Government threatens councils with new housing need methodology

Government threatens council with new housing need methodology

The Government has threatened councils with a new housing need methodology if they don’t submit a Local Plan by March 2018. The threat is contained in a Government newsletter that has been reported upon by Lichfields the planning consultancy. The report can be found here.

It is of course unclear what this new methodology might entail. However, the Government is desperate to increase the level of housebuilding, so it is likely this new methodology will further increase Hart’s target.

The new deadline of 31 March 2018 gives a critical backstop date for Hart to submit its Local Plan for inspection. The target date for submission was vaguely described as Spring 2018 in the latest consultation. However, as we know Hart Council has missed every deadline it has set itself. So, it remains to be seen if the new administration can get a new plan together on time, especially as Hart has already effectively turned down an application on one of its preferred sites.

 

 

 

 

Hart Council to destroy its own Local Plan

Council Incompetent over farm home plan destroying Local Plan

Hart destroys its own Local Plan

Hart Council will effectively destroy its own Local Plan. It has taken the decision to oppose the appeal into the Cross Farm care home application by proceeding ‘on the basis that the planning application has been refused’.

This is laughable because the Cross Farm development was one of the preferred sites in the recent draft Local Plan consultation. The proposal is for a 160 unit care village and a 64-bed care home. The potential impacts of the decision to turn down the application are:

  1. Hart loses 224 dwellings from its draft Local Plan, potentially rendering it unsound
  2. The Local Plan no longer meets the specialist housing needs of older people, potentially rendering it unsound
  3. The council loses around 25Ha of valuable SANG land, constraining capacity to build new homes in the district
  4. The cost of the appeal is likely to be around £100,000, rising to over over £200,000 if Hart Council loses
  5. May lead to the introduction of a further round of consultation into the Local Plan, costing more money and losing another six months in the schedule

It is looking like the new CCH/Lib Dem administration is even worse than the previous Tory administration when it comes to planning policy. It may well be time for the Secretary of State to step in and appoint commissioners to replace this failing council.

The full article in the Fleet News and Mail can be found here.

Hart fails to decide Cross Farm application on time

Sad clown at Hart council fails to decide Cross Farm Appeal document 16/03400/OUT

Hart Council clowns fail to decide Cross Farm application

Hart Council has failed to decide the Cross Farm in Crookham Village planning application on time. This has led the developers to submit an appeal on the grounds of non-determination. This comes on the heels of the failure to determine the Grove Farm (Netherhouse Copse) application back in December 2016.  This is Jedi-level incompetence that makes the Council look like clowns.

The original application was made in January this year and should have been decided by 7 April. The application doesn’t seem to have been considered at all by the Planning Committee. Details of the original application for the Cross Farm development can be found here, and searching for 16/03400/OUT. The appeal documents can be found by searching for 17/00078/NONDET.

The proposed Cross Farm development in Crookham Village was one of the recommended sites in the recent Local Plan consultation. This indicates that the proposal was supported by officers.

We can only guess at why it wasn’t determined on time. Clearly,  the council is dysfunctional. The Conservatives were in charge of the council when the application should have been decided. However, Community Campaign Hart (CCH) held the chair of the Planning Committee at that time. Now the Planning Committee is chaired by Graham Cockarill of the Liberal Democrats, and the administration is jointly run by CCH and Lib Dems. Therefore, it seems none of the parties are able to get a grip on the planning process and take decisions on time.

One explanation might be that despite Cross Farm being in the draft Local Plan, CCH councillors felt unable to support the proposals. Therefore, they abdicated responsibility, so they could blame any decision on the Inspector. Of course, the appeal will be at council taxpayer expense.

[Update] Another explanation might be that it wasn’t in the interests of the Tory administration or the officers to bring this to the Committee on time. Cross Farm in Crookham Village was a preferred site in the draft Local Plan. If Cross Farm had been rejected at Committee, it would have effectively scuppered the Local Plan. [/Update]

Cost of Cross Farm, Crookham Village appeal

It is likely that this public enquiry style appeal will cost the council over £100,000 to defend. We find it difficult to understand how they expect to win the appeal given that the site is in the draft Local Plan. Therefore, we think it likely the inspector will award costs to the developer should they win. This would bring the total costs of the appeal to over £200,000.

The overall council budget is ~£10m. Surely, this appeal money could be better spent on local services, infrastructure or social housing?

 

Government to force Hart to increase housing target

Increased housing target will lead to more £1m houses like this at Hartley Row Park, Hartley Wintney, Hart District, Hampshire.

Government to force Hart to increase housing target.

