Local Plan: Brownfield sites protected from redevelopment

Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Council protecting from redevelopment.

Brownfield sites protected from redevelopment

The draft Local Plan put forward by Hart Council includes proposals to make brownfield sites protected from redevelopment. We think this proposal is bonkers and should be challenged in the consultation.

There are two different types of protection proposed in the Local Plan. The first identifies “Strategic Employment Areas”:

  • Bartley Wood, Hook
  • Bartley Point, Hook
  • Cody Park, Farnborough
  • Meadows Business Park, Blackwater
  • Osborne Way, Hook
  • Waterfront Business Park, Fleet

These sites are “given the highest protection and safeguarding against loss to non-B-class employment uses by protecting them for B-class uses”. We would agree that some of these sites should be given some protection. But some of the sites, particularly in Hook suffer from high vacancy rates. Indeed, some of the sites have already been converted to domestic use.  Recently the owners of the Virgin Media offices at Bartley Wood have sought advice on whether planning permission would be required to convert some of those buildings to housing. This demonstrates that there is little demand for offices on even the sites of alleged ‘strategic’ importance.

The trouble with this policy is that it cannot stop conversion of offices to apartments. These types of development require no planing permission. Nor do they bring any S106 or CIL contributions to infrastructure. Moreover, they don’t provide an attractive sense of place. By preventing proper redevelopment Hart is cutting off vital infrastructure funding. This makes no sense whatsoever.

The second type of protection is to “Locally Important Employment Areas”:

  • Ancells Business Park, Fleet
  • Blackbushe Business Park
  • Eversley Haulage Yard
  • Eversley Storage
  • Finn’s Business Park, Crondall
  • Fleet Business Park, Church Crookham
  • Grove Farm Barn, Crookham Village
  • Lodge Farm, North Warnborough
  • Murrell Green Business Park
  • Potters Industrial Park, Church Crookham
  • Rawlings Depot, Hook
  • Redfields Business Park, Church Crookham
  • Optrex Business Park, Rotherwick

These sites are offered a lower level of protection, but nevertheless the council is putting in place barriers to redevelopment.

Poor brownfield sites should not be protected from redevelopment

The reason this is a bad policy is that the Local Plan itself, as well as the Employment Land Review (ELR), acknowledges that there is an over-supply of low grade office space (para 125). The ELR states that investment in this stock is unviable (para 6.17):

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Owners of these sites have three choices. First they can keep the wasting asset and collect no rent, which is not an attractive commercial proposition. Second, they can convert the offices into flats. By and large, they need no planning permission for this. However, these types of development carry no obligation for S106 or CIL payments to councils. Nor do they deliver a good ‘sense of place’. Finally, they could apply for planning permission to properly redevelop these sites into attractive homes, with a particular focus on affordable homes for the young. These types of development will be high-density, but with a good sense of place, and will attract some funding for infrastructure.

The consequences of this policy will be to discourage redevelopment of sites and either lead to more sites being simply converted or worse, sitting idle as eyesores.

We believe this policy should be reversed, particularly as it is a direct contravention of a statement made by the council leader, who said there were no plans to restrict the development of brownfield sites at a council meeting in September 2016:

https://www.hart.gov.uk/sites/default/files/4_The_Council/Council_meetings/M_Archive/16%2009%20Council.pdf )

Please respond to the Local Plan Consultation

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to planningpolicy@hart.gov.uk before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation

Breaking News: Hart proposes new settlement at Murrell Green

Murrell Green new settlement proposal

Proposed new settlement at Murrell Green

Hart District Council has proposed a new settlement at Murrell Green as part of its spatial strategy for the Hart Local Plan. This was debated at a meeting of the Local Plan Steering Group last night. The proposal is expected to be agreed at a special Cabinet Meeting to be held on 9 February at 8pm.

The new settlement contains a site for a proposed new secondary school, outlined in yellow in the image above.

We are delighted that the new settlement at Winchfield will not form part of Hart’s strategy.

However, we are disappointed at seeing Murrell Green being put forward as a solution.

[Update] Concerns have been raised about the viability of the proposal [/Update]

Brownfield Capacity

At the council meeting last week, the Leader admitted that Hart now estimate the brownfield capacity at 2,126 dwellings. This excludes the former police college at Bramshill.

HDC Question about brownfield capacity

A realistic assessment of the capacity of Bramshill is around 250 units, bringing the total up to 2,376. However, sadly, Moulsham Lane has been given the go ahead (150 units). This would mean we would have capacity to meet even the over-stated remaining requirement of the old Strategic Housing Market Assessment (SHMA) on brownfield sites alone.

New SHMA overstates the true housing requirement

However, it now appears as though the council has caved in to demands to build even more houses that we don’t need. They have agreed to an increase in our housing allocation to 8,022. On a like for like basis, this leaves us short by 462 units.

