Proposal for Massive Distribution Centre at Lodge Farm

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.

 

 

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

Guest Post: What is wrong with Shapley Heath

What is Wrong with Shapley Heath

What is Wrong with Shapley Heath

Today, we have a guest post from Tristram Cary, chairman of the Rural Hart Association. In this post, he sets out his reasons why the Shapley Heath Garden Community is a bad idea.

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

Introduction

Hart District Council is exploring the potential to build a new community in the district of up to 5,000 new homes, with associated community facilities, to meet its long-term housing requirements.” This statement, from the introduction to SHGV Community Survey, sums up HDC’s motivation for embarking on a major publicly-funded project which includes a SHGV website, a sophisticated Communications and Engagement Strategy, a SHGV Stakeholder’s Forum with five Thematic Groups and the commissioning of 13 Baseline Surveys on things like Transport, Heritage, Landscape, Flooding and Utilities.

This article makes the case that:

  1. Hart District Council (HDC) has no business undertaking the SHGV project because:
    • It is a blatant attempt to pre-determine Hart’s future development by promoting its preferred strategy over viable alternatives
    • It is not in synchronisation with the Local Plan which should guide all HDC’s planning activities
  2. By failing to consider the trade-offs involved in developing SHGV over alternative development strategies, the results of the SHGV Project in general, and the Community Survey in particular, will be largely invalid.
  3. The SHGV Project is not merely an expensive and misguided attempt at pre-determination. It is also damaging the prospects for regenerating Fleet (and Hart’s other urban centres), which is an Objective of the Local Plan (unlike SHGV)
  4. SHGV is objectively a bad development strategy for Hart (when compared to the alternatives) in terms of sustainability, climate/carbon footprint, and green spaces.

Predetermination

The SHGV Project team explains that the SHGV project is not an attempt at pre-determination because it is subordinate to the Local Plan. The Project team explains that the SHGV conclusions and recommendations will only carry weight if and when the Local Plan is updated to include SHGV, at that therefore the SHGV project is neutral and unbiased.

This argument is wrong for the following reasons:

  • SHGV is in fact the chosen strategy of HDC. HDC is dominated by Community Campaign Hart (CCH) whose primary objective is to save Fleet/Church Crookham from over-development by building a new Settlement in the Winchfield area. This is made clear in many of CCH’s newsletters (available on the CCH website). Here is an extract from the Spring 2012 CCH Newsletter:

We either continue to grow Fleet & Church Crookham outwards (in which case what, realistically, do you do with the traffic?) or we look at a new settlement.  Winchfield is about the only sustainable location for such a new settlement in Hart District.”

  • The Communication and Engagement Strategy for SHGV is heavily biased in favour of SHGV and makes no attempt to present a balanced view of SHGV in comparison to the alternatives. To illustrate this here are some quotes (with my comments in blue):

Use Shapley Heath in communications where possible [to get the public used to the idea that it is going to happen];

Create awareness of what the alternatives might be (sequential development, developments on appeal) [these are bad alternatives – no mention has been made of good alternatives including regeneration of Fleet to make it more attractive and commercially successful];

We want our audience to know why we think it’s the right location to explore [a clear bias in favour of SHGV and against alternative locations such as Rye Common];

Highlight key benefits – a new community with a unique character, green spaces, employment opportunities, retail space, leisure facilities, economic development, new schools, and other critical infrastructure [no mention of Key Disadvantages such as loss of green space, coalescence of towns, lack of growth potential, damage to prospects of Fleet regeneration, increasing housing capacity which would be taken up by Rushmoor and Surrey Heath under the Duty to Cooperate etc];

Be clear about the limited brownfield opportunities in the district [biased in favour of SHGV and ignores the alternative strategies];

Use subject matter experts (like Lord Taylor of Goss Moor) to highlight the benefits of garden communities from experience elsewhere [stressing benefits without acknowledging the downsides].

Failure to Consider Trade-Offs as a part of the SHGV Project

The SHGV project’s stated aim is to conduct an assessment of the potential of SHGV as a means of satisfying Hart’s long-term housing needs. The SHGV project team insists that the project is unbiased and that all alternatives will be properly explored as required by the Local Plan Inspector. However, if that is true, why would the SHGV project not be open about the pros and cons of SHGV when compared to alternative strategies such as alternative sites for a Garden Village and re-generation of Hart’s urban centres? Every alternative strategy will have advantages and disadvantages, and to hide the disadvantages is clearly biased.

