Crondall Parish Council PO Box 623 Surrey GU9 1HB

Contact: Mary Harris Telephone: 07510 917232 e-mail: clerk@-pc.gov.uk Reference: CRON-LT-LDF-0004

Date: 23rd February 2016

Mr Daryl Phillips Chief Executive Officer Council

By Email

Dear Mr Phillips

RE: Re-Issued Hart Housing Options Consultation Response

Crondall Parish Council submits the attached Consultation Response Questionnaire as part of our formal response to your re-issued consultation on housing options and as part of the development of the new Hart District Local Plan. The clear feeling of the Parish Council was that the questionnaire still did not provide sufficient flexibility to allow the nuanced response such a complex matter requires; hence this letter (and its annexes) provide additional details, suggestions and reasoning.

Given the complex and critical nature of this consultation, a village meeting was arranged to discuss the issues. The meeting was attended by around 200 parishioners – by far the best attended meeting in local memory. A suggested response was outlined and broadly endorsed by the attendees who were also very much encouraged to make their own personal responses to the consultation.

The details are contained in Annex A (Hart Response Form) and Annex B (Crondall Parish Expanded Points).

In summary:-  The new settlement (Option 3) is generally supported as the only option that comes with unique opportunities (see Section 4 of Annex B) but only to the extent that better use of brownfield sites (and a possible reduction in overall housing growth: see Section 7.2 of Annex B) cannot achieve what is required.  We would encourage a much more pragmatic approach to all brownfield sites, but in particular Police College and Manor. Similar ‘Listed Building’ sites in sensitive areas have been developed at many other locations across the UK and we

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encourage Hart to find ways to assist developers to re-use these sites as well. The Stonegate report provides a large number of properties that can also be considered (see Annex B, section 7.3).  The Parish Council is of the view that the consultation process does not give respondents a true choice but appears rather focussed on a single outcome. The highly constrained nature of the questionnaire1 (and especially the on-line version) substantially limits the range of answers, so much so that the questionnaire is essentially invalid as posed, so free-form answers are required. Many residents have raised concerns about this limitation and it has been the subject of considerable concerned debate amongst Parish Councils and councillors. o Option 1 shows “zero” development values for many suitable sites, including: Bramshill, Mattingly and , while only 30 dwellings are attributed to Fleet. This is not a sustainable or practical option. o With no specific values for development in rural parishes under Options 2 & 3, the “choice” cannot be seen as informed or fair. o We remain unclear as to how the responses submitted will be processed and given the various late changes in wording and reported errors, we can retain confidence in the process.  Crondall Parish Council is deeply disappointed in the appearance of 2 unacceptable SHLAA sites under Option 1. These were not discussed with the Parish Council as might be expected under a more constructive approach. The allocation of large development targets to individual parishes without prior discussion is simply unacceptable. o Much of Option 1 is contrary to the stated “Key Issues” and “Vision”. This is explored further in section 7.8.  In the Parish of Crondall, SHLAA 73 & 74 are firmly rejected:-. o The scale of the proposed development is completely unacceptable in terms of impact (~50% increase in housing). This would wholly and negatively alter the character of the village and have a strongly negative impact on the important Conservation Area. o The visual impact of ribbon development, particularly of SHLAA 74 would expand the village way beyond its traditional boundaries and limits. On a practical level development of these sites is unsustainable in terms of access, traffic impact on small local roads, sewage, schools and very limited local employment. o Both sites suffer from poor ground water conditions and development would exacerbate existing surface water issues, especially for residents in Greensprings and Ashley Close o SHLAA 74 has high existing amenity value to the Scout Association as a County camping facility and is regularly used by local Scouts.  The assessments of SHLAA 73 & 74 are materially inaccurate in respect of over 14 high- level indicators discussed in the Sustainability Appraisals including transport, flooding,

1 The later variation of the constraints is noted, but this was poorly communicated long after many residents had submitted their responses.

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employment, health, schools, infrastructure and access. These are described in detail in section 6.2 of Annex B.  The use of SHLAA 73 & 74 on the scale described would be contrary to The Key Issues, vision and priorities and thus render the Local Development Plan internally inconsistent.  The Parish Council proposes a better plan for Crondall with a more modest arrangement of sites totalling up to 50 units, if Option 1 was eventually required. This includes a new SHLAA site that has come forward during this process. This possibility is based on a ‘fair share’ of development as outlined in section 7.1 (Annex B).  The Parish Council also proposes a number of Strategic Gaps to be included in the Local Development Plan to help to protect the character of the countryside and rural parishes.

Crondall Parish Council acknowledges its responsibility to share a reasonable part of the development pressure across the District and asserts its right on behalf of its residents to manage the distribution of those dwellings across the Parish. The location of specific developments at both the District and Parish levels needs to be sustainable in respect of both practical infrastructure and character issues. Hart currently has a 6 year land-supply, during which time the Parish Council is willing to work with Hart to allocate local sites to achieve a fair share solution.

Crondall Parish Council recognises that the distribution of development for the New Local Plan is a complex task with multiple trade-offs and compromises. We would welcome an early opportunity to discuss the details with Hart and work towards a mutually acceptable solution once they have digested the overall results of this consultation. This is a fundamental principle of Localism and will help Hart to achieve a Local Development Plan that can be supported by Parishes during the formal inspection stage.

Yours sincerely,

Mary Harris Clerk, Crondall Parish Council As directed by vote (x for, x against) at the meeting of 22nd February 2016, Minute 1??/16

Cc Cllrs Crookes, Gorys, Kennett Ranil Jayawardena MP Mr Daniel Hawes

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Annex A – Hart Response Form

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Annex B – Crondall Parish Council Expanded Points

1 Q1: Needs of Specialist Groups The issue of needs requires clarification. Specialist groups with specific legal status in relation to housing are not defined in the SHMA. Section 102 discusses various ethnic groups, but does not explain how such figures are within or without the overall demands. Some specialist groups (such as ex-service personnel) are identified but we have no definite basis from which to judge any specific need.

