Hart District Council under-estimates brownfield capacity again

Posted on May 16, 2015August 20, 2015

Vacant Sun Park (Guillemont Park) block near J4A of M3, Cove, Hart District, Hampshire

A preliminary application has been made to build 350 dwellings at the old Sun Park (Guillemont Park) site, near J4A of the M3, Fleet, in addition to the earlier application for a further 120 homes on another part of the site. Provided concerns over road access can be overcome, this looks like a valuable addition to our brownfield capacity.

On the face of it, this is good news but further illustrates how misleading Hart District Council’s figures about brownfield capacity were when the council voted for plans to test a new town at Winchfield back in November 2014. Back then, they estimated overall brownfield capacity at only 700 units.

However, even though this site (SHL152) was in their assessment of Land Availability (SHLAA), it underestimated capacity (300 dwellings compared to the total now at 470), and wasn’t counted as a brownfield site as it was included in their “Adjacent to settlement boundaries” section.

If Hart Council are serious about a “brownfield first” strategy, surely they must now create a proper register of potential sites and properly assess the capacity and feasibility of delivering our residual requirement on brownfield only sites.

If you are worried about Hart’s hopeless position on the Local Plan and like our 5-point plan to bring it back on track and add to the pressure to Hart to adopt a brownfield strategy and drop all ideas of a new town, the please sign and share our petition:

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Please tell Hart Council how much you value our countryside

Posted on May 14, 2015June 15, 2015

Hart District Council is running a consultation about the quantity and quality of open space provision within Hart District. This is a great opportunity for you to express your support for the countryside and open spaces within Hart and request that they are maintained as havens for exercise, quiet contemplation, for viewing wildlife – or whatever you use them for.

This has surely got to be better than handing over our countryside over to developers and filling them with concrete.

The survey can be found here and more details on Hart’s website here.

If you would like to join our campaign please sign and share our petition:

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We Heart Hart submits objection to Hop Garden Road development in Hook

Posted on May 10, 2015August 19, 2015

We Heart Hart has submitted an objection to the Hop Garden Road (Owens Farm) development in Hook.

The full details of the submission can be found here:

Submission to oppose development of Hop Garden Road

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The summary of the submission is presented below:

The purpose of this submission by the We ♥ Hart Campaign is to oppose the specific unnecessary development proposed at Hop Garden Road in Hook and demonstrate to other developers who may wish to put forward speculative proposals for the over-development of the district that they will face formidable opposition to their plans. Hart District is facing a scale of development that is against the wishes of its residents and in contradiction to stated Government policy to place planning decisions in the hands of local people.

Let me remind you of the Prime Minister’s words in 2012, taken from this Telegraph article:

http://www.telegraph.co.uk/earth/hands-off-our-land/9002655/Hands-Off-Our-Land-Housing-estates-will-not-be-plonked-next-to-villages-pledges-David-Cameron.html

He said: “I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control. The fear people have in villages is the great big housing estate being plonked down from above.

“Our reforms will make it easier for communities to say ‘we are not going to have big plonking housing estate landing next to the village, but we would like 10, 20, 30 extra houses and we would like them built in this way, to be built for local people’.”

Mr Cameron, who was being interviewed in his Oxfordshire constituency, denied that the reforms would lead to large swathes of the countryside being built on.

He told BBC1’s Countryfile programme: “Here we are in west Oxfordshire one of the most beautiful parts of our country, set in some of England’s finest countryside. I would no more put that at risk than I would put at risk my own family.

“I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control.”

We ♥ Hart object to this proposed development and any future speculative proposals on the grounds summarised below:

The SHMA and OAN are not objective and represent a “need” that is far too high.
Understated brownfield capacity means green field development is not necessary
This proposed development will not contribute towards meeting the needs of the changing demographics of the district
The proposed development will make the current infrastructure funding gap worse
Lack of consideration of the environment

You can help by going along to the appeal, to be held between Tuesday 12th May and Thursday 14th May, 10am to 5pm. The first day starts at 10am and probably through to 5pm at Hart Council’s Civic Offices, Harlington Way, GU51 4AE, Fleet. More details here.

link

Hart Council rules out register of brownfield sites

Posted on May 9, 2015September 27, 2015

Vacant, derelict brownfield site in Hook, Hampshire

Vacant, derelict block in Hook, Hampshire

In a worrying development at the Hart Council meeting on Thursday 30th April, the leader of the council, Stephen Parker, ruled out creating a register of brownfield sites in the district, whilst at the same time insisting that the council supported a “brownfield first” strategy.

