hart district draft local plan: strategy and sites 2016 - 2032 · 1.4 for reasons that are stated...

Hart District Draft Local Plan: Strategy and Sites 2016 - 2032

Representations to Regulation 19 Consultation

On behalf of

Martin Grant Homes

March 2018

Hart District Draft Local Plan: Strategy and Sites 2011 - 2032

Representations to Regulation 19 Consultation

On behalf of

Martin Grant Homes

Project Ref: 25681/P2/A5 25681/P2/A5 25681/P2/A5

Status: Draft Final Draft Final

Issue/Rev: A B C

Date: March 2018 March 2018 March 2018

Prepared by: Mark Owen/Jonathan Locke Mark Owen/Jonathan Locke Mark Owen/Jonathan Locke

Checked by: Jonathan Locke Jonathan Locke Jonathan Locke

Authorised by: Nick Paterson-Neild Nick-Paterson-Neild Nick Paterson-Neild

Date: 26th March 2018

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Introduction

25681/P2b/A5/JL Page 1 March 2018

1.0 INTRODUCTION

1.1 These representations are submitted on behalf of Martin Grant Homes (“MGH”) in

promotion of land west of Ewshot Lane, Church Crookham, Hart (“the Site”) as a suitable

location for residential development through the Development Plan process.

1.2 Initial capacity testing of the Site, having regard to environmental constraints,

demonstrates that at approximately 3.74 hectares it could accommodate up to 150

dwellings (40dph).

1.3 The Site is located in a sustainable location and is promoted as suitable for residential

development which is both available and deliverable within the first five years of Local

Plan adoption.

1.4 For reasons that are stated within these representations, MGH consider the Pre-

Submission Hart Local Plan to be unsound and will require amendments.

1.5 These representations form MGH’s case presenting reasons for unsoundness and the

inclusion of the Site as a housing allocation within the emerging Hart Local Plan (2011 –

2032).

Response to Consultation on Draft Hart Local Plan (Regulation 19) Background


2.0 BACKGROUND

2.1 The Site falls outside the existing development boundaries of Fleet and Church Crookham,

within the Parish of Ewshot. From a total Site area of approximately 6.4ha, 3.4ha has

been identified as having potential to accommodate up to 150 residential dwellings.

2.2 A detailed Vision Document, informed by technical work, was submitted in support of our

representations in response to the Council’s Regulation 18 consultation on the Draft Local

Plan. For the reader’s assistance, this document is included again at Appendix A.

2.3 The Site is sustainably located on the edge of the Fleet and Church Crookham settlement

boundary, identified as the largest and most sustainable settlement within the District by

the Council. The Site is located within walking distance of local services and facilities

whilst Fleet town centre is within cycling distance. Onward connections by public bus and

rail are also available within the vicinity of the Site. Nearby developments at Albany Park

and Crookham Park are delivering further supporting infrastructure such as schools, retail,

community facilities and SANG, which would be available to use by future residents of

any development on the Site.

2.4 The Site is located within 5km of the Thames Basin Heaths SPA and would therefore

require mitigation of potential adverse impacts on the SPA from additional dwellings. The

Albany Park development of 300 dwellings to the west of the Site, also being brought

forward by MGH, would provide significant SANG in excess of its own requirements.

Therefore, such excess SANG could provide for the needs of the development on land

west of Ewshot Lane.

2.5 From detailed surveys, it has been found that the Site has limited ecological interest,

there are no overriding heritage constraints preventing the development of the Site, whilst

the WWII Type 24 Pillbox on the Site would be retained. Boundaries predominantly

accommodate trees, none of which are covered by Tree Preservation Orders, screening

proportions of the Site from wider view. The Site is not covered by any statutory or non-

statutory designations for landscape character or quality. Whilst the Site is located within

Flood Zone 1, there is an existing ditch to the south west border of the Site. The land is

also classed as Grade 3 agricultural land (Good to Moderate) according to Natural

England’s Agricultural Land Classification Maps.

2.6 An indicative masterplan for the Site demonstrates that having regard to the constraints

involved, up to 150 new homes could be delivered.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Sustainability Appraisal


3.0 SUSTAINABILITY APPRAISAL

3.1 The Sustainability Appraisal (SA) makes reference to a ranking system for the settlements

within the District. Fleet (including Church Crookham) is categorised as a Tier 1 settlement

(main urban area). At paragraph 6.4.3, the SA states that:

“Fleet, incorporating Elvetham Heath to the north and Church Crookham to the south, is the District’s main settlement, with services/facilities and employment opportunities that indicate suitability for growth.”

3.2 The options for development are assessed against a number of sustainability topics and

objectives as set out within table 4.1 of the SA. These include, accessibility, biodiversity,

climate change mitigation, communities, employment and the economy, flood risk /

climate change adaption, housing, historic environment, land and other resources,

landscape, transport and water.

3.3 The SA recognises at paragraph 6.2.8 that there are arguments for supporting higher

growth, including the need to fully meet affordable housing needs. The SA makes

reference to the National Planning Practice Guidance (NPPG) which states that “An

increase in the total housing figures included in the local plan should be considered where

it could help deliver the required number of affordable homes.” Housing growth can also

act as a driver for economic growth.

3.4 We note at paragraph 6.4.12 of the SA that it states that a modest scale scheme involving

our clients site on land west of Ewshot Lane (referenced SHL166) does warrant

examination. In addition, it states that a development of this site in addition to Stillers

Farm (SHL90):

“….cou ld poten t ia l l y serve to ‘round-off’ the settlement edge.”

3.5 At paragraph 6.5.10 the SA states that the non-strategic allocation of South of Church

Crookham, Fleet (comprising Stillers Farm and our client’s site) is identified as potentially

‘standing-out’ in planning and sustainability terms, and “hence worthy of detailed

examination through the appraisal of reasonable spatial strategy alternatives.”

We note that this non-strategic allocation is therefore identified in Option 2 (Non-

Strategic), Option 5 (Pale Lane + non-strategic) and Option 6 (West of Hook + non-

strategic) as indicated under Table 6.3 of the SA.



3.6 Summarising the findings of the spatial alternatives for housing delivery, the SA concludes

that Option 1 (“Do minimum”) approach would perform the best in terms of the majority

of sustainable objectives. This would solely involve the allocation of Hartland Village

(referenced Hartland Park within the SA) with its proposed 1,500 dwellings.

3.7 Whilst large scale development is generally capable, at a given scale, of providing services

required to support the daily needs of its new population, in order for the Hart Local Plan

to be considered “sound” in that it is positively prepared, the Council should consider a

range of sites to deliver housing needs across the plan period. The phraseology used for

the selected option is itself, not positive, aptly named the “do minimum” option.

3.8 As stated within our representations to the Council’s Regulation 18 consultation, we

consider it necessary to repeat a quote from the 2017 Housing White Paper which

emphasises the need to bring more small and medium sized sites forward in order to

make more land available for homes in the right places (page 18, Step1: Planning for the

right homes in the right places). It also states:

“Policies in plans should allow for a good mix of sites to come forward for development, so that there is choice for consumers [and] places can grow in ways that are sustainable.”

(Paragraph 1.29, p25, 2017 Housing White Paper)

3.9 The Council’s “do minimum” approach however continues to ignore two critical aspects of

housing delivery; the ability to plan for a good mix of sites as advocated by the Housing

White Paper, and to fully consider the settlement hierarchy, and in addition to delivering

strategic housing sites, to also deliver smaller sites which can be delivered quickly with

lower infrastructure requirements, in sustainable locations such as the land west of

Ewshot Lane.

3.10 In summarising the spatial options, of which the SA confusingly numbers the non-strategic

option (which includes the Site plus Hartland Park) Option 4 (elsewhere in the SA it is

numbered Option 2), the SA concludes that “significant negative effects are predicted,

for options other than the ‘do minimum’.” The assessment is so high level that such a

generalised assessment of Spatial options does not account for, and is not justified, for

the higher performance of individual sites, including the land west of Ewshot Lane.

3.11 The methodology the SA used is therefore considered too high level in not fully appraising

a direct comparison of a range of potential sites at differing scales and locations that



could provide housing over the Plan period. The outcome of such an approach is that

certain sites which perform well against sustainability objectives are missed and ‘hidden’

within a grouping of other sites, given as a group, a generalised sustainability score.

3.12 The SA summarises the key reasons for selecting the “do minimum” approach, only

allocating the 1,500 dwelling proposals at Hartland Park, are twofold; first it delivers what

the Council consider to be sufficient annual housing delivery over the Plan period,

exceeding the Plan commitment for 388 dwellings per annum (by providing 397dpa), but

also that it performs well in terms of the majority of sustainability objectives, “which itself

is a strong indicator of overall sustainability” (SA, paragraph 8.2.2).

3.12 A key feature of maintaining a range of allocation sizes, as advocated by the Housing

White Paper, is that this helps the Council, over the Plan period, to “maintain a robust

‘housing trajectory’, i.e. maintain a situation whereby there is a five year supply of

deliverable sites” (SA, paragraph 10.9.2) as required by the NPPF (paragraph 47) to

deliver a wide choice of high quality homes. Maintaining a range of allocated sites would

better allow robustness for ensuring a five-year supply of housing.

