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.

FOI request reveals Winchfield failed testing

Flood Taplins Farm Lane 28 March 2016 shows why Winchfield failed testing

Flood risk means Winchfield failed testing

The documents that reveal why Winchfield failed testing have been revealed by persistent efforts from Winchfield Action Group. A Freedom of Information request has revealed the results of a new testing document. The full document can be downloaded on the link below.

In summary, the main issues were impact on:

  1. Historic Environment
  2. Bio-diversity
  3. Landscape
  4. Water Quality
  5. Flood risk

However, in our opinion, the impact of flood risk was massively downplayed in the report. More detail is given in the analysis below. Moreover, some of the alleged positives in the report are also complete nonsense.

For instance, they claim that building a “renewable and low-carbon energy generation and transfer” plant will diversify energy supply. What they mean is expanded upon in the Sustainability Assessment – they mean building a wood-burning power station utilising locally sourced timber (p74). Such a plant would be extremely undesirable since burning wood produces more CO2 than burning coal, and none of the proposed master plans include such space for such a plant.

They also claim that building 3,000 new houses, with associated traffic will somehow “reduce the
emissions of greenhouse gases and manage the impacts of climate change”. Again, complete and utter nonsense. They completely ignore research that shows higher density development in urban areas is much more sustainable than green field development.

This leaves the Local Plan in something of a pickle. Their preferred green field site of Murrell Green has been severely impaired by the presence of a Major Accident Hazard pipeline and their obvious second choice is not viable.

This puts at risk the other green field sites in the district, namely Pale Lane (Elvetham Chase) and Netherhouse Copse (Grove Farm). At the same time, Hart Council is seeking to protect our brownfield sites from redevelopment. These problems arise because they are proposing a ridiculous housing target of over 10,000 dwellings.

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. 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

Detail of how Winchfield failed testing

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

First, they say there was some evidence of wet ground at the far east of SHL183, but “no other obvious evidence of current or past flooding”.

Winchfield Strategic Assessment - Flood Risk 1

This is of course complete nonsense. The detailed assessment also says there’s only a one in 30 year chance of surface water flooding. The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone. The image at the top of this post documents just one of those events. The posts documenting the flood events can be found here (4 Jan) , here (7 Jan), here (9 March on Station Road) and here (28 March due to #StormKatie).

They seem to gloss over the flood risk being over 55 on a 74 point scale for five of the eight SHLAA sites they consider.

Winchfield Strategic Assessment - Flood Risk 2

Winchfield Strategic Assessment - Flood Risk 3

Winchfield Strategic Assessment - Flood Risk 4

Winchfield fails testing – Strategic Assessment

Motion of No Confidence in Hart District Council submitted

Breaking News: Motion of No Confidence submitted in Hart District Council

Motion of No Confidence submitted in Hart District Council

A motion of no confidence in Hart District Council has been submitted by Community Campaign Hart (CCH), (or as some call them Completely Concrete Hart) and the Liberal Democrats.

Apparently, they are unhappy that a new settlement at Winchfield has not been included in the Local Plan. They plan to push for Winchfield to be re-included if they manage to take over.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

We think this is a bad idea for a number of reasons:

  1. This will add extra delay to the Local Plan process, adding to the risk that sites like Grove Farm (Netherhouse Copse) and Pale Lane (Elvetham Chase) will be given the go ahead at appeal before the Local Plan can be put in place
  2. Winchfield has failed testing. The main issues with the proposal are:
    • groundwater and surface water flooding,
    • Cost of new road infrastructure and the need to travel to Fleet for main services
    • requirement for new wastewater treatment works
    • too much delivery risk concentrated in one site
    • impact on landscape
    • impact on heritage assets and SSSIs
  3. CCH have completely failed to oppose the main issue: we are being asked to build too many houses. Hart Council have arbitrarily added an extra 2,000 houses to the already inflated SHMA figure of 8,000, giving a total over 10,000 houses. Tackling this would mean we don’t need a new settlement at Winchfield or Murrell Green, nor would we need Pale Lane or Grove Farm
  4. A new settlement at Winchfield will likely have a major impact on congestion in Church Crookham and the western edge of Fleet.

