Independent Expert says we are being asked to build too many houses

Time to celebrate we don't need so many houses

Time to celebrate: Hart, Rushmoor and Surrey Heath don’t need so many houses

An independent expert, Alan Wenban-Smith has taken a look at our housing needs assessment and concluded that Hart District is being asked to build too many houses.  He says that the overall house-building rate for the combined area of Hart, Surrey Heath and Rushmoor should more than halve from 1,180 dwellings per annum (dpa) to 558 dpa, and that for Hart should fall from 370 to 268dpa.  This would reduce the overall housing need for the housing market area from 23,600 to 11,160 and that for Hart from 7,500 to around 5,500.  This calls into question the validity of carrying out a new “Housing Options” consultation now when there is serious doubt about the accuracy of the housing numbers we need to deliver. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

This is very good news in that if this analysis is upheld at inspection it should lead to the following conclusions:

  • We can meet all of our remaining housing need from brownfield sites alone.
  • We definitely would not need a new town in Winchfield or anywhere in Hart, nor would we need any urban extensions.
  • The risk of needing to build 3,000 houses to cater for the unmet needs of Surrey Heath and Rushmoor should fall away.
  • There may be an opportunity to ask Surrey Heath and Rushmoor to build more houses for Hart, so we could keep our beautiful countryside.

Mr Wenban-Smith’s full report was commissioned by We Heart Hart and Winchfield Action Group can be downloaded here:

Critique of Hart SHMA

Critique of the Hart, Rushmoor and Surrey Heath SHMA by Alan Wenban-Smith

The summary of his argument, together with the implications is discussed below:

The starting point for assessing housing need in Hart used the 2011-based population projections from the Government and then made a series of changes to extend those projections out to 2031; adjust for higher inward migration estimates and for smaller average household size.  These 2011-based projections have been superseded by more recent 2012-based figures that already make projections to 2031 and already include the adjustments made above.  The effect of this is to reduce the start-point considerably.

Hart has already commissioned a review of the Strategic Housing Market Assessment (SHMA) to take account of these latest Government figures and so should include this reduction.  We should know the results of this work early in 2016.  However, this does call into question the validity of conducting a new consultation now when the numbers are subject to such a large degree of change.

Then Mr Wenban-Smith challenges the jobs forecasts in the SHMA, concluding that the level of jobs growth we achieved in the period 1998-2008 would be a “good result” and the increases in jobs and houses needed to support economic growth should be reduced.

Finally, he then goes on to say that the level of house need shown in the SHMA cannot be delivered by the market.  If the amount of land required to meet the need is allocated by the council, then this will lead to housebuilders cherry picking the best sites and building at a rate that gives them most profit,  not at the rate required to meet the needs. So, he concludes that the level of housing proposed is unsustainable, and therefore contrary to the NPPF and should be reduced.  This is in-line with current guidance about SHMAs from the Planning Advisory service that says:

Based on these reasons, we conclude that the OAN should be principally understood as a measure of future demand rather than aspiration. Accordingly we propose a working definition as follows:

‘The housing that households are willing and able to buy or rent, either from their own resources or with assistance from the State’.

Hart Council missing out key information about housing options

Hart District Council Offices

Hart District Council issuing misleading information about housing options

Hart Council has just published its new Housing Options paper in relation to the Local Plan, in preparation for running a consultation from November 23 2015 to January 15 2016. We believe the information contained in that paper is misleading for a number of reasons and have some suggestions on how you might respond to the consultation.  In summary the issues are:

  1. The SHMA is currently being revised and likely to reduce the housing need, so why are we being consulted on a housing requirement that is no longer valid?
  2. The SHMA has been challenged by an independent expert who says we don’t need so many houses.
  3. Hart’s estimate of brownfield capacity is way too low, and far lower than they said as recently as October 1 2015.
  4. Government rules have been changed to encourage more brownfield development and this paper makes no mention of this.
  5. The infrastructure costs of a new town are enormous, but the paper doesn’t clearly set out the economic consequences of the choices we make on housing options.

