Winchfield Action Group and We Heart Hart submit objections to Hart’s consultation process

Designated area of outstanding natural profitability

Designated area of outstanding natural profitability

As you may know, Hart Council is about to embark upon a new consultation about our housing options as part of the Local Plan process.  We Heart Heart and Winchfield Action Group (WAG) have significant concerns about the way this consultation has been constructed and submitted a number of detailed points to the council.  In addition, WAG will be making a statement at the Cabinet meeting tomorrow. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

The main thrust of the objections is as follows:

  • Overall the consultation is too complicated and the instructions are not clear.  Given that a large number of submissions to the last consultation were invalid, this is a serious concern that needs to be addressed.
  • The Council have not explained why they have reduced the brownfield capacity of the district to 400 units when they said there was 1,800 as recently as October. The consultation also makes no reference to the fact that the Council is currently seeking more brownfield sites across the district.
  • The consultation unfairly biases its whole analysis towards the conclusion that we must build a new town in Winchfield.

There are also a number of other points made in the detail.

The statement and the detailed point can be found on the downloads below.

Statement to Hart Cabinet
 
Detailed feedback on Housing Options Consultation

Is housing capacity in Fleet really only 30 dwellings?

Housing Capacity of 30 units in Fleet Hampshire

Housing Capacity of 30 units in Fleet Hampshire

Hart Council has published a booklet as part of its forthcoming consultation setting out its estimate of housing capacity for each parish in the district.  There are a number of strange anomalies in that booklet, including stating the capacity of Bramshill to be zero, when there is the old Police College ripe for redevelopment and Elvetham Heath, again set to zero when Hart even identify a capacity of 45 homes in their main consultation document.

But the most egregious anomaly is the estimate of only 30 units in Fleet itself.  This misses out many brownfield sites that are ripe for redevelopment such as:

  1. The complex of offices that includes Admiral House, Flagship House, Hart Council Offices and the Harlington Centre that were identified and promoted by Fleet Future:
Vacant Office Admiral House, Harlington Way, Fleet, Hart District, Hampshire

Admiral House, Harlington Way, Fleet, Hart District, Hampshire

Harlington Centre, Fleet, Hart District, Hampshire

Harlington Centre, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Hart District Council Offices

Hart District Council Offices

2. The derelict offices on Fleet Road, again identified by Fleet Future:

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

3. Fleet Police Station:

Old Police Station in Fleet, Hart District, Hampshire

Old Police Station in Fleet, Hampshire

4. The still vacant units on Ancells Farm that have not yet been taken up by Stonegate:

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

Vacant Office at Ancells Farm, Fleet, Hampshire

5. The 119-acre Pyestock (aka Hartland Park), which has capacity for thousands of homes and where development of a new warehouse has stalled:

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

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

 

It is ridiculous, and some might say negligent, that Hart Council should be promoting a new town at Winchfield and/or urban extensions in Fleet or Hook for the Local Plan when there is plenty of vacant and derelict land that could form a more sustainable solution. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

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

Time to celebrate we don't need so many houses

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

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

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

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

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

Critique of Hart SHMA

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

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

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

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

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

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

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

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

Hart Council missing out key information about housing options

Hart District Council Offices

Hart District Council issuing misleading information about housing options

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

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

Housing allocation out of date

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

SHMA is invalid

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

Estimate of brownfield capacity is too low

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

Government has made brownfield development more attractive

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

Astronomical Infrastructure Costs

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

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

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

Hart Council planners “lose” 1,400 homes from brownfield sites

Let's just make up the brownfield numbers

Let’s just make up the brownfield numbers

Back in October 2014, Hart District Council said we had capacity for around 750 new dwellings on brownfield sites.  Since then, a number of new sites were identified through the Stonegate Report and other sites such as Bramshill and Fleet police station came up.  This led the Council to say as recently as October 1, that there was capacity for 1,800 homes on brownfield sites.

However, Hart Council have now published a draft housing options paper on their website that says brownfield capacity is now only 400 units [Update: a later version of the same document now states brownfield capacity as 450 units, although this is lower than the official SHLAA estimates for the same sites].  It seems that over the past six weeks, it seems the planners have “lost” 1,400 houses.

As far as we know very few, if any, of the initial 750 units have been given planning permission since October last year.  We have made a FOI request to get to the bottom of it.