3.13 This risk is acknowledged within the SA at paragraphs 10.9.2 and 10.9.13 where it states

respectively that;

“In this respect, the proposal to allocate only one large brownfield site (Hartland Park) rather than a package of smaller greenfield sites has a degree of risk attached” (paragraph 10.9.2)

3.14 The SA states that within the context of other sites within the District with planning

permission, including large greenfield urban extensions at Fleet/Church Crookham, Yately

and Hook, there is an implied degree of assurance that there would be a sufficient range

of sites available. We consider that, whilst such sites will assist delivery, the Council are

dependent on Hartland Park to deliver the Council claimed Plan requirement of 388dpa,

and as such dependence on a single site does not provide sufficient flexibility and this

would further be exacerbated should housing need increase as anticipated and referred

within our previous representations. Accordingly, Hartland Park should be complemented

by other allocations to increase market choice and competition and to provide a more

robust land supply.

3.15 At the back of the SA are 12 tables which assesses each reasonable alterative option

based upon a specific sustainability objective. We would like to take this opportunity to

emphasise a number of comments from this assessment. The SA methodology for



assessing the sustainability of the site options (which groups sites into categories bringing

the problem of ‘hiding’ sustainable sites within a potentially unsustainable grouping due

to the high level of assessment) is presented at appendix IV. There is further

inconsistency within the site options SA assessment which will be picked up as these

representations pick up the SA assessment of the Site’s performance against each relevant

sustainability objective.

3.16 The following within Appendix V of the SA is noted;

“Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration. The ability to predict effects accurately is also limited by understanding of the baseline (now and in the future under a ‘no plan’ scenario). In light of this, there is a need to make considerable assumptions regarding how scenarios will be implemented ‘on the ground’ and what the effect on particular receptors would be.”

3.17 The above SA statement raises the concerning acceptance that “considerable

assumptions” had been made. It is recognised that there were a considerable number of

sites to appraise (which is the SA reasoning for using groupings in the methodology),

however, this has been to the detriment of a full detailed appraisal of highly sustainable

sites such as the land west of Ewshot Lane. Furthermore, we would consider that there

is a lack of detail and reasoning for why the “do minimum” approach was selected over

the “non-strategic” option which would have delivered an appropriate range of deliverable

housing sites.

Accessibility

3.18 Under the Sustainability Topic of ‘Accessibility’ the SA states the following in respect to

the non-strategic allocation of South of Church Crookham, Fleet (which includes the Site)

(our emphasis):

“There is no district or local centre within the southern part of Fleet, certain new services and facilities are being delivered as part of the adjacent new Crookham Park scheme - including expansion of Church Crookham Junior School, in 2019, to 150 places per year group - which may have capacity.”

3.19 In conclusion, in respect to this Sustainability Topic the SA states that it is difficult to

differentiate the alternatives.



3.20 The main concern raised by the SA in respect of a non-strategic scheme at ‘South of

Church Crookham’, which it describes as “appropriate in the sense that this is the District’s

main town” … “might create risks in terms of the capacity of community infrastructure”,

particularly referencing secondary school capacity, and whether there is sufficient scope

for expansion. It concludes that “significant negative effects are not predicted, however,

given the potential for a new secondary school to be delivered as part of a new settlement

in the Murrell Green/Winchfield area, in the medium term.”

3.21 Whilst there will be a need for secondary provision, the SA accepts this would not give

rise to predicted significant negative effects. In appraising potential short to medium term

capacity within local secondary schools to accommodate potential secondary school

pupils, it is worth noting the Hampshire School Place Plan (2018-2022) (the “HSPP”) which

concludes, based on findings across the County, that an average pupil yield per 100

dwellings would be in the region of 21 secondary school children. This would give rise to

a potential, based on the promoted 150 dwellings on land west of Ewshot Lane, for the

need to accommodate 32 (31.5 rounded) secondary school age pupils once fully developed

and occupied.

3.22 The amount of secondary school pupils that may need to be accommodated is not a

significant number. There are two nearby secondary schools, Robert May’s Secondary at

Odiham, only 5.5 miles drive to the west of the Site by car (c.12 minutes), which is

anticipating an expansion by 1 form of entre (FE) by 2019, according to the HSPP. It is

more interesting to note that the HSPP also states another closer secondary school,

Calthorpe Park Secondary School in Edenbrook, Fleet, a short distance to the north, there

are plans to expand by 2FE (from 10FE to 12FE) by 2021. This would match the potential

timings for the delivery and occupation of dwellings on the Site (i.e. potential first

occupation by 2020/2021).

3.23 It is considered that both secondary schools, within the context of a rural District, are

within sustainable distances from the site. In particular, Calthorpe Park Secondary School

would be only 2.9 miles (8 minutes) drive from the Site, but children attending the school

from the Site would benefit from convenient access to a local school bus service.

Stagecoach run a school bus service (the 610) which has a current pick-up location only

a short distance to the east of the Site. The current route of the school bus is shown

below:



3.24 Students using the local no.610 school bus service to Calthorpe Park Secondary School

would be able to walk to the current pick up bus stop at the Quetta Park bus shelter,

taking only 15 minutes. This represents a very sustainable way for children from the Site

to get to the school and thereby reduces dependence on the private car. It is therefore

considered that in terms of accessibility to education, there would be no justified reason

for the Site to receive a lower scoring than the chosen “do minimum” option, which the

Council ranked as no.1.

3.25 The walking route students could take to catch the no.610 Stagecoach school bus service

is presented below:



3.26 It is also worth noting that the higher order facilities (the largest selection within the

District) available at Fleet can also be sustainably accessed using public transport. The

no.10 public bus service provides regular connections to Fleet through the day. There are

however a number of services being brought forward adjacent to the west of the site, to

the southern fringe of Church Crookham at Albany Park. Albany Park was allowed at

appeal (reference: APP/N1730/A/14/2228404, 26TH June 2015), for 300 dwellings, a GP

surgery, retail floorspace for a convenience foodstore, open space, leisure facilities and

16.18ha of SANG. The services being provided at Albany Park would all be within

sustainable walking distance of residents of the Site.

3.27 It is worth noting that the Inspector in allowing the Albany Park Appeal stated:

“the appeal site is situated on the edge of the settlement of Fleet and Church Crookham, identified in the LP as the largest and most sustainable settlement within the District and is therefore well located in the context of the District. Additional facilities are also proposed within the development.”

3.28 In terms of accessibility therefore, the Site is very sustainable, with all services and

facilities required for daily needs within walking distance, and higher order comparison

shopping available at fleet using the no.10 bus service. It is therefore considered that in

terms of the SA scoring, the Site should receive the same rank (1) as Hartland Park,

rather than the secondary (2) rank it received.

Biodiversity

3.29 The key consideration raised within the SA concerned the need to ensure avoidance of

significant adverse effects on the Thames Basin Heaths SPA. The ‘non-strategic’ option

was ranked (2) rather than equal (1) to the “do minimum” Hartland Park option due to

not delivering SANG but having the potential to impact the SPA. It is considered this

secondary ranking is incorrect and the Site (highlighting the problem with a grouping

methodology for SA assessment), should receive equal (1) rank with the “do minimum”

option.

3.30 Whilst the Site would not provide its own on-site SANG, the SA recognises in its

assessment of Biodiversity, that:

“there may be potential to provide SANG i.e. SANG that will have ‘spare capacity’ available for residents other than the residents of the new site in question.”



3.31 The Site on land west of Ewshot Lane, whilst not providing its own SANG would be

adjacent to the Albany Park development of 300 dwellings, being brought forward by

MGH, which would provide significant SANG well in excess of its own requirements.

Therefore, taking the acceptance of the SA statement above, development of the Site

would be considered to be able to accommodate its SANG requirements through that

provision, and would be able to provide contributions to support its maintenance.

3.32 It is therefore concerning that the SA concludes that, having not had regard to the above,

lower growth is “preferable” and that it is “very difficult to differentiate between the other

alternatives”. We disagree, and consider that the availability of excess SANG capacity

adjacent to the site elevates its sustainability credentials against this SA objective. It is

therefore also not considered appropriate to consider “all options, other than Option 1

(do minimum) as the worst performing option as having the potential to result in

significant negative effect, given the potential for impacts to the SPA.”

Climate Change Mitigation

3.33 The SA ranks both the “do minimum” option and “non-strategic” option equally as (3). It

is considered however, that given the availability of services and facilities within walking

distance as part of the Albany Park development, including a convenience store, GP

practice, leisure facilities and significant open space through 16.18ha of SANG, there is

the opportunity to reduce dependence on the private car and thereby contribute towards

the SA objective to reduce CO2 emissions. It is for this reason that development should

be provided to the most sustainable settlements, in particular Fleet as the only Tier 1

settlement in the District. We consider the site should be ranked (1) against this SA

objective.