Housing allocation out of date

The housing need assessment is based on the current version of the Strategic Housing Market Assessment (SHMA), and they do not mention in the paper that the SHMA is currently being revised to take account of new Government population and household projections.  These new projections show a big reduction in forecast population from 322K used in the SHMA to 289K for the whole housing market area and a reduction of 1,602 in Hart household projections.  It seems reasonable to assume that Hart’s housing allocation will therefore fall, but this is not mentioned at all in the consultation paper.

SHMA is invalid

The Housing Options paper does not take account of the opinion of independent expert, Alan Wenban-Smith that the SHMA says we are being asked to build too many houses.  This means that the paper is asking us to consider how we might build houses that aren’t needed and is therefore invalid.

Estimate of brownfield capacity is too low

Back in November 2014, Hart Council said we had capacity for 750 dwellings on brownfield sites. Very few or none of those sites have been granted permission since then. At cabinet on October 1 2015, the joint-CEO of Hart Council said that he thought the brownfield capacity had increased to around 1,800 units. We said at the time we thought this was a low estimate and it could be in the range of 2,400-3,688. However, the new paper says that brownfield capacity is now only 400 units.  The paper pours cold water on the notion that the former police college at Bramshill can be re-developed, but who in their right mind would want to see a Grade 1 listed building start to decay, and who would want to preserve the hideous 1970’s accommodation blocks?  This is clearly a site ripe for redevelopment, and the environmental impacts should be low compared to the prior use of the site.  So, the question remains, what has happened to the other 1,400+ units and why aren’t Hart taking account of them?

Government has made brownfield development more attractive

The Government has also just relaxed the rules about building on brownfield sites to make it more attractive.  This makes it more likely that the brownfield capacity identified in the Stonegate report can be delivered.  The Hart paper fails to mention this. The paper also fails to mention that Hart has kicked off a process to identify even more brownfield sites across the district, but the results of that study won’t be known for some time.  It does seem odd to be so definitive about the so-called lack of brownfield capacity when there are so many positive developments underway.

Astronomical Infrastructure Costs

Hart have published some analysis to show the infrastructure requirements of a new settlement.  They haven’t been definitive about how much this would cost, but it would include a new motorway junction, significant changes to existing roads and bridges, a new sewage works, 4 new schools and a new railway station.  Our estimate of the cost of this infrastructure is £300m+.  A realistic expectation of the developer contribution for 4,000-5,000 houses would be £40-50m.  Hart already have an infrastructure funding deficit of £78m.  It is clear that we cannot afford the infrastructure costs of a new town, and that existing settlements would be starved of investment if it went ahead. The new housing options paper makes very little reference to the economics of development for any of the approaches it identifies.  Surely, we should know about the economic consequences of the housing options choices we make?

It is becoming increasingly clear that the housing options paper and the associated consultation is a pig-in-a-poke, but nevertheless as it is there we must respond to it.  It looks increasingly like a faction of the council is hellbent on concreting over large swathes of our countryside, despite all the evidence that we don’t need to.

We urge you to Vote against Approach 3 (a new settlement at Winchfield).  But when asked for any other comments, use this article to ask them to think again about brownfield. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Housing targets systematically over-stating housing need

Is this what we want Hart to turn into?

Is this what we want our countryside to turn into?

A review of a sample of Strategic Housing Market Assessments (SHMAs) across the south of England has indicated that on average, local planning authorities are being asked to plan for 41.9% more houses than the needs identified by DCLG population projections. The consequence of this is it is likely that far more green field land is being allocated for housing than is necessary to meet our housing need.

Regular readers will know that for some time we have been concerned about the overall level of housing Hart District is being asked to deliver.  To this end,  we have been analysing our Strategic Housing Market Assessment (SHMA), and together with Winchfield Action Group (WAG), we have commissioned an independent look at Hart’s SHMA.