We predict a stormy council meeting on 25 May.

[Update  – Statement from Conservative Council Leader]

Conservative Council Leader Stephen Parker commented:

We have a clear track record of success in running Hart Council. Despite cuts to Hart’s government funding we used Conservative ministerial contacts to reduce the cuts, froze Council tax for 6 years and made minimum increases for the last two years. At the same time we made innovative partnerships to make sure that no cuts were made to our services or to our support to the voluntary sector. We delivered the new Hart Leisure Centre, a superb facility which pays for itself with no increases to Hart’s Council tax. We listened to residents in making our Local Plan which maximises use of brownfield sites and protects our towns and villages from unwanted expansion. At no time in the last eight years of Conservative leadership have they challenged any of these successes. Residents will no doubt look forward to reading their joint manifesto.

[/Update]

[Update 2 – statement from CCH]

Statement about motion to bring about a vote for Council Leader

Until fairly recently Hart District Council had a democratic process of electing the council Leader every year at the AGM. This right was taken away by the then Conservative administration, presumably because they realised that as is the case now there would be times when they did not have a majority on the council.

The Conservatives forced through the instigation of a 4 year term for the council Leader, the maximum period they could have gone for without falling foul of legislation.

Out of 33 councillors there are 14 Conservative, 10 Community Campaign, 8 Lib Dems and 1 Hook Independent. No one party have the 17 councillors required to hold a majority on the council.

The Community Campaign have asked the current Leader if he’d be willing to continue as Leader with a proportional Cabinet made up of 3 Conservatives, 2 Lib Dems and 2 Community Campaign members. Given the proportionality of such a Cabinet it does not seem to be an unreasonable request.

We await his response. However, should the Conservatives not wish to work with a cross party partnership then we believe that the Council should have the right to elect a new Leader.

The nature of the council’s constitution is such that in order to bring about the opportunity to elect a new Leader a motion to withdraw support for the current leadership needs to be lodged 7 clear working days before the council’s AGM.

The full motion moved by Cllr. James Radley of the Community Campaign reads;
The council wishes to use this AGM, as it represents the traditional point in the municipal year, to undertake a vote for the leader of council. To bring about such a vote the constitution requires that a vote to remove the current leader first be tabled. To this end this council retracts support for the current leader and does so as required by the constitution by voting to ‘remove from office the current Leader of the Council and agrees that a new Leader should be elected forthwith’.

[/Update 2]

[Update 3: Lib dems tweet to say they don’t support new settlement at Winchfield]

NE Hants Lib Dems statement about Winchfield

[/Update 3]

Where is the draft Hart Local Plan?

Hart Local Plan - Keep Calm and Wait until 26 April

Hart Local Plan – Keep Calm and Wait until 26 April

Regular readers maybe wondering what has happened to the Hart Local Plan. On February 9th, Hart Cabinet agreed to a spatial strategy as part of the draft Local Plan that was due to go out to consultation in March. Obviously, there have been further delays. This is what we now understand to be the position:

Hart Local Plan timetable

The draft local plan will be released 26 April for a six-week Reg 18 consultation period after a briefing session with Parish Councillors on the 25th. There will be roadshows at the main settlements. Every house in the district will receive an A5 leaflet advising them of the consultation.

The Reg 19 process will follow in about November with submission of the full plan to the Secretary of State in mid-February 2018. All responses during the Reg 18 will be made public including the names of the individuals but with no contact details.

Hart Local Plan Headlines

Hart Council have decided to build 10,185 houses up to 2032 of which around 50% have already been built or granted permission. Please note that this number is far higher than 8,022 target the recently published Strategic Housing Market Assessment and more than double the requirement generated from demographic change. The numbers are now correct as of 31 January 17 and include all office conversions which have been approved.

