Hart District Council Draft Local Plan Strategy and Sites 2011-2032 in relation to Land at Grange Farm, Hartley Wintney Representations on behalf of Cove Construction Ltd

9th June 2017

Contents

1. Introduction 3

2. Legal Compliance 4

3. Specific Representations on the Draft Local Plan Strategy and Sites 2011-2032 6

4. Land at Grange Farm, Hartley Wintney 20

Appendix 1: Site Location Plan

Appendix 2: Vision Document Appendix 3: Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067

David Murray-Cox

Client Cove Construction Ltd Our reference COVR3008

9th June 2017

1. Introduction

1.1 These representations have been prepared on behalf of Cove Construction Ltd (hereafter referred to as Cove) in response to the consultation on the Hart District Council Draft Local Plan Strategy and Sites 2011-2032 document.

1.2 Cove is promoting land at Grange Farm, located to the south-west of Hartley Wintney, to the west of Grange Lane and between West Green Road and Thackham’s Lane for a residential development of between 125 - 175 dwellings as well as a significant area of Suitable Alternative Natural Greenspace (SANG) and other open space uses.

1.3 This land has been considered by Hart District Council in the preparation of the Local Plan under reference SHL019.

1.4 To the north of the site is West Green Road, beyond which is the built development of Hartley Wintney to the north-east. The eastern boundary of the site is formed predominantly by Grange Lane. Beyond this is the A30 and residential development.

1.5 The location of the site is identified on the Site Plan at Appendix 1.

1.6 This submission is also supported by a Vision Document, enclosed at Appendix 2.

1.7 The Vision Document for this site presents one way in which this site could be developed. The exact quantum of development and SANG will be established through further design work.

1.8 Cove consider that this site represents an opportunity for sustainable development and would welcome the opportunity to discuss this matter with Officers and relevant stakeholders.

1.9 Section 2 and 3 of these representations sets out our client’s comments on the Hart District Council Draft Local Plan Strategy and Sites 2011-2032 document and its associated evidence base.

1.10 Section 4 of these representations provides details on the way in which the land at Grange Farm, Hartley Wintney was considered by the Council in its evidence base and also sets out the opportunity presented by this site.

2. Legal Compliance

Date of adoption and length of the plan

2.1 Our clients note that the proposed Plan Period covers a period from 2011-2032.

2.2 Significantly the Local Development Scheme (April 2017) envisages that the Local Plan will be adopted in the summer of 2018.

2.3 The Framework states at paragraph 157 that “Crucially, Local Plan should … be drawn up over an appropriate timescale, preferably a 15-year time horizon”. The 15 year period is also critical to the operation of paragraph 47 of the Framework.

2.4 Cove considers that as a result the 15 year period would therefore expire in summer 2033 and the plan should be amended to cover the period to 2033 / 2034.

2.5 Accordingly, the level of development planned for should be increased to reflect the extended plan period.

Duty to Co-operate

2.6 The Duty to Cooperate (DtC) is an integral part of the plan making process and is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of Plan preparation.

2.7 As demonstrated through the outcome of the 2012 Coventry Core Strategy Examination and the 2013 Mid Sussex Core Strategy Examination, if a Council fails to satisfactorily discharge the DtC, a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.

2.8 It is recognised that the DtC is a process of ongoing engagement and collaboration. As set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In this regard, the Council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside their existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the requirement to meet any unmet needs (including housing need). This is not simply an issue of consultation but a question of effective cooperation to ensure that the Housing Market Area’s (HMA’s) housing needs are met in full.

2.9 Cove note that the Council commissioned Wessex Economics to prepare a Strategic Housing Market Assessment (SHMA) which outlines some cross boundary issues with regard to the provision of housing across the HMA (which in this case includes the following areas: Hart, Rushmoor and Surrey Heath).

2.10 Further the draft Plan outlines at Paragraphs 10, 11 and 96 – 98 that discussions of the emerging Plan outlines the cross boundary issues considered during its preparation with

neighbouring authorities Rushmoor Borough Council and Surrey Heath Borough Council are taking place.

2.11 However, as the DtC is a process of continued cooperation it is essential that the Council prepare a DtC statement to effectively demonstrate what steps the Council has taken through each round of consultation to ensure that the plan has been subject to ongoing and effective cooperation with any interested parties to which a strategic cross boundary issue, such as unmet housing needs, may effect.

2.12 Furthermore, the Planning Practice Guidance (PPG) sets out the public bodies which are subject to the DtC and contains a list of the prescribed bodies, of which one is the Mayor of London. The PPG then goes on to state that:

‘These bodies play a key role in delivering local aspirations, and cooperation between them and local planning authorities is vital to make Local Plans as effective as possible on strategic cross boundary matters’

2.13 Cove therefore urge the Council to actively engage with the Mayor of London with regards to the DtC. The Further Alterations to the London Plan will require significant cross boundary working to deal with the level of unmet housing needs beginning to emerge from London, to which Hart District may be able to help accommodate some of this unmet need.

3. Specific Representations on the Draft Local Plan Strategy and Sites 2011-2032

3.1 The following section of these representations provides specific comments on the policies and paragraphs contained within the Draft Local Plan Strategy and Sites 2011- 2032 document. These comments should be read in the context that the Plan period should be extended to 2033/34.

Settlement Hierarchy – Paragraphs 87-91

3.2 We note that the settlement hierarchy indicates that Hartley Wintney is a ‘secondary local service centre’, with this finding based on evidence presented through the Settlement Hierarchy for Hart District 2010.

3.3 We also note that paragraph 21 of the draft Plan identifies Hartley Wintney as a larger village.

3.4 Our client supports the identification of Hartley Wintney as a ‘Secondary Local Service Centre’. On this it appears that the draft Local Plan acknowledges that Hartley Wintney is a sustainable settlement within the District and should be seen as an appropriate location for future growth to assist the Council in meeting its housing needs.