The Government will force Hart to increase its housing target says Sajid Javid, the Secretary of State for Communities and Local Government, it is reported in the Telegraph today. The article says:

Families living in some of the most sought-after parts of the country will be forced to accept more homes being built near them to tackle the housing crisis, the Communities Secretary has said.

Sajid Javid said that he wants communities which have benefited from soaring property prices to play their part in solving the housing crisis.

New rules to force councils to increase their housing targets will be published in the next three weeks.

Excerpts from his speech have been tweeted. It is clear Mr Javid has in mind councils that have yet to produce a Local Plan.

We don’t agree with Government that Hart needs to build even more houses. The 10,185 target adopted in the recent Local Plan Consultation is clearly ridiculous. It is already more than twice the need identified by the Government’s own population forecasts. What we need is more social housing for those who can’t rent and can’t buy. We also need more 1 and  3-bed properties to help the young get on the housing ladder

Hart District Completions compared to target by number of bedrooms

We certainly don’t need more £1m houses like those for sale in Hartley Wintney at the moment.

Land-banking causing delays to building

We might also address the land-banking in the district, where thousands of houses have not been built, even though planning permission has been granted.

Year of grant Net uncompleted dwellings
2003 5
2005 1
2006 0
2008 1
2009 2
2010 14
2011 58
2012 591
2013 402
2014 793
2015 1,066
2016 148
Grand Total 3,081

It remains to be seen if the new Hart Council administration can stand up to this bullying from central Government. We need a lower, more realistic housing target.

 

Gallagher propose schools under power lines

Gallagher propose schools under power lines

Gallagher propose schools under power lines

In a desperate attempt to influence the Local Plan Consultation, a ‘newsletter’ has been issued in which Gallagher propose new schools under power lines. This is a last minute attempt to try and shoehorn a new settlement at Winchfield into the draft Local Plan. Apparently, the newsletter has only been issued to residents of Fleet and Church Crookham.

We have seen the newsletter and compared the schematic to the local OS map. As far as we can tell, the high voltage power line goes directly over the school grounds. Moreover, there is a pylon directly on top of the sports pitches. Our best attempt at showing the location of the school, and powerline is shown in the graphic above. Aside from the obvious electrocution risk, overhead power lines have been linked to increased risk of childhood cancers such as leukaemia. The secondary school is also right next to the mainline railway line.

The document has been issued by Curtin & Co on behalf of Gallagher. They apparently specialise in the ‘Politics of Planning’. The contact given is David Scane, who can be reached at davids@curtinandco.com. We deplore this crony corporatism. We recommend that WeHeartHart supporters email this man. We should let him know that we don’t approve of these shabby tactics and how ridiculous it is to propose schools in such an unsafe location.

Of course, no evidence has been produced in the Local Plan to show a new school is required. Even if such evidence is produced, it isn’t clear why we can’t simply allocate land for a school without the hundreds of acres for housing.

We have updated our guidance with this new information in our suggested response to the consultation that can be found on the download link below. 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

CPRE slams Hart Local Plan

CPRE Murrell Green has slammed the draft Hart Local Plan

CPRE slams Hart Local Plan

The local CPRE has slammed the draft Hart Local Plan, saying it is incoherent and lacks regard for the countryside.

They say:

CPRE’s District Group for North East Hampshire are concerned that the Local Plan has no coherent strategy but is instead a series of tactics to deliver a housing and development supply without any recognition of the role of countryside and the value of the natural environment.

The rural areas seem to have been completely missed in that there is no recognition of the role or function of the countryside and rural communities in this part of the county. Hart’s Vision ignores landscape value, the value of historic or heritage assets, as well as the social and health value the countryside provides for recreation.

Employment site assessment and policies appear to be ill-considered, especially in the rural areas. There are no criteria to support the policies and this results in some sites that employ few people being designated as important for jobs yet other vibrant employment sites in the villages are allocated for housing. This is in direct conflict with the Plan’s aim to protect employment sites particularly in the rural areas.

Murrell Green, which lies close to Hartley Wintney, Winchfield and Hook, is a potential greenfield settlement for 1,800 houses and a secondary school. The site contains endangered woodland, ancient lanes and hedgerows, and lakes and ponds. The proposals show no regard for these natural features and there are concerns about water supply for the high level of proposed housing

We agree with the CPRE, and many of their ideas are incorporated in our suggested response to the draft Local Plan consultation. Please ask the council to think again  by downloading the link below and review our suggested comments on the draft Local Plan. 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

Local Plan misses opportunity to regenerate urban centres

Hart Local Plan to regenerate urban centres

Hart Local Plan to regenerate urban centres

The consultation on the Draft Local Plan misses an opportunity to regenerate urban centres in Hart District.

