Independent Expert says Hart housing target is too high

Alan Wenban-Smith of Urban and Regional Policy blasts Hart housing target

Independent expert, Alan Wenban-Smith has reviewed the latest Strategic Housing Market Assessment (SHMA) and concluded that the Hart housing target is way too high.

Regular readers may recall that the same expert examined the previous version of the SHMA and came to similar conclusions.

The crux of his arguments are as follows:

  1. The SHMA uses an inappropriate start-point for analysis. It uses the 2012-based population projections instead of the more up to date 2014-based projections. Making this change would knock around 850 houses off the start point
  2. The adjustments made for so-called market signals and affordable housing are inappropriate.
  3. The massive upwards adjustment for alleged jobs growth would result in loads more people moving to Hart. These people would then work elsewhere which is contrary to the sustainability principles of the National Planning Policy Framework

Taken together, his suggested adjustments would reduce the Hart housing target from around 8,000 to around 4,500. We have already built or planned more then 4,500 houses, so the Local Plan would become irrelevant.

We do not quite agree with all of his conclusions. If it were up to us, we would add some extra social rented housing to help those who cannot afford to even rent their own home.

But nevertheless, it is astonishing that Hart Council has decided to add a further 2,000 houses on to the already inflated SHMA. Hart’s approach is putting unnecessary pressure on our valuable green fields.

We will be compiling our suggested responses to the Local Plan consultation over the next few days. Please do keep checking in as we add further content.

The full report from Alan Wenban-Smith on the Hart housing target can be downloaded from the button below.

Independent Expert critique of Hart SHMA

Time to work together to head off new Hart housing threat

Hart Housing threat: sites under consideration

Hart Housing threat: sites under consideration

Overshadowed by our earlier  story of CCH further delaying the Hart Local Plan was the news of the new Hart housing threat of our target being raised from 7,500 to over 10,000 new houses up to 2032. This comes on top of the potential financial costs of delay.

Details of how this has come about are sketchy. It is related to how Hart should respond to Government rules about how to deal with affordable housing. We understand Hart Council is working on a ‘topic paper’ to give a further explanation.

We have analysed the impact of this new target below. Sadly, most of the large, sensitive green field sites are potentially under threat once again.  In addition, it is likely that Hart would no longer have more than five years of land supply. This exposes us to the threat of speculative planning applications. If most of these additional houses end up being ‘affordable’, they won’t attract contributions from developers to fund vital infrastructure.

So, we have come to the conclusion that it is time for all the politicians and pressure groups to work together to fight off this new threat rather than spend their time arguing over where the new houses should go. This level of development will mean that substantially all of the district will be under threat for some time. Moreover, this increased rate of building will be carried forward into the new planning period making things even worse for decades to come. We need to demand three key actions:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. Challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. Pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

Impact of the Hart housing threat on sensitive sites

First we take a look at where we would need to build to meet this new target and compare it to last year’s consultation; the most recent land supply position and our estimate of a ‘fair’ housing target.

Impact of new Hart housing threat on Hart District sites

Impact of new Hart housing threat on sensitive sites

As can be seen above, if the housing target remains around current levels, our remaining housing needs can easily be met from brownfield sites such as Hartland Village (Pyestock), the sites Hart Council identified in the consultation, Bramshill House and some further redevelopment of Ancells Farm and Bartley Wood. Moulsham Lane, Yateley was given the go ahead at appeal over the summer.

For some reason related to the Hop Garden Road appeal, Hart decided to increase our housing requirement up to 8,022 houses.  This is achievable from the 4,000 units we have identified on brownfield sites. But the planners would need to be persuaded to:

  • Redevelop the area around the Harlington and Hart’s offices in Fleet for mixed use.
  • Bring the many other smaller borwnfield sites across the district into the equation.

Failing that, it is inevitable that one of the green field sites is chosen.  For the purposes of this analysis we have used Grove Farm/ Netherhouse Copse as that is up for determination at the moment and the officers have recommended it.

Our estimate of a ‘fair’ housing target is based on the work of Alan Wenban-Smith. This starts with the population projections which on their own would generate a housing need of 5,040 houses over the planning period. A generous allowance is then added for additional economic growth to arrive at a need of 7,140 houses. This is easily achievable on brownfield sites, with some left over for future periods. Note that the new housing target is twice the level of housing required to meet the projected population forecasts.

