Calderdale and Dorset reduce housing target

Calderdale Reduces Housing Target

Calderdale Reduces Housing Target

Calderdale and Dorset councils have now both reduced their housing targets in the light of the Government consultation on the new way of calculating housing need. This comes hot on the heels of a similar announcement from Leeds City Council.

Despite the Government saying it was starting ‘formal intervention’ against Calderdale for not producing its Local Plan on time, the housing target has been reduced from 17,000 to 13,000. Calderdale Council has said it will be looking at further opportunities on brownfield sites and increasing densities of town centre developments. The full story can be found here.

Meanwhile, Dorset council is looking to reduce the number of homes it is planning for following the publication of the government’s consultation on a standard methodology for objectively assessed need (OAN). This story can be found here (paywall).

With at least three councils now reducing their housing target, surely it is time for Hart to follow suit. As we have reported before, Hart planned to build a ridiculous 10,185 houses in the draft Local Plan. This compares to the 8,022 in the SHMA. The new Government approach would result in 292 dwellings per annum, or 6,132 over the plan period from 2011-2032. This would be likely increased to around 6,500 once we take into account the need to build a few extra for Surrey Heath. The balance left to plan for could easily be accommodated on brownfield sites:

  • Sun Park (320), from Local Plan para 109
  • Grove Farm (423), sadly green field but given the go ahead by the inspector at appeal
  • The forthcoming Rawlings depot site in Hook (123)
  • The remaining 40 can come from any number of brownfield sites for instance:
    • Hartley Wintney (Nero Brewery – 10)
    • Winchfield (Winchfield Court extension – 17)
    • The derelict eyesores on Fleet Road – up to 200

It is time the CCH/Lib Dem coalition dropped their ridiculous new town ideology and worked to protect our valuable green fields. Sadly, there is no sign of them doing so.

 

 

Fleet and Crookham groups fail to oppose ridiculous housing target

The Scream - Hart Rushmoor and Surrey Heath SHMA

Fleet and Crookham groups fail to oppose ridiculous housing target

The responses to the draft Local Plan consultation have finally been published and it is clear that groups from Fleet and Church Crookham groups have failed to oppose the ridiculous housing target.

We have looked at the responses from the following groups and can find no mention of their objection to the housing target:

  • Face IT
  • Fleet and Church Crookham Society
  • Church Crookham Parish Council
  • Fleet Town Council

Many of these groups strongly oppose the now withdrawn Cross Farm proposal that was included as a strategic site in the draft Local Plan. Their message seems to be: go ahead and build thousands of houses we don’t need, but don’t put them in Fleet or Church Crookham.

Councillors fail to challenge the ridiculous housing target

Completely Concrete Hart CCH fail to challenge the ridiculous housing target

Community Campaign Hart CCH councillors fail to challenge the ridiculous housing target

Moreover, three Community Campaign Hart councillors have responded to the consultation without opposing the ridiculous housing target of 10,185 in the draft Local Plan:

Between them, these councillors argued for:

  • Fewer homes at the brownfield site Hartland Village (Pyestock), which would add to pressure for green field development
  • Dropping Murrell Green in favour of Winchfield East, even though the Murrell Green sites were in the area of search in the 2015 consultation (see image below)  and the Winchfield East sites fared less well in testing.
  • Removing Cross Farm from the Local Plan. This application for this site has now been withdrawn.

No wonder they are being nicknamed Completely Concrete Hart

Winchfield and Hook New Town proposal

Area of search for Winchfield new settlement opportunity

Brian Blewett of the Liberal Democrats has also responded, supporting the position of Blackwater and Hawley Town Council and Neighbourhood Plan group. Neither of these groups opposed the housing target. As far as we can tell, Hook and Crondall Parish Councils did not oppose the housing target either.

We struggle to understand the logic of this position. We can’t understand why members who purport to stand for the good of the whole of Hart support the ridiculous uplift from the SHMA total of 8,022. The Government consultation is clear, Hart’ new housing need is going to be 6.132 units. The remaining target can be met from brownfield sites alone.

Some councillors and local groups oppose the ridiculous housing target

In better news, Andrew Renshaw, member for Hartley Wintney argued for a lower overall housing target. As did the following groups:

  • Crookham Village Parish Council
  • Dogmersfield Parish Council
  • Eversley Parish Council
  • Hartley Wintney Preservation Society
  • Odiham Society
  • Rotherwick Parish Council
  • Rural Hart Association
  • Whitewater Valley Preservation Society
  • Winchfield Action Group
  • Winchfield Parish Council

Alastair Clarke, chair of the Hart District Association of Parish and Town Councils (HDAPTC), also opposed the housing target in his personal response.