3.5 However, our client raises concerns that the settlement hierarchy is based on evidence which is some 7 years old and as a result we would urge the Council to update this evidence base document to ensure it is fully up-to-date and based on robust evidence.

Objectively Assessed Need - Paragraph 94

3.6 We note the Council’s intention to Plan for 10,185 homes over the plan period. However this requirement should be expressed as being for “at least” 10,185 dwellings (consistent with Policy SS1) in order to help ensure that the necessary level of development is provided and provide a degree of flexibility in the event that certain sites stall, take longer to deliver or do not progress during the Plan period. However, as noted above, our client contends that the Plan period should expire in 2033/34and consequently the housing requirement should increase incrementally by the annual requirement.

Policy SS1: Spatial Strategy: Scale and Distribution of Growth

3.7 In the first instance our clients note that within the wording of Policy SS1 under ‘New Homes’ there are two rows for completions (row a and b). We assume that this is an oversight on the council’s part and that row b should in fact refer to ‘New homes with planning permission as at 31 January 2017’ as per Table 2, however we would welcome clarification in this regard.

How we will meet out Housing Needs 3.8 Our clients support paragraph 111 of the emerging Plan in as much as it highlights that there will be a requirement for additional Greenfield release adjacent to existing settlements to meet the housing requirement.

3.9 However, our clients have significant concerns that the Plan does not make any provision for development within or adjacent to the settlement of Hartley Wintney. This is especially concerning when consideration is given to the role of Hartley Wintney within the settlement hierarchy as a Tier 3 settlement and secondary local service centre.

3.10 Table 4 of the Plan identifies the following non-strategic allocations in edge of the rural settlement locations:

 Crookham Village 100 dwellings  Eversley 124 dwellings  Land adjacent to Riseley 83 dwellings  Long Sutton 10 dwellings  South Warnborough 34 dwellings  Yateley 88 dwellings

 TOTAL 439 dwellings

3.11 The Background Paper ‘A Settlement Hierarchy for Hart District’, on which the proposed settlement hierarchy is based, identifies Crookham Village, Eversley, Long Sutton, South Warnborough all as “Tier 4” (Main Villages), with Riseley identified as a “Tier 5” settlement (Smaller Village).

3.12 As such with the exception of Yateley the above settlements are all ranked by the Council’s own evidence base as less sustainable than Hartley Wintney and therefore by inference less suitable to accommodate growth. For example, the settlement of Crookham Village only meets 4 of the categories used to rank settlements within the Background Paper ‘A Settlement Hierarchy for Hart District’; compared to Hartley Wintney which meets 11 of the categories. As a result the allocation of land at these settlements rather than Hartley Wintney does not meet the requirements of the Framework which supports the delivery of sustainable development.

3.13 Further paragraphs 34, 35 and 37 of the NPPF seek to ensure that development plans incorporate policies which minimise the need to travel, reduce journey lengths and promote sustainable transport modes. Development in and around the main Fleet area (including Church Crookham and Elvetham Heath) or in the Primary/Secondary Local Service Centres (including Hartley Wintney) would clearly have a greater propensity for shorter journeys by more sustainable modes compared with development in locations elsewhere in the district.

3.14 As such the current dispersal strategy allocates additional development to Tier 4 and 5 settlements. These “Tier 4” and “Tier 5” settlements do not have the range of facilities or services which are available in the Tiers 1-3 settlements and by this virtue will promote less sustainable patterns of development.

3.15 Furthermore, this ad-hoc dispersal strategy down to such lower tier settlements will risk increasing pressure on the local road network and utilities capacity without delivering the necessary quantum to fund the required infrastructure.

3.16 There is no explanation within the draft Local Plan as to why the Council does not propose to allocate sites at Hartley Wintney.

3.17 Our clients also have concerns with the Sustainability Appraisal issued for consultation alongside the emerging Local Plan, as it does not provide a robust assessment which considers the impact that these allocations will have on the respective settlements. Nor does it consider the impact of not allocating development the Council’s own vision statement noting that; “Historic villages such as Odiham and Hartley Wintney will be vibrant centres providing facilities for residents and visitors.”

3.18 Historically, Hartley Wintney has seen limited levels of growth when compared to other settlements (10% as identified within the March 2016 refined options consultation) across the District. There is a clear risk that the absence of any allocations within the settlement will stifle the viability and vitality of Hartley Wintney centre over this and future plan periods and as a result there is a clear need to ensure that Hartley Witney sees a proportional amount of growth relative to the spatial strategy.

3.19 It should also be noted that land at Grange Farm (Site Reference 19a and 19b) was shortlisted for residential development as part of the Delivering New Homes Consultation between February and March 2016. However, there is no justification within the emerging Plan or its evidence base, including the Sustainability Appraisal, as to why it has been discounted. We set out the reasons why the site should be included as an allocation at Section 4 of this submission.

3.20 The National Planning Policy Framework is clear at Paragraph 158 in that each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence.

3.21 Our clients have significant concerns that the lack of any justification/ evidence for the removal of Grange Farm as a preferred site for residential development and also the fact that no land is allocated at Hartley Wintney. On this basis it is considered that the Plan does not meet any of the tests of soundness as set out at paragraph 182 of the Framework.

3.22 It is also noted that under Policy SS1 the Council identify the supply of housing to meet their housing target of 10,185, comprising:

a) Completions (1st April 2011 up to 31st January 2017) - 2,160

b) Completions (1st April 2011 up to 31st January 2017) - 3,144 (as noted above we assume this refer to new permissions)

c) Previously developed land - 210

d) Strategic Sites (Policy MG3 and Policies SC1-SC4) - 3,720

e) Extensions to smaller settlements (Policy SC5) - 611

f) Rural Exception Sites (Policy SC9) - 50

g) Windfall Allowance - 290

Total - 10,185

3.23 In the event that all of the sources of supply identified in rows B – G deliver the total amount of development expected, within the plan period, then just 10,185 dwellings will be delivered, exactly the Council’s housing target.

