Our client, Winchfield Parish Council (WPC), are delighted that a new settlement policy has been recommended for removal from the proposed Hart Local Plan. This follows evidence commissioned by WPC and prepared by MBELC and JB Planning regarding the unsuitability of the location for the new settlement.
In March 2018, MBELC prepared a report on behalf of WPC which addressed the landscape constraints to the ‘area of search’ (AoS) for a new settlement identified in the proposed Hart Local Plan (Draft Policy SS3). [Read more about this project here] . In November 2018 Michelle Bolger gave evidence on the unsuitability of the location at the Local Plan Examination hearing session.
The hearing sessions finished in December 2018 and last week the Inspector advised the Council about the further steps or main modifications that he considers are necessary for the Plan to be made legally compliant and/or sound. [The Inspector’s advice is set out in a letter, dated February 2019, which can be accessed here].
In his letter the Inspector reiterates a number of concerns that were raised in our report and through our attendance at the relevant hearing session. With regards to Policy SS3 he concludes that: ‘…Policy SS3 is not required for the Plan to be sound and, in light of my comments above, I consider that the most appropriate course of action would be to remove it… from the Plan through Main Modifications(MMs). This would allow the Plan to progress towards adoption without any significant delay to the examination process’. 
The Inspector reaches his conclusion based on ‘a number of fundamental concerns with regard to the soundness of Policy SS3’.  His concerns include that there is:
Insufficient evidence to support the ranking of the AoS within the Council’s Post Submission Interim Sustainability Appraisal Report (Post Submission SAR) ;
A lack of detailed assessments to support the Post Submission SAR’s findings on specific matters such as heritage ;
Insufficient evidence to allow a suitably robust comparison of reasonable alternatives to be undertaken ;
‘Inconsistent assumptions’ applied in relation to the appraisal of the AoS when compared against alternatives in the Post Submission SAR ; and
Little evidence to demonstrate that a new settlement could actually be delivered within the AoS .
In explaining these concerns, the Inspector agrees with the key issues identified in our report, including:
The highly constrained nature of the AoS (by its landscape sensitivity, biodiversity features, areas of ancient woodland, heritage assets, the M3 motorway, the railway line, etc.)  which were not adequately addressed by the site promotors; and
The inability to deliver a new settlement due to land ownership, specifically, the large parcel in the middle of the AoS which is unavailable to the site promoters. 
Overall, the Inspector’s advice is clear. Where new settlements are proposed, robust evidence should demonstrate why a new settlement is the most appropriate growth strategy for the Local Plan, and this evidence should robustly consider its deliverability and reasonable alternatives. As highlighted by our work, and agreed by the Inspector, this has not occurred in the case of Policy SS3.