It’s great that such a diverse set of groups has seen the logic of opposing the ridiculous 10,185 housing target.

Conclusion

It is time all parishes and groups within Hart united behind the opportunity that the new Government consultation brings. This will benefit the whole of Hart and help stop the needless playing off of one parish against another.

 

 

 

 

 

 

 

New Government methodology to reduce Hart housing need

Time to celebrate reduction in Hart housing need

New Government methodology reduces Hart housing need

Yesterday, the Government published a consultation (Planning for the Right Homes in the Right Places) on its proposals to simplify and standardise the calculation of housing need. The good news is that Sajid Javid’s new  methodology, if adopted, will result in a significant reduction in Hart housing need. There are also reductions for Rushmoor and Surrey Heath.

Significant reduction in Hart Housing need

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

Impact on Hart Housing Need

If this proposal was adopted, the full housing requirement for Hart would fall to 6,132 new dwellings. This compares to the Hart’s current Local Plan total of some 10,185 and the total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022. The new target of 6,132 is above the 5,144 we recommended in the recent Local Plan consultation. But, clearly, if the new figure of 6,132 was adopted, we would welcome it.

The Government now calculates housing need on the basis of the most up to date demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings.

This vindicates the stance we have been taking for years now: Hart’s housing target is ridiculous. The current SHMA takes out of date demographic projections and makes lots of spurious and arbitrary adjustments that don’t address the needs of the district. Then Hart Council added a further 2,000 houses to that. This new approach proposed by the Government is much more sensible.

Impact on Rushmoor and Surrey Heath

This is also good news for Rushmoor and Surrey Heath. Rushmoor’s overall housing target reduces by 2,982 houses. Rushmoor has already said it can meet it’s current target, so this leaves it with significant extra capacity.

Surrey Heath’s target reduces by 630 houses. Surrey Heath has said it will endeavour to meet its current housing target, but if it can’t, then Hart and Rushmoor would be expected to make up any shortfall. Previous estimates of their shortfall were around 1,400 houses. These new proposals make any problems Surrey Heath has much easier to solve.

Taken together, these reductions are very welcome and reduce the risk that Hart will be forced to take any overspill from Surrey Heath.

Impact on the Hart Local Plan

There is further good news. If the current Local Plan is more than five years old or if the new Local Plan is not submitted by 31 March 2018, then the new methodology must be used. This means that Hart should start considering this new methodology immediately.

Impact of new housing need methodology on Hart Local Plan

Impact of new methodology on Hart Local Plan

If the new methodology was adopted, then the Hart housing need drops and Hart would need to build far fewer houses. According to the recent Local Plan consultation, a total of 5,594 houses have already been built or planned for as of January 31 2017. This would 600-700 houses left to plan for, maybe a few more to give scope for taking Surrey Heath over spill. In round numbers, let’s assume 1,000 houses left to plan for. Planning for a few more houses than those demanded by the standard method would mean that the Inspector would have to work on the assumption that the Plan was sound.

New Government housing methodology - impact on planning inspectors

New Government housing methodology – impact on planning inspectors

This could be easily made up from brownfield sites in the draft Local Plan. Sun Park (320) and Hartland Park (1,500) would more than meet the remaining need, with plenty of room to spare. This would mean Hartland Park could be built at a slower rate.

The implication of this is that we would need no new settlement. No building at Murrell Green, no new settlement at Winchfield or at Rye Common. Furthermore, Pale Lane (Elevetham Chase) and Cross Farm wouldn’t be required. It remains to be seen whether the inspector will take account of this new methodology to save Netherhouse Copse (Grove Farm) in the current ongoing appeal.

Impact on Neighbourhood plans

In a further piece of good news, the Government proposes that the way housing need in Neighbourhood plans is calculated should be simplified. It says that it should be based on the proportionate population of the Neighbourhood planning area.

New Government housing methodology - Neighbourhood plans

New Government housing methodology – Neighbourhood plans

This is essentially the same proportionate method that we have been advocating for some time. It will finally mean that David Cameron’s promise that local areas should not simply have new housing estates dumped upon them will be met. This proposal will also effectively mean that existing urban areas should become more dense. This is another policy we advocated in the recent consultation.