3.24 This assumption does not allow for any delays or complexities of housing delivery. Indeed, commitments and allocations totalling 0 dwellings above the proposed housing target, does not represent a true commitment to flexibility to ensure that the current proposed housing requirement is met, especially when the Council have already included a proportion of windfall development.

3.25 The NPPF directs Local Planning Authorities to “boost significantly” the supply of housing and to plan positively at paragraph 47 and 157 respectively. The Council’s choice to only allocate/identify sufficient land to just meet their identified target does not adhere to the main thrust of the NPPF and the Government’s initiative of ‘Planning for Growth’.

3.26 As a result our clients consider that the Council need to allocate additional sites in order to achieve ‘at least’ 10,185 dwellings – if they conclude that this is not necessary then the plan will not achieve the level of development envisaged and consequently the plan will not be deliverable, and therefore fail the Framework’s tests of soundness set out at Paragraph 182. Further, our clients argue that the Council should not expect additional development to come forward from windfalls, given the significant proportion of such supply already identified. The Council therefore need to allocate sites at sustainable settlements (such as Hartley Wintney).

Strategic Allocations/ New Settlements 3.27 In addition, from experience across the country, it is apparent that often Local Plan allocations do not necessarily deliver the level of housing or rate of delivery that was originally anticipated when allocated. This is an issue often exacerbated when an authority is heavily reliant on the delivery of housing through large strategic site(s), where the rate of delivery often slows due to the complexity of providing the necessary infrastructure and the impact of the prevailing market conditions at that time.

3.28 In this regard our clients have concerns that a significant proportion of housing supply is to be met through the provision of 1,800 units at Murrell Green and 1,500 units at Hartland Village during the plan period. It is considered that the plan places an over reliance on two large scale sites.

3.29 This position is even more precarious when consideration is given to the fact that the two sites together total 71% of the total remaining housing requirement to be identified (i.e. not already permitted or built out) during the identified plan period (4,591 dwellings). Further, the sites also represent 32.4% of the total housing requirement for the District.

Any failure of these sites to deliver housing at the rate expected, or if they fail to be delivered at all would put the Council’s housing land supply position and the achievement of the policy requirements of the emerging Local Plan in general at significant risk.

3.30 We would bring to the Council’s attention the Nathaniel Lichfield and Partners (NLP) Report titled “Start to Finish: How quickly do Large-scale Housing Sites Deliver” dated November 2016. A copy of this can be provided if necessary.

3.31 The report highlights (page 8) that the period from planning approval to first housing delivery increases with larger sites, with the total period being in the order of 5.3 – 6.9 years from submission of planning application to first delivery.

3.32 On the basis that a planning application for Murrell Green is yet to be submitted (and there are significant technical constraints to be overcome) and that the application for Hartland Village was only validated on 10th March 2017 (Ref No: 17/00471/OUT) and with consideration to the findings of the NLP report, it is unlikely that any development will be achieved on these sites until summer 2022 to early 2024. This does not tally with the Council’s own aspiration to see the sites deliver by 2021.

3.33 In addition, this would leave between 8-10 years to deliver the housing requirement for the sites over the plan period at a quantum of circa 150 – 187.5 (respectively) units per annum. In this regard the NLP report is clear at Figure 7 that the average annual build out rate for a site of between 1,500 – 1,999 dwellings is circa 130 dwellings per annum.

3.34 As such, and without consideration to technical feasibility of the sites which is considered below, there is a clear risk that these sites will not deliver the provision as identified within this current Plan Period.

3.35 If the Council is to proceed on a strategy which requires the delivery of these two sites then it is critical to the soundness of the plan that the Council ensures a sufficient range of sites in sustainable locations are allocated through a dispersed approach to ensure the delivery of short term housing needs until the strategic plan allocations start to deliver.

3.36 Our clients therefore consider that the Council need to allocate additional greenfield sites in sustainable locations, including Tier 3 settlements, such as Hartley Wintney, to ensure there is flexibility in the supply should these sites not deliver as forecasted and ensure that the provisions of paragraph 47 of the Framework to boost significant the supply of housing is achieved.

Summary - Policy SS1 3.37 For the reasons set out above our clients consider that Policy SS1 is unsound. Our clients contend that the plan does not meet any of the tests of soundness set out at paragraph 182 of the Framework in respect to the spatial strategy:

 Positively prepared – whilst it is acknowledged that the Council seeks to meet its Full Objectively Assessed Housing Need, it is not considered that it has done this in a manner which is sustainable, on the basis that it has not allocated any proportion of growth to Hartley Wintney and supports a dispersal

strategy which sees significant levels of development in unsustainable settlements, effectively leap frogging the more sustainable and suitable locations. In addition, the Council need to allocate additional land to ensure that they deliver at least 10,185 dwellings, especially as the Plan has sought to rely on two strategic allocations with no certainty on the exact quantum of delivery they can achieve over the plan period;

 Justified – the plan has not been based on the most appropriate strategy or on its own evidence base, specifically in regard to the disregard to Hartley Wintney as a suitable site to facilitate additional development;

 Effective – We do not consider that the spatial strategy is deliverable over the Plan period on the basis that it relies too heavily on two large strategic allocations, without providing the necessary flexibility through Tier 2 and 3 settlements to deliver in the short term.

 Consistent with national policy – we set out above the various paragraphs where the Spatial Strategy is not in accordance with the Framework.

Managing Growth – Paragraph 137

3.38 We support the Councils statement that “Development of all kinds needs to be managed and directed to the most sustainable locations in the District in line with the Spatial Strategy”.

3.39 However, for the reasons set out above, our clients do not consider that the Council are meeting this objective especially when consideration is given to the fact that the Council have sought to allocate land within Tier 4 and 5 settlements and have completely disregarded the feasibility of any land at Hartley Wintney, a more sustainable settlement.