He said that the Strategic Housing Land Availability Assessment (SHLAA) had identified only 750 dwellings as being “deliverable” within the time-scale of the Local Plan.

The council insisted that all sites in the Local Plan must be “deliverable”. However, this is misleading as the term “deliverable” has a special meaning in planning terms and only applies to the first five years of the plan when it is submitted. Beyond five years sites only have to be “developable”.

We have previously posted that there are loads of mistakes in the SHLAA that have the effect of reducing the apparent brownfield capacity and the density assumptions that Hart uses are far below what they themselves say would be achievable in urban areas.

If Hart were to include “developable” sites such as the vacant and derelict offices, Bramshill House, Pyestock (aka Hartland Park) and Sun Park as potential sites and increase the density assumptions then it is entirely possible that the whole of our remaining housing requirement could be met by brownfield development.

Surely any credible “brownfield first” strategy should include as its starting point a register of all the redundant brownfield sites in the district.

If you would like to join the campaign to get Hart to think again, then please sign and share our petition:

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NPPF Definition of Deliverable:

“to be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable”

NPPF Definition of Developable:

“to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged”

Leaflet campaign doubles size of We Heart Hart petition

Posted on May 4, 2015August 19, 2015

A big thank you to all the volunteers who have helped with the We Heart Hart leafleting campaign. Just before we started leafleting we had 923 signatories. Today, the number is 1,846; meaning the petition has doubled in size in just three weeks. This is more than three times the number of people who responded to Hart District Council’s consultation and more than 8 times the number of people who expressed a preference for a new town.

Support for our cause has increased after we published the legal opinion from Peter Village QC that said that Hart was in a “hopeless position” with the Local Plan. Surely it is time for Hart to think again and adopt our 5-point plan to bring the Local Plan back on track which is summarised below:

Create a medium growth scenario with a lower housing requirement than the current high growth scenario to give an option to reduce the environmental impact of development.

Create a formal brownfield option and invite a competition to design the best way of using our brownfield land.

Do the work and consult upon the additional elements of a proper Local Plan such as employment, education, transport, retail and other infrastructure.

Consider the Environment and Landscape by carrying out proper habitat studies and landscape character assessments.

Fix the management and governance problems within Hart Council that have resulted in the past failure and current hopeless position.

If you would like to support our position, then please sign and share our petition.

Go to Petition

Rushmoor’s Employment Land Review has errors that reduce brownfield site availability

Posted on May 3, 2015June 15, 2015

Vacant Block at Ancells Farm, Fleet, Hart District, Hampshire

Rushmoor Borough Council has produced a draft Employment Land Review (ELR) on behalf of Hart District Council, Surrey Heath and Rushmoor. We Heart Hart has examined this draft document and found some serious errors in the way they have calculated both the historic jobs growth numbers and the future jobs projections for the area. Moreover, after discounting the Experian methodology for calculating future jobs growth saying:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”,

they recommend that the scenario that is used for testing should be based on the numbers for housing development contained in the SHMA, which themselves are inflated by the self same Experian forecasts they earlier dismissed as unreliable. This is clearly an absurd position that results in the forward B-class job projections (598 per annum) being nearly double the rate (300 per annum) that would be achieved if we continued at the rate of growth that was delivered between 1998 and 2012. The impact of this is that the amount of employment land we need is being over-stated and so reducing the amount of brownfield land that might be available for housing. This represents a great opportunity for Hart Council to challenge Rushmoor to re-visit the ELR and revise it so that more brownfield land comes available across the three districts.

We have asked several questions about the errors we found, but have not received satisfactory responses. We urge you to contact your councillors and ask them to challenge Rushmoor to come up with more realistic estimates and revise the ELR before it becomes final and sign our petition:

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The detail of the analysis is shown below.

ELR Table 8.2

The starting point for the analysis is Table 8.2 that shows the forecast employment change in a number of different types of jobs, from which it is possible to derive the ratio of B-Class jobs to all jobs at 53% (17,428/32,906). B-Class jobs means those jobs that require office space or light industrial units, rather than an indication that they are somehow inferior. Then we must look at Figure 7.12 that allegedly compares the historic rate of growth of B-Class jobs to the forward projections.

