Housing targets systematically over-stating housing need

Is this what we want Hart to turn into?

Is this what we want our countryside to turn into?

A review of a sample of Strategic Housing Market Assessments (SHMAs) across the south of England has indicated that on average, local planning authorities are being asked to plan for 41.9% more houses than the needs identified by DCLG population projections. The consequence of this is it is likely that far more green field land is being allocated for housing than is necessary to meet our housing need.

Regular readers will know that for some time we have been concerned about the overall level of housing Hart District is being asked to deliver.  To this end,  we have been analysing our Strategic Housing Market Assessment (SHMA), and together with Winchfield Action Group (WAG), we have commissioned an independent look at Hart’s SHMA.

However, we have also been inspired by the work of Alan Wenban-Smith criticising the Vale of the White Horse SHMA. This has led us to take a look at a number of SHMAs around the area, comparing the starting point of the official Government population and household forecasts to the end point of the recommended housing need after taking into account a number of additional elements like additional inward migration to the area, affordable housing, changes in average household size and jobs forecasts.

The findings are quite alarming and lead to a number of conclusions, some of which should be relevant for national planning policy.

We have looked at 6 SHMAs covering large areas of Hampshire, Berkshire, Surrey and Oxfordshire.  Overall the total “starting point need” for these areas is 272,200 houses, and the end point “need” is 386,286 houses, or an uplift of 41.9%.  This is shown in the table below:

 

SHMA AreaLoca Authorites coveredAuthorStarting year yearEnd point yearStarting point "need"Ending point "Need"% Uplift over starting pointNotes
HRSHHart, Rushmoor Surrey HeathWessex Economics20112031158002360049.4Starting point is 2011 DCLG and SNPP projections
South HampshirePortsmouth, Fareham, Gosport, Chichester, Bognor Regis, Southampton (West Centre), Southampton (East), Winchester, Eastleigh, Lymington, Totton, HavantGL Hearn201120368710513161151.1Starting point is 2011 DCLG and SNPP projections
East HampshireEast HampshireNathaniel Lichfield & Partners201120288105960518.5Start point 2010 SNPP
WaverleyWaverleyGL Hearn201120317670940022.6Start point 2011 SNPP and CLG projections
BerkshireBracknell Forest, Reading, West Berks, Wokingham, Slough, South Bucks, RBWMGL Hearn201320369577211201017.02012-based SNPP
OxfordshireCherwell, Oxford, South Oxon, Vale of White Horse, West OxonGL Hearn201120315774810006073.32011-based projections
Total27220038628641.9

 

The DCLG population and household forecasts “are statistically robust and are based on nationally consistent assumptions“, so the net effect of adjustments across all SHMAs should be close to zero.  If this sample is indicative of what is going on across the country, then councils will be planning for far more houses than we need and as a consequence will be allocating for development far more green field land than is necessary to meet our housing requirements, with disastrous consequences for our countryside. Current housing delivery is around 150K per annum, and the DCLG figures suggest an underlying need of 220K per annum. If my analysis of this sample is indicative of what is going on across the whole country, councils will end up planning for about 312K houses which would be a big waste of national resources.

We would like to see this analysis repeated on a national basis.  However, an FOI request to the DCLG has not been successful because they don’t collate this data at a national level.  For a Government that wants to focus on brownfield development, this looks to us to be a reckless omission.

The SHMAs on which this analysis is based are:

Hart, Rushmoor and Surrey Heath, here.

South Hampshire, including Portsmouth, Fareham, Gosport, Southampton, Eastleigh and Havant, here.

East Hampshire, here.

Waverley, here.

Berkshire, here.

Oxfordshire, here.

 

 

Hart Council Leader stonewalls questions about revisions to the SHMA

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Regular readers may remember that we put a number of questions to the Hart Council meeting on 29 October about changes in household, population and jobs forecasts that should be incorporated into the revised SHMA.  All of these questions were met with a wall of silence and peremptory answers.  The Q&A can be found on the council website, with the relevant questions and answers re-produced in full below.

We have not yet received an answer from the Joint Chief Executive to back up his assertion that the brownfield capacity of the district is only 1,800 units.