It remains a mystery where they have gone to, but one can only assume that there is a cabal of concrete campaigners in Hart who are determined to build on our beautiful countryside at the same time as they protect vacant and derelict office blocks In Hook, Fleet and all across the district. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

 

Community Campaign Hart Council Chairman to discuss brownfield development with Ranil

Hart District Council Offices

Hart District Council Offices

Concrete Community Campaign Hart (CCH) member and chairman of Hart District Council is to meet with our Local MP Ranil Jayawardena to challenge any misunderstandings there might be about the brownfield capacity of Hart District.

CCH are clearly alarmed at Ranil’s intervention on planning matters, especially as Ranil said he was against large-scale, top-down developments generally and he believed (as We Heart Hart believe), that our remaining housing allocation can be met from brownfield sites alone.

CCH have said they are opposed to redeveloping the derelict sites on Fleet Road in Fleet, Hampshire, and instead prefer to build a new town in Winchfield.

The chairman’s statement on this matter is included in the draft minutes of last week’s meeting and reproduced below:

Secondly, I have become aware of the disquiet felt by many members from all political groups about the Planning pronouncements from our MP Ranil Jayawardena. In particular, the assertion that Hart has enough Brownfield sites to build all its housing needs without the need to disturb any significant Greenfield sites outside current settlement boundaries. This is in direct contradiction to the advice we as a council have been given by officers, consultants and members on the Local Plan Steering Group.

In my role as Chairman I have had the pleasure of talking to Ranil on this issue whilst undertaking other civic duties. I therefore took the opportunity to invite him to a private meeting with this Council to explore why such disparate views have come about. His current position is that he would welcome such a meeting. My invitation was made to ensure no misunderstandings remain unchallenged between us as having a fully engaged, briefed and passionate advocate for Hart in Westminster is important for this Council.

I will be working with the Council Leader and Rail’s [sic] office to agree a date that will fit in with his Parliamentary responsibilities. It is therefore likely that the timing of such a meeting will not be a midweek evening so I apologise to working members in advance.

We do hope that Ranil maintains his position and points out to Hart Council members some of our work on brownfield capacity and Ranil also further explains his policy of pushing local councils to be more active.

Separately, the Council Leader expressed some sympathy with the view we should build on brownfield sites alone and even conceded it might be theoretically possible, but fell short of making a commitment to do so. Our questions and the Leader’s answers below:

Question: Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?

Response: Putting to one side the matter that this is a quotation out of context, Mr. Jayawardena makes three points in this opinion statement. Firstly he says that brownfield should be used before greenfield; as a statement of principle I wholly agree, and always have. However, we are obliged to maintain a five year land supply. As fast as we approve fresh applications, previous consents are being built out; this is a moving target. Unless we can deliver brownfield site planning consents at the rate of that of our ongoing annual housing requirement we cannot deal with this sequentially. Given that we do not have deliverable and developable brownfield sites sufficient for our own Objectively Assessed Housing Needs (OAHN), we are obliged to allocate some sites other than brownfield to achieve the numbers required. Second, he is opposed to a number of specific sites, as am I. We are however compelled to allocate sites which we would prefer not in order to fulfil our OAHN. He states that he believes the OAHN can be met from brownfield sites; this is probably theoretically true, if we compel the use of unavailable sites including those in current active employment use. That is not available to us.

Question: What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?

Response: CPO is not a cheap option. We would be obliged to pay market price for such land, plus the costs of acquisition, and this for a site where the owner has not perceived an opportunity to develop at a profit. It is simply unrealistic that Hart DC could undertake CPO on the scale necessary, and in the timeframes necessary, to persuade an Inspector that such a plan would be deliverable. The Council could not afford to do it. Further, to produce tracts of apartments for young professionals would result in fundamentally unbalanced communities. We need communities which provide for all our residents, including families and older people. Young professional ghettoes are not good planning. In the event that a site would become appropriate for CPO, the site would be considered on its individual merits. You should be aware, however, that the seizure of the assets of others even paying full value is not something this council has seen as desirable, which is why it was not considered as an appropriate means of site assembly should a new settlement proceed.

Question: How many sites would meet those criteria and how many dwellings might they yield?

Response: A site would be considered on its merits at the time.

Government to extend “planning in principle” rights to green fields

Example of Urban Sprawl

Example of Urban Sprawl

The Government appears to be trying to extend the recently announced “planning in principle” rights to green field developments. This could mean tens of thousands of new homes in green field areas will be forced upon communities that do not want them.