Strategic Sites - Policy MG3: Housing-led

3.40 Policy MG3 identifies the allocation of strategic sites at:

a) Hartland Village (see Policy SC1);

b) Murrell Green (see Policy SC2);

c) Cross Farm (see Policy SC3); and

d) Sun Park (see Policy SC4)

3.41 Detailed consideration is given to the feasibility of these sites under the respective policies below.

Policy SC1: Hartland Village 3.42 The Policy supports the redevelopment of a large, previously developed site between Fleet and Farnborough of 54ha for 1,500 dwellings.

3.43 Our client’s first concern with the allocation of this land is that it is situated within the strategic gap between Fleet and Farnborough at its narrowest point (i.e. between the M3 motorway to the north and the Basingstoke Canal to the south). This Gap remains a key issue in the context of redeveloping the site for a new community. This part of the Strategic Gap has been carried forward into the draft Local Plan in which the saved Gaps have been redrawn to be much more focussed into the areas where they are really deemed necessary. As such there is considered to be a clear inconsistency in the Plan in that it both identifies land for safeguarding as a local gap but then erodes such gap through the allocation of land for residential development. As a result the allocation of this land for the proposed development is unjustified and unsound.

3.44 In addition, and as highlighted above, our clients have significant concerns that the site will be unable to deliver 1,500 new homes as currently proposed over the plan period.

Policy SC2: Murrell Green 3.45 The Policy supports an area of farmland to the south of the A30 between Pheonix Green and Hook, to become a new settlement of around 1,800 new homes by 2032.

3.46 We see from the proposed schematic that the proposed development is focused on the eastern half of the site, with the site constrained to the west by land within the Flood Zone, also the high voltage pylons that dissect the site from north to south.

3.47 Our clients have significant concerns that the concept schematic has not given due regard to Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067 Gaston Wood/Murrell Green (PO65) which dissects the proposed land uses for built development from north to south. We have appended a copy of the HSE Plan to this submission (Appendix 3).

3.48 The pipeline in the vicinity of the proposed allocation is a Major Accident Hazard Pipeline as per the Pipelines Safety Regulations 1996. As a result it is not clear whether detailed consideration has been given to the HSE guidance document L82: A Guide to the Pipelines Safety Regulations 1996, (http://www.hse.gov.uk/pubns/books/l82.htm), in particular the guidance on safety regulations 15 and 16 and the emergency plan under Regulation 25.

3.49 In particular, the guidance requires local authorities at county or equivalent level, once notified of a pipeline by HSE, under regulation 25 to prepare an emergency plan for each major accident hazard pipeline passing through their area. The requirement under these Regulations is for emergency plans which should specifically relate to the protection of the health and safety of people, not environmental damage. We can find no reference to this piece of evidence being prepared. Given that the proposed pipeline runs directly through the centre of a proposed allocation this document is a key piece of evidence which would be required to support the justification for the allocation.

3.50 We also have concerns that Policy SC2, its supporting text and the Sustainability Appraisal does not have any regard or indeed mention the presence pipeline. Further, a review of the Detailed Site Assessment completed by the Council makes no reference to the pipeline under the utilities section. This is a key oversight which is fundamental to the actual delivery of the site in accordance with the proposed numbers. Our clients

have significant concerns that the site will be unable to deliver 1,800 new homes as currently proposed.

3.51 In addition, the M3 and a railway line run to the south of the site. As a result the proximity of such strategic infrastructure will be a source of noise, air and possibly light pollution. It is clear that consideration will need to be given to the design and layout of any development on this site before any quantum can be established; especially should a significant buffer be required to protect the amenity of future residents of the site. We would request that this evidence is completed to allow a robust capacity assessment to be undertaken.

3.52 We would also note that the Council’s own site assessments indicates the following constraints to building on the site:

 Accessibility to services is one of the key issues, with relatively poor access to a number of facilities particularly primary education and healthcare facilities;

 Although not identified as a Strategic or Local Gap the existing rural use of the site provides a buffer between the settlements of Hook and Hartley Wintney. This will be lost if the site is developed. However, our client’s would raise that Murrell Green to Hartley Wintney is identified as an local gap in emerging Policy MG6; and

 There are three SINCʼs within the site and one further SINC adjoining its western boundary. As such there are clear ecological concerns with building on the site.

3.53 In addition, the site consists predominantly of open fields with some areas of woodland, which are concentrated in the eastern part of the site; it is therefore a prominent site within is uncontained. Further due to the topography of the area views of the site from Bassetʼs Mead Country Park, which is located to the west. Development of this site will cause a loss of the rural landscape that separates Hook and Hartley Wintney and is likely to cause visual intrusion to the area.

3.54 In summary we consider that the scale of proposed development is overly optimistic and as a result will have clear ramifications for the delivery of Policy SS1 (Spatial Strategy). It its present state we consider this Policy unjustified and unsound.

Policy SC3: Land at Cross Farm 3.55 The Policy supports the principles of land to the south Crookham Village to come forward as a new care village for older person’s accommodation.

3.56 We are also aware that a hybrid application for the construction of a 160 unit care village incorporating a 64-bed care homes (Use Class C2) and central facilities building (Ref No: 16/03400/OUT) has been lodged to Hart District Council and is currently under determination.

3.57 We note that there has been a considerable level of public opposition to the application, with some 316 objections to the proposals. In this regard we would highlight paragraph 155 of the NPPF which highlights that “A wide section of the community should be

proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area…”. Clearly the level of public opposition which has been received against the proposals does not support the allocation of this land when considered against the requirement of the Framework.

