Shapley Heath Major Road Transport Issues

Shapley Heath Major Road Transport Issues: Eastbound travel perhaps requires new road

Shapley Heath Major Road Transport Issues: Eastbound travel perhaps requires new road

We first raised issues about the Shapley Heath sustainable transport goals here. That post focused on the minor roads within the area of search. This post examines the major road network surrounding the proposed new development and the gaps in the network. The Shapley Heath Survey has a number of questions about “sustainable transport”. Interestingly, there’s not even an option to request improvement to local roads or to rail services.  When many people think of sustainable transport they think of walking, running and cycling. This can be for fitness, leisure, work or even light shopping.  So, it is worth exploring whether the road network in and around the area of search is capable of delivering the basics such as pavements and cycle paths.

The conclusion for the major roads is that significant investment will be required to alleviate congestion and provide adequate pavements and cycle paths.  Here is the overall assessment, followed by an examination of each road one by one.

Shapley Heath Major Road Issues - Overall Assessment

Shapley Heath Major Road Issues – Overall Assessment

Having read the rest of this article, you might like to respond to the Shapley Heath survey. This is your chance to make known your concerns about the proposals. We have produced a handy guide with suggestions as to how you might choose to answer the freeform questions. The guide can be found on the download below. The full survey can be found here. The survey closes on 5 July.

Shapley Heath Survey with Suggested Responses
Shapley Heath Survey with Suggested Responses

Eastbound Travel

Starting with the those people who might want to travel to Crookham Village, Church Crookham, Fleet or further afield to Farnham, Farnborough or Guildford. We have already established that Chatter Alley, which is only single lane in places with no cycle path or pavement is totally unsuitable for a massive influx of new cars and people. Similarly, Pale Lane is too narrow. So, that raises the possibility of a new road from the eastern tip of the area of search to Hitches Lane. This would help access to Fleet and the Crookhams. This is shown on the image at the top of this post. It would need to be a proper 2-lane road with cycle paths and at least one pavement. Sadly, it would cut through part of the Edenbrook Country Park, but we can think of no other way of directing the extra traffic from 5-10,000 new houses eastbound.

Shapley Heath Major Road Transport Issues: A287

A287

Shapley Heath Major Road Transport Issues: A287

Moving clockwise, the next major road is the A287. The junction with the B3016 Odiham Road is already dangerous. So, there would need to be a new roundabout across the dual carriageway there. The rest of the road is suitable for busy 2-way traffic, but there’s no pavement or cycle path for much of the length of the road. That means this road would need to be widened to accommodate pedestrians and cyclists. And the roundabouts to Odiham and North Warnborough would probably also need to be improved.

M3 Junction

M3 Junction

M3 Junction

Prior studies into a Winchfield new town have raised the possibility of a new motorway junction. This seems unlikely on cost grounds, which means that significant improvements to Junction 5 of the M3 will be required. There is a rudimentary pavement across the junction that can also be used by cyclists, but it is quite dangerous. The pavements on the approach roads are also poor with scant provision for cyclists.

Hook Roundabouts

Hook Roundabouts

Hook Roundabouts

There is little provision for pedestrians on the B3349 from the M3 to Hook and no cycle lane. The roundabout already gets busy so would probably require improvement if Shapley Heath gets built. The other roundabout on Griffin Way South has poor provision for walkers and cyclists and would also need to be improved. Similarly, the roundabout with the A30 would need to be improved, especially as more houses are already being built near there.

Shapley Heath Major Road Transport Issues: A30 London Road

A30 London Road

A30 London Road

The A30 does have a pavement/cycle path between Holt Lane and the turning for Borough Court Road. However, elsewhere the pavement provision is poor. There is room for a cycle path on the dual carriageway part, but not elsewhere. Presumably a new access road will be built to access the Murrell Green part of the development, so a new roundabout across the dual carriageway will be needed.

Hartley Wintney Junctions

Hartley Wintney Junctions

Hartley Wintney Junctions

There are pavements at each of the junctions in Hartley Wintney, but no cycle lanes. However, main road through Hartley wintney gets very busy already, so significant improvements will need to be made at the following junctions:

  • A30/Dilly Lane & Thackham’s Lane
  • A30/B3011 Bracknell Lane
  • A30/A323 Fleet Road

It’s not at all clear if there is enough space to make significant improvements such as adding extra lanes.

Shapley Heath Major Road Transport Issues: A323 Fleet Road

A323 Fleet Road

A323 Fleet Road

It is already almost impossible to turn right out of Church Lane on to Fleet Road, so this junction would need to be improved, perhaps with a roundabout. The stretch of the A323 from Hartley Row Park to the M3 bridge would need widening and improving because it has no pavements and no cycle lane. The junction with Pale Lane would also need to be improved, probably with a roundabout.

 

Walk for Winchfield

Walk for Winchfield

Walk for Winchfield

The CPRE, the Countryside Charity, has organised a “Walk for Winchfield” on 25th July 2021 at 2.30pm. The route covers much of the area proposed for the Shapley Heath Garden Community. This is a chance to appreciate wildlife and countryside that might be lost if this project were to go ahead.

It starts at the Basingstoke Canal car park opposite the Barley Mow pub. The walk starts along the canal (see map and detailed instructions on the download below). It later passes the delightful St Mary’s Norman church, then along Bagwell Lane and beside Odiham Common. After crossing the B3016, the walk continues to Totters Lane, up to the old railway bridge high over Winchfield cutting, then down the bridleway towards Murrell Green. It turns off through fields and woodlands back to the B3016, then on to Winchfield Station. The route then completes by going down Station Road to the footpath up to Taplins Farm, then along Taplins Farm Lane to Winchfield Hurst to complete the circuit at the Barley Mow. Most of the route is on footpaths, but there are a few stretches on quiet roads without pavements.

With the wet summer, long trousers and stout footwear are recommended. There will be a competition for the best photograph of views or wildlife that might be lost.

There is Facebook Event set up for the walk. Please indicate your interest, so the organisers can keep track of how many people want to come along: https://www.facebook.com/events/343895127298516/

There is also a not-for-profit online shop where you can purchase merchandise to express your support: https://shop.spreadshirt.co.uk/say-no-to-shapley-heath/all

We hope to see you there on the day.

