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Proposal for a massive distribution centre at Lodge Farm near North Warnborough and Hook in Hart District, Hampshire

Proposal for Massive Distribution Centre at Lodge Farm

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Proposal for Massive Distribution Centre at Lodge Farm

Proposal for Massive Distribution Centre at Lodge Farm

There is a new proposal for a massive distribution centre at Lodge Farm, North Warnborough.  The backers have submitted a “scoping opinion” for an Environmental Impact Assessment and a separate pre-app to Hart Council. The company promoting the scheme is Obsidian Strategic.

The proposal is enormous in scale. Their cover letter calls for 105,000 square metres (or over 1.1m sq ft) of B2/B8 (storage and distribution) floor space over 5 separate warehouses. They also plan to provide space for 200 EV charging points. The overall site is over 32 hectares or 79 acres. The cover letter says the buildings will be 18-20m tall. However, the “Theoretical Visibility Plan” says 15-35m above existing ground level.

[Update 13 Jan 2024]: A dedicated group has been set up to oppose this development. You can visit their website to see their detailed objections here. [/Update]

Proposal Details

The scoping opinion application (Number: 22/01347/EIA ) can be found here.

The pre-app (Number: 22/01355/PREAPP) can be found here.

The scoping opinion was submitted first and at the time of writing had attracted 333 public comments, mostly opposed. Only 3 comments were in favour. The pre-app appears to have slipped under the radar, attracting only 3 public comments, all opposed.

We think that those who have objected to the scoping opinion should also submit their comments on the pre-app. It is difficult to object to a request for an opinion. Better to object to the actual application. However, Hart seem to only allow comments on the scoping opinion and not on the pre-app. This seems very odd to us, but we have sent in an objection direct to [email protected]. Both applications seem to have been delegated to officers to make a decision without the involvement of councillors, another worrying feature of this proposal.

Below we set out our main reasons for objecting to the proposed distribution centre at Lodge Farm.

  1. Fatally flawed Flood Risk assessment glosses over groundwater flooding.
  2. Incomplete Ecology Assessment misses out Basingstoke Canal impact.
  3. Defective Transport Assessment.
  4. No Analysis of Noise and Pollution
  5. Impact on Key Views from the Canal.
  6. Optimistic Economic Assessment overlooks Pyestock/Hartland Park distribution centre was cancelled.
  7. Impact on Food Production.

Each point is covered in more detail below:

Flood Risk at Proposed Distribution Centre at Lodge Farm

As part of the application, they have produced a Flood Risk Assessment. The document covers fluvial, surface water, reservoir, sewer and groundwater flooding.

The site is adjacent to the River Whitewater and part of the site to the South East is deemed at risk of flooding from the river. They have carefully avoided siting any of the warehouses on that part of the site. Roughly the same part of the site is assessed as being susceptible to surface water flooding. They propose to address this issue using a Sustainable Drainage System or SuDS.

However, their assessment of groundwater flooding is superficial and they do not provide a map. Helpfully, Hart has an online map that shows areas subject to groundwater flooding. We have superimposed the site boundary on to that map and it shows that most of the site is subject to groundwater flooding. See the image below.

Distribution Centre at Lodge Farm - Groundwater Flood Risk

Distribution Centre at Lodge Farm – Groundwater Flood Risk

We can certainly add anecdotal evidence to that map. A few years ago we got stuck axle deep in muddy water while attempting to cycle through the adjacent Bartley Heath woods. We recall the fields that the site covers were also flooded at that time.

Incomplete Ecology Assessment

The promoter have also produced an ecology assessment. However, this is incomplete as it fails to address the proximity of the site to the Basingstoke Canal SSSI and conservation area. About a third of the site is within the 500m buffer zone for the canal and all of it within the 1,500m buffer zone. As can be seen in the image below, the site is adjacent to a large number of SINCs and other SSSIs.

Distribution Centre at Lodge Farm - Ecological Constraint of Basingstoke Canal

Distribution Centre at Lodge Farm – Ecological Constraint of Basingstoke Canal

The report also highlights important species that have been found nearby including dormice, otters, water voles, hedgehogs, harvest mice and rare breeds of bats. Indeed some of the trees on site are assessed as being suitable to support roosting bats. They propose keeping those trees and implementing a “sensitive” lighting scheme. However, we remain to be convinced that the noise and pollution from thousands of daily HGV movements will be conducive to supporting bat or any other habitat.