However, we have also been inspired by the work of Alan Wenban-Smith criticising the Vale of the White Horse SHMA. This has led us to take a look at a number of SHMAs around the area, comparing the starting point of the official Government population and household forecasts to the end point of the recommended housing need after taking into account a number of additional elements like additional inward migration to the area, affordable housing, changes in average household size and jobs forecasts.

The findings are quite alarming and lead to a number of conclusions, some of which should be relevant for national planning policy.

We have looked at 6 SHMAs covering large areas of Hampshire, Berkshire, Surrey and Oxfordshire.  Overall the total “starting point need” for these areas is 272,200 houses, and the end point “need” is 386,286 houses, or an uplift of 41.9%.  This is shown in the table below:

 

SHMA AreaLoca Authorites coveredAuthorStarting year yearEnd point yearStarting point "need"Ending point "Need"% Uplift over starting pointNotes
HRSHHart, Rushmoor Surrey HeathWessex Economics20112031158002360049.4Starting point is 2011 DCLG and SNPP projections
South HampshirePortsmouth, Fareham, Gosport, Chichester, Bognor Regis, Southampton (West Centre), Southampton (East), Winchester, Eastleigh, Lymington, Totton, HavantGL Hearn201120368710513161151.1Starting point is 2011 DCLG and SNPP projections
East HampshireEast HampshireNathaniel Lichfield & Partners201120288105960518.5Start point 2010 SNPP
WaverleyWaverleyGL Hearn201120317670940022.6Start point 2011 SNPP and CLG projections
BerkshireBracknell Forest, Reading, West Berks, Wokingham, Slough, South Bucks, RBWMGL Hearn201320369577211201017.02012-based SNPP
OxfordshireCherwell, Oxford, South Oxon, Vale of White Horse, West OxonGL Hearn201120315774810006073.32011-based projections
Total27220038628641.9

 

The DCLG population and household forecasts “are statistically robust and are based on nationally consistent assumptions“, so the net effect of adjustments across all SHMAs should be close to zero.  If this sample is indicative of what is going on across the country, then councils will be planning for far more houses than we need and as a consequence will be allocating for development far more green field land than is necessary to meet our housing requirements, with disastrous consequences for our countryside. Current housing delivery is around 150K per annum, and the DCLG figures suggest an underlying need of 220K per annum. If my analysis of this sample is indicative of what is going on across the whole country, councils will end up planning for about 312K houses which would be a big waste of national resources.

We would like to see this analysis repeated on a national basis.  However, an FOI request to the DCLG has not been successful because they don’t collate this data at a national level.  For a Government that wants to focus on brownfield development, this looks to us to be a reckless omission.

The SHMAs on which this analysis is based are:

Hart, Rushmoor and Surrey Heath, here.

South Hampshire, including Portsmouth, Fareham, Gosport, Southampton, Eastleigh and Havant, here.

East Hampshire, here.

Waverley, here.

Berkshire, here.

Oxfordshire, here.

 

 

Hart Council Leader stonewalls questions about revisions to the SHMA

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Regular readers may remember that we put a number of questions to the Hart Council meeting on 29 October about changes in household, population and jobs forecasts that should be incorporated into the revised SHMA.  All of these questions were met with a wall of silence and peremptory answers.  The Q&A can be found on the council website, with the relevant questions and answers re-produced in full below.

We have not yet received an answer from the Joint Chief Executive to back up his assertion that the brownfield capacity of the district is only 1,800 units.

Question: Given that the baseline estimate of the number of households in Hart in 2011 and 2031 used in the SHMA was 35,760 and 42,220 respectively, but the new DCLG 2012-based household projections (Table 406) for 2031 show that Hart will have only 40,618 households, a reduction of 1,602, can you confirm that these revised figures will lead to a corresponding reduction in Hart’s assessed housing need?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: When will the 6,560 excess housing requirement for the whole HMA be removed from the assessed need in the SHMA given that the new DCLG 2012-based population projections (Table 426) show a population projection of only 289K for the HMA for 2031, compared to the SHMA (Appendix F, Figure 2) starting assumption of 307K and the final population estimate of 322K used to determine housing need?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What justification is there for assuming the significant social changes implied in the SHMA given that the SHMA increases the number of houses that need to be built based in part on very ambitious jobs forecasts which when combined with the population projections in the SHMA results in a massive increase in the proportion of people of working age who will be in employment (see table below)?