This shortfall might well be met by the Netherhouse Copse application (436), which we now understand has been appealed by the developers on the grounds of non-determination. So even with the new SHMA, there is no need for a new settlement at Murrell Green.

At council last week, the leader refused to answer our questions about the reasonableness of building houses to increase inward migration to the district, when many of those people would work outside the district and thus put pressure on infrastructure.

HDC Question about housing numbers

The assumptions I put forward are all in the new SHMA, see here.

We need to challenge this new SHMA and resultant spatial strategy strongly. This will ensure we build the right number and right type of houses to meet local needs, rather than needlessly concrete over our precious green fields.

The full minutes of the council meeting can be found here.

 

 

 

Hart Local Plan: Green fields or fictitious jobs?

 

Should Hart concrete over its green fields for the sake of uncertain jobs forecasts

It is now becoming clear that the forthcoming Hart Local Plan will present us with a choice of concreting our green fields versus building houses for people who live elsewhere and many of them will work outside the district.

We have now had the opportunity to read the new Strategic Housing Market Assessment (SHMA) in more detail, and in particular the detail of the main driver of the housing target uplift: the jobs forecast. We have found:

  1.  The jobs forecasts uplift SHMA calculations increase the overall housing requirement for the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath by 22% over and above those required by demographics and making allowance for market signals
  2. The National Planning Policy Guidance (NPPG) does not require Hart Local Plan to accommodate extra housing if jobs forecasts are in excess of forecast workforce changes in the area.
  3. The SHMA calls the jobs forecasts ‘uncertain’ and ‘divergent’
  4. If we follow the SHMA, the Hart Local Plan will plan for jobs levels closer to the the extreme high end of the jobs forecasts
  5. That all of the alleged extra jobs will have to be filled by people coming from outside the district, and many of them will work outside the district. This will have a big impact on local infrastructure, particularly roads, rail, schools and healthcare facilities.
  6. Planning for around 900 extra jobs per annum would mean we could meet our remaining housing needs from only brownfield sites
  7. The SHMA says that it would be a more sustainable policy position to plan for increased economic growth to come from productivity improvements, rather than adding lots of lower skilled jobs

This is clearly a ridiculous position, and Hart District Council should follow the advice of Peter Village QC, and consult on the level of employment we wish the Hart Local Plan to accommodate and offer us the choice of planning 900 extra jobs per annum to protect our green fields.

[update]

We would suggest the following approach to the consultation:

Option A, plan for 900 jobs per annum, and around 6,500-7,000 houses, which can be achieved on brownfield (Hartland Village, Bramshill and Sun Park) or

Option B, plan for 1,200 jobs per annum and >8,000 houses for which you will have to give up Grove Farm, and some other area like Murrell Green and/or Pale Lane or West of Hook

We think there would be overwhelming support for Option A, and we would still be planning for 250 extra jobs per annum than the demographics would suggest, so meeting the requirement for positive development.

[/update]

We set out our analysis below.

What does the NPPG say we must do?

As can be seen below, the NPPG simply asks that plan makers ‘consider’ what they should do if the jobs forecasts are in excess of the forecasts for working age population. In particular, it asks for both housing and infrastructure to be considered.

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

Indeed the SHMA itself says that the NPPG does not require plan makers to make any uplift in housing numbers at all.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.50 NPPG does not require housing uplift

SHMA 11.50 NPPG does not require housing uplift

So, whilst the impact on housing and infrastructure should be considered there is no requirement to to actually increase the housing numbers.

What do the jobs forecasts say?

There is a wide range of jobs forecasts ranging from 910 pa (Experian), through 950 pa (Cambridge Econometrics) to the extreme forecast of Oxford Economics at 1,480 per annum.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Section 5 summary range of forecasts

SHMA Section 5 summary range of forecasts

The SHMA acknowledges that the housing numbers required are extremely sensitive to the jobs growth assumptions made

SHMA 11.1 wide spectrum of forecasts

SHMA 11.1 wide spectrum of forecasts

The SHMA calls for us to plan for 1,200 extra jobs per annum which is closer to the extreme high end of the Oxford economics forecast.

What does the SHMA say about the Employment Forecasts?

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

The SHMA says that there is genuine uncertainty about the scale of jobs growth that might be expected and the forecasts are widely spread and divergent.

Where would the people come from and where would they work?

We are told that the extra people to fill these jobs would come from other areas:

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment SHMA 11.56 Population growth from inward migration from other areas

SHMA 11.56 Population growth from inward migration from other areas

If other local authorities are following NPPG, they should already be planning housing for these people. Indeed we have found that many planning authorities are planning for an average of 42% more housing than demographic trends would suggest they need.