2 Q2: Appropriate Sites This is a highly nebulous question, with multiple outcomes. In general the principles in Hart’s “Draft Vision and Strategic Priorities for Hart” (see section 7.8) should be followed to place specialist housing closest to the services its residents need. Several potential brownfield sites are ideally suited to specialist groups e.g. the ageing population and affordable housing due to their better infrastructure links, giving access to work and reduced “cost of living”.

3 Q3: Settlement Hierarchy We believe this should be refined and corrected to reflect 6 years of developments and the concurrent withdrawal of rural services

The settlement hierarchy is a rather broad method to use to categorise development areas. We recommend a review of the current Hierarchy to re-validate the changes over the past 6 years, since it was prepared, with a view to a more objective set of criteria and clearer links to applicable policies, specifically:-  An isochrone approach to transport sustainability based on realistic journey times and journey methods to typical employment, shopping and leisure facilities. Note that many residents now shop “on-line” and avoid the high street  The practicality of living without a car at rural locations (hint: it’s very difficult)  Access to primary and secondary schools as this is another major and unavoidable transport use  Employment by floor space is not a good measure of the number of people used and transport demands. Broadband enabled employment is a more significant factor.

We note that in the Hart Settlement Hierarchy (2010) paper that is referenced in this consultation at Section 3.3 it lists smaller settlements has having: “limited or no services or public transport - they do not constitute sustainable locations for new housing.” Given that Crondall village now has no

2 Hart, Rushmoor and Surrey Heath Strategic Housing Market Assessment, Dec 2014 [SHMA]

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Date: 19 January 2016 public transport and very limited services, it is clearly demonstrated that the village is not a suitable location for ‘sustainable’ development.

The development of over the past years pushes it more into a Tier 2 category. Winchfield should be included as a Tier 4 settlement given that it has a railway station.

4 Q4: Overall Approach Option 3 if absolutely necessary

The ‘new settlement’ at Winchfield (Option 3) is generally supported but subject to the following:-  Opportunities to review and clarify the overall District development targets must be clearly and thoroughly investigated  Options to deliver more housing via additional brownfield sites must be pursued more vigorously and imaginatively  Housing density should be increased where practical (ie. multi-story apartment styles in the more highly urbanised locations).  Any development of Winchfield should minimise land requirement and create a sense of a centre and identity  If Winchfield were to be developed, it should be truly innovative and a leading example of “green” development. Through design it should be possible to minimise the use and provision of cars and increase reliance on cycling, walking and public transport. A new junction onto the motorway should not be supported.  Strategic Urban extensions should be supported. As commented on by County Council, such sites would best enable school expansion, make best use of existing infrastructure and enable the expansion of health, public transport and other facilities  The development of Strategic Urban Extensions and sites such as Winchfield provide the best options to achieve lower overall emissions in development, occupation of dwellings and the business of “living”. This is in support of:- o Key Issues: 9 o Hart’s Draft Vision o Draft Strategic Priorities: 9, 10 & 11

5 Q5: Combined Approaches Strategic choices with local details

The underlying issue with the combined strategies question concerns the detail of the parts that are mixed in each strategy. At the lower levels there are good and bad features of each strategy and hence the definition of a mixed approach is core to its attractiveness.

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Figure 5-1. Summary of views on combined approaches

Our view is based on the following criteria:-  Sustainability  Matched infrastructure developments  Accessibility More work needs to be done on the feasibility and deliverability of Winchfield. So while approach 3 is the preferred approach, if it were not realised approach 4 might also be considered, where the emphasis is on strategic urban extensions, supported by some strictly limited and appropriate dispersal if absolutely necessary.

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6 Q6: Ranked Sites Overly constrained responses to unsustainable options, based on inaccurate assessments, but better options are possible to achieve a fair share

6.1 Summary This question and its framing in terms of the constrained types of response allowed is at the heart of our issues with this consultation. At a moral level, it is unreasonable to expect residents to rank sites at distant locations that have no bearing on their (home) locations. Others have as little knowledge of our sites as we do of theirs.3

Many residents have been confused by the on-line response form and its overly constrained format. In particular, the case that none of the listed sites is preferred is “avoided” by the structure of the on-line form. Crondall robustly rejects the anything remotely approaching the envisaged development of SHLAA 73 & 74 for the following reasons:-  Unsustainable impact on the village  Undesirable location (access, traffic, flooding etc)  Excessive dwellings Our concern is deepened by the material errors in the Sustainability Assessments pertaining to these 2 sites, to the extent that their selection is completely invalid.

However, Crondall Parish Council understands the need to manage the overall development targets and hence is proposing a “fair share” of the overall development target. This is based on a sustainable approach with considerably lower impact on the parish. Existing and new SHLAA sites are examined here with a more detailed proposal in section 7.3.

6.2 Accuracy of SHLAA 73 & 74 Assessments Material errors that invalidate their selection

The published SHLAA statements titled “Local Plan Site Assessment: Stage 2 – High Level Site Assessment – SHLAA 73 – Land West of Crondall Confidential Draft - 1.1 – May 2015” and the equivalent for SHLAA 74 have been carefully reviewed.

There are several issues with the SHLAA assessments for 73 & 74 that invalidate them as assessments, most are common to both assessments, some specific comments are noted as such:-

3 The late revision of the on-line form to avoid respondents having to rank unknown site sis noted, but this was after many residents had tried to complete the form and reverted to the printed and PDF versions.