3.58 Local Gap

3.59 The site is Greenfield land and located within the designated Fleet/Church Crookham – Crookham Village Local Gap.

3.60 This is at odds with emerging Local Plan Policy MG6 (Gaps between Settlements) which identifies land between Fleet/Church Crookham to Crookham Village as a gap and notes that development will only be supported where it would not diminish the physical and visual separation of settlements. As such there is considered to be a clear inconsistency in the Plan in that it both identifies land for safeguarding as a local gap but then erodes such gap through the allocation land for residential development. As a result the allocation of this land for the proposed development is unjustified and unsound.

3.61 Mineral Safeguarding Area

3.62 Our clients are also aware that the proposed allocation site lies within an area defined for mineral safeguarding, which indicates where viable, safeguarded minerals are likely to be present. The purpose of Mineral Safeguarding is supported by Policy 15 of the Hampshire Minerals and Waste Plan, the National Planning Policy Framework (paras 143 & 144) and National Planning Policy Guidance (para 003).

3.63 In order to meet the requirements of the Hampshire Minerals Plan, there is an expectation that LPA’s will not normally permit other types of development (non- minerals) within the MWCA in order to avoid needless sterilisation of the mineral resources, unless the safeguarding issue has been appropriately addressed.

3.64 The prior extraction of minerals can be planned so as to fit in to a development’s timescales and contribute to the overall sustainability of the development through the use of locally sourced materials and reducing the quantities of waste that need to be exported. However any conclusion that prior extraction is incompatible with the proposed development need’s to be evidenced.

3.65 A review of application WA/2015/2283 (currently pending consideration) does not provide any evidence that this has been considered in the formation of the application.

3.66 To establish the viability of prior extraction and its potential extent, further exploratory work would be required to be undertaken on site and submitted to the MPA in the form of a minerals safeguarding report or assessment.

3.67 Until such a time that this is provided it is contended that the site is not deliverable and should be removed from the Plan. In any case and unless the mineral deposit can be proved unworkable/ unviable we question the current trajectory of delivery in the first five years of the plan period.

3.68 In summary we consider that the allocation of land at Cross Farm is unjustified and thereby unsound, we respectfully therefore request it is removed from the Local Plan as a proposed allocation.

Policy SC5: Land allocations for New Homes

3.69 Policy SC5 identifies the allocation of a series of non-strategic sites.

3.70 Detailed consideration is given to the feasibility of these sites under the respective policies below.

Eversley – Cemex A and B (SHL112) 3.71 Land at Eversley, known as Cemex A and B is proposed for allocation for the erection of 124 units. We understand the proposals consist of two areas of development for housing with the remaining area to be used for public amenity space and SANG mitigation land. Our client notes that to the north of the site are the existing dwellings fronting onto the Reading Road. To the northwest is the Eversley recreation ground and park. To the west, is the Kingsley Road residential area of Eversley Centre with an agricultural field further south. To the south of the site is the wooded Lower Eversley Copse SINC and further open agricultural land. To the east are the residential areas served by Hollybush Lane.

3.72 Our clients have concerns regarding the sustainability of the site for development, as well as the suitability of Eversley to accommodate this scale of growth. Eversley is identified as a Tier 4 settlement and as such is not considered to have the provision of services or infrastructure to support the propensity for this scale of development. Indeed the High Level Site Assessment Proforma, completed in April 2015, indicates that “accessibility to some services and facilities is poor and there are infrastructure deficiencies that would be exacerbated.”

3.73 We would also bring to the Council’s attention its own Local Plan Site Assessment: Stage 4 – Detailed Site Assessment proformas which indicate that the:

“Overall the site relatively performs poorly against the sustainability objectives with the potential development of the site affecting 11 of the 21 objectives negatively and 3 affected positively. There are five objectives against which development could have a moderate negative effect: SA6 (settlement coalescence and character); SA9 (countryside and landscape); SA17 (Access to services); SA18 (efficiency of transport networks) and SA19 (access to education). In addition, the site’s impact on biodiversity, water and soil quality, on flood risk and on carbon emissions are considered to be key sustainability issues against which a negative performance is anticipated.”

3.74 The NPPF requires at paragraph 152 that local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. As identified by the Council’s own Site Assessment the proposals will negatively impact on over half of the 21 objectives. Our client therefore considers that the allocation of land at Eversley is unsound and unjustified and request that the land is removed as an allocation. Its

allocation will undermine the function of the settlement hierarchy which seeks to steer growth to the most sustainable settlements in the Borough.

3.75 Further, we are aware that the Hampshire Minerals and Waste Plan Policies Map indicates that the whole of this site may be subject to minerals safeguarding for sharp sand and gravel. As Cove outline above under Policy SC3 until such a time that a minerals safeguarding report or assessment is provided it is contended that the site is not deliverable and should be removed from the Plan. In any case and unless the mineral deposit can be proved unworkable/ unviable we question the current trajectory of delivery in the first five years of the plan period.

3.76 The sites are also located adjacent to a large area of woodland, known as the Lower Eversley Copse, which is also a SINC. As a result there are clear ecological considerations which will restrict the scale of development which can be achieved on the site.

Yateley – Land between Eversley Road and Firgrove Road 3.77 Land at Eversley Road and Firgrove Road is allocated for some 88 units in the emerging Plan. However our client has significant concerns over the location of the site.

3.78 The whole site is within the designated Local Gap between Yateley and Eversley Cross, and as a result development of the site will significantly reduce and undermine the remaining gap and contribute to settlement coalescence. This is at odds with emerging Local Plan Policy MG6 (Gaps between Settlements) which identifies land between Eversley to Yateley as a gap and notes that development will only be supported where it would not diminish the physical and visual separation of settlements. As such there is considered to be a clear inconsistency in the Plan in that it both identifies land for safeguarding as a local gap but then erodes such gap through the allocation land for residential development. As a result the allocation of this land for residential development is unjustified and unsound.