But it gets worse, in that the SHMA would lead to many of these inward migrants working outside the district, putting unsustainable strains on the transport network. We already know the rail network is forecast to be running well over planned capacity with no real plan to fix it.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.51 Excess housing supply could lead to extra out commuting

SHMA 11.51 Excess housing supply could lead to extra out commuting

Currently, more than half of Hart’s working population work outside the district and 40% of the HMA’s working population work outside the HMA.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.1 and S11.15 out commuting calculation errors

SHMA Figure 11.1 and S11.15 out commuting calculation errors

What would the Hart Local plan be if we planned for fewer jobs

If we planned for closer to 900 extra jobs per annum, we would need 950 houses per annum in the HMA. Hart would need 305 per annum, leading to an overall housing requirement of 6,405 which would mean we wouldn’t need any more green field sites.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figures 11.13 and 11.14 housing projections for range of job growth

SHMA Figures 11.13 and 11.14 housing projections for range of job growth

Taking account of market signals, the housing requirement for the HMA would be around 1,050 per annum. This would lead to Hart’s overall need being around 7,000. Again, we wouldn’t need any more green field sites to meet this requirement.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

What does the SHMA say about economic growth?

The SHMA says it would be more desirable to achieve economic growth through productivity enhancements and it would be a more sustainable solution.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.55 Better to achieve economic growth through productivity improvement

SHMA 11.55 Better to achieve economic growth through productivity improvement

So, why don’t we go for a more sustainable solution and plan for 900 extra jobs per annum?

New Hart SHMA published: housing target rises despite falling population projections

The Scream - 2016 New Hart SHMA also covering Rushmoor and Surrey Heath

The 2016 new Hart SHMA also covering Rushmoor and Surrey Heath has been published and Hart’s housing target has been increased from 7,534 to 8,022. This increase comes despite the forecast population for 2032 being lower than assumed in the 2014 SHMA.

For those uninitiated in the terminology of the Local Plan, the SHMA is the Strategic Housing Market Assessment. This is the totally objective document that is entirely above any criticism because it is produced by consulting only those who have a vested interest in building more houses.

Just like the last SHMA, a number of spurious assumptions and arbitrary uplifts have been applied to artificially increase the housing target to 53% above what we would need if we stuck to the demographic projections.

Essentially, we are being asked to concrete over our green fields to build houses for people who need to move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. Other districts should already be planning to house those people.

Here is the summary of how they did it, followed by our critique of the methodology and results:

2016 new Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

Demographic Startpoint

They have used the 2012-based population projections to arrive at the 785 dwellings per annum for the whole housing market area (HMA), consisting of Hart, Surrey Heath and Rushmoor. This results in a housing need of 254 dwellings per annum or 5,334 for the whole planning period up to 2032. Already most of this target has been built or permitted in Hart. If we stuck to this, we would not need to grant permission on any of the sensitive green field sites like Grove Farm (Netherhouse Copse), Elvetham Chase (Pale Lane), Owens Farm (West of Hook), Murrell Green or Winchfield.

However, even this starting point is inflated. The new SHMA states that if they used the 2014-based population projections instead, then the starting point would fall by 94 dwellings per annum for the HMA as a whole. The target would fall by 41 dpa for Hart, or a total of 861 dwellings.

2016 New Hart SHMA Figure 6 Appendix H impact of 2014-based SNPP Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 6 – Appendix H: Impact of 2014-based SNPP projections

Market Signals Uplift

This starting point is then inflated for ‘market signals’ and affordable housing requirements. We agree that there is evidence that younger people cannot get on the housing ladder, or in some cases cannot even rent properties in the area because property prices are too high. The uplifts they recommend increase the target by ~15%, resulting in 903 dpa for the HMA and 292 dpa or a total of 6,132 for Hart. Again, the remaining target for Hart could easily be met from brownfield development at Pyestock (Hartland Village) and Sun Park.

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

However, we do challenge the methodology they have applied in this case. They run two scenarios to estimate the extra houses required to meet the needs of people who are apparently not forming households at the expected rate. These would result in a 7-14% increase in the number of houses.

However, they arbitrarily choose a 15% uplift, which is larger than either of their modelled scenarios.

Even the SHMA itself calls into question whether this uplift will actually achieve anything:

9.72…Of course, there is no way of knowing in advance exactly how improvements in housing affordability would increase household formation rates (if at all)

Moreover, there is no evidence at all that simply allocating more land for development will either increase the number of houses being built or reduce the price of housing. The same section shows that development land in Hart, with planning permission costs £4.1m per hectare (section 9.12). At Hart’s preferred housing density of 30 dph, this equates to the land cost alone of a new home being around £133,000.  Build costs, S106 contributions and a profit for the developer could easily see the sale price of new homes being around £400,000. If housebuilders cannot achieve this level of pricing, then they simply won’t build the houses.

Affordable Housing Uplift

Some further adjustments are then made to lift the housing target 985 dpa for the HMA, or a further 24 dpa (504 in total) for Hart resulting in a total of 6,636 over the whole planning period. Even if this adjustment were accepted, this would still be easily accommodated on brownfield land in Hart.