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 Bus Stop ▼. Although this shown as “red” due to distance, there is no bus service at the stop mentioned. In fact there are no public transport services at all in Crondall, other than. a very limited quasi-private pre-booked taxi-share arrangement.  Employment centre ▼. Any number of small local businesses could be named, to select Redfields is illogical. Redfields is generally fully staffed and there is limited additional employment opportunity except through natural staff “churn”. Distances to real employment possibilities (Farnham, Rushmoor and Fleet centre) are considerably longer. This should be orange or red.  Health Facility ▼. The existing surgery is at or near capacity and has recently taken pre- application planning advice to extend its parking facilities to address long-standing issues of patient access.  Primary School ▼. While local, the school only has a single form (30) pupil entry and is well attended, leaving little or no space for any significant extra pupil numbers. It is understood that the school is over- subscribed for academic year 2016/17. The only option would be to effectively double the size of the school and its internal infrastructure, a massive task that is constrained by the physical limits of the school grounds and access/transport issues that continue to plague drop-off & pick-up times. Development on these sites (~250 houses generating 0.34 primary school pupils per house) would create an additional 75 pupils, i.e. approximately 11 per school year who would need to access other schools, resulting in additional journeys. This should be red.  Secondary School ▼. While Court Moor is closest and shown as red, the opportunity to get into the school from out of its catchment is nil. Parents are rumoured to move into Fleet for a few years simply to access Court Moor. Most Crondall children attend Calthorpe Park.  Infrastructure provision ▼. It is not clear why each sub-criteria has not been colour coded to inform the overall assessment. Based on the detail below and the summary text in this section of the Assessment, this should be “red” overall. o Schools ▼: See note above – “red”. o Retail ▼. The discussion should focus on the complete lack of any major retailer within walking distance. Fleet, Farnham and are the main destinations, with some convenience shopping at QEB and the local BP garage. The village shop (including Post Office) is currently in the process of sale and its future is uncertain, this should be “red”.

4 HCC estimates of pupil place numbers generated by development.

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o Health ▼. The proposed healthcare centre is in Fleet, creating more unsustainable journeys. o Transport (Road): ► An HGV alleviation or prevention scheme has been requested by the village for many years. A request via Hart/HCC was recently rejected. Subsequently there has been damage to listed roadside properties within the village centre. o Transport Other ▼. The assessment fails to note the significant issues with traffic of all sizes passing through Crondall. While many new residents might head north, a reasonable proportion will head south with no practical alternative other than passing through the village. There have been numerous incidents of damage to properties along Street, with the recent destruction of the Grade 2 listed wall (opposite the shop). Crondall's roads are generally too narrow for the volume of traffic that use them, in particular the junction opposite the Village Shop. At certain times of day, the Northern 100m of Dippenhall Street are effectively a single lane road with passing places. At school pick-up / drop off time it is often gridlocked. Crondall is used as a cut through for non-local traffic towards Farnham, the A31 and the south creating an existing high volume of non-local traffic passing through Crondall. o Transport (other) ▼. This notes the removal of the bus service, hence as a single criterion should be “red”. o Green Infrastructure and SANG ▼. If a site cannot provide its own SANG and it’s not clear where suitable SANG could be provided, then surely the assessment is “red”. o Sewage is not discussed ▼. The village has a long history of problems due to hydraulic inundation of its sewers that Thames Water have been unable to solve due to costs. The existing sewage treatment plant would be UNABLE to cope with an extra 250 dwellings as it currently struggles with ~ 5005.  Current Use and Relevant Planning History (SHLAA 74) ►. The site is also used as an amenity space by the adjacent Scouts and regularly hosts large-scale “district” and “county” camps and high profile events. Any development here would have a significant and negative impact on the use of the adjacent land by local, District, and County-wide Scout Groups. The Scout Land is used by Groups from across the County for weekend camps.

5 While there are 538 houses within the village boundary, some are still on private sewage treatment systems, but we have recently discovered that Clare Park hospital is also connected. Hence a working figure of ~500 houses is used.

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Figure 6-1. SHLAA 73 has a significant impact on the Conservation Area and the setting of several listed buildings

 Nature Conservation ►. Given the statements in the text, the overall assessment should be “orange” at best and is certainly unattractive overall.  Landscaping. We agree with the overall assessments.  Agricultural Land (SHLAA 73) ▼. There is no urban land within the SHLAA site (although there is some adjacent to it). Given that the land is overwhelmingly high grade agricultural, with a very small area at the southern tip used as meadow (as it is subject to flooding), the overall assessment must be “red”.  Agricultural Land (SHLAA 74) ►. The assessment of Grade 4 land is disputed.  Heritage Assets (SHLAA 73) ▼. The impact on the Conservation Area and the setting of several listed buildings is understated. In particular the topology of the ground provides a unique setting for the listed buildings.  Heritage Assets (SHLAA 74) ►. Royal Oak House is a locally listed building (#11) ~50m north of the site.  Air Quality ▼. Residents frequently complain about the odour from the sewage treatment works.  Flood risk (SHLAA 73) ▼▼. We agree with the statements given, but the MAJOR missing issue is one of surface water run-off. Residents adjoining the site often have water pouring off the field, any development will make this situation worse. Flow management schemes have a chequered history of success and the key argument is one of “expected” run-off rates and the performance of over-loaded drainage systems. The misery that this has already caused, the risk of recurrence and problems of finding a permanent solution cannot be overstated.  Flood risk (SHLAA 74) ▼. The site suffers from major ground water issues, especially during the winter. The adjacent Scouting facility (eastern edge) has installed major ditches

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to manage the run-off of surface and ground water from this site. Water also collects at the northern boundary. Any scheme would need a carefully considered surface water mitigation design.  Location and scale of development (SHLAA 73) ▼. While we generally agree with the wording, the logic of simply joining the existing northern and southern dwellings “…consistent with the envelope of the existing built form…” is strongly disputed. Villages do not evolve according to the colouring-in of some lines on a map, they are constrained by physical issues, roads, ownership and amenity values. Given the strong wording of the impact of this site discussed under “Landscape” and “Heritage Assets”, this statement does not make sense.  Location and scale of development (SHLAA 74) ▼. The link to the existing Rural Exception scheme (south) and distributed houses of Bowling Alley (north) cannot be considered an extension of the Crondall built up area. The gap between the existing settlement boundary and other buildings is there to ensure Crondall is NOT subject to ribbon development of the type described.  Site Access (SHLAA 73) ▼. The words used underline the problems with creating an access to this site. After careful review of the plan, we cannot see the “access via Pankridge Road” (Street sic) unless there is an unknown easement across an existing garden. Other options are via extremely narrow small roads. This statement should be “red”.  Summary of Opportunities (SHLAA 73). The wording of this section is entirely contrary to the preceding sections, the facts and the corrections offered above. Based on this revised assessment the site should be “Rejected”.  Summary of Opportunities (SHLAA 74). The site does not relate well to the village and would constitute ribbon development. The wording does not match the details even in their uncorrected form. Based on this revised assessment the site should be “Rejected”.

