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.

Where is the draft Hart Local Plan?

Hart Local Plan - Keep Calm and Wait until 26 April

Hart Local Plan – Keep Calm and Wait until 26 April

Regular readers maybe wondering what has happened to the Hart Local Plan. On February 9th, Hart Cabinet agreed to a spatial strategy as part of the draft Local Plan that was due to go out to consultation in March. Obviously, there have been further delays. This is what we now understand to be the position:

Hart Local Plan timetable

The draft local plan will be released 26 April for a six-week Reg 18 consultation period after a briefing session with Parish Councillors on the 25th. There will be roadshows at the main settlements. Every house in the district will receive an A5 leaflet advising them of the consultation.

The Reg 19 process will follow in about November with submission of the full plan to the Secretary of State in mid-February 2018. All responses during the Reg 18 will be made public including the names of the individuals but with no contact details.

Hart Local Plan Headlines

Hart Council have decided to build 10,185 houses up to 2032 of which around 50% have already been built or granted permission. Please note that this number is far higher than 8,022 target the recently published Strategic Housing Market Assessment and more than double the requirement generated from demographic change. The numbers are now correct as of 31 January 17 and include all office conversions which have been approved.

Housing Numbers by area

  • Fleet 200 – mostly through office redevelopment
  • Hook was 200 now 10 from office redevelopment plus another 87. However, developers may chance their arm again with Owens Farm (750), and of course around half the Murrell Green site is in Hook Parish.
  • Sun Park 320
  • Hartland Park (Pyestock) 1500. Fleet town council have apparently made the point that the site offers only 20% affordable homes and the density per hectare is up to 97 in places which is equivalent to city centre densities which is of concern to them. OUr view would be to make the most of available brownfield sites.
  • Murrell Green 1800 but with challenges. There are 4 promoters and it will be some 3 to 4 years before planning permission is approved. It includes the site for a secondary school but there won’t be enough developer contributions to pay for it. New school funding rules mean that Hampshire can’t pay for it either.  It’ll probably be an Academy at a cost of circa £36 million. So we get a site for a school, but no money.
  • Crondall 66
  • Crookham Village 100 + 64 predominantly the care village
  • Eversley 124 on two sites
  • Heckfield 86
  • Long Sutton 10
  • Odiham 119 as per NP
  • Hartley Wintney 0. It seems odd that HW’s Neighbourhood Plan will be ignored. It should be noted that Murrell Green directly abuts Hartley Wintney Parish and about half of the proposed Pale Lane (Elvetham Chase) development is in HW parish.
  • South Warnborough 34 on two sites
  • Yateley 88
  • An additional 50 via rural exceptions and a further 290 from windfall.
  • Interestingly, no mention of Winchfield, or their Neighbourhood Plan, but roughly half of Murrell Green is in Winchfield Parish.
  • Apparently, Bramshill will be very difficult to develop because of all the complications with the Grade 1 listed site.

Other news

Apparently East Hants have done such a stellar job on the Local Plan, the Planning Policy team is now back in house at Hart, reduced in size from 8 to 2.

There is a risk that developers will continue to pursue Pale Lane and take it to appeal before the Local Plan is adopted.

We await the results of the Grove Farm (Netherhouse Copse) appeal in June.

Hart Cabinet sell us down the river as they plan for 10,000 houses

Hart Cabinet sell us down the river by planning for far more houses than we need

Hart Cabinet plan for houses we don’t need

Hart Cabinet sold us down the river on Thursday night as they voted to plan for 10,000 houses to be built in Hart District in the period up to 2032.

Aside from vote on the paper some other interesting information was disclosed on a number of subjects:

  • Hart Cabinet vote on the 10,000 houses?
  • Do we need a secondary school?
  • Grove Farm (Netherhouse Copse) update
  • Hart Cabinet and Council politics

Hart Cabinet vote on the 10,000 houses?

Well, the short answer is we don’t. Our statement was received without challenge and was described as “informed” by the joint Chief Executive. There really is no answer to the points about double counting, nor the extra 1,200 houses on top of the alleged additional affordable housing requirement. To his credit, Ken Crookes asked some challenging questions. He didn’t really receive satisfactory answers.

