Grove Farm development approved at appeal

Breaking News: Hart needs to build 1,500 fewer houses for the Local Plan

Grove Farm (Netherhouse Copse) development allowed on appeal

The planning inspector has granted outline planning permission to the Grove Farm (Netherhouse Copse) development, between Fleet and Crookham Village. This comes as a blow to those of us who oppose green field development, so our commiserations go to those most affected by this decision.

Grove Farm - Netherhouse Copse appeal decision

The full decision can be found here.

Impact of Grove Farm (Netherhouse Copse) decision

It is early days to come to firm conclusions, but here are a few thoughts:

  • Costs. The appeal decision doesn’t talk about the costs of the appeal, but at the very least the council will have to meet its own costs. These are likely to be of the order of £100,000. This is a self-inflicted wound as it was the council itself that failed to make a decision on the planning application. This left the developer with little choice but to appeal on the grounds of non-determination.

 

  • Local Plan. This decision adds 423 houses to the housing supply that weren’t in the draft Local Plan. Theoretically, this could free up other sites that are in the Local Plan. Of course, if the council adopts the new Government methodology for calculating housing need, we certainly won’t need a new settlement now, and it is questionable whether even Hartland Village will be required. [Update 2] The finding that the polices are out of date and the level of housing supply is irrelevant makes it imperative that the council gets the Local Plan and associated policies in place ASAP [/Update 2].

 

  • Community Campaign Hart (CCH). This party will be particularly angry and disappointed at this decision. They also suffered setbacks with the recent decisions at Watery Lane, Crookham Park and Edenbrooke. However, to our knowledge, CCH have never challenged the ridiculous housing target. Now they are putting in place obstructions to brownfield development. Perhaps now is the time to rethink their strategy. They should focus on a sensible housing target and brownfield development.

We will provide further updates as we find out more information.

[Update 1]

Detailed findings from the Inspector

The decision rested on a number criteria. First, the inspector found limited impact on the Local Gap between Fleet and Crookham Village. Here is the Inspector’s summary:

Grove Farm (Netherhouse Copse) Local Gap decision

Grove Farm (Netherhouse Copse) Local Gap decision

Second, the inspector found no grounds to reject the application based on highway safety:

Grove Farm (Netherhouse Copse) Highway Safety decision

Grove Farm (Netherhouse Copse) Highway Safety decision

Third, the inspector found it to be very significant that most of the policies that the council relied upon for its defence were out of date:

Grove Farm (Netherhouse Copse) Out of date policies

Grove Farm (Netherhouse Copse) Out of date policies

Grove Farm (Netherhouse Copse) Out of date policies 2

Grove Farm (Netherhouse Copse) Out of date policies

Fourth, the inspector didn’t determine one way or the other whether the council has a five year land supply. Essentially, the five year land supply is irrelevant.

Grove Farm (Netherhouse Copse) Housing Supply Irrelevant

Grove Farm (Netherhouse Copse) Housing Supply Irrelevant

In summary, the inspector found significant economic benefits, and that the potential harms would not outweigh those benefits.

Grove Farm (Netherhouse Copse) Summary of decision

Grove Farm (Netherhouse Copse) Summary of decision

[/Update 1]

 

Hart SANG plan to obstruct brownfield development

James Radley of CCH pulling the string of Graham Cockarill in Hart SANG plan to obstruct brownfield development

CCH calling the shots on Hart SANG plan to obstruct brownfield development

Hart Council has published a new report recommending that its own SANG land should not be used to enable brownfield development. This effectively renders the council’s SANG useless and calls into question the council’s ability to fund the repayments on the loan it has taken out to buy the SANG.

The document is sponsored by Community Campaign Hart (CCH) Deputy Leader, James Radley and not the portfolio holder for Planning, Lib Dem Graham Cockarill. This indicates that CCH is pulling the strings on important planning matters. The Hart SANG plan will be discussed at Cabinet tomorrow.

Hart SANG plan

Hart has bought its own SANG land at Bramshot Farm which lies between Ancells Farm and the link road between Hartland Village and the M3. The site has capacity to support 1,745 new houses. The new report proposes that no SANG land is allocated to the sites set out below unless signed off by both the Services Portfolio Holder (James Radley) and the chair of the Planning Committee (Graham Cockarill).

