Hart keeps 10,185 housing target

Posted on September 30, 2017October 21, 2017

At Thursday’s council meeting it became clear that Hart Council is keeping the 10,185 housing target for now. We asked a number of questions (see below) about the new Government consultation which reduces Hart’s housing target to 292 dwellings per annum, compared to the 485 dpa in the draft Local Plan.

The basic answer from the council was that so far, this is just a consultation, so they are sticking with the ridiculous housing target. However, they didn’t give any indication that they were going to consider the lower target even as an option. We think this is a dereliction of duty.

Impact of new housing need methodology on Hart Local Plan

Impact of new methodology on Hart Local Plan

We are disappointed that this approach keeps our sensitive large green field sites at risk of inappropriate development. Sites remaining at risk include Murrell Green, Winchfield, Rye Common and Pale Lane (Elvetham Chase).

Local Plan Update

There is still no sign of the 1,200 responses to the Local Plan consultation being published. We were led to believe at Cabinet these would be shown to councillors at last week’s LPSG and published shortly afterwards. It is now nearly four months since the consultation completed, so there can be no excuses.

Hart News Local Plan update

Questions to HDC 28 September 2017 about Hart Housing Target

Q1: Recently the Government launched a consultation on a new method for calculating housing need. If this new approach was adopted Hart’s target building rate would fall to 292 dwellings per annum, compared to 382 in the SHMA and 485 in the draft Local Plan. How does HDC plan to respond to this consultation?

A: There could be benefits to having a standard approach to assessing the need for housing, but
a formula drawn up by the Government can never fully understand the complexity and
unique needs of local housing markets, which vary significantly from place to place. It is
crucial that councils and communities can lead new development in their areas.

The consultation runs until the beginning of November and we shall use that time to assess
the robustness of the government’s draft proposals to understand how it would meet all our
housing needs such as the need locally to deliver affordable homes for example. We intend
also to work with out Housing Market Area Partners and with other partners, such as the
District Council Network and the Local Government Association, to formulate our
response to the consultation.

Supplementary: Will you make the consultation response public, and if so, when?

A: We will endeavour to put as much in the public domain as soon as possible.

Q2: The same consultation (Table 1 and Para 54) indicates that councils with no Local Plan should start to use the new methodology immediately. What steps have the Council taken, and what steps will you take to adopt this new method and when?

A: The point about using the methodology immediately is not strictly true. The Government’s
paper is a consultation only on a possible standardised methodology. Clearly one cannot
prejudge the use of a possible methodology prior to the end of the consultation whilst also
speculating on the outcome. In any event, the consultation makes it clear that only if
adopted, the new methodology will only take effect for Local Plans submitted either after
1 April or when the new revised National Planning Policy Framework (NPPF) is published
(whichever is the later). It would clearly therefore be premature at such an early time to
start to speculate wildly about the possible use of an methodology that has not yet even
been agreed.

Q3: Both Rushmoor and Surrey Heath have also seen their housing targets reduced by the new methodology by 142 and 30 dpa respectively. Rushmoor have already said they will accommodate their original, higher figure. Will Hart still need to consider building additional houses for Surrey Heath?

Significant reduction in Hart Housing need

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

A: The Governments’ paper is a consultation and consultation only – one should not speculate
about the outcome. It would therefore, be totally unwise to start to speculate about how
our market area partners would react to the consultation and what that may mean for
future unmet housing needs particularly as Surrey Heath is already well behind in meeting its
current needs.

Q4: The consultation says (Para 46) that Inspector should work on the assumption that the approach to calculating housing need is sound, if the plan calls for more houses than the standard method would provide. What does HDC now consider to be the most appropriate housing target to plan for in the Local Plan?

New Government housing methodology – impact on planning inspectors

A: The current arrangements for calculating housing need remain in place until such time as the
methodology for calculating housing need is changed by the Government. The objectively
assessed housing need for Hart remains at 382 new homes/annum but we agree with the
previous administration that an affordable housing uplift is essential and that we should be
planning to deliver at least 485 new homes/annum.

