Please help Hart fend off an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

Rushmoor Borough Council has published a draft Local Plan where it proposes to build only 8,200 of its assessed need of 9,822 houses over the plan period.  It is clear that Rushmoor is seeking to offload the remaining 1,622 houses on to Hart District.

We need to oppose this move and We Heart Heart have produced some materials to help you do this easily.  Our voice will have greater weight if we can get more Hart residents to comment on Rushmoor’s plan than Rushmoor residents. Please follow the simple process below:

  1. Download the Local Plan response form from the link below.
  2. On page 3, fill in your name and contact details and type your name and date in the boxes at the bottom of the page.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to [email protected]
  5. Share a link to this page to all your friends and family as well as any sports clubs or community groups you belong to via word of mouth, email, Facebook and Twitter and ask them to put in a response and share this page again.
  6. If you have not already done so, please sign and share our petition too.
Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form

A summary of the arguments we are putting forwards is outlined below.

Slippery slope to taking more housing than the other districts

The proposal to take an additional 1,622 houses from Rushmoor puts us on the slippery slope to accepting a further 1,400 houses from Surrey Heath such that Hart District ends up having to build the most houses in the Housing Market Area.

 

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

 

This will impact all of our districts including Blackwater and Hawley; Bramshill;  Church Crookham; Crondall; Crookham Village; Dogmersfield; Elvetham Heath; Eversley; Ewshot; Fleet; Greywell; Hartley Wintney; Heckfield; Hook; Mattingley; North Warnborough; Odiham; Rotherwick; South Warnborough; Winchfield; and Yateley adding additional pressure to an already difficult situation and make it more likely we have to accept both a new town and urban extensions on our beautiful green fields and countryside.

Hart and the rest of Housing Market Area are being asked to build too many houses

The whole Housing Market Area (HMA) should reduce the assessed need by 7,800 units which would reduce the pressure on Hart directly and remove the need for Surrey Heath and Rushmoor to ask us to build >3,000 houses for them. This is discussed in more detail here.

Rushmoor isn’t making best use of its brownfield sites

This is discussed in more detail here and here. As can be seen, if Rushmoor gets more creative with Wellesley and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need.   It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build out of this wealth of opportunity.  Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries.  It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas.  Neighbouring districts could be approached to provide SANG capacity if required.  Rushmoor should also take a closer look at all the vacant sites in the district and seek to convert them to residential use.

Rushmoor’s Employment Land Review is overblown and seeks to protect more employment land than is necessary.

This is discussed here.  It is also clear that past forecasts got it wrong as evidenced by the large number of vacant office blocks and empty shops across Hart District.  If the ELR was reduced to more sensible levels they could free up more land for housing.

Indeed, even if you accept the overblown employment forecasts, there will be a surplus of nearly 600K sq m of employment space at the end of the plan period, covering around 195 Ha.  Yet Rushmoor seeking to protect 96 Ha of land whilst asking Hart to build 1,600 houses on green fields.

Rushmoor’s infrastructure plans are not credible

We posted here that Hampshire as a whole has a £1.9bn infrastructure funding deficit, with Rushmoor’s share of that being £80m.  Rushmoor makes no mention of this deficit in its draft Local Plan.  Hart’s own numbers show an infrastructure deficit of £78m.  All of these numbers are probably an under-statement given they were all produced before the scale of development now proposed was known.  This is in contravention of NPPF para 177 that says there must be a “reasonable prospect” of delivering the required infrastructure alongside housing:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan”

Finally, they don’t even attempt to quantify the extra infrastructure Hart would need to build the extra 1,600 houses nor do they make any offer to fund any of that extra cost.

Rushmoor not planning to meet the needs of the ageing population

Figure 10.15 of the SHMA sets out the need for specialist housing and registered care places for the HMA and Rushmoor.  This states Rushmoor must build 710 sheltered and extra care units as well as provide an extra 600 registered care places. Their draft Local Plan makes no mention of the extra registered care places and sets no target for the sheltered and extra care units.  This is in contravention of NPPF para 50 which states:

“local planning authorities should…plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)”

Therefore the Rushmoor draft Local Plan runs the risk of being found unsound and should be revised.