Defective Transport Assessment

Obsidian Strategic have also produced a transport assessment. Unfortunately it is defective in two key respects:

  1. It omits the additional traffic movements from the 1,500-2,400 employees at the site.
  2. It doesn’t cover the impact on roads and junctions in the wider area.

Employee Traffic Movements Omitted

The assessment covers the additional traffic movements from the vehicles using the new centre. It quotes a range of additional movements dependent upon the eventual end use. The range is somewhere between 4,509 and 12,273 additional movements per day. The highest peak morning would be 581 2-way movements. the evening peak could be as high as 810 2-way movements. The report also says that a “high proportion of the vehicles to/from the site will be HGVs”.

Distribution Centre at Lodge Farm HGV movements

Distribution Centre at Lodge Farm HGV movements

The report also covers the additional movements generated by the 200 EV charging stations. They estimate the 200 charging stations could lead to 2,000 additional 2-way movements per day. This gives a total maximum number of 14,273 additional movements per day. We estimate that could be 700 total additional movements in the morning rush hour and nearly 1,000 in the evening busy period.

The economic assessment suggests that the proposal could deliver 1,500-2,400 jobs at the site. However the transport assessment doesn’t seem to take account of the additional movements from the employees. Of course, not all of the employees will work on the same day. But it is reasonable to expect the additional employee movements will be of the order of 1-2,000 per day.

They also talk of potentially providing service facilities to support the EV charging stations. It is possible that non-EV vehicles may stop at the services too, further increasing traffic.

Overall, this is a massive increase in traffic, mostly of heavy vehicles. We hesitate to think what impact it will have on J5 of the M3 and surrounding roads, especially at already busy peak times.

Wider Impact Ignored

The backers have not run a full Traffic Impact Assessment. They assume that the biggest impacts of the proposed development will be on the A287/B3349/Holt Lane roundabout and the Station Road/B3349 roundabout in Hook.

However, they have not really considered the wider potential impacts. They haven’t looked at the additional traffic likely to be generated on the B3349 from the A33 and M4. It is inconceivable that such a large warehouse would not attract traffic from the M4. Nor have they looked at the potential impacts further along the A287, notably the junction with the B3016 to Winchfield and the single carriageway part of the A287 towards Farnham and through Upper Hale.

Surely, this can’t be allowed to go ahead with such a superficial analysis of the traffic impact.

No Analysis of Noise and Pollution

In addition to the big increase in traffic movements, such a massive development is bound to have an impact on noise and pollution levels for the surrounding area. As far as we can tell, Obsidian have not provided any analysis of noise or pollution. We would have particular concern for the residents of Holt Lane, Derby Fields and Mill Lane

Surely, they can’t be allowed to get away with this?

Impact on Key Views

Hart’s Conservation Appraisal of Basingstoke Canal contains a number of key views. One of them is view number 6 looking northwards across the river Whitewater flood plain.

Basingstoke Canal Key Views

Basingstoke Canal Key View Number 6

We can’t imagine how 5 warehouses, each 20m tall will do anything to enhance this view.

Optimistic Economic Assessment for Proposed Distribution Centre at Lodge Farm

They have produced an economic assessment for the proposed development. They do make some good points about additional jobs, extra business rates and an increase in gross value added for the area.

However, they make extensive use of the 2016 Hart, Rushmoor and Surrey Heath Employment Land Review in their assessment. They make the claim that “only two out of the 24 [employment] sites have ‘distribution’ identified as their core use”.  This may well be true.

What they don’t mention is that Pyestock/Hartland Park was removed from the review.  Outline planning permission had been granted in 2005 for a 125,500 sq m distribution centre. The permission was extended in 2012. Even though the nearby road system has been improved to cope with the extra traffic, no takers could be found for the distribution centre. Later the site was sold and is now being redeveloped for housing.

It is difficult to believe their claims for a shortage of distribution sites, when a site of similar size could not find an investor at a time vacancy rates were even lower than today.

South East Logistics Availability from CBRE report

South East Logistics Availability from CBRE report

Note that the vacancy rate data shown above is taken from the CBRE report included in their own application. We conclude that the economic benefits they promise should be taken with a rather large pinch of salt.

Impact on Food Production

It is widely acknowledged that the world is about to endure a food crisis. The Prime Minister has outlined plans to boost UK food production with his “Grow for Britain” strategy. The site of the proposals is currently used for agriculture and food production.

It seems to us, that we should do all we can to protect the nation’s food security and keep growing food on productive fields, rather than concrete over them.