The new target of 10,177 houses makes it much more difficult to achieve on brownfield. Again, the brownfield capacity could be larger than indicated above if the councillors and planners were to finally deliver on their brownfield study. If they don’t, it is inevitable that most of the sensitive green field sites including Pale Lane (Elvetham Chase), the land west of Hook and one or more of Murrell Green, Winchfield, Lodge Farm or Rye Common come into the equation. As you can see this new housing target will impact everyone.

Impact of Hart housing threat on the land supply

In the absence of the Hart Local Plan and up to date policies, the only defence we have against voracious developers is the five year land supply. This gives some limited control over speculative planning applications. So, we have taken a look at what the new target will mean for our five year land supply.

Impact of new Hart housing threat on 5 year land supply

Impact of new housing target on Hart District 5 year land supply

The left hand columns show the current 5-year land supply that Hart Council use. This shows we are in the relatively comfortable position with over 6 years land supply. If We Heart Hart’s fair housing target was adopted this would rise to 8 years supply.

However, the new housing target would reduce our land supply to below the crucial 5-year threshold leaving Hart very exposed. We would need another 525 additional houses to be granted permission ASAP to bring us back over the threshold.

Conclusion

We are in a very serious position with many of our cherished green fields under grave threat from speculative planning applications. There is no Local Plan and our policies are out of date. Hart is running an infrastructure funding deficit of £78m. The new housing target is double what we need to meet the official Government population forecasts. If the new housing target is adopted, Hart will no longer have a five year land supply. Unless we change tack, all our green fields will be concreted over and lost forever.

To preserve all that makes Hart such a great place to live we need to take serious action:

  1. The councillors need to stop squabbling and get a Local Plan in place ASAP
  2. We need to challenge robustly this new housing target and get the ridiculous new Government rules changed
  3. We need to pressure the council to properly examine the brownfield options for the district, complete their brownfield study and bring these sites forward instead of the precious green field sites.

This can only be done by everyone with a stake in Hart housing development working together to get the best outcome for Hart.

Local Labour Party set out their position on Pyestock

North East Hampshire Labour Party set out their position on Pyestock

The North East Hampshire Labour Party have responded to our request for them to set out their position on developing a new sustainable village at the Pyestock (aka Hartland Park) site. This is an important issue for the Hart Local Elections 2016.

Their response can be found here. They say they support the redevelopment of Pyestock, but still support the idea of a new town at Winchfield.

There are a number of points in their post that We Heart Hart disagrees with and a number of inaccuracies that are addressed below:

Not building enough to meet housing targets

First, it is true that taken as a whole, the country is not building enough to meet its overall housing targets. However, not all of the blame can be pinned on Local Authorities or Government. A recent report form the Communities and Local Government select committee, chaired by Labour MP Clive Betts has said:

The real problem isn’t local authorities failing to give planning permission but developers getting planning permission and then, possibly as a way to maximise profits, taking a long to time to fully develop sites. We are calling on the government to review these proposals, and to identify the powers local authorities need in order to require or encourage developers to build out sites in their areas.

We support the development of brownfield sites for housing where it contributes to meeting local housing needs.

This chimes with our research and that of Alan Wenban-Smith. There is also evidence that housing targets across our area are over-stating the real need, being on average 41.9% higher than the official population projections would suggest.

Inaccurate assessment of the remaining housing need and infrastructure funding

Second, the local Labour party say:

Due to this national under-development, Central Government has given Hart a fairly high building target to reach by 2032 of around 7,500 homes. Somewhere in the region of 3,500 homes have had [sic] been granted planning permission, some of which being on brownfield sites. These developments are simply extensions to our existing towns and villages, but crucially don’t come with any money to pay for improvement to our infrastructure, be it our schools or surgeries.

We agree the target is 7,534 new homes are said to be our ‘need’ in the planning period up to 2032. But, they are inaccurate in their inference that 4,000 homes are yet to be granted planning permission for Hart’s Local Plan. Hart Council’s own figures in the recent consultation stated that only 2,500 still needed to be permitted (see here, para 21). Their claim about infrastructure funding is also untrue in that all developments (with the narrow exception of office conversions) attract S106 or CIL payments.