Food Risk and other Climate Change Adaption Issues

3.34 The SA ranks the “do minimum” approach as (1) and the non-strategic option as (3). No

reasoning has been provided to support why Option 1, the “do minimum” option of

developing at Hartland Park is ranked higher than the alternatives. Whilst we do not

question the Hartland Park ranking, it is also unclear why there is a difference in ranking

between Option 4, ‘West of Hook’ and Option 2 ‘non-strategic’, which includes the Site.

Both West of Hook (Option 4) and the Site (which is referenced with the South of Church

Crookham against this objective) both are within areas of very low probability surface



water flood risk which could be mitigated, yet West of Hook receives a (2) rank to the

Site’s (3) rank.

3.35 It is considered that there are significant flaws in the SA assessment of options against

this objective and the reasoning is altogether unclear. We consider that the Site should

receive a minimum ranking of (2) to match that of West of Hook (Option 4), rather than

the current (3) ranking.

Historic Environment

3.36 The SA ranks the “do minimum” Hartland Park Option 1 as the (1) ranked option and all

other options as rank (2). The reasoning provided for this within the SA is that it is

“difficult to differentiate the other options” and as Option 1 would provide a new

settlement, it would not be as affected by all the other options by heritage constraints.

3.37 We would not disagree that the other SA options have heritage constraints, however, we

would disagree that it is difficult to differentiate between them. The Site does not include

any Listed structures, but does include a WWII Type 24 Pillbox on the eastern side of the

Site. This would be retained and there would be an opportunity to enhance its setting to

increase its recognition. Stiller’s Farmhouse and the Barn to the south of Stiller’s

Farmhouse (both Grade II Listed) are located outside the site to the east. Landscaping

within the Site, together with the sensitive design and layout within would be capable of

mitigating any impact on the settings of those nearby listed buildings.

3.38 In appraising the options, the SA should have applied the NPPF guide at paragraph 126

which states Local Plans should conserve historic assets “in a manner appropriate to their

significance”, and at paragraph 132 where the NPPF states “the more important the asset,

the greater the weight should be, and particularly paragraph 134 which states:

“Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including its optimum viable use.”

3.39 It is considered that the SA has not gone far enough in its analysis, which, otherwise may

have concluded a variance of ranking the Options. We do however concur that the Site

should be ranked (2).



Landscape

3.40 The SA ranks non-strategic Option 2 as (3), despite recognising that the Draft Local Plan

proposes to remove the site from the current designated gap between Church Crookham

and Ewshot as a result of recently designated SANG within the gap helping to secure the

integrity of the gap in the long term. It is therefore considered that the Site should be

ranked (2) against this SA objective.

Transport

3.41 This SA objective provides a clear example of the difficulty with the methodology in that

it groups the Site within Option 2 ‘non-strategic’ sites and concludes that due to low

positions within the settlement hierarchy and limited public transport to reach higher

order centres, Option 2 is ranked (3). This could not be further from the truth with the

Site which is on the fringe of the southern extent of Fleet, the District’s only Tier 1

settlement, and benefiting from sustainable transport options to nearby services and

facilities, with Albany Park within walking distance, and Fleet centre a short walk and bus

journey from the Site.

3.42 It is considered that the Site should be ranked equal (1) to Option 1, the “do minimum”

option.

Water

3.43 The SA ranks Option 1, “do minimum” as the highest rank, and Option 2 “non strategic”

which includes the Site, as the least performing option, ranked (3). It is however very

unclear why, without any commentary, Option (2) received the lowest rank or why Option

(1) received the highest rank.

SA Table A: Summary findings of the GIS analysis

3.45 These representations have provided an appraisal of the Site against the key sustainability

objectives. It is worth briefly noting that for proximity to an SPA, SINC and ancient

woodland, amber grades are given. Within the methodology within Appendix IV of the SA,

for those SA considerations, there are no “amber” categories.

3.46 Further, in terms of accessibility (SA, p114), the Site was given a negative red rating on

the basis of being beyond 2km from a town, district or local centre. This doesn’t take into



account the new local centre facilities coming forward as part of the adjacent Albany Park

development. Taking this into account would have seen the SA rank as dark green (within

500m) rather than red (beyond 2km).

3.47 It is of further note that the methodology makes no allowance for consideration of the

significance of a historic asset to enable weighing against the potential public benefits of

the development of the Site. Under “Historic Environment” (SA, p116), the Site is rated

red in terms of being within 50m of a listed building. Whilst this is correct, the

methodology makes no allowance for an appraisal or comparison between sites and the

significance of historic assets which affect potential development on a site. Therefore, by

virtue of having a WWII pillbox on the site and the Grade II Listed Buildings at Stiller’s

Farm, it is rated the same as any other site with a Listed Building within 50m.

Summary

3.48 The Sustainability Appraisal fails to fully utilise the settlement hierarchy when formulating

the spatial strategy, instead favouring a’ Do Minimum’ approach that only considers the

allocation of Hartland Park only. We consider the SA should consider a greater range of

options for delivering required housing over the Plan period to complement the delivery

at Hartland Park. The approach to spatial assessment has not been fully justified within

the Sustainability Appraisal.

3.49 The Sustainability Appraisal has not fully considered medium sized sites and thus fails to

bring enough forward for inclusion in the Draft Hart Local Plan. Objective 3 in the Draft

Hart Local Plan states a need to support the vitality and viability of the district’s town and

village centres to serve the needs of residents. Failing to fully consider medium sized

sites on the edge of the primary settlement does not support the needs of those in the

District.

3.50 Large strategic residential allocations can deliver substantial housing numbers across a

plan period; small to medium sites can deliver short term housing needs. The Draft Plan

as currently proposed seriously lacks this ability, particularly around the largest and most

sustainable settlement in the District, Fleet (including Church Crookham). It is therefore

not considered that the Draft Local Plan fully complies with the NPPF (paragraph 182)

requirement to be positively prepared, or effective in ensuring a sufficient supply and mix

of housing over the Plan period.



3.51 It is highly likely that the Council will need to consider further options for housing delivery,

such as the Site, given that the Objectively Assessed Housing Need (“OAHN”) is likely to

be higher than currently allowed for within the Draft Plan (388dpa). This has been

assessed through an assessment by Barton Willmore of the Council’s Sustainable Housing

Market Assessment (“SHMA”) 2016, submitted with representations to the Council’s

previous Regulation 18 consultation.

3.52 It is recommended that the Sustainability Appraisal’s approach is revised to fully consider

a variety of options and individual sites, and specifically to not exclude medium sized

settlements as potentially suitable locations for development.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Housing Need


4.0 HOUSING NEED

4.1 The NPPF requires that, when providing OAN, Local Plans should be based on adequate,

up-to-date and relevant evidence about economic, social and environmental

characteristics. National Planning Practice Guidance (“NPPG”) sets out the methodology

for OAN to take full account of demographic trend, change in job numbers, market signals

and affordable housing needs.

4.2 The NPPF, at paragraph 47, requires local authorities to boost significantly the supply of

housing, using their evidence base to ensure that their Local Plan meets the full,

objectively assessed needs for market and affordable housing in the Housing Market Area

(“HMA”).

4.3 At paragraph 159 of the NPPF, in plan-making, local planning authorities are required to

understand their housing needs through production of a Strategic Housing Market

Assessment (“SHMA”). The methodology for assessing housing need is set out within the

PPG (ID 2A 014 - 029).

4.4 The most recent SHMA is dated 2016 which concludes an Objectively Assessed Housing

Need (“OAHN”) of 1,200dpa for the HMA as a whole between 2014 - 2032 (not reflecting

the proposed Plan period of 2011 - 2032), with 382dpa allocated to Hart District.

4.5 However MGH note that the housing requirement of 388 dpa within the Draft Plan has

been derived using, as a start point, the Government’s proposed approach to calculating

housing need which results in an indicative figure for Hart of 292 homes per annum. The

District have applied a 25% uplift to this figure taking this requirement to 388 homes per

annum. This housing requirement figure is only slightly higher (6 dpa) than the 2016

OAHN.

4.6 Yet if the Council are to submit their Plan for examination in spring this year, they will

need to update the SHMA’s OAHN, as all plans submitted before at least November 2018

will be assessed against the existing OAHN methodology, rather than the proposed

standardised approach to assessing local housing need which the Council have used to

determine their housing requirement.

4.7 On this basis, MGH are concerned that an up-date to the 2016 SHMA has not been

undertaken and should be undertaken (and consulting on it) prior to submission of the



Proposed Submission Version of the Local Plan to the Secretary of State for Examination

in Public. Without doing so, the Council run the risk of submitting an unsound plan (in

the context of NPPF, paragraph 182) for examination.

4.8 Barton Willmore previously conducted a full housing need technical review for Hart

District, which was submitted to support our representations to the Regulation 18 Local

Plan. The Council has significant ambitions for job growth within the District, citing within

the SHMA a target of 1,200 new jobs per annum across the HMA. This is not then clearly

proportioned between the constituent authority areas that form the HMA. Applying a

proportional division of the 1,200 new annual jobs allocates 567 jobs per annum to Hart

District. This would lead to a need for 636dpa based on unadjusted household formation

rates. We previously concluded that with adjustment based on alleviating household

formation suppression in Hart would lead to an increased range between 666 and

724dpa.