The cabinet chose to plan for the extra 2,000 houses on top of those set out in the Strategic Housing Market Assessment (SHMA), even though Ken abstained.

The plan was supported by two cabinet members from Hook. They apparently favour a new settlement that will deliver more houses in Hook Parish. But they vehemently oppose the proposed new development to the west of Hook, that is outside the Thames Valley Heath SPA zone of influence.

There is a risk that Hart will no longer have a five year land supply, now it has agreed an uplift to 10,000 houses. Apparently, officers are working on a new document.

The leader and joint chief executive will now proceed to produce a draft Local Plan. A new consultation will be held on this draft will begin some time in March.

Do we need a new secondary school?

One of the justifications for the new settlement at Murrell Green is that the district needs a new secondary school. You may recall that the council voted on a resolution to include a secondary school in the Local Plan.

However, in his statement to cabinet, the joint chief executive said that although:

Hampshire County Council (HCC) welcome the principle of a new school site, the scale of growth envisaged in the Local Plan is not one that would require the delivery a new school in the planning period.

HCC is responsible for planning school places. But HCC is not responsible for delivering new schools as they will now be delivered as free schools, outside local authority control.

Apparently, Hart has also been offered secondary schools by the developers of Winchfield, West of Hook and Rye Common.

In other words, Hart has acted outside its responsibilities in resolving to deliver a site for a school and the authority responsible for planning school places don’t believe we need a new school. So, we are creating a new settlement to create capacity for houses we don’t need and a school we don’t need either.

Grove Farm (Netherhouse Copse) update

In conversation we found out more about the Grove Farm application. The developer has now appealed this case on the grounds of non-determination.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

To re-cap, the Community Campaign Hart (CCH) chair the planning committee and failed to make a decision on the application at last December’s planning meeting. The council officers has recommended approval.

Hart is going to fight the appeal, probably on the grounds of wishing to maintain the Local Gap between Fleet and Crookham Village.

If Hart does lose its five year land supply, then this will make things difficult at appeal.

Apparently, the risk of losing £1.6m of New Homes Bonus has been mitigated because the indications from Government are that they are no longer going to push through those proposals.

However, there is still a significant risk that Hart will lose this appeal. The expectation is the appeal inquiry will be held in June, with a decision in August.

Hart Cabinet and Council Politics

We have now heard from several sources that one of the reasons Hart Cabinet appears to be so dysfunctional is that the ruling Conservative Party fears a vote of no confidence over the summer. This would entail CCH bidding to oust the Tories, presumably to be replaced by some sort of CCH/Lib Dem coalition. Maybe, the CCH coup is dependent upon the outcome of the Grove Farm appeal.

So, it appears as though we are planning for the extra houses to deliver a new settlement and secondary school we don’t need to appease CCH, who would prefer the new settlement at Winchfield.

It does seem very odd that we are having a new settlement forced upon us by dysfunctional politics.

 

 

Statement to Hart Cabinet

Hart District Council and Hart Cabinet Offices, We Heart Hart. We Love Hart

Statement to Hart Cabinet

The crucial Hart Cabinet meeting to decide the spatial strategy to be incorporated in the forthcoming consultation on the Hart Local Plan will be held tonight at 8pm.

Public participation is allowed and we have been allowed to speak. A copy of our prepared statement is shown below. Please do come along and watch the debate.

Statement to Hart Cabinet 9 February 2017

Thank you for allowing me to speak.

This is an important time for Hart – you are setting out a strategy that will impact the quality of life of Hart residents for many years to come, so it is important you do the best job you can.

Hart Council is in a perilous position and facing the threat of losing around £2m of NHB if the Local Plan is not in place on time and of course the threat of many speculative planning applications. So, it is right that you are risk averse at this time.

However, I would like to use this statement to persuade you to change direction.

I would like you to focus on reducing the housing target of 10,000 by removing the unnecessary uplift of 2,000 extra houses on top of the SHMA target of ~8,000.

The SHMA starts with the ONS population and household projections. It says the “the household projections… are statistically robust and are based on nationally consistent assumptions”. They take account of international migration and migration between districts.

On their own, these projections would point to a need for around 5,300 houses over the planning period. If, however, the SHMA used the more up to date 2014-based figures, the housing need would fall to around 4,500, compared to the 10,000 you are proposing to build.