Note of caution

So far, this is just a consultation and is not yet adopted. There is therefore a risk that developers will seek to water down the proposals or amend them. We have done a quick analysis of the Government spreadsheet and that shows that roughly half of Local Authorities have had their targets increased and roughly half have seen a reduction. Overall, the housing need identified by the Government is about 266,000 houses per annum, in line with previous estimates of overall national requirements. So, in our view, developers don’t have much of an argument – the proposals seem to redistribute the housing targets where they are most needed.

Moreover, there are some potential pitfalls in planning for certain groups such as the elderly and affordable housing in paras 89 & 90. However, this is really about how to get the total to add up, rather than changing the total.

Conclusion

Overall, we think that if these proposals are adopted it is very good news for Hart, Rushmoor and Surrey Heath. The new Hart housing need would be very achievable and would save many of our precious green fields that are under threat.

We would urge you to respond to the Government’s consultation and give it your support.

We also expect the council to set to work immediately to revise the draft Local Plan to take account of these new developments. This should be easy. They are already planning for far more houses than we need, so striking out the controversial green field developments should be a relatively simple task.

 

 

 

 

Developers battle over new settlement options for Hart District

Battle of the Bastards - the fight for new settlement options for Hart District

Battle of the Bastards – the fight for new settlement options for Hart District

A trio of developers have commenced battle over new settlement options for Hart District. There was a meeting of senior councillors on 9 August 2017, where developers representing three potential new settlement sites made presentations. These presentations will be discussed at Cabinet on Thursday 7 September at 7pm. The three sites were:

  • Rye Common
  • Murrell Green
  • Winchfield

Minutes from the meeting have been published on the Hart website and here.

New settlement options for Hart District – Rye Common

The developer raised the following points regarding their presentation:

  • The site could deliver up to 1,500 with possible potential to expand to 2,000 homes if more land were to be made available.
  • The site is in one ownership.
  • Only a small part of the site was within 5km of the SPA. SANG provision included in the proposal.
  • Design and some technical evidence is at an early stage due to a change in supporting consultants.
  • No secondary school site proposed, although a site of 5ha could be made available in line with HCC guidelines.
  • Some areas of Common Land would need to be de-registered to provide access and re-provided elsewhere.
  • A range of infrastructure to be provided including primary education facilities.
  • Site has areas of groundwater flooding, but no fluvial risk.
  • Access on to the A287.
  • Site would provide open space, allotments etc.
  • There would be no coalescence issues.
  • Small scale employment provision included.

The actual presentation that was given has not been published on the Hart Council website. Overall we view this as a very weak proposal that clearly is not as well thought through as the other proposals.

New settlement options for Hart District – Murrell Green

The presentation and other documents related to this proposal can be found on the links below:

Murrell Green near Hook and Hartley Wintney Framework Plan.

Murrell Green Framework Plan with pipeline

The main points made by Lightwood, the developer in the presentation were:

  • The site can deliver 1,800 -2,990 units if required
  • Plans and evidence are well advanced
  • Developer already on board for first phase
  • In partnership identified proposals to include innovative initiatives within the home and related to travel options, including for electric and driverless cars and provision of electric bikes as central to the masterplan
  • Connectivity through access to the A30
  • Revised secondary school location proposed (9.7ha) with direct access in and out of the site and avoiding residential areas proposed in discussion with HCC
  • A range of infrastructure to be provided including primary education facilities
  • Discussions held with Stagecoach re possible bus routes
  • Access to Winchfield station will be provided
  • Promoters control a significant proportion of the site through option agreements
  • High proportion of 2 and 3 bedroomed dwellings
  • A proportion of dwellings will be designed to be easily extended to prevent the need to move
  • There are viable solutions to ensure that the gas pipeline is not a constraint on development
  • Small scale employment proposed on site
  • Supportive of the use of design codes
  • High speed broadband to be included
  • Design/layouts will ensure protection of the setting of the listed building
  • Open space includes SANG provision, sensory gardens, allotments, sports pitches

We have read these documents and think there are significant problems with this proposal. First, the design proposals still ignore the presence of the high pressure gas main. They make passing reference to re-routing it, but come up with a cost of only £2m. This seems like a very low figure to re-route about a mile of 24″ high pressure pipeline.

Second, the site is being promoted by Lightwood Strategic, which is, in our opinion quite a lightweight organisation with negative net assets. They have entered into some sort of arrangement with Crest Nicholson, but at this stage all of their promises must be taken with a very large pinch of salt.

Third, they make great virtue out of the Amount of SANG they are delivering. Yet, in other parts of the document they offer up some of this land for even more housing. They aren’t quite specific, but the area they identify to the south and west of the site includes the former landfill site at Beggars Corner.

