If a new town is the answer, then Hart Council is asking the wrong question – CPRE

Winchfield in Hart District, Hampshire

Winchfield

Hampshire Campaign to protect Rural England (CPRE) have published a new article on their website saying, “If a new town is the answer, then Hart is asking the wrong question”.

The article goes on to note that a new town at Winchfield will not deliver many homes during the plan period and so will be futile.  The CPRE also notes that there is evidence that the housing market assessment maybe 30-50% too high, echoing our analysis of a number of SHMAs in the South of England.

They also note that a new town is likely to build the wrong type of housing in the wrong place to meet the needs of the district, saying “Those in need of a £200,000 property close to urban amenities, public transport and employment may not be in the market for a £300,000 property in a remote dormitory village”.

We wholeheartedly agree with CPRE’s sentiments.

If you would like to give Hart Council more encouragement to persist in getting Pyestock released 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, updated our two guides to responding to the consultation and they 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

Hart Council calls for Pyestock to be released for housing

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire could be released for housing.

Joint-CEO of Hart District Council, Daryl Phillips has called for Hartland Park (Pyestock) to be released for housing in an article in Fleet News and Mail. The article claims the site is on the market, and this appears to be confirmed by its presence on the Jones Lang Lasalle website here and here.

Hart Council believes that the 119-acre (48 Hectare) site could yield over 1,000 dwellings.  That would equate to an undemanding density of around 20 dwellings per hectare.  We think that opportunities for increasing density should be explored, taking account of the environmental sensitivity.  Who knows, there might even be sufficient space for new schools if it were shown that a new secondary school was required.  The old Bramshott Farm site across the road may well be earmarked as SANG.

The advantage of Pyestock as a site is that it is close to Fleet railway station and could be reached by bicycle or on foot and it is close to existing employment sites in Fleet and around Farnborough airport.  The site is very close to the M3 and the road system has already been improved in anticipation of thousands of lorry movements.

If the owners could be persuaded to release this site for housing, then it is certain that we would have sufficient brownfield capacity to meet or housing needs up to 2031 and beyond, as it would take our capacity up to over 3,500, when our remaining need to be permitted is 2,500. We definitely would not need a new town, nor would we need an urban extension.

If you would like to give Hart Council more encouragement to persist in getting Pyestock released 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, updated our two guides to responding to the consultation and they 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

 

 

 

New Housing Market Assessment delayed again

Hart District Strategic Housing Market Assessment SHMA delayed again

According to an email we have seen from Rushmoor Borough Council, it appears as though the new Strategic Housing Market Assessment (SHMA) for Hart, Rushmoor and Surrey Heath has been delayed again until June 2016.

Back in January, Rushmoor said that the new SHMA and Employment Land Review (ELR) would be published in May 2016.  Around that time, Hart were saying “late-February” with perhaps some highlights a little earlier. Now, according to an email we have seen, dated today, the new SHMA and ELR have been pushed back until June, with publication of their draft submission Local Plan due in October or November 2016.  An extract of the email is shown below:

Key Milestones Dates
Publication of updated SHMA June 2016
Publication of updated ELR June 2016
Publish draft submission Local Plan October / November 2016
Submission of Local Plan, Sustainability Appraisal (SA) Report and Proposals Map to Planning Inspectorate February 2017
Hearing sessions May 2017
Receipt of Inspector’s Report October 2017
Adoption and publication of Local Plan and Proposals Map December 2017

Hart Council plans to publish a draft Local Plan (a plan in a similar state to the Local Plan Rushmoor sent out for consultation last Summer) in Summer 2016.  We find it difficult to believe that they will be able to stick to this timetable if the new evidence base is not going to be published until June.

Hart is now at significant risk of the Government stepping in and doing the Local Plan for them, as Government minister Brandon Lewis has said that Local Authorities may have their Local Plans written for them if they are not in place by early 2017.

As regular readers will know, this is not the first time the timetable has slipped as we reported here and here.