Failure to present SHGV in the context of the alternative strategies will invalidate the results of the Community Survey.

SHGV Project is already Damaging the Prospects for the Regeneration of Fleet and Hart’s other urban centres

The Local Plan identifies that Hart does not provide adequate retail and leisure outlets for its residents. As a result, “The outflow of retail expenditure from the District…is relatively high and is likely to remain high in the future”: [Local Plan para 65.]

The Local Plan goes on to identify the cause of this problem: “The main centres in Hart have not kept pace with other centres in the wider area. Other centres have strengthened and improved their offering through investment and development. Failure to invest in the centres will see them continue to fall in the rankings”: [Retail, Leisure and Town Centre Study Part 1 para 2.15].

To provide Hart with adequate retail and leisure outlets the Local Plan states that “The challenge for Fleet specifically will be to secure investment so that it can compete with the comparable towns in neighbouring districts. All the neighbouring towns are subject to regeneration or expansion projects”: Local Plan Para 66

To attract major investment into Fleet an essential first step is to invest in a Masterplan for Fleet which would identify how the residential, employment, leisure, education, transport, and infrastructure needs could be developed in a coordinated way so that Fleet would become a better, greener, more prosperous and more commercially successful town. It is quite extraordinary that HDC has failed in its clear duty to invest in a Masterplan for Fleet (and note that HDC’s investigation into regeneration of the Civic Quarter is not sufficient)

But to make matters worse, by investing solely in the SHGV project, HDC is sending a further clear signal to developers that Fleet is not a priority. So HDC’s claim that the SHGV project is ‘neutral’ and can run in parallel with the Local Plan without damaging the Local Plan objectives is false. HDC has clearly nailed its colours to the SHGV mast, and by doing so it is already significantly damaging Fleet’s future prospects.

SHGV is Objectively a Poor Strategy

SHGV is objectively a poor strategy compared to the alternatives for the following reasons:

  1. It is a well-established fact that larger settlements are more sustainable than smaller ones (because larger settlements have more residential, employment, health and leisure facilities within easy reach of the residents than smaller ones). SHGV is therefore going to generate a larger carbon footprint than a strategy based on re-generating Hart’s existing towns and villages. This should be a critical issue now that HDC has declared a Climate Emergency and has undertaken to ‘put the reduction of CO2 at the front and centre of all policies and formal decision-making.’
  2. SHGV scores badly against several of the Guiding Principles of Garden Villages. In particular:
    • Green Space – Garden Communities should be surrounded by countryside. SHGV will not be
    • Sustainable Scale – This principle includes the ‘capacity for future growth to meet the evolving housing and economic needs of the local area’. SHGV will have very limited geographical scope for future growth
    • Future Proofed – This principle also includes the ‘capacity for future growth’ which SHGV will not have

Coalescence and Conurbation

What's wrong with Shapley Heath - Coalesence

What is wrong with Shapley Heath – Coalesence

This map shows the density of residential housing in the district (based on March 2017 residential address data in 1km squares). Areas which are not coloured in green are countryside (having less than one home per hectare).

Points to note are:

  1. The green areas of urban development clearly show how coalescence has already caused towns like Yateley, Camberley, Farnborough and Aldershot to be merged into a single conurbation
  2. This conurbation already spreads in a continuous thread from the centre of London westwards to the westerly edge of Fleet
  3. At present Fleet, Hartley Wintney, Hook and Odiham are all surrounded by countryside which adds significantly to their character and provides an important leisure amenity. This is what gives the district its rural character
  4. SHGV would merge Fleet, Hartley Wintney, Hook and Odiham a continuous conurbation, in defiance of the Garden Village principles and the Local Plan vision to maintain the rural character of the district

What is Wrong with Shapley Heath: Conclusions

  1. The SHGV Project is not an unbiased exploration of the potential of SHGV. It is an attempt at pre-determination.
  2. SHGV is causing real damage to the Local Plan aim of attracting investment for the re-regeneration of Fleet and other urban centres
  3. The results of the Community Survey will not be valid because no balanced context has been provided on the advantages/disadvantages of SHGV and alternative strategies
  4. SHGV is objectively a poor strategy which does not align with HDC’s Climate Emergency commitment to put the reduction of CO2 at the front and centre of all polices and decision-making
  5. SHGV will cause coalescence between Fleet, Harley Wintney, Hook and Odiham which will significantly damage their character as well as the rural nature of Hart District.