Finally, the roads proposals are totally inadequate. The access to the south is over the tiny bridge over the railway line and the A30 will become a bottleneck in Hartley Wintney and Hook with the addition of  2,000 further houses between them.

The other significant part of the Lightwood presentation was the legal opinion from their QC. This is clearly designed to warn other developers not to send Hart’s Local Plan for judicial review. It is also a warning to local pressure groups to let them get on with their proposals without hindrance or the Local Plan may fail, leaving Hart open to new, even higher housing numbers from the Government.

New settlement options for Hart District – Winchfield

Finally, Gallagher Estates and Barratt Homes made their presentation about the Winchfield proposal.

Winchfield Garden Community Master Plan with pylons and powerline

Winchfield Garden Community Master Plan with pylons and powerline

The main points made by the developer in the presentation were:

  • A scheme for 1,800 homes presented but opportunities to expand to 2,400 to west and south west
  • All land under control of the promoters
  • Technical work including viability very advanced
  • Neighbourhood centre to north of railway line
  • Engagement with Stagecoach
  • A range of infrastructure to be provided including primary education facilities
  • Shuttle signals to be added on road tunnel under railway, will allow for 3m pedestrian/cycle access
  • 14ha proposed for a secondary school, in discussion with HCC
  • Solutions proposed to deal with identified flooding issues
  • Transport modelling work undertaken to prevent rat runs
  • A unique situation as focused around a railway station

The main problem with this proposal are:

  • Gallaghers totally ignore the electricity pylons traversing the school sites and the housing both to the north and south of the railway line.
  • The flood risk on that land is very significant, with the site and roads flooding three times in 2016 alone. They can’t just dismiss this with a single bullet point.
  • The roads proposals to get into and out of the proposed development are totally inadequate.
  • The proposal includes a footpath from the B3016 to Bagwell Lane and the western part of the development which is not currently a footpath and crosses land that is not in the ownership of the consortium.

Our Response

Overall, we think the motive behind these presentations is for the council to be able to say it has studied all of the options in detail.

Our view is that all of these proposals are unnecessary because they only arise from the Council’s insistence on setting a housing target of over 10,000 units, despite the over-inflated SHMA figure of 8,000. If we just reverted back to the SHMA figure, then none of these new settlement proposals will be required. Indeed, if we reverted to a more sensible housing target of 5,144, we could meet all of our housing needs for decades to come form brownfield sites alone.

We think that there is going to be a big battle ahead. The developers are going to fight to get their proposal into the Local Plan. We will continue to fight to reduce this ridiculous housing target and get more of our housing need met on brownfield sites.

 

Please oppose Owens Farm development in Hook

Owens Farm Landscape Strategy Plan at Hook, Hart District, Hampshire

Owens Farm Landscape Strategy Plan

[Update: Planning application now submitted]

Please help to oppose another green field development, this time another 700 houses at Owens Farm in Hook.

This is not yet a formal planning application, but it is expected that a planning application will be lodged in the next couple of months. Developers are required to demonstrate that they have consulted the community before making an application. The developer is “consulting” on their proposal through their website here.

Please take less than 5 minutes to lodge a response in objection. A simple “not needed, not wanted” response is enough to ensure that they cannot claim community indifference to their proposal which is the opposite of what residents have demanded.

You can lodge your objection to Owens Farm here: http://www.owensfarm.co.uk/have-your-say.php. If you prefer you can email comments to info@arplanning.co.uk.

If you need any help for a more detailed objection, please use these references for guidance:

Thank you for your help.

 

Challenge the ridiculous housing target in the Local Plan Consultation

Challenge the ridiculous housing target

Challenge the ridiculous housing target in the Local Plan consultation

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

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

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

The detail of our analysis is shown below. Please object to this ridiculous housing target by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to planningpolicy@hart.gov.uk before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation

There are several lines of argument:

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

Vastly over-achieves against Government housing policy

The 2012-based government projections of population and number of households, points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-170,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

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

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

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

If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.

There might be some justification if this process had resulted in more house building. But it is clear from a recent House of Lords report that it has not:

Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over 240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.

We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding.

This is borne out by local experience, where, as of 1 April 2016 there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

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

Strategic Housing Market Assessment results in a ridiculous housing target

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

Inappropriate Starting Point

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

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

Affordable Housing Uplift

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

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

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

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

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

Jobs Growth Adjustment

Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area, a shortfall of 15-30,000, or almost all the projected job growth.

Second, the projection of 1,200 jobs per annum is far more than the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, the SHMA uses a very circular argument to account for the number of jobs. The argument is: the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs.