James Farm Nursery Hartley Wintney, Hart District, Hampshire

New SHLAA sites mean our remaining housing need can be met from brownfield sites alone

James Farm Nursery Hartley Wintney, Hart District, Hampshire

James Farm Nursery Hartley Wintney

Hart Council has added a number of new sites to its SHLAA evidence base.  There is a mix of brownfield and green field sites, as we explore below, but the overall impact is to increase the brownfield capacity  to 2,493-2,535 units which is now enough to meet the remaining need of 2,500.

The sites are:

SHL25 Land attached to Brook House, Crondall, green field
SHL81 Vertu, Beacon Hill Road, Church Crookham, brownfield site, 65-70 units
SHL176 Hawley House, Hawley, in Blackwater and Hawley Parish, brownfield site, WHH estimate 8-10 units
SHL177 Land at Croft Lane, Hartley Wintney, green field site, WHH estimate
SHL178 Broden Stables & Stable Yard, Crondall, brownfield site 14-27 units
SHL179 Bowenhurst Lane, Crondall, brownfield site, 30-35 units
SHL180 Crondall Bee Farm, green field site
SHL181 Land south of Little Rye Farm, greenfield site
SHL189 Land at James Farm, Hartley Wintney, brownfield site, 8 units

We have been through each document and some have not yet been fully assessed by Hart’s Planners, so we have had to estimate the size of sites SHL176 and SHL177 using Google Maps and the capacity. Hart Council have not estimated the size of SHL180 either, but that site looks so remote and so close to Basingstoke Canal, that we feel it unlikely ever to be permitted so we have not bothered to estimate a size or capacity for it.

The total capacity of these new brownfield sites is 125-150 units, bringing our total estimate of brownfield capacity up to 2,493-2,535 units.

We have updated our table of brownfield sites and our brownfield thermometer accordingly.

Created using the Donation Thermometer plugin https://wordpress.org/plugins/donation-thermometer/.2,350Hart District Brownfield Development Target3,993Hart District Brownfield Development Target170%

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, updated our two guides to responding to the consultation and they 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

 

Hart Council fiddles while the budget burns

 

Michael Deacon, the political sketch-writer for the Telegraph has recently bemoaned the fact that his role has become merely one of transcription as the quality of discourse in the House Of Commons has descended to such an extent all he needs to do is simply write down what is said, because the truth itself has become beyond parody.

It is with this in mind, that we ask you to read our account of part of the Hart Council meeting that took place on 25 February 2016.

There were a number of formalities about the minutes and questions from members of the public that we shall cover later in this post.

We then moved on the section of the meeting where the council signs off the minutes of meetings from committees.

The chairman of the Overview and Scrutiny Committee raised what appeared to be a perfectly sensible point that members who are appointed to the O&S Committee of the newly formed Joint Procurement contract should also be members of Hart’s O&S Committee. We thought this would take about 30 seconds to resolve. How wrong we were.

After some back and forth discussion, the Leader proposed an ill-defined motion of amendment to agree with part of the suggestion, but leave unresolved some of the finer points of detail.

As he finished speaking, the room was filled by the sound of various moans and grunts, resembling the sound of a bagpiper tuning up, as a number of councillors inflated themselves into a state of maximum self-importance.  It is a pity that these inflation efforts were inversely matched by their vacuous contributions.

“How will we cope”, demanded one councillor, “if the meetings of this new committee are arranged for a time when Hart’s delegates might have an appointment at the hairdressers?”

At this point, there was a loud sucking noise as the life-force began to be drained from everyone in the room, as if a dementor had entered the building.

One can only speculate as to the motives of the councillors involved for indulging in such filibustering. Perhaps it was displacement activity, because the upcoming discussion on how to fix the forecast £1.16m budget deficit in 2017/18 was going to be “too technical” for them.

After the discussion about the finer points of the details of the process how to select two people to sit on the joint O&S Committee had continued for 20 minutes, I was overwhelmed by an insatiable desire to go home and watch some paint dry.