That’s right, the latest demographic projections point to a need that is less than half of that you are proposing.

However, it is probably right that the housing target should be inflated a little to cater for what is termed suppressed household formation and concealed households.

The SHMA has done this by firstly increasing Hart’s target up to around 6,100 new dwellings to cater for households that are termed ‘can’t rent, can’t buy’ and those who can rent but can’t buy.

Secondly, it then makes a further increase of around 500 affordable homes. This brings the total target to around 6,600.

To my mind 6-6,500 houses would be reasonable overall that would mean we could meet the rest of the target from brownfield sites alone.

To emphasise: The SHMA has met the demographic need and already takes account of suppressed household formation, concealed households and affordable housing.

The SHMA then goes on to add a further 1,400 houses for economic growth, bringing the overall total to 8,000.

This ‘economic growth uplift’ does by definition mean that you are planning for additional inward migration to Hart, people whose needs are supposed to be met elsewhere. Not only that, the SHMA assumes many of these people will also work outside the district and thus put increasing pressure on the creaking transport infrastructure. This is not sustainable development.

Yet, you are now proposing to add a further 2,000 houses to the total to meet extra questionable affordable housing needs.

However, we have already established the SHMA itself has already taken account of the affordable requirement, so this extra 2,000 is double counting.  It will require us concreting over our green fields to meet non-existent housing needs. This is unsustainable over-development.

We wouldn’t need the new Murrell Green settlement if you removed the 2,000 unnecessary houses from the target. I might add the new settlement is entirely unsuitable. It is bordered by the M3 and A30. Criss-crossed by the railway, power lines and a high-pressure gas main. A big chunk of the site is former landfill. Only last year a solar farm was turned down on the grounds it would spoil the view from the Odiham Deer Park and spoil the enjoyment of walkers on the public footpaths. This proposal is far more intrusive than solar panels.

So finally, I urge you, please do the right thing and plan for a sensible housing target. Don’t blight our green fields with so many unnecessary houses. If you really want to help the concealed households, make sure you allocate some of the existing housing target to subsidised social-rented accommodation.

Hart Housing Target increased to 10,000

Hart Council goes through the looking glass as it ups the Hart housing target to 10,000

Through the looking glass as Hart housing target increases to over 10,000

We have gone through the looking glass as the Hart Housing target has been increased to over 10,000.

Hart has now published the document that will be discussed at Cabinet on Thursday 9 February. The main headlines are as follows:

  1. The Hart housing target has been increased to 10,077, with shall we say, questionable justification
  2. The proposed housing allocations are outlined, including a new settlement at Murrell Green

Hart housing target increased

The housing target has been increased to 10,077 as per the table below. This represents a 125% uplift on the 2014-based demographic projections.

ItemItem totalTotal
Housing demand as per 2016 SHMA8,022
Flexibility2,055
Affordable housing rental uplift520
Rural exception site delivery50
Starter homes/shared ownership285
Market housing1,200
Total "Need"10,077
Completions 2011-2016(1,830)
Commitments (to 31 Jan 2017)(3,385)
Windfalls(297)
Remaining to meet need4,565

This is a very questionable increase. The SHMA already factors in a 53% uplift on the ‘natural’ demographic projections, which would give a total requirement of 5,334 dwellings. But if they had used the more up to date 2014-based projections, the start point would fall to 4,473. If we were to use the raw 2014-based figures as our total housing target, we would have already built or permitted the total requirement.

Second, the justification to increase the total to 10,077 is to build 855 extra affordable/starter homes. But the overall increase is set at 2,055 because they don’t expect to build more than 40% affordable properties. This is simply absurd.

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

Third, the SHMA has already made allowance for extra affordable homes (as can be seen above), and then this has already been uplifted for extra so-called jobs growth, which themselves will deliver more affordable homes.  Hart Council seems to be adding uplift on top of uplift in a quite random and arbitrary way. We have already analysed the SHMA here and here.

Fourth, the paper itself says there is no well proven evidence-based formula to uplift the housing target. There is nothing in National Planning Policy Framework (NPPF) that requires the target to be uplifted in a mechanistic way. Nor that the requirements have to be met in full.