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

There are two issues with this approach. First, column G shows there is a net negative need across the HMA, but Rushmoor needs to find 84 dpa. These are arbitrarily shared amongst all three districts, even though there is no net need across the three districts as a whole. Second, the whole analysis appears to double count the housing uplift for market signals above in that the ‘concealed families’ are already accounted for in the market signals analysis.

Accordingly, we believe this adjustment should be removed from the calculation.

Jobs Growth Adjustment

The most egregious adjustments come from the jobs growth adjustments. The total housing requirement is increased to 1,200 dpa for the HMA. This results in 382 dpa for Hart or a total of 8,022 new houses over the planning period. This increase means it is likely we will have to allocate green field land for development.

We have a number of issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area.

Second, the projection of 1,200 jobs per annum is far in excess of the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, they use a very circular argument to account for the number of jobs. The argument is basically, the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs. So, they then decide we will need to import some extra people and those people will need houses. Clearly, this is not an expression of the ‘need’ for the district.

However, the population projections already assume inward migration from other areas and international migration from abroad. Note that since the Brexit vote, migration from the EU is likely to fall, so these projections may well overstate the level of international migration.

These additional people must be coming from other areas. However, we know from analysis of other authorities that they are also increasing their housing targets by around 42% above the demographic projections. So, the question remains, where will the people come from to live in the extra houses? All local authorities need to meet their own local needs, so if all local authorities plan for far more than they need, we will have too many houses, but we will have concreted over our countryside.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. And other districts should already be planning to house those people.

It is a farce. This adjustment to the housing targets should be removed.

2016 New Hart SHMA Conclusions

We believe a realistic housing target for Hart is around 6,000. This would meet the needs identified from the most up to date population projections and give a sensible allowance for additional houses to cater for ‘concealed households’ and the younger people who want to get on the housing ladder. Affordability will come from building more smaller properties and taking advantage of the Government Starter Homes Scheme.

This housing target will mean we can build all of our remaining requirement on brownfield sites and still have many brownfield sites available for future generations.

However, given the perilous state of the Local Plan, we can’t simply ask for this to be redone. We must argue in the consultation about the new Local Plan that the housing target in the SHMA is too high, and therefore the plan does not need to allocate as much green field land for development. We have no doubt that there will be a number of developers arguing for an even higher target.

The new Hart SHMA and appendices are available for download below:

Hart Rushmoor & Surrey Heath 2016 SHMA
Hart Rushmoor & Surrey Heath 2016 SHMA Appendices

 

 

 

 

Hart misses out on brownfield starter homes scheme

Berkeley Homes (St Edward) launches consultation site for new development at Hartland Village, aka Pyestock and Hartland Park

The Government has given the green light for thousands of starter homes to be built on brownfield sites across the country. Rushmoor is one of the 30 Starter Home Land Fund partnerships, but unfortunately, Hart District is not on the list.

The partnerships have been established under the government’s £1.2 billion Starter Homes Land Fund. This scheme supports the development of starter homes on sites across England. They will be built exclusively for first-time buyers between 23 and 40 years old at a discount of at least 20% below market value.

It is a real shame that Hart has not seized the initiative to be part of this scheme, when only last year it was saying:

Hart District Council is proud to be one of a number of local planning authorities who have agreed to first pilot the creation of a Brownfield Land register

Hart has also not yet published the results of their brownfield study. This was supposed to outline the art of the possible with a number of urban brownfield sites in Fleet.

It is also disappointing because Hart is not building enough smaller properties whilst over-building 4+bed houses. A real commitment to starter homes on brownfield sites would go a long way towards meeting the housing needs of the district.

However, all is not lost as the Homes and Communities Agency is seeking expressions of interest from local authorities who are interested in using their land to deliver homes at pace through the recently announced £1.7 billion accelerated construction scheme. This will see up to 15,000 homes started on surplus public sector land this Parliament.

Open letter to Ranil Jayawardena, Sajid Javid and Gavin Barwell

Ranil Jayawardena Stephen Parker and Michael Fallon meet at Pyestock (Hartland Park or Hartland Village

Below is the text of an open letter sent to our Local MP, Ranil Jayawardena asking for his help to make changes to national policy to help Hart come up with a more realistic Local Plan and help fend off the threat of too many houses.

Let’s see what happens.

Dear Ranil,

To date, I have been very impressed with you as our local MP. You seem to be well in tune with your constituents and your campaign to promote more brownfield development in our area is to be commended.

I know that, quite rightly, you are reluctant to get involved in local planning matters because they are the responsibility of the local council. However, I am writing to you today to ask for your support in changing some elements of national policy that should help Hart District Council produce a more realistic Local Plan.