A map and detailed route instructions can be found on the on the download below:

Walk for Winchfield
Walk for Winchfield

 

You might like to respond to the Shapley Heath survey. This is your chance to make known your concerns about the proposals. We have produced a handy guide with suggestions as to how you might choose to answer the freeform questions. The guide can be found on the download below. The full survey can be found here. The survey closes on 5 July.

Shapley Heath Survey with Suggested Responses
Shapley Heath Survey with Suggested Responses

Shapley Heath Mapgate: Council map hides the reality

Shapley Heath Mapgate - Coalescence

Shapley Heath Mapgate – Coalescence

They say a picture paints a thousand words. However, sometimes, what’s missing from a picture can tell you more than what’s in it. As you may know, Hart has published a survey about the proposed Shapley Heath Garden Community. There is a map associated with the survey that is published on the dedicated Garden Community website.

Shapley Heath #Mapgate - Heart Shaped Love It

Shapley Heath #Mapgate – Heart Shaped Love It

Note the soft boundaries, the warm orange dots and the attempt to make the boundary heart shaped, so you will subliminally love it. Of course the OS map on which it is based doesn’t include the Edenbrook development on the western Fleet boundary.

To combat this propaganda, Winchfield Parish Council has published some maps of its own, showing the impact of Shapley Heath should it ever go ahead. The first, at the top of this post, shows the potential coalescence with surrounding towns and villages. If they build in the NE zone, it will effectively join Fleet to Hartley Wintney. On the other hand, if they build in the NW, around Murrell Green, then it will coalesce Harley Wintney and Hook. If they build both sides, then effectively, Fleet, Hartley Wintney, Hook and the new town will become a single, large conurbation. We have previously termed this Hartley Winchook.

Shapley Heath Mapgate: Central Land Not Available

Shapley Heath #Mapgate - Central Land Not Available

Shapley Heath Mapgate – Central Land Not Available

The next map shows land ownership in the area of search. The areas in green are under the control of the developers. Land that is potentially available to the developers – presumably not yet under option – is shown in blue. The red zone is land that is not and never will be under the control of the developers. Areas of ancient woodland, shown in brown, cannot be developed either.

As can be seen, there’s vast swathes of land in the area of search that cannot be developed. This means they have to build either in the NW area, the NE area or both. But none of those options allows for a single coherent settlement. All three options lead to coalescence.

Shapley Heath Mapgate: Additional Constraints

Shapley Heath #Mapgate - Physical Constraints

Shapley Heath Mapgate – Additional Constraints

However, the constraints don’t stop there. When you add on the additional environmental items such as the Sites of Importance for Nature Conservation (SINCs) and Sites of Special Scientific Interest (SSSIs), then the area becomes even more constrained. The physical constraints of the high-voltage electricity pylons, the high pressure gas main, the M3, railway line and the former landfill all add further restrictions on what is safe or sensible to develop.

Conclusion

If you display an anodyne map to the general population, they will form one view of the site under consideration. When faced with maps that actually convey real information, then perceptions can change markedly. We wonder why Hart Council aren’t taking more heed of the Inspector’s words when he examined plans for a new town in the same area as part of the Local Plan (our emphasis):

I have a number of fundamental concerns with regard to the soundness of Policy SS3.

There is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership within the identified AoS.

Policy SS3 is not required for the Plan to be sound and, in light of my comments above, I consider that the most appropriate course of action would be to remove it (along with any other necessary subsequent changes) from the Plan.

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

All of these issues are known, yet the Council is pressing on spending money they don’t have, on a project we don’t need and probably won’t work anyway.

Having read this article, you might like to respond to the Shapley Heath survey. This is your chance to make known your concerns about the proposals. We have produced a handy guide with suggestions as to how you might choose to answer the freeform questions. The guide can be found on the download below. The full survey can be found here.

Shapley Heath Survey with Suggested Responses
Shapley Heath Survey with Suggested Responses

Shapley Heath survey launched by Hart Council

Hart Council launch Shapley Heath Garden Community Survey

Hart Council launch Shapley Heath survey

We are sure readers will be as delighted as we are that Hart have launched another survey about the proposed Shapley Heath Garden Village. The survey is exploring the potential to build a new garden community in the Winchfield and Murrell Green area, with the working title Shapley Heath. The survey runs from 26 May through to 5 July and is supported by a new project website – hartgarden.community.

Readers may remember that Policy SS3, the policy that paved the way for a new town in the Winchfield/Murrell Green area was thrown out of the Local Plan by the Inspector. Yet, Hart Council have resurrected the plans, outside of the Local Plan process. They applied for funding support from Government and received a £150K grant in 2019. That bid was clearly for a new town of up to 10,000 houses.

Shapley Heath: Vision Document 10000 houses.

Shapley Heath: Vision Document 10000 houses

The main bid document clearly stated that this development would be in addition to the requirements of the Local Plan.

Shapley Heath in addition to Local Plan

Shapley Heath in addition to Local Plan

However, the Council is now insisting that they are testing a new community of  “only” up to 5,000 houses.

They have couched the survey in terms of “exploring the opportunity”, so there aren’t many options to express the view that you do not want this development to go ahead. However, there are some freeform questions that allow you to express your actual opinion.

The survey is around 24 questions, so please allocate 20-30 minutes for your response. We have produced a handy guide with suggestions as to how you might choose to answer the freeform questions. It can be found on the link below. The full survey can be found here.

Shapley Heath Survey with Suggested Responses
Shapley Heath Survey with Suggested Responses

 

Shapley Heath Viability Study flawed

Shapley Heath Garden Village Viability Study

Shapley Heath Viability Study

Hart Council has released the Shapley Heath Viability Study under a Freedom of Information request. At first glance, it looks as though the proposal is viable.

Shapley Heath Garden Village Viability Summary

Shapley Heath Garden Village Viability Summary

The summary shows 5,300 units in total, split 60:40 into 3,180 open market units and 2,120 affordable units of various types. This generates revenue of £1.68bn. It appears as though the discounted cash-flow gives a £32.1m surplus at the end of the project. This comes after an investment of £164m in infrastructure.