Housing Numbers by area

  • Fleet 200 – mostly through office redevelopment
  • Hook was 200 now 10 from office redevelopment plus another 87. However, developers may chance their arm again with Owens Farm (750), and of course around half the Murrell Green site is in Hook Parish.
  • Sun Park 320
  • Hartland Park (Pyestock) 1500. Fleet town council have apparently made the point that the site offers only 20% affordable homes and the density per hectare is up to 97 in places which is equivalent to city centre densities which is of concern to them. OUr view would be to make the most of available brownfield sites.
  • Murrell Green 1800 but with challenges. There are 4 promoters and it will be some 3 to 4 years before planning permission is approved. It includes the site for a secondary school but there won’t be enough developer contributions to pay for it. New school funding rules mean that Hampshire can’t pay for it either.  It’ll probably be an Academy at a cost of circa £36 million. So we get a site for a school, but no money.
  • Crondall 66
  • Crookham Village 100 + 64 predominantly the care village
  • Eversley 124 on two sites
  • Heckfield 86
  • Long Sutton 10
  • Odiham 119 as per NP
  • Hartley Wintney 0. It seems odd that HW’s Neighbourhood Plan will be ignored. It should be noted that Murrell Green directly abuts Hartley Wintney Parish and about half of the proposed Pale Lane (Elvetham Chase) development is in HW parish.
  • South Warnborough 34 on two sites
  • Yateley 88
  • An additional 50 via rural exceptions and a further 290 from windfall.
  • Interestingly, no mention of Winchfield, or their Neighbourhood Plan, but roughly half of Murrell Green is in Winchfield Parish.
  • Apparently, Bramshill will be very difficult to develop because of all the complications with the Grade 1 listed site.

Other news

Apparently East Hants have done such a stellar job on the Local Plan, the Planning Policy team is now back in house at Hart, reduced in size from 8 to 2.

There is a risk that developers will continue to pursue Pale Lane and take it to appeal before the Local Plan is adopted.

We await the results of the Grove Farm (Netherhouse Copse) appeal in June.

Hart Tories claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory form abject failure

North East Hampshire Conservatives have managed to claim victory, despite their abject failure to plan for a sensible amount of housing for Hart District.

On Thursday, the Conservative led Hart Cabinet agreed to plan for more than 10,000 houses. This is many more than is required to meet the needs of Hart residents. Yet, because they have managed to avoid putting those houses near Fleet, they claim it as some sort of victory. They show no concern for Hart residents who live in the more rural areas.

Apparently, the Hart Tories are concerned about over-development, transport, traffic, education, loss of green space and the impact of development on existing infrastructure. But only in the immediate area around Fleet. The rest of us will just have to suffer.

To recap, to meet the demographic projections for Hart residents and meet the needs of those who can’t get on the housing ladder, we need to build 6,000-6,500 new dwellings. Anything over and above that requires massive in-migration to Hart. That is, massive in-migration of people whose housing needs are supposed to be met elsewhere. The SHMA also assumes that most of these people will work outside the district, putting even further pressure on local infrastructure.

Hart is planning for more than twice the demographic projections. They are not alone, other nearby districts are planning for 42% more houses than the demographic projections require.

However, their so-called victory may be short lived. The Grove Farm application is being appealed by the developers. The Planning Committee also has to make a decision about Pale Lane soon. It seems likely that they will turn it down. However, it seems equally likely the developer will appeal that decision too. With no Local Plan, out of date policies and a questionable 5-year land supply, the inspector may well grant permission for both these sites.

The only sensible way out of this, is to remove the extra 2,000 houses they voted through on Thursday and demonstrate that the houses are not required.

Hart Cabinet sell us down the river as they plan for 10,000 houses

Hart Cabinet sell us down the river by planning for far more houses than we need

Hart Cabinet plan for houses we don’t need

Hart Cabinet sold us down the river on Thursday night as they voted to plan for 10,000 houses to be built in Hart District in the period up to 2032.