3.79 We would also bring to attention the conclusions of the Inspector who dismissed the planning appeal for application 14/02072/OUT relating to the land off Crosby Gardens to the north of Eversley Road (SHLAA Ref: SHL103). That appeal was dismissed primarily on the basis of likely harm to the functioning of the Local Gap. We would urge that the Council acknowledge this position and remove the site as a proposed allocation from the emerging Plan.

Odiham 3.80 We note that, in the case of Odiham, the emerging Neighbourhood Plan has sought to allocate land to the sum of 119 new homes. We understand that the Neighbourhood Plan was subject to a referendum on 4th May 2017, where the Plan received a majority vote in favour. As a result the Plan is to go before full Council in June 2017 for ratification and for it to become part of the Development Plan.

3.81 As a result, our clients do not make any specific comments given the status of the emerging Neighbourhood Plan, other than to highlight the clear inconsistency in approach the Plan is taking between Odiham and Hartley Wintney. Odiham is classed by the Council’s own evidence base as a Tier 3 settlement, the same as Hartley Wintney, as a result there is a clear contradiction in the approach the Council is taking

between the two settlements. We would urge that Hartley Wintney also sees a proportionate level of growth relative to its status in the hierarchy.

South Warnborough – Plough Meadow & Granary Court 3.82 Policy SC5 seeks to allocate a total of 34 houses (18 units at Plough Meadow and 16 units at Granary Court) adjoining the settlement of South Warnborough.

3.83 South Wanborough is identified within the Background Paper ‘A Settlement Hierarchy for Hart District’ as a Tier 4 settlement. It only meets 3 of the categories used to rank settlements in the hierarchy and as a result is an unsustainable location for the allocation of development. This position is clear in the High Level Site Assessment’s completed by Adams Hendry Consulting Ltd, which indicates that the site at Plough Meadow has the following accessibility to employment and services:

 Bus Stop – (Monks Corner Cross Roads, service 13) 0.37km  Railway Station - (Hook) 7.77km  Employment Centre – (RAF Odiham) 3.43km  Public Open Space – (South Warnborough Recreation Ground) 0.68 km  Health Facility – (Odiham Health Centre) 4.39km  Primary School – (Long Sutton Primary School) 3.1km  Secondary School – (Robert Mayʼs School, Odiham) 4.07km  Supermarket – (Tesco, Hook) 7.45km

3.84 We would also note that the Site Assessment clearly notes that South Warnborough “is in a remote area of Hart with very few retail outlets nearby. Therefore, it is likely that consumers would travel out of the district to Basingstoke where there is a far greater choice of comparative stores”.

3.85 In respect to land at Plough Meadow, we would note that the site is inaccessible to most services and facilities and will as a result encourage car dependency, the site is within the Conservation Area and is therefore likely to impact on important views, development will cause visual intrusion to the west, southwest and northwest and development will cause harm to the rural character of South Warnborough, and in particular the northern entrance to the village.

3.86 Our client therefore has significant concerns that the Council have sought to allocate land at South Warnborough and that any development within this locality and of this scale should come forward via windfall rather than as a Local Plan allocation.

Crondall 3.87 We note that the Plan identifies a total of 66 houses to be allocated to the settlement of Crondall through the Neighbourhood Plan process. A review of the Crondall Neighbourhood Plan website does not provide a clear indication of the timescale for adoption of the Neighbourhood Plan. Nor is there any published draft Plan at present, the Neighbourhood Plan is therefore in the infancy of preparation.

3.88 Whilst the intention of the Neighbourhood Development Plans delivering a proportion of the Council’s housing supply is plausible, our clients remain concerned how reliable this strategy will be and what would happen if NDP’s are not delivered.

3.89 Crondall itself is a Tier 4 settlement and therefore does not have the necessary services, facilities and infrastructure to sustain significant growth.

3.90 We would urge the Council to reconsider its position in respect to development in Crondall and reallocate such development to settlements such as Hartley Wintney.

Riseley – Land South of Riseley 3.91 Table 6 of the emerging Plan identifies a total of 83 units to be apportioned to the settlement of Riseley.

3.92 Our clients have significant concerns that this level of housing is identified for Riseley, not least because the settlement is actually located within Wokingham Borough and therefore the additional housing provision will naturally support Wokingham Borough Council meet their housing need rather than Hart District Council.

3.93 Riseley is not assessed in Hart’s evidence on settlement hierarchy, but it is highly unlikely that it would be equivalent to a main village.

3.94 This position is supported by the Council own High Level Site Assessment which indicates the distance the site is from key services, namely:

 Railway Station – (Mortimer) 6.75km

 Health Facility – (Swallowfield Medical Practise) 2.73km

 Primary School – (Lambs Lane Primary School) 3.69km

 Secondary School – (Oakbank School) 6.75km

 Supermarket – (Lidl, Reading) 7.71km

3.95 As such it is considered that the apportionment of 83 dwellings to Riseley is incongruous with the overall settlement size, its sustainability relative to the hierarchy of settlements and would result in an unnatural extension to the settlement to the south, with the settlement size increasing by some 33% as a result of the proposed growth.

3.96 In addition, we would also note that the Detailed Site Assessments undertaken to support the proposals allocation outlines that the “indicative residential capacity of the site is considered to be 69 dwellings, at an assumed density of 30 per hectare.”

3.97 We do not consider that the Plan in this regard conforms to the requirements of paragraph 182 of the Framework; and is not justified, effective or consistent with national policy.

Policy MG6: Gaps between Settlements

3.98 We have no specific comments to make on this Policy, other than to highlight that in a number of instances, as identified above, there is a clear conflict between sites proposed for allocation and those areas to be safeguarded as a local gap.

3.99 We therefore suggest that the sites identified for allocation in the emerging Plan which are also situated in a gap as identified in Policy MG6 are removed from the Plan.