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6.3 Suitability of SHLAA 73 & 74 Catastrophic impact and unsustainable development

In addition to the factual errors discussed above, the SHLAA sites 73 & 74 are not suitable for development on anything like the scale assumed, if at all.

Figure 6-2. SHLAA 73 & 74 have a huge and unsustainable impact when compared to the existing village boundary

The problems can be summarised as:-  Unsustainable impact on the village due to:- o Sewerage system already operating above capacity such that it still over-fills under storm conditions. Thames Water have attributed this to ancient historic cross- connections to rainwater drains which they consider too costly to trace and resolve. o The generation of excessive additional traffic (at least 50% over existing based on scaling, given that most if not all new-comers will commute to work outside the village). Any new development will be largely populated by outlanders with no specific links to the village and hence the need to commute. o The access routes for these 2 SHLAA sites are not properly defined. o There is little local employment, shopping or public transport in Crondall and hence all residents would need vehicle transport. o A primary school that is full. Additional transport required to ALL secondary school options.  Significantly increased surface flood risk through run-off (and failure/clogging of any engineering solution to ameliorate that)  Unacceptable harm to the Conservation Area and numerous listed buildings through adverse changes to their setting and additional traffic disturbing foundations.  A strongly negative effect on the approach to Crondall, with SHLAA 74 imposing itself into the existing green-gap between Bowling Alley and Lefroys Field.

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Figure 6-3. SHLAA 74 sits above and is only separated from Pankridge Street by a thin strip of land making any development visually intrusive and ruining the green gap

6.4 Other SHLAA Sites in Crondall Better options, carefully examined

6.4.1 Summary The following additional SHLAA sites in Crondall are brought to your attention. Not all of these were available when the Hart consultation process began, but given the evolving nature and strategy to form the overall Local Development Plan, these should now be considered. In particular, given the fundamental problems with SHLAA 73 & 74, these alternative sites form a better set of possible future options. The following assessment includes all Crondall SHLAA sites.

Given the issues with the SHLAA Sustainability Assessments (already discussed), the “rejection” of other sites in the LDP process is disputed and a pragmatic re-assessment is discussed here. Key discrepancies with the existing SHLAA assessments are also noted.

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SHLAA Name Notes Status 72 4 Acre Field Current owner has stated no wish to develop. Reject 73 Land West of See section 6.2, unsuitable for large scale Substantially Crondall development, a modest development (~20 at Reduce most) could possibly fit behind Greensprings. 74 Land North West See section 6.2, unsuitable for development. Reject of Crondall 76 Old Parsonage Development application is current, pre- Pending6 Meadow application advice has been strongly negative. 159 Dippenhall St A modest (30) dwelling development has been Refine proposed by the land-owner who wishes to work closely with the Parish Council. 178 Broden Stables, Unsuitable ribbon development on an extremely Reject Redlands Lane narrow road and poor vehicle access. New Mill Lane Possible site with good transport connections, Progress should include road and junction improvements. Potential Well Road Not yet submitted. Some potential housing and Investigate amenity ideas, but risks ribbon development with poor road connectivity. Table 6-1. Summary of other and existing SHLAA sites in Crondall

6.4.2 SHLAA 72: “4 Acre Field” There are several material errors in this assessment:-  ▼ Bus services, employment and schools all have the same corrections required as discussed in section 6.1.  Planning History: an application was strongly rejected by Hart in 2005.  ► Nature Conservation: is clearly a constraint and should be marked “orange”.  ▼ Agricultural Land: grade 3 is clearly a major constraint and should be marked “red”.  ▼ Availability Assessment: Since the previous owners submitted this into the SHLAA process, the new owners have regularly stated to neighbours that they have no intention of developing the site and have confirmed this for this consultation process.7  Summary of Opportunities: The wording of this section is contrary to the tenor of the preceding sections, notwithstanding the corrections offered above. Based on this corrected assessment the site is firmly “Rejected”.

6 Given the submission of an application on this site a firm view might be seen as predetermination, hence only the current and known facts are reported. 7 Personal email from owner

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 Conservation Area statement – this is deemed an important view in the Conservation Area document

Figure 6-4. SHLAA 72 is part of an important view that forms part of the Conservation Area definition

6.4.3 SHLAA 76: Old Parsonage Meadow There are several material errors:-  ▼ Bus services, employment, schools, health and infrastructure provision all have the same corrections required as discussed in section 6.2.  ► Agricultural land states that it is urban land, which is clearly untrue. It was most recently used for growing Christmas trees, and thus has some agricultural value. It should be an orange colour.  ▼ Flood risk. The surrounding area already suffers from surface water flooding and several properties have been recently flooded on Dippenhall Street. Development will exacerbate surface water run off – should be red in colour.

6.4.4 SHLAA 159: Dippenhall St There are several material errors in this assessment:-  ▼ Bus services, employment and schools all have the same corrections required as discussed in section 6.2.  ▼ Planning History: there has been pre-application advice (14/00577/PREAPP), with a strongly negative response citing the sustainability arguments against an extension to the village, heritage and impact on landscape issues. This response was addressed to Adams Hendry themselves, hence it is unclear why this was not mentioned? It is also unclear why there is no coloured conclusion to the statements?  ► Nature Conservation: is clearly a constraint and should be marked “orange”.  ▼ Agricultural Land: grade 3 is clearly a major constraint and should be marked “red”.  ▼ Un-neighbourly Uses: The site has 2 fuel pipes (10” and 12”) and a high pressure gas main running across it. We believe the gas pipe is part of the National Gas Transmission System (NTS) operating ~85 bar. Safety “no development” distances around these vary, a

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single gas pipe. An UK HSE consultation (p39) refers to an 80m buffer zone from a “Total night time residential population”. The methodology is based on assessments of the “risk” to individuals over long time periods, so is a complex assessment, but having the fuel pipes adjacent to the gas will only increase the risk and hence the safety distances.