4.9 The Council’s evidence will however need to be updated Despite this, the proposed Local

Plan period would also not be compliant with the NPPF requirement for a minimum 15-

year period.

Unmet Housing Need

4.10 MGH has concerns regarding the Draft Plan’s insufficient consideration of unmet need

from authorities within and outside the HMA area.

4.11 The Draft Plan states (paragraph 107) that the level of housing proposed in the Rushmoor

Local Plan shows that it can exceed its identified housing needs, with a significant surplus

compared to the Government’s indicative figures.

4.12 However, the Draft Plan states that Surrey Heath has indicated a potential housing

shortfall in its area yet states that its Plan is at an early stage.

4.13 Considering Surrey Heath has a potential housing shortfall and neither Local Plans have

yet been tested through public examination, MGH considers that Hart District should be

considering whether it is necessary to meet unmet needs from neighbourhood authorities,

especially as it is one of the least constrained District’s in the region therefore in a prime

position to help provide for that unmet housing need.



4.14 In order to fully allow provision for contributing towards unmet housing need, the Council

should ensure identification and full consideration, including within the Sustainability

Appraisal, of potential suitable development sites, including the Site west of Ewshot Lane,

Church Crookham.

4.15 It is again recommended that Hart District Council undertake a full review of the SHMA

to include both analysis of Rushmoor and Surrey Heath, influences on housing need from

outside the HMA and also to review its timespan.

Plan Period

4.16 The Draft Plan would cover 2016 - 2032, a 16-year period. However, we view a summer

2018 adoption, as stated within the latest Local Development Scheme, to be unrealistic.

Should this optimistic adoption timeframe be achieved, a remaining period of 13 years

and 9 months would be expected at most. This is less than the 15 years that the NPPF

recommends from the point of adoption as directed within paragraph 157 of the NPPF.

Consequently, the Plan does not allocate as much housing as it should. It also puts

pressure on the delivery of the subsequent Local Plan.

4.17 We would therefore recommend that the Local Plan runs to 2034, assuming a summer

2019 adoption (which is more realistic), in order that as directed by the NPPF (paragraph

157) a 15-year time horizon can be drawn up to take account of longer term requirements.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Draft Local Plan - Vision and Objectives


5.0 DRAFT LOCAL PLAN - VISION AND OBJECTIVES

5.1 MGH hold concerns that the current Draft Plan Vision fails to reflect the objectives the

emerging Local Plan should meet in order to accord with the requirements of the NPPF,

and would reiterate concerns previously raised in response to the Council’s Regulation 18

consultation.

5.2 Whilst MGH would support the prioritisation of previously developed land in order to

lessen the pressure on development within the countryside, given the housing need over

the Plan period, undeveloped sites on the edge of settlements, such as the Site west of

Ewshot Lane, Church Crookham, will need to be included, allocated and developed to

complement a new settlement and other strategic sites and development on previously

developed land such as Hartland Village (referenced Hartland Park within the SA).

5.3 In addition to the need for Local Planning Authorities, in development of Local Plans, to

ensure their Local Plan meets the full objectively assessed needs for market and

affordable housing, there is also a requirement for the maintenance of a minimum five

years’ worth of housing land against housing requirements. As stated earlier in these

representations, whilst major strategic residential allocations or a new settlement can

contribute significantly towards overall housing need over the Plan period, in the short

term, in support of maintaining five years supply of deliverable housing in the early years

of the Plan period, the Council needs to also allocate small to medium scale housing sites

which can be delivered quickly, within 5 years, such as the land west of Ewshot Lane.

5.4 The Vision should therefore reflect the need for a mix of development scales across the

District in sustainable locations by amending the first sentence of the second paragraph:

“We will have played our role in meeting future housing, social and economic needs, including the maintenance of a supply of sites sufficient to deliver five years’ worth of housing”

5.5 The Vision should ensure that it reflects the need to locate development at the most

sustainable settlements within the District with convenient, sustainable access to services

and facilities.

5.6 Finally, Objective 1 should be made clearer in its synergy with the requirement of the

NPPF at paragraphs 47 and 158 to meet in full, objectively assessed needs for market

Response to Consultation on Draft Hart Local Plan (Regulation 19) Draft Local Plan - Vision and Objectives


and affordable housing, taking full account of demographic trend, change in job numbers,

market signals and affordable housing needs.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Spatial Strategy


6.0 SPATIAL STRATEGY

6.1 The Draft Hart Local Plan lacks a clear and coherent housing distribution policy based on

justifiable evidence.

6.2 Fleet and Church Crookham are designated as a Tier 1 settlement, the most sustainable

urban area of the District. Despite this status, other than Hartland Village (Draft Policy

SS2) which is a development of a brownfield site, there are no residential allocations

proposed around the settlement despite there being sustainable reasonable alternatives,

such as the Site, which have not been fully considered within the Sustainability Appraisal.

6.3 It is clear that the potential for a higher housing need, following an updated SHMA to

support economic growth and a yet unknown quantity of housing to be provided under

the Duty to Cooperate requirement, would point to the need to consider urban extensions

in sustainable locations such as Fleet and Church Crookham.

6.4 In addition to the above, we find it surprising that the Draft Plan only looks to allocate

one large site (Hartland Village), contrary to guidance within the Housing White Paper to

provide a mix of housing sites.

Windfalls

6.5 Windfalls have been included in the consideration of housing delivery, totalling 275

dwellings. This reliance on windfalls and on unclear housing distribution policy raises

concerns about deliverability and sustainability.

6.6 MGH advise that following an update to the SHMA, the Council will need to find further

sustainable sites suitable for residential development and look to locate development in

the most sustainable locations in line with the settlement hierarchy. This should include

the Site, on land west of Ewshot Lane.

6.7 The NPPF (paragraph 48) allows Local Planning Authorities to make an allowance for

windfall in the five-year supply if “they have compelling evidence that such sites have

consistently become available in the local area and will provide a reliable source of

supply”. The Council have provided insufficient evidence that the windfall provision

included would provide a reliable source of supply based on historic windfall delivery rates

and expected future trends. Unless it can be justified in line with such requirements,

windfall sites should be removed from housing calculations.

Response to Consultation on Draft Hart Local Plan (Regulation 19) Detailed Policies


7.0 DETAILED POLICIES

7.1 MGH have concerns regarding a number of detailed policies within the Draft Plan which

are outlined below.

Policy SS1: Spatial Strategy: Scale and Distribution of Growth

7.2 Due to concerns raised above in respect of reliance on windfalls, the need for a 15 year

plan period from adoption, the need to consider unmet need from neighbouring authorities

and the need to update the OAN evidence base plus provide more flexibility in terms of

land supply, MGH object to this draft policy on the basis that it would not meet full OAHN

and would therefore be contrary to paragraph 47 in that it would not meet the full

objectively assessed needs for market and affordable housing in the housing market area

and as required by paragraph 157 of the NPPF, would not plan positively for the

development and infrastructure required in the area.

7.3 We are concerned that the Draft Plan fails to allocate residential development at Fleet

(including Church Crookham), save in respect of Hartland Village, which as the largest

settlement in the District, has been designated a main town (Tier 1) settlement within the

settlement hierarchy.

Policy H2: Affordable Housing

7.4 We consider that additional wording should be included at ‘d)’ and ‘e)’ to refer to any

future amendments to Part M of Building Regulations to ensure flexibility, and also

consistency with draft policy H1 which includes a footnote for criterion ‘b)’ regarding any

future amendments to the Regulations. We would therefore suggest the following

additional wording (underlined):

d) a t l eas t 15% of the a f fordab le un i t s w i l l be access ib l e and adap tab le as de f ined by requ i rem en t M 4 (2 ) o f the Bu i l d ing Regu la t i ons , o r as o therw ise am ended by the B u i l d ing Regu la t i ons . e) w here ev idenced by l oca l need, a p ropor t ion o f a f fordab le dw el l ings w i l l be bu i l t as w heelcha i r u ser dw el l ings t o m eet the requ i rem en ts o f Bu i l d ing Regu la t ions M 4 (3 ) , or as o therw ise am ended by the Bu i l d ing Regu la t i ons .



Policy H6: Internal Space Standards for New Homes

7.5 We note that this draft policy refers to DCLG’s Technical Housing Standards (March 2015)

which the Planning Practice Guidance (PPG) (Para. 002 Ref ID:56-001-20150327)

describes as ‘optional’ technical housing standards. We also note that the Government’s

recently published Housing White Paper indicates, as part of its proposals of ‘Planning for

the right homes in the right places’ (see page 18), that space standards will be reviewed

to make better use of land for housing by encouraging higher densities. We therefore

consider that such Technical Housing Standards should be considered as a guide to allow

for flexibility on the basis that they are not statutory standards and will be subject to

review. We would therefore suggest re-wording the policy as follows:

W here p l ann ing perm iss ion i s requ i red deve lopm en t p roposa ls for new hom es shou ld look to , m ust m eet or ex ceed the na t iona l l y descr i bed space s tandard , or any subsequen t am endm en ts to these s tandards .