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What steps will be taken to adjust the jobs forecasts in the SHMA given that, a) the revised BRES job numbers for 2013 show that the compound annual growth rate in jobs we have achieved since the recession ended in 2009 is ~0.5% which is much lower than the ~0.8% growth rate assumed in the SHMA for the period 2011-2031, b) this comes at a time when the UK is creating more jobs than the rest of the EU put together and c) it is inevitable we will experience at least one more recession during the plan period?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: What steps are being taken to accelerate the delivery of the Local Plan given that the recent Government announcement indicated that Local Plans need to be brought into force by 2017 and the current LDS shows the Local Plan being adopted in Summer 2017 and other DPD’s in Autumn 2018 and the track record of past slippage?

Response: Section 99 of the Housing and Planning Bill which provides for the reserve powers for the SoS at DCLG to recover a local plan does not have any dates. The operative wording is “if the Secretary of State thinks that a local planning authority are failing or omitting to do anything it is necessary for them to do in connection with the preparation, revision or adoption of a development plan document”. The Joint Chief Executive, who is the planning lead on the District Councils Executive network, has ascertained that provided that councils are making reasonable progress towards a local plan, the SoS does not intend to intervene. The powers are intended for a small minority of councils who are making little or no effort to establish a plan. I have independently validated this with my own contacts on the Environment, Economy and Housing Board at the Local Government Association among others. We therefore don’t think the Government will intervene if we meet our new timetable given we will already be at examination in the Spring of 2017.

Fog descends on the Hart Local Plan

Fog descends on Hart Local Plan

Fog descends on Hart Local Plan

A number of new developments are emerging on the Hart Local Plan, that show that the overall process is confused and murky.

First, we understand that a new Housing Options paper is being produced that will go to a special meeting of Hart Council Cabinet on 18 November.  This paper will then be offered for consultation, although the consultation period is not clear.  Usually, six weeks are allowed for consultation, but there is some suggestion that this period will be reduced.

Second, it has emerged that the Strategic Housing Market Assessment (SHMA) is being revisited to take account of changes in the population and household forecasts.  We hope that this work will also take the opportunity to take a fresh look at the outlandish jobs forecasts in the current version of the SHMA.  We believe that this work should result in an overall reduction in the housing allocation for Hart and the rest of the housing market area that includes Surrey Heath and Rushmoor.  This would be good news and should remove the threat of Surrey Heath and Rushmoor asking Hart to build 3,000 houses for them.  It is understood that this work will be completed early in the New Year.

Third, Hart District Council is embarking upon a process to identify additional brownfield sites across the district by consulting with town and parish councils.  It is unclear how long this process will take, but it is fairly clear it will not be complete by the time the Housing Options paper is due to be completed.  The council has still not committed to creating a proper register of brownfield sites across the district.

Finally, Rushmoor are still working on the results of the consultation they ran over the summer and are planning to publish a revised Local Plan for consultation early in the New Year, presumably taking account of the revised SHMA.

Pulling all of this together, it appears we are going to be consulted again on Housing Options which is to be welcomed, but the number of houses we need to accommodate will not take account of the latest thinking in the revised SHMA, nor Rushmoor’s revised plan nor will it take account of the total brownfield capacity in the district.  It also seems odd that the council is seeking to force through a new consultation on a compressed timescale in the run up to Christmas, which is a time most residents will be focused on other things.  All in all, a very murky process.

Community Campaign Hart takes aim at the Heart of Hart

Hart District Council takes aim at the Heart of Hart

Community Campaign Hart takes aim at the Heart of Hart

Community Campaign Hart (CCH) have published a new newsletter on their website that calls for a new settlement to destroy the Heart of Hart in Winchfield.