Figure 6-5. Fuel and gas pipelines crossing SHLAA159 with “no development” buffer zone.

 Summary of Opportunities: The wording of this section is contrary to the tenor of the preceding sections, notwithstanding the corrections offered above.

Nevertheless and mindful of the Parish Council’s ‘Fair Share’ stance, it has been in proactive discussion with the owners and a more modest number of dwellings could be investigated to seek the right design and infrastructure arrangements, in extremis.

6.4.5 SHLAA 178: Broden Stables, Redlands Lane This site was submitted after the High Level Site Assessments were completed. The following points are noted, based on the categories included in the High Level Site Assessments:-  ▼ Bus services, employment and schools all have the same issues as discussed in section 6.2.  ► Infrastructure, current use are all very similar to SHLAA 159 and should be marked “orange”.  ► Nature Conservation: is clearly a constraint and should be marked “orange”.  Mineral rights are not known.  ► Landscape: slightly less visually intrusive than other sites, this has very similar constraints to SHLAA 73, in that development constitutes “ribbon” development

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away from the core part of the village.  ▼ Agricultural Land: grade 3 is clearly a major constraint and should be assessed as “red”.  ▼ Flood Risk: The land is subject to high ground water flood risks (image extracted from SHLAA 159 flood assessment). In addition the whole lower part of Redlands Lane suffers from very high surface water run-off from the golf course. This would need to be mitigated and managed to reduce the instances of large water volumes running down Redlands Lane.

Figure 6-6. SHLAA 178 has significant ground water issues

 ▼ Site Access: While the site can be physically accessed from Redlands Lane, it is Redlands Lane itself that is the major constraint on development. The road is narrow and poorly maintained, with an elongated pinch-point at Redlands Bridge.

Figure 6-7. Redlands Lane is narrow and poorly maintained, making access difficult past the existing Health Centre

Overall, this is not an attractive site to develop and better options are available.

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6.4.6 SHLAA (New): Mill Lane This site was proposed during the consultation process. It was discussed at the Parish Council’s December meeting (Minute 180/15) and generally supported in principle. The key benefits being:-  ► Bus services, employment and schools all have similar issues as discussed in section 6.2. However, its direct access to the A287 mitigates some of these issues with simple access to the road network.  ► Infrastructure, current use are all very similar to SHLAA 159 and should be marked “orange”.  ▲ Nature Conservation. There are no specific or known issues.  Mineral rights are not known.  ► Landscape: will require some detailed design and screening.  ▲ Agricultural Land: grade 4 and is currently used for equestrian activities  ▲ Flood Risk: no specific flood risks, this is a well-drained site with existing drainage facilities. However, some neighbouring sites (i.e. Finns Business Park) have significant sewerage issues and any development at this location should look to mitigate or improve those problems.  ▲ Site Access: clear access to the A287

This site is particularly suitable to extract some planning gain in the shape of an improved access to the A287 for all residents and users of Mill Lane. The Parish Council is in receipt of several complaints about the dangers of this junction, the inclusion of a roundabout to further mitigate speeds along the A287 would work well with the new roundabout at Redfields Lane (part of the Watery Lane development) to create a comprehensive speed management area.

The potential developer’s agent (Gregory Grey Associates) states that the site is ready for relatively rapid development due to existing service provision.

6.4.7 SHLAA (Potential): Land on Well Road During the consultation period Friday Street (local developers) have written to the Parish Council to propose adding another site to the SHLAA process. This is a site adjoining Hook Meadow and Well Road to the west of Hook Cottage on Well Road. Friday Street have suggested a mixed series of uses for this site possibly including:-  A small set of dwellings  Additional car parking  A Burial ground extension

This is a very recent proposal and the Parish Council has not yet resolved how to respond, but is likely to seek clarification and further discussions. There are practical issues involving burial grounds and any development would be the “wrong side” of the village generating extra traffic through the village (in a similar manner to SHLAA 159).

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7 Q7: Other Comments 7.1 Parish Consultation Broad agreement to Crondall Parish Council’s approach, with unprecedented attendance at public meeting

Given the complexity of the questionnaire and issues being discussed, both within the Parish options and the wider Hart consultation, the Parish Council organised a public meeting on 21st Dec at the Village Hall in Crondall. Around 200 parishioners attended (an unprecedented number, even dating back to the wider combined parish with ) and were taken through the details, options and issues. This culminated in a lively debate exploring the options and issues in more detail. Subsequently the Parish Council received over 40 messages of congratulation for both the content and style of the meeting.

Printed copies of the consultation material (provided by Hart) were made available to the public in the village’s Church Rooms and printed response forms made available at the shop, the Plume of Feathers, the Hampshire Arms, in the Church Rooms and delivered to any parishioner that requested them.

The following could be concluded:-  Parishioners are concerned by the complexity of the consultation and the highly constrained nature of the questionnaire.  There is overwhelming agreement that SHLAA 73 & 74 are highly unsuitable for development in terms of scale and location.  There is broad agreement with Crondall Parish Council’s approach (as contained in this reply), with a majority supporting Option 3 over Option 2, but setting Option 1 as the least attractive.

7.2 Core Development Numbers Revisit and revise to set a realistic baseline

The current Hart Strategic Housing Market Assessment (SHMA) has two main flaws:- 1. It is based on out of date population projections, especially given that the later 2012-based projections show a reduced population and number of households for Hart. 2. Latest PAS guidance notes that the “OAN should be principally understood as a measure of future demand rather than aspiration”. Yet the future jobs forecasts call for a near doubling of the job creation rate compared to the period 1998-2012, with consequent massive increases in the labour market participation rate and additional housing. However between 2009-2013 Hart has not produced jobs at this forecast rate. These aspirational jobs forecasts should be removed from the SHMA. This will reduce “need”, and remove the pressure for Hart to build for Surrey Heath & Rushmoor. The total of these

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points would remove 2,000 houses from Hart’s “need” (and over 12,000 from the Housing Market Area) according to Alan Wenban-Smith. It is understood that this consultation is one “snapshot” based on constantly evolving evidence, but it would be unacceptable to predicate the whole of Hart’s plan on numbers that were clearly out of date. Additionally we would suggest that some flexibility be demonstrated in the development approach that would allow Hart to respond to changes in such predictions. Thus a robust approach can be based on the latest numbers, with some flexibility going forward to be addressed in future evolutions of the plan as “actual” demands reveal themselves.