4. Land at Grange Farm, Hartley Wintney

Context

4.1 Cove is promoting land at Grange Farm, located to the south-west of Hartley Wintney, to the west of Grange Lane and between West Green Road and Thackhams Lane for a residential development of up to 125 -175 dwellings, with on-site Suitable Alternative Natural Greenspace (SANG) and other open spaces.

4.2 To the north of the site is West Green Road, beyond which is the built development of Hartley Wintney to the north-east. The eastern boundary of the site is formed predominantly by Grange Lane. Beyond this is the A30 and residential development. The site is currently in agricultural use (low grade, Grade 3), horticultural and equestrian use. It is a 20.3ha land parcel and topographically is relatively flat.

4.3 The location of the site is identified on the plan at Appendix 1.

4.4 The site is not currently the subject of any planning applications, however it was considered by Hart District Council in the preparation of the Local Plan under reference SHL019 (SHLAA Report November 2016) with the site being found to be: suitable; available and achievable.

4.5 Furthermore, in the Refined Options for Delivering New Homes, published for consultation in March 2016, highlighted the site as a shortlisted option for housing, with a proposed capacity of 190 dwellings.

4.6 As indicated above in Section 3 there is no explanation as to why Grange Farm has been discounted, having been identified as a shortlisted option in 2016. Our client maintains that it represents a sustainable site to support Hart District Council in delivering its housing requirement in a sustainable location given Harley Wintney’s position in the settlement hierarchy.

4.7 Cove has prepared a Vision Document, provided at Appendix 2, which provides an indication on how the site can come forward. Our client would welcome the opportunity to discuss this, and any other options, with the Council to provide further refinement over the deliverability of the scheme.

SHLAA Site Assessment SHL019 - 2016

4.8 The site was considered in the Council’s Strategic Housing Land Availability Assessment (2016) under site reference SHL019.

4.9 The SHLAA recorded the site size as 32ha in total, with circa 2.2ha being promoted for housing, to a total of circa. 65 dwellings (it is acknowledged that the Refined Options for Delivering New Homes considered 190 dwellings).

4.10 The SHLAA analysis of the site identified that:

 The site is within Flood Zone 1, however the site is at risk of groundwater flooding;

 The site is located within 5km Special Protection Area zone of influence and therefore mitigation measures will be required;

 There are no Scheduled Ancient Monuments, Historic Parks and Gardens, Sites of Special Scientific Interest, National Nature Reserves, Local Nature Reserves, ancient woodland or Public Rights of Way in the vicinity of the site or close enough to be affected by development of the site;

 Parts of the site (to the East) are covered by the Hartley Wintney Conservation Area and the western boundary of the site adjoins the West Green conservation area. There are a number of listed buildings located in close proximity to the site; and

 The eastern boundary of the site adjoins a SINC and the western boundary of the site is located approximately 200m away from a SINC.

4.11 Whilst the above constraints are noted, it is considered that they can be adequately addressed through a robust planning submission. Further the proposed provision of on- site SANG alleviates concerns surrounding impact on the SPA, as well as the site adjoining the SINC to the east of the site (as the SANG will be on the eastern proportion of the site). The proposals can be sensitively designed in order to address any heritage impacts and ensure the proposals are not detrimental to the surrounding townscape or setting.

4.12 The SHLAA states that the site is supported by a willing landowner and concludes that the site is suitable, available and achievable, with potential for housing in the short-term (0-5 years).

The Opportunity

Suitability of Location

4.13 Cove considers that land at Grange Farm represents an opportunity to deliver a sustainable and inclusive community at a settlement which is acknowledged as a sustainable location in existing and emerging planning policies.

4.14 In the emerging Local Plan, Hartley Wintney is identified as a Tier 3 settlement (Secondary Local Service Centres) and is therefore recognised as one of the most sustainable locations in the District.

4.15 Hartley Wintney is a large village and a range of local services and facilities, including local shops (One Stop Community Stores Ltd, Phoenix Green Service Station, Organically Speaking, and other uses such as inter alia; estates agents, florists and wine merchants), public houses (Waggon Horses, The Cricketers, and The Phoenix Inn) primary schools (Oakwood Infants School, Greenfields Junior School and Grey House School), doctor’s surgery (Hartley Wintney Surgery), dental surgery (Quaintways Cottage Dental Surgery), chemist (Llyods Pharmacy), library (Hartley

Wintney Car Park – every Monday), bank (Natwest and Lloyds TSB), and a range of local restaurants/ cafes (Baristas Coffee House and Bistro, The Courtyard Cafe and Costa Coffee). As also shown on the services plan provided within the Vision Document at Appendix 2.

4.16 The village is well served by Public Transport with the nearest bus station located off London Road immediately north of Southern Haye, which provides the following services:

 Hartley Wintney to Winchfield Station (1 – Hartley Wintney Community Bus) (every 30minutes from 07:06 – 08:06 and 18:03 – 19:33);

 Camberley – Hartley Wintney – Hook (2 – Hartley Wintney Community Bus) (every two hours);

 Hartley Wintney – Camberley (3 – Hartley Wintney Community Bus) (2 x daily);

 Odiham – Yateley – Farnborough (408 – Stagecoach) (1 x daily); and

 Hook – Alton (65X – Stagecoach) (2 x daily).

4.17 In addition, we are aware that Fleet Buzz operate a regular service between Reading and Aldershot (no72), with this service provided in Hartley Wintney Centre.

4.18 Further Hartley Wintney is served by Winchfield Station (circa 1.2miles from the Grange Lane site access). The station provides regular services to Waterloo and southbound to Portsmouth, via Basingstoke.

4.19 In summary, and as shown above and by the Council’s own evidence base, Hartley Wintney is one of the most sustainable settlements in the District and should see growth proportionate to its role within the hierarchy.

4.20 The site provides the opportunity to make the fullest possible use of public transport, cycling and walking, and offer a focus for development in a location which is sustainable. We consider that the site accords with the principles set out at paragraphs 17 (bullet point 11) and 47 of the National Planning Policy Framework.