Now I will never know how they propose to fix the deficit, which is around 10% of spending, a bigger budget deficit than Greece. But no doubt they did work out how to resolve a diary clash.

 

The first item on the agenda was the minutes of the previous meeting.  We did point out that there was a factual inaccuracy in the minutes, in that the information the chairman said was available on the planning portal is not in fact available. I also informed him that the FOI request the minutes advised me to make to find out how many 1 & 2-bed homes we had built or permitted and how many specialist units for the elderly we had built had in fact been rejected.  The minutes were not amended, but were signed off.

It is striking that not a single councillor was endowed with enough curiosity to find out how well Hart had been meeting the housing needs of the District as expressed in the SHMA.

Last night we asked what we thought were three relatively innocuous questions, which we will cover in another post.

The first was a request to understand more about the remit and objectives of the Cabinet Member for Town and Village Regeneration.  We found it rather odd that the Leader of the council did not think his own cabinet member was capable of answering questions about his own role.  The answer we got was bland and did not include mention of a single objective, other than it had been deemed important that the role encompassed car-parking charges, because of the important link between car-parking and regeneration.

The second question was about the proposals in the corporate plan for the council to create a trading entity to build houses.  We got a reasonable response to this question, but it is clear that the idea is at a very early stage and nothing has yet been agreed.

Finally, we tried to ask a question whose answer was designed to provide evidence to combat developers who are insisting that Hart is not building enough houses.  This was inspired by the recent House of Lords report that showed that in recent years 100,000 fewer houses were built each year than were granted permission. Hart Council only has control over granting permission and cannot control the rate of building.  The question simply asked “for each of the past five years on how many houses have been permitted and how many built in Hart District.  This was ruled ‘too technical’ for council and will be referred to the FOI request process.

Response to Hook Action Against Over Development

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

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

Hook Action Against Over Development have written an article on their website which has been shared on Facebook, criticising both our support of a brownfield solution to our housing needs and the statement from the CPRE saying that the Winchfield New Town proposal was the worst site and the worst option for development.

We re-produce their article below, together with our responses in blue:

There has been a lot of talk about brownfield development and some claims that a new settlement is not necessary because brownfield housing development can provide for all of Hart’s housing needs. Brownfield housing development is the reuse of property or land for residential use where it was previously used for something else, for example office space, industrial land, military use or farm buildings.

Yes, we do believe that all of Hart’s remaining housing need can be met from brownfield sites, and we have set out the case and our plan here and here.  This draws on sites in the SHLAA at only ~26 dwellings per hectare (dph) and the work of the Stonegate Report, plus we have added the civic area that Fleet Future recommended for redevelopment and Fleet Town Council have raised their council tax to fund the costs of preparing a redevelopment plan.

One group in particular from outside of Hook is putting forward the suggestion that the Hart consultation is a simple choice between brownfield and greenfield development. But no matter how much they repeat it does not make it any more true. The CPRE, an organisation with laudable aims, appears to have now fallen for this fiction and hijacking of the term “sustainable development”.

We believe they are referring to We Heart Hart.  We believe the CPRE have not put forward an actual plan, but have clearly stated that they think that a new town at Winchfield is the worst site and worst option for development in Hart.  Sustainable development was defined by the Sustainable Development Commission as:

“Sustainable development is development that meets the needs of the present, without compromising the ability of future generations to meet their own needs.”

The concept of sustainable development can be interpreted in many different ways, but at its core is an approach to development that looks to balance different, and often competing, needs against an awareness of the environmental, social and economic limitations we face as a society.

We believe that sustainable development does not include concreting over the equivalent of 25 football pitches per year of green fields and leaving untouched, vacant, decaying office blocks. A new settlement would compromise future generations by needlessly concreting over hundreds of hectares of green fields, depriving future generations of the health benefits of the countryside. The economics of the proposals don’t stack up, requiring ~£350m of infrastructure spending, money that neither Hart nor Hampshire County Council have, especially now that HCC is facing an £81m per annum funding deficit. 