Brownfield sites affected

The following brownfield sites will effectively be blocked from development by the Hart SANG plan:

  • Bartley Wood, Hook, RG27, 9UP
  • Bartley Point, Hook, RG27 9EX
  • Cody Park, Farnborough, GU14 0LX
  • Meadows Business Park, Blackwater, GU17 9AB
  • Osborne Way, Hook, RG27 9HY
  • Waterfront Business Park, Fleet, GU51 3OT
  • Ancells Business Park, Fleet, GU51 2UJ (right next door to Bramshot Farm)
  • Blackbushe Business Park, GU46 6GA
  • Eversley Haulage Yard, RG27 0PZ
  • Eversley Storage, RG27 0PY
  • Finn’s Business Park, Crondall, GU10 5HP
  • Fleet Business Park, Church Crookham, GU52 8BF
  • Grove Farm Barn, Crookham Village, GU51 5RX
  • Lodge Farm, North Warnborough, RG29 1HA
  • Murrell Green Business Park, RG27 9GR
  • Potters Industrial Park, Church Crookham, GU52 6EU
  • Rawlings Depot, Hook, RG27 9HU
  • Redfields Business Park, Church Crookham, GU52 0RD
  • Optrex Business Park, Rotherwick, RG27 9AY

Essentially, development on every significant potential brownfield site other than Hartland Park and Sun Park (which already have SANG earmarked), will be hindered by this new proposal.

This new proposal runs contrary to the Vision outlined in the draft Local Plan which says:

The priority will have been given to the effective use of previously developed land (‘brownfield land’) so that ‘greenfield’ development will have been limited,

It also runs contrary to paras 105 and 107:

Our preference is still to deliver as much of our New Homes Left to Plan as possible on previously developed land.

many new homes will be built on brownfield sites (where possible and if they are viable)

Their new approach also goes against policy MG2 that says:

Policy MG2: Previously Developed Land

The Council will encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value.

Of course, this plan also goes against stated Government policy to encourage brownfield development. See here and here.

Financial impact of Hart SANG plan

However, all the large, controversial green field developments are being proposed with their own SANG. This includes Murrell Green, Winchfield, Pale Lane (Elvetham Chase), Rye Common and Grove Farm (Netherhouse Copse). Most of these sites are probably outside the 5km catchment area of this SANG anyway or closer to Crookham Park SANG. Of course, the new Government consultation has reduced Hart’s housing target by ~4,000 houses compared to the draft Local Plan. If this new target (plus a few extra to help out Surrey Heath) was adopted, our remaining housing target could be more than met by Sun Park and Hartland Park alone.

So, if the main brownfield sites are excluded from using the council SANG, the other brownfield sites have their own SANG and the major greenfield sites are not needed, or have their own SANG,  we have to ask what it will be used for.

Apparently, the council is about to sign an agreement with Rushmoor to use the SANG to support the delivery of approximately 1,500 new homes in Rushmoor. However, the latest Government housing target consultation has reduced Rushmoor’s allocation by ~3,000 dwellings and Surrey Heath’s by 630 houses. This calls into question whether Rushmoor will need this SANG at all.

The council is strapped for cash, and has borrowed £5.3m to fund the purchase of this SANG. It must payback this loan in instalments up to 2023/24:

Financial implications of Hart SANG plan

These new developments call into question the immediate demand for this SANG, and of course, Hart’s ability to repay the loan.

Conclusion

It is a scandal that Hart is using its powers to obstruct brownfield development. The major greenfield developments come with their own SANG, and probably aren’t required anyway. Rushmoor and Surrey Heath’s housing targets will probably be reduced. This calls into question the financial sustainability of the council’s purchase of this SANG land.

image

New Government methodology to reduce Hart housing need

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.

Significant reduction in Hart Housing need

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 housing need methodology on Hart Local Plan

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

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

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.

 

 

 

 

Developers battle over new settlement options for Hart District

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

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 near Hook and Hartley Wintney Framework Plan.

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

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.

 

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,