Recommendations

  1. HDC should abandon the SHGV Project and invest instead in a comprehensive Masterplan for Fleet which is an essential first step towards meeting the Local Plan objective to secure funding for Fleet regeneration
  2. Failing a), the SHGV project should provide clear information about the pros and cons of SHGV when compared to the alternative development strategies
  3. Respondents should be encouraged to object to the clear bias of the SHGV Community Survey

Shapley Heath Climate Change Impact

Shapley Heath Climate Change Impact

Shapley Heath Climate Change Impact

In the light of the focus on the environment in the General Election campaign, we thought it would be a good idea to look at the Shapley Heath Climate Change impact.

Shapley Heath Climate Change Impact: Summary

  • 1,000,000 tonnes of CO2 emitted from construction
  • 312,000 tonnes of CO2 per annum from the occupants
  • Loss of pasture carbon sink
  • Damage to SSSIs, Ancient Woodland and heritage

Yet, Hart has agreed the “serious impact of climate change globally” and recognises “the need for urgent action”.  Councillor Graham Cockarill is standing in the General Election as a Liberal Democrat candidate. They say “the UK should be leading the world on tackling the environment crisis”.

Why are they pursuing an unnecessary new town that goes against their own climate change policies?

Shapley Heath Climate Change Impact: CO2 emissions

According to this article in the Guardian, construction of an average 2-bed cottage emits around 80 tonnes of CO2.  The average size of Shapley Heath dwellings is likely to be larger, so let’s assume 100 tonnes of CO2 per dwelling.  The vision and bid documents both suggested the eventual size of Shapley Heath will be 10,000 houses. So, building 10,000 houses will emit around 1,000,000 tonnes of CO2. There will of course be additional emissions from building new roads, supermarkets and office blocks.

These 10,000 houses will house around 24,000 people, and each of them will emit on average ~13 tonnes of CO2 per annum each. So, there will be 312,000 tonnes of CO2 emitted by the occupants of the houses.

Moreover, the existing pasture acts as a carbon sink, so this benefit will be lost too.

Remember, the Hart Local Plan, the Inspector’s report and even the bid document said that Shapley Heath isn’t required to meet our housing targets, so all of these emissions are entirely avoidable.

Shapley Heath Climate Change Impact: Damage to Nature

The area of search contains or borders many important natural sites. These include:

  • Odiham Common SSSI
  • Basingstoke Canal SSSI
  • Numerous ancient woodland sites that are also Sites of Importance for Nature Conservation
Shapley Heath Climate Change Impact - Damage to nature

Shapley Heath Climate Change Impact – Damage to nature

Hart District Council and Lib Dem Climate Change Policies

Back in September, Hart Cabinet decided the following in respect of climate change (our emphasis):

  1. Recognises the serious impact of climate change globally and agrees that there is a need for urgent action; and

  2. Agrees that a cross party Climate Change Member Working Group be established and that the Terms of Reference for that Group as set out in Appendix 1 be agreed in principle; and

  3. That a Climate Change Strategy and Action Plan led by the Member Working  Group be prepared by January 2020 based on Hart District Council becoming a net zero carbon emitter by 2040 at the latest.

Councillor Graham Cockarill is standing in the General Election as a Liberal Democrat candidate. They say:

The UK should be leading the world on tackling the environment crisis. Our planet is on the brink of being irreparably damaged and we are responsible for that damage.

Why are they pursuing an unnecessary new town that goes against their own climate change policies?

Return of the New Town: Winchfield fights back

We Heart Hart and Winchfield Parish Council (WPC) are fighting back against the decision to award funding for the  new town.

WPC has written to the Secretary of State demanding that the decision to award £150,000 of capacity funding to support the delivery of the Hartley Winchook/ Shapley Heath garden community new town be reversed.   In addition, We Heart Hart has written to MHCLG making a similar request, using slightly different arguments. We understand that the Rural Hart Association will also be making representations to MHCLG.

A summary of the WPC letter is shown below, together with links to the full text. The full text of the WHH letter follows.