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

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

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

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

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

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs, that someone thinks might be possible to create in Hart. Then those people will add to the strain on Hart’s infrastructure (roads, schools, healthcare), but work outside the district. This is not ‘sustainable development’ on any reasonable interpretation of the phrase. Moreover, those exporting districts should already be planning to house those people.

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

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

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

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

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

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

Is the Murrell Green new settlement viable?

Murrell Green new settlement proposal

Murrell Green new settlement proposal

We wrote yesterday that the council has prioritised the Murrell Green new settlement as part of the Hart Local Plan. However, there are very real questions about the viability of these proposals.

  • Environmental concerns
  • Infrastructure issues
  • Coalescence of Hartley Wintney and Hook
  • Financial stability of the promoter

Environmental concerns about the Murrell Green new settlement

Part of the site includes Beggars Corner which is the triangular piece of land between the railway and motorway. A proposal for a solar farm on this land was turned down at appeal last year. The main reasons for turning it down were:

  1. Harming the enjoyment of those walking the public footpath across the site. This is shown as a dotted red line on the map
  2. Spoiling the view from the Deer Park at Odiham

Houses are obviously taller than solar panels, and indeed some houses might have solar panels on their roofs. So, how can it be sensible to build houses when solar panels were deemed inappropriate?

Furthermore, a significant part of Beggars Corner used to be landfill, with unknown contents

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

It is not appropriate to build houses on this type of land. Nor should it be promoted as green-space for children or dog walking when we don’t know what toxins lie beneath.

It should also be noted that a 110kV electricity transmission line traverses the site as well as a high pressure gas main. Hardly appropriate for housing or recreation.

Gas Main through Murrell Green new settlement Site

Gas Main through Murrell Green Site

The site is also within the Thames Valley SPA 5km zone of influence. There are three Sites of Interest to Nature Conservation (SINC) on the site plus a further SINC just to the west at the River Whitewater.

Finally, there are a number of public footpaths that currently criss-cross the site and they appear to be destoyed by this new proposal.

Infrastructure Issues

The only access to the south of the proposed Murrell Green new settlement is Totters Lane. This is single track in places with a very narrow bridge over the railway. To the north there is the A30 which is already very busy, with choke points at Phoenix Green, Hartley Wintney and the roundabout in Hook. It is difficult to see how these choke points can be alleviated.

Those of us who use Winchfield station know that the car-park is frequently full to capacity and of course, the whole line to London is running over capacity. The idea that either Hook or Winchfield stations can accommodate the extra passengers from thousands more houses is simply laughable.

In addition, the previous strategic assessment of Murrell Green included concerns about:

  1. Healthcare provision – I can speak from personal experience that Whitewater Health that covers Hook and Hartley Wintney is full
  2. Primary school provision
  3. Availability of supermarkets

Coalescence of Hartley Wintney and Hook

The proposed site abuts the south western boundary of Hartley Wintney parish and is close to what are currently quite widely spaced houses.

Hook SHLAA sites in Hart District, Hampshire

Hook SHLAA sites in Hart District, Hampshire

The western side of the Murrell Green new settlement comes within a couple of hundred metres of the new development to the NE of Hook (sites 1, 2 and 3 on the image above). Note that sites 4 and 126 on the map above are not (yet) included in the new settlement proposal.

In essence, we are creating Hartley Winchook.

Financial viability of the promoter

Last year, it came to light that there was a ‘secret plan‘ for a very large settlement that included both Winchfield and Murrell Green. The Murrell Green part of the proposal was promoted by a company called Pearson Strategic Limited.

There are a number of pertinent facts about this company:

  1. It only has one director, James Turner
  2. It was only incorporated in November 2014 and has no revenue
  3. At the time of its last accounts, it has a negative net worth of £3,240
  4. Its only real asset is promotion rights over Totters Farm that has been mortgaged under a fixed and floating charge to Monopro Limited.

One really has to question whether we should be building the Hart Local Plan around a site with such little backing.

Accounts to Pearson Strategic can be found here.

Fixed and Floating charge document can be found here.

Conclusion

Some Hart Councillors seem hellbent on a new settlement regardless of the suitability or viability. In addition, they have not challenged the new Strategic Housing Market Assessment (SHMA) hard enough. If we are sensible about the housing targets and get properly serious about the brownfield opportunities we don’t need a new settlement anywhere in Hart.

Time to make our voice heard again.

