Fleet Regeneration – Yes we can!

Candidate for Fleet Regeneration: Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Council protecting from redevelopment.

We must deliver Fleet Regeneration

A guest post from Tristram Cary, chairman of the Rural Hart Association, setting out why we must and how we can deliver Fleet Regeneration.

Fleet Regeneration Report

40% of the population of Hart live in Fleet, and yet, in the Local Plan, Fleet is only taking only 21% of the housing development. This massive imbalance puts a huge strain on Hart’s countryside. It is extraordinary that Hart is preventing the regeneration of Fleet when you consider that:

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

  1. Fleet is the most sparsely populated town of its size in Britain (see above)
  2. Hart admits in para 236 of the Local Plan that, without regeneration, “it is unrealistic for Fleet to try to compete” for comparison shopping with neighbouring towns such as Camberley (which is the same size as Fleet)
  3. The new National Planning Policy Framework (para 86) requires districts to “take a positive approach to the development of Town Centres” and to “recognise that residential development often plays an important role in ensuring the vitality of Town Centres”

Hart’s extraordinary lack of ambition for Fleet is explained by Councillor Cockarill’s statement at the 4 January Council Meeting that any serious Fleet regeneration was “a pipedream”. Hart claims that Fleet is full, and that it would not be possible to raise any serious money for its regeneration.

The Rural Hart Association (RHA) commissioned a study from Lambert Smith Hampton (LSH), a leading Town Centre regeneration specialist, to analyse the potential for Fleet regeneration. This study was submitted to Hart in response to the Reg 19 Consultation, and the full document is available on the link above. The key findings of the study are that:

  1. Fleet has ample opportunities for re-generation if only Hart would consider mixed-use (residential and retail) developments
  2. It is hopeless for Fleet to resist the residential conversion of redundant office blocks – there is no realistic prospect of these ever being revived for business use.

It’s worth reading the following summaries provided by directors of LSH.

“As has been widely reported the growth of online retail sales is having a major impact on the retail landscape – online sales are currently circa 16% of all UK sales and growing annually. There is a fundamental structural change in our shopping habits which in turn is having a major impact on retailers and town centres. The retail centres that are thriving tend to be those regional locations offering a high quality experiential mix of retail and leisure or the smaller centres that are able to provide easily accessed, convenience retail facilities in an aesthetically pleasing environment.

Interestingly, we have started to witness retail assets (shopping centres and retail parks) particularly in the South East being acquired or redeveloped for their residential potential.  In some instances, we are seeing retail being proposed above shopping centres and in other instances the complete redevelopment for residential – examples include Forbury Park in Reading which has consent for 765 homes and Whitley’s Shopping Centre in Bayswater which is to be redeveloped for a mixed retail and residential scheme. This trend is likely to continue especially in areas where residential values are high and the retail assets are stagnating.

The Hart Shopping Centre could offer such potential in the future – retaining strong convenience retail facilities at ground floor level with retailers such as Waitrose but with residential accommodation on the upper parts.

What is clear, is that on a national basis we have too many shops and alternative uses, in particular residential, is a desirable way of regenerating our town centres”.

Sean Prigmore, Retail Director, Lambert Smith Hampton

And,

“I have been actively involved in the Fleet office market for more than 30 years.

The office market in Fleet has been in decline for a number of years as larger corporates have vacated to consolidate occupation in larger centers and locations benefitting from more amenity – such as Farnborough Business Park. Key Business centres such as Reading and Basingstoke have prospered whilst the smaller satellite office location such as Fleet are finding it harder to prove their relevance as office locations. M3 HQ, 70,000 sq ft on ABP, has been vacant for many years and is unlikely to be occupied as offices again. There is the potential to enable redevelopment of larger unwanted office stock for residential and to focus B1 provision in locations better served by public transport and amenity and in buildings which will allow business space for the SME sector where what demand there is lies.”

Paul Dowson , Director, Lambert Smith Hampton

Fleet Regeneration Sites

Fleet Regeneration Sites

The Lambert Smith Hampton report identifies eight sites in Fleet Town centre which between them could provide 990 homes in mixed-use developments, and LSH is confident that these sites would attract developer investment. [Personally, I would add the entire civic quarter – ed]. It is shocking that Hart has turned its back on mixed use developments in Fleet without even investigating their potential. We hope that Hart Council will restructure its Local Plan to take account of the LSH report before submitting it for Inspection.