In their article they make criticism of We Heart Hart and the good residents of Winchfield, and come to the conclusion that the only viable option for delivering the housing we need is a new settlement of 3,000-5,000 houses in Winchfield.  In their article they make a number of assertions that we believe are false, and will now seek to correct them, point by point.  But first, it is important that we start with the areas where we agree with CCH.

Points of Agreement

CCH say:

Until Hart have an LDP which meets the approval of a Government-appointed inspector, developers are in effect able to build on almost any greenfield site they choose

We broadly agree with this, although as in the case of Hop Garden Road in Hook, sometimes common sense can prevail especially now that Hart has more than 5 years of land supply.  However, if CCH are so concerned about the lack of a Local Plan, they should work more closely with We Heart Hart and others to ensure that Hart Council takes proper steps to improve the management of the Local Plan project that has slipped its timescale by two years within two years.  They would do better to use their time at council meetings to ask questions about the local plan rather than seek to stifle difficult questions.

Points of Difference

1. CCH say:

There just isn’t enough brownfield land available to accommodate that number of new homes, unless we are going to build high-rise tenement blocks along the length of Fleet Road.

This is simply not true on a number of levels.  First, the council hasn’t even created a proper register of brownfield sites so it hasn’t properly assessed capacity.  Second, our own work has shown there’s capacity for between 2,438 and 3,688 units, compared to the remaining unsatisfied “need” of 2,900 given at the last cabinet.

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

Third, parts of Fleet Road are a disgrace to the district and should be redeveloped, not with tenements, but with mid-rise (say 3-4 storey) high quality apartments to help young people get on the housing ladder.  Finally, there is brownfield capacity all over the district including Ancell’s Farm, Bartley Wood, Pyestock, Bramshill and Guillemont Park.  They really should get out more and see all of the vacant offices around the district.

2. CCH say:

With a mainline railway station far closer to it than to any other new development in Fleet; with the option to integrate new roads onto the A30 and through to the M3; together with sufficient scale to fund three new primary schools and a new secondary school, Winchfield strikes many as being the best compromise

This is economic incompetence of the highest order.  The council’s own assessment of infrastructure needs points to costs of over £300m for a new town including the schools, but not including improvements to healthcare.  The ballpark estimate for developer contributions made by a senior Hart Councillor is around £40m.  There’s already a £78m infrastructure funding deficit in the district and £1.9bn across Hampshire.  Not only would a new town at Winchfield destroy green fields, it would destroy ancient hedgerows and put at risk SSSI’s and SINCs, but it would no doubt further increase congestion in Fleet and Church Crookham.

3, CCH say:

Consequently they have resorted to social media and other marketing techniques to promote the ‘wehearthart’ message.

However, their messaging is incomplete. They point to the council wishing to build a new town at Winchfield and seek to demonize anyone who may have reached the conclusion, however reluctantly, that a new town at Winchfield is the least worst solution out of an abhorrent set of options. They do not explain what the alternatives are, as the National Planning Policy Framework (NPPF) mandates that this level of housing must go somewhere within Hart’s borders

We do not see what is wrong with communicating with the public using social media on the serious issue of the Local Plan, particularly when the council gets its own facts wrong.  However, We Heart Hart has explained what the alternatives are at some length, and the CCH Chairman of the council sought to have questions that we raised to indicate a different path censored at council meetings.  The alternatives are:

a) Reduce the alleged housing need by challenging the SHMA, particularly taking into account the latest DCLG population forecasts that indicate a lower population in 2031 than assumed in the SHMA and the reducing ridiculous jobs forecasts.  CCH would do well to engage with this debate instead of seeking to censor it.

b) Explore the options for reducing the assessed housing need by exploring so called “policy on” options to protect the environment and ecology.  Note that Winchfield is beautiful countryside in its own right, but is also within the 5km zone of influence of the Thames Valley Heath SPA.

c) Properly get to grips with brownfield options by establishing a brownfield register, actively encouraging landlords to redevelop their derelict sites and exploring the use of Compulsory Purchase Orders on sites that have sat vacant for years with no apparent signs of progress (e.g. Hartland Park aka Pyestock).