 

Breaking News: Hart proposes new settlement at Murrell Green

Murrell Green new settlement proposal

Proposed new settlement at Murrell Green

Hart District Council has proposed a new settlement at Murrell Green as part of its spatial strategy for the Hart Local Plan. This was debated at a meeting of the Local Plan Steering Group last night. The proposal is expected to be agreed at a special Cabinet Meeting to be held on 9 February at 8pm.

The new settlement contains a site for a proposed new secondary school, outlined in yellow in the image above.

We are delighted that the new settlement at Winchfield will not form part of Hart’s strategy.

However, we are disappointed at seeing Murrell Green being put forward as a solution.

[Update] Concerns have been raised about the viability of the proposal [/Update]

Brownfield Capacity

At the council meeting last week, the Leader admitted that Hart now estimate the brownfield capacity at 2,126 dwellings. This excludes the former police college at Bramshill.

HDC Question about brownfield capacity

A realistic assessment of the capacity of Bramshill is around 250 units, bringing the total up to 2,376. However, sadly, Moulsham Lane has been given the go ahead (150 units). This would mean we would have capacity to meet even the over-stated remaining requirement of the old Strategic Housing Market Assessment (SHMA) on brownfield sites alone.

New SHMA overstates the true housing requirement

However, it now appears as though the council has caved in to demands to build even more houses that we don’t need. They have agreed to an increase in our housing allocation to 8,022. On a like for like basis, this leaves us short by 462 units.

This shortfall might well be met by the Netherhouse Copse application (436), which we now understand has been appealed by the developers on the grounds of non-determination. So even with the new SHMA, there is no need for a new settlement at Murrell Green.

At council last week, the leader refused to answer our questions about the reasonableness of building houses to increase inward migration to the district, when many of those people would work outside the district and thus put pressure on infrastructure.

HDC Question about housing numbers

The assumptions I put forward are all in the new SHMA, see here.

We need to challenge this new SHMA and resultant spatial strategy strongly. This will ensure we build the right number and right type of houses to meet local needs, rather than needlessly concrete over our precious green fields.

The full minutes of the council meeting can be found here.

 

 

 

Hart Local Plan: Green fields or fictitious jobs?

 

Should Hart concrete over its green fields for the sake of uncertain jobs forecasts

It is now becoming clear that the forthcoming Hart Local Plan will present us with a choice of concreting our green fields versus building houses for people who live elsewhere and many of them will work outside the district.

We have now had the opportunity to read the new Strategic Housing Market Assessment (SHMA) in more detail, and in particular the detail of the main driver of the housing target uplift: the jobs forecast. We have found:

  1.  The jobs forecasts uplift SHMA calculations increase the overall housing requirement for the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath by 22% over and above those required by demographics and making allowance for market signals
  2. The National Planning Policy Guidance (NPPG) does not require Hart Local Plan to accommodate extra housing if jobs forecasts are in excess of forecast workforce changes in the area.
  3. The SHMA calls the jobs forecasts ‘uncertain’ and ‘divergent’
  4. If we follow the SHMA, the Hart Local Plan will plan for jobs levels closer to the the extreme high end of the jobs forecasts
  5. That all of the alleged extra jobs will have to be filled by people coming from outside the district, and many of them will work outside the district. This will have a big impact on local infrastructure, particularly roads, rail, schools and healthcare facilities.
  6. Planning for around 900 extra jobs per annum would mean we could meet our remaining housing needs from only brownfield sites
  7. The SHMA says that it would be a more sustainable policy position to plan for increased economic growth to come from productivity improvements, rather than adding lots of lower skilled jobs

This is clearly a ridiculous position, and Hart District Council should follow the advice of Peter Village QC, and consult on the level of employment we wish the Hart Local Plan to accommodate and offer us the choice of planning 900 extra jobs per annum to protect our green fields.

[update]

We would suggest the following approach to the consultation:

Option A, plan for 900 jobs per annum, and around 6,500-7,000 houses, which can be achieved on brownfield (Hartland Village, Bramshill and Sun Park) or

Option B, plan for 1,200 jobs per annum and >8,000 houses for which you will have to give up Grove Farm, and some other area like Murrell Green and/or Pale Lane or West of Hook

We think there would be overwhelming support for Option A, and we would still be planning for 250 extra jobs per annum than the demographics would suggest, so meeting the requirement for positive development.

[/update]

We set out our analysis below.

What does the NPPG say we must do?

As can be seen below, the NPPG simply asks that plan makers ‘consider’ what they should do if the jobs forecasts are in excess of the forecasts for working age population. In particular, it asks for both housing and infrastructure to be considered.