Shapley Heath viability study
Shapley Heath viability study

Shapley Heath Viability Study flaws

But, the good news ends there. There are three major flaws in the analysis:

  • Mismatch between the viability study and the commitments made in the Shapley Heath bid
  • Significant areas infrastructure are not even mentioned in either the study or the bid
  • The infrastructure spend per unit is much lower than proposed at the Grazeley Garden Town just over the border in Wokingham/West Berkshire.

Let’s look at each area in turn:

Mismatch between viability study and commitments

The bid to Government for £150K to support further work on Shapley Heath Garden Village contained a number of infrastructure commitments:

Shapley Heath Bid Infrastructure Commitments

Shapley Heath Bid Infrastructure Commitments

These included 4 primary schools, a health centre and health garden. Railway station and car park improvements were also promised.

However, the sketchy costings in the viability study missed out key elements:

Shapley Heath Garden Village Viability Assessment Infrastructure Costs

Shapley Heath Garden Village Viability Assessment Infrastructure Costs

The eagle-eyed amongst you will note that it only mentions 3 primary schools and there is no mention of a health centre. It is debatable whether the railway station improvements are included in the “transportation” bucket. So, there is a primary school and a health centre missing.

The missing infrastructure

However, the issues don’t stop there. First, let’s continue the discussion about railways. They don’t give any detail on the proposed improvements to the station. Winchfield station car-park is already full on weekdays and the line is acknowledged to be running over-capacity. The station has short platforms too.

Already 500 houses are being built in north-east Hook. Hook station car park is also full. So, it is likely many of these residents will try and use Winchfield station. Adding a further 5-10,000 new houses at Shapley Heath is equivalent to adding as many houses as in Fleet parish today. This would put a massive further strain on the station. It is difficult to see how this could be accommodated at the current site. Indeed, a study in 2015 by Hart Council said that it might be appropriate to relocate the station to Murrell Green. The cost of this wasn’t calculated, but it is difficult to see how they would get change from £25m.

The road improvements mentioned do not seem to include:

  • Improvements to the bridges over the railway on Station Road, Taplins Farm Lane and Pale Lane.
  • Strengthening and widening the the bridges over the River Hart at the Queens Head, Dogmersfield and Pale Lane
  • Improving the roads to the east side of the development including Taplins Farm Lane, Pale Lane, Chatter Alley/Pilcot Road through Dogmersfield to Crookham Village or Totters Lane.

It is difficult to see how they can improve M3 J5, the A30, B3016 and A287 as well as the above for the paltry £20m they have set aside. Remember the roundabout improvements on the A30 near Blackbushe cost £4m.

Moreover, the 2015 study also talked of a new juntion on the M3. This would likely cost around £100m. Of course, we don’t know how much, if anything they have allowed for re-routing the high-pressure gas main or burying the high voltage power lines or a new sewage works.

Lower spending per unit than Grazeley

Wonkingham and West Berkshire councils are planning the Grazeley Garden Town. This is for around 15,000 new homes just south of the M4 and west of the A33.  They suggest £750m of infrastructure spending is required for a town of this size. This equates to £50,000 per unit. The Shapley Heath viability study suggests £164m for 5,300 houses. This is around £31K per unit. The spending would have to increase by £101m to £265m to match the level of spending per unit at Grazeley.

Summary

We can estimate the extra spending required to match the commitments made and quantify the missing elements:

  • Extra primary school: £5m
  • Health Centre/Garden: £2m
  • New railway station: £25m
  • Additional road improvements: £20m
  • Bridge improvements: £18m
  • Total: ~£70m

We don’t know if they have set realistic budgets for re-routing the high pressure gas main, burying the power lines and building a new sewage works.

These extra requirements would likely render the project not viable, because it would more than wipe out the £32m surplus. Remember what Councillor Radley said:

Time to hold him to his word.

This is another of our posts showing:

  • What is Shapley Heath, explaining its location and scale?
  • All the reasons why Shapley Heath Garden Village is a bad idea
  • An outline of an alternative approach to long term planning in Hart

The master page containing all of these posts can be found here. A link is also provided in the navigation at the top of the page.  Please do keep an eye out for further updates and share them with your friends.

 

 

 

 

Hart CEO breaches Government guidance on housing need

In an email to councillors, the joint-CEO of Hart Council has made a desperate attempt to justify the Council’s inflated housing requirement in the Local Plan. This justification breaks Government guidance on when to build more than indicated by the standard method.

This comes after the release of ONS figures showing reduced household growth in Hart. By our calculations, we already have sufficient housing supply to 20141 and beyond without an unnecessary 5,000 house new town at Winchfield/Murrell Green.

In summary, he uses bluster, imaginary new ONS releases, unstarted Government consultations and dodgy logic to try to justify why the housing requirement will go up, when in fact the ONS figures show it is going down.

We are in the ridiculous position of the council arguing that we should keep an inflated housing requirement and build far more than we need to.

Inflated housing requirement breaches Government guidance

This is against Government guidance on when to plan for more housing than the standard method.

When to build more than the standard method

When to build more than the standard method

  1. There is no funding in place to promote growth. No part of Hart is identified by the M3 LEP as a growth area that will attract investment
  2. There are no strategic infrastructure improvements planned. In fact Hart has a massive infrastructure funding deficit. Extra houses will make this worse.
  3. Rushmoor is already planning for far more houses than it needs. The new ONS projections mean Surrey Heath can meet its own needs in full.

So, Hart meets none of the criteria to justify building more than the standard method says.

However, the council is breaking with this guidance and planning to build even more houses in the new town. They are proposing to spend £1.5m of public money to press on with it anyway.

Below we reproduce the email in full, together with our comments in red.

Hart CEO email to councillors

Dear Councillors, last night we received questions about the implications for the local plan and the assessment of Hart’s housing needs following the sharp fall in household projections as reflected in recently published Office of National Statistic (ONS) projections on 20th September 2018.  The household projection data is a key input into the new standard method of assessing housing need, and the new figures have prompted dramatic drops in many councils’ housing need figures when factored into the standard method.

Graham Cockarill pointed out that this was of concern to the Government and that the Government had delayed the use of the new methodology for calculating housing need because the revised projections undermined the Government’s objective to boost significantly the supply of new homes through building 300,000 new homes per annum.