[Note that this is exactly in line with Ranil’s call for regeneration of our urban centres – ed]

Hart Local Plan: Remove brownfield restrictions

Brownfield site at Ancells Farm, Fleet, Hampshire. Hart Local Plan protecting from redevelopment.

Hart Local Plan restricting redevelopment of sites like this

This is the third part of our submission to the Regulation 19 Hart Local Plan consultation. This article explains how Hart’s policies are restricting brownfield redevelopment and why they must remove policy ED2, change their SANG policy and remove their Article 4 direction on Permitted Development Rights.  The process for making a submission is as follows:

  1. Go to the Hart Local Plan Consultation page of the Council website
  2. From the Hart website, download and complete Response Form Part A (Personal Details). A copy can be downloaded here.
  3. Also download and complete the Response Form Part B (Your Representations), a separate Part B is required for each representation you wish to make. A copy can be downloaded here
  4. Make sure you include words of this form in each representation. Policy [X] is not sound because it is not [positively prepared, justified, effective or consistent with national policy] (delete as appropriate).
  5. Once you have filled in Part A and Part B, please email them to planningpolicy@hart.gov.uk or post them to Planning Policy Team, Hart District Council, Harlington Way, Fleet, Hampshire, GU51 4AE. 
Submissions have to be made before 4pm on 26 March 2018. If you are keen to get your submission completed, you can use the summary guide we have pulled together, or for the more adventurous, you can use our full submission. Please edit the text into your own words.
WHH Local Plan Reg 19 Guide
WHH Local Plan Reg 19 Entry

How the Hart Local Plan restricts brownfield development

Policy ED2 relates to safeguarding employment land and Para 297 refers to SANG owned by the council.

Policy ED2 protects essentially every major employment site in the district from redevelopment.

The reason this is a bad policy is that the prior version of the Local Plan itself, as well as the Employment Land Review (ELR), acknowledges that there is an over-supply of low grade office space (para 125). The ELR states that investment in this stock is unviable (para 6.17):

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.

Owners of these sites have three choices. First they can keep the wasting asset and collect no rent, which is not an attractive commercial proposition. Second, they can convert the offices into flats. By and large, they need no planning permission for this. However, these types of development carry no obligation for S106 or CIL payments to councils. Nor do they deliver a good ‘sense of place’. Finally, they could apply for planning permission to properly redevelop these sites into attractive homes, with a particular focus on affordable homes for the young. These types of development will be high-density, but with a good sense of place, and will attract some funding for infrastructure.

The consequences of this policy will be to discourage redevelopment of sites and either lead to more sites being simply converted or worse, sitting idle as eyesores.

We believe this is contrary to Government policy.

Remedy: Consequently policy ED2 should be removed.

Moreover, the Inspector should be aware that the council has implemented a new policy regarding SANG that effectively further obstructs brownfield development. This is already blocking schemes that would provide homes that ordinary people can afford (as distinct from Affordable Homes that ordinary people can’t afford). The schemes affected are a conversion on Ancells Farm and proposals to redevelop the old police station in Fleet town centre. It has been suggested that this SANG policy may be unlawful.

In addition, Hart has commenced work to implement an Article 4 direction to block permitted development on brownfield sites.

In effect they have set some nice sounding objectives about protecting our historic assets and building green infrastructure, but their policies act against their objectives and actively create a worse place to live by leaving decrepit buildings to rot and scar the landscape.

We think the Inspector should also take a view on these policies since they are closely related to the Local Plan, even though they are not contained within it.

Remedy: We believe that the SANG policy and the Article 4 direction should be removed

Affordable homes blocked by Hart’s restrictive brownfield policies

Affordable homes blocked at Zenith House, 3 Rye Close, Fleet, Hampshire by Hart's restrictive brownfield policies

Affordable homes blocked by Hart’s brownfield policies

The delivery of 36 affordable homes is being blocked by Hart’s restrictive brownfield policies. Magna Group is seeking to convert Zenith House on Rye Close on Ancell’s Farm in Fleet into 36 relatively affordable properties, designed to retail at £175,000 to £300,000. But they are being blocked by Hart’s restrictive SANG policy.