Policy NBE4: Thames Basin Heaths Special Protection Area (TBHSPA)

7.6 MGH support the principles within Policy NBE4.

7.7 The Site west of Ewshot Lane, whilst not of sufficient size to provide on-site SANG would

benefit from being able to utilise surplus SANG available as part of the Albany Park

development to the west of the Site.

Policy NBE5: Biodiversity 7.8 Although we do not disagree with the principles of this policy, we consider that the first

sentence of this policy should be revised as follows to reflect the NPPF more closely:

I n order t o conserve and, w here poss ib le , enhance b iod ivers i ty , new deve lopm en t w i l l be perm i t ted p rov ided:

Policy NBE8: Sustainable Water Use 7.9 This draft policy refers to DCLG’s Technical Housing Standards (March 2015) which the

Planning Practice Guidance (PPG) (Para. 002 Ref ID:56-001-20150327) describes as

‘optional’ technical housing standards. We therefore consider that such Technical Housing

Standards should be considered as a guide to allow for flexibility on the basis that they

are not statutory standards and will be subject to review. We would therefore suggest re-

wording the policy as follows:



A l l new hom es shou ld look to m us t m eet the w a ter ef f i c i ency s tandard o f 110 l i t r es/ person/ day , or any subsequen t am endm en ts to these s tandards .

Policy NBE9: Historic Environment 7.10 We agree, in accordance with the NPPF, that proposals for new development that may

affect heritage assets will be supported where they conserve the significance of the

heritage asset. However, paragraph 131 of the NPPF states clearly that local planning

authorities should take account of the desirability of sustaining and enhancing the

significance of heritage assets. On this basis, the NPPF is quite clear in stating that

enhancing the significance of a heritage asset is not a requirement (see also the statutory

duty for Conservation Areas in s72 of the 1990 Act). We therefore consider that this policy

should be amended to make it clear, in accordance with the NPPF, that proposals for new

development should protect, conserve or, where possible, enhance heritage assets.

Policy I3: Transport

7.11 Although we agree with this draft policy, we consider the wording for criterion ‘d)’ needs

to be flexible to refer to any subsequent up-dates to the Council’s parking standards and

therefore recommend the following additional wording:

d) prov ide approp r ia te park ing prov is ion , in t erm s of am oun t , des ign and l ayou t , i n a ccordance w i th the Counc i l ’ s pub l i shed park ing s tanda rds , or any subsequen t am endm en ts t o these s tandards , or as se t ou t i n Ne ighbourhood P lans ;

Policy I4: Open Space, Sport and Recreation / Table 7: Open Space Standards

7.12 Whilst MGH support the inclusion of sufficient open space, sport and recreation facilities

as part of development proposals, there is concern regarding the standards outlined in

Table 2 of the Draft Plan in that in part they are excessive.

7.13 It is clear that Table 2 seeks to exceed the standards provided by Fields in Trust (“FiT”),

and many of the standards do. However, the quantum of natural / semi-natural

greenspace is overly excessive and would prove onerous to developers to be able to

accommodate, potentially affecting the viability of proposals.

7.14 FiT guidelines advise that 1.8ha of natural / semi-natural greenspace per 1,000 population

should be understood as a guide for new development proposals. This is well exceeded

within the suggested quantum within Table 2 which would require 8ha per 1,000



population within SPA Zones of Influence and 6.92ha per 1,000 population outside SPA

Zones of Influence.

7.15 Whilst it is understood that the Council are seeking to lessen recreational pressure on

SPA areas, it would be incorrect to impose such a requirement in addition to the

requirement for SANG as set out within draft Policy NBE4. It would be unjustified and

therefore unsound contrary to the requirements of paragraph 182 of the NPPF.

7.16 In order to remain sound, the Council are advised to return the natural / semi-natural

greenspace requirement down to 1.8ha per 1,000 population and remove the change in

quantum for areas within the Zone of Influence of an SPA area.

7.17 Open space standards proposed within draft Table 2 exceed the FiT guidelines as set out

below:

Open Space Table 7 Requirement FiT Guideline

Parks and Gardens 0.85ha per 1,000 population (within 800m for local parks / gardens, within 400m small local parks and gardens)

0.80ha per 1,000 population (within 710m)

Natural / Semi-natural greenspace

8ha per 1,000 population in SPA Zone of Influence. 6.92ha per 1,000 population in other areas. (400m, 2km, 4km and 5km dependant on scale)

1.8ha per 1,000 population (within 720m)

Amenity Green Space 400m 0.6ha per 1,000 population (480m)

LAPs 2.81 sites per 1,000 head population (60m)

0.25ha per 1,000 population (100m)

LEAPs 1.49 sites per 1,000 population (240m)


NEAPs 1.10 sites per 1,000 population (600m)


7.18 In summary, Policy I4 and supporting Table 2 would be unsound as such quantum of

natural / semi-natural greenspace, in addition to SANG requirements, would not be

justified as required by paragraph 182 of the NPPF. We would recommend required open

space standards revert to levels similar to those advocated by the FiT.

7.19 In addition, we consider this first paragraph within this policy suggests that the Council

will only support development proposals that enhance and improve the quality, capacity,

accessibility and management of sports and recreational facilities including playing fields,



built facilities and the open space network. We consider that the wording of this policy

should be reworded to state that ‘where possible’ development proposals should look to

enhance and improve sports and recreational facilities, as the nature of certain sites may

mean that enhancing and improving facilities is not achievable. Suggested revised text

below:

W here poss ib le , deve lopm en t p roposa ls w i l l be suppor ted w here they shou ld look to enhance and im prove the qua l i t y , capac i ty , access ib i l i t y and m anagem en t o f spor t s and recrea t iona l fac i l i t i es inc lud ing p l ay ing f i e l ds , bu i l t f ac i l i t i es and the open space netw ork .

Response to Consultation on Draft Hart Local Plan (Regulation 19) Conclusion


8.0 CONCLUSION

8.1 Martin Grant Homes, as raised in response to the previous Regulation 18 consultation on

the Draft Local Plan, hold concerns that there is a lack of consistency between the

evidence, the Vision and the Draft Plan.

8.2 The SHMA, which is now a further year out of date, requires a full review in order to fully

cater for the economic growth needs for the District, without which, economic growth

objectives will not be met. Further, the SHMA and Draft Plan will need to ensure it fully

considers the remainder of the HMA and beyond in terms of unmet housing need; and

given the relatively less constrained nature of Hart District the responsibility to assist in

context of neighbouring Districts which experience greater constraints.

8.3 It is of concern that the Council are not producing a positively prepared Local Plan by

maintaining a “do minimum” spatial strategy which involves the allocation of one solitary

site allocation; the strategic Hartland Village (referenced Hartland Park within the SA)

allocation. In addition to Hartland Village, it is considered that there is a need to allocate

a range of housing sites as advocated by the 2017 Housing White Paper, and to locate

development to the most sustainable locations around the District. Fleet, which includes

Church Crookham, is ranked as a Tier 1 settlement, representing the most sustainable

settlement in the District. The focus for additional residential development in addition to

Hartland Village, should be directed to sustainable locations such as the Site on land west

of Ewshot Lane.

8.4 As demonstrated within our review of the Council’s Sustainability Appraisal, the Site is

sustainable and should be seen as a reasonable alternative for housing delivery,

contributing to short term housing needs and ensuring the Council has a five year supply

of housing sites as required by the NPPF at paragraph 47. Whilst the Sustainability

Appraisal improves on some of the flaws of the former, there are still significant

deficiencies which, according to the report, arise due to the large number of alternatives

and therefore a perceived need to group all options into a smaller number of spatial

Options for delivery. As a consequence, a sustainable site such as our client’s on land

west of Ewshot Lane has been downgraded in its sustainability ratings as part of wider

spatial options. This hides potentially very sustainable options for housing delivery,

providing the homes required over the Plan period.

8.5 In summary, MGH consider that there is a need to consider greater housing growth than

currently allowed within the Draft Plan and that, in compliance with the NPPF and

Response to Consultation on Draft Hart Local Plan (Regulation 19) Conclusion


consideration of reasonable alternatives in line with sustainability considerations, the Site

west of Ewshot Lane, Church Crookham, is a deliverable, suitable and sustainable location

for strategic residential development in contribution towards this need. We consider that

a number of changes, as set out in this representation are required in order that the

emerging Local Plan can be considered sound in that it has is positively prepared,

justified, effective and consistent with national policy as required by paragraph 182 of

the NPPF.