The Government has issued guidance on how to calculate housing need in this period. This says that although the new standard method is not mandatory, any deviation will be closely scrutinised

Planning guidance use of standard method to calculate housing need

Planning guidance use of standard method to calculate housing need

But it has emerged today that the ONS plans to publish a different version of its figures on 3 December.

Yes, but this new version apparently just puts more detail on the figures released on 20 September 2018, by breaking out the household projections by housing type. There is no suggestion that the overall figures will change.

ONS Household type projections December 2018

ONS Household type projections December 2018

The ONS is also planning to publish a set of variant based household projections in which household formation rates for younger adults (those aged 25 to 44 years) are higher.

They may well be, but we can find no evidence of this in the ONS’ schedule of upcoming releases up to 31 December 2019. If this is going to arrive, then it is beyond the timing of the Local Plan examination and thus cannot be considered.

The ONS’s willingness to publish “variant” projections reflects its acknowledgement of concerns about the new approach taken to drawing up the 2016-based figures. Unlike the 2014-based projections, which drew on data from as far back as the 1971 census, the 2016-based figures were compiled with statistics that only go back to 2001. Critics have said that the new projections thus ‘bake in’ the adverse consequences for household formation of housing under-delivery  in this century.

“Experts” have been predicting that the average household size would continue to fall in line with the experience of earlier decades. However,  the 2011 census showed that this trend had come to an end.  Actual behaviour stubbornly refused to comply with expert opinion. The ONS’ own analysis of its new numbers still shows a reduction in average household size out to 2039. However, the rate of reduction in the newer 2016-based figures is slower than the 2014-based projections. We believe that part of this is down to social change – people are getting married later than in the 1960’s and 1970’s. THe increase in house prices may have played a part, but we already know from Ian Mulheirn’s analysis that building more won’t reduce prices. Prices are mostly driven by ultra-low interest rates.

ONS impact of 2016-based projections on household size

ONS impact of 2016-based projections on household size

In its methodology document, the ONS acknowledges those complaints. It says some respondents to its consultation on the new method thought that using data from only the 2001 and 2011 censuses would be “insufficient”. It says that: “There was a view that only using the 2001 and 2011 censuses would result in a downward trend in household formation for the younger age groups, which in turn would downplay the need for housing for younger people”.

OK. So what. It seems the ONS disagrees with this view, or it wouldn’t have continued with the method it has adopted.

The government has already said that it will consult on adjustments to the way housing need is calculated so it is consistent with delivering 300,000 new homes per year by the mid-2020s and that it will do this “as soon as possible”.

The Government may well have said that, but the consultation has not been launched. In effect, the Government has set a ‘top-down’ target of 300,000 houses per annum. Now the detailed bottom-up work has shown this to be far more than we need, it is trying to find a way of fudging the numbers to arrive back at the number it first thought of. It is inconceivable that such a consultation can be launched, completed and the results analysed before the Hart Local Plan is examined. This might be a risk to the housing target we eventually adopt. However, surely the way to mitigate this risk is to demonstrate flexibility of supply, rather than increase the target. We have already shown that Hart has sufficient supply out to 2041 and beyond, without the unnecessary new town.

In effect therefore, the Government is not running with the current 2016 household projections for use with the standard methodology and as Cllr Cockarill highlighted, the Government’s objective is to boost the supply of new homes and wants to put in a methodology that does exactly that.

This is, at best, a disingenuous statement. The current Government guidance says the national household projections should be used. It isn’t clear which version should be used, but surely it makes most sense to use the most up to date figures.

Planning guidance setting the baseline using national household growth projections

Planning guidance setting the baseline using national household growth projections

The worked examples in the Government guidance are a bit ambiguous. We believe that using the new Government standard method is either:

Hart Household change 2018-2028

Hart Household change 2018-2028

a) 212 * (1+0.4) = 297 dwellings per annum using the capped 40% affordability uplift, or worst case

b) 212 *(1+0.5) = 318 dwellings per annum

Hart Housing Numbers

This compares to the 388dpa used in the Local Plan.

I think we can safely read into this that it means that the overall number of homes to be built is likely to go up rather than down.

There is no justification for this statement. There is already at least 70dpa headroom (or over 1,120 houses in the plan period) between the Government standard method and the Hart Local Plan. And even this elevated housing target does not require the proposed new town to be built. In any event, the best mitigtion for this is to demonstrate flexibility in supply

That was exactly why we included a buffer in our housing needs and until we see what they new “variant”  projections look like it is not wise to make any assumptions about not having to meet our neighbour potential unmet housing need.

The new household projections mean that Surrey Heath can meet its own need. Rushmoor is already planning for far more houses than it needs to build.

We now have the ridiculous situation of the council arguing to keep an inflated housing requirement and build more houses than we need so it can somehow justify keeping the unnecessary new town in the Local Plan.

 

Parish Council demolishes Winchfield new town plan

Figure 6 Winchfield New Town Summary of Key Findings

Winchfield new town area not suitable for large scale development

The Parish Council have demolished plans for the proposed Winchfield new town in their submission to the Hart Local Plan Regulation 19 consultation. The have produced a 690-page report that can be found here. Their main conclusions about Policy SS3 that calls for the new town to be built in the area of search are (our emphasis):

Our review of the available technical evidence, with STR005 released only through a FOI request, demonstrates the highly constrained nature of the AoS, and the significant environmental and infrastructure issues that need to be overcome. A Site Appraisal prepared by Michelle Bolger Expert Landscape Consultancy is provided and this demonstrates that the AoS is significantly constrained and concludes that little land exists within the AoS which could be considered suitable for large scale residential development. We flag up the complete failure of the Draft Plan to identify the key infrastructure necessary for the provision of a new settlement, or indicate how it will be provided, by whom and when. Given the complete lack of any detailed evidence demonstrating that a new settlement is either deliverable or viable, we do not see how provision can be made for it within the Draft Plan.

Winchfield New Town Expert Evidence

The expert evidence from Michelle Bolger is a joy to behold. Her much shorter report can be downloaded from the link below, together with the appendix that contains the wonderful graphics depicting all of the constraints on the area of search.

