleetNorth (inc Elvetham Heath)13602947116.7
FleetPondtail182018984.3
FleetWest185719786.5
Fleet Total91601131623.5
Greywell1041040
Hartley Wintney212622224.5
Heckfield137135-1.5
Hook2718311114.5
Mattingley2322382.6
Odiham & Long Sutton271228806.2
Rotherwick2052123.4
South Warnborough21326223
Winchfield2392587.9
Yateley79427959.2
Total34170373369.3

It should be noted that the data only runs up to 2011 and so misses out most or all of certain developments such as QEB in Church Crookham, Dilly Lane and Rifle Range Farm in Hartley Wintney, Edenbrook and the planned new developments at Hawley Park Farm, new development to the North East of Hook and at Watery Lane.

It does show that the area with the largest increase is what was known as Fleet North, which has now been split after incorporating Elvetham Heath.

It is not really for us to point fingers at different areas of the district.  We will let readers make up their own mind and draw their own conclusions from the data.

If anyone finds an error in any of the data, then please do get in touch and we will make any corrections that are needed.

[Update]

I was asked to provide updated data of the permissions and completions since 2011.  There is no easy way to get this data.  This is a copy of what I received:

The majority of the information (with details of location and parish) on housing completions and permissions for the next few years can be found in the following two published documents :

Appendix 2&3
http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/Hart%205%20yr%20supply%20statement%20at%201st%20October%202015.pdf

And http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/Final%20Dwelling%20Completion%20Figures%202014-15_for%20website.xlsx

It’s regrettable  that you only used figures from the superseded five year land supply (2001-2011) calculation in the Interim Housing Delivery Strategy which was superseded by the Five Year Land Supply Position Statement:
Five Year Housing Land Supply Position Statement, 1st October 2015
2014-15, and the Completions list from Hampshire County Council (1st April 2015) both of which were linked on the  council website “Current planning policy and guidance” referring to the local plan consultation, and also discussed at a council meeting.

I’m glad got said you’d incorporate the latest numbers, and look forward to seeing this. I believe you’ll find disproportionate housing allocation to the North and East of the region whilst minimal development in the centre, West or south.

I can confirm that I used neither of the Housing Land Supply documents to produce the table above.  As the original post says, the source for the above is the census.

The link to the pdf just gives a long list of sites in a form that it is impossible to analyse in any meaningful way, least of all by parish.  The spreadsheet contains a list of starts, completions and losses for 2014-2015, a summary of which by Parish is shown below.

Dwellings started completed and lost in Hart District 2014-15

[/Update]

Lock, stock and two smoking barrels

I present without further comment the contents of a letter I sent to Hart District Council yesterday (Friday 20 November 2015). Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Errors, omissions and anomalies in the (Strategic Housing Land Availability Assessment) SHLAA and consultation materials

Dear Messrs Daryl Phillips and Stephen Parker,

It is clear that Hart Council has been very busy, publishing a vast array of new material about the SHLAA and the materials to be used in the forthcoming consultation about Housing Options.  I have burned a considerable amount of midnight oil going through those materials in some detail, and I have identified material errors, omissions and anomalies that give me serious cause for concern that I would like to share with you.  The Excel workbook containing the amalgamation of the SHLAA Master List, the NHB data and the SHLAA detail is attached for reference. These fall into several broad categories:

  • Assessment of brownfield site capacity and delivery
  • Deliverable and developable sites not included in the Developing a Local Plan for Hart paper (DLP) nor the New Homes Sites Booklet (NHB)
  • Sites missing from NHB but in the SHLAA
  • Discrepancies between capacity shown in NHB compared to SHLAA detail
  • Sites shown in detailed assessment but not in master list
  • Sites assessed as “not currently developable”, but have been granted planning permission
  • Range of meanings of “not currently developable”
  • Lack of consideration of the economic aspects of housing options 
  1. Assessment of brownfield site capacity and delivery.

There are a number of components to this:

In Hart News in September, and again at cabinet on 1 October, it was said that brownfield capacity had increased to 1,800 units. Now, this has miraculously fallen by 75% to 450 units on some dubious grounds. First, para 41 of the DLP states correctly that years 6-10 need only “developable” sites to be included, beyond that you can be more vague about sites.  We are already 4 years into the plan period and, according to the land supply calculation based on the current inflated SHMA, we have 5.7 years of land supply.  Yet, you are only selecting sites to be included in your calculations that meet the most onerous criterion of being “deliverable”.  As you know I have two FOI requests outstanding with you, the first is inquiring about the disposition of the 750 brownfield units that we were told were achievable back on November 2014, and the second asking for the analysis to support the 1,800 figure.  It seems to me you have inappropriately applied criteria that are too onerous in order to artificially reduce the potential brownfield capacity.  An example of this would be excluding Bramshill, when everyone knows it will be preferable for this site to undergo some sort of redevelopment to stop the Grade 1 listed building decaying and of course the hideous 1970’s accommodation blocks need replacing too.