Conclusion on Proposed Distribution Centre at Lodge Farm

We believe that we should oppose this development because of the flood risk, the risk to local ecology, the additional traffic, noise and pollution, impact on the views from Basingstoke Canal and the apparently illusory economic benefits.

 

 

Hart SANG plan to obstruct brownfield development

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James Radley of CCH pulling the string of Graham Cockarill in Hart SANG plan to obstruct brownfield development

CCH calling the shots on Hart SANG plan to obstruct brownfield development

Hart Council has published a new report recommending that its own SANG land should not be used to enable brownfield development. This effectively renders the council’s SANG useless and calls into question the council’s ability to fund the repayments on the loan it has taken out to buy the SANG.

The document is sponsored by Community Campaign Hart (CCH) Deputy Leader, James Radley and not the portfolio holder for Planning, Lib Dem Graham Cockarill. This indicates that CCH is pulling the strings on important planning matters. The Hart SANG plan will be discussed at Cabinet tomorrow.

Hart SANG plan

Hart has bought its own SANG land at Bramshot Farm which lies between Ancells Farm and the link road between Hartland Village and the M3. The site has capacity to support 1,745 new houses. The new report proposes that no SANG land is allocated to the sites set out below unless signed off by both the Services Portfolio Holder (James Radley) and the chair of the Planning Committee (Graham Cockarill).

Brownfield sites affected

The following brownfield sites will effectively be blocked from development by the Hart SANG plan:

  • Bartley Wood, Hook, RG27, 9UP
  • Bartley Point, Hook, RG27 9EX
  • Cody Park, Farnborough, GU14 0LX
  • Meadows Business Park, Blackwater, GU17 9AB
  • Osborne Way, Hook, RG27 9HY
  • Waterfront Business Park, Fleet, GU51 3OT
  • Ancells Business Park, Fleet, GU51 2UJ (right next door to Bramshot Farm)
  • Blackbushe Business Park, GU46 6GA
  • Eversley Haulage Yard, RG27 0PZ
  • Eversley Storage, RG27 0PY
  • Finn’s Business Park, Crondall, GU10 5HP
  • Fleet Business Park, Church Crookham, GU52 8BF
  • Grove Farm Barn, Crookham Village, GU51 5RX
  • Lodge Farm, North Warnborough, RG29 1HA
  • Murrell Green Business Park, RG27 9GR
  • Potters Industrial Park, Church Crookham, GU52 6EU
  • Rawlings Depot, Hook, RG27 9HU
  • Redfields Business Park, Church Crookham, GU52 0RD
  • Optrex Business Park, Rotherwick, RG27 9AY

Essentially, development on every significant potential brownfield site other than Hartland Park and Sun Park (which already have SANG earmarked), will be hindered by this new proposal.

This new proposal runs contrary to the Vision outlined in the draft Local Plan which says:

The priority will have been given to the effective use of previously developed land (‘brownfield land’) so that ‘greenfield’ development will have been limited,

It also runs contrary to paras 105 and 107:

Our preference is still to deliver as much of our New Homes Left to Plan as possible on previously developed land.

many new homes will be built on brownfield sites (where possible and if they are viable)

Their new approach also goes against policy MG2 that says:

Policy MG2: Previously Developed Land

The Council will encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value.

Of course, this plan also goes against stated Government policy to encourage brownfield development. See here and here.

Financial impact of Hart SANG plan

However, all the large, controversial green field developments are being proposed with their own SANG. This includes Murrell Green, Winchfield, Pale Lane (Elvetham Chase), Rye Common and Grove Farm (Netherhouse Copse). Most of these sites are probably outside the 5km catchment area of this SANG anyway or closer to Crookham Park SANG. Of course, the new Government consultation has reduced Hart’s housing target by ~4,000 houses compared to the draft Local Plan. If this new target (plus a few extra to help out Surrey Heath) was adopted, our remaining housing target could be more than met by Sun Park and Hartland Park alone.

So, if the main brownfield sites are excluded from using the council SANG, the other brownfield sites have their own SANG and the major greenfield sites are not needed, or have their own SANG,  we have to ask what it will be used for.

Apparently, the council is about to sign an agreement with Rushmoor to use the SANG to support the delivery of approximately 1,500 new homes in Rushmoor. However, the latest Government housing target consultation has reduced Rushmoor’s allocation by ~3,000 dwellings and Surrey Heath’s by 630 houses. This calls into question whether Rushmoor will need this SANG at all.