Figure 7.12 ELR

By inspection, Figure 7.12 shows the trend in B-Class jobs as approx 555 per annum from 2002-2012. The data from Table 8.2 allows us to derive total job growth of around 1,048 per annum. However, as we shall show below, this number is far in excess of the actual job growth achieved according to the SHMA.

The SHMA contains data on the historic rates of job growth. This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data. This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%. This would equate to a growth rate of B-Class jobs of 382 per annum, far lower than the 555 jobs per annum shown in figure 7.12.

Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum (35 B-Class per annum) for the 3 years in question or a CAGR of 0.05%, again far lower than the 555 in figure 7.12. It is difficult to see how the 555 number was derived since it is much higher than either period covered in the SHMA. Despite repeated questions, no one has been able to explain how they derived their number for Figure 7.12.

Comparison of the BRES data and the ABI data shows a discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data. This would equate to B-Class jobs growth rate of 280 per annum, or about half the number in Figure 7.12 of the ELR.

Taking the 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum, or 300 B-Class jobs per annum.

However, the scenario recommended for testing in the ELR assumes a rate of B-Class jobs growth of 598 per annum (or total jobs growth of 1,128 per annum), nearly double the rate that would represent a forward projection of past performance over the economic cycle. Incidentally, this is almost the same number as the future jobs growth number contained in the SHMA, which is based on the same Experian forecasts that the ELR itself discredits.

Hart New Town plan proposes school next door to child sex offender unit

Posted on May 2, 2015June 15, 2015

Mildmay Oaks Hospital next door to proposed school

Proposed school next door to Mildmay Oaks Hospital that held escaped child sex offender

Most residents in Hart District will have heard of the recent escape of a convicted child sex offender from the Mildmay Oaks hospital in Winchfield (formerly known as the Vistacare hospital). Fortunately, the patient has been found and detained in another establishment.

However, what many may not know is that the Barratt Homes plan for a new town at Winchfield included a secondary school right next door to the Mildmay Oaks hospital and a further primary school only a little further away. The image above is taken from the Barratts Vision document with an illustration added to highlight the proximity of the hospital adjacent to the proposed schools.

It seems beyond the bounds of credulity that anyone would consider that a suitable location for a secondary school was right next door to a hospital looking after convicted child sex offenders, especially when the unit failed CQC inspection twice whilst under the management of Vistacare and now has suffered a serious security breach under the new Partnerships in Care management.

The constraints placed by the location of the hospital have not been considered in the on-going testing of the new town location.

Surely it is time now for Hart Council think again about its absurd new town plan.

Top QC says Hart Council’s position on the Local Plan is “hopeless”

Posted on May 1, 2015August 19, 2015

Scales of Justice weigh against Hart District Council

Top planning QC, Peter Village has produced a devastating legal opinion on Hart District Council’s Local Plan process and pronounced that they are in a “hopeless position“. Hart Council have received this opinion, but have refused a meeting to discuss ways of improving the plan. In fact, at last night’s council meeting, council leader Stephen Parker dismissed the report as “just one opinion among many”.

It is imperative that Hart gets a high quality local plan in place quickly and fends off the demands from Surrey Heath and Rushmoor Borough Councils to build an extra 3,100 houses in Hart. The council’s attitude displays a staggering level of arrogance and complacency that can only lead to more delays and extra costs to get the plan right. We urge all voters to press their council candidates to push to get the Local Plan process back on track by adopting our 5-point plan and dropping all ideas of a new town in Hart District.

The essence of the opinion is:

The Regulation 18 public consultation in the autumn of 2014 addressed housing options and did not consider other vital issues such as employment, retail, transport and infrastructure.

Hart District Council said in April 2014 that they would conduct a second Reg 18 consultation in March 2015, which they have since dropped and now intend to proceed directly to a Regulation 19 consultation on the Draft Plan for Final Inspection. This plan is likely to fail because either the Local Plan will not contain all the elements it should, or they will not have consulted on all of the things they should consult upon.

Hart have not consulted upon the demands from Surrey Heath and Rushmoor that Hart build 3,100 houses for them.

Hart have not considered a medium growth “policy on” scenario of not meeting the full housing need on environmental grounds.

Hart have not properly considered the brownfield capacity of the district, highlighting that the capacity could be up to 3,500 dwellings, far more than the 750 dwellings Hart is still insisting upon.