Supplementary: The total of the Government housing targets for each planning authority amounts to ~266,000 dpa, in line with national needs identified in ONS figures. In the draft Local Plan, Hart is planning for more than twice the demographic requirement in the local ONS numbers. If this was repeated across the country, it would result in over 500,000 dpa, so what justification is there for keeping Hart’s planning target at 485 dpa, given that the new 292 dpa target already includes an affordable housing uplift to the base demographic requirement?

A: Not all districts are the same and we are not starting from the same point, This
consultation ends in November, with the results not available until the new year, and we
need to progress our local plan process rather than waiting for these consultation results. If
you need more detail please get in touch with me and I will try to help.

CPRE concerned about new Government housing targets

Posted on September 27, 2017September 27, 2017

CPRE concerned about new Government housing targets.

In an article appearing in today’s Fleet News and Mail, the CPRE is concerned about new Government housing targets.

The Fleet N&M has picked up on our article that shows Hart’s housing target will fall to 6,132 new dwellings under new Government proposals. This compares to the Hart’s current Local Plan total of some 10,185. The total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022.

CPRE is concerned about the impact of the new guidelines in southern and east Hampshire and in Basingstoke and Deane. Whilst we share some of this concern, we are delighted about the result for Hart, RUshmoor and Surrey Heath.

We have asked some questions of council that will be tabled at tomorrow’s meeting, so we will find out how Hart plans to respond to these new proposals.

The full Fleet N&M article can be found here.

Hart misses another Local Plan deadline

Posted on September 23, 2017September 22, 2017

Hart misses another Local Plan deadline

Hart Council has missed another Local Plan deadline. According to reports we have heard of Thursday’s Local Plan Steering Group (LPSG) Meeting, there was no discussion of the results of the recent Local Plan consultation.

Apparently the responses were still being analysed. At the 7th September Cabinet meeting, we were led to believe the consultation responses would be discussed at the LPSG and published shortly thereafter. This continues the trend of Hart Council missing every deadline it sets itself.

This means the Council has missed another self-imposed deadline which puts at risk the overall timetable for the Local Plan. The Regulation 19 consultation is due to start in January 2018.

Previously, councils were threatened with having their housing need determined for them if the Local Plan is not in place on time. However, as we reported here, this threat is now lower for Hart. The new Government consultation results in much lower housing need for Hart at 6,132 over the plan period. This compares to the SHMA at 8,022 and the draft Local Plan at 10,185.

It isn’t clear whether prior Government threats to withhold the New Homes Bonus if councils don’t get their act together are still in force.

However, having out of date policies and no Local Plan means Hart is at the mercy of speculative applications from developers.

Cross Farm application withdrawn

Posted on September 20, 2017September 20, 2017

Cross Farm planning application withdrawn

Cross Farm Site Layout

The planning application for a 160-unit Care Village at Cross Farm has been withdrawn. This comes hot on the heels of our report a few days ago where we said the appeal for this site had been withdrawn.

The details of the application can be found here, or going on the http://publicaccess.hart.gov.uk/ website and searching for 16/03400/OUT.

Impact of Cross Farm Withdrawal

The withdrawal is of course good news for residents of Crookham Village. This area has seen significant development in recent years.

However, it leaves the Hart Local Plan in some difficulty as this was one of the flagship sites in the recent consultation. But, things may not be too bad as the Government has announced a new methodology for calculating housing need that should lead to a significant reduction in Hart’s housing need. If this new methodology is adopted, none of the green field sites in the Local Plan consultation will be required.

We await further developments.

Hart major planning site update

Posted on September 17, 2017October 7, 2017

Hart major planning site: Hartland Park (Pyestock) Master Plan

This post will provide a Hart major planning sites update. We will cover:

Hartland Park (Pyestock)
Pale Lane (Elvetham Chase)
Grove Farm (Netherhouse Copse), Fleet
Cross Farm

Hart Major Planning Site: Hartland Park (Pyestock)

The first Hart major planning site is Hartland Park. This is the site of former Pyestock National Gas Turbine Establishment. Hart Council’s planning committee has agreed to the principle of building up to 1,500 new homes on this brownfield site.

Hart Major Planning Site: Hartland Village

The decision is subject to a number of conditions:

Hampshire County Council withdrawing its highway objection.
Confirmation of viability issues associated with affordable housing.
Securing appropriate SANG land.
Further consideration by the Major Sites Sub-Committee.