Due to their insistence that 4,000 more homes need to be granted permission, they say it is inevitable we have to build more housing in the countryside. However, as we have shown above, their claim is inaccurate, but even if it were true, our analysis has shown that there is capacity for around 4,000 homes on brownfield sites. It seems rather perverse to on the one hand support brownfield development, but at the same time be in favour of more green field development.

We have done our own analysis to show that the infrastructure costs of a new town will far exceed developer contributions and Winchfield Parish Council commissioned a report from professional planners, John Boyd Associates, into the new town idea and they concluded that:

  1. There is a lack of evidence to justify the need for a new settlement
  2. Winchfield is not a suitable location for a new settlement
  3. A new settlement is not a viable approach
  4. There should be more of a focus on alternatives such as brownfield development and dispersal

All in all it appears as though the local Labour Party has come to the wrong conclusions based on some dodgy data and inaccurate assumptions.  So, We Heart Hart does not support their position. A summary of all of the local candidates’ positions on this can be found here.

 

Winchfield Parish Council demolishes the new town idea in their response to the Local Plan Consultation

Hart in Heart of Hart, Winchfield, Hart District, Hampshire

Winchfield Parish Council (WPC) have submitted their response and covering letter (see downloads below) to Hart Council’s Local Plan consultation and effectively demolished all of the arguments supporting Hart’s new town idea.  The response was pulled together with the help of professional planners at John Boyd Planning Associates.

There are four main planks to WPC’s argument:

  1. Lack of evidence to justify the need for a new settlement
  2. Winchfield is not a suitable location for a new settlement
  3. A new settlement is not a viable approach
  4. There should be more of a focus on alternatives such as brownfield development and dispersal

The lack of evidence is demonstrated by the fact that Hart has not yet consulted upon the issues recommended by Peter Village QC namely, employment, retail, transport, and infrastructure. Moreover, it is premature and illogical to be conducting the consultation now when the Strategic Housing Market Assessment (SHMA) is being revised and we don’t know what the Objectively Assessed Need is going to be. They also note the work done by Alan Wenban-Smith that seriously challenged the numbers in the existing SHMA.

The challenge to the suitability of Winchfield as a location is demonstrated by the significant barriers to delivery outlined by Hart themselves such as education, transport and foul water drainage. They also point out that the main argument used in favour of a settlement at Winchfield, the presence of a railway station, is undermined by the suggestion that the station would have to be relocated to support the new town. There are also significant doubts about the capacity of the available sites to accommodate a new settlement of sufficient size to be viable, especially when one considers the environmental constraints such as SSSIs and SINCs as well as the space that will have to be found for SANGs, shops, car-parks, schools and recreational facilities. Not only that, but the disparate nature of the sites will make it very difficult to plan a coherent and compact nuclear settlement.

WPC also challenge the viability of a new settlement by pointing out the massive costs of infrastructure with no evidence being presented to indicate how these costs would be met.  The NPPF (para 47 & 173) calls for housing and infrastructure to be planned together, so if it cannot be demonstrated that the right infrastructure can be funded and built, then the whole new town idea could be rejected by an inspector and the Local Plan found unsound.

WPC’s submission welcomes Hart’s belated focus on brownfield development, but criticises them for ignoring an important study by Stonegate Homes, the further opportunities presented by the changes to permitted development rights and the results of Hart’s own findings of new “Zones of Brownfield Opportunity”.  They also point out that Hart’s ‘Economic Development Strategy’ (2015) identifies that the District Council must direct its resources to urban regeneration, and that focusing growth in and adjacent to Hart’s main settlements would
boost investment in infrastructure and regeneration in the locations where it is needed most and help close the £78m funding gap.

Finally, they say that it would be inappropriate to try and meet the housing needs of our ageing population through a new town option.

All in all, this is an eloquent and devastating attack on the whole idea of a new town and is very much in-line with what We Heart Hart has been saying for months.  We can only hope that the councillors will take heed of such an important report from professional planning consultants and get the Local Plan back on track to being found sound at inspection.