4.21 As such we consider the merits of the site below, in light of paragraph 159 of the NPPF, which underlines that local planning authorities should establish realistic assumptions about the availability, suitability and the likely economic viability of land across the District.

Site Access

4.22 The site is capable of being accessed and egressed from Grange Lane and West Green Road.

Environmental Considerations

4.23 The Environment Agency’s online flood risk mapping service indicates that the site is within Flood Zone 1. However it is acknowledged that the site is at risk from ground

water flooding and as a result any proposals would be supported by a detailed flood risk assessment and drainage strategy to ensure that mitigation measures are in place to alleviate any concerns in this regard.

4.24 It is acknowledged that the site is located within 5km of the Thames Basins Heath Special Protection Area and in line with the requirement of Policy NRM6 of the South East Plan and the need to protect the Thames Basin Heaths SPAs from the impacts of additional development and particularly an increased population.

4.25 Development within the 5km zone is acceptable subject to appropriate mitigation. The proposals include the provision of a bespoke Suitable Alternative Natural Greenspace, which will mitigate the impact of the increased population on the Thames Basin Heaths SPA. It will be developed in liaison with Natural England and ensure that the route and management meet their requirements.

4.26 Parts of the site (to the East) are covered by the Hartley Wintney Conservation Area and there are a number of listed buildings located in close proximity to the site, specifically Hartley Grange (Grade II). As a result the proposals would need to give due regard to their setting; however it is considered that a sympathetic design can come forward which respond to the setting of the assets.

4.27 Beyond the above constraints, there are no Scheduled Ancient Monuments, Historic Parks and Gardens, Sites of Special Scientific Interest, National Nature Reserves, Local Nature Reserves, ancient woodland or Public Rights of Way in the vicinity of the site or close enough to be affected by development of the site. It does not lie within an Air Quality Management Area or minerals safeguarding area. The site does not form part of a strategic or local gap, and provides strong defensible boundaries.

4.28 The provision of suitable SANG on the eastern portion of the site, will ease the transition from urban form to the countryside and will provide a natural stop to the settlement boundary of Hartley Wintney to the east.

Available

4.29 The Site is available now with Cove keen to promote the land through the development plan process and to agree with the Council a programme for bringing the land forward for development within the Plan period.

Achievable

4.30 A residential led scheme at the Site is capable of being achieved within the Plan period. It is our view that the Site can be delivered within the first five years of the Plan period, with the scale of growth can be phased to deliver across the short to medium term.

Next Steps

4.31 Grange Farm offers an ‘unconstrained’ area of land centrally located within the confines of the wider village which is also discreetly situated but with excellent links and access to village facilities and the primary road network. Development here could make a significant contribution towards meeting the village’s future housing needs (including

affordable homes) which can be supported by community infrastructure and the opening up of access to the countryside through the provision of SANG land.

4.32 Cove considers that the Council should allocate sites at Hartley Wintney to ensure compliance with the provisions of the Framework and give credence to its location within the settlement hierarchy.

4.33 We would welcome an opportunity to discuss how land at Grange Farm can support the Council in meeting this objective.

Appendix 1: Site Location Plan

Appendix 2: Vision Document

VISION DOCUMENT

Site boundary Sch Primary school Sports field LAND USE Predominantly residential Sch Infant school Church Open space Education Nursery/ preschool Orchard High street Community buildings PO Post office Allotment GP GP surgery Restaurant

Pub National Trust house

June 2017 GRANGE FARM | 1 VISION DOCUMENT

Site boundary Bus service 7 (Riseley to Reading) CONNECTIVITY A Road Bus services 1 (Winchfield to Hartley Wintney) B Road Bus service 2 (Camberley to Hook) Road generally wider than 4m Bus service 408 (Odiham to Farnborough) Road general narrower than 4m Public right of way Bus stop

June 2017 GRANGE FARM | 2 VISION DOCUMENT

Site boundary Public right of way Woodlands, copses and tree belts Contour lines CONSIDERATIONS Flood zone 3 SSSI Elvetham Hall Pipeline Zones Conservation area Inner zone Public right of way Middle zone Listed building Outer zone

June 2017 GRANGE FARM | 3 VISION DOCUMENT

Site boundary Sports pitch FRAMEWORK Development parcel Allotments SANG or development Parking Open space Footpath Street

0m 100m

June 2017 GRANGE FARM | 4

Appendix 3: Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067

Cove Construction Ltd 1 Alpha Centre, North Lane, Aldershot, Hampshire GU12 4RG Aldershot Hampshire GU12 4RG

Advice : HSL-170511113420-637 Crosses Consultation Zone

Please enter further details about the proposed development by continuing with the enquiry on the HSE's Planning Advice Web App from the Previous Enquiries tab either now or at a later time, unless the Web App has stopped the process and notified you to contact HSE. Your Ref: Murrell Green Development Name: Murrell Green Local Authority Reference: Hart

Comments:

Commercial In Confidence The proposed development site which you have identified currently lies within the consultation distance (CD) of at least one major hazard site and/or major accident hazard pipeline; HSE needs to be consulted on any developments on this site. This advice report has been generated using information supplied by Kevin Miller at Cove Construction Ltd on 11 May 2017. You will also need to contact the pipeline operator as they may have additional constraints on development near their pipeline.

HSL-170511113420-637 Date enquiry processed :11 May 2017 (474967,154836) 7067_1338 Southern Gas Networks 7068_1339 Southern Gas Networks HSL/HSE accepts no liability for the accuracy of the pipeline routing data received from a 3rd party. HSE/HSL also accepts no liability if you do not consult with the pipeline operator. You may wish to contact HSE's Planning Advice team to discuss the above enquiry result on 01298 218159 or by email at [email protected].

HSL-170511113420-637 Date enquiry processed :11 May 2017 (474967,154836)