We have previously applauded the Government for introducing this right to brownfield sites. Just three weeks ago David Cameron, the Prime Minister, said that the new “planning in principle” changes would apply to brownfield sites like former car parks and industrial areas. However Government documents said the new power will apply to “housing identified in local plans and neighbourhood plans” which include greenfield areas.

One document states: “The Government proposes to legislate to enable the Secretary of State to grant ‘permission in principle’ via a development order to land that is allocated for development in locally produced plans and registers.”

This development may have important implications for the Hart District parishes (e.g. Winchfield, Odiham, Fleet) that are in the process of creating their Neighbourhood Plans and of course for the Hart Local Plan.  Surely, this will mean that will be more reluctant to identify potential sites for development because Hart Council Planners will no longer have the powers to block inappropriate schemes nor to insist that the design, density, size and location of homes is in keeping with local areas.

This proposal significantly undermines local democracy and should be opposed.

 

Fog descends on the Hart Local Plan

Fog descends on Hart Local Plan

Fog descends on Hart Local Plan

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

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

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

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

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

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

Ranil emphasises the need for infrastructure alongside housing

Ranil Jayawardena at a brownfield site

Ranil Jayawardena at a brownfield site in Hampshire

Local MP, Ranil Jayawardena has published a new article re-stating his preference for brownfield regeneration and emphasising the need for proper infrastructure to be delivered alongside housing and calling on local councils to take a more active approach.

This is the key passage from his article:

This is an important point. It is clear to me that infrastructure improvements are an absolute necessity for any development – and Government has a role in this part of the equation.

Whether brownfield or greenfield, infrastructure is critical to ensure that these developments not only provides homes for our friends and children, but are taken as opportunities to improve the way of life for existing residents. Whether brownfield or greenfield, development should not come before infrastructure.

I welcome the Hampshire Combined Authority proposal, specifically a ten-year Transport Investment Fund to be used to significantly improve our roads and public transport. This is a good start, but to plan our future, we must consider the past. We should be thinking about the existing infrastructure deficit also and how this can now be mitigated, so that existing residents end up with a better deal.

It is only right that infrastructure is delivered alongside any new development, rather than leaving communities hoping for improvements in the future, when our roads are already jammed and our trains are already crammed.

Ranil also calls on Local Authorities to take a more active role in developing their areas, by actively considering Compulsory Purchase Orders and using development profits to fund additional infrastructure:

There is another way to fund infrastructure, of course. If regeneration is led by local government, through its ownership of the land (whether by private treaty or CPO), the profit that local government makes from the redevelopment can be invested in infrastructure or for the benefit of taxpayers. This is particularly important with brownfield sites, since sites may not be viable – after taking into account a developer’s profit – if they are also required to pay CIL/s106 at the normal level and it would not be good to see large-scale brownfield regeneration without any infrastructure improvements.

Through this vision of active local government, brownfield regeneration genuinely benefits local people, rather than shareholders of a developer, through improved infrastructure and lower Council Tax.

I should probably say that I accept, often, brownfield sites are not in common ownership and, even if they are, the landowner doesn’t wish to develop them. To my mind, however, that is not a reason for brownfield to be put in the ‘too difficult’ pile. Rather, I believe local government has a role to outline how it wishes to comprehensively improve the existing built environment, through purchasing and redeveloping land if not already in its ownership

We wholeheartedly welcome Ranil’s new intervention and we can only hope that Hart District Council are listening. We urge you to sign Ranil’s petition using the button below.

 

Sign Ranil's Petition

 

 

Community Campaign in bitter clash with We Heart Hart

Community Groups in bitter clash over homes Fleet News and Mail 20151028

Community Groups in bitter clash over homes in Hart District, Hampshire

Fleet News and Mail has covered our story where we challenged Community Campaign Hart’s (CCH) plan to decimate the heart of Hart.

Hart District Council takes aim at the Heart of Hart

Community Campaign takes aim at the Heart of Hart

To remind readers, we took CCH to task over their assertions that there was no sustainable alternative to building a new town at Winchfield and their claims about infrastructure and traffic.  In particular, we dispute CCH’s claim that there isn’t enough brownfield capacity, an area where we are backed up by the views of our Local MP, Ranil Jayawardena.

We are delighted that Fleet News and Mail has brought these arguments to a wider audience.  Let’s see how the general public react to the forthcoming Housing Options paper.

A large image of the Fleet News and Mail article can be found here.

This story was also covered in Get Hampshire on November 3 2015: Community Groups in bitter clash over Winchfield homes plan