The council is strapped for cash, and has borrowed £5.3m to fund the purchase of this SANG. It must payback this loan in instalments up to 2023/24:

Financial implications of Hart SANG plan

These new developments call into question the immediate demand for this SANG, and of course, Hart’s ability to repay the loan.

Conclusion

It is a scandal that Hart is using its powers to obstruct brownfield development. The major greenfield developments come with their own SANG, and probably aren’t required anyway. Rushmoor and Surrey Heath’s housing targets will probably be reduced. This calls into question the financial sustainability of the council’s purchase of this SANG land.

image

Local Plan: Brownfield sites protected from redevelopment

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

Brownfield sites protected from redevelopment

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

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

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

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

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

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

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

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

Poor brownfield sites should not be protected from redevelopment

The reason this is a bad policy is that the Local Plan itself, as well as the Employment Land Review (ELR), acknowledges that there is an over-supply of low grade office space (para 125). The ELR states that investment in this stock is unviable (para 6.17):

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Owners of these sites have three choices. First they can keep the wasting asset and collect no rent, which is not an attractive commercial proposition. Second, they can convert the offices into flats. By and large, they need no planning permission for this. However, these types of development carry no obligation for S106 or CIL payments to councils. Nor do they deliver a good ‘sense of place’. Finally, they could apply for planning permission to properly redevelop these sites into attractive homes, with a particular focus on affordable homes for the young. These types of development will be high-density, but with a good sense of place, and will attract some funding for infrastructure.

The consequences of this policy will be to discourage redevelopment of sites and either lead to more sites being simply converted or worse, sitting idle as eyesores.

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

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

Please respond to the Local Plan Consultation

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

Response to the Hart Draft Local Plan Consultation
Response to the Hart Draft Local Plan Consultation
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Time to work together to head off new Hart housing threat

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Hart Housing threat: sites under consideration

Hart Housing threat: sites under consideration

Overshadowed by our earlier  story of CCH further delaying the Hart Local Plan was the news of the new Hart housing threat of our target being raised from 7,500 to over 10,000 new houses up to 2032. This comes on top of the potential financial costs of delay.

Details of how this has come about are sketchy. It is related to how Hart should respond to Government rules about how to deal with affordable housing. We understand Hart Council is working on a ‘topic paper’ to give a further explanation.

We have analysed the impact of this new target below. Sadly, most of the large, sensitive green field sites are potentially under threat once again.  In addition, it is likely that Hart would no longer have more than five years of land supply. This exposes us to the threat of speculative planning applications. If most of these additional houses end up being ‘affordable’, they won’t attract contributions from developers to fund vital infrastructure.

So, we have come to the conclusion that it is time for all the politicians and pressure groups to work together to fight off this new threat rather than spend their time arguing over where the new houses should go. This level of development will mean that substantially all of the district will be under threat for some time. Moreover, this increased rate of building will be carried forward into the new planning period making things even worse for decades to come. We need to demand three key actions:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. Challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. Pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

Impact of the Hart housing threat on sensitive sites

First we take a look at where we would need to build to meet this new target and compare it to last year’s consultation; the most recent land supply position and our estimate of a ‘fair’ housing target.

Impact of new Hart housing threat on Hart District sites

Impact of new Hart housing threat on sensitive sites

As can be seen above, if the housing target remains around current levels, our remaining housing needs can easily be met from brownfield sites such as Hartland Village (Pyestock), the sites Hart Council identified in the consultation, Bramshill House and some further redevelopment of Ancells Farm and Bartley Wood. Moulsham Lane, Yateley was given the go ahead at appeal over the summer.

For some reason related to the Hop Garden Road appeal, Hart decided to increase our housing requirement up to 8,022 houses.  This is achievable from the 4,000 units we have identified on brownfield sites. But the planners would need to be persuaded to:

  • Redevelop the area around the Harlington and Hart’s offices in Fleet for mixed use.
  • Bring the many other smaller borwnfield sites across the district into the equation.

Failing that, it is inevitable that one of the green field sites is chosen.  For the purposes of this analysis we have used Grove Farm/ Netherhouse Copse as that is up for determination at the moment and the officers have recommended it.

Our estimate of a ‘fair’ housing target is based on the work of Alan Wenban-Smith. This starts with the population projections which on their own would generate a housing need of 5,040 houses over the planning period. A generous allowance is then added for additional economic growth to arrive at a need of 7,140 houses. This is easily achievable on brownfield sites, with some left over for future periods. Note that the new housing target is twice the level of housing required to meet the projected population forecasts.

