Elvetham Chase Appeal Documents Revealed

Wates Pale Lane aka Elvetham Chase Appeal

Elvetham Chase Appeal Documents

The Pale Lane aka Elvetham Chase appeal documents have been made available. At the time of writing, they haven’t yet been published on the Hart Council website, nor on the Planning Inspectorate website. These documents confirm our story that the Wates have appealed the decision to turn down the proposed development of 700 new houses.

The two documents can be found as downloads at the foot of this article.

The key elements of their statement of case are:

Elvetham Chase Appeal – Policies out of date

Elvetham Chase Appeal Policies out of date

Wates argue that the policies used to refuse the original application are out of date. This argument was successful when the Grove Farm development was approved on appeal.

Elvetham Chase Appeal – Little impact on Fleet

Elvetham Chase Appeal Policies little impact on Fleet

Wates also argue that, contrary to Hart’s refusal decision, the Pale Lane development will have little impact on Fleet. In addition, the policies Hart have used to justify this stance are out of date.

Elvetham Chase Appeal – Local Plan too slow

Elvetham Chase Appeal Policies Local Plan too slow

Wates are also arguing that Hart have not kept to their timetable for the Local Plan. There was supposed to be a presentation to members during May, prior to submission on 18 June. We understand that presentation did not happen, so the 18 June deadline may be at risk.

They also argue that the draft Local Plan and the site allocation may well face legal challenge.

The draft Local Plan doesn’t include Pale Lane in the site allocation. They say the plan is a long way from adoption and that refusal isn’t justified on those grounds. Wates are effectively saying that the draft Local Plan should carry very little weight in the appeal decision.

Elvetham Chase Appeal – Our View

We think the appeal will rest on this issue. If the Inspector believes the draft Local Plan carries significant weight, then he may well refuse the appeal. If however, he believes the opposite, then on the past precedent of Grove Farm, then he will probably allow the development to proceed.

We think Hart’s chances of successfully fighting this appeal are higher than Grove Farm, and it is probably worth the cost and effort of doing so. However, we hear some councillors are much less optimistic about Hart’s chances of success. Let’s hope common sense prevails and the appeal is dismissed.

We will work on what we think are the best arguments for fighting the appeal.

Wates Pale Lane/ Elvetham Chase Appeal Statement
Wates Pale Lane/ Elvetham Chase Appeal Statement
Wates Elvetham Chase/ Pale Lane Appeal Statement of Common Ground
Wates Elvetham Chase/ Pale Lane Appeal Statement of Common Ground

Appeal statement of case that can be found here.

Draft statement of common ground that can be found here.

 

Council announce Hart Local Plan Submission Date

Council announces Hart Local Plan submission date

Council announces Hart Local Plan submission date

The council has announced the submission date for the Hart Local Plan.

The news is contained in papers due to be considered by Cabinet on 7 June. The relevant paper can be found here.

They say the plan will be submitted during week commencing 18 June:

It is anticipated that the Hart Local Plan Strategy and Sites 2016-2032 Submission Version (the Submission Plan) will be submitted to the Secretary of State in the week commencing 18 June 2018. Once submitted the Submission Plan does not supersede the Hart Local Plan 1996 – 2006 (Saved Policies). The saved policies will still comprise the Development Plan for Hart.

This is in line with earlier commentary from the Joint Chief Executive at an earlier council meeting.

Impact of submitting the Hart Local Plan

Although the submitted plan doesn’t yet form the development plan for Hart, it should have some weight in determining planning applications (and one hopes, planning appeals):

The Submission Plan gains some weight in decision-making. Paragraph 216 of the National Planning Policy Framework (NPPF)) states that decision-takers may also give weight (unless material considerations indicate otherwise) to relevant policies in emerging plans according to:

  • The stage of preparation of the emerging plan (the more advanced the preparation, the greater the weight that may be given).

  • The extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given).

  • The degree of consistency of the relevant policies in the emerging plan to the policies in NPPF (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given).

The council’s comentary says:

The Submission Plan is at an advanced stage of preparation. Therefore, it should be given weight in the decision-making process and so upon submission to the Secretary of State it should be used in the determination of planning applications. Furthermore, as it reflects approved Council policy, applications that are determined in accordance with the Submission Plan should not be considered as representing “departures” where approval would otherwise require referral to Council for determination.

We can only hope that the submission of the Local Plan helps in fending off the unwelcome appeal against the decision to refuse planning permission for 700 new houses at Pale Lane.