 

In conclusion, the Rushmoor draft Local Plan contains many serious flaws and needs to be revised.

Link

 

Rushmoor has potential capacity for over 30,000 homes

Rushmoor Borough Council SHLAA Analysis

Rushmoor Borough Council SHLAA Analysis

In an earlier post, we highlighted how Rushmoor is not making the best use of the land set aside for the Wellesley (aka Aldershot Urban Extension) development.  Modern planning techniques could increase the yield of that site to over 21,500 dwellings.

We Heart Hart has now been given access to Rushmoor’s full SHLAA.  This shows that outside Wellesley, Rushmoor have identified 60.51Ha with a planned density of 51dph yielding 3,083 units. In addition, 128.74Ha are shown where they are not currently planning to build any houses (zero yield sites).  If these sites were planned to deliver at the same 51dph, they would yield an additional 6,560 units.  Without changing Wellesley, this would bring the available total capacity up to 13,493 units (or density could be increased on the 60.51Ha), far in excess of the assessed need of 9,822.

As can be seen, if Rushmoor gets more creative with Wellesley, and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need.   It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build and what to foist on to Hart District.  Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries.  It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas.  Neighbouring districts could be approached to provide SANG capacity if required.

This analysis will form part of our response to Rushmoor’s draft Local Plan.

 

Hart District and Rushmoor can meet their housing needs from brownfield sites for 50 years or more

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

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire

A new paper by young architecture graduate, Gareth Price shows that Hart District and Rushmoor Borough could build 49,000 homes on brownfield sites by shedding the old models of the past and adopting a more modern approach of building higher density developments in existing urban areas.  This would avoid urban sprawl and protect our green fields to act as amenity space for the enjoyment of all.

Gareth’s document goes through many of the brownfield sites in both Hart and Rushmoor and applies modern techniques to demonstrate how more can be made of existing land to build more affordable homes on brownfield sites in urban areas to meet the needs of younger people who are struggling to get on the housing ladder and the elderly who will more, smaller more manageable homes closer existing amenities and infrastructure.

The paper illustrates also illustrates where these techniques have been applied in London and on the continent to create vibrant, cohesive communities.

This paper is exactly the sort of thing that We Heart Hart had in mind when we put forward our 5-point plan for improving Hart’s approach to the Local Plan where we called for a competition to be held amongst architects to illustrate the art of the possible on our brownfield sites and provide a vision to guide the regeneration of our urban town centres as an alternative to endless urban sprawl across our green fields.

No doubt there will be some who will disagree with the level of development intensity Gareth proposes for some areas in Hart, where he concludes we could build 25,000 homes on them.  However, it is clear that the capacity of the brownfield sites he has studied is very much greater than the 700 dwellings Hart has said we could deliver over the period up to 2032.  Indeed, according to our brownfield monitor the capacity is already up to 2,360 units in just 6 months.  We must challenge Rushmoor to make more of their brownfield sites.

The paper can be downloaded below:

 

A sustainable approach to building on brownfield sites in Hart District and Rushmoor
A sustainable approach to building on brownfield sites in Hart District and Rushmoor

 

Link

Hampshire has £1.9 billion infrastructure funding gap and Rushmoor faces £80m funding shortfall

£1.9 billion infrastructure funding deficit in Hampshire

£1.9 billion infrastructure funding deficit in Hampshire

A series of interesting revelations have resulted from the recent publication of Rushmoor Borough Council’s Draft Local Plan.  The bottom line is that back in 2013, Hampshire County Council identified an infrastructure funding deficit of £1.91bn out of a total requirement of £2.16bn, or to put it another way more than 88% of the requirement is not funded.

Hampshire Infrastructure Funding deficit of £1.9bn

Hampshire Infrastructure Funding deficit of £1.9bn

Of this gap, £80m was attributed to Rushmoor:

“For the infrastructure defined, a total estimated funding shortfall of approx. £80 million has been identified for Rushmoor Borough over the next 15 years.” 

All of these figures were compiled before the latest housing requirement was calculated so the up to date figures are likely to be much higher.

In its draft Infrastructure Plan, Rushmoor makes no mention of the costs of the infrastructure needs it has identified nor has it explained where it will get the funding from to meet those needs.