Aside from vote on the paper some other interesting information was disclosed on a number of subjects:

  • Hart Cabinet vote on the 10,000 houses?
  • Do we need a secondary school?
  • Grove Farm (Netherhouse Copse) update
  • Hart Cabinet and Council politics

Hart Cabinet vote on the 10,000 houses?

Well, the short answer is we don’t. Our statement was received without challenge and was described as “informed” by the joint Chief Executive. There really is no answer to the points about double counting, nor the extra 1,200 houses on top of the alleged additional affordable housing requirement. To his credit, Ken Crookes asked some challenging questions. He didn’t really receive satisfactory answers.

The cabinet chose to plan for the extra 2,000 houses on top of those set out in the Strategic Housing Market Assessment (SHMA), even though Ken abstained.

The plan was supported by two cabinet members from Hook. They apparently favour a new settlement that will deliver more houses in Hook Parish. But they vehemently oppose the proposed new development to the west of Hook, that is outside the Thames Valley Heath SPA zone of influence.

There is a risk that Hart will no longer have a five year land supply, now it has agreed an uplift to 10,000 houses. Apparently, officers are working on a new document.

The leader and joint chief executive will now proceed to produce a draft Local Plan. A new consultation will be held on this draft will begin some time in March.

Do we need a new secondary school?

One of the justifications for the new settlement at Murrell Green is that the district needs a new secondary school. You may recall that the council voted on a resolution to include a secondary school in the Local Plan.

However, in his statement to cabinet, the joint chief executive said that although:

Hampshire County Council (HCC) welcome the principle of a new school site, the scale of growth envisaged in the Local Plan is not one that would require the delivery a new school in the planning period.

HCC is responsible for planning school places. But HCC is not responsible for delivering new schools as they will now be delivered as free schools, outside local authority control.

Apparently, Hart has also been offered secondary schools by the developers of Winchfield, West of Hook and Rye Common.

In other words, Hart has acted outside its responsibilities in resolving to deliver a site for a school and the authority responsible for planning school places don’t believe we need a new school. So, we are creating a new settlement to create capacity for houses we don’t need and a school we don’t need either.

Grove Farm (Netherhouse Copse) update

In conversation we found out more about the Grove Farm application. The developer has now appealed this case on the grounds of non-determination.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

To re-cap, the Community Campaign Hart (CCH) chair the planning committee and failed to make a decision on the application at last December’s planning meeting. The council officers has recommended approval.

Hart is going to fight the appeal, probably on the grounds of wishing to maintain the Local Gap between Fleet and Crookham Village.

If Hart does lose its five year land supply, then this will make things difficult at appeal.

Apparently, the risk of losing £1.6m of New Homes Bonus has been mitigated because the indications from Government are that they are no longer going to push through those proposals.

However, there is still a significant risk that Hart will lose this appeal. The expectation is the appeal inquiry will be held in June, with a decision in August.

Hart Cabinet and Council Politics

We have now heard from several sources that one of the reasons Hart Cabinet appears to be so dysfunctional is that the ruling Conservative Party fears a vote of no confidence over the summer. This would entail CCH bidding to oust the Tories, presumably to be replaced by some sort of CCH/Lib Dem coalition. Maybe, the CCH coup is dependent upon the outcome of the Grove Farm appeal.

So, it appears as though we are planning for the extra houses to deliver a new settlement and secondary school we don’t need to appease CCH, who would prefer the new settlement at Winchfield.

It does seem very odd that we are having a new settlement forced upon us by dysfunctional politics.

 

 

Hart Housing Target increased to 10,000

Hart Council goes through the looking glass as it ups the Hart housing target to 10,000

Through the looking glass as Hart housing target increases to over 10,000

We have gone through the looking glass as the Hart Housing target has been increased to over 10,000.