Question: Given that the baseline estimate of the number of households in Hart in 2011 and 2031 used in the SHMA was 35,760 and 42,220 respectively, but the new DCLG 2012-based household projections (Table 406) for 2031 show that Hart will have only 40,618 households, a reduction of 1,602, can you confirm that these revised figures will lead to a corresponding reduction in Hart’s assessed housing need?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: When will the 6,560 excess housing requirement for the whole HMA be removed from the assessed need in the SHMA given that the new DCLG 2012-based population projections (Table 426) show a population projection of only 289K for the HMA for 2031, compared to the SHMA (Appendix F, Figure 2) starting assumption of 307K and the final population estimate of 322K used to determine housing need?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What justification is there for assuming the significant social changes implied in the SHMA given that the SHMA increases the number of houses that need to be built based in part on very ambitious jobs forecasts which when combined with the population projections in the SHMA results in a massive increase in the proportion of people of working age who will be in employment (see table below)?

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What steps will be taken to adjust the jobs forecasts in the SHMA given that, a) the revised BRES job numbers for 2013 show that the compound annual growth rate in jobs we have achieved since the recession ended in 2009 is ~0.5% which is much lower than the ~0.8% growth rate assumed in the SHMA for the period 2011-2031, b) this comes at a time when the UK is creating more jobs than the rest of the EU put together and c) it is inevitable we will experience at least one more recession during the plan period?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What steps are being taken to accelerate the delivery of the Local Plan given that the recent Government announcement indicated that Local Plans need to be brought into force by 2017 and the current LDS shows the Local Plan being adopted in Summer 2017 and other DPD’s in Autumn 2018 and the track record of past slippage?

Response: Section 99 of the Housing and Planning Bill which provides for the reserve powers for the SoS at DCLG to recover a local plan does not have any dates. The operative wording is “if the Secretary of State thinks that a local planning authority are failing or omitting to do anything it is necessary for them to do in connection with the preparation, revision or adoption of a development plan document”. The Joint Chief Executive, who is the planning lead on the District Councils Executive network, has ascertained that provided that councils are making reasonable progress towards a local plan, the SoS does not intend to intervene. The powers are intended for a small minority of councils who are making little or no effort to establish a plan. I have independently validated this with my own contacts on the Environment, Economy and Housing Board at the Local Government Association among others. We therefore don’t think the Government will intervene if we meet our new timetable given we will already be at examination in the Spring of 2017.

Community Campaign Hart Council Chairman to discuss brownfield development with Ranil

Hart District Council Offices

Hart District Council Offices

Concrete Community Campaign Hart (CCH) member and chairman of Hart District Council is to meet with our Local MP Ranil Jayawardena to challenge any misunderstandings there might be about the brownfield capacity of Hart District.

CCH are clearly alarmed at Ranil’s intervention on planning matters, especially as Ranil said he was against large-scale, top-down developments generally and he believed (as We Heart Hart believe), that our remaining housing allocation can be met from brownfield sites alone.

CCH have said they are opposed to redeveloping the derelict sites on Fleet Road in Fleet, Hampshire, and instead prefer to build a new town in Winchfield.

The chairman’s statement on this matter is included in the draft minutes of last week’s meeting and reproduced below:

Secondly, I have become aware of the disquiet felt by many members from all political groups about the Planning pronouncements from our MP Ranil Jayawardena. In particular, the assertion that Hart has enough Brownfield sites to build all its housing needs without the need to disturb any significant Greenfield sites outside current settlement boundaries. This is in direct contradiction to the advice we as a council have been given by officers, consultants and members on the Local Plan Steering Group.

In my role as Chairman I have had the pleasure of talking to Ranil on this issue whilst undertaking other civic duties. I therefore took the opportunity to invite him to a private meeting with this Council to explore why such disparate views have come about. His current position is that he would welcome such a meeting. My invitation was made to ensure no misunderstandings remain unchallenged between us as having a fully engaged, briefed and passionate advocate for Hart in Westminster is important for this Council.

I will be working with the Council Leader and Rail’s [sic] office to agree a date that will fit in with his Parliamentary responsibilities. It is therefore likely that the timing of such a meeting will not be a midweek evening so I apologise to working members in advance.

We do hope that Ranil maintains his position and points out to Hart Council members some of our work on brownfield capacity and Ranil also further explains his policy of pushing local councils to be more active.

Separately, the Council Leader expressed some sympathy with the view we should build on brownfield sites alone and even conceded it might be theoretically possible, but fell short of making a commitment to do so. Our questions and the Leader’s answers below:

Question: Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?