Our views on Hartland Park

We agree with this decision in principle, but echo the council’s concern about a number of items:

The developer is proposing only 20% Affordable Housing. We would like to see more affordable housing and especially some social housing for those who can’t rent and can’t buy.
We are concerned about the road network and therefore think Kennels Lane should be upgraded to provide a relief road around the site
There should be a proper cycle/walking route installed to provide easy access to Fleet station.

We will continue to monitor this development.

Full documents on Hart’s planning site can be found here.

Hart Major Planning Site: Pale Lane (Elvetham Chase)

Pale Lane (Elvetham Chase) planning application dates

Second up is Pale Lane aka Elvetham Chase. This is an application for 700 new houses near Pale Lane, between Elvetham Heath, the railway and the M3. The controversial planning application was submitted for this site back in November 2016. The deadline for determination passed months ago, but it seems as though the agreed date for determination was changed to September 15 2017 by agreement with the developer. Sadly, no decision has been forthcoming because the site wasn’t even considered at the planning meeting held on 13 September.

There is therefore a risk that the developer will launch a “Non-Determination” appeal just like those that were launched for Grove Farm (Netherhouse Copse) and Cross Farm.

Consequently, we are concerned that the council seems to be missing the deadlines for these major applications.

Full documents on Hart’s planning site can be found here.

Hart Major Planning Site: Grove Farm (Netherhouse Copse)

[Update] This site has been approved for development by the planning inspector [/Update] The third Hart major planning site is Grove Farm (Netherhouse Copse). This is an application for 423 new houses on the site off Hitches Lane in Fleet. The appeal for this site was heard back in July. The Planning Inspectorate had published a document on its website saying the appeal decision would be made public on September 15 2017.

Grove Farm (Netherhouse Copse) Appeal Dates

Sadly, this deadline has not been met. We Heart Hart understands the decision will now be made on or before October 6 2017, although the website is now ambiguous.

Full documents on Hart’s planning site can be found here.

Grove Farm (Netherhouse Copse) Appeal

We can live in hope that the Government’s announcement on the new housing need methodology will influence the decision in a positive way.

Hart Major Planning Site: Cross Farm

[Update] The appeal and planning application have been withdrawn] Finally, we have Cross Farm. This is an application for a 160-unit care village in Crookham Village. This was supposed to be determined a few months ago. The council failed to make a decision on time and the developer launched an appeal. The council did say it would fight the appeal, going against it’s own draft local plan.

Cross Farm Appeal withdrawn

However, it now appears as though the appeal has been withdrawn, so it isn’t clear whether the site will be in the next version of the Local Plan or not.

Full documents on Hart’s planning site can be found here.

Conclusion

All in all this is mixed news for the Hart major planning sites. First of all, we are pleased Hartland Village has passed one of the planning hurdles. Yet, we are concerned about the lack of decision on Pale Lane (Elvetham Chase). It is frustrating that no decision has been made in the Grove Farm (Netherhouse Copse) appeal. Finally, the Cross Farm application seems to be in limbo, with no formal decision by the Council and the withdrawn appeal.

We do hope that the three green field sites are dropped as a result of Hart’s housing ‘need’ being reduced due to the new Government methodology.

New Government methodology to reduce Hart housing need

Posted on September 15, 2017September 22, 2017

Time to celebrate reduction in Hart housing need

New Government methodology reduces Hart housing need

Yesterday, the Government published a consultation (Planning for the Right Homes in the Right Places) on its proposals to simplify and standardise the calculation of housing need. The good news is that Sajid Javid’s new methodology, if adopted, will result in a significant reduction in Hart housing need. There are also reductions for Rushmoor and Surrey Heath.

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

Impact on Hart Housing Need

If this proposal was adopted, the full housing requirement for Hart would fall to 6,132 new dwellings. This compares to the Hart’s current Local Plan total of some 10,185 and the total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022. The new target of 6,132 is above the 5,144 we recommended in the recent Local Plan consultation. But, clearly, if the new figure of 6,132 was adopted, we would welcome it.

The Government now calculates housing need on the basis of the most up to date demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings.

This vindicates the stance we have been taking for years now: Hart’s housing target is ridiculous. The current SHMA takes out of date demographic projections and makes lots of spurious and arbitrary adjustments that don’t address the needs of the district. Then Hart Council added a further 2,000 houses to that. This new approach proposed by the Government is much more sensible.