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

CCH need to wake up, smell the coffee, listen to Ranil Jaywardena and use their talents to establish a different vision to protect the countryside they profess to love rather than coming out with incomplete, inaccurate nonsense.  Be careful who you vote for in next year’s local elections.

This story now covered in the local press, see here.

Questions for Hart Council meeting on 29 October 2015

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Hart District Council meets again on 29 October at 7pm.  We have been busy preparing some questions for them on brownfield capacity; the impact of the new Government announcements about brownfield sites; Ranil’s statement about protecting our green fields; when they might use Compulsory Purchase Orders to acquire vacant sites; the inaccurate assumptions in the SHMA and the slippage in the timetable for the Hart Local Plan.

The questions can be downloaded from the button, and are re-produced below:

Questions to Hart Council on 29 October 2015

To Daryl Phillips

  1. Please provide an analysis, including SHLAA ref, site name and description, site area in hectares, and expected yield, of the sites that have been used to build up the estimate provided at cabinet on 1 October 2015, when you asserted that the ‘guesstimated’ capacity for brownfield development in the district up to 2031 was now 1,800 dwellings (up from the 750 dwelling estimate of a year ago and compared to the 2,438 units estimated by WeHeartHart).
  1. How will the recent Government announcement extending permitted development rights indefinitely and allowing automatic planning permission in principle on brownfield sites impact your assessment of brownfield capacity?

To Stephen Parker

  1. Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?
  1. What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?
  1. How many sites would meet those criteria and how many dwellings might they yield?
  1. Given that the baseline estimate of the number of households in Hart in 2011 and 2031 used in the SHMA was 35,760 and 42,220 respectively, but the new DCLG 2012-based household projections (Table 406) for 2031 show that Hart will have only 40,618 households, a reduction of 1,602, can you confirm that these revised figures will lead to a corresponding reduction in Hart’s assessed housing need?
  1. When will the 6,560 excess housing requirement for the whole HMA be removed from the assessed need in the SHMA given that the new DCLG 2012-based population projections (Table 426) show a population projection of only 289K for the HMA for 2031, compared to the SHMA (Appendix F, Figure 2)
Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

starting assumption of 307K and the final population estimate of 322K used to determine housing need?

  1. What justification is there for assuming the significant social changes implied in the SHMA given that the SHMA increases the number of houses that need to be built based in part on very ambitious jobs forecasts which when combined with the population projections in the SHMA results in a massive increase in the proportion of people of working age who will be in employment (see table below)?

 

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

 

  1. What steps will be taken to adjust the jobs forecasts in the SHMA given that, a) the revised BRES job numbers for 2013 show that the compound annual growth rate in jobs we have achieved since the recession ended in 2009 is ~0.5% which is much lower than the ~0.8% growth rate assumed in the SHMA for the period 2011-2031, b) this comes at a time when the UK is creating more jobs than the rest of the EU put together and c) it is inevitable we will experience at least one more recession during the plan period?
Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Hart, Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

  1. What steps are being taken to accelerate the delivery of the Local Plan given that the recent Government announcement indicated that Local Plans need to be brought into force by 2017 and the current LDS shows the Local Plan being adopted in Summer 2017 and other DPD’s in Autumn 2018 and the track record of past slippage?

Hart household projections fall according to new figures from DCLG

Cows in Winchfield, Hart District, Hampshire

Do we want to lose our cows to concrete?

In a piece of good news, revised population projections published by the Department of Communities and Local Government (DCLG) show that Hart will have fewer households in 2031 than were assumed in the Strategic Housing Market Assessment (SHMA).  This should have the effect of reducing the housing requirement being imposed on Hart District as part of the Local Plan.  This might reduce the remaining 2,900 houses left to grant permission for and make it more likely we can meet all of the remaining need from brownfield sites.