 

Cover letter:

Winchfield Parish Council Cover Letter

Full response:

Winchfield Parish Council Local Plan Consultation response

response  covering letter

House of Lords says Government housing policy is short-sighted

House of Lords says Government Housing Policy is short-sighted

House of Lords says Government Housing Policy is short-sighted

A House of Lords Select Committee has described Government housing policy as ‘short-sighted’.  Baroness O’Cathain said:

It is increasingly clear that we need to build more houses in England and we wholeheartedly support that objective. However if we build those houses in the wrong place, to a poor standard, without the consent of local communities we are only storing up future misery for the people in those houses and others nearby.

That is why we are recommending local authorities are once again empowered both to build new homes of their own, and to ensure all developments are of a suitably high quality. Spending a little bit extra on good quality design at the outset can avert massive costs to people, society and Government in the long-run.

The Government should review the National Planning Policy Framework to make sure developers aren’t using financial viability to play fast and loose with design quality and sustainability. If developers submit substandard plans local authorities should be able to ask them to think again without builders falling back on questionable viability assessments to get their way

The full report can be found here.

Developers come in for some damning criticism, with the report saying that they build at a rate to suit themselves and optimise their return on investment (para 268). They also point out that houses are being built at a much slower rate than planning permission is being granted and call for sanctions to be placed on developers who don’t build at the rate required:

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.

The report also calls for a review of compulsory purchase powers (Para 283), suggests that there might be a different taxation regime for landowners selling land (para 280).

The report also calls for the reintroduction of a formal, national brownfield first policy (para 295).

This report is very much in line with the views of Alan Wenban-Smith who provided the independent critique of the SHMA.

In other news, our submission to the House of Commons Economic Affairs Select Committee inquiry into the Economics of the Housing Market has been published.

How developers have gained a stranglehold over Local Plans

The new age of crony capitalism

The new age of crony capitalism has gained a hold over our planning system

The latest 2012-based government projections of population and the number of households points to a need of around 215,000 dwellings per annum, compared to recent delivery of around 150,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

However, there is increasing evidence that housebuilders have too strong an influence over the process that is leading to housing market assessments being artificially inflated to a level much higher than that required by the national household projections.

By way of example, in Hart, the only consultees outside of the council in the work to produce the Strategic Housing Market Assessment (SHMA) were housebuilders, their representatives and registered providers. The resulting objectively assessed “need” was nearly 50% above the starting point identified by the DCLG’s 2011-based population projections. A series of adjustments were made to the raw forecasts to take account of inward migration to the area, average household size and a near doubling of the historic job creation rate. Many of these adjustments have been shown to be erroneous by the release of the DCLG 2012-based population forecasts that are much lower than those identified in the needs assessment.

The experience of the Hart, Surrey Heath and Rushmoor SHMA is by no means unique. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the baseline population projections of around 42%.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 305,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. An FOI request has been made to the DCLG to provide the national figures, but this has been refused on the grounds that DCLG “does not hold this information”. Given the importance that is being placed on housing delivery, it is quite staggering that central Government is not monitoring the results of housing needs assessments on a national basis.

As a group of local residents, we looked at the housing needs assessment for Hart and came to the conclusion that many of adjustments and the resulting “need” were inappropriate and challenged the Council. But, as we were lay people and not planning “experts” our views fell on deaf ears. So, we decided to seek the opinion of professional planning consultants to provide an independent challenge to the objectively assessed need. Our experience indicates that many planning consultants are reluctant to get involved in challenging these assessments because they get most of their work from developers and do not wish to bite the hand that feeds them. We approached a number of planning consultants and they either did not reply to us, were conflicted or said they normally act for developers and would be unable to help. Eventually, we found Alan Wenban-Smith.

Once a Local Plan gets to the stage of being examined by the Planning Inspector, the situation gets worse. Because housing needs assessments are usually produced for a combination of planning authorities but Local Plans are examined at the planning authority level, the actual housing need numbers are effectively unchallengeable. The examination focuses on the process for arriving at the housing need and the actual content is immune from challenge. Residents and environmental interests are being crowded out of inspections by the expensive hordes of lawyers, agents and consultants hired by builders and landowners who share an interest in a narrow discussion focused on achieving the maximum possible increase in estimated housing needs.

In effect, the whole process of assessing housing need through to inspecting the resulting Local Plans has been hijacked by the development industry and their narrow interests. This is in direct contravention of the NPPF which states that local people should be empowered to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of their area.