Hart’s housing strategy is brownfield first, but Hart cannot propose development on sites that are in commercial use or that have not been put forward for housing. If they were to do so then the Local Plan would fail inspection again at the first hurdle and this would be a disaster. Even hypothetically utilising these unavailable brownfield sites would demand construction at inner city density in order to meet Hart’s objectively assessed housing need. We cannot believe that CPRE are promoting building at such a density in Hart. That would not be sustainable.

We agree that sites need to be developable and eventually deliverable and nobody wants to see the Local Plan fail. Back in September, Hart Council said that they thought the brownfield capacity was 1,800 units.  Miraculously, this has fallen by 75% to only 450 units in the consultation. However, as described above, most of the sites we have put forward are in the SHLAA and in no worse state of deliverability than those put forward for consultation. The other sites are in the Stonegate report and we understand Stonegate are working hard to secure these sites.  The average density for the SHLAA sites is less than Hart’s planning rule of thumb at 26dph, and the Stonegate sites are at no higher density than developments that Hart has granted permission for such as the McCarthy & Stone’s recent development on Fleet Road which many people think is an attractive building.

Hart are actually consulting on which of Hart’s green fields should be selected for housing in the event that there is insufficient brownfield land to meet the housing need. Given the vast expansion of the existing towns and villages in Hart already, with Hook alone having a 25% expansion approved for this Local Plan period, the only suitable and truly sustainable option is a new settlement to allow for a planned increase in infrastructure. Just expanding existing towns and villages either piecemeal or with “urban extensions” is still building on green fields, but in a way that will not provide the opportunity to build extra schools, roads and health facilities that the thousands of new Hart residents will require. That would not be sustainable.

The proposed new town will in fact deliver over 1,800 houses in Hook Parish, which is more than the proposed urban extension and more than the undeveloped brownfield sites.  To be clear, we do not support urban extensions either because we believe all of the remaining need can be met on brownfield sites. The infrastructure costs for a new town do not stack up and a new town will do nothing to close the large £12.2m existing infrastructure funding gap in Hook, and £20.7m gap in Fleet and Church Crookham. No evidence has been presented that we need a new secondary school and the funding for a new town will not address existing road bottlenecks, nor will there be sufficient funding to address the roads requirements of a new town. We repeat, we do not believe concreting over 25 football pitches each year is at all sustainable.

Elimination of all potential commercial property space in Hart is in fact extremely short-sighted. Even the Enterprise M3 Local Enterprise Partnership which is urging more housing would not want to see commercial space becoming rare and expensive. There is already an acknowledged shortage within Hart of small business units and light industrial space. Larger available office space provides options for small local businesses to grow without leaving the area. A thriving local economy needs a balance of housing and business to provide employment opportunities locally and avoid all of these new residents having to take to the roads and railways to commute out of the area for work on already busy transport links. That would not be sustainable.

Nobody is saying that all of the vacant commercial space be handed over to housing.  But even the Employment Land Review, based as it is on the inflated Strategic Housing Market Assessment (SHMA) and the inflated jobs forecasts, suggests that there will be around 600,000 sq m of vacant employment space across the Housing Market Area at the end of the plan period and Rushmoor was planning to “protect” 96 Ha of vacant brownfield sites that simply are not needed. If there was such a shortage of offices or of light industrial space, places like the Murrell Green Estate would not have the big vacancies they currently have. Of course it would be more sustainable to free up some of these spaces and redevelop them for residential use rather than leave them to rot and decay.

There is very little brownfield land in Hart but there is an amusing “brownfield site slideshow”, made available by campaigners whose aim is to push development away from their village, to supposedly “demonstrate” how much brownfield land is available for housing. If you happen to see it, do bear in mind that:

  • Several of the sites are already being developed for housing (and therefore counted in existing housing build numbers!) such as Landata House and Greenwell in Hook, Sun Park and others.
  • Several of the sites are being converted to other commercial uses, e.g. Warehousing at Pyestock and retail development on Fleet Road where M&S are looking to move to an expanded new store.
  • Several of the sites are in fact just one vacant floor(or even a partial floor) in an otherwise occupied office building!