Perhaps this explains why Rushmoor is so keen to offload 1,600 houses on to Hart.  Remember Hart already has a £78m funding deficit of its own, and this is probably an under-statement because it doesn’t include any allowance for additional schools, improved railways or better GP surgeries.

The National Planning Policy Framework para 177 says:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.”

It is simply inconceivable that both Rushmoor could have got so far with its Local Plan without addressing how its infrastructure is going to be funded.  Surely this must be enough to find its plan unsound.  We Heart Hart will work to help Hart residents object to Rushmoor’s draft Local Plan.

Hart Council rolls over and starts to plan for an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Do we want Hart District to turn into an urban sprawl?

We Heart Hart understands that at the Local Plan Steering Group last week councillors were told that they will have to start planning for an extra 1,600 houses from Rushmoor.  We have previously warned that by planning for a new town, Hart was creating capacity that would force it to take the unmet needs of Surrey Heath and Rushmoor. Indeed the advice from Peter Village QC was that Hart should pursue the duty to cooperate discussions in a “robust and inquisitive manner”.

This would take Hart’s target to 2032 up to 9,134, up from the current (in our view overblown) target of 7,534.  This is simply wasting the good work that has identified additional brownfield capacity in the district.

However, Hart Council’s actions are going much further than the advice they received from the Planning Inspector as recently as March 2015:

“Tactically, Hart should show to an inspector that it acknowledges the housing problem, and accept that it is likely to have to take an element of unmet need now. This would show an inspector that Hart is being reasonable in the circumstances. In practice this could mean taking an element of Rushmoor’s need now, but dealing with further shortfalls in Rushmoor and Surrey Heath through an early review once there is more certainty over what those authorities can deliver. Hart would need to quantify the amount of unmet need it is agreeing to take in its plan. It would also need to justify why it’s not taking all the unmet need.”

So, far from taking “an element” of Rushmoor’s need now, they are proposing to plan to take the whole lot.  Of course there are no reports yet of how they are going to close the existing £78m funding gap, let alone how to fund the extra infrastructure required to support the extra 1,600 houses we have to build for Rushmoor.

The whole reason why we are being put in this position is that the combined housing market area of Hart and Rushmoor and Surrey Heath Boroughs is being asked to build too many houses because the Strategic Housing Market Assessment (SHMA) is based on some dodgy forecasts.  If the SHMA was brought down to more realistic levels, then neither Rushmoor nor Surrey Heath would have a shortfall.

We need to challenge Rushmoor’s plan now.  We have created a template letter, together with an up to date distribution list of all of the Hart District Councillors and it is available for download below.  Please download it, and all you need to do is cut and past the contents into an email; choose your local councillor email adresses;  add your name and address; alter the contents as you see fit and send it off.  We have also created a template document for challenging Rushmoor’s plan.

Letter to Hart Councillors rejecting proposal to take 1,600 houses from Rushmoor
Letter to Hart Councillors rejecting proposal to take 1,600 houses from Rushmoor
Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form

 

Please sign and share our petition and support our 5-point plan to change course:

 

Go to Petition

 

This story has been covered in Get Hampshire.

 

Link

Hart Council gives go ahead for two office conversions

Vacant brownfield Block at Ancells Farm, Fleet, Hart District, Hampshire

Vacant Office at Ancells Farm, Fleet, Hampshire

Further to our posts about the additional brownfield capacity in Hart District, the council have given the go ahead for two office conversions.

The first is at Pioneer House on Ancells Farm, Fleet and the second is at Providence House, Bartley Wood, Hook.

The Ancell’s Farm, Fleet development is for 33 units and the Bartley Wood, Hook development is for 113 apartments.

Overall, this look to be a welcome development because it relieves pressure on green field development in the district.  However, we would prefer it, if these developments were carried out as part of a master plan to convert certain areas to residential use from office use as opposed to piecemeal development along with necessary infrastructure.

These developments were already counted in our brownfield tracker.

We need to find more of these developments so we can avoid building a new town in Hart and protect our valuable green fields.

Hart Council Local Plan behind Schedule

Hart District Local Plan Project Behind Schedule

Hart District Local Plan Project Behind Schedule

Hart Council is falling behind its own schedule for the delivery of the Local Plan.  This is exposing the district to increasing pressures from developers who have more latitude to push through inappropriate development when there is no Local Plan in place. This does not engender a great deal of confidence that the rest of the project will proceed to schedule.