The final summary is shown on the image above. This summarises the findings of the whole report in relation to the various sites that have been put forward, concluding (emphasis mine):

All of the sites are significantly constrained and the vast majority of the area of search (AoS) south of the M3/Railway is considered to be unsuitable for large scale development (i.e. it would cause severe landscape harm that would be difficult to remedy or mitigate)…

Land within the north-western parts of the AoS…are also significantly constrained. Development here could not occur without harm to the local countryside character and this would also impact upon the character and enjoyment of the Public Right of Way network. Development may also result in visual coalescence between Hartley Wintney and Hook.

Overall this appraisal finds that the AoS identifies a landscape that is highly unsuitable for large scale residential development. The new settlement envisaged by draft policy SS3 would result in significant landscape and visual harm and be at risk of harming components within the landscape which hold high landscape, amenity, ecological and heritage value.

The build up to the final conclusion starts with the area of search:

Figure 1 Winchfield New Town Area of Search and Context

Figure 1 Winchfield new town Area of Search and Context

It then goes on to show Hart’s own landscape capacity study which shows that most of the area has low or low/medium capacity. The only area with medium/high capacity is the proposed Elvetham Chase (Pale Lane) site and it’s westward extension towards Winchfield. The Murrell Green area is shown as Medium capacity. However, this was decided before the Major Accident Hazard gas pipeline was discovered by Hart Council.

Figure 2 Winchfield New Town Landscape Capacity Study

Figure 2 Winchfield Landscape Capacity Study

The paper then goes on to identify the constraints in the area of search, starting with areas designated as SSSI’s, SINCs, tree preservation orders, ancient woodland, and listed buildings.

Figure 3 Winchfield New Town Key Constraints Designations

Figure 3 Winchfield New Town Key Constraints Designations

Then other constraints such as visual sensitivity, flooding, footpaths, unavailable land, landfill, narrow bridges, high voltage transmission lines and the gas pipeline are added:

Figure 4 Winchfield New Town Key Constraints Assessment

Figure 4 Winchfield Key Constraints Assessment

Then all of the constraints are brought together on one diagram, showing just how little land exists within the AoS that could be considered suitable for large scale residential development.

Figure 5 Winchfield New Town Key Constraints Composite

Figure 5 Winchfield Key Constraints Composite

 

All of this report is drawn from pre-existing material. One wonders why Hart Council is continuing to promote such a daft idea. Certainly, £50K is not going to cover costs of putting together a robust Winchfield new town master-plan to fulfill all of their magical promises to turn horses into unicorns. We shall see what the inspector makes of this.

The report and appendix can be downloaded here:

Winchfield Site Appraisal
Winchfield Site Appraisal
Winchfield Site Appraisal Appendix
Winchfield Site Appraisal Appendix

 

Stop Elvetham Chase hypocrisy (and CCH)

Stop Elvetham Chase Hypocrisy

Stop Elvetham Chase Hypocrisy

We have done some more digging to expose the Stop Elvetham Chase hypocrisy, after our article revealing that a leading member of was standing for election for Community Campaign Completely Concrete Hart.

To recap, Stop Elvetham Chase have consistently argued against development of Pale Lane. This is a position we agree with. However, they now support the unnecessary new town in Winchfield that is being proposed as part of the Hart Local Plan.

They have come up with 13 reasons to object to Elvetham Chase, many of which also apply to Winchfield. These reasons are reproduced below with our comments in red.

Stop Elvetham Chase Hypocrisy – their reasons apply to Winchfield too

1. The effect on the area – The valley of the River Hart is a naturally beautiful area. There will be a loss of hedges, trees and fields. It will destroy the semi-rural character of the approach to Winchfield, Fleet and Hartley Wintney. The area around the development is a haven for wildlife the developer’s proposal does not address this issue. When the green fields are gone they are gone for good! Quite. All these arguments apply even more to Winchfield.

2. The existing road design through Elvetham Heath is designed with no stopping areas, traffic islands and central islands to slow traffic through this residential estate. The use of these roads to take more traffic to the M3 and A30 will have a huge safety impact for pedestrians, cyclists, children walking to school and a significant increase on noise and pollution for the residents of Elvetham Heath. No doubt a new development at Winchfield will also affect traffic levels through Elvetham Heath. Not only that the roads through Winchfield are even narrower than the one through Elvetham Heath and not suited to 5,000 more houses.

3. The existing lanes surrounding Winchfield and Dogmersfield are narrow and windy with dangerous bends and bridges they are not designed to cope with the additional traffic any development the west side of Fleet would bring. Exactly.

4. Local secondary schools are at capacity. The houses planned or under construction at Brickyard, Pale lane and Grove farm (1700 homes in total) will be closer to Calthorpe than the children of Elvetham Heath. Calthorpe has no capacity to take any more children and as such it is proposed that children from Elvetham Heath and other perimeter areas of Fleet will be bussed to schools with capacity such as Yateley. It is possible that Elvetham Heath will be taken out of the catchment area for Calthorpe Park school totally. There is no evidence that we need a new secondary school. But, this argument applies equally to Winchfield, as they have yet to find a site for a school that is suitable. Even so, there’s no need to concrete over 100’s of acres of countryside to provide 10Ha for a new school.

5. Transporting children to schools miles away will have a detrimental environmental impact. It will also have a social impact on children, time spent travelling to school will reduce time for family activities, school clubs etc. It will also affect the health of our children, walking to and from school is a good form of physically activity. Not really an argument. Plenty of children travel a long way to school already.

6. Foot paths and road crossing points surrounding Elvetham Heath on roads such as Hitches Lane, Reading Road North and Elvetham Road are narrow and dangerous and congested to use at peak times such school start and finish times. Extra traffic will further compromise the safety of pedestrians and cyclists. Indeed, Basingstoke and Deane have opposed the new settlement on the grounds of too much extra traffic. These arguments apply equally to Winchfield.