Now perhaps the future really is an office building with some adjacent floorspace being residential, but can anyone imagine this being attractive to either residential or commercial tenants?!

The fact that some of the sites have already been taken up for redevelopment simply proves our case and shows it can be done.  Our brownfield solution has taken account of the sites that are already underway. Work at Hartland Park (aka Pyestock) stopped years ago, and there is no sign of it re-starting.  The owners will not wish to keep an expensive site forever generating no returns. Of course if M&S moves into another Fleet Road site, then they will leave behind a different vacant block to go with the many other vacant units in the Hart Centre.

There are plenty of examples of mixed residential and commercial use, both in this country and on the continent.  Nobody is suggesting this should happen without comprehensive redevelopment.

This current consultation is clearly not about a choice between brownfield and greenfield development, it is about the best way to provide Hart’s required housing with essential supporting infrastructure and only a new settlement can achieve that. For more, please refer to our previous article hookdevaction.org.uk/hart-housing-consultation-restarted-your-action-needed.

The Hartley Winchook new town is not required, it not viable because of the flood risks and the massive, unfunded infrastructure costs, and will not be sustainable in any sense of the word. There is a brownfield alternative, and we should seize that opportunity.

 

 

Here are the slideshows of vacant brownfield sites we have found in Hart and Rushmoor:

 

  • We Heart Hart's Mascot - Bravehart
    We Heart Hart's Mascot - Bravehart

 

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, updated our two guides to responding to the consultation and they 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

Through the infrastructure looking glass

Comparison of infrastructure costs and contributions of different development scenarios

Comparison of infrastructure costs and contributions of different development scenarios

We had a surreal moment today debating with one of our district councillors revealed that she was strongly in favour of a new town because it would deliver some infrastructure funding, and other development approaches would deliver no funding.  Here is the Facebook post in question:

Wendy Makepeace-Brown No infrastructure from infill

There are a number of issues with this.

First, it is factually incorrect to state that either urban extensions or brownfield development will deliver no funding, as is described here.

Second, it seems very odd to us that councillors are ignoring basic economics and clearly are not looking at the big picture.  Surely the best way to look at this is to compare the incremental infrastructure costs of any particular development approach and the expected incremental developer contributions and, given we have an existing £78m infrastructure funding deficit, seek to minimise the gap.

In questions to the council last March we asked about the level of funding that might be attached to each development option and what the expected level of spending might be. There were no answers of substance.

It is very troubling that a councillor should seek to promote the idea of a new town because of the alleged funding contributions it might deliver, but ignore the overall costs that would be involved.

In the image above, we have shown our estimates of the impact of a new town on the infrastructure funding gap – the £78m deficit increases to £378m.  The costs are so high because the road network in Winchfield was designed for a small settlement, currently only 250 houses, which is clearly very different to that required for a settlement of 5,000 houses, plus there is no mains sewage or mains gas, overhead power lines will need to be moved or buried and a new sewage works will be needed. There is no reliable data on dispersal, brownfield or urban extensions, but we have created two hypothetical scenarios.

Scenario A looks at what the overall gap might be if, for sake of argument, £250m of funding was required to create infrastructure on brownfield sites that were converted, rather than properly redeveloped, so no S106/CIL funding was forthcoming from developers.  We would still be better off than with a new town. And remember it is self evident that the infrastructure requirement for a brownfield solution will be very much lower than for a brand new settlement.

Scenario B looks at what the overall gap might be if, for sake of argument, there was mixed brownfield development, with a more realistic infrastructure estimate of £150m and developer contributions of £40m.  The overall funding gap would be £188m.

Of course, a £188m funding gap would be bad news, but it would be much better news than the new town idea, especially as most of the existing gap is in Fleet, Church Crookham and Hook.