There are four main sections to this letter:

  • Process and outcome of assessing housing need
  • Affordable housing
  • Infrastructure contributions
  • Suggested policy changes

The links in the text take you to more in depth research, mostly from the WeHeartHart.co.uk website, which I run, to support the assertions made. I have also copied this letter to the ministers responsible for this area of policy and the leader and joint-CEO of Hart Council.

Assessing Housing Need

 

The 2012-based government projections of population and number of households points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-150,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

However, there is increasing evidence that house builders have too strong an influence over the process that is leading to housing market assessments being artificially inflated to a level much higher than that required by the national household projections.

In Hart, the 2014 Strategic Housing Market Assessment (SHMA) is currently being revised to take account of more up to date population and household forecasts. However, I believe the process being followed will be largely the same as before.

The way it works is as follows. The raw household forecasts are subject to a set of dubious adjustments and convoluted calculations to arrive at a spurious objectively assessed ‘need’.  In the case of the 2014 SHMA, the outcome was ~7,500 houses. For the SHMA area as a whole this results in an uplift to the raw DCLG household forecasts of more than 50%.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 305,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”.  I did make a FOI request to the DCLG to provide the national figures, but this has been refused on the grounds that DCLG “does not hold this information”. Given the importance that is being placed on housing delivery, it is quite staggering that central Government is not collecting the data to allow it to monitor the results of its own housing policy.

The experience of the Hart, Surrey Heath and Rushmoor SHMA is by no means unique. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the baseline household projections of around 42%.

A further illustration of the absurdity of the calculations used in the 2014 SHMA is contained in its own appendix.  This clearly shows that if the more up to date 2012-SNPP number were used, the starting point for Hart would fall from 337 to 247 dwellings per annum or a fall of 1,800 units over the plan period.

Taken together, these results show that the process for producing the SHMAs is fatally flawed and cannot be justified.

There might be some justification if this process had actually resulted in more house building. But it is clear from a recent House of Lords report that it has not:

Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over 240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.

We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding

This is borne out by local experience, where as of 1 April this year there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

It is clear that creating ever increasing housing targets is merely encouraging ‘land-banking’ by builders, who then build at a rate to maximise their own profits.

Imagine my surprise to find out that one of the outcomes from Hart’s yet to be published revised SHMA is that the housing target is going to be raised again to over 10,000 units (although this is being further examined by the council). Yes, you read that correctly: despite the starting point being based on the more up to date population forecasts described above, that should result in a ‘need’ of 1,800 fewer houses, the target is going to be raised 30% above the earlier ‘need’ and nearly 100% above the new starting point.

Apparently, there are some further arbitrary adjustments, some other sophistry and some new guidance from Government about the provision of so called ‘Affordable Homes’ that means in order to satisfy a shortfall of ~800 affordable homes, we must build over 2,000 more new houses in total because the affordable component cannot be more than 40% of the total.

The consequence of this change is that it will inevitably mean we can no longer meet our remaining housing need from brownfield sites and will have to sacrifice great swathes of our beautiful countryside to satisfy some bureaucratic pen-pushers rather than the actual housing needs of the district.

This is plainly ridiculous and cannot be allowed to stand. But that leads me on to policy improvements  around ‘Affordable Homes’

 

Affordable Homes

 

Many in Government seem to hold the view that merely calling some houses ‘”Affordable” makes them so. This is clearly an absurd position to take.

Let’s take a local example in my own village.  Recently, Bewley Homes built around 90 new houses in a new development called Hartley Row Park at a reasonably sensible add-on to the village.

The lowest price for a 3-bed semi-detached home was set at £465,000. The lowest anticipated price of the 2-bed homes that were due to be released later in 2016 was £370,000. This means that the cheapest 3-bed house is 11.5 times median income, and the cheapest 2-bed home will be 9.2 times median income.  Even with a 20% ‘Affordable’ homes discount, the cheapest new properties will be totally out of reach of middle-income families in the district.

This is further compounded by the lack of measurement and poor controls over the size of properties bring built. There is clear evidence that Hart is under-building 1-bed and 3-bed starter homes and over-building 4+bed properties. This is doing nothing for the younger residents of Hart, whom the Local Plan is supposed to serve, yet encouraging even more inward migration from London into properties that locals cannot afford. Clearly, the controls needed are really a matter for the local council, but there may be something that can be done at a national level to mandate new developments to meet local needs.

However, there are some national policies that need to be examined, not least the ‘Help to Buy’ scheme, interest rates and QE.

As any economist will tell you, if you subsidise the price of anything, then demand will go up and prices will follow. I find it quite amazing that a supposedly free-market Conservative Government is borrowing to use taxpayers’ money in the HTB scheme to subsidise higher house prices, especially at a time when we still have a massive budget deficit.