This is contrary to Para 131 of the Plan that says “The delivery of town centre redevelopment opportunities must be a priority”. The National Planning Policy Framework (NPPF) indicates (paragraph 23) that planning policies should promote competitive town centre environments and set out policies for the management and growth of centres over the plan period.

This can be best illustrated by using Fleet as an example.

Fleet is the lowest density town of its size in the country. The chart below that there is significant scope for increasing development density in Fleet.

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

 

The retail offer in Fleet is poor, the cultural facilities (e.g. Harlington Centre) are outdated and there is no proper cinema.

Fleet Health score versus benchmarks

Fleet Health score versus benchmarks

 

However, Fleet has the highest average earnings per person of comparative towns by quite a large margin (eg 9% more than Camberley). High earnings should give Fleet a significant advantage over the comparison towns.

 

Fleet earnings versus competitors

Fleet earnings versus competitors

The Local Plan Vision and Objectives fail to take advantage of the opportunity to modernise Hart’s urban centres while at the same time protecting Hart’s countryside.

We believe that the Vision for the Local Plan should be centered on the proposition that Fleet and other urban centres will be re-generated. With Hart District Council’s full and active support, a plan based on urban regeneration would achieve the following benefits:

  1. An ambitious Hart Urban Re-generation Project (HURP) would attract private investment and thus be affordable
  2. Private investment would allow for Hart’s infrastructure to be upgraded in line with the urban re-generation
  3. Good urban design principles would achieve a higher population density in the urban centres while at the same time providing an improved ‘sense of place’ and making the urban centres more desirable places to live.

A similar approach could be adopted in Yateley to provide a proper retail-led centre and improvements could be made to Blackwater. The requirement for additional retail facilities in Hook, identified in the Local Plan could also be met.

Apparently, Hart did have a plan to conduct a brownfield study to evaluate the ‘art of the possible’ in our urban centres. This project has not delivered.

 

In addition, Yateley lacks a defined centre, Blackwater is indistinct and Hook lacks good quality restaurants and shopping facilities.

The council should be setting out a bold plan to improve the retail, cultural and recreational amenities in the district. We should also develop plans for a theatre and cinema in Fleet as part of an attractive mixed-use redevelopment. There will be significant cash available from developers to fund such an ambitious plan.

Moreover, the council should work collaboratively with developers to regenerate other urban areas such as Blackwater and redevelop the centres of Yateley and Hook.

Please ask the council to think again  by downloading the link below and review our suggested comments on the draft Local Plan. 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

Challenge the ridiculous housing target in the Local Plan Consultation

Challenge the ridiculous housing target

Challenge the ridiculous housing target in the Local Plan consultation

The main objection to the draft Local Plan is the ridiculous housing target. We believe the Strategic Housing Market Assessment target of 8,022 is too high. Despite that, Hart have added more than 2,000 houses to this target and plans to build 10,185 houses.

This puts massive pressure on the district and puts many greenfield sites such as Murrell Green, Winchfield, Grove Farm (Netherhouse Copse), and Pale Lane (Elvetham Chase) at risk. Moreover, this rate of housebuilding will be carried forward in future planning periods, making it inevitable we end up with unattractive urban sprawl.

We believe the housing target should be a more reasonable 5,144 which will meet the changes driven by demographic change, immigration and deliver social housing for those who cannot afford to rent or buy their own home. The remaining housing target can be met from brownfield sites alone.

The detail of our analysis is shown below. Please object to this ridiculous housing target by downloading the link below and review our suggested comments on the draft Local Plan. 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

There are several lines of argument:

  • Vastly Over-achieves against Government housing policy
  • Strategic Housing Market Assessment target of 8,022 is too high
  • Hart’s decision to increase the target by 2,000 dwellings to the target is inappropriate

Vastly over-achieves against Government housing policy

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 130-170,000 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.

It is worth noting that the DCLG forecasts project forwards the recent high level of inward migration to the UK. Government policy and the impact of Brexit is likely to reduce inward migration so, it is likely the 2014-based projections are too high. Moreover, the DCLG forecasts also assume a reduction in average household size.

The 2016 Strategic Housing Market Assessment (SHMA) has arrived at a ‘need’ of some 8,022 new dwellings over the plan period.

For Hart, the raw 2014-based DCLG forecasts, as opposed to the 2012-based forecasts used in the SHMA,  would result in a starting point for housing need of c. 4,473 new houses (see Figure 6 of the SHMA).  Hart’s overall housing requirement as defined in the SHMA is some 79% above the starting point. The ridiculous housing target of 10,185 used in the Local Plan is some 127% above this basic requirement.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 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”. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.