No need to increase the Hart Housing Target to meet afordable homes requirement

Hart Affordable housing uplift

In short, the proposed uplift is double counting uplifts that have already been made that we are under no obligation to meet anyway.

If we were to build at this inflated rate, then this would be carried forward and compounded in future demograpgic projections.

Housing Allocations

The paper sets out the proposed allocations to meet this fictitious target, including 1,800 new houses at Murrell Green.

Housing allocations to meet the Hart Housing Target

Hart District housing allocations

No mention is made of Bramshill or Grove Farm (Netherhouse Copse), which are currently under consideration by the COuncil. Indeed we understand that the developers have appealed the Grove Farm application on the grounds of non-determination. Hart were already late in considering the application in December and cancelled the January meeting. Grove Farm is not on the agenda for the February meeting. It is difficult to see how they can defend the appeal.

Conclusions

Hart District Council is in a very perilous position. If it doesn’t get a Local Plan in place soon, it will lose around £2m per year in New Homes Bonus.

So everyone has a strong incentive to get a Local Plan. But by increasing the target to over 10,000 houses, everyone loses for decades to come.

It is difficult to work out the best way forwards. We could either wait until the Regulation 18 Consultation comes out in March and hope that we can influence matters for a better outcome. Alternatively, we can fight now for radical change of both the plan and the people running the process.

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

 

 

 

 

CCH force delay to the Hart Local Plan as housing numbers rise

CCH force delay to Hart Local Plan- this is no time to keep calm

This is no time to keep calm

We Heart Hart has learned that last night’s meeting of the Hart Local Plan Steering Group was a”disaster”.  Concrete Community Campaign Hart (CCH) councillors forced a further delay on to the timetable by insisting that Winchfield New Town is included as an option.

Affordable Housing blow

In a further blow, it appears as though Hart’s housing allocation has been further inflated by up to 2,000 additional houses due to new Government guidelines that may force Hart to build even more ‘Affordable Homes’. This new requirement would be in addition to the 40% of homes that must be ‘Affordable’ in the SHMA target.

Apparently, there are no plans to publish the new Strategic Housing Market Assessment (SHMA) until they are ready to publish the Regulation 18 consultation on the new draft Local Plan. We don’t know the timescale for that yet.

This shows that Hart’s statement in October that Hart had to build 1,500 fewer houses was a total sham.

Impact of Delay to the Hart Local Plan

There were three potential options on the table at LPSG for detailed consideration. However, CCH insisted on a fourth option that included the Winchfield New Town. We don’t know the specifics of the other options, but we suspect they included Grove Farm/Netherhouse Copse.

WeHeartHart had been led to believe that the Winchfield New Town option failed testing due to concerns about groundwater flooding and lack of infrastructure. The level of testing that was carried out is now in doubt. It is difficult to see how a further delay and more testing is going to change the viability of the new town.

CCH’s stance is strange because the delay to the Local Plan will weaken Hart’s defences against the speculative applications being submitted by developers. The proposed developments at Grove Farm/Netherhouse Copse and Bramshill House are due to be determined at tonight’s Planning Committee meeting. Of course, an application to develop the Pale Lane site into Elvetham Chase has recently been submitted and this will need to be determined in the New Year. If there is no draft Local Plan, then it will be difficult to defend against it.

Conclusion

It is imperative that we get the Hart Local Plan in place quickly so we can manage the inevitable housing growth that we face. CCH should stop their ideological pursuit of the unviable Winchfield New Town and start to work constructively to solve the problems of the whole district.

We would wish to see many new homes that are truly affordable for Hart residents. However, there is strong evidence of developer land-banking in Hart and of not building enough smaller properties. Simply increasing the housing target won’t lead to a meaningful increase in housing supply. Even the smallest properties at recent developments (for instance Rifle Range Farm/Hartley Row Park at Hartley Wintney) were out of reach of most Hart residents. We think the new additional target for affordable homes should be vigorously challenged.

Hart Local Plan and planning application update

Hart Local Plan and planning application update

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

Hart Local Plan Timetable

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

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

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

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

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

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

Upcoming Planning Applications

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

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

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

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

Conclusions

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

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