7.3 Brownfield Development A positive approach to the least worst options

The Parish has read the material supplied by WeHeartHart with great interest. We strongly suggest that a more pragmatic approach to brownfield sites (eg. Bramshill Police college and Minley Manor) be adopted. The development of sensitive brownfield sites is never easy, but a pragmatic approach can enhance the survival of the core listed buildings and their setting. This re- use of existing sites (and accompanying infrastructure) is completely preferable to taking greenfield options that can only be converted once.

We note the comments of Hart at the Parish Briefing relating to this consultation (D. Phillips, 2 Dec 15) that in particular the brownfield sites at Bramshill and Minley Manor would be difficult to develop due to their listed status. However, we note the following examples of highly successful local rural development of listed sites:-  Park is Grade 1 and 2 listed and was sensitively developed.  The Winchfield area includes Winchfield House (grade 2* listed, No: 1246041), while the SA7 assessment simply recommends design constraints.

In the specific case of Bramshill, we note:-  The Conservation Officer’s comments in relation to the current application appear to refer to existing planning policy, but parishes were specifically instructed (D. Phillips, 2 Dec 15) that the new Local Plan was developed without current policy constraints, with only national policies applying.  Sustainability Appraisal of the High Level Site Assessments, 9th September 2015, around page 134 o SA6: the creation of a new, focussed and local community is a positive outcome. Such behaviours are clear in villages, but even within the larger conurbations, smaller community/neighbourhood groups exist over modest geographical areas. o SA7: the re-use of brownfield land must be positive when considered in isolation for this site, there are plenty of examples of sensitive and preserving development of listed buildings. o SA8: the net effect on biodiversity cannot be classed as “major negative effect”, since the existing use as a training college is mitigated by conversion.

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o SA9: the re-use of brownfield alone is positive in this regard. When combined with the option to avoid greenfield, it is overwhelmingly positive. o SA15: Given the national policy to support the re-use brownfield land, this should be scored as “major”. o SA17 & 20: the job losses have already occurred, the comment is invalid.

It is therefore apparent that the several suitable brownfield listed building sites have been previously and most satisfactorily developed. Bramshill would appear to be quite developable if suitably encouraged. We believe that across the District a more positive and pragmatic approach should be taken.

7.4 Taking a Fair Share A fair burden in a sustainable manner

Since 2011 (and informally before that), Crondall Parish Council has continued to offer to take a “fair share” of development. The concept of “fair share” is rooted in both moral and practical arguments. Morally, the parish accepts that “nil” development is not a sustainable position and “some” should be equitably spread across the whole district – commensurate with sustainability. On a practical level, it is understood that Hart need to achieve an overall set of figures.

We are deeply concerned that the previous LDF consultation8 had 500 dwellings proposed in rural parishes (when a “dispersal” approach was comprehensively disparaged) while this new version has 1530 dwellings (under option 1). There is currently no defined allocation under Options 2 & 3 and hence there is no possibility of making an informed choice.

The character of Crondall village and the wider parish with its very limited services and crumbling infrastructure will simply not support large numbers of additional houses. Additionally, the sustainability of large areas of rural development is openly questioned on grounds of transport, access to schools and the significantly larger carbon footprint of such developments over a more urban focus.

The Parish Council notes the basic targets for Hart as:  Existing: 35,000 dwellings (2011 census)  Built or planned: 4,600 dwellings (2015 Hart Housing Consultation paper)  Required additional development: 2,500 (2015 Refined Options for Delivering New Homes consultation paper, para 21)

Based on these figures we calculate that Hart needs to find an additional:-

8 Housing Development Options Consultation Paper, August 2014

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2,500 = 6.3% [35,000 + 4,600]

Crondall currently has 734 houses (2015 Tax Base calculation) in the entire parish, with only 538 inside the current village development boundary.

Applying the same ratio to Crondall, we arrive at a basic fair share of 46 dwellings across the entire parish.

The Parish along with the wider District has already absorbed some development and hence there is an argument for reduction. However, the Parish understands the challenges at Hart and hence is prepared to offer a figure of around 50 for the completion of the plan period (to 2032).

7.5 A Better Plan for Crondall A sustainable approach to accept a fair share of ~50 with long term potential

The Parish Council has looked carefully at the situation and considered the longer term interests of the village; it has considered what could be sustainable, reasonable and justifiable balancing the needs across Hart with practical development possibilities within the parish.

Figure 7-1. NPPF, para 55 requires sustainable development in rural areas that enhances or maintains vitality, a 50% increase would be entirely contrary to this.

The table below shows a more sustainable approach for Crondall under Option 1 (ONLY offered in the event that Option 3 is not adopted). These figures and selection are based on the justification below.

Location Target Mill Lane: 35 Other development: 15 Total: 50 Table 7-1. A Reasonable, Fair and Deliverable approach is proposed

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7.6 Pragmatic and Consistent Approach to SPA Constraints Setting the SPA into context for better site choices

We urge Hart to be more pragmatic and make positive decisions concerning the use of sites close to the SPA that are practical in all other respects. This is to avoid historic happenstance driving development into the fresher green fields of Hart. The existing SPAs run right up to developed areas in many places, yet achieve their functions. The 400m buffer zone covers half of the main runway at Farnborough, which is a strange juxtaposition. The existing SPA document (para 1.5), states that while “net housing development is to be avoided”, it does not prohibit such development.