Estimated Infrastructure costs by area March 2013

Hart District Estimated Infrastructure costs by area March 2013

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, updated our two guides to responding to the consultation and they 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

 

CPRE says Winchfield is worst site and worst option for development

Winchfield in Hart District, Hampshire

Winchfield in Hart District Hampshire

The CPRE has published an article today saying that Winchfield is the “worst site and worst planning option for Hart”.

The article goes on to say that a “new town at Winchfield would be very damaging in an area of environmental sensitivity” and that the “CPRE has long campaigned for a ‘brownfield first’ policy which puts the protection of the countryside at the heart of policy making…more development and re-development in older urban areas must be pursued with greater urgency”.

We wholeheartedly agree with the CPRE and think that brownfield is the answer to our housing needs.

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, updated our two guides to responding to the consultation and they 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

Hart Council refusing to answer FOI requests about consultation or Open Spaces survey

Hart District Council (HDC) Keep Calm and Hide the Facts 2

Hart Council Keep Calm and Hide the Facts.

We are aware a number of Freedom of Information Act (FOIA) requests have recently been rejected by Hart District Council.

Requests about the aborted consultation

First, we know of two people who made requests about the recently aborted consultation.  These were refused on the following grounds:

The November 2015 Refined Housing Options Consultation was stopped before it was complete and there is no intention to complete it. The data that you seek therefore, is unfinished and unrefined. There is no intention to refine it or to use it further.
​The Council also does not consider that it is in the public interest to publish this unrefined data from the aborted consultation. The consultation was incomplete, some responses would not have been received because it did not go to the appropriate deadline; there may have been persons who may have wanted to respond and will not have done so until the last few days or indeed the last day; their responses may well affect the results of the consultation. To publish the unrefined and incomplete data would therefore, give a misleading and inaccurate impression of the outcome of the consultation. It would be difficult or would require a disproportionate effort to correct this impression or to provide an explanation particularly as the consultation as a whole has been stopped and the Council does not hold the final information.

Request about the Open Spaces Survey in May 2015

We made our own request for the results of the Open Spaces Survey, carried out in May 2015. This too was rejected for the following reasons:

Regulation 12(4)(d) [of the Environmental Information Regulations] however, provides an exception to the duty to make environmental information available when the request relates to material which is still in the course of completion, unfinished documents or incomplete data. By nature of being an unfinished document (by definition), draft documents will similarly engage the exception. A draft version of a document will still be considered an unfinished document even if the final version of the document has been published.

Under Regulation 12(4)(d)) the request for information is refused.  The Open Space Survey is still incomplete. It is still as a draft stage and the Council has not yet had a proper opportunity to review the draft or consider how it wishes to respond to this draft document. The document has not therefore been approved and the analysis contained within it and the methodology and implications of the work undertaken still requires consideration by senior officers and approval by Executive Members. It is however the the Council’s intention to publish the compete [sic] report at an objective time in the future. It will be published as part of the Local Plan evidence base which will inform the draft Local Plan when it is published later this year.

In support of maintaining the exception, the Council has drawn a distinction between the public interest in the public being able to review and comment on finalised projections and being provided with unfinished information which is in the process of being produced, debated and approved. In the Council’s view releasing the draft document in its present form would present a misleading picture to the public which, in turn, would misinform and distract debate. In the Council’s view it is also important, in general, that authorities are able to operate within a “safe space” when preparing information of this nature.

The Council also highlights that the draft Open Space Survey and analysis is relatively technical and is, essentially, concerned with providing accurate information through which further wider analysis and ultimately (if required) policy to be formulated. Officers should therefore, have the opportunity (the “safe space”) to conduct this ongoing work free from concern about the need to justify and explain their work before it is complete and free from concern that their work might be undermined or distracted by debating evolving methodologies and data in public.

In the Council’s view, the need to maintain a safe space should carry some weight. It is clear that the decision-making process in relation to these matters is incomplete at the time of the request (and remains incomplete at this time) and there is a strong likelihood that the integrity of and effectiveness of the decision-making process would be harmed by the disclosure of inchoate information In some instances where there is a concern that disclosing information might create public confusion or might misinform debate, it might sometimes be appropriate for the authority to preface such disclosures with a corrective or explanatory narrative. However, in this instance the Council considers that this is not always appropriate since an authority will not always hold final, completed versions of documents which allow for discrepancies to be resolved.

