Tag Archives: Hart District Council

Hart District Council, Hampshire, England

Hart Council on collision course with new Government brownfield planning policies

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Hart Council on Collision Course with Government Brownfield Planning Policy

Hart Council on Collision Course with Government Brownfield Planning Policy

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

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

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

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

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

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

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

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

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

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

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

  • requiring local authorities to plan proactively for the delivery of Starter Homes. Surely, apartments in higher density developments in urban areas will give a much greater opportunity for delivering starter homes.  Yet Hart is eschewing this type of development.

  • extending the current exception site policy, and strengthening the presumption in favour of Starter Home developments, starting with unviable or underused brownfield land for retail, leisure and institutional uses (Good but will be exploited by developers to build on the edges of towns and villages)

  • enabling communities to allocate land for Starter Home developments, including through neighbourhood plans

  • bringing forward proposals to ensure every reasonably sized housing site includes a proportion of Starter Homes (

  • implementing regulations to exempt these developments from the Community Infrastructure Levy, and re-affirming through planning policy that section 106 contributions for other affordable housing, and tariff-style general infrastructure funds, will not be sought for them” We don’t agree with this aspect of Government policy in that all extra housing will create additional demands for infrastructure, so a way needs to be found of funding infrastructure.  However, even the contributions to green field development are not sufficient to cover the costs of additional infrastructure partly because 40% of developments that have to be “affordable” do not attract CIL or S106 contributions.

 

Additional response to Rushmoor Local Plan

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Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

We have made an additional submission to the Rushmoor Borough Council Local Plan consultation pointing out the absurdity of seeking to protect 96 Ha of employment land when there’s going to be a surplus of 195 Ha of employment land across the Housing Market Area of Hart District, Surrey Heath and Rushmoor Boroughs at the end of the plan period.

This is available as a download for those wishing to add their voice to the consultation.

 

Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan
Download Now!365 Downloads

 

Our first submission and reasoning can be found here and here.

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Questions for Hart District Council July Meeting

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Protect our green fields

Protect our green fields

There’s another Hart District Council meeting next week on 30 July.  We Heart Hart has tabled some questions about school places and brownfield sites.  This includes asking Hart to consider our 5 point plan for change.

Please feel free to use our questions as inspiration for your own.

Update: I have added two further questions:

  • It appears Hart is now proposing to publish a draft Local Plan prior to the pre-submission version.  Will publication of this draft be accompanied by a Reg 18 consultation and when will the LDS be updated to reflect this change?

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

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Cows in Winchfield, Hart District, Hampshire

Cows in Winchfield under threat

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

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

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

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

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

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

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

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

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

 

Go to Petition

 

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

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Construction Workers

Construction Workers

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

The study covered 4 areas:

  • Education
  • Transport
  • Utilities
  • Flood Risk

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

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

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

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

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

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

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

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

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

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

Government and CPRE call for more building on brownfield sites

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Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

In response to the Government’s Productivity Plan, announced today, the Campaign for the Protection of Rural England (CPRE) has called for the Government to implement a ‘brownfield first’ rule.

The Government will introduce a new zonal system which will effectively give automatic permission on suitable brownfield sites.  This was welcomed by the CPRE in their statement, but they asked the Government to go further saying:

“To achieve the development we want and need on brownfield land, the Government should implement a ‘brownfield first’ rule at the heart of planning to prioritise urban redevelopment and leave behind the unsustainable status quo – where developers cherry pick green fields for development. Communities must also be involved from the start to ensure good design, and it is desperately important that new developments include a significant amount of affordable housing.”

We Heart Hart wholeheartedly agrees with this approach, and would like to see the combined boroughs of Hart, Surrey Heath and Rushmoor implement these ideas by prioritising building on the 196 hectares of vacant employment land that will remain in the Housing Market Area at the end of the plan period.  In particular, Rushmoor is protecting 96 hectares of employment land, whilst at the same time asking Hart to build 1,600 houses on beautiful green fields.  We think this is madness and it forms one of our arguments opposing the Rushmoor Local Plan.  If you would like to put in your objection, please see our post here and please use the pre-prepared form on the link below.

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!362 Downloads

 

There are certainly plenty of brownfield sites to be considered:

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

 

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

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Example of Urban Sprawl

Example of Urban Sprawl

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

The main reasons are:

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

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

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!362 Downloads

 

Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan
Download Now!365 Downloads

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Owens Farm saved as Hop Garden Road Appeal dismissed

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Owens Farm Hop Garden Road Hook

Owens Farm Hop Garden Road Hook

We found out today that the Hop Garden Road appeal we attended was dismissed, so the land at Owens Farm, Hook has been protected from development.

This is great news, although it has to be said that it isn’t at all clear whether the evidence we submitted swayed matters one way or the other.

However, it was upheld that the council does have a current five year land supply.  Our evidence, on this occasion was in support of the council, indicating that there was in fact a land supply far in excess of five years because the Strategic Housing Market Assessment (SHMA) was too high and the housing supply didn’t include the brownfield redevelopment of employment sites recently started.

Charles Church Homes argued that the Housing Market Assessment was under-cooked and Hart should be building far more houses, in particular, the 1,600 houses from Rushmoor.

So, we should celebrate a small victory.

Massive surplus of brownfield employment land but Rushmoor wants Hart to concrete over green fields

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Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

The Employment Land Review (ELR) shows there is a massive surplus of around 600K sq m employment space occupying around 195 Ha of land across the combined area of Hart District, Surrey Heath and Rushmoor Boroughs. Yet, Rushmoor is seeking to protect 96 hectares of this land whilst at the same time trying to force Hart to build 1,600 houses for them on our beautiful green fields.

Employment Space (sq m)
Overall Requirement to 2032 (a)266,368
Current vacant space (b)527,840
Sites with planning permission (c)338,187
Surplus in 2032 (b+c-a)599,659

If you would like to ask Rushmoor to revise its draft local plan, please download our pre-prepared response form and send it to [email protected].

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Download Now!362 Downloads

 

The analysis to support the conclusion is shown below.  We posted earlier that the ELR is based on the same flawed jobs forecasts as the housing market assessment that predict a near doubling of the job creation rate we achieved in the period 1998-2012.  However, even if you accept these flawed forecasts and the unnecessary increase in housing it will lead to, the requirement for employment land in the combined economic area is 266K sq m using Rushmoor’s preferred Scenario 3.

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

However, as of December 2014, over 527K sq m of employment floorspace was lying vacant.

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Moreover, there is a glut of employment space all across neighbouring districts with very high levels of vacant office space (note that there are also high vacancy rates on industrial land):

Office vacancy rates in neighbouring districts

Office vacancy rates in neighbouring districts

In addition to the vacant units shown above, there is currently 388K sq m of floorspace on 110 Ha of land that currently has planning permission but is not yet being built:

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Drawing this together, there is a need for 266,000 sq m of space to meet the inflated employment forecasts, there’s currently 527,000 sq m lying vacant, with a further 338,000 sq m with planning permission, but not yet built.  This would leave a surplus of nearly 600,000 sq m of employment space that might occupy around 195 Ha of land, using the same ratio of employment space to land use as the existing planning permissions.

It is clearly ridiculous for all of this land to be protected when even if say 100 Ha is made available, at 100 dwellings per hectare there could be room for 10,000 dwellings, a very large proportion of the overall 24,413 houses that have been allocated to Hart, Surrey Heath and Rushmoor.

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

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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
Download Now!362 Downloads

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

Slippery slope to taking more housing than the other districts

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

 

Hart 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.

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