The council has given its prior approval to the development. However, Hart is effectively blocking the development by refusing to allocate any of its SANG.

redevelopment of Old Police Station,Crookham Road, Fleet, Hart District, Hampshire being blocked by restrictive brownfield policies

Proposals to redevelop Fleet Police station being blocked by restrictive brownfield policies

We understand the same developer owns the old Fleet Police station on Crookham Road in Fleet and plans to replace it with 14 new dwellings. However, we understand the council planning officers have been instructed to refuse planning permission for even compliant proposals.

This has the effect of:

  • Restricting the supply of housing that would be affordable for many young people trying to get on the housing ladder
  • Adding extra pressure to build on green field land
  • Stopping the market dealing with the problem of the over-supply of dilapidated office blocks in the district

This policy is also blocking Ranil’s ideas for regenerating Fleet. His petition can be found here.

It transpires that Hart’s SANG policy may well be illegal. We understand that legal representations have been made that cast doubt on Hart’s SANG policy:

First the policy is clearly intended to frustrate the delivery of housing rather than to facilitate development.  The policy confers on the head of the regulatory services absolute discretion to allocate SANG but makes clear that SANG will not be allocated to any development unless the Council considers it to be acceptable.

That means that if Planning Permission is granted on appeal the Council will nevertheless use its powers in relation to SANG to thwart that development.

The policy may result in the Council preventing people from exercising the rights they have been granted by Parliament through the permitted development process. In effect the Council is removing a property right from them in breach of the terms of the Human Rights Act 1998.

Furthermore the Council is in breach of its duty to make proper provision to facilitate the delivery of housing.

It certainly looks like the council is setting itself up for more expensive legal battles.

 

 

 

 

 

Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council seeks to block development of brownfield sites

Hart District Council is seeking to block development of brownfield sites. It has put forward proposals to be discussed at the Planning meeting later today to implement an Article 4 direction to

Withdraw permitted development rights related to the change of use of offices, light-industrial units, and storage or distribution units to residential use within the Strategic Employment Sites and the Locally Important Employment Sites

This covers substantially all the brownfield sites in the district. We do have some sympathy for the view that simple conversion of office sites to residential is not good for the district. We much prefer complete redevelopment of these sites, so the provide higher quality housing and a better sense of place.

But the council’s approach is heavy-handed and sends a signal that they do not welcome brownfield development. Moreover, this approach will discourage the regeneration that our urban centres badly need.

The proposals call for:

  • Draft Article 4 Direction and supporting documents;
  • Give notice as soon as possible after a Direction has been made by local advertisement, site notice, owners and occupiers (unless reasons to justify not doing so);
  • Send a copy of the direction and the notice to the Secretary of State;
  • Notify the county planning authority;
  • Following the above, take into account any representations received; and
  • Confirm the Direction by giving notice as above and sending a copy of the confirmed direction to the Secretary of State.

They have to give 12 months notice of the implementation of the direction.  They identify as risks that:

  • Developers may make claims for compensation from a local authority
  • The proposals could result in a rush of applications before the rights are withdrawn, it is not
    possible to mitigate against this risk.

A more positive approach would be to put a policy in the draft Local Plan that unequivocally encourages  redevelopment of brownfield sites and give examples of the kinds of scheme the council would encourage.

Hart Brownfield sites in Employment Land Review

The other puzzling thing is that Hart’s own Employment Land Review identifies much of the employment land in the district as:

Lower grade stock for which there is limited demand and a large supply. As a result of limited demand. The poorer quality stock is remaining vacant for prolonged periods.

They say that:

The current over-supply of lower grade office accommodation is limiting investment in the refurbishment of such stock as low rent levels make such investment unviable.

To summarise, Hart is seeking to block the redevelopment of low grade office blocks, and there’s no hope of refurbishing these into high quality office accommodation. So it seems that we are going to be stuck with many of the eyesores in the photo carousel below. They really have gone through the looking glass.

 

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.