You have under-stated the brownfield capacity in the DLP, compared to the assessed capacity in the SHLAA documents. This is shown in the table below:

Parish/Ref Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High) Sum of Brownfield Capacity in Table 1 in DLP doc
Blackwater and Hawley 320 320 300
SHL100 320 320 300
Church Crookham 6 6 8
SHL28 6 6 8
Elvetham Heath 45 45 45
SHL104 45 45 45
Fleet 221 221 83
SHL113 12 12 17
SHL245 8 8 14
SHL320 150 150 20
SHL322 37 37 17
SHL41 6 6 6
SHL42 8 8 9
Grand Total 592 592 436

 

This shows that the capacity shown in the DLP (excluding the 20 units from the sites with planning permission) is some 156 units lower than your own assessments in the SHLAA documents with most of the discrepancy arising from sites SHL320 & 322.  Correcting this would reduce the net requirement by 156 units.

In Figure 2 of the DLP, you assert that 52% of the development completed or where permission has been granted since 2011 is on brownfield sites. Yet at September Council, a question was asked along similar lines and the response was “these figures exclude brownfield sites that require planning permission, because those are not currently split between greenfield and brownfield developments”.  This leads one to conclude either that you have simply made up the figures in the DLP, or you knowingly misled the Council and the public in September.  Which is it?

  1. Deliverable and developable sites not included

[updated with this note]

There’s a large number of deliverable and developable sites that are in the SHLAA but not apparently referred to in the DLP or the NHB.  A list if these is shown in the table below (some of which are in the NHB):

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 320 320
SHL100 320 320
Church Crookham 6 6
SHL28 6 6
Elvetham Heath 45 45
SHL104 45 45
Fleet 25 243 248
SHL113 12 12
SHL245 8 8
SHL275 25 12 17
SHL320 150 150
SHL322 37 37
SHL41 6 6
SHL42 8 8
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Hook 550 550
SHL1&2 550 550
South Warnborough 16 16 16
SHL172 16 16 16
Grand Total 41 1,186 1,191

The land supply document shows a total of 3,878 units built, permitted or deliverable up until 1 April 2015, some 722 below the 4,600 figure you assert in the DLP.  I accept that 340 units from SHL1 & 2 and 10 from SHL69 are included in the land supply.  But the land supply does not include 300 units from Watery Lane.  Netting all of this off, then there are around 5,000 units already accounted for by being completed, permitted or deliverable, which would reduce the current net requirement by ~400 units compared to what you assert in the DLP.

  1. Sites missing from NHB but in the SHLAA

There are 76 units on sites in the SHLAA that are not already on the brownfield list and not strategic sites that do not appear in the NHB.  These are shown in the table below:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Fleet 10 10
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Heckfield 5 5
SHL157 5 5
Mattingley 48 48
SHL160 48 48
Yateley 7 7
SHL18 7 7
Grand Total 76 76

 

This raises the question as to why these sites have not been included in the NHB process either as selected or rejected sites.

 

  1. Discrepancies between capacity in NHB and SHLAA

There are material discrepancies between the site capacities shown in the NHB and those in the SHLAA.  Sometimes the NHB can be above the SHLAA figures and sometimes below.  But overall, adding up all of the sites where the NHB capacity is outside the range of SHLAA lower and upper limits, the NHB shows a lower capacity of some 1,500 units.  This demonstrates that the potential capacity of dispersal sites is being materially under-stated.  These sites are shown in the table in Appendix 1.

 

  1. Sites present in the detail of the SHLAA but not on the master list, and hence not in the NHB, nor mentioned in the DLP.

There are three sites, SHL167, 168 and 169 appear in the detailed assessments of sites, but not on the master list.

  1. Sites shown as “not currently developable” but have in fact been granted planning permission

Sites SHL68 and SHL117 are listed in the detail SHLAA documents as “not currently developable”, but according to the master list of sites have been granted planning permission.

  1. Range of meanings of “not currently developable”

It is clear from the above that the term “not currently developable” is a somewhat elastic phrase that can include sites that are just an administrative stroke of the pen away from deliverability as well as sites that face very significant challenges.  Many sites in the NHB and of course many of the strategic sites face very significant challenges that it is difficult to see how they can be remedied, such as proximity to flood zones, SSSI’s, SINCs, TPOs and the SPA and lack of proximity to existing settlements whereas others are much closer to deliverability.

However, the main materials being circulated for the consultation do not make this distinction clear.

  1. Lack of discussion about economics

The discussion about infrastructure costs in the DLP, with the only mention of costs being the woefully [inadequate] £30m for a new motorway junction – I would think there is little chance of change out of £100m.  But even so this misses out other important infrastructure items like the local road system, new or upgraded railway station, widening of the railway bridges over the local roads, new sewage farm, burying overhead power lines, new schools and new healthcare facilities to name but a few.  Hart currently has a £78m infrastructure funding deficit, Hampshire as a whole £1.9bn and the local NHS is predicted to have a large annual funding deficit.

These issues associated with a new town should be spelled out in detail, and I would think many of the same issues will arise with urban extensions.

It is certainly true that these issues will need to be resolved before the Local Plan can be found sound at examination.