Winchfield fights back: WPC Letter

The letter has the support of Hartley Wintney, Dogmersfield, Crondall, Greywell and Long Sutton & Well Parish Councils. The Parish Councils of Eversley, Odiham and South Warnborough have made known to WPC their concerns about the proposed development and will consider adding their full support to the letter when they next meet. WPC’s letter highlights the following concerns:

  1. The Inspector’s findings following the independent examination of the Local Plan rejected the SHGV proposal, which followed HDC’s Garden Village Application in November 2018.
  2. HDC’s ongoing promotion of SHGV is not supported by the Inspector’s findings on the submitted Local Plan and he is quite clear that other options need to be considered in an impartial manner.
  3. The absence of sound justification for bringing forward SHGV (as it is not needed to meet identified housing needs) and the lack of evidence to demonstrate that the proposal is deliverable and sustainable was confirmed by the Inspector’s findings on the submitted Plan.
  4. The numerous shortcomings with HDC’s bid when considered against the Garden Communities prospectus lead us to question how it has been successful.
  5. HDC pre-determined the plan-making process, and failed to provide the evidence to the Inspector to demonstrate that it had impartially assessed reasonable alternatives. If HDC proceed with a Local Plan review as indicated based on SHGV as its chosen long term growth strategy, it will irresponsibly overlook the Inspector’s criticisms of the current Plan’s failure to impartially assess reasonable alternatives, and continue to ignore local opinion. HDC’s bid to be included in the Gardens Community Programme is a further demonstration of their continuation of pre-determine the planning process.
  6. HDC’s ongoing promotion of SHGV is not supported by the local communities directly impacted by this large scale proposal.

The full text of their letter can be found here. And the appendix can be found here.

Winchfield Fights Back: We Heart Hart letter

The full text of our letter is set out below:

Dear Ministers,

 Re: Hart District Shapley Heath Garden Community Funding Award

My name is David Turver. I run a campaign in Hart District called We Heart Hart. We have taken an active role in the Hart Local Plan, and I was invited to speak at the examination hearing. We have successfully campaigned against the new settlement proposal. We believe that urban regeneration and brownfield development is a much more sustainable and better way to deliver Hart’s longer term development needs.

I note that you have recently awarded £150,000 of capacity funding to Hart District Council to support the delivery of the Shapley Heath so-called Garden Village in Winchfield/Murrell Green.

I would like to share with you some extra facts which may cause you to reconsider your decision. The main letter sets out the main points, backed up with links and references in the Appendices. I have copied my local MP, the leader of the Conservatives on Hart Council and your garden communities email address so you can obtain a soft copy of this letter and follow the embedded links if required.

New Settlement Policy SS3 not required and not sound

Hart’s Garden Community bid in November 2018 relied on Policy SS3 being found sound in their Local Plan examination. Policy SS3 proposed a new settlement in the same area of search as the proposed Shapley Heath development. The Local Plan itself acknowledges that the new settlement is not required to meet Hart’s housing needs. The Planning Inspector, Jonathan Manning, found that he had “a number of fundamental concerns with regard to the soundness of Policy SS3”. As a result, Hart Council has removed policy SS3 from the Local Plan to make the plan sound. See Appendix A for more details.

More work required to make new settlement sound leading to a delay of up to five years

The Inspector has said that much more work was required to make the new settlement sound:

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options. Any further SA work would also need to include additional standalone consultation….

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.

There are several alternative options, including alternative sites and alternative strategies such as urban regeneration. So, it is clear that a new SA would be a considerable undertaking in its own right. In the risk assessment accompanying Hart’s bid they anticipated this outcome. Their mitigation was to press-on regardless with the new settlement DPD, independent of the Local Plan. I am not at all convinced that creating a DPD outside of the Local Plan process is in line with the planning regulations.

However, the Inspector makes clear that significant SA work and a standalone consultation ought to precede a new DPD.  Moreover, in Hart’s latest consultation into the modifications required to make the Local Plan sound, they have completely changed their tune. The Sustainability Appraisal Addendum says that “the AoS/DPD process will effectively be replaced by a different process, most likely a new Local Plan” (see Appendix B). The impact of this is that:

  1. The further SA work may conclude that there are better alternatives to delivering longer term growth. I know there are many in the District who support our local MP’s call for urban regeneration.
  2. Even if it is decided that a new settlement is the best long term growth option, the timescales for a new Local Plan process indicate that work on a new DPD will not start for a considerable time; maybe up to five years.