Wates launch Elvetham Chase aka Pale Lane appeal

Wates launch Elvetham Chase aka Pale Lane appeal

Elvetham Chase aka Pale Lane appeal

[Update 1: 29/5/2018: We understand that the developers have stated they intend to appeal, but have not yet submitted the appeal documentation]

[Update 2: 6/6/2018: Story now confirmed by Fleet News and Mail. Copy here.]

[Update 2: 8/6/2018: Appeal documents published here.]

We understand that the agents for the developers have submitted a Pale Lane appeal. The site, also known as Elvetham Chase was, quite rightly in our view, turned down for development of 700 new houses by Hart Council back in February. The developers, Wates, were apparently quite angry.

The Pale Lane appeal comes despite the recent Hart Local Plan Regulation 19 consultation. Of course, the draft Local Plan doesn’t include Pale Lane in the housing plans. We understand that Hart plan to submit the Local Plan to the inspector on 18 June. The plan published as part of the consultation has some weight to fend off this unwelcome development. That weight should increase when the plan is submitted to the Inspector. But it won’t have the same weight as a plan declared sound by the Inspector.

We don’t yet know the timeline for the Local Plan inspection hearing. Nor do we know the timeline for the Pale Lane (Elvetham Chase) appeal.

Impact of Pale Lane Appeal

So, this move sets in train some complex legal and procedural manoeuvres and a race agaisnt time for both Hart and Wates. Clearly, Wates believe they can win or they wouldn’t be spending the money on the appeal. They are clearly hoping their appeal will be heard prior to the Local Plan being inspected and declared sound.

Despite opposing the development, we think the grounds for rejecting the proposed development were quite weak. The grounds for the decision can be found here. Unfortunately, Hart doesn’t have a good track record in defending appeals.

We have to hope that the current state of the Local Plan will provide stronger defence that the Council’s current outdated policies.

Another of the 1 in 30 year Winchfield Floods

Winchfield Floods Taplins Farm Lane 20180411

Winchfield Floods: Taplins Farm Lane 11 April 2018

It seems 1 in 30 year Winchfield floods are becoming a habit. Here are images of the flooding on Taplins Farm Lane on 11 April 2018.

This area has flooded many times in recent years as we documented here (4 Jan 2016) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie). Earlier this year Winchfield flooded on 24 January and on 30 March as documented here.

Apparently, this latest flood comes just after the drainage culverts were cleared last week.

It is almost as if the Sustainability Assessment and Flood Risk Assessment are total nonsense.

Winchfield Floods Taplins Farm Lane 20180411

Winchfield Floods: Taplins Farm Lane 11 April 2018

 

Winchfield Floods Taplins Farm Lane 20180411

Winchfield Floods: Taplins Farm Lane 11 April 2018

 

Winchfield Floods Taplins Farm Lane 20180411

Winchfield Floods: Taplins Farm Lane 11 April 2018

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.

Cabinet Update: Pressure on to deliver the Hart Local Plan

Hart District Council seeks to block brownfield development

Hart District Council under pressure to deliver the Local Plan

Unfortunately, we could not make it to the Cabinet meeting on Thursday 5 April. However, we have received feedback from the meeting about the Hart Local Plan item.

Respondents to the Hart Local Plan Regulation 19 Consultation

We understand there were around 300 respondents to the consultation. However, there are about 1,500 individual representations. The council has its work cut out to analyse the representation and provide a response to each one.

Key themes

The key themes emerging from the consultation include a number of contradictory elements:

  • Inadequate infrastructure
  • Housing numbers too high
  • Housing numbers too low (from developers)
  • Housing numbers not robust
  • Quality of life issues
  • Reliance on strategic sites
  • Revisit reg 18 for sites
  • Should have more sites to spread the load
  • New gaps / more gaps
  • No gaps at all (from developers)
  • Employment sites/  brownfield sites
  • Regeneration of town centres, particularly Fleet
  • No minimum internal size (floor space) specified

In addition, there is a need to focus on sustainability and decide if the approach of adding a new settlement is sound. Apparently, Basingstoke and Deane objected to the new town on the grounds of the extra traffic it would generate. [Obviously we believe it is not sound, but that is for the Inspector to decide].

Timetable to submission of the Hart Local Plan

There was discussion of the work required before the Hart Local will be ready for submission. This includes:

Feedback from the Independent Planning Consultant (Keith Holland, a former Inspector) is expected by late April.

In addition a topic paper has to be produced to explain how the housing number was arrived at and other options if different numbers were used (i.e. plan ‘b’ and plan ‘c’).