Figure 7-2. SPA buffer areas include the main runway and developed areas without notable effects on wildlife

The wording can clearly be interpreted as “Net” = overall change, “avoided” = subject to comparison with other options. In the example of Bramshill, the conversion from Police training facility to housing will result in less disturbance to the local wildlife. Indeed, a practical assessment of wildlife shows that they evolve and adapt to their local circumstances, in particular bird life thrives on urban handouts. Across many sites the comparison of modest degradation of a small area at the edge of a large SPA site needs to be set against the long-term and permanent loss of green habitat elsewhere in the District.

As an example: SHLAA 100 & 153 have parts within an SPA 400m buffer zone, yet they receive only modest negative marking for this point (under SA8). It would appear that the proximity to SPA has unexplained variable treatment through the Sustainability Appraisal of the High Level Site

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Assessments, hence several sites are not as positively marked as they might be and the selection of developable sites is artificially constrained.

7.7 Distributed Development within the Parish Around 15 additional dwellings distributed in the rural areas

While it is understood that Hart needs to consider the larger scale development targets, at the local level more modest scales of development can make a significant contribution to those local targets.

Changes is planning regulations now permit the change of use of agricultural buildings to residential use. It is envisaged that there will be a number of suitable buildings of this type within Crondall Parish that will come forward for development.

The Parish Council has become aware of a policy adopted (and accepted by Inspection) in other rural areas to allow a modest and controlled degree of development over the plan period. The Scottish Border’s policy HD2 (page 75) on small rural developments (this was featured in the BBC series “The Planners”) allows some “modest” development in the countryside. This was “Examined” by the Scottish Government appointed Reporter and approved with modification in October 2015, with minor changes to HD2 (see page 250 onwards of the Examiner’s report).

(A) Building Groups Housing of up to a total of 2 additional dwellings or a 30% increase of the building group, whichever is the greater, associated with existing building groups may be approved provided that: a) the Council is satisfied that the site is well related to an existing group of at least three houses or building(s) currently in residential use or capable of conversion to residential use. Where conversion is required to establish a cohesive group of at least three houses, no additional housing will be approved until such conversion has been implemented, b) the cumulative impact of new development on the character of the building group, and on the landscape and amenity of the surrounding area will be taken into account when determining new applications. Additional development within a building group will be refused if, in conjunction with other developments in the area, it will cause unacceptable adverse impacts, c) any consents for new build granted under this part of this policy should not exceed two housing dwellings or a 30% increase in addition to the group during the Plan period. No further development above this threshold will be permitted. Figure 7-3. Extract from Scottish Borders policy HD2 allowing modest and controlled rural development

The effect of this policy has been carefully analysed for the Parish of Crondall and could generate up to 41 additional dwellings. While not an ideal policy, it is seen as a “least worst option”, a test that must be applied to many of the decisions in this process. The issues of additional vehicle journeys is negative, but small and manageable. Design and sustainable services would need careful specification.

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Figure 7-4. 120 distributed rural dwellings could deliver up to 41 extra houses

The counterpoint is the “deliverability” of such sites. Our view is that a modest number could be defined under the SHLAA scheme once owners become aware of the possibility. In most cases the land for potential development is owned by the residents that currently occupy such land and hence we propose 15 dwellings as a windfall contribution for this phase.

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7.8 Consistency with Hart’s Key Issues, Vision Helping to ensure a self-consistent plan

The use of SHLAA 73 & 74 is materially contrary to “Draft Vision and Strategic Priorities for Hart”9. To propose such a scale of development in these areas would result in a Local Plan that was internally inconsistent and hence open to challenge at Inspection. Specifically, the following points are made in relation to the contents of this document (see following sub-sections):-  Key Issues (Table 1)  Draft Vision (page 6)  Draft Strategic Priorities (Table 2)

7.8.1 Comparison with Key Issues Key Issues (numbers taken from Table 1):-  4: A 50% increase in the scale of the village would overwhelm the small roads that serve it, while generating excessive demands on schooling that could not be met locally.  5: Crondall has a vibrant rural economy supporting many physical business, but also a growing number of “e-businesses” which are not constrained by physically access to workers. The Crondall community is extremely vibrant with a diverse demographic and does not need significant extra dwellings to survive and thrive.  6: Development on the scale discussed would overwhelm the local character and landscape. This is especially the case both for SHLAA 73 (which, due to the topology of the site would seriously affect many listed buildings) and for SHLAA 74 (which would extend ribbon development to Bowling Alley and be extremely visible from Pankridge Street).  7: The extended nature of the existing design of Crondall already generates many additional internal car journeys e.g. taking children from the northern end to school (a distance of ~1.3km). The proposed developments would increase this exacerbating both the internal traffic jams in Crondall and the parking problems around the school.  8: With no public bus service in Crondall, families are entirely dependent on their cars, placing addition financial burdens on those with lower incomes. The sustainability issues are obviously extremely negative and this would generally drive Hart to create more housing closer to transport hubs, which clearly don’t exist in Crondall and neither are they readily accessible at many other suggested locations.  10: Development on SHLAA73 would have significant and negative effects on surface water run-off. We are already seeing the effects of more intense rainfall as predicted by UK Government climate change warnings10, (which makes a mockery of previously accepted

9 Draft Vision and Strategic Priorities for Hart, November 2015, PDF file “5pm FINAL” 10 https://www.gov.uk/guidance/climate-change-explained highlighting “Warming is expected to cause more intense, heavy rainfall events”

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design guidelines), and this poses a significant risk to houses on the west side of Crondall abutting SHLAA 73.  11: The design of any new development will include surface water drainage that washes all mud, dog faeces, oil etc off those surfaces and straight into the . While not an attractive prospect with the current design, an additional 50% increase in cars and people will cause additional and unacceptable contamination.  13: The protection of open fields as green infrastructure, especially SHLAA 74 which provide huge amenity value to the local, District and County Scout users is self-evident.  14: SHLAA 73 impinges on the Conservation Area and the setting of several listed buildings.