The consequence of this is that local planning authorities are being bounced into allocating green field sites for development because they are easier to develop than brownfield sites. This will result in an over-supply of land and lead to land-banking by the developers, who will only build at a rate consistent with maximising their profits. If they supplied new housing at a rate that meant house prices fell, they would immediately reduce output because their business model and in particular the price they pay for land is predicated on steadily increasing house prices. So, in effect we are being asked to allocate too much of our most valuable green field land for housing, but will not actually increase the supply of housing to meet the needs of our neighbourhoods and we leave acres of vacant and derelict brownfield sites.

We need to take action now to remove the stranglehold of developers have on this process, put more power back in the hands of local people and take further measures to mandate the development of brownfield sites and protect our countryside. This might involve increasing the powers of local authorities to compulsorily purchase derelict sites and use the profits to invest in our creaking infrastructure.

We must stiffen the resolve of our local representatives to resist the self-interest of developers and work instead for their electorate.  We must also stand up and fight for brownfield only development to protect our countryside from urbanisation. We must vote against a new town.

We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided.  It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

There is a brownfield solution to Hart’s housing needs

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

Vacant Office at Ancells Farm, Fleet, Hampshire

We have done some further analysis on Hart’s Strategic Housing Land Availability Assessment (SHLAA) and come to the conclusion that Hart’s housing needs can be met from brownfield sites alone.  We believe this is a potentially viable solution that should form part of the forthcoming Housing Options consultation as part of the Local Plan.  Instead Hart Council have ignored the wishes of 2,130 people who signed the WeHeartHart petition and only put forward solutions that involve concreting over vast swathes of our countryside.

Hart District Brownfield Development Target

[Updated 2 March 2016 to add in the new brownfield SHLAA sites as described here]

[Updated 31 March 2016 to include Pyestock (aka Hartland Park)]

[Updated 30 August 2016 to re-set target to 2,350 now that Moulsham Lane, Yateley has been given the go ahead]

So, how have we arrived at our conclusion?

Brownfield sites in the SHLAA

We have been through the SHLAA and identified those sites that are mostly or wholly brownfield in nature, and added up total capacity as recorded in the SHLAA.  Pyestock (aka Hartland Park), is now also an official SHLAA site.  In total, these sites amount to between 3,208 and 3,250 homes at an average density of a relatively modest 28 dwellings per hectare (dph). The detail is shown in the table below:

ParishRef.NameBrownfield Capacity in Table 1 in DLPSite Assessment Capacity (Low)Site Assessment Capacity (High)Size (Ha.)Low Density (dpa)
Total3,2083,25011727.9
Blackwater and HawleySHL21Linkwater Cottages, Blackwater12120.6418.75
Blackwater and HawleySHL100Sun Park, Guillemont Park North3003203201226.66
BramshillSHL106Bramshill (Police Training Centre)2502501025
Church CrookhamSHL2826/32 Bowenhurst Road8660.4214.28
Crookham VillageSHL158Crondall House, Fleet27271.1323.89
DogmersfieldSHL39Fermoy, Farnham Road5102.232.24
DogmersfieldSHL55Land at Church Lane, Dogmersfield20200.8224.39
Elvetham HeathSHL104Land at Elvetham Heath4545452.2520
EversleySHL127Land at Paul’s Field, Eversley70702.825
EversleySHL140Land off Warbrook Lane53531.7630.11
EwshotSHL36Dachs Lodge, Redfields, Church Crookham29291.224.16
EwshotSHL80Tanglewood, Ewshot770.3122.58
EwshotSHL174Peacocks Nursery Garden Centre1051053.530
EwshotSHL235Land at Willow Croft, Church Crookham50502.7518.18
FleetSHL41Imac Systems, Fleet6660.05120
FleetSHL42Camden Walk, Fleet9880.2433.33
FleetSHL50Waterfront Business Park, Fleet60601.4641.09
FleetSHL6918 Church Road, Fleet10100.07142.85
FleetSHL102Land at Bramshot Lane45451.825
FleetSHL113Thurlston House1712120.6817.64
FleetSHL245Land at 154-158 Albert Street & Fleet Road14880.1844.44
FleetSHL275Land at Little Mead, Fleet12171.0611.32
FleetSHL320Fleet Town Centre Zone 2201501501.883.33
FleetSHL322Fleet Town Centre Police Station1737370.6160.65
FleetSHL357Land at Sankey Lane, Fleet20200.6431.25
FleetTBAPyestock (aka Hartland Park)1,5001,50048.238.1
Hartley WintneySHL95Nero Brewery, Hartley Wintney660.1540
Hartley WintneySHL216Land adj. to James Farm Cottages, Hartley
Wintney
660.2920.68
HookSHL111Hook Garden Centre, Reading Road, Nr. Hook57574.4712.75
Long SuttonSHL296Old Dairy, Long Sutton550.225
OdihamSHL29Land at Butts End660.415
OdihamSHL66Rear garden of 4 Western Lane, Odiham16160.6425
OdihamSHL119Land at the rear of Longwood, Odiham990.3129.03
South WarnboroughSHL70Stables at Lees Cottage, South
Warnborough
550.2520
South WarnboroughSHL172Granary Court, South Warnborough16160.6923.18
WinchfieldSHL34Land adjoining Winchfield Court18251.0616.98
WinchfieldSHL84Land at Winchfield Lodge60603.815.78
WinchfieldSHL114Trimmers Cottage, Winchfield Hurst12120.4924.48
Church CrookhamSHL81Vertu, Beacon Hill Road, Church Crookham65701.7636.93
Blackwater and HawleySHL176Hawley House, Hawley8100.326.66
CrondallSHL178Broden Stables & Stable Yard, Crondall14271.410
CrondallSHL179Bowenhurst Lane, Crondall30351.520
Hartley WintneySHL189Land at James Farm, Hartley Wintney880.3125.8