So, what are we to conclude from the above?  First, the discrepancies outlined above, once corrected will make a very material difference to the calculation of how many more houses we need to build on green field sites (if any) and the capacity of each parish to deliver them.  I do not wish to subscribe to conspiracy theories.  However, the sum-total of the above, coupled with the obvious single-minded desire on the part of some members to push through a new town at all costs, leads me to conclude that either the people who created these consultation documents were incompetent or they are by their omission or intent about to mislead the public.   It is also clear that whatever systems and processes you are using to plan, manage, monitor and control the SHLAA are completely inadequate with such large discrepancies between different views of the same data.

It is clear to me that the forthcoming consultation should be postponed until these discrepancies are ironed out.

I would like you to treat this letter as a formal complaint and respond according to LGO guidelines.  I might also add that I will copy this letter to the chairman of the Standards Committee to ask him to set up an investigation and to our Local MP.  You might expect this letter and your response to be presented as evidence in any examination of the Local Plan.

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 15 12 12
SHL21 15 12 12
Bramshill 300 250 250
SHL106 300 250 250
Crondall 112 130 130
SHL159 65 100 100
SHL72 16 18 18
SHL76 31 12 12
Crookham Village 70 100 100
SHL53 70 100 100
Dogmersfield 40 5 10
SHL39 40 5 10
Eversley 91 123 123
SHL127 50 70 70
SHL140 41 53 53
Ewshot 120 187 187
SHL174 63 105 105
SHL355 48 75 75
SHL80 9 7 7
Fleet 706 881 886
SHL102 43 45 45
SHL275 25 12 17
SHL333 500 750 750
SHL50 46 60 60
SHL51 92 14 14
Hartley Wintney 208 287 301
SHL155 117 194 194
SHL216 8 6 6
SHL35 34 3 17
SHL45 25 51 51
SHL91 10 11 11
SHL97 12 10 10
SHL99 2 12 12
Heckfield 169 45 65
SHL109 44 5 5
SHL257 62 20 30
SHL259 63 20 30
Hook 2,090 3,849 3,849
SHL123 13 20 20
SHL3 543 1,000 1,000
SHL4 458 1,800 1,800
SHL5 1,065 1,000 1,000
SHL6 11 29 29
Long Sutton 63 65 65
SHL296 6 5 5
SHL335 34 35 35
SHL336 23 25 25
Mattingley 130 40 60
SHL239 55 20 30
SHL240 75 20 30
Odiham 3,308 2,894 2,904
SHL108 387 160 160
SHL110 2,160 1,900 1,900
SHL138 204 261 261
SHL228 48 75 75
SHL29 10 6 6
SHL328 25 30 30
SHL329 44 30 30
SHL57 47 75 75
SHL59 115 175 175
SHL60 11 12 12
SHL65 36 50 50
SHL67 53 80 80
SHL78 168 40 50
Rotherwick 130 200 200
SHL86 130 200 200
South Warnborough 36 20 25
SHL70 7 5 5
SHL75 29 15 20
Winchfield 119 32 42
SHL114 11 12 12
SHL262 108 20 30
Yateley 9 60 60
SHL13 0 8 8
SHL149 0 10 10
SHL17 0 30 30
SHL303 9 12 12
Grand Total 7,716 9,180 9,269

See more at our consultation page:

link

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

Is this what we want Hart to turn into?

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:

  1. Download the Local Plan response form from the link below.
  2. 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.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to [email protected]
  5. 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.
  6. If you have not already done so, please sign and share our petition too.
Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form

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 DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

 

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.

Link

 

Launch of We ♥ Hart Petition

The We Heart Hart Campaign (aka We Love Hart and We ♥ Hart) have now started a campaign on 38 degrees to petition Hart Council to change its approach to the Hart Local Plan. This petition can be found here: https://you.38degrees.org.uk/petitions/we-hart.

Please support this petition by signing it and sharing it with all your friends via e-mail, Facebook and Twitter.

We need to protect all of our parishes 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 from this invidious plan.

We Heart Hart Campaign Logo

We Heart Hart Campaign Logo

Hart District

Hart is a beautiful district made up of a mixture of large urban settlements such as Fleet and smaller village type settlements such as Odiham. The space around these settlements is largely made up of green fields and woodland which give Hart its essential rural feel.

In December 2014, for the fourth year running, Hart was named the best place to live in the country in a survey by the Halifax. Each settlement has a distinctive community feel; the quality of the schools is excellent and the 84 square miles of green fields and wooded landscape are a perfect example of England’s green and pleasant land that is excellent for wildlife, cycling and walking.

This essential nature of Hart is now being put under pressure by the National Planning Policy Framework and Hart Council’s response to it. In the years up to 2031, Hart has to build another 7,500 homes. Hart Council is proposing to meet the bulk of this need by building a new settlement in the heart of Hart at Winchfield destroying over 700 acres of green fields and woodland in the process.

We are mounting a campaign against these proposals because we believe the Strategic Housing Market Assessment that gave rise to the need for 7,534 extra houses (not to mention the extra 3,100 houses from Surrey Heath and Rushmoor) is flawed and Hart’s response to this is inappropriate.

This is putting all of the parishes of Hart District at risk 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.