According to their own schedule they are apparently slipping in these areas:

  • The Employment Land Review is not complete – they have consulted, but not published an updated document.  It is based on the same pie in the sky job forecasts as the SHMA.
  • The Retail and Main Town uses should have been finished in March. There is no document about this subject beyond 2012 on Hart’s website.
  • The landscape capacity assessment should have been completed in April, but again nothing published on their website.
  • Settlement hierarchy paper should have been completed in May.
  • A shortlist of strategic sites for Phase 2 testing should have been complete in April, but it is my understanding that this decision has yet to be taken.
  • The Vision should have been completed in May, again nothing published.

After receiving an unsatisfactory response to a question raised at Hart Council back in April, we raised a Freedom of Information request to receive a copy of the project they are following to deliver the Local Plan. The document we received can be found here. It is clear they are suffering from “unwarranted optimism”.

We Heart Hart Petition breaks 2,000 barrier

We Heart Hart Campaign Logo

We Heart Hart Campaign Logo

The We Heart Hart petition is now really taking off, breaking through the 2,000 barrier over the weekend. This is approaching four times the number of valid responses to Hart Council’s consultation that took place in Autumn 2014 and more than 9 times the number of people (220) of said they favoured a new settlement.

It seems that the people of Hart are backing our 5-point plan for change and waking up to the reality that the Council’s plans will:

Created using the Donation Thermometer plugin https://wordpress.org/plugins/donation-thermometer/.2,350Raised 3,993 towards the 2,350 target.3,993Raised 3,993 towards the 2,350 target.170%
  • Turn the northern part of Hart will turn into a single urban sprawl when there is an alternative of building higher density in urban areas to help rejuvenate our high streets
  • Ignore many brownfield sites untouched all over the district where we could build housing
  • Destroy our environment and the very nature of Hart’s unique appeal – the reason we all love living here.

If you would like to join our campaign, please sign and share our petition:

 

Go to Petition

 

Surely it is now time for Hart Council to think again, act on the legal opinion describing their position as “hopeless”,  focus on brownfield first and listen to the people.

Hart District is being asked to build too many houses

Housing Market Area Migration and housing capacity

Figure 1: Housing Market Area Migration and housing capacity

Hart District is being asked to build 7,534 houses in the planning period up to 2032 (now 9,134 as Hart is starting to plan for an additional 1,600 houses from Rushmoor).  This target is based on the Objectively Assessed Housing Need (OAHN) contained in the Strategic Housing Market Assessment (SHMA) carried out by Hart District and Rushmoor and Surrey Heath Boroughs. We believe this target is too high because the SHMA is based on a number of flawed assumptions:

  • Inward migration assumptions unrealistic
  • Average household size unreasonable
  • Jobs growth forecasts not credible
  • Overall adjustments lead to building rate higher than national requirement

These are set out in more detail below and in the submission to the Owens Farm (Hop Garden Road), Hook appeal. The overall impact of correcting these errors would be to reduce Hart District’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone and won’t need a new town at Winchfield or anywhere else.

Inward Migration Assumptions Unrealistic

Inward migration to this or any other district represents a “want” of people living elsewhere to live in Hart and not a “need”.  Many people may desire to live in Hart because it is one of the best places to live in the country, but no-one “needs” to move to live here in the strict sense of the word.  Indeed inward migration to Hart represents the unmet needs of other districts.  If Government policy is followed, then the housing, employment, education and other “needs” of the people “wanting” to move to Hart should be met by the local authorities where they currently live and thus the apparent need for housing in Hart arising from inward migration should substantially reduce.  There is no evidence presented in the SHMA to evaluate the impact of reduced inward migration to Hart from other districts as a result of those districts now being forced to meet their own needs, nor the impact of the implementation of the Northern Powerhouse.  Indeed London has now agreed to meet its own housing need in full, which should reduce the scale of inward migration to the HMA.