There might be some justification if this process had 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 2016 there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

The unintended consequence of this policy is effectively state-sponsored profiteering on behalf of the major housebuilders. It is plainly ridiculous that the housing target in Hart’s SHMA and the SHMAs of neighbouring areas are massively above the requirement suggested by demographic change, immigration and changes to household size.  Accordingly, the housing target and the Local Plan should be adjusted downwards to more realistic levels.

Strategic Housing Market Assessment results in a ridiculous housing target

Following on from the above, we can now analyse the reasons why the SHMA has arrived at a ridiculous housing target that is too high. We can also arrive at a more realistic figure.

Inappropriate Starting Point

First, the starting point used is the 2012-based DCLG forecasts, or around 5,334 dwellings over the plan period. The starting point should be revised downwards by using the more up to date 2014-based forecasts which would result in a starting point of 4,473 dwellings.

The SHMA then uplifts the starting point in response to market signals to provide more housing for what are termed suppressed households. These are, for instance younger people in the 25-34 age bracket who are still living with their parents and are unable to afford to form their own household. Almost by definition these people cannot afford to rent their own accommodation or buy their own house. The SHMA suggests a 15% uplift on the start-point. Even though some element of household size reduction is included in the DCLG forecasts. We would agree with this and increase the need by 671 units to arrive at a total housing need of 5,144. However, we would insist that these units are delivered as social rented housing. The proposed Hart Development Corporation could be an appropriate vehicle to deliver these homes, or partnerships with local Housing Associations.

Affordable Housing Uplift

The SHMA then makes a further upward adjustment for affordable housing. This is to help those able to afford to rent, but not able to access home ownership. By definition, these people are already housed. It is therefore difficult to see how building more houses will assist these people. If they can afford to rent, then it is very likely that they can afford to service a mortgage, but cannot afford a deposit. The way to help these people is with shared ownership or ‘Help to Buy’ schemes. It is also worth noting that some of these people may be taking an entirely rational decision to rent and not buy because they think property prices are too high and thus represent a poor investment when assessing potential future returns.

The only plausible reason to build more houses to help these people would be that it would lead to a general fall in house prices. This is a false premise as discussed by Ian Mulheirn of Oxford Economics here.

The extent that we do see high house prices as a policy priority in and of themselves (e.g. for wealth distributional reasons), this is not a problem that will be solved by any plausible amount of new supply. Many econometric studies in the UK (see page 43 here for a comparison of results) have concluded that a 1 percent increase in the housing stock per household will only cut prices by at most 2 percent. Consequently, even if we were to add 300k new houses per year (about 150k in excess of household formation, approaching 0.5 percent of current stock), this would only lower prices by about 1 percent per year. This is peanuts in the context of price rises over the past 20 years….

Building many more houses that people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.

Therefore, the affordable housing need should be seen as the proportion of overall housing need that should be built as ‘affordable’ units. The SHMA adds 504 extra affordable units to the total housing requirement. However, this 504 units represents only 11.2% of the 4,473 raw housing need. Hart’s target is to build 40% affordable housing and recent delivery has averaged just over 20%. If this were to continue and the housing target were revised to start at 4,473, then around 900 affordable homes would be delivered in addition to the 671 social rented units identified above.

Jobs Growth Adjustment

Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several 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, a shortfall of 15-30,000, or almost all the projected job growth.

Second, the projection of 1,200 jobs per annum is far more than 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, the SHMA uses a very circular argument to account for the number of jobs. The argument is: 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.

They then decide we will need to import some extra people and those people will need houses. The SHMA then acknowledges that most of these people will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.

Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.

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.

Clearly, this uplift is not an expression of the ‘need’ for the district, nor is it ‘sustainable development’. The SHMA itself recognises that most of these additional people will, in fact, work outside the district. This is against the sustainability principles of the NPPF.

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. Then those people will add to the strain on Hart’s infrastructure (roads, schools, healthcare), but work outside the district. This is not ‘sustainable development’ on any reasonable interpretation of the phrase. Moreover, those exporting districts should already be planning to house those people.

Accordingly, there should be no jobs growth uplift in the SHMA.

This leaves us with a housing need for Hart of 5,144 made up of 3,573 open market units, 671 social rented units and 900 affordable homes made available through ‘Help-to-Buy’ or shared ownership.