In this instance however, the data still needs to be assessed and analysed and the Council considers that it would be difficult to place the withheld documents in context or counteract any resulting confusion as, by virtue of their draft status, the final versions of the document does not yet exist. So, without a completed version of the information to reference, the public would be left with a provisional, misleading picture of the grounds for the decision-making process. The Council does not believe that this would contribute to the public interest in participation in decision-making in this case.

The Council is mindful that there is a general presumption in favour of disclosing environmental information and that there is an inbuilt public interest in enabling public participation in decision making in planning matters. However, public interest considerations should always be relevant to the exception being relied upon, to the specific nature of withheld information and to the context at the time of the request. In this case, the Council considers that the information is incomplete, that it does not exist in a finalised form and that its disclosure would, by misinforming public debate, impede the decision making process that it supports. For the reasons the Council has concluded that, in this case, the public interest favours maintaining the exception.

We can just about understand the reasons for not publishing the results of the abandoned consultation.

But the rationale for withholding the OPen Spaces Survey seems to be they think the public are too stupid to interpret the results on their own. We have no idea what an “objective time” might be. We can see no reason whatsoever why Hart Council have not completed the analysis of Open Spaces survey, some 9 months after it was carried out.  We would go further and say that we can see no reason why the raw results of the survey cannot be released if the council does not have the resources to conduct a proper analysis of the results. Moreover, we think that the results of such a survey may well be of more than passing interest to those participating in the current consultation.

We have asked for this decision to be reviewed.

 

Urban areas not taking their fair share of development 2001-2032 Part 3

Proposed percentage increase in dwellings by parish in Hart District Dispersal 2001-2032

Proposed percentage increase in dwellings by parish in Hart District Dispersal 2001-2032

Our previous posts (here and here) about the level of development that will be faced by the different parishes under the different development proposals put forward by Hart District have been criticised for two reasons:

  1. That the parishes are grouped in to clusters and,
  2. That the analysis does not go back far enough in time

The answer to the first point is that unfortunately, Hart have only provided the development from 2011-2015 in the parish groupings shown, so there is no other way of presenting the data and still maintaining accuracy.

In answer to the second point, we have now incorporated the census data from 2001 into the calculations, so now it is possible to see the percentage increase in the same parish clusters from 2001-2032 and from 2011-2032.  The results in graphical and tabular form are shown above and below. This data for dispersal shows that Fleet, Church Crookham and Crookham Village will not take more proportionate development than many other areas of Hart such as Hook, Hartley Wintney and the “Other” rural districts.  But it does show that Yateley and Blackwater have taken least proportionate development over both time periods and the smaller rural districts would take a very large proportionate increase if this strategy were pursued to the fullest extent.

First, the dispersal approach, the graph is shown above, and the table below:

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

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

Second, the urban extension approach below. This shows that Hook will take the largest proportionate development using this approach over both time periods and Crookham Village will also see a very large proportionate increase in housing. Again Yateley and Blackwater are relatively unscathed, with the smaller rural districts taking relatively little proportionate development.  This would point towards a need for some more dispersal towards those districts, but not to the full extent described above:

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

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

 

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

And finally, the new town approach. This shows again that Hook parish would bear a large proportionate increase in housing, plus the Winchfield part of “Others” would also bear a massive increase in housing, with Winchfield enduring a 6-fold increase during the plan period, with much more thereafter.

Proposed percentage increase in dwellings by parish in Hart District New Town 2001-2032

Proposed percentage increase in dwellings by parish in Hart District New Town 2001-2032

 

Proposed percentage increase in dwellings by parish in Hart District New Town Table 2001-2032

Proposed percentage increase in dwellings by parish in Hart District New Town Table 2001-2032

To us, this points to the need to redouble efforts to rebalance the housing proposals and redouble efforts to find a brownfield solution.

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