Reader may recall that set out a 5-point plan to address these issues and this is summarised below:

Create a medium growth scenario with a lower housing requirement than the current high growth scenario to give an option to reduce the environmental impact of development.

Create a formal brownfield option and invite a competition to design the best way of using our brownfield land.

Do the work and consult upon the additional elements of a proper Local Plan such as employment, education, transport, retail and other infrastructure.

Consider the Environment and Landscape by carrying out proper habitat studies and landscape character assessments.

Fix the management and governance problems within Hart Council that have resulted in the past failure and current hopeless position.

If you want to press for change, please sign our petition:

Go to Petition

The full Legal Opinion and our latest Press Release can be found below:

Peter Village QC Legal Opinion

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We Heart Hart Press Release 1 May 2015

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This has been covered in the Basingstoke Gazette.

QC Opinion

Press Release

How to make a better Local Plan for Hart District

Posted on April 25, 2015September 27, 2015

Protect our green fields

We know that progress on the Local Plan for Hart District is slow and that it is not going in the direction many would like to see. We thought it was time to outline an alternative approach, and see if Hart Council and the candidates for election will change their minds. Below we set out a five point plan for change:

Create a medium growth scenario
Create a formal brownfield option and invite a competition to design the art of the possible
Do the work and consult upon the additional elements of a proper Local Plan
Consider the Environment and Landscape
Fix the management and governance problems

1. Create a Medium Growth Scenario

We need to work on creating a reasonable, alternative “medium growth” scenario to go alongside the current “high growth” scenario. We have posted earlier about why we believe the SHMA is flawed (as shown here and here) and is forcing us to build too much – 7,534 houses in Hart plus 3,100 extra from Surrey Heath and Rushmoor. Hart District Council should work with Rushmoor and Surrey Heath work to create a joint new, “policy on” lower housing requirement for the whole Housing Market Area that:

Takes account of the environmental damage that large scale over-development would cause to our valuable countryside and the green belt in Surrey Heath

Uses more realistic jobs growth assumptions of say around 650-750 jobs per annum over the cycle which is above what was achieved over the last economic cycle as opposed to the existing assumption in the SHMA of 1,130 jobs per annum

Uses more realistic inward migration and household size assumptions.

The more realistic assumptions above could reduce the overall housing “need” for the combination of Hart, Rushmoor and Surrey Heath by around 8,000 dwellings from 23,600 to 15,790. We believe this would relieve the pressure on all three districts, and in particular, reduce the pressure on Hart to take the unmet needs of Surrey Heath and Rushmoor Boroughs.

2. Create a formal brownfield option and invite a competition to design the art of the possible

We have already demonstrated that Hart has no effective brownfield strategy. Hart Council should create a new, formal “reasonable suitable alternative” option of meeting the housing need solely through brownfield development. This should involve the following:

Creating a complete database of all of the potential brownfield sites in the district, including those not yet in the SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock (aka Hartland Park), Sun Park, Ancells Farm, Bartley Wood, Fleet High St and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).

Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.

Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.

This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor.

3. Do the work and consult upon the additional elements of a proper Local Plan

Hart District Council needs to work on the other elements that should make up a local plan such as education, retail, transport, employment, meeting the needs of the ageing population and other infrastructure. Hart should conduct suitable, high level strategic analysis to build an evidence base to answer the following questions:

Education. How many school places will we need and where in both the current “high growth” and proposed “medium growth” alternative requirement scenarios? How might these be delivered and what are the costs of the alternatives?

Retail. What is the range, type and location of shops required across the district, taking into account changing shopping habits, the growth of the internet, changing demographics and the alternative growth scenarios? How will we regenerate our high streets?

Transport. What investment will be required in the major road and rail infrastructure under both growth scenarios? Considering alternative sites for each of the development options (including the new “brownfield option”), what investment will be required in minor roads, making broad assumptions on the location of alternative sites?

Employment. This review should be conducted across the Hart, Surrey Heath and Rushmoor. What types and quantities of employment land will be required under the alternative growth scenarios, taking into account changing work structures and habits; what is the current forecast surplus/deficit in 2032? Would any extra employment land need to be found? How much current employment land could be released for housing?