APPENDIX A

Vision Document

L A N D W E S T O FE W S H O T L A N E


V I S I O N D O C U M E N TF E B R U A R Y 2 0 1 7

Submitted on behalf of Martin Grant Homes

1. VISION AND KEY BENEFITS . . . . . . . . . . . . . . . . . 3

2. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . 4The Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3. PLANNING CONTEXT . . . . . . . . . . . . . . . . . . . . . . 6Housing needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Sustainable Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

4. SITE APPRAISAL . . . . . . . . . . . . . . . . . . . . . . . . . 8Transport and Connectivity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8Landscape and Visual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Archaeology and Built Heritage . . . . . . . . . . . . . . . . . . . . . . . . . . 10Surface Water Drainage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Foul Drainage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Arboriculture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5. DESIGN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Mix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Green Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Concept Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12


3VISION DOCUMENT • FEBRUARY 2017


1. VISION AND KEY BENEFITSWe present this document on behalf of Martin Grant Homes to promote the inclusion of Land West of Ewshot Lane as a housing allocation site within the emerging Hart District Council Local Plan. The development will create a sustainable extension to Church Crookham, providing new homes and open space of the highest design quality to help meet the identified housing need in the District and facilitate improvements to the local highway network.

THE VISION IS UNDERPINNED BY A NUMBER OF KEY THEMES:

• Creating a rich variety of habitats to increase the biodiversity of the Site and opportunities for flora and fauna to thrive

• Delivering highway, access and transportation improvements to Ewshot Lane

• Respecting and enhancing the setting of existing cultural heritage assets including listed buildings and pill box

• Accommodating elements of green infrastructure to respond to the landscape setting and rationalising the Local Gap to a logical edge

• Retaining, protecting and enhancing the existing landscape structure of field boundaries and trees

• Improving and connecting the existing pedestrian routes to create an integrated and permeable network

• Adopting a best practice approach to sustainable urban drainage

• Delivering up to 150 homes and open space in accordance with policy

VISION DOCUMENT • FEBRUARY 20174


2. INTRODUCTIONThis document demonstrates that Land West of Ewshot Lane is a deliverable site which should be allocated within Hart District’s emerging Local Plan. The identification of this sustainable site on the edge of a settlement boundary will support the Council in meeting its objectively assessed needs figure for housing.

2.1 On behalf of our client, Martin Grant Homes, we consider the Land West of Ewshot Lane presents an opportunity for sustainable residential development, on the edge of the most sustainable settlement within the district, capable of assisting the District in providing its objectively assessed housing needs and a contribution to the 5-year supply of deliverable sites for housing.

2.2 There have been significant residential-led developments granted planning permission in the area immediately surrounding the subject site. Of particular note is the Land West of Redfield’s lane (14/00504/MAJOR) (Granted at appeal). The Inspector’s decision demonstrates that sites on the edge of the Church Crookham / Fleet settlement boundary should be considered to be in a sustainable location. In addition, there have been two planning applications for residential uses granted on land at Blue Prior Business Park to the west of the Site. One of these permissions is for 72 assisted living units on land which directly abuts the western boundary of the Site. The other permission is for 13 residential dwellings within a central location in the business park. These permissions clearly demonstrate the direction of development in the surrounding area towards residential and the acceptability of new homes in this location.

2.3 On this basis, this document presents and explains why we consider this site is a suitable location for development which we hope will be of assistance to the Council as you progress work for the new Hart District Local Plan.

THE SITE2.4 The Site extends to approximately 6.40ha and, whilst it falls within the boundary of Ewshot Parish, it is situated on the edge of the Fleet and Church Crookham settlement boundary. Fleet and Church Crookham is identified by Hart District Council as the largest and most sustainable settlement within the District. Therefore, the Site is well located within the context of the District and is an appropriate location for new development.

2.5 The Site is bounded to the north by Avondale Lawn Tennis Club and Redfields Garden Centre. Immediately to the west of the Site is an area of previously undeveloped land which has planning permission for the erection of 72 assisted living units. Beyond is Freeland’s Croft Nursing Home and Blue Prior Business Park. Planning permission has been granted for the development of a Site within the business park for 13 residential dwellings (13/01882/OUT & 15/02257/REM). At the former Queen Elizabeth Barracks Site to the east of Redfield’s Lane, planning permission was granted for a residential-led redevelopment comprising 872 residential units, a new primary school and a new local centre (11/00001/MAJOR). To the east of the Site is predominantly open fields, including Stiller’s Farm with a small group of buildings which comprise a car mechanics and agricultural buildings. To the south are open fields with sporadic buildings associated with agricultural use. At its closest, the Site is some 0.9km from the settlement area of Ewshot.

2.6 As outlined above, there is a clear progression of residential uses and development of sites in close proximity to

the Site west of Ewshot Lane. This illustrates the suitability of Land West of Ewshot Lane as a sustainable location for residential development. Also, by reason of the major residential-led developments, supporting infrastructure such as schools, retail, community facilities and SANGs are being delivered which are of benefit to the local community and able to support further residential growth.

2.7 The Site provides the opportunity to accommodate residential development which would fit with the pattern of development surrounding the Site. Residential uses can be seen to the east and west of the Site to the west of Ewshot Lane and, therefore, the development of the Site for residential use would fit with this pattern of development and help to establish a consistent new settlement boundary.

2.8 The majority of the Site is designated as ‘Local Gap’. The Gap is between the settlement of Fleet / Church Crookham, directly to the north and east of the Site, and the settlement of Ewshot, some 900m to the south of the Site. The Local Gap boundary runs directly through the Site and does not follow any physical land boundary. As such, it does not present a defensible boundary which is easily maintained to safeguard against encroachment. Ewshot Lane, which runs directly to the east of the Site, would provide a defensible boundary to mark the edge of the Local Gap and given the significant separation to the settlement boundary of Ewshot, it is not considered that this would represent a harmful closure of the Local Gap or prejudice the future function of the Gap.



FIGURE 1. SITE LOCATION PLAN

Church Crookham

Crookham Park

Redfields Lane

Ewshot Lane

Albany Park



3. PLANNING CONTEXT

HOUSING NEEDS3.1 National policy (National Planning Policy Framework; paragraph 47) establishes the need for local authorities to boost significantly the supply of housing through ensuring that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. In order to meet this need, a range of sites across Hart District Council are required to be identified through the plan process and deliver housing development.

3.2 We are aware that Hart District Council is working towards the adoption of a new Local Plan. The housing need figure used to inform the preparation of this plan to date is taken from the Hart, Rushmoor, and Surrey Heath SHMA, published by Wessex Economics in December 2014. This assessment sets the objectively assessed needs for Hart District between 2011 and 2031 at 370 dpa and for the housing market area, 1,180 dpa. These figures are not considered up-to date as the housing targets are based on interim 2011-based household projections which is considered not reliable as it does not use Census 2011 and is underpinned by recessionary trends. Therefore, the current dwelling numbers proposed are based on an unsound position and should be significantly higher.

3.3 Barton Willmore’s assessment of Full Objectively Assessed Need (OAHN) for Hart District between 2011 and 2031 is at least 730 dpa. Across the wider HMA (incorporating Rushmoor and Surrey Heath), OAHN is 1,950 dpa. This assessment takes full account of demographic trends, change in job numbers, market signals and affordable housing needs as of February 2016.

3.4 Hart District Council is understood to be currently updating their SHMA. On the basis of the above, the figure will represent a significant increase upon that which was assessed in the 2014 SHMA. In seeking to address its housing needs, it is expected that the Council is likely to need extensions to sustainable settlements, a new settlement and strategic urban extensions. The inclusion of land west of Ewshot Lane, Church Crookham will assist the Council in addressing short term housing needs.

SUSTAINABLE DEVELOPMENT 3.5 National Planning Policy (the NPPF and PPG) promotes a presumption in favour of sustainable development. An assessment of the three dimensions of sustainability is provided below as a basis for the Site’s sustainability credentials to be assessed.

ECONOMIC3.6 Sustainable development approaches encourage locations where existing services and employment opportunities can bring immediate benefit to future residents. The Site is located in an accessible location with a number of local day to day facilities within acceptable walking distance, as well as employment opportunities. Fleet town centre is well within acceptable cycling distance, providing a wide range of facilities commensurate with its size. There is a regular bus service within the vicinity of the Site, which provides connections to the centre of Fleet, the rail station and Farnborough.

3.7 The Site would also benefit from the infrastructure being provided at Albany Park (14/01223/FUL) including a proposed medical centre, a convenience food store (both of which would be in walking distance from this Site), funding for the extension of Zebon Copse Centre (plus provision of additional sports pitches and pavilion) and significant transport improvements to Redfields Lane (including the junction with the A287 to the south).

3.8 The redevelopment of the former Queen Elizabeth Barracks and associated infrastructure would also benefit a residential use for the Site. In particular, the new local centre to the north east of the Queen Elizabeth Barracks Site which includes a Sainsbury’s

The allocation of Land West of Ewshot Lane within Hart District Council’s new Local Plan would support the Council in meeting the National Policy requirement to boost significantly the supply of housing. The delivery of housing on the site would represent a sustainable development in relation to economic, social and environmental considerations. In particular, the site is in an accessible location and well related to local services, facilities and Fleet Town Centre.



supermarket. The local centre is approximately 600m from the Site and would be easily accessible on foot via the access point to the east of Ewshot Lane, directly opposite the Avondale Lawn Tennis Club.