But the bigger impact on house prices has probably come from ultra-low interest rates and QE. This inexorable flow of cheap money has artificially raised the price of all assets and property in particular. You cannot hope to bring house-prices to reasonable levels unless and until you address monetary policy.

 

Infrastructure Contributions

 

Hart, like many other places in the country is suffering from creaking infrastructure. Our schools are full, it is difficult to get appointments at the doctors and road congestion is increasing.

According to the latest figures available Hart is running a £78m infrastructure funding deficit, and this is probably an under-estimate as it was prepared before the current, let alone the new SHMA. Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It is true that many developments attract S106 or CIL contributions towards infrastructure. However, it is also clear that both ‘Affordable Homes’ and office conversions using ‘Permitted Development Rights’ deliver no such contributions. Overall, the policy mix has delivered a massive funding gap, yet we are expected to continue to even more houses, when the funding delivered is much less than the funding required to bring the infrastructure up to scratch.

This is clearly unsustainable and must change.

 

Suggested Policy Changes

 

As I see it you can help your constituents by demanding policy changes in several key areas:

  • The Government should collect and analyse all SHMAs across the country to monitor that the total of the local ‘needs’ is in line with the overall national totals
  • There should be some greater controls put on the way that seemingly arbitrary adjustments to the starting points are made to ensure they do not go too far above those levels. 20% would seem like a reasonable level to me.
  • Encourage builders to build existing planning permissions faster by introducing a charge equivalent to council tax rates when development has not completed after a specified period of time.
  • Stop subsidising higher house prices through HTB, QE and ultra-low interest rates.
  • Introduce a ‘planning gain levy’ on land owners who make significant windfalls from selling agricultural land for development to fund infrastructure. This would be similar to the original ideas behind “Garden Cities” where landowners helped fund infrastructure
  • Introduce S106/CIL funding for all new development. Every new home has people in it and they all use local infrastructure, so all new development should include some contribution
  • Introduce ‘open book accounting’ to each development and force developers to make increased S106 contributions if they make more than planned profit on a development.
  • Increase Government funding for smaller, local infrastructure projects such as road widening, junction improvement, bridge widening, school building and surgery building. This would be a much better use of money than building white elephants like HS2.

I do hope you find this letter constructive and helpful in understanding the impact of national policy on your local area.

May I wish you and your family a Merry Christmas and a happy and prosperous New Year.

 

Yours sincerely,

 

Time to work together to head off new Hart housing threat

Hart Housing threat: sites under consideration

Hart Housing threat: sites under consideration

Overshadowed by our earlier  story of CCH further delaying the Hart Local Plan was the news of the new Hart housing threat of our target being raised from 7,500 to over 10,000 new houses up to 2032. This comes on top of the potential financial costs of delay.

Details of how this has come about are sketchy. It is related to how Hart should respond to Government rules about how to deal with affordable housing. We understand Hart Council is working on a ‘topic paper’ to give a further explanation.

We have analysed the impact of this new target below. Sadly, most of the large, sensitive green field sites are potentially under threat once again.  In addition, it is likely that Hart would no longer have more than five years of land supply. This exposes us to the threat of speculative planning applications. If most of these additional houses end up being ‘affordable’, they won’t attract contributions from developers to fund vital infrastructure.

So, we have come to the conclusion that it is time for all the politicians and pressure groups to work together to fight off this new threat rather than spend their time arguing over where the new houses should go. This level of development will mean that substantially all of the district will be under threat for some time. Moreover, this increased rate of building will be carried forward into the new planning period making things even worse for decades to come. We need to demand three key actions:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. Challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. Pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

Impact of the Hart housing threat on sensitive sites

First we take a look at where we would need to build to meet this new target and compare it to last year’s consultation; the most recent land supply position and our estimate of a ‘fair’ housing target.

Impact of new Hart housing threat on Hart District sites

Impact of new Hart housing threat on sensitive sites

As can be seen above, if the housing target remains around current levels, our remaining housing needs can easily be met from brownfield sites such as Hartland Village (Pyestock), the sites Hart Council identified in the consultation, Bramshill House and some further redevelopment of Ancells Farm and Bartley Wood. Moulsham Lane, Yateley was given the go ahead at appeal over the summer.

For some reason related to the Hop Garden Road appeal, Hart decided to increase our housing requirement up to 8,022 houses.  This is achievable from the 4,000 units we have identified on brownfield sites. But the planners would need to be persuaded to:

  • Redevelop the area around the Harlington and Hart’s offices in Fleet for mixed use.
  • Bring the many other smaller borwnfield sites across the district into the equation.

Failing that, it is inevitable that one of the green field sites is chosen.  For the purposes of this analysis we have used Grove Farm/ Netherhouse Copse as that is up for determination at the moment and the officers have recommended it.