Other infrastructure. It is likely that a new town, particularly in Winchfield, would require even further infrastructure spending due to its current lack facilities such as mains sewage and mains gas. What is the cost of providing additional infrastructure for a new town such as sewage, gas, roads, electricity, rail etc?

Ageing Population. What type of housing is required to meet the needs of the 6,850 extra people aged over 75 and the extra 3,620 people who will be suffering from dementia or have some sort of mobility problem and where should it be located?

For each option and scenario Hart should outline the total cost of infrastructure spending required and the likely contribution from developers so that a proper financial model can be created.

4. Consider the Environment and Landscape

Fourth, Hart should conduct the other studies that are required to update the evidence base such as the landscape character assessment and an assessment of the potential damage caused to our wildlife by over-development.

Once this work has been completed, Hart District Council should carry out a new Regulation 18 consultation on the above that includes both a medium and high growth scenario and the properly evaluated options for meeting the housing need including the new proposed “brownfield” option. It would be preferable if the current “Option 4 – New town at Winchfield” (or indeed a new settlement anywhere in Hart) was dropped as an option. It will be important for the council to step up its engagement efforts during this period to ensure that a much larger proportion of the public responds to the consultation.

After the results of the consultation is known, firm up a preferred growth scenario and delivery option(s) to work up into a more detailed Local Plan and conduct an exercise to ensure democratic endorsement of the preferred option. This could take the form of a district wide referendum or a series of Parish Polls, followed by a Regulation 19 consultation before submission to the inspector.

5. Fix the management and governance problems

Finally, Hart need to work on the setting up the Local Plan project properly and address the governance deficiencies. There is clearly no properly defined scope or deliverables as the recent questions to the Planning Inspector demonstrate. Moreover, the timeline keeps slipping as we were originally supposed to have been consulted on a draft plan in March 2015, and it is clear that Hart is nowhere near that milestone even though it has dropped that consultation from its plan. This indicates the Local Plan project is not properly resourced. The Council needs to appoint a suitably qualified, experienced project manager, follow a properly recognised project management methodology such as Prince 2 and invest in the proper resources required to carry out the project on time to proper quality standards.

Given the prior failure of the earlier Local Plan at inspection and the current hopeless path the new Plan is taking, it is also clear that the governance of the Local Plan is deficient, with power effectively concentrated into the hands of only two people. The Council needs to explore ways of separating powers so that there is better transparency and accountability on both the “officer” and “member” sides. We suggest that the project should report to the joint chief executive who is not also in charge of planning; that roles of council leader and portfolio head for planning are carried out by two separate people and the council members elect a more proactive and capable chairman. This should lead to a wider range of opinions to be heard and appropriate checks and balances to be implemented.

It remains to be seen if our Parliamentary candidates or our Hart District Council candidates will endorse this plan.

If you would like to join the campaign to change Hart’s mind, please sign and share our petition.

Go to Petition

North East Hampshire Candidates declare their positions on Winchfield New Town

Posted on April 24, 2015October 6, 2015

The issue of a new town in Winchfield is a local issue and will not be decided by MP’s in Parliament. However, many people want to know where their local parliamentary candidates for NE Hampshire stand on the issue. MP’s do have the ability to influence Government policy on the National Planning Policy Framework, and on the incentives given to develop brownfield land. Winchfield Action Group have posted on Facebook their report of the recent hustings in Odiham. This has given an interesting view of all of the candidates standing for election in the North East Hampshire constituency at the 2015 General Election #GE2015:

Conservatives (Ranil Jayawardena): Against. Brownfield development is the way forward.

Monster Raving Loony Party (Mad Max Bobetsky): Totally against building in Winchfield. It’s beautiful.

Labour (Amran Hussain): Support locally led development. Majority are against the new town in Winchfield. Endorses our suggested new approach to the Local Plan.

Greens (Andrew Johnston): Against a new town. Brownfield redevelopment should be a priority.

Libdems (Graham Cockarill): There are not enough brownfield sites in Hook and Winchfield. A new town is long term the way to go, although not necessarily in Winchfield. Note that as a councillor, Mr. Cockarill was head of planning at the time of the vote for the new town on November 27 2014 and voted in favour of it.

If you would like to know more about each candidate’s position, their contact details can be found on our contacts page.

Our understanding of the positions of the district council candidates can be found here.

As I understand it, all of the major parties have recently expressed strong support for brownfield development; but that does not necessarily translate into local policy that is adopted by local councillors.