No plans to meet commitments in the Garden Community bid

In their bid, Hart committed to producing a New Settlement DPD in December 2019 if they received the Garden Community funding (see Appendix C). Yet, in response to recent questions at council, they confirmed that they have no current plans to start the additional SA work required by the Inspector; no plans to produce the New Settlement DPD and have not allocated any of the £786K budget set aside for the New Settlement in FY19/20. It might be expected that the wide scope SA work would take at least six months, plus a further 2-3 months for a consultation. It is therefore difficult to see how work can start on a new DPD this financial year. Therefore, it is difficult to see how the Garden Communities grant money can be spent effectively during this financial year.

Deceptive Communications

In addition, I am sorry to report that the Lib Dem/Community Campaign Hart led Hart Council has not been as open and transparent as one would hope in its communications on this matter.  Recently, the council was asked who had been informed that Policy SS3 had been found unsound and removed from the Local Plan. Their answers stated that both Homes England and MHCLG had been kept informed prior to the funding announcement. However, a subsequent release of correspondence shows that the removal of Policy SS3 was a passing comment to an official in Homes England in an email about a different subject. There is no record of MHCLG being contacted directly. I am therefore concerned that MHCLG may not have been aware that the new settlement had been found unsound between Hart Council’s bid and the award of funding in June 2019. It would be a shame if the Government awarded money to fund an unnecessary and unsound white elephant project.

Alternative options

Quite separately, Hart made a recent bid for funds under the Future High Streets scheme and was turned down. Our local MP, Ranil Jayawardena is running a campaign to support urban regeneration within Hart.

The catalyst for this could be the publicly owned civic quarter containing the Hart Council offices and the Harlington Centre. The area is ripe for mixed-use redevelopment including offices, homes, social and retail. If all levels of Government got behind this, it would spark interest in redeveloping the rest of the High Street, including the Hart Shopping Centre.

Conclusions

In conclusion, it is clear that the facts have changed since the bid was submitted.

  • Policy SS3 covering the Shapley Heath new settlement has been found to be unnecessary and unsound and removed from the Hart Local Plan.
  • There are no plans to conduct the wide ranging SA work required that might bring the new settlement back on to the agenda.
  • There is no guarantee that such work will conclude that a new settlement is the best option for long term growth.
  • It is inconceivable that such work could be completed during this financial year, meaning that work on a new settlement DPD could not even start before FY20/21, so the funds you have awarded could be wasted.

Therefore, I would be grateful if you could review your decision in the light of new facts. There are many residents of Hart who would be pleased if the Garden Communities funds were redirected towards regeneration of our decaying urban centres instead of concreting over the very green fields that make Hart such a great place to live.

Thank you for your kind consideration of these points. I understand Hart Council representatives are meeting with Homes England this month, so I hope you have time to re-consider the funding decision before that meeting. I look forward to your prompt reply.

Yours faithfully,

 

David Turver

cc:           Ranil Jayawardena MP (by email)

[email protected] (by email so the embedded links work)

Anne Crampton, leader of Conservative group on Hart Council (by email)

 

Appendix A: – Hart’s Assumptions and Inspector’s Report into Hart Local Plan

Here is Hart’s bid assumption that Policy SS3 would need to be found sound in the Local Plan:

Winchfield Fights Back - Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

Shapley Heath funding assumes Policy SS3 remains in Hart Local Plan

The Inspector’s post-hearing letter about the examination of the Hart Local Plan can be found here.

May I draw particular attention to paras 17-39. A summary of his findings with respect to the Sustainability Appraisal and the New Settlement are shown below:

  • The ranking of Option 1b (the new settlement) “as the best performing under heritage is not justified”.
  • For land and other resources, the ranking of Option 1b “is also therefore not, in my view, robust”.
  • The Inspector decided that “the decision not to rank the options in terms of flood risk to be very questionable”.
  • On landscape issues the Inspector concluded:

Option 1b was ranked joint highest with Option 1a. However, it is unclear why this is the case, given that the proposed new settlement would result in the development of large areas of open countryside and Option 1a already benefits from planning permission and is largely previously developed land. Further, the post submission SA notes that Pale Lane is ‘relatively unconstrained’, but despite this and it being a smaller site / potential development, Option 3a is ranked lower than Option 1b.