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

Indeed the SHMA itself says that the NPPG does not require plan makers to make any uplift in housing numbers at all.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.50 NPPG does not require housing uplift

SHMA 11.50 NPPG does not require housing uplift

So, whilst the impact on housing and infrastructure should be considered there is no requirement to to actually increase the housing numbers.

What do the jobs forecasts say?

There is a wide range of jobs forecasts ranging from 910 pa (Experian), through 950 pa (Cambridge Econometrics) to the extreme forecast of Oxford Economics at 1,480 per annum.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Section 5 summary range of forecasts

SHMA Section 5 summary range of forecasts

The SHMA acknowledges that the housing numbers required are extremely sensitive to the jobs growth assumptions made

SHMA 11.1 wide spectrum of forecasts

SHMA 11.1 wide spectrum of forecasts

The SHMA calls for us to plan for 1,200 extra jobs per annum which is closer to the extreme high end of the Oxford economics forecast.

What does the SHMA say about the Employment Forecasts?

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

The SHMA says that there is genuine uncertainty about the scale of jobs growth that might be expected and the forecasts are widely spread and divergent.

Where would the people come from and where would they work?

We are told that the extra people to fill these jobs would come from other areas:

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment SHMA 11.56 Population growth from inward migration from other areas

SHMA 11.56 Population growth from inward migration from other areas

If other local authorities are following NPPG, they should already be planning housing for these people. Indeed we have found that many planning authorities are planning for an average of 42% more housing than demographic trends would suggest they need.

But it gets worse, in that the SHMA would lead to many of these inward migrants working outside the district, putting unsustainable strains on the transport network. We already know the rail network is forecast to be running well over planned capacity with no real plan to fix it.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.51 Excess housing supply could lead to extra out commuting

SHMA 11.51 Excess housing supply could lead to extra out commuting

Currently, more than half of Hart’s working population work outside the district and 40% of the HMA’s working population work outside the HMA.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.1 and S11.15 out commuting calculation errors

SHMA Figure 11.1 and S11.15 out commuting calculation errors

What would the Hart Local plan be if we planned for fewer jobs

If we planned for closer to 900 extra jobs per annum, we would need 950 houses per annum in the HMA. Hart would need 305 per annum, leading to an overall housing requirement of 6,405 which would mean we wouldn’t need any more green field sites.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figures 11.13 and 11.14 housing projections for range of job growth

SHMA Figures 11.13 and 11.14 housing projections for range of job growth

Taking account of market signals, the housing requirement for the HMA would be around 1,050 per annum. This would lead to Hart’s overall need being around 7,000. Again, we wouldn’t need any more green field sites to meet this requirement.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

What does the SHMA say about economic growth?

The SHMA says it would be more desirable to achieve economic growth through productivity enhancements and it would be a more sustainable solution.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.55 Better to achieve economic growth through productivity improvement

SHMA 11.55 Better to achieve economic growth through productivity improvement

So, why don’t we go for a more sustainable solution and plan for 900 extra jobs per annum?

New Hart SHMA published: housing target rises despite falling population projections

The Scream - 2016 New Hart SHMA also covering Rushmoor and Surrey Heath

The 2016 new Hart SHMA also covering Rushmoor and Surrey Heath has been published and Hart’s housing target has been increased from 7,534 to 8,022. This increase comes despite the forecast population for 2032 being lower than assumed in the 2014 SHMA.

For those uninitiated in the terminology of the Local Plan, the SHMA is the Strategic Housing Market Assessment. This is the totally objective document that is entirely above any criticism because it is produced by consulting only those who have a vested interest in building more houses.

Just like the last SHMA, a number of spurious assumptions and arbitrary uplifts have been applied to artificially increase the housing target to 53% above what we would need if we stuck to the demographic projections.

Essentially, we are being asked to concrete over our green fields to build houses for people who need to move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. Other districts should already be planning to house those people.

Here is the summary of how they did it, followed by our critique of the methodology and results:

2016 new Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

Demographic Startpoint

They have used the 2012-based population projections to arrive at the 785 dwellings per annum for the whole housing market area (HMA), consisting of Hart, Surrey Heath and Rushmoor. This results in a housing need of 254 dwellings per annum or 5,334 for the whole planning period up to 2032. Already most of this target has been built or permitted in Hart. If we stuck to this, we would not need to grant permission on any of the sensitive green field sites like Grove Farm (Netherhouse Copse), Elvetham Chase (Pale Lane), Owens Farm (West of Hook), Murrell Green or Winchfield.