7. There will be a significant increase in noise for existing houses along the perimeter of Fleet Road and the roads through Elvetham Heath. Existing gardens will be forced into red unacceptable levels. The new development will be sandwiched by a railway, the M3 and Fleet Road. Any new occupants will be surrounded by pollution and noise this has clear dangers to public health. The Environmental Health Department at Hart does not support the use of the Pale Lane site for residential development due to the very high levels of noise and constraint from the railway and the M3. Indeed a new settlement at Winchfield will detrimentally affect Elvetham Heath. In addition, the proposed area of search for the Winchfield new town is bisected by the M3 and the railway and bordered by the A30. Moreover, the Murrell Green portion is crossed by a Major Accident Hazard high pressure gas pipeline.

8. Local doctors surgeries are operating at capacity and have long waiting times for even routine appointments. Yes, and a new town won’t fix this either.

9. Pale Lane and the immediate area are liable to flooding. The proposal put forward by the developers makes little mention of the River Hart flood plane any development would contribute to the problem. Tell me about it. Winchfield East is very susceptible to flooding. It has flooded three time this year so far, and at least three times in 2016.

10. The development is against Hart’s policy to allow development of green field sites. There are enough Brownfield sites to meet demand. Hart has 6 years land supply exceeding the requirement for 5 years laid down by the Governments national policy Planning Framework. The land at Pale Lane and Grove Farm is not required to meet those obligations. Pale Lane is a green field site and it has not been previously identified for development. Indeed. We have been arguing this for more than three years now. This argument applies equally to Winchfield.

11. Car parking at railways stations of Winchfield and Fleet are at capacity. Trains are full and cannot cope with current demand. Indeed. 5,000 new houses at Winchfield will make this even worse, and no doubt impact Hook too.

12. The provision of a cycle path on the new development does not link to the existing cycle network and is of little purpose. No plans detailed enough for examination have been put forward for Winchfield.

13. There will be an impact on Fleet Pond with is a site of special scientific interest. There will be an increase of users (humans, dogs and vehicles). It is dubious whether Elvetham Chase will have any impact on Fleet Pond. Similarly, WInchfield. But whilst we are on the subject of SSSIs, why not consider Basingstoke Canal and Odiham Common which both border the proposed area of search for Winchfield?

As you can see, it seems their principles only extend as far as the railway line, and can’t be extended beyond their own narrow view. Stop Elvetham Chase hypocrisy. And now they are standing for CCH, stop Completely Concrete Hart hypocrisy too.

Hart Local Plan: Remove Policy SS3 to build a new town

We have finally pulled together our submission to the Regulation 19 Hart Local Plan consultation. This, the first of a series of article explains some of the reasons why Policy SS3 to build a new town should be removed.

The process for making a submission is as follows:
  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to [email protected] or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry
WHH Local Plan Reg 19 Entry

Why should Policy SS3 for a new town be removed from the Hart Local Plan?

The most egregious part of the draft Local Plan is the proposal to include an unnecessary new town. This should be removed for the following reasons:

  • The new town is not required, even with the inflated housing numbers in Policy SS1
  • The proposal is unsustainable and undeliverable
  • The supposed sweetener of a secondary school is unnecessary and won’t be placed in a viable location
  • Will lead to coalescence with surrounding settlements
  • Breaks a number of the council’s own objectives elsewhere in the plan
  • It will hinder the much needed regeneration of our urban centres, in particular Fleet

The new town is not required

The housing numbers in the draft Local Plan are too high. Even if one assumes the housing numbers are correct, the council itself admits that the new town is not required.

Hart Local Plan Regulation 19: Hart say we don't need a new town

Not only that, the council themselves admit that the housing supply is under-estimated.

Hart Local Plan Regulation 19: Understated housing supply

And even this under-estimate does not include housing supply identified in the Winchfield and Hartley Wintney Neighbourhood plans.

The combination of the over-inflated housing demand numbers and the under-stated housing supply numbers mean that the new town simply is not required.

The new town proposal is unsustainable

The area of search identified in the Local Plan contains a very wide area, consisting of the areas known as Murrell Green and Winchfield.

Hart Local Plan Regulation 19: Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

We don’t need Hartley Winchook new town so why is it in the Local Plan?

The attempts at sustainability appraisals of the Murrell Green and Winchfield sites have been poor, but nevertheless have demonstrated some very significant weaknesses that cannot be overcome.

SHL167 SHLAA Map - Beggars Corner, Winchfield, Hart District, Hampshire

SHL167 SHLAA Map – Beggars Corner, Winchfield, Hart District, Hampshire

Let’s deal with Murrell Green first. Part of the site, known as Beggars Corner was the subject of a planning application for a Solar Farm. This was refused on the grounds that it would spoil the views from Odiham.  It is difficult to see how a 1,800 unit development would be any less intrusive than a solar farm. Moreover, that planning application identified that part of the Beggars Corner location is former landfill and some of it has unknown contents. This does not appear to be a suitable location on which to build new houses, or indeed form part of a SANG.

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

The sustainability appraisal conveniently did not cover this part of the proposed Murrell Green development.

Moreover, the SA did not manage to discover that there is a Major Accident Hazard Pipeline crossing the site.  Not only that, the developer’s proposal included a secondary school sited right on top of the pipeline. After examination of the HSE rules regarding such installations, I conclude that neither houses nor schools will be able to be built within up to 100m of that pipeline. I also understand that roads should not cross such pipelines either. See analysis here.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

When one adds in other constraints such as SINCs, proximity of a high voltage power line, the railway and the M3, it appears as though the Murrell Green part of the area of search is not suitable for large scale development.

Turning to the Winchfield part of the area of search, it should be noted that the Winchfield sustainability assessment had to be extracted from HDC by FOI request. It can be found here.

The first point to note is that much of land in the Winchfield area of search is not in fact for sale. This comprises the central swathe known as Talbothay’s Farm plus other areas. Immediately, this leads to the conclusion that it won’t be possible to plan for a coherent settlement if the central part is not available.

In addition, the main areas considered to be constraints in the SA report were:

  • Historic Environment
  • Bio-diversity
  • Landscape
  • Water Quality
  • Flood risk

More detail on this can be found here. Other spurious claims were made in the SA, such as the claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is building a wood-burning power station utilising locally sourced timber (p74). Such a plant would be extremely undesirable since burning wood produces more CO2 than burning coal, and none of the proposed master plans include such space for such a plant. Plus, of course, I don’t think many people would support chopping down Bramshill forest to fuel such a plant. This claim was used to indicate that Winchfield was somehow more sustainable than other potential locations.