The new target of 10,177 houses makes it much more difficult to achieve on brownfield. Again, the brownfield capacity could be larger than indicated above if the councillors and planners were to finally deliver on their brownfield study. If they don’t, it is inevitable that most of the sensitive green field sites including Pale Lane (Elvetham Chase), the land west of Hook and one or more of Murrell Green, Winchfield, Lodge Farm or Rye Common come into the equation. As you can see this new housing target will impact everyone.

Impact of Hart housing threat on the land supply

In the absence of the Hart Local Plan and up to date policies, the only defence we have against voracious developers is the five year land supply. This gives some limited control over speculative planning applications. So, we have taken a look at what the new target will mean for our five year land supply.

Impact of new Hart housing threat on 5 year land supply

Impact of new housing target on Hart District 5 year land supply

The left hand columns show the current 5-year land supply that Hart Council use. This shows we are in the relatively comfortable position with over 6 years land supply. If We Heart Hart’s fair housing target was adopted this would rise to 8 years supply.

However, the new housing target would reduce our land supply to below the crucial 5-year threshold leaving Hart very exposed. We would need another 525 additional houses to be granted permission ASAP to bring us back over the threshold.

Conclusion

We are in a very serious position with many of our cherished green fields under grave threat from speculative planning applications. There is no Local Plan and our policies are out of date. Hart is running an infrastructure funding deficit of £78m. The new housing target is double what we need to meet the official Government population forecasts. If the new housing target is adopted, Hart will no longer have a five year land supply. Unless we change tack, all our green fields will be concreted over and lost forever.

To preserve all that makes Hart such a great place to live we need to take serious action:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. We need to challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. We need to pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

This can only be done by everyone with a stake in Hart housing development working together to get the best outcome for Hart.

Hart Local Plan and planning application update

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Hart Local Plan and planning application update

There is a great deal of activity behind the scenes about the Hart Local Plan. The timetable for delivery is becoming clearer and there are updates on a number of planning applications that will shape the future of our district.

Hart Local Plan Timetable

We Heart Hart understands the upcoming timetable for the Hart Local Plan is as follows:

During w/c 28 November: The new Strategic Housing Market Assessment (SHMA) will be sent to councillors.

29 November 2016: Local Plan Steering Group (LPSG) Meeting, where we understand the timetable for the Hart Local Plan will be discussed and drafts of new Planning Policies will be considered.

December 13 2016: A further LPSG meeting will be held to review the draft spatial strategy. This will set out the number of houses we need to build and suggest where they will be built.

December 14 2016: We understand that the planning application for 423 houses at Grove Farm (aka Netherhouse Copse) near Crookham Village to the west of Fleet, will be considered at the Planning Committee. It is possible that some of the applications to redevelop the former Police College at Bramshill House will be considered.

January 26 2017: Draft Local Plan to go to full Council.

Upcoming Planning Applications

The long standing application for around 550 houses to the North East of Hook was finally signed off on 21 November.

The application for 423 houses at Grove Farm (aka Nether House Copse), near Crookham Village will be considered at the Planning Meeting on December 14. More details of this application can be found here and searching for application reference 16/01651/OUT.

It is possible that some of the applications for redevelopment of the former Police College at Bramshill House will be considered. There are a number of applications outstanding on this site that can be found here. The main applications appear to be 16/00726/FUL for 235 units and 16/00721/LBC for 25 units. At least this is a brownfield site, although controversial, being so close to the Thames Valley Heath SPA.

This week, Wates submitted an outline planning permission for 700 dwellings at Pale Lane (also known as Elvetham Chase). More details of this application can be found here and searching for application reference 16/03129/OUT

Conclusions

We don’t yet know how HDC are going to treat these applications, or if they have other ideas for strategic locations for additional housing. Of course, we await an application to redevelop the brownfield site at Pyestock (Hartland Village) and of course Winchfield has been mooted as a site for a new town, but we believe this has failed testing. Other strategic sites that were being considered include Murrell Green (between Hook and Hartley Wintney), Lodge Farm and West of Hook. Of course proposals are also being developed for the so called Rye Common New Village.

It is galling to say the least that we are seeing so many applications on greenfield sites instead of brownfield sites. It is imperative Hart produces the new Hart Local Plan and the new Planning Policies ASAP. This will allow us to regain control over where houses are built in the district.