Notwithstanding the above, the SHMA makes a subjective judgement to cherry pick inward migration data from 2005-2010 as being the “most realistic” approach to take to future demographic modelling.  Moreover, it uses spurious statistical analysis to try to infer causation from a weak correlation (R2=~0.65) between housing completions and inward migration.  This is inherently flawed for a number of reasons outlined below.

First, of course it is self-evident that the period during which the HMA delivered most housing was when inward migration was highest.  However, as was argued above, this scale of inward migration represents unmet needs of other districts rather than the unmet needs of Hart.

Second, the period when we were building most and attracting most inward migration was during one of the longest uninterrupted periods of economic growth in history, supported by a large structural deficit in the national accounts and the biggest credit binge of all time.  Of course it ended in a spectacular bust and can in no way be described as a “normal” or “sustainable” set of economic conditions.  The economic conditions we are seeing now with more moderate growth linked to the need for the Government, companies and people to live within their means and reduce debt will be the situation for the foreseeable future and thus represent a more “normal” situation.

The period 2007-2012 includes the final year of the boom, the recession and the now more moderate pace of economic growth that surely more closely represents future conditions.  Indeed, as Figure 1 shows (data taken from Fig. 7.4 of the SHMA on p71) taking the period 2007-2012, the HMA delivered 2,942 new dwellings which at an average of 2.5 people per dwelling created capacity for an extra 7,355 people to live in the area.  Despite that, the HMA experienced an overall outward migration of 1,824 people.  It surely cannot be considered sound to base the future housing “need” on increasing inward migration projections when recent data shows that in fact the HMA is undergoing net outward migration despite creating significant capacity for more people to live here.

Accordingly, the additional 1,210 houses postulated in the SHMA arising from inward migration should be removed from the housing “need”.

Average Household Size Forecasts Unreasonable

Average Houshold Size projections for Housing Market Area

Figure 2: Average Household Size projections for Housing Market Area

 

Figure 7.7 of the SHMA (reproduced as Figure 2 above) shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. This is in direct contradiction to both the 2008-based and 2011-based CLG projections.  Yet the forward projections used in the SHMA reverse the trend shown in actual data in the census and persist with the inaccurate forecasts of a continuing fall in the average household size.

Part of the justification for this is given as “at the time of the 2011 Census, the British economy was still in recession”.  This is factually incorrect as a cursory examination of the GDP numbers on the BBC website shows that the economy came out of recession in mid-2009.  It seems the forecasting “experts” are at a loss to properly explain this reversal of trend.

Moreover, given that the starting point for the SHMA projections is DCLG sourced figures, it would be somewhat odd for the DCLG forward projections not to include its own forecasts for household size.  There is therefore a significant risk that this part of the SHMA has double counted erroneous household size projections.

It is therefore inappropriate continue to assume a continuing downward trend in household size.  Surely a more prudent assumption would be to assume that the current household size is maintained and update that assumption and the SHMA as more real data comes to light.

Accordingly, the 1,500 additional houses in the SHMA related to the flawed household size assumption should be removed.

Jobs Growth Forecasts not Credible

The SHMA uses a set of jobs growth assumptions that are based on forecasts that are vastly in excess of what has been achieved in the most recent economic cycle.

The SHMA contains data on the historic rates of job growth for the HMA.  This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data.  This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%.  Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum for the 3 years in question or a CAGR of 0.05%.

Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3: Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3 shows a comparison of the BRES data and the ABI data that demonstrates the discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data.

Taking this 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum.

However, the SHMA uses as its central assumption that future jobs growth of 1,130 per annum will be achieved, equating to a CAGR of ~0.79%, nearly double what was achieved over the most recent economic cycle and far higher than that achieved during the unsustainable boom of 1998-2008.  Given the constraints on Government spending and tighter credit conditions that are likely to persist for some time due to tighter bank regulation, it is inconceivable that we will achieve an economic growth rate nearly twice that achieved during the last economic cycle. Figure 4 shows the comparison of these growth rates.

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

Figure 4: Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Little justification for this is given other than it is based on Experian forecasts. The recent job creation history (2009-2012) showed jobs growth of 67 per annum as we came out of the recession.  67 jobs per annum equates to less than 6% of the jobs that the SHMA assumes we will create. Revised figures for 2013 demonstrate a CAGR of jobs growth from 2009-2013 at 0.52%, still well below the SHMA projections at a time the UK as a whole is creating more jobs than the rest of the EU put together.  This demonstrates that the Experian forecasts are pie in the sky and it beggars belief that such unproven Experian forecasts should take precedence over the actual real world achievement.