They also claim that building 3,000 new houses, with associated traffic will somehow “reduce the
emissions of greenhouse gases and manage the impacts of climate change”. Again, complete and utter nonsense.

They also say there was some evidence of wet ground at the far east of SHL183, but “no other obvious evidence of current or past flooding”.

Winchfield Strategic Assessment - Flood Risk 1

This is of course complete nonsense. The detailed assessment also says there’s only a one in 30 year chance of surface water flooding. The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone. Evidence documenting the flood events can be found here (4 Jan) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie). I also understand that a similar area has flooded again in January 2018. These are obviously more than one in 30 year events.

The area east of Winchfield fared less well than Murrell Green in the sustainability assessment even with the grossly understated the flood risk. And of course there were other issues with Historic Environment, Bio-diversity, Landscape and Water Quality. It is difficult to see how this could deliver a significant number of houses.

The area west of Winchfield was ruled out of the sustainability assessment, because it is a more peripheral location relative to the train station, does not offer a central focus and is in close proximity to Odiham SSSI. It therefore offers little prospect of significant housing development.

It is clear that there are very considerable constraints even before considering the infrastructure problems.

Hart has not put together proper estimates of the costs of infrastructure; despite saying it would do so.

Hart Testing Commitment January 2015

We have made several estimates that can be found here, here and here. Essentially, if a new motorway junction is required, the costs will be in excess of £300m. If the new junction is not required, the costs will be at least £200m. A rough schedule of requirements includes:

  • Secondary school and three primary schools
  • New sewage works
  • Power station (as per SA)
  • Improved drainage
  • Re-routing or burying of electricity power lines
  • Railway station upgrade to extend platforms and car park (or relocate)
  • The bridges that carry the railway over Station Road, Taplins Farm Lane and Pale Lane will all need to be upgraded in some way
  • New big roundabouts at either end of the B3016
  • New smaller roundabouts from B3016 and A30 to the new town, new roundabout to join Pale Lane and the A323, new roundabout on A287/Crondall Road and at Pilcot Road/Hitches Lane
  • New or widened roads at Bagwell Lane, Taplins Farm Lane/Church Lane, Station Road, Pale Lane and Chatter Alley/Pilcot Road. Plus many ancient hedgerows will have to be relocated.
  • Potentially widening the A30 around Phoenix Green on the approach to artHHartley Wintney
  • New healthcare facilities
  • New sports and community facilities

If this is a 5,000 dwelling new town, with 40% ‘affordable’, the remaining market houses might be expected to generate £15-20K per unit of S106/CIL. This would amount to around £45-60m. This is well short of the funding requirement and therefore might be expected to make the existing infrastructure funding gap worse.

Taken together, it is difficult to see how such a new town could be either sustainable or viable. Indeed, it is notable that in the three years of this saga, with many Hart Council members being supportive and apparently developers becoming anxious, no planning application has been made. Perhaps that’s because the developers also realise this is a pipedream.

Secondary school unnecessary and not in a suitable location

A number of councillors have made a fuss about a new settlement bringing a new secondary school. The trouble with this is that they have yet to provide a shred of evidence that a new secondary school is in fact required.

Back in 2015, Hampshire’s forecast went as far as 2018 and they were predicting a surplus of places up to 2018. They also forecast a falling birth rate and a significant number of existing pupils attending Hart schools from outside the district.

In 2017, HCC published a new school place plan that showed an overall surplus of places in both secondary and primary schools up to 2021.

A recent letter from a Hampshire Councillor shows that 98% of Hampshire secondary pupils have been allocated a place at a school of their choice for the next academic year.

Hampshire schools keep up with demand

So, having established that a new school is probably not required, we must now address the proposals that have been put forward over the past three years for the sites of new secondary schools.

First, we had Barratts in 2014 putting up a proposal to place a new school right next door to an institution housing sex offenders.

Mildmay Oaks Hospital next door to proposed school

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

Then we had the proposal, described above to build a secondary school right on top of the high-pressure gas main running through the Murrell Green site.

More recently we have had another proposal from promoters of Winchfield which placed the secondary school directly under the high-voltage power lines.

Winchfield Garden Community Master Plan with pylons and powerline

Winchfield Garden Community Master Plan with pylons and powerline

If after three years of trying, they cannot find a suitable location for a secondary school, one does have to come to the conclusion that they never will.

In conclusion, it is apparent that we don’t need a secondary school, and none of the developers involved have managed to find a suitable location.

Coalescence

The area of search is very wide. It borders Hook to the west, Hartley Wintney/Phoenix Green to the north east and comes very close to the Edenbrook development and the proposed Pale Lane development to the east. The bulk of the proposal also comes very close to Dogmersfield.

In other areas of the Local Plan, the council have been quite assiduous in defining strategic gaps. They have produced no such gaps around the new area of search, nor to the east of Hook or anywhere around Hartley Wintney. Nor are any gaps proposed to the north west of Fleet.

Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

If they are allowed to go ahead with this area of search, unconstrained by strategic gaps, there is a strong risk that they will come up with proposals that lead to coalescence of our proud villages.

Breaks the Objectives elsewhere in the Hart Local Plan

Elsewhere in the Local Plan, Hart have come up with a number of objectives. These are reproduced below with my comments in bold on how these proposals break those objectives.