Our estimate of a ‘fair’ housing target is based on the work of Alan Wenban-Smith. This starts with the population projections which on their own would generate a housing need of 5,040 houses over the planning period. A generous allowance is then added for additional economic growth to arrive at a need of 7,140 houses. This is easily achievable on brownfield sites, with some left over for future periods. Note that the new housing target is twice the level of housing required to meet the projected population forecasts.

The new target of 10,177 houses makes it much more difficult to achieve on brownfield. Again, the brownfield capacity could be larger than indicated above if the councillors and planners were to finally deliver on their brownfield study. If they don’t, it is inevitable that most of the sensitive green field sites including Pale Lane (Elvetham Chase), the land west of Hook and one or more of Murrell Green, Winchfield, Lodge Farm or Rye Common come into the equation. As you can see this new housing target will impact everyone.

Impact of Hart housing threat on the land supply

In the absence of the Hart Local Plan and up to date policies, the only defence we have against voracious developers is the five year land supply. This gives some limited control over speculative planning applications. So, we have taken a look at what the new target will mean for our five year land supply.

Impact of new Hart housing threat on 5 year land supply

Impact of new housing target on Hart District 5 year land supply

The left hand columns show the current 5-year land supply that Hart Council use. This shows we are in the relatively comfortable position with over 6 years land supply. If We Heart Hart’s fair housing target was adopted this would rise to 8 years supply.

However, the new housing target would reduce our land supply to below the crucial 5-year threshold leaving Hart very exposed. We would need another 525 additional houses to be granted permission ASAP to bring us back over the threshold.

Conclusion

We are in a very serious position with many of our cherished green fields under grave threat from speculative planning applications. There is no Local Plan and our policies are out of date. Hart is running an infrastructure funding deficit of £78m. The new housing target is double what we need to meet the official Government population forecasts. If the new housing target is adopted, Hart will no longer have a five year land supply. Unless we change tack, all our green fields will be concreted over and lost forever.

To preserve all that makes Hart such a great place to live we need to take serious action:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. We need to challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. We need to pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

This can only be done by everyone with a stake in Hart housing development working together to get the best outcome for Hart.

CPRE says most sites yet to be identified on Hart brownfield register

CPRE Hampshire Logo

The CPRE (Campaign for the Protection of Rural England) have been analysing Hart’s brownfield register. The have concluded that most of the brownfield sites without planning permission are not yet on the register.

CPRE Investigation

Spokespeople for CPRE North East Hampshire, Edward Dawson and Philip Todd said:

“Hart’s pilot Brownfield Register lists all the sites with planning permission that have yet to be built. However, some sites in Hart do not currently have planning permission.

These include a rural site in South Warnborough and the former Pyestock works called Hartland Village.

It suggests that most brownfield sites without planning permission; ones which should form the basis of a new Brownfield Register, are yet to be identified.

CPRE welcomes that Hart has identified sites that can accommodate nearly three times as many homes as it had forecast would come forward from brownfield sites.”

We Heart Hart Analysis

This concurs with our own analysis that showed:

  • All but two of the sites already have planning permission, indeed a number of them have already been built (e.g. Queen Elizabeth Barracks at Church Crookham, Landata House in Hook, and Monachus House in Hartley Wintney).
  • Some of the sites are not even brownfield sites, for example Rifle Range Farm in Hartley Wintney.
  • None of the sites that Hart Council itself identified as brownfield sites in the recent consultation are recorded in the register.
  • None of the other potential sites that have not yet been permitted on Ancells Farm or along Fleet Road have made it on to the register.
  • Very few, if any, of the brownfield sites in the SHLAA that we identified in our brownfield solution, most particularly sites like the former police college at Bramshill House have made it into the register.
  • Over 2,000 of the units in the register have already been granted planning permission, with 1,500 units at Hartland Village (aka Pyestock) and 16 at another site yet to be granted permission.

CPRE in North East Hampshire is encouraging the identification of more brownfield sites across Hart to protect our greenfield sites from unnecessary development.

Hart recommends Grove Farm and Bramshill planning proposals be accepted

Hart District Council recomend approval of Grove Farm Bramshill House planning applications

Hart District Council officers are recommending that the planning application for Netherhouse Copse (aka Grove Farm) and some of the applications to redevelop the former Police College at Bramshill House be granted. This has been revealed in papers recently published to go before the Planning Committee that meets on 14 December 2016. The relevant papers are available for download below.

Netherhouse Copse (Grove Farm)

The Nether House Copse (Grove Farm) application is for 423 dwellings on a green field site on Hitches Lane, Fleet in Hampshire. The controversial proposals have been opposed by a wide range of local community groups including Crookham Village and Dogmersfield Parish Councils and Fleet Town Council. But they have also been supported by various parts of Hampshire County Council and Thames Water amongst others. The planning officers have recommended that the application be granted, subject to certain conditions, and that it should go to full council for ratification. See p176 of the Agenda download below.