Response: Putting to one side the matter that this is a quotation out of context, Mr. Jayawardena makes three points in this opinion statement. Firstly he says that brownfield should be used before greenfield; as a statement of principle I wholly agree, and always have. However, we are obliged to maintain a five year land supply. As fast as we approve fresh applications, previous consents are being built out; this is a moving target. Unless we can deliver brownfield site planning consents at the rate of that of our ongoing annual housing requirement we cannot deal with this sequentially. Given that we do not have deliverable and developable brownfield sites sufficient for our own Objectively Assessed Housing Needs (OAHN), we are obliged to allocate some sites other than brownfield to achieve the numbers required. Second, he is opposed to a number of specific sites, as am I. We are however compelled to allocate sites which we would prefer not in order to fulfil our OAHN. He states that he believes the OAHN can be met from brownfield sites; this is probably theoretically true, if we compel the use of unavailable sites including those in current active employment use. That is not available to us.

Question: What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?

Response: CPO is not a cheap option. We would be obliged to pay market price for such land, plus the costs of acquisition, and this for a site where the owner has not perceived an opportunity to develop at a profit. It is simply unrealistic that Hart DC could undertake CPO on the scale necessary, and in the timeframes necessary, to persuade an Inspector that such a plan would be deliverable. The Council could not afford to do it. Further, to produce tracts of apartments for young professionals would result in fundamentally unbalanced communities. We need communities which provide for all our residents, including families and older people. Young professional ghettoes are not good planning. In the event that a site would become appropriate for CPO, the site would be considered on its individual merits. You should be aware, however, that the seizure of the assets of others even paying full value is not something this council has seen as desirable, which is why it was not considered as an appropriate means of site assembly should a new settlement proceed.

Question: How many sites would meet those criteria and how many dwellings might they yield?

Response: A site would be considered on its merits at the time.

Government to extend “planning in principle” rights to green fields

Example of Urban Sprawl

Example of Urban Sprawl

The Government appears to be trying to extend the recently announced “planning in principle” rights to green field developments. This could mean tens of thousands of new homes in green field areas will be forced upon communities that do not want them.

We have previously applauded the Government for introducing this right to brownfield sites. Just three weeks ago David Cameron, the Prime Minister, said that the new “planning in principle” changes would apply to brownfield sites like former car parks and industrial areas. However Government documents said the new power will apply to “housing identified in local plans and neighbourhood plans” which include greenfield areas.

One document states: “The Government proposes to legislate to enable the Secretary of State to grant ‘permission in principle’ via a development order to land that is allocated for development in locally produced plans and registers.”

This development may have important implications for the Hart District parishes (e.g. Winchfield, Odiham, Fleet) that are in the process of creating their Neighbourhood Plans and of course for the Hart Local Plan.  Surely, this will mean that will be more reluctant to identify potential sites for development because Hart Council Planners will no longer have the powers to block inappropriate schemes nor to insist that the design, density, size and location of homes is in keeping with local areas.

This proposal significantly undermines local democracy and should be opposed.

 

Fog descends on the Hart Local Plan

Fog descends on Hart Local Plan

Fog descends on Hart Local Plan

A number of new developments are emerging on the Hart Local Plan, that show that the overall process is confused and murky.

First, we understand that a new Housing Options paper is being produced that will go to a special meeting of Hart Council Cabinet on 18 November.  This paper will then be offered for consultation, although the consultation period is not clear.  Usually, six weeks are allowed for consultation, but there is some suggestion that this period will be reduced.

Second, it has emerged that the Strategic Housing Market Assessment (SHMA) is being revisited to take account of changes in the population and household forecasts.  We hope that this work will also take the opportunity to take a fresh look at the outlandish jobs forecasts in the current version of the SHMA.  We believe that this work should result in an overall reduction in the housing allocation for Hart and the rest of the housing market area that includes Surrey Heath and Rushmoor.  This would be good news and should remove the threat of Surrey Heath and Rushmoor asking Hart to build 3,000 houses for them.  It is understood that this work will be completed early in the New Year.

Third, Hart District Council is embarking upon a process to identify additional brownfield sites across the district by consulting with town and parish councils.  It is unclear how long this process will take, but it is fairly clear it will not be complete by the time the Housing Options paper is due to be completed.  The council has still not committed to creating a proper register of brownfield sites across the district.

Finally, Rushmoor are still working on the results of the consultation they ran over the summer and are planning to publish a revised Local Plan for consultation early in the New Year, presumably taking account of the revised SHMA.

Pulling all of this together, it appears we are going to be consulted again on Housing Options which is to be welcomed, but the number of houses we need to accommodate will not take account of the latest thinking in the revised SHMA, nor Rushmoor’s revised plan nor will it take account of the total brownfield capacity in the district.  It also seems odd that the council is seeking to force through a new consultation on a compressed timescale in the run up to Christmas, which is a time most residents will be focused on other things.  All in all, a very murky process.