Then  a further series of tasks are required:

  • Update project plan
  • Format each representation, enter onto database including HDC response
  • Update consultation statement
  • Identify issues arising from consultation
  • Make minor modifications to plan
  • Provide statements of common ground (highways, neighbouring councils etc.)
  • Review and update topic papers (including the new one on housing numbers)
  • Infrastructure plan review
  • Soundness check list
  • Review reg 18 and how consultation was responded to

There might be another meeting of the Local Plan Steering Group (LPSG) before submission.

The project team consists of one full-time leader and three part-time team members. However, the leader has been off sick recently. They want to get the plan submitted as soon as possible to help fight off two anticipated appeals. [We don’t know which ones exactly, but we would hazard a guess at Elvetham Chase (Pale Lane) and West of Hook].

They hope to achieve submission by mid-to-late May. [Our view is that this sounds ambitious given the level of work and the apparently sparse resources allocated].

Questions from the floor

Apparently, a number of questions were asked relating to:

  • Which housing numbers to use. Should these be based on the old SHMA or the newer Government methodology. It appears as though this hasn’t been decided yet. [We would prefer if the new Government methodology was used, as it gives a lower number. However, the inflated numbers the council have used in the Local Plan are slightly higher than the SHMA, once they are adjusted for the building between 2011 and 2016. So, either scenario does not require a new town].
  • Membership of the LPSG. Apparently, Conservative members won’t be invited to the LPSG unless their particular expertise is required.
  • Resourcing for the Local Plan. Apparently this is a very sensitive subject that resulted in some argument. [We take it that the officers feel under pressure to deliver quickly and are struggling for resource].

Let’s see what happens.

 

 

Winchfield Flood on Taplins Farm Lane Again

Winchfield Flood Taplins Farm Lane 30 March 2018

Winchfield Flood Taplins Farm Lane 30 March 2018

As sure as night follows day the great Winchfield flood has happened again on Taplins Farm Lane. This follows another flood in Winchfield earlier this year.

Winchfield Flood 24 January 2018

Winchfield Flood 24 January 2018

This area has flooded many times in recent years as we documented here (4 Jan 2016) , here (7 Jan)here (9 March on Station Road) and here (28 March due to #StormKatie).

This of course flies on the face of the Winchfield Sustainability Assessment that claimed the area was only at risk of flooding once in 30 years.

Winchfield Strategic Assessment - Winchfield Flood Risk 1

Winchfield Strategic Assessment - Winchfield Flood Risk 3

We do hope the Inspector takes this into account when assessing the Local Plan.

 

Stop Elvetham Chase go Completely Concrete

Stop Elvetham Chase go full completely concrete Hart

Hypocritical Stop Elvetham Chase go Completely Concrete

The Stop Elvetham Chase group have decided to put up a candidate in the Local Elections standing for Community Campaign Completely Concrete Hart.

This smacks to us of hypocrisy as they are rightly vehemently opposed to the Elvetham Chase (Pale Lane) development. However, they now strongly support a new town in Winchfield, part of which is very close to the area where they oppose development. This is shown in the graphic above.

Their candidate, Angela Delaney is fighting the Fleet West ward. Richard Woods, who defected from the Tories in late 2016, currently holds this seat. It appears that Richard is standing down because he isn’t mentioned as a candidate on CCH’s website.

Stop Elvetham Chase’s statement has been placed on their Facebook page. Interestingly, comments have been disabled, so it is clear they are only interested in one-way communication. Not a good start for a budding politician. It is reproduced below with our comments in red.

This group was set up to fight the Elvetham Chase development. Hart council’s strong endorsement of the local plan on the 4th January and subsequent refusal of Wates’ proposal has, for now, protected Pale Lane. We thank all the members of this group for supporting the campaign and objecting so strongly to the development. Stop Elvetham Chase did start with laudable intentions.

However this is only a stay of execution. We know Wates have every intention of appealing the decision. The local plan, in its current state, with the new settlement option, gives Hart Council a strong chance of successfully refusing the appeal.  This is because approval of Pale Lane would jeopardise the new settlement – which would ultimately deliver more affordable housing for Hart. The presence or otherwise of the new town in the draft Local Plan will have no bearing on the Pale Lane Appeal. This is because even the council have said the new town is unnecessary, without Pale Lane. The Conservatives will tell you that we don’t need the higher housing targets – they support a local plan with the new settlement removed. We believe this is naive in the extreme, given the housing crisis this country is facing. It’s not just the Conservatives that say this. It was in the Council’s own communication to members (see below) and stated at the January 4th meeting by Councillor Cockarill. The housing numbers in the Local Plan will deliver ~1,500 more houses than the Government mandated figure. The Government figure already includes an affordability uplift.