3.9 An additional benefit in providing new homes close to the above services and employment opportunities is the added economic support new residents will provide to village centres. The NPPF recognises town/village centres as the heart of their community and encourages efforts to support their viability and vitality. It appreciates that residential development can play an important role in ensuring the vitality of centres and seeks to encourage policies that help residential development come forward on suitable Sites. This development would bring economic benefit to and increase the vitality and viability of surrounding centres.

SOCIAL3.10 The provision of new homes, including affordable homes, will respond to the social aspect of sustainable development. Affordability in Hart District has deteriorated since 2001 and the house price to income ratio is currently one of the highest in the country (10.7 compared with the national average of 6.5). In, addition, 71% of first time buyers are unable to afford to buy a lower quartile priced-house. The increased delivery of market and affordable housing, including housing development on the Site will contribute to improving the situation in Hart District as well as the wider South East.

ENVIRONMENTAL 3.11 The Site lies within 5km of the Thames Basin Heaths SPA. As such, any housing development will be required to mitigate impact on the SPA through Suitable Alternative Natural Greenspace (SANG). As the Council will be aware from the appeal in respect of 300 homes at Albany Park (REF: 14/01223/FUL), there is significant additional capacity in the proposed SANG at Albany Park being brought forward by Martin Grant Homes, which is capable of serving development at Ewshot Lane. As such, the development would not have an adverse impact on the SPA.

3.12 The Site is in an accessible location with a number of local day to day facilities within acceptable walking distance, as well as employment opportunities. Fleet town centre is well within acceptable cycling distance, providing a wide range of facilities commensurate with its size. There is a regular

bus service within the vicinity of the Site, which provides connections to the centre of Fleet, the rail station and Farnborough.

3.13 In relation to ecology, preliminary survey work and data searches indicate that there is limited ecology interest at the Site. Ecological requirements will be addressed through the development design, layout and landscaping.

3.14 A Historic Environment Desk Based Assessment has identified no overriding heritage constraints which are likely to preclude development of the Site. Stiller’s Farmhouse and Barn are the nearest heritage assets to the Site, however, the rural setting of these listed buildings has already been significantly changed with the addition of modern agricultural buildings and a car workshop in the immediate setting and the redevelopment of the Former Queen Elizabeth Barracks in the wider setting. Of note is a WWII Type 24 pillbox overlooking Ewshot Lane which falls within the Site. The WWII pillbox would be retained as a heritage asset within green space and enhanced with any necessary minor works undertaken to stabilise its condition and make the structure safe in a publicly accessible setting.

3.15 Trees are predominantly located along the boundaries of the Site with the exception of three oak trees within the Site. The boundary trees provide useful screening and initial indications are that these trees should be retained. Two of the trees within the Site are in good condition with the third within a state of decline.

3.16 To summarise, in relation to sustainability the site will offer economic benefits including the provision of new residents living in the new homes to support local services and new population which will help to support the viability and vitality of local centres. It will offer social benefits through the provision of new housing and social housing in an area of unaffordability and high housing need. Environmentally, the site is in an accessible location within acceptable walking and cycling distance of a wide range of facilities. In addition, the site will mitigate any impact on the Thames Basin Heath SPA through using the additional capacity of the Albany Park SANG. As such, it is considered that the development would constitute sustainable development as required by the NPPF.



4. SITE APPRAISALThe Site and immediately adjacent areas have been the subject of a comprehensive technical assessment to understand the key constraints and opportunities which will influence future development in this location. The assessment has demonstrated that there are no constraints in relation to access, landscape and visual considerations, ecology, trees, archaeology, drainage or Utilities which would prevent or delay the site coming forward for development.

TRANSPORT AND CONNECTIVITY4.1 The Site is in an accessible location with a number of local day to day facilities including shops, schools and leisure within acceptable walking and cycling distances, along with employment opportunities. Fleet town centre is within acceptable cycling distance and provides a wider range of facilities commensurate with its size. There is a regular bus service within the vicinity of The Site, which provides connections to Fleet town centre, the rail station and Farnborough. Development in this location would, therefore, benefit from its accessibility to local facilities and services with genuine opportunities for journeys by sustainable modes of travel.

4.2 Access to the development will be achieved via a re-alignment of Ewshot Lane which would create a change in priority discouraging through vehicle movements. Improvements to Ewshot Lane can be delivered to provide a safe and suitable access with pedestrian and cycle facilities connecting to existing infrastructure. The access complies with the design guidance contained within the Manual for Streets.

4.3 Initial appraisal confirms that development traffic could be accommodated in an acceptable manner on the immediate transport network, in particular at the Ewshot Lane junction with Aldershot Road/Redfields Lane. We do not believe increases in traffic flows would be at a level which would have a material impact on the safe and efficient operation of the transport network.

FIGURE 2. PROPOSED SITE ACCESS HIGHWAYS DETAIL

4.4 In summary, the development would provide:

• Opportunities for sustainable modesof travel;

• Safe and suitable access for all; and

• Improvements to the transport networkwhich limit the impacts of development.

LANDSCAPE AND VISUAL4.5 The Site is not covered by any statutory or non-statutory designations for landscape character or quality. The Site comprises a large pastoral field with three mature trees located within the western part of the Site. The main landscape features of the Site are provided by the hedgerow lined field boundaries, which contain a number of mature trees, and these are generally in good condition. None of the trees within the Site are covered by Tree Preservation Orders (TPOs) and there are no public rights of way crossing the Site. The Site is generally well contained by the boundary vegetation, with some filtered views from the public footpath running immediately adjacent to the southern site boundary and from the two listed buildings at Stillers Farm.

4.6 The Site lies within the Redlands Landscape Character Area (LCA) as defined by the Hart District Landscape Assessment 1997. The key characteristics of this LCA include a mixed, fragmented landscape with a complex network of roads and settlements, displaying rural character but with suburbanising influences and a well-wooded nature which reduces the visual intrusion of built development. The enhancement priority within the LCA is to create a more coherent landscape, managing existing and planting new woodland, trees and hedgerows. The landscape character of the Site and its immediate surroundings are influenced

Ewshot Lane

Realigned Ewshot Lane



FIGURE 3. CONSTRAINTS PLAN

Ewshot Lane

Redfields Industrial

Estate



4.10 The habitats on-site consist of a single grassland field bounded by native hedgerows, two of which (along the eastern and northern boundary are species-rich). A shallow stream runs along the southern boundary and there are a small number of mature trees. Part of the field is taken up by a former car parking area which is colonising with sparse vegetation. The majority of the field is semi-improved grassland and does not support a high component of broadleaved species.

4.11 The survey and data searches suggest some potential for dormice within boundary vegetation, badger activity close to the site, possible bat roosting opportunities within trees and modest potential for common reptile species to occur. Further scoping work is also required in respect of great crested newts and invertebrates. Despite the potential that certain protected species issues may materialise and mitigation may need to be provided, there is no reason to believe that such species will provide any overriding constraint to development, if present.

4.12 Through the provision of a sensitive masterplan there will be opportunities to provide some ecological enhancements alongside development, including new native planting (e.g. trees, scrub, grassland) to strengthen wildlife links and green infrastructure. Aquatic habitat could be provided as part of the surface water drainage design and new features created for birds, bats and invertebrates.

ARCHAEOLOGY AND BUILT HERITAGE4.13 A Historic Environment Desk Based Assessment has identified no overriding heritage constraints which are likely to preclude development of the Site.

4.14 The nearest designated heritage assets are Stillers Farmhouse and Barn, both Grade II listed building. Stiller’s Farmhouse dates from the 17th century but includes 18th, 19th century and 20th century additions and alterations. The adjacent barn is of 18th century date. The Stiller’s Farm complex includes a range of modern agricultural sheds that now serve a range of non-agricultural uses. The original rural setting of the listed buildings has been altered over the last century, notably by the construction of the adjacent Queen Elizabeth Barracks, now being developed for residential housing.

4.15 The farmhouse is set slightly back from the Lane with its principal elevation to the south-west; the high hedgerows that border Ewshot Lane lend screening and privacy to the lower storey. The barn lies adjacent to the more modern farm buildings, set back from the lane with a drive and open grass to the south-west. The barn is currently occupied by a car repair business.

4.16 Existing hedgerows along Ewshot Lane would be retained and strengthened with development stepped back from the Ewshot Lane hedge opposite the farm to maintain its immediate setting. The proposed site access design would help to retain the sinuous, narrow form of Ewshot Lane and reduce traffic along the Lane.

4.17 Within the Site a WWII Type 24 pillbox overlooking Ewshot Lane is of interest as part of the wider GHQ Line A defences established in 1940, but is not a designated heritage asset. No impacts on the setting of the pillbox in relation to the GHQ Line A defences and the local topography are anticipated from residential development on the Site. The WWII pillbox would be retained as a heritage asset within green space and enhanced with any necessary minor works undertaken to stabilise its condition and make the structure safe in a publicly accessible setting. This would be similar to the way that similar structures have been preserved and presented within the Crookham Park SANG at Ridding’s Copse.