A further illustration of the outlandish nature of the Experian forecasts is given in para 7.70 of the SHMA.  In its forecast published in 2013, Experian assumes there were 145,000 jobs in the HMA in 2011.  Whereas the 2011 Census says there were only 122,300 and the BRES data says 125,000.  How can we trust Experian to forecast the future when it can’t even get the the past right?

Even the Employment Land Review produced by Rushmoor Borough Council described the Experian forecasts as:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”

The SHMA also says at para 7.85:

“…there are many ways labour markets can adjust to an increase in demand for labour that do not require an increase in the resident workforce. In summary these are:

  • A reduction in unemployment
  • A rise in economic activity rates
  • A shift away from part time working to full time working
  • An increase in double jobbing
  • A reduction in out-commuting
  • An increase in in-commuting

None of these changes require an increase in resident population, and all of them will be stimulated if
wage and salary levels increase.

In the modelling, allowance has been made for only one of these effects…”

No explanation is given for not taking into account the other ways in which the labour market can adjust.

In addition, if one compares the jobs forecasts to the population forecasts, the overall forecasts imply a massive, unrealistic increase in the percentage of people of working age in employment as can be seen in the 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%

This shows an increase from around 70% of working age people in employment to 86-88%.  No justification for this increase is given anywhere.

From the above, it is clear that the employment forecasts are outlandishly large and the SHMA does not even take into account most of the ways in which jobs can increase without leading to a need for more housing.  It is clear we should not be basing our housing requirement on such forecasts.

Figure 4.1 of the SHMA demonstrates that Hart in particular and the whole HMA enjoy high levels of employment and unemployment levels that are below the regional and national averages.

Therefore, the number of jobs to be created in the future should at least partially be a matter of “want” rather than “need”.  The future employment targets should be based on a realistic assessment of the capacity of the economy to create jobs in the private sector as it is these jobs that will support the largely state sector jobs in education and health that will be required to support the increased population.

As noted above para 7 of the NPPG states that local communities should be involved

“from the earliest stages of plan preparation, which includes the preparation of the evidence base in relation to development needs”.

Moreover, a recent legal opinion from Peter Village QC has said:

“There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues.”

It therefore follows that the local community should be consulted upon the employment targets it wishes to set and the related scale of development required to meet that target.  No such consultation has taken place, nor is it planned which represents a significant flaw in the Local Plan process. The evidence from the petition indicates that local people are more likely to express a preference for a lower level of development.

Finally, despite enjoying high levels of employment, it is clear that we need to change the way we forecast jobs growth in the area as past methods have resulted in vast amounts of unused employment land and vacant retail outlets with examples illustrated here and here.

It is clear that past employment forecasts have been erroneous; that the future employment forecasts in the SHMA are spurious and do not represent a realistic assessment of future economic or employment growth rates; and the local communities have not been consulted upon this key issue.  Nevertheless, we can achieve enviable growth and employment rates in line with the requirement to “plan positively” without having to resort to such over-development.

Accordingly, the 5,100 additional houses in the SHMA related to the flawed employment forecasts should be removed.

Overall adjustments lead to building rate higher than national requirement

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 5: 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 5 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 6: 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 6 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.

Conclusions

The overall impact of removing these errors would be to reduce the overall housing target for the combined area by around 7,800 units.  This would reduce Hart’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone.

The brownfield development tracker

Brownfield Development thermometer for Hart District

Given the recent success in quantifying the brownfield development potential in Hart District, we thought it would be good to set up a monitor to see how close we are to identifying all of the dwellings we need to meet the residual requirement of 4,000 units for the Hart Local Plan.

This of course assumes that we have to deliver the Objectively Assessed Housing Need (OAHN) in the Strategic Housing Market Assessment (SHMA).  There is a chance we might have to deliver an extra 3,100 houses for Surrey Heath and Rushmoor.  But equally there is also the potential for us to challenge the SHMA and end up with a lower housing target.

We will try and keep track of this as the process develops.