  • The Inspector has this to say on the climate change ranking:

Option 1b has been ranked the highest under the category climate change. This is as a result of the potential for the proposed new settlement to deliver a district heating system. However, there is little evidence to suggest that this is a feasible or realistic option that is being actively pursued by the site promoters. I consider this raises doubt about the appropriateness of such a ranking.

  • The ranking for the impact on water was also criticised by the Inspector.

In conclusion on the SA the Inspector said:

In my judgement the scoring of Option 1b above or equal to other options is not justified by the evidence. As a result, I consider that Policy SS3 and its supporting text are not justified, as, on the currently available evidence, it cannot be determined that it represents the most appropriate long-term growth strategy.

I consider that the post submission SA is therefore not robust and should not be relied upon in support of the Plan.

In addition, the Inspector clearly states:

Given my earlier findings in terms of the housing requirement, 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 through Main Modifications (MMs). This would allow the Plan to progress towards adoption without any significant delay to the examination process…

I consider that it would not be unsound for the Plan to retain the Council’s aspirations to plan for long-term needs beyond the Plan period, which could include the delivery of a new settlement. But, the Plan should clearly state that this, as a growth option, would need to be fully considered and evidenced in a future (potentially early or immediate) review of the Plan or a subsequent DPD…

I am of the view that a significant level of further supporting work would be required for Policy SS3 to be found sound in its current form, which would need to include appropriate and proportionate area/site assessments, infrastructure considerations, viability testing, evidence in support of deliverability and further SA work, which would need to be done in an impartial manner with sufficient evidence to support its findings and comparisons with alternative options…

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.

 

 

Appendix B: Local Plan Modifications and Sustainability Appraisal Addendum

The main modification related to removing Policy SS3, New Settlement from the Hart Local Plan can be found below. The full consultation can be found here.

Winchfield Fights Back - Shapley Heath Policy SS3 removed from Hart Local Plan

Winchfield Fights Back – Shapley Heath Policy SS3 removed from Hart Local Plan

The Sustainability Appraisal Addendum accompanying the consultation into the Main Modifications to the Local Plan can be found here.

I draw your attention to page 2:

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

Winchfield Fights Back: SA Addendum impact on Winchfield New Town Area of Search

 

Appendix C: Bid Commitments and Lack of Current Plans

No doubt you already have a copy of their bid commitment. Here is the commitment to produce a New Settlement DPD for consultation by December 2019.

Winchfield Fights Back: Shapley Heath New Town Bid Timeline for DPD

New Settlement Bid Timeline for DPD

The draft minutes from the Hart Council meeting held on 25 July 2019 can be found here. I refer you to Q&A in Appendix A.

Here is the response that shows no plans to carry out the additional SA work required by the Inspector:

Winchfield fights back: No plan for SA work

Winchfield fights back: No plan for SA work

No plans to allocate budget:

Hart Council has no idea how it will spend £786K winchfield new town money

Hart Council Knows Nothing: No idea how much of £786K will be spent or when

No plans for a New Settlement DPD.

Hart Council has no plan for Winchfield New Town proposals

Hart Council Knows Nothing: No plan for New Settlement DPD

 

Appendix D – Deceptive Communications

Statement at Hart Cabinet in July that both Homes England and MHCLG were informed:

Winchfield fights back: Chairman Announcement MHCLG kept informed

Winchfield fights back: Chairman Announcement MHCLG kept informed

Question asking how MHCLG and Homes England were kept informed of the changing status of the New Settlement in Policy SS3 in the Hart Local Plan.

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

Winchfield fights back: Cockarill MHCLG and civil servant kept informed

 

The subsequent release of correspondence shows only one email to Kevin Bourner informing him in passing of the removal of Policy SS3. This can be found here.

Key passage:

Winchfield fights back: HDC email to Homes England

Winchfield fights back: HDC email to Homes England

The only correspondence with MHCLG prior to the announcement is asking for an update on the announcement timetable. This email is not addressed to Simon Ridley who made the award.

 

 

 

 

Where is the draft Hart Local Plan?