4.18 No previous archaeological investigations are known within the Site, consequently the presence, location and significance of any buried archaeological remains within The Site cannot currently be confirmed on the basis of the available information. Investigations at the QE barracks site found low levels of archaeological remains of likely Iron Age date and archaeological investigations may be required prior to development of The Site: such works could form part of a programme of archaeological investigations secured by planning condition.

by a number of urbanising features including the Redfields Garden Centre and tennis club to the north, the nursing home and industrial park to the west and a number of large utilitarian buildings at Stillers Farm to the east of The Site.

4.7 The Site is covered in part by the edge of the Fleet/Church Crookham to Ewshot Local Gap policy CON21 which covers a large area of land extending up to Beacon Hill Road to the east of the Site. The policy as defined by the Hart District Local Plan protects the separate identity of settlements, preventing their coalescence. The Site is considered to play a very limited role in providing separation between Church Crookham and Ewshot, with the rising land at Ridding’s Copse to the south east providing containment to urban fringe activities on the southern edge of Fleet and reinforcing the separation between Fleet and Ewshot.

ECOLOGY4.8 A Preliminary Ecological Appraisal (PEA) comprising an extended Phase 1 survey of habitats was undertaken in June 2016 to map and describe the habitats present on-site and to identify any potential for protected or notable species. This was supported by a desktop search for environmental records.

4.9 No part of the Site lies within any statutory or non-statutory nature conservation area, nor is any such area located directly beyond any boundary. However, the Site lies in proximity to several designated sites of wildlife importance, including the Thames Basin Heaths (TBH) Special Protection Area (SPA) which is located c.1.6km east of the Site. As is well established, mitigation is required for all net new development within 5km of the TBH SPA and this will necessarily take the form of (i) providing Suitable Alternative Natural Greenspace (SANG) and (ii) making the required Strategic Access Management and Monitoring (SAMM) payment. It is envisaged that SANG provision will be provided by spare capacity at the approved Albany Park SANG being brought forward by the same developer on land to the west of Redfield’s Lane. The Land West of Ewshot Lane sits comfortably within the catchment area for the Albany Park SANG and this SANG has sufficient capacity to accommodate the housing numbers from this site. Additional sites of lower importance (e.g. Local Nature Reserves) also occur within 1km but are not likely to be significantly impacted by this development.

1 1VISION DOCUMENT • FEBRUARY 2017


SURFACE WATER DRAINAGE4.19 The concept drainage strategy is based on the assumption of no infiltration due to the site soil conditions. Surface water run-off from the proposed development will drain into the existing ditch to the north of the Site, the water flow will be limited to the existing greenfield rate. The strategy will seek to mimic the existing drainage scenario and utilise sustainable drainage design features which capture the surface water across the site. It is anticipated that this will include permeable paving areas which store the rain water and slowly drain into the proposed network. These types of drainage features will offer a level of water treatment. At the northern corner of the Site, an attenuation pond will capture all of the Site’s surface water before being drained at a controlled rate into the existing ditch.

FOUL DRAINAGE4.20 There are currently two options for the foul drainage identified in the concept drainage strategy. Option one is to install a gravity sewer from the western side of The Site through to the existing gravity sewer system in Blue Prior Business Park. This route involves running a sewer through an existing carpark, across a section of green space and into the newly constructed nursery car park. Based upon preliminary review, this existing sewer is at a sufficient depth to cater for the Site.

4.21 Option two involves installing a new foul pumping station at the lowest point of the Site in the northern corner near to the proposed attenuation pond and run a rising main along the northern boundary towards Ewshot Lane on the east side of the Site. Once in Ewshot Lane, there is an existing gravity sewer running north towards the main village centre which can be connected into.

UTILITIES4.22 BT and Scottish and Southern Energy both have existing plant running along the eastern site boundary on Ewshot Lane. These could be connected into the Site via the proposed access arrangement. South East Water has an existing potable water main running down Ewshot Lane as far as Rose Cottages, this main could be extended towards the proposed access for the development. Southern Gas Network has an existing gas main serving Humphrey Park to the north of the proposed Site entrance, this would require extension along Ewshot Lane to provide gas to the development. Based upon the proximity of these existing services to the development it is acceptable to assume that the Site can be supplied with utilities.

ARBORICULTURE4.23 The Site itself is bounded by trees along the southern boundary and Ewshot Lane frontage, some of which are worthy of retention within the scheme but others are of poor quality and value.

4.24 Within the Site are three mature oaks of some visual stature. One of these trees exhibits low vitality, so a decision on whether it is retained will need careful consideration.

4.25 Openings in the road frontage tree cover permit the placement of an access road and cycle/footway network to serve the development without material detriment to the tree cover.



5. DESIGNThe key parameters associated with the proposed development are set out in this section relating to amount, mix, density and type of green space together with principles underpinning the concept. The concept plan is informed by the Site’s relationship with the wider surrounding area and includes approximately 3.74 ha of land for residential development and 2.64ha of land for open space.

LAND USE5.1 Amount: The Site comprises some 6.40ha and will provide a minimum of 2.64ha of open space, integrating existing trees, hedgerows, areas of surface water flooding and providing appropriate buffers to existing heritage assets. Approximately 3.74ha of land will be available for residential development.

5.2 Density: The development area will accommodate a range of densities across the Site from 20 – 40dph consistent with responding to the character of the surrounding area. It will also assimilate the development into the wider landscape context whilst making efficient use of land. Lower density edges are anticipated adjacent to Ewshot Lane, towards the southern boundary and adjacent to the existing dwellings to the north associated with Rose Cottages.

MIX5.3 The Site can deliver a broad mix of housing types and tenures as part of creating a balanced, safe and sustainable community for the future. The precise mix will be determined at a later stage in the process and in discussion with the relevant consultees. Notwithstanding, the density of the Site will facilitate the delivery of a range of 2, 3, 4 and 5 bed homes. Although the density range will not require the use of apartments to meet the dwelling requirement, some 2 bed apartments may be appropriate on Site as part of providing a mixture of typologies to meet an identified need.

GREEN SPACE5.4 The Site will deliver a minimum of 2.64ha of open space in accordance with the requirements of the 2012 Open Space Assessment. SANG provision will be made off-site within the consented Albany Park SANG approximately 1km to the west. A range of typologies will be provided, including:

• Children’s Play Space;

• Amenity Greenspace

CONCEPT PLAN 5.5 The concept has been informed by a thorough assessment of the Site and relationship to the immediate and wider context. It provides a framework for the delivery of a high quality, sustainable extension to the existing built up area of Church Crookham. Particular consideration has been given to integrating the Site into the surrounding landscape context, the Local Gap, existing landscape assets and provision of new open space typologies to create a multi-function green infrastructure network.

5.6 Embracing the Site’s relationship to existing employment uses, existing and consented facilities, and public rights of way has created a permeable network of routes within the Site. These routes will be direct, safe and convenient to maximise the opportunities for people to travel by sustainable modes.

5.7 The scale of development will be informed by the prevailing scale of surrounding buildings and relationship with the immediate and wider countryside, typically ranging between 2 and 3 storeys. A central area of open space will provide a focus and sense of arrival for the development. This intrinsic legibility will be reinforced by the character and pattern of radiating streets, key spaces, landmark buildings, and retained vegetation.



FIGURE 4. CONCEPT PLAN Ewshot Lane



FIGURE 5. ILLUSTRATIVE MASTERPLAN

Redfields Industrial Park

Ewshot Lane


Land West of Ewshot Lane provides a natural and logical extension to Church Crookham that will link and extend existing landscape assets and publicly accessible open space, facilitating development of the highest design quality. The delivery of up to 150 new homes will contribute towards meeting an identified need and facilitate highway improvements to Ewshot Lane, diversify habitats and enhance the setting of cultural heritage assets.


All plans are reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown copyright Reserved. Licence No. AR152684.

Barton Willmore

T: 0118 943 0000 / F: 0118 943 0001

Desk Top Publishing and Graphic Design by Barton Willmore

This artwork was printed on paper using fibre sourced from sustainable plantation wood from suppliers who practice sustainable management of forests in line with strict international standards. Pulp used in its manufacture is also Elemental Chlorine Free (ECF).

Project Ref: 25681/A5/Documents

Status: Final

Issue/Rev: m

Date: February 2017

Prepared by: Various

Checked by: NPN

Copyright

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore.

J:\25000 - 25999\25600 - 25699\25681 - Land West of Ewshot Lane\A5 - Reports & Graphics\Graphic Design\Documents\Vision Doc

bartonwillmore.co.uk town Planning MasterPlanning & Urban Design architectUre lanDscaPe Planning & Design Project ManageMent & cost consUltancy environMental & sUstainability assessMent graPhic Design PUblic engageMent research

all barton willmore stationery is produced using recycled or Fsc paper and vegetable oil based inks