Impact on Rushmoor and Surrey Heath

This is also good news for Rushmoor and Surrey Heath. Rushmoor’s overall housing target reduces by 2,982 houses. Rushmoor has already said it can meet it’s current target, so this leaves it with significant extra capacity.

Surrey Heath’s target reduces by 630 houses. Surrey Heath has said it will endeavour to meet its current housing target, but if it can’t, then Hart and Rushmoor would be expected to make up any shortfall. Previous estimates of their shortfall were around 1,400 houses. These new proposals make any problems Surrey Heath has much easier to solve.

Taken together, these reductions are very welcome and reduce the risk that Hart will be forced to take any overspill from Surrey Heath.

Impact on the Hart Local Plan

There is further good news. If the current Local Plan is more than five years old or if the new Local Plan is not submitted by 31 March 2018, then the new methodology must be used. This means that Hart should start considering this new methodology immediately.

Impact of new methodology on Hart Local Plan

If the new methodology was adopted, then the Hart housing need drops and Hart would need to build far fewer houses. According to the recent Local Plan consultation, a total of 5,594 houses have already been built or planned for as of January 31 2017. This would 600-700 houses left to plan for, maybe a few more to give scope for taking Surrey Heath over spill. In round numbers, let’s assume 1,000 houses left to plan for. Planning for a few more houses than those demanded by the standard method would mean that the Inspector would have to work on the assumption that the Plan was sound.

New Government housing methodology – impact on planning inspectors

This could be easily made up from brownfield sites in the draft Local Plan. Sun Park (320) and Hartland Park (1,500) would more than meet the remaining need, with plenty of room to spare. This would mean Hartland Park could be built at a slower rate.

The implication of this is that we would need no new settlement. No building at Murrell Green, no new settlement at Winchfield or at Rye Common. Furthermore, Pale Lane (Elevetham Chase) and Cross Farm wouldn’t be required. It remains to be seen whether the inspector will take account of this new methodology to save Netherhouse Copse (Grove Farm) in the current ongoing appeal.

Impact on Neighbourhood plans

In a further piece of good news, the Government proposes that the way housing need in Neighbourhood plans is calculated should be simplified. It says that it should be based on the proportionate population of the Neighbourhood planning area.

New Government housing methodology – Neighbourhood plans

This is essentially the same proportionate method that we have been advocating for some time. It will finally mean that David Cameron’s promise that local areas should not simply have new housing estates dumped upon them will be met. This proposal will also effectively mean that existing urban areas should become more dense. This is another policy we advocated in the recent consultation.

Note of caution

So far, this is just a consultation and is not yet adopted. There is therefore a risk that developers will seek to water down the proposals or amend them. We have done a quick analysis of the Government spreadsheet and that shows that roughly half of Local Authorities have had their targets increased and roughly half have seen a reduction. Overall, the housing need identified by the Government is about 266,000 houses per annum, in line with previous estimates of overall national requirements. So, in our view, developers don’t have much of an argument – the proposals seem to redistribute the housing targets where they are most needed.

Moreover, there are some potential pitfalls in planning for certain groups such as the elderly and affordable housing in paras 89 & 90. However, this is really about how to get the total to add up, rather than changing the total.

Conclusion

Overall, we think that if these proposals are adopted it is very good news for Hart, Rushmoor and Surrey Heath. The new Hart housing need would be very achievable and would save many of our precious green fields that are under threat.

We would urge you to respond to the Government’s consultation and give it your support.

We also expect the council to set to work immediately to revise the draft Local Plan to take account of these new developments. This should be easy. They are already planning for far more houses than we need, so striking out the controversial green field developments should be a relatively simple task.

Hart edges towards Murrell Green development

Posted on September 14, 2017September 13, 2017

Murrell Green near Hook and Hartley Wintney Framework Plan.

Hart edges towards Murrell Green development

Last week’s Cabinet meeting led us to believe Hart is edging towards favouring the Murrell Green development as a new settlement option. Minutes here.

The meeting received the note of the meeting (as reported on here) that took place in August to discuss the new settlement options. These were Murrell Green, Winchfield and Rye Common. The backers of Rye Common did not leave any materials that could be published. This indicates that this proposal is not well developed and so it very unlikely to be adopted. We heard a couple of anecdotes that the Winchfield presentation did not go well. This leaves the Murrell Green development as the remaining option for a new settlement.

It was clear the councillors did not want to talk about the content of the presentations. Instead, they focused on process matters, satisfying themselves that the presentations and the note of the meeting covered all of the points raised in the meeting.

James Turner of Lightwood Strategic who are the backers of Murrell Green was at the Cabinet Meeting. He explained they have a plan to deal with the gas main issue. They plan to run a stronger gas pipe, encased in concrete along the route of the spine road. They think this will cost around £2m, and the developer will fund it.

Alternatives to Murrell Green Development

We did put to the Cabinet that the only reason they ‘need’ a new settlement is because they are pursuing the ridiculous 10,000+ housing target. Even the 8,000 figure in the Strategic Housing Market Assessment is too high. We are not confident that the council will reduce the housing target to a more sensible figure.

The results of the recent Local Plan consultation will not be published until later this month.

We do hope they take on board our representations to:

Reduce the housing target to a more sensible figure
Focus on brownfield development
Take the opportunity redevelop our town centres, like Rushmoor is doing

We can live in hope.

Rushmoor leads urban regeneration push

Posted on September 13, 2017January 13, 2018

Rushmoor leads urban regeneration push

Leader of Rushmoor Council, Dave Clifford has published an article in Get Surrey, setting out how the council is tackling urban regeneration in Aldershot. Full article here.

He acknowledges the challenges facing town centres from increased internet shopping. Their response has been to produce a prospectus for Aldershot town centre. This includes a joined up plan to support redevelopment of areas such as Westgate and the Galleries. But they have also taken a leadership position by acquiring properties on Union Street. This is part of a plan to consolidate ownership, so a redevelopment plan can be put together.

There is much to be done, but it is clear Rushmoor is rising to the challenge.

Well done Rushmoor.

Hart is missing an opportunity

Hart Local Plan to regenerate urban centres

This is in stark contrast to Hart Council. The recent Local Plan consultation acknowledged “The delivery of town centre redevelopment opportunities must be a priority”. However, no significant proposals were put forward to improve the town centres of Fleet, Blackwater, Yateley or Hook. We did put forward some ideas on this in our response to the Local Plan consultation.

It remains to be seen if the new administration has the vision and the political will to tackle these issues.

Developers battle over new settlement options for Hart District

Posted on September 2, 2017September 2, 2017

Battle of the Bastards – the fight for new settlement options for Hart District

A trio of developers have commenced battle over new settlement options for Hart District. There was a meeting of senior councillors on 9 August 2017, where developers representing three potential new settlement sites made presentations. These presentations will be discussed at Cabinet on Thursday 7 September at 7pm. The three sites were:

Rye Common
Murrell Green
Winchfield

Minutes from the meeting have been published on the Hart website and here.

New settlement options for Hart District – Rye Common

The developer raised the following points regarding their presentation:

The site could deliver up to 1,500 with possible potential to expand to 2,000 homes if more land were to be made available.
The site is in one ownership.
Only a small part of the site was within 5km of the SPA. SANG provision included in the proposal.
Design and some technical evidence is at an early stage due to a change in supporting consultants.
No secondary school site proposed, although a site of 5ha could be made available in line with HCC guidelines.
Some areas of Common Land would need to be de-registered to provide access and re-provided elsewhere.
A range of infrastructure to be provided including primary education facilities.
Site has areas of groundwater flooding, but no fluvial risk.
Access on to the A287.
Site would provide open space, allotments etc.
There would be no coalescence issues.
Small scale employment provision included.

The actual presentation that was given has not been published on the Hart Council website. Overall we view this as a very weak proposal that clearly is not as well thought through as the other proposals.

New settlement options for Hart District – Murrell Green

The presentation and other documents related to this proposal can be found on the links below:

Murrell Green – Written Opinion from Anthony Crean QC
Murrell Green – Framework Plan
Murrell Green – Vision Document
Murrell Green – Letter from Crest Nicholson
Murrell Green – Letter from Bosch
Murrell Green – Q and A response

Murrell Green Framework Plan with pipeline

The main points made by Lightwood, the developer in the presentation were:

The site can deliver 1,800 -2,990 units if required
Plans and evidence are well advanced
Developer already on board for first phase
In partnership identified proposals to include innovative initiatives within the home and related to travel options, including for electric and driverless cars and provision of electric bikes as central to the masterplan
Connectivity through access to the A30
Revised secondary school location proposed (9.7ha) with direct access in and out of the site and avoiding residential areas proposed in discussion with HCC
A range of infrastructure to be provided including primary education facilities
Discussions held with Stagecoach re possible bus routes
Access to Winchfield station will be provided
Promoters control a significant proportion of the site through option agreements
High proportion of 2 and 3 bedroomed dwellings
A proportion of dwellings will be designed to be easily extended to prevent the need to move
There are viable solutions to ensure that the gas pipeline is not a constraint on development
Small scale employment proposed on site
Supportive of the use of design codes
High speed broadband to be included
Design/layouts will ensure protection of the setting of the listed building
Open space includes SANG provision, sensory gardens, allotments, sports pitches

We have read these documents and think there are significant problems with this proposal. First, the design proposals still ignore the presence of the high pressure gas main. They make passing reference to re-routing it, but come up with a cost of only £2m. This seems like a very low figure to re-route about a mile of 24″ high pressure pipeline.

Second, the site is being promoted by Lightwood Strategic, which is, in our opinion quite a lightweight organisation with negative net assets. They have entered into some sort of arrangement with Crest Nicholson, but at this stage all of their promises must be taken with a very large pinch of salt.

Third, they make great virtue out of the Amount of SANG they are delivering. Yet, in other parts of the document they offer up some of this land for even more housing. They aren’t quite specific, but the area they identify to the south and west of the site includes the former landfill site at Beggars Corner.

Finally, the roads proposals are totally inadequate. The access to the south is over the tiny bridge over the railway line and the A30 will become a bottleneck in Hartley Wintney and Hook with the addition of 2,000 further houses between them.

The other significant part of the Lightwood presentation was the legal opinion from their QC. This is clearly designed to warn other developers not to send Hart’s Local Plan for judicial review. It is also a warning to local pressure groups to let them get on with their proposals without hindrance or the Local Plan may fail, leaving Hart open to new, even higher housing numbers from the Government.

New settlement options for Hart District – Winchfield

Finally, Gallagher Estates and Barratt Homes made their presentation about the Winchfield proposal.

Winchfield Garden Community Master Plan with pylons and powerline

The main points made by the developer in the presentation were:

A scheme for 1,800 homes presented but opportunities to expand to 2,400 to west and south west
All land under control of the promoters
Technical work including viability very advanced
Neighbourhood centre to north of railway line
Engagement with Stagecoach
A range of infrastructure to be provided including primary education facilities
Shuttle signals to be added on road tunnel under railway, will allow for 3m pedestrian/cycle access
14ha proposed for a secondary school, in discussion with HCC
Solutions proposed to deal with identified flooding issues
Transport modelling work undertaken to prevent rat runs
A unique situation as focused around a railway station

The main problem with this proposal are:

Gallaghers totally ignore the electricity pylons traversing the school sites and the housing both to the north and south of the railway line.
The flood risk on that land is very significant, with the site and roads flooding three times in 2016 alone. They can’t just dismiss this with a single bullet point.
The roads proposals to get into and out of the proposed development are totally inadequate.
The proposal includes a footpath from the B3016 to Bagwell Lane and the western part of the development which is not currently a footpath and crosses land that is not in the ownership of the consortium.

Our Response

Overall, we think the motive behind these presentations is for the council to be able to say it has studied all of the options in detail.

Our view is that all of these proposals are unnecessary because they only arise from the Council’s insistence on setting a housing target of over 10,000 units, despite the over-inflated SHMA figure of 8,000. If we just reverted back to the SHMA figure, then none of these new settlement proposals will be required. Indeed, if we reverted to a more sensible housing target of 5,144, we could meet all of our housing needs for decades to come form brownfield sites alone.

We think that there is going to be a big battle ahead. The developers are going to fight to get their proposal into the Local Plan. We will continue to fight to reduce this ridiculous housing target and get more of our housing need met on brownfield sites.