Hart Local Plan - Keep Calm and Wait until 26 April

Hart Local Plan – Keep Calm and Wait until 26 April

Regular readers maybe wondering what has happened to the Hart Local Plan. On February 9th, Hart Cabinet agreed to a spatial strategy as part of the draft Local Plan that was due to go out to consultation in March. Obviously, there have been further delays. This is what we now understand to be the position:

Hart Local Plan timetable

The draft local plan will be released 26 April for a six-week Reg 18 consultation period after a briefing session with Parish Councillors on the 25th. There will be roadshows at the main settlements. Every house in the district will receive an A5 leaflet advising them of the consultation.

The Reg 19 process will follow in about November with submission of the full plan to the Secretary of State in mid-February 2018. All responses during the Reg 18 will be made public including the names of the individuals but with no contact details.

Hart Local Plan Headlines

Hart Council have decided to build 10,185 houses up to 2032 of which around 50% have already been built or granted permission. Please note that this number is far higher than 8,022 target the recently published Strategic Housing Market Assessment and more than double the requirement generated from demographic change. The numbers are now correct as of 31 January 17 and include all office conversions which have been approved.

Housing Numbers by area

  • Fleet 200 – mostly through office redevelopment
  • Hook was 200 now 10 from office redevelopment plus another 87. However, developers may chance their arm again with Owens Farm (750), and of course around half the Murrell Green site is in Hook Parish.
  • Sun Park 320
  • Hartland Park (Pyestock) 1500. Fleet town council have apparently made the point that the site offers only 20% affordable homes and the density per hectare is up to 97 in places which is equivalent to city centre densities which is of concern to them. OUr view would be to make the most of available brownfield sites.
  • Murrell Green 1800 but with challenges. There are 4 promoters and it will be some 3 to 4 years before planning permission is approved. It includes the site for a secondary school but there won’t be enough developer contributions to pay for it. New school funding rules mean that Hampshire can’t pay for it either.  It’ll probably be an Academy at a cost of circa £36 million. So we get a site for a school, but no money.
  • Crondall 66
  • Crookham Village 100 + 64 predominantly the care village
  • Eversley 124 on two sites
  • Heckfield 86
  • Long Sutton 10
  • Odiham 119 as per NP
  • Hartley Wintney 0. It seems odd that HW’s Neighbourhood Plan will be ignored. It should be noted that Murrell Green directly abuts Hartley Wintney Parish and about half of the proposed Pale Lane (Elvetham Chase) development is in HW parish.
  • South Warnborough 34 on two sites
  • Yateley 88
  • An additional 50 via rural exceptions and a further 290 from windfall.
  • Interestingly, no mention of Winchfield, or their Neighbourhood Plan, but roughly half of Murrell Green is in Winchfield Parish.
  • Apparently, Bramshill will be very difficult to develop because of all the complications with the Grade 1 listed site.

Other news

Apparently East Hants have done such a stellar job on the Local Plan, the Planning Policy team is now back in house at Hart, reduced in size from 8 to 2.

There is a risk that developers will continue to pursue Pale Lane and take it to appeal before the Local Plan is adopted.

We await the results of the Grove Farm (Netherhouse Copse) appeal in June.

Is the Murrell Green new settlement viable?

Murrell Green new settlement proposal

Murrell Green new settlement proposal

We wrote yesterday that the council has prioritised the Murrell Green new settlement as part of the Hart Local Plan. However, there are very real questions about the viability of these proposals.

  • Environmental concerns
  • Infrastructure issues
  • Coalescence of Hartley Wintney and Hook
  • Financial stability of the promoter

Environmental concerns about the Murrell Green new settlement

Part of the site includes Beggars Corner which is the triangular piece of land between the railway and motorway. A proposal for a solar farm on this land was turned down at appeal last year. The main reasons for turning it down were:

  1. Harming the enjoyment of those walking the public footpath across the site. This is shown as a dotted red line on the map
  2. Spoiling the view from the Deer Park at Odiham

Houses are obviously taller than solar panels, and indeed some houses might have solar panels on their roofs. So, how can it be sensible to build houses when solar panels were deemed inappropriate?

Furthermore, a significant part of Beggars Corner used to be landfill, with unknown contents

SHL 167 Landfill details Beggars Corner

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

It is not appropriate to build houses on this type of land. Nor should it be promoted as green-space for children or dog walking when we don’t know what toxins lie beneath.

It should also be noted that a 110kV electricity transmission line traverses the site as well as a high pressure gas main. Hardly appropriate for housing or recreation.