Pale Lane aside, we believe it is absolutely right to plan for a new settlement that will deliver the infrastructure that Hart desperately needs. CCH were asked at council before Christmas to show their workings on the infrastructure funding gap. They didn’t even allow the question to be asked, let alone answer it. The reason is that they know, the new settlement will increase the funding gap and starve Fleet and Church Crookham of much needed investmentWithout a new settlement we will soon return to a ‘planning by appeal’ situation which has been so disastrous for Hart (ref: Grove Farm and Watery Lane). A sound Local Plan, without a new town and without Pale Lane, will stop this situation. With no long term plan for secondary school places (to meet demand from the 2000 houses at Hartland and Grove Farm), surgery waiting times lengthening and our roads more congested than ever we think this is unacceptable for Hart.  Hampshire County Council have not said we need a new school. The Local Plan contains no proposals for a new school, doesn’t address healthcare and does nothing for roads. A new town will only make things worse. A local plan with the new settlement option removed will also pave the way for Wates to successfully appeal Pale Lane. No it won’t. The Local Plan will be sound without the new town. Indeed, it may even be unsound with the new town.

So, after much consideration we have decided to support Community Campaign Hart (CCH), who we can trust to safeguard the local plan (which is already progressing well and is due for submission to a Govt inspector this month) and by extension, Pale Lane. CCH are committed to taking the politics out of local matters, focusing on putting residents’ needs first. Cough…only if you live in Church Crookham, and even then, the extra traffic from a new town will impact both Fleet and Church Crookham.

We are absolutely delighted to announce that Angela Delaney, one of our group and one of the original four who spearheaded the Stop Elvetham Chase Development campaign, is standing as CCH candidate for Fleet West. Angela has worked tirelessly over the last year to fight Pale Lane and protect Fleet West from the impact this development would have caused. But apparently she doesn’t care at all about the impact that a new town at Winchfield would cause. She’s passionate about supporting a local plan with a new settlement to protect our schools, health service and roads. In fact the Local Plan doesn’t promote a new school, doesn’t address healthcare and won’t fix the roads. In fact it will make matters worse for Fleet, because it will starve it of infrastructure, increase commuter traffic and probably reduce retail traffic. We hope her track record speaks for itself. Cough…not quite in the way she wants us to believe, but let’s wish that she is more successful than CCH have been with Edenbrook, Grove Farm and Watery Lane.

We hope you’ll support Angela but ultimately everyone must make their own decision at the ballot box. Well done for standing for election, which is more than Councillor Woods did when he defected. If you don’t support our position then we thank you for your support so far and understand if you wish to leave our group at this point. I will stay if you don’t mind, just to see what you are up to. You have lost a lot of support from Winchfield residents who also oppose Pale Lane. If you support Angela, we can guarantee that she will work with the same energy she fought Pale Lane, to represent local residents’ interests. Cough.

Why a new settlement debunked predetermination

Hart Housing Numbers

 

Hart Local Plan: Restore strategic gaps

Hart Regulation 18 Strategic gaps

Hart Local Plan Regulation 19 consultation removes the Regulation 18 Strategic Gaps

This is the sixth and final part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart have removed the strategic gaps around Harley Wintney and Hook that were present in the last consultation. We believe they should restore them and policy NBe2 should be amended.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 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.

Restore the strategic gaps to the Hart Local Plan Regulation 19 Consultation

The Local Plan identifies strategic gaps between settlements.

Hart Local Plan Regulation 19: Hartley Winchook leads to no strategic gaps around Hartley Wintney nor to the east of Hook

Hart Local Plan Regulation 19 Consultation Strategic Gaps

However, no gaps are proposed to the east of Hook, to the north west of Fleet or anywhere around Hartley Wintney. This is contrary to the Regulation 18 consultation (see top), where strategic gaps were included to the east of Hook and the SW of Hartley Wintney. These should be restored and new ones added to give effective gaps between Winchfield and the west of Fleet/Elvetham Heath to avoid coalescence into a Hartley Winchook urban sprawl.

Remedy: This policy needs to be amended to include:

  1. A gap to the west of Hook from the east bank of the River Whitewater to at least the power line between Hook and Hartley Wintney
  2. A gap to the south and west of Hartley Wintney/Phoenix Green. This should be at both sides of the A30, from the existing end of development to the Murrell Green light-industrial estate and from St Mary’s Park to the motorway
  3. A gap from Elvetham Heath/A323 to the River Hart and from Edenbrook/Hitches Lane to the River Hart
  4. A gap from the east of Taplins Farm Lane/The Hurst to the River Hart.