 

Local Authority2011 householdsSHMA start point for 2031 using 2011-based population projectionNew projection for 2031 using 2012-based population projectionChange between 2011-based and 2012-based projectionsSHMA end-point for 2031
Hart357574222040618-160243291
Rushmoor365594083042362153246381
Surrey Heath33632381703832115140689
Total10594812122012130181130361

 

However in other news, the same new figures for Rushmoor and Surrey Heath show higher projections for households up to 2031 than were assumed in the SHMA.  This might increase the housing requirement for Surrey Heath and Rushmoor and they may ask that Hart builds those houses for them.

What is clear is that the SHMA then makes several dubious adjustments to the baseline DCLG projections that add a further 9,000 or so houses to the total for the housing market area that need to be challenged.

The DCLG figures can be found here and here.  The SHMA can be found here.

If SHMA adjustments were applied nationally we would be building too many houses

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 1: Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Evidence presented at the examination of the Vale of the White Horse Local Plan has demonstrated that if the adjustments made to the baseline DCLG housing projections were applied on a national basis, they would increase the national output of housing to double the DCLG estimate of what is needed and triple the recent output of housing.

Applying a similar approach to the Hart, Rushmoor and Surrey Heath SHMA shows that on a national basis, we would be delivering 54% more housing than we need on a national basis, see Figure 1 above.  Surely it cannot be right that we are being asked to build at a rate that would lead to a surplus of housing.

England housing delivery actuals and projected 1946-2031

Figure 2: England housing delivery actuals and projected 1946-2031

The baseline DCLG projections for the combination of Hart, Surrey Heath and Rushmoor call for 790 houses per annum (SHMA Figure 7.3).  This equates to the DCLG projection of 220,000 houses per annum nationally (see figure 2 above).  This compares to recent performance of around 150,000 houses per annum.

The final SHMA, after taking into account past under-delivery, amount to a total of 24,413 houses (see table below), or an increase of 54.6% over the DCLG baseline figures.  The duty to cooperate might mean that Hart District has to build more houses than either Surrey Heath or Rushmoor as part of our Local Plan.

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

If the same 54.6% uplift were applied to the DCLG projection, we would be building over 340,000 houses per annum nationally, more than double recent performance.

In recent years Hart has built more houses than it has been required to do and built at a rate above regional and national averages (SHMA Table 5.11).  It is beginning to look like the total of the local SHMAs are much larger than the overall requirement as defined by the DCLG. Surely it cannot be right that we are being asked to build at rate more than 50% higher than the DCLG suggests we need to meet overall demand.

Latest jobs growth figures well short of SHMA estimates

Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

The Government have released the revised BRES job numbers for 2013 and these show that the jobs growth rate we have achieved since the recession ended in 2009 is still much lower than the jobs growth rate assumed in the SHMA for the period 2011-2031, during which period it is inevitable we will experience at least one more recession.  This comes at a time when the UK is creating more jobs than the rest of the EU put together, so can hardly be described as a normal set of circumstances.

The flawed jobs growth rate in the SHMA adds 5,100 extra houses to to the overall housing allocation to the combined Housing Market Area of Hart, Surrey Heath and Rushmoor.  The impact of this is that it pushes up Hart’s own allocation and forces Surrey Heath and Rushmoor to ask Hart to become a sink for 3,000 extra houses for them. Furthermore, these jobs forecasts lead to over-estimates of the amount of employment land we need and so constrains the amount of land that might be made available for housing.

Hart becomes Housing Sink for Surrey Heath and Rushmor

Hart becomes sink for 3,100 houses from Surrey Heath and Rushmoor

If these errors in the SHMA growth rate were corrected the threat from Surrey Heath and Rushmoor would evaporate and Hart’s own housing allocation for the Local Plan would come down from 7,534 to around 6,750, which would definitely mean the remaining requirement could be made from brownfield sites alone.

How long before the penny drops with Hart District Council and the other Hampshire boroughs that they need to revise the SHMA to a more realistic number?