Gas Main through Murrell Green new settlement Site

Gas Main through Murrell Green Site

The site is also within the Thames Valley SPA 5km zone of influence. There are three Sites of Interest to Nature Conservation (SINC) on the site plus a further SINC just to the west at the River Whitewater.

Finally, there are a number of public footpaths that currently criss-cross the site and they appear to be destoyed by this new proposal.

Infrastructure Issues

The only access to the south of the proposed Murrell Green new settlement is Totters Lane. This is single track in places with a very narrow bridge over the railway. To the north there is the A30 which is already very busy, with choke points at Phoenix Green, Hartley Wintney and the roundabout in Hook. It is difficult to see how these choke points can be alleviated.

Those of us who use Winchfield station know that the car-park is frequently full to capacity and of course, the whole line to London is running over capacity. The idea that either Hook or Winchfield stations can accommodate the extra passengers from thousands more houses is simply laughable.

In addition, the previous strategic assessment of Murrell Green included concerns about:

  1. Healthcare provision – I can speak from personal experience that Whitewater Health that covers Hook and Hartley Wintney is full
  2. Primary school provision
  3. Availability of supermarkets

Coalescence of Hartley Wintney and Hook

The proposed site abuts the south western boundary of Hartley Wintney parish and is close to what are currently quite widely spaced houses.

Hook SHLAA sites in Hart District, Hampshire

Hook SHLAA sites in Hart District, Hampshire

The western side of the Murrell Green new settlement comes within a couple of hundred metres of the new development to the NE of Hook (sites 1, 2 and 3 on the image above). Note that sites 4 and 126 on the map above are not (yet) included in the new settlement proposal.

In essence, we are creating Hartley Winchook.

Financial viability of the promoter

Last year, it came to light that there was a ‘secret plan‘ for a very large settlement that included both Winchfield and Murrell Green. The Murrell Green part of the proposal was promoted by a company called Pearson Strategic Limited.

There are a number of pertinent facts about this company:

  1. It only has one director, James Turner
  2. It was only incorporated in November 2014 and has no revenue
  3. At the time of its last accounts, it has a negative net worth of £3,240
  4. Its only real asset is promotion rights over Totters Farm that has been mortgaged under a fixed and floating charge to Monopro Limited.

One really has to question whether we should be building the Hart Local Plan around a site with such little backing.

Accounts to Pearson Strategic can be found here.

Fixed and Floating charge document can be found here.

Conclusion

Some Hart Councillors seem hellbent on a new settlement regardless of the suitability or viability. In addition, they have not challenged the new Strategic Housing Market Assessment (SHMA) hard enough. If we are sensible about the housing targets and get properly serious about the brownfield opportunities we don’t need a new settlement anywhere in Hart.

Time to make our voice heard again.

 

Save Rye Common Action Group launch website

save rye common action group. Oppose rye common new village development

Rye Common which is between Odiham and Crondall in Hart District, Hampshire

The Save Rye Common Action Group have launched their website to promote their opposition to the proposed Rye Common New Village development. They have also published a report from Berrys, a leading firm of quantity surveyors that sets out the main reasons for opposing development on this splendid example of the local countryside.

Please do all you can to support them.

Their website can be found here, and the Berrys report can be found here.

More details about the proposals can be found in our earlier article.

Odiham Parish Council to discuss Rye Common Proposals

Rye Common, Odiham, Hart District, Hampshire

The Basingstoke Gazette has run a story about the proposed Rye Common new village development. Odiham Parish Council is going to discuss the proposals for a new village between Odiham and Crondall.  It is clear they are very concerned about the proposals, with chairman saying:

“The parish council are well aware of the consultation being undertaken for a large development at Rye Common, located within the parish of Odiham.

“This has of course created significant interest and indeed concern within our community.”

He added: “While the parish council are required to review all proposals with an open mind, I have heard no local enthusiasm for the scheme and would want to understand how this volume of houses proposed works against HDC’s revised Strategic Housing Market Assessment.”

“It is hard to see any value to our existing community and in my view would significantly impact the character of Odiham and the surrounding of communities.”

We Heart Hart is quoted in the article saying:

“The Rye Common development is simply not required because our housing targets are reducing and there are plenty of brownfield sites available that can meet our housing needs for decades to come.”

More details about the proposals and how to respond to the consultation can be found here.