 

Hart Local Plan: No plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

Hart Local Plan Regulation 19 consultation: no proper plans for infrastructure

This is the fifth part of our submission to the Hart Local Plan Regulation 19 consultation. This article explains how Hart haven’t properly planned for infrastructure. In addition, the plans they do have will starve the places that really need it of investment. Policy I1 needs to be changed and policy SS3 needs to be removed. The process for making a submission is as follows:

  1. Go to the Hart Local Plan Regulation 19 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

How the Hart Local Plan Regulation 19 consultation needs to be changed to deal with infrastructure

One leading councillor has gone on the record, calling for an ‘infrastructure led’ Local Plan. Yet, they have not allowed questions to be put to them about infrastructure, let alone answer them.

Back in October 2014, Hart Council produced an infrastructure delivery schedule that set out the current deficit, split by type and area.  This shows a deficit of £78m not including healthcare facilities. The breakdown is shown by type and area in the images below:

Hart Local Plan Regulation 19 consultation: Hart District Estimated Infrastructure costs by type March 2013.

Hart District Estimated Infrastructure costs by type March 2013.

The breakdown of the costs by area showed the Fleet/Church Crookham and Hook areas had by far the largest deficits.

Hart Local Plan Regulation 19 consultation: Estimated Infrastructure costs by area March 2013

Hart District Estimated Infrastructure costs by area March 2013

Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It should be noted also that SWR has recently put forward proposals to reduce services at Winchfield and Hook, exacerbating the rail capacity problem. The Local Plan doesn’t even mention improvements to the rail network in infrastructure policies.

A more recent estimate from Hampshire County Council has estimated the infrastructure funding gap for Hart as £72m.

Hart Local Plan Regulation 19 consultation: Hart infrastructure funding gap £72m

Hart infrastructure funding gap £72m

Hart’s share of the gap is made up of:

  • Transport, £34m
  • Education: £38m.
  • Countryside: To be Determined.
  • Extra Care places: To be Determined.

No estimate has been made of the requirements or costs of additional healthcare provision.

The infrastructure policies in the Local Plan are insipid and fail to address the funding gap:

  • Policy I1: Infrastructure – weak policy simply requiring developers to deliver adequate infrastructure as part of their developments, when the studies above show that developer contributions won’t be adequate to bridge the gap
  • Policy I2: Green Infrastructure – feeble policy to supposedly protect green infrastructure. Yet they are proposing to build a new town that will destroy the best of our green infrastructure
  • Policy I3: Transport – inadequate policy simply to provide ‘maximum flexibility in the choice of travel modes’, nothing specific to improve road network or put pressure on SWR to improve rail
  • Policy I4: Open space, sport and recreation – policy to support development that improves sporting facilities, but no tangible plans for anything new
  • Policy I5: Community Facilities – a very vague policy to improve childcare facilities, healthcare, police stations, youth provision, libraries, community halls, local shops, meeting places, cultural buildings, public houses, places of worship, and public toilets. But crucially, no specific projects or proposals.

Yet, the National Planning Policy Framework (NPPF) is clear that infrastructure must be planned alongside new housing. Failure to adequately plan for infrastructure requirements and costs could lead to the Local Plan being found unsound. See references to paras 17 and 177 of the NPPF below.

plan to avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

NPPF Para 17: Avoid infrastructure funding gap

It is clear from this post, that the proposals to build a new town will probably exacerbate the existing funding gap and not deliver any infrastructure in Fleet, Church Crookham and Hook, the very places where funding is most required.

Remedy: We therefore think the remedy to this issue should be that policy SS3 is removed in its entirety (with consequent changes to policy SS1 already outlined elsewhere). The infrastructure policies should be reworked to include as a minimum:

  • Acknowledgement of the existing £72m infrastructure funding gap
  • Quantification of the items missing from the Hampshire County Council assessment such as healthcare, extra-care housing for the elderly and green infrastructure
  • A set of prioritised, costed projects that are required to alleviate the worst of our infrastructure problems in Fleet/Church Crookham and Hook. This should include road improvements, particularly near Fleet station and the bridge over the railway near the end of Elvetham Heath Road. It should also include significant improvements to the cultural facilities, particularly in Fleet.
  • Plans to tackle Network Rail/SWR over rail capacity and services
  • Proposals for raising the necessary funds for delivering the required projects
  • Some external validation that the infrastructure plans in the draft Local Plan are ‘sound’ and will pass inspection

We believe that in preparation for the next review of the plan, a new policy should be created to regenerate our urban centres including attracting private capital so that we create a better place to live and address the existing infrastructure problems before even considering a new town that will only make matters worse.