  1. To support the vitality and viability of the District’s town and village centres to serve the needs of residents. Adding a new settlement will draw retail traffic away from our existing urban centres, most notably Fleet, and lead to even faster degeneration of Fleet as a retail destination. This can hardly be described as supporting vitality and viability.
  2. To conserve and enhance the distinctive built and historic environment in the District including the protection of heritage assets and their settings. The proposed area of search includes a Norman church dating back to the Domesday Book and several SSSI’s including at Odiham and Basingstoke Canal. There are numerous other distinctive and historic buildings. Building a new settlement right next door to these valuable assets with neither conserve nor enhance the environment.
  3. To protect and enhance the District’s natural environment, landscape character, water environment and biodiversity, including ensuring appropriate mitigation is in place for new development to avoid adverse impacts on the Thames Basin Heaths Special Protection Area (TBHSPA).Building a new settlement in one of the most attractive parts of the district, containing many woodlands and hedgerows supporting much wildlife such as deer and kingfishers, used by many for leisure and recreation will actively damage the landscape and biodiversity.
  4. To provide measures for adapting to the impacts of climate change and minimising the contribution of new development to the causes of climate change, including reducing the risk of flooding by directing development away from areas at risk of flooding, and using opportunities offered by new development to reduce the causes and impacts of flooding from all sources. We have already established that the SA grossly under-stated the flood risk in the area known as Winchfield East, yet they are proposing to build on this area, directly against their stated objective.
  5. To promote healthy and sustainable local communities through protecting and enhancing community, sport, health, cultural, recreation and leisure facilities, and through the delivery of a multi-functional green infrastructure network across the District. We already have a multi-functional green infrastructure network in Winchfield used for recreation and leisure. Building on it will destroy it, again directly contravening their own objective.
  6. To maintain the separate character and identity of settlements by avoiding development that would result in their physical or visual coalescence. Again, we established the risk of coalescence earlier. This proposal, if implemented would effectively create a single urban conurbation from Hartland Park in the east, across Fleet and Hartley Wintney to Hook in the west. This is an appalling prospect, again directly breaking their own objective.

Remedy:  I would propose that Policy SS3 is removed entirely from the Hart Local Plan, and consequent amendments are made to SS1.

Local Plan: Is the new town an example of predetermination?

Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

Is the new town plan an example of predetermination?

Our research for the Hart Local Plan Regulation 19 consultation has thrown up the possibility that the inclusion of the new town is an example of predetermination. We hope to publish our response in full in the next few days, however, we thought readers might be interested in this analysis which is shown below.

If you are keen to get your submission completed, then you might find inspiration in the work of Hartley Wintney Preservation Society or the Winchfield Action Group. These can be found on the downloads below:

WAG Regulation 19 guide
WAG Regulation 19 guide
HWPS Reg 19 Guide
HWPS Reg 19 Guide

The consultation runs from 9 February 2018 to 4pm on 26 March 2018. The whole suite of documents can be found here.

Now on to our Predetermination research.

Events in November 2014 that indicate Predetermination

Back in 2014, HDC conducted a consultation on housing distribution. This was a non-site specific consultation, with no reference to Winchfield in the Housing Development Options Consultation paper. The council then moved with undue haste to put a paper to Cabinet on 6 November and Council on 27 November where Winchfield was identified as the only option to be tested for a new settlement.

This process was challenged at the time, by amongst others by Hartley Wintney Parish Council. See here.

At the subsequent Cabinet and Council meetings, attempts were made to remove the words “at Winchfield” from the proposed Housing Distribution Strategy.

Housing Distribution Strategy November 2014

It is important to note that the removal of these words would not have precluded the testing of Winchfield. They would merely have opened up the possibility of testing other sites. Failure to remove those words amounted to a strong signal that the council were not open to considering suitable alternatives. Indeed, there was no attempt to even identify suitable brownfield sites that might meet some or all of our housing requirement.

The minutes of both Cabinet and Council show that amendments intended to open up other sites for testing failed.

Much debate happened at council. One councillor remarked that the “only option is Winchfield” and removing the words “in Winchfield” would give residents “false hope”.

This is backed up by contemporaneous email exchanges with councillors such as:

Winchfield is the only option - predetermination

Winchfield is the only option

Options running out imminently. Predetermination

Options running out imminently

Note that although they say they will look at other sites if they come up, they actually vote to exclude that possibility. Indeed some councillors seemed concerned that options to purchase the land may have been due to expire. Maybe this explains their haste to predetermine Winchfield as the sole option for testing.

2016: Draft Local Plan with no new settlement disappears and housing target increases

We understand that in December 2016, a draft Local Plan was produced that did not include a new town at Winchfield or anywhere else. The main reason for this is that despite earlier assertions that there just wasn’t enough brownfield capacity in the district, a planning application for 1,500 new homes on the former Pyestock site had been made. Moreover, a number of office conversions had appeared using Permitted Development Rights. This draft document was rejected by the Community Campaign Hart group and never saw the light of day. The Inspector may wish to request a copy of this document.

This draft was intended to meet the then current SHMA target of 8,022 new dwellings.

Shortly afterwards, it became apparent that the housing target would be increased by more than 2,000 houses. Many people thought the rationale for increasing the housing target by a further 2,000 units was spurious to say the least. However, this meant that it was no longer possible to meet our remaining needs through brownfield development alone.

Lo and behold, later in 2017, a new Regulation 18 consultation was published which included a new settlement at Murrell Green (much of which is in Winchfield Parish boundaries). The Sustainability Assessment test results for Winchfield had to be dragged out of the council using a Freedom of Information request. The SA results for Murrell Green conveniently overlooked the fact that a Major Accident Hazard Pipeline in the form of a high pressure gas main runs through the site. The site schematics included a school built right on top of the gas pipe.

Recent Developments that suggest predetermination

Since the 2017 Regulation 18 consultation, the Government have come up with new proposals to calculate housing need. These reflect much of the criticism we made of the previous attempts at the SHMA. These can be found here, here, here and here. These new targets result in a build rate required of 292dpa over the plan period from 2016-2032 and include an ‘affordability uplift’. Adopting this target would mean that Hart had already granted permission for more houses than is required over the plan period.

Yet, inexplicably, the council has decided to remove the 40% cap on the affordability uplift and introduce a further 25% uplift to give a resultant 388 dpa. Even this inflated target could be easily met without a new settlement. However, policy SS3 has included a new town area of search, even though even the Council admit it is not required (See here, slide 9).

Why a new settlement debunked predetermination

Given all of the history outlined here, it is difficult to come to any other conclusion than certain members of the council had predetermined that they wanted a new settlement and they wanted it at Winchfield. In summary, certain members of the council have frustrated all attempts to test other locations; they have even derailed versions of the Local Plan without a new settlement at Winchfield and ignored all opportunities to avoid concreting over many of the best parts of the district even though even they admit a new town is not required.

It is difficult to avoid the conclusion that certain members of the council had predetermined the outcome from the outset.