However, even this starting point is inflated. The new SHMA states that if they used the 2014-based population projections instead, then the starting point would fall by 94 dwellings per annum for the HMA as a whole. The target would fall by 41 dpa for Hart, or a total of 861 dwellings.

2016 New Hart SHMA Figure 6 Appendix H impact of 2014-based SNPP Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 6 – Appendix H: Impact of 2014-based SNPP projections

Market Signals Uplift

This starting point is then inflated for ‘market signals’ and affordable housing requirements. We agree that there is evidence that younger people cannot get on the housing ladder, or in some cases cannot even rent properties in the area because property prices are too high. The uplifts they recommend increase the target by ~15%, resulting in 903 dpa for the HMA and 292 dpa or a total of 6,132 for Hart. Again, the remaining target for Hart could easily be met from brownfield development at Pyestock (Hartland Village) and Sun Park.

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

However, we do challenge the methodology they have applied in this case. They run two scenarios to estimate the extra houses required to meet the needs of people who are apparently not forming households at the expected rate. These would result in a 7-14% increase in the number of houses.

However, they arbitrarily choose a 15% uplift, which is larger than either of their modelled scenarios.

Even the SHMA itself calls into question whether this uplift will actually achieve anything:

9.72…Of course, there is no way of knowing in advance exactly how improvements in housing affordability would increase household formation rates (if at all)

Moreover, there is no evidence at all that simply allocating more land for development will either increase the number of houses being built or reduce the price of housing. The same section shows that development land in Hart, with planning permission costs £4.1m per hectare (section 9.12). At Hart’s preferred housing density of 30 dph, this equates to the land cost alone of a new home being around £133,000.  Build costs, S106 contributions and a profit for the developer could easily see the sale price of new homes being around £400,000. If housebuilders cannot achieve this level of pricing, then they simply won’t build the houses.

Affordable Housing Uplift

Some further adjustments are then made to lift the housing target 985 dpa for the HMA, or a further 24 dpa (504 in total) for Hart resulting in a total of 6,636 over the whole planning period. Even if this adjustment were accepted, this would still be easily accommodated on brownfield land in Hart.

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

There are two issues with this approach. First, column G shows there is a net negative need across the HMA, but Rushmoor needs to find 84 dpa. These are arbitrarily shared amongst all three districts, even though there is no net need across the three districts as a whole. Second, the whole analysis appears to double count the housing uplift for market signals above in that the ‘concealed families’ are already accounted for in the market signals analysis.

Accordingly, we believe this adjustment should be removed from the calculation.

Jobs Growth Adjustment

The most egregious adjustments come from the jobs growth adjustments. The total housing requirement is increased to 1,200 dpa for the HMA. This results in 382 dpa for Hart or a total of 8,022 new houses over the planning period. This increase means it is likely we will have to allocate green field land for development.

We have a number of issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area.

Second, the projection of 1,200 jobs per annum is far in excess of the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, they use a very circular argument to account for the number of jobs. The argument is basically, the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs. So, they then decide we will need to import some extra people and those people will need houses. Clearly, this is not an expression of the ‘need’ for the district.

However, the population projections already assume inward migration from other areas and international migration from abroad. Note that since the Brexit vote, migration from the EU is likely to fall, so these projections may well overstate the level of international migration.

These additional people must be coming from other areas. However, we know from analysis of other authorities that they are also increasing their housing targets by around 42% above the demographic projections. So, the question remains, where will the people come from to live in the extra houses? All local authorities need to meet their own local needs, so if all local authorities plan for far more than they need, we will have too many houses, but we will have concreted over our countryside.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. And other districts should already be planning to house those people.

It is a farce. This adjustment to the housing targets should be removed.

2016 New Hart SHMA Conclusions

We believe a realistic housing target for Hart is around 6,000. This would meet the needs identified from the most up to date population projections and give a sensible allowance for additional houses to cater for ‘concealed households’ and the younger people who want to get on the housing ladder. Affordability will come from building more smaller properties and taking advantage of the Government Starter Homes Scheme.

This housing target will mean we can build all of our remaining requirement on brownfield sites and still have many brownfield sites available for future generations.

However, given the perilous state of the Local Plan, we can’t simply ask for this to be redone. We must argue in the consultation about the new Local Plan that the housing target in the SHMA is too high, and therefore the plan does not need to allocate as much green field land for development. We have no doubt that there will be a number of developers arguing for an even higher target.

The new Hart SHMA and appendices are available for download below:

Hart Rushmoor & Surrey Heath 2016 SHMA
Hart Rushmoor & Surrey Heath 2016 SHMA Appendices