A number of these sites are “not currently developable” according to Hart.  But most of the green field sites they have put forward are also not currently developable.  We believe that the issues surrounding brownfield sites should capable of being resolved more easily than those for green field sites.

Sites not in the SHLAA

There are a number of sites not in the SHLAA that nevertheless should be considered that amount to around 785 additional homes.  These include the parts of Ancells Farm, Bartley Wood and Fleet High Street that have not already been permitted or counted elsewhere. We have also counted the complex of under-utilised offices that include Admiral House, Flagship House, Hart Offices and Harlington centre in Fleet.  Much of this site was recommended by Fleet Future, but for some reason Hart Council have ignored it.  But we can think of no reason why a council that was truly committed to a brownfield first strategy would not offer up its own under-utilised offices to be part of new, mixed use development and move to one of the other vacant office blocks in the district.  These sites, with an allowance for parts of sites that have already been permitted, are shown in the table below.

ParishSite DescriptionEstimated capacityNote
Total785
FleetAdmiral House, Flagship House, Hart Offices and Harlington centre350Paper by Gareth Price identified 775 units on a larger site incorporating much of this area
FleetAncells Farm370From Stonegate report
FleetFleet vacant offices220From Stonegate report
HookBartley Wood200From Stonegate report
Less units already granted permission or already counted-355Part of Ancells Farm and Barley Wood already granted. SHL 320 already counted

Conclusions

Drawing this together, there’s capacity for between 3,993 and 4,035 units on brownfield sites, without increasing the density on any of the SHLAA sites.

Now, according to Hart, we have to find space for a further 2,350 homes (now that 150 houses have been approved at Moulsham Lane, Yateley), according to the current Strategic Housing Market Assessment (SHMA).  This shows that we have now more than met our remaining needs from brownfield sites alone. We certainly do not need a new town at Winchfield or any new urban extensions in Hook, Fleet or Elvetham Heath.

However, we also know that Alan Wenban-Smith has challenged the SHMA and said that we need around 2,000 fewer houses.  If this were accepted by the inspector, we would have an even bigger surplus of brownfield capacity to take into the next planning period.

We also know that the SHMA is being revised, and the Government has published revised population and household forecasts earlier this year and these showed much lower figures for Hart.  Again, this should result in a lower housing allocation, and we would end up with a surplus of brownfield sites until the next planning period.

This begs the question why Hart Council is not including a formal brownfield option in its forthcoming consultation, when that was the clear view of the 2,130 people who signed the WeHeartHart petition.  Persisting with new town and urban extension solutions is untenable.  Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

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
Total27220038628641.9
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

 

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.