Hart’s decision to increase the target by 2,000 dwellings results in a ridiculous housing target

It follows from this that Hart’s decision to add a further 2,000 units to the SHMA to establish an alleged ‘policy on’ ridiculous housing target of 10,185 is both specious and unnecessary:

  • The needs of both suppressed households and those who can rent, but can’t buy are already met by the revised housing target identified above
  • The addition of a further 2,000 homes would simply import even more people into Hart, most of whom would work outside the district, again contrary to the sustainability principles of the NPPF.
  • There is no evidence that this level of development would lead to falling house prices. Indeed, with residential land priced £4.1m per hectare (SHMA section 9.12) and a density of 30 dph, land prices alone would amount to £133,000 per dwelling. Build costs, S106 contributions and developer profits would see average house prices around £400,000.
  • It is not at all clear why we must build 2,163 extra houses to meet an alleged additional affordable housing need of 865
  • Rushmoor has already said it can meet its share of the over-inflated housing target. Reducing the overall SHMA targets for the whole Housing Market Area (HMA) will release pressure on both Surrey Heath and Rushmoor, such that ‘additional flexibility’ is not required
  • We are currently living in the most benign conditions for housebuilding in living memory. We are experiencing low absolute interest rates and negative real interest rates. The markets are awash with excess capital thanks to Quantitative Easing and the planning regime is very favourable to developers. As the House of Lords report referred to above indicates, planning permission is being granted at a much faster rate than new homes are being built. The only conclusion one can draw from this is that the market cannot absorb many more houses than are being built without a major fall in house prices. The house builders will not build faster as it will damage their profitability. Simply granting permission for more housing through blighting more of our green fields will not impact house prices nor will it lead to more houses being built.

It would be appropriate for the Inspector to express an opinion on the ridiculous housing target in the SHMA and the extra 2,000+ houses. Hart should set out a ranking of sites it wishes to take forward, such that the spatial strategy can be easily adjusted depending upon the final housing target that is agreed.

Draft Local Plan has no infrastructure plans or costings

 

Hart Local Plan contains no infrastructure plans or costings

Local Plan contains no infrastructure plans or costings

The draft Local Plan contains no infrastructure plans or costings. We think this is a massive error by the council that makes the draft Local Plan unsound.

If you agree, please download from the link below and review our suggested comments on the draft Local Plan. 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

Here is our analysis of the infrastructure weaknesses in the Local Plan

Local Plan contains no infrastructure plans

Paragraphs 7, 17 and 177 of the NPPF/NPPG make clear that infrastructure should be planned alongside housing. Para 395 of the draft Local Plan says there’s a Draft Infrastructure Delivery Plan (IDP) available for viewing alongside the Local Plan. However, no IDP has been made available.

Given that back in 2013, a £78m infrastructure funding deficit was identified, this is a critical omission. In particular, we think Hart Council should focus on:

  1. The requirement for a new secondary school. The Murrell Green proposal includes a site for a new school, albeit on top of a high-pressure gas main. However, no evidence has been presented to demonstrate a new secondary school is required. WeHeart Hart research shows that a new secondary school may not be required, and the sustainability assessment for Murrell Green mentions a 9% surplus of places.
  2. Railways. SW Trains have indicated that the mainline rail route to London is 20% over-crowded at present and is forecast to be 60% overcrowded by 2043. Para 58 of the Local Plan makes no mention of this, and there is no apparent plan to improve capacity.
  3. Our roads are becoming increasingly congested and generally in a poor state of repair. There is no sign that the council has carried out an overall road transport assessment to establish the level of investment required to improve our roads so they can cope with the scale of development that is being proposed
  4. Paras 65 & 66 make no mention of groundwater and surface water flood risk in Winchfield, which was identified in the Sustainability Assessment
  5. Para 68 provides no plan to fix the acknowledged wastewater capacity issues
  6. None of the plans for the strategic sites include proper plans for sports and community facilities such as allotments.

Local Plan contains no cost analysis for infrastructure requirements

Neither the Local Plan nor the Sustainability Assessment contain a financial assessment of the alternative means of providing the housing need. We think this is a very significant omission.

We already have a £78m infrastructure deficit, so this is a critical issue. The financial analysis should include:

  1. An assessment of the major infrastructure requirements generated by each of the approaches you have considered. These include new roads; road improvements such as roundabouts; railway station and parking improvement; railway line capacity improvements; schools; healthcare; fixed and mobile telecommunications, flood prevention, wastewater disposal and social infrastructure. A high level cost of each item should be provided.
  2. An analysis of the likely contribution that could be expected from developers and other providers to meet these requirements.
  3. An estimate of the likely contributions from Government such as New Homes bonus and grants to support brownfield development.
  4. A calculation of the gap between the requirement and the contributions for each development scenario

Residents should then be able to see the financial impact of the proposals and make decisions based on that.

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