7.8.2 Comparison with Draft Vision On page 6 of the “Draft Vision and Strategic Priorities for Hart” an outline vision is presented. Curiously the development patterns proposed by Hart do not accord with much of this, specifically:-  “Effective use of previously developed land” - requires considerably more use of brownfield sites and more imaginative solutions to the limitations imposed on some sites. In particular the Stonegate11 report should be more carefully considered with a view to the accessing, re-using and re-purposing of existing buildings.  “Coalescence of settlements will have been avoided” – this requires the avoidance of ribbon development and the establishment of strategic gaps to maintain those distinctions; the proposals for Crondall fail both these tests.  “The best of Hart’s natural, built and heritage assets will have been protected, and where possible enhanced” – this implies and requires only minimal development in and adjoining Conservation Areas, as large scale development can never enhance such heritage assets.

7.8.3 Comparison with Draft Strategic Priorities The draft Strategic Priorities are generally accepted, however, we note that there is no priority assigned to them. In such cases the parallel application of such criteria will cause conflicts and contradictions where 2 or more priorities cannot be met simultaneously. Specifically we note:-  1. This should include a reference to the regular assessment of that need and the methods of assessment.  2. We would suggest a review of SHMA partnering with a better and more equitable long term view.  5. We suggest the separation of transport and schools as these are two distinct issues. HDC have some control over schools, less over road building programmes and none over commercial transport services (i.e. rural bus provision).  6. This is strongly supported and the inconsistency of SHLAA 73 & 74 development with this priority is noted.

11 Viability of office to residential conversions to meet Hart DC Housing supply, Stonegate Homes Ltd, 5/21/2015

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 7. The assessment of flood risk needs to go beyond the immediate development and ensure that “downstream” problems are avoided and where possible existing situations are improved. The current situation as a baseline for development should not be accepted, where possible flood risks must be reduced and some element of “future proofing” included.  9. The absence of rural bus services is much lamented and HDC should work harder to find suitable alternatives.  11. Is very much supported especially in the context of the Winchfield new town.

7.9 Definition of Strategic Gaps Protecting valued character into the future

It is understood that this round of consultation will feed directly into the final Local Plan for consultation in Summer 2016. Crondall has one the highest numbers and densities of listed buildings in Hart, second only to Odiham. Unlike other villages, Crondall sits in a large bowl (as noted in the Crondall Conservation Area report), providing attractive all-round rural views and settings for the village (it also collects water very efficiently contributing to the flooding issues!). This makes it very difficult to blend new development into that setting and hence the request to define a number of strategic gaps. This is exactly matched to the draft strategic priorities suggested by Hart to avoid the coalescence of settlements.

The following figure makes pragmatic suggestions for such strategic gaps.

Figure 7-5. Proposed strategic gaps to enhance and preserve the historic setting

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Strategic Gaps are proposed to enhance and preserve both the Conservation Area and the listed buildings within it. A secondary function is to ensure that the ever-growing conurbation of Fleet and (currently extended to Watery Lane) is not permitted to “join up” with Crondall to create a massive “Greater Fleet” ribbon development from the M3 down to Farnham.

The following gaps are proposed:- 1. Upper Pankridge Street: to avoid a union of Crondall Village with development in Bowling Alley 2. Redfields Lane: to maintain separation between the Watery Lane development, land to the east of Redfields Lane and the edge of the Bowling Alley developments 3. Crondall Road: to avoid ribbon development along the A287 and preserve the isolated character of the existing hamlets. 4. Dippenhall Street: to avoid ribbon development along Dippenhall Street. 5. Mill Lane-West: to ensure a clear development gap between the existing Mill Lane developments and any further development along the A287.

The Parish Council has avoided the temptation to place such gaps everywhere, limiting them to the areas that are most threatened by encroachment, relying on the general presumption against new building in rural areas (notwithstanding the policy proposed in 7.7 which limits this to existing hamlets) to prevent unplanned development.

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7.10 Overall Consultation Process A more constructive way forward for an enhanced solution

The Parish Council notes that the process for this round of consultation has several significant draw-backs:-  The options presented appear to be extremely polarised in their layout and approach. The previous consultation (October 2014) was quite clear in its outcomes and we would have expected the Dispersal and SPA avoidance strategies to be removed, with a clear focus on the refinement of detail.  Option 1 (as presented in this round of consultation) is very much not as “dispersed” as previously suggested. As noted, Option 1 makes no attempt to disperse housing across all the villages (notably with “0” in Winchfield).  This extremely polarising approach has caused considerable animosity between councillors and parishes as each seek to protect their areas.  The approach of the questionnaire and the ‘detail constraints’ on its completion have stifled many comments and rail-roaded respondents into an extremely limited range of practical conclusions.

Crondall Parish Council wishes to propose a more collaborative approach based on a top-down allocation of housing (a fair share matched by strategic considerations) which the Parish Council can allocate across the Parish. We see this as the essence of localism, either by direct negotiation or a Neighbourhood Plan. Clearly there is no value in a Neighbourhood Plan if Hart has already allocated development sites.

Figure 7-6. NPPF para 17 (Planning principles), requires protection of rural communities and surrounding countryside

The NPPF (para 17, point 5) requires that Local Authorities take account of the differing needs and expectations of rural communities, this cannot be accomplished in isolation.

The need for the deliverability of sites is clear, but with over 6 years of land-supply in the Hart “bank”, there are several years for the Parish to work with local developers to establish local options and solutions to meet a fair share of the development target. Local discussions with sympathetic landowners are well-known to deliver better solutions and more planning gain than imposed and centrally negotiated deals.

We therefore seek an early meeting with Hart to define a fair and reasonable target that the Parish Council can work with as part of the overall Local Development Plan.

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8 Moving Forward Given the difficult and complex issues raised by this consultation, Crondall Parish Council would like to propose a way forward:-  A meeting with Hart to discuss:- o The results and implications of the consultation o A pragmatic way forward to define a ‘fair share‘ of development o Agreement on the strategic gaps  To be part of the review and comment process with Hart to update and correct the SHLAA and Sustainability Assessments in order to create a better and more accurate basis for decision making. This is in accordance with NPPF para 167.  To look again at developing a Neighbourhood Plan to meet an agreed and reasonable ‘fair share’ of development at sites that the Parish brings forward in accordance with the principles of Localism  To work with Hart and local developers to investigate, refine and down-select potential sites

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