Hart has now published the document that will be discussed at Cabinet on Thursday 9 February. The main headlines are as follows:

  1. The Hart housing target has been increased to 10,077, with shall we say, questionable justification
  2. The proposed housing allocations are outlined, including a new settlement at Murrell Green

Hart housing target increased

The housing target has been increased to 10,077 as per the table below. This represents a 125% uplift on the 2014-based demographic projections.

ItemItem totalTotal
Housing demand as per 2016 SHMA8,022
Flexibility2,055
Affordable housing rental uplift520
Rural exception site delivery50
Starter homes/shared ownership285
Market housing1,200
Total "Need"10,077
Completions 2011-2016(1,830)
Commitments (to 31 Jan 2017)(3,385)
Windfalls(297)
Remaining to meet need4,565

This is a very questionable increase. The SHMA already factors in a 53% uplift on the ‘natural’ demographic projections, which would give a total requirement of 5,334 dwellings. But if they had used the more up to date 2014-based projections, the start point would fall to 4,473. If we were to use the raw 2014-based figures as our total housing target, we would have already built or permitted the total requirement.

Second, the justification to increase the total to 10,077 is to build 855 extra affordable/starter homes. But the overall increase is set at 2,055 because they don’t expect to build more than 40% affordable properties. This is simply absurd.

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

Third, the SHMA has already made allowance for extra affordable homes (as can be seen above), and then this has already been uplifted for extra so-called jobs growth, which themselves will deliver more affordable homes.  Hart Council seems to be adding uplift on top of uplift in a quite random and arbitrary way. We have already analysed the SHMA here and here.

Fourth, the paper itself says there is no well proven evidence-based formula to uplift the housing target. There is nothing in National Planning Policy Framework (NPPF) that requires the target to be uplifted in a mechanistic way. Nor that the requirements have to be met in full.

No need to increase the Hart Housing Target to meet afordable homes requirement

Hart Affordable housing uplift

In short, the proposed uplift is double counting uplifts that have already been made that we are under no obligation to meet anyway.

If we were to build at this inflated rate, then this would be carried forward and compounded in future demograpgic projections.

Housing Allocations

The paper sets out the proposed allocations to meet this fictitious target, including 1,800 new houses at Murrell Green.

Housing allocations to meet the Hart Housing Target

Hart District housing allocations

No mention is made of Bramshill or Grove Farm (Netherhouse Copse), which are currently under consideration by the COuncil. Indeed we understand that the developers have appealed the Grove Farm application on the grounds of non-determination. Hart were already late in considering the application in December and cancelled the January meeting. Grove Farm is not on the agenda for the February meeting. It is difficult to see how they can defend the appeal.

Conclusions

Hart District Council is in a very perilous position. If it doesn’t get a Local Plan in place soon, it will lose around £2m per year in New Homes Bonus.

So everyone has a strong incentive to get a Local Plan. But by increasing the target to over 10,000 houses, everyone loses for decades to come.

It is difficult to work out the best way forwards. We could either wait until the Regulation 18 Consultation comes out in March and hope that we can influence matters for a better outcome. Alternatively, we can fight now for radical change of both the plan and the people running the process.

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

 

 

 

 

Status of Hart Local Plan set out in email to parish councils

Hart District Local Plan delayed again

The current state of play of the Hart Local Plan was set out in an email to Parish Councils last week.  We reproduce it below with our commentary in [bold italics]

Dear All, I am writing to update you on the current position with regard to the Hart Local Plan.

The Council’s overall strategic position on the Local Plan was agreed in October 2016.  It is to:

“Seek to meet Hart’s full, objectively assessed need for new homes, subject to the inclusion of an appropriate contingency to allow for any delays or the non-delivery of sites, and that it will also seek to accommodate any demonstrated unmet need for new homes from its Housing Market Area partners, and additionally provide for essential infrastructure including a site for a secondary school”. 

We have a Local Plan Steering Group (LPSG) that was set up by Cabinet and comprises a small Core Group of Members (The Leader, the respective Portfolio Holders for Planning and Housing, all Group Leaders, and the