Bramshill House Police College

The proposals for the largely brownfield site at Bramshill House are more complex, in that there are a total of 7 applications covering various aspects of the proposed redevelopment.

Applications 2 and 3 (respectively 16/00722/FUL, 16/00724/FUL) cover the conversion of the main Bramshill House, the Stable Block and Nuffield Hall into both a single dwelling house (00722) and offices (00724).  Application 7 (16/01290/FUL) covers the provision of 14.4Ha of Suitable Alternative Natural Greenspace (SANG). The officers recommend that these three proposals be granted planning permission, subject to a number of conditions.

Applications 1 (16/00720/FUL), covers converting Bramshill House into 25 dwellings and publically accessible museum space. Application 4 (16/00726/FUL) covers the development of up to 235 dwellings in the grounds of Bramshill House. Application 5 (16/00727/FUL) covers the development of 14 dwellings in a different part of the grounds. Finally Application 6 (16/00728/FUL) is for 9 residential units in an area of the site known as Pinewood.

The officers have asked the Planning Committee for a ‘steer’ on these applications. The applicants have asked that Hart view the development of these additional dwellings as enabling development. This would fund the maintenance of the main Grade I listed building. The Officers have said that applications 1, 4 and 5 are opportunities to recommend the applications for approval, subject to agreeing to total volume of housing. They are not minded to recommend Application 6 for approval.

Analysis

Overall we are opposed to the Netherhouse Copse proposal as this is green field development. We believe there is plenty of brownfield land available to meet our housing needs. We agree in principle that the Bramshill site should be redeveloped. However, we recognise the sensitivity of the site. We would suggest that suitable payments are made for the provision of infrastructure and affordable housing without increasing the number of houses that are built.

We predict fireworks at the Planning Committee, especially after the recent defection of two councillors from the Tories to CCH. The full council meeting on 15 December will be interesting to say the least. As the Kaiser Chiefs might say, “I predict a riot”.

It really is a shame that more councillors and more of the various groups across the district did not get properly behind a brownfield strategy. Plus they did not heed our warnings about the poor management of the Local Plan project. If they had, we might have a brownfield focused Local Plan by now and have a proper defence against the Grove Farm proposals.

Hart Planning Committee Agenda 14 December 2016
Hart Planning Committee Paper about Bramshill House

 

 

Hart Local Plan and planning application update

Hart Local Plan and planning application update

There is a great deal of activity behind the scenes about the Hart Local Plan. The timetable for delivery is becoming clearer and there are updates on a number of planning applications that will shape the future of our district.

Hart Local Plan Timetable

We Heart Hart understands the upcoming timetable for the Hart Local Plan is as follows:

During w/c 28 November: The new Strategic Housing Market Assessment (SHMA) will be sent to councillors.

29 November 2016: Local Plan Steering Group (LPSG) Meeting, where we understand the timetable for the Hart Local Plan will be discussed and drafts of new Planning Policies will be considered.

December 13 2016: A further LPSG meeting will be held to review the draft spatial strategy. This will set out the number of houses we need to build and suggest where they will be built.

December 14 2016: We understand that the planning application for 423 houses at Grove Farm (aka Netherhouse Copse) near Crookham Village to the west of Fleet, will be considered at the Planning Committee. It is possible that some of the applications to redevelop the former Police College at Bramshill House will be considered.

January 26 2017: Draft Local Plan to go to full Council.

Upcoming Planning Applications

The long standing application for around 550 houses to the North East of Hook was finally signed off on 21 November.

The application for 423 houses at Grove Farm (aka Nether House Copse), near Crookham Village will be considered at the Planning Meeting on December 14. More details of this application can be found here and searching for application reference 16/01651/OUT.

It is possible that some of the applications for redevelopment of the former Police College at Bramshill House will be considered. There are a number of applications outstanding on this site that can be found here. The main applications appear to be 16/00726/FUL for 235 units and 16/00721/LBC for 25 units. At least this is a brownfield site, although controversial, being so close to the Thames Valley Heath SPA.

This week, Wates submitted an outline planning permission for 700 dwellings at Pale Lane (also known as Elvetham Chase). More details of this application can be found here and searching for application reference 16/03129/OUT

Conclusions

We don’t yet know how HDC are going to treat these applications, or if they have other ideas for strategic locations for additional housing. Of course, we await an application to redevelop the brownfield site at Pyestock (Hartland Village) and of course Winchfield has been mooted as a site for a new town, but we believe this has failed testing. Other strategic sites that were being considered include Murrell Green (between Hook and Hartley Wintney), Lodge Farm and West of Hook. Of course proposals are also being developed for the so called Rye Common New Village.

It is galling to say the least that we are seeing so many applications on greenfield sites instead of brownfield sites. It is imperative Hart produces the new Hart Local Plan and the new Planning Policies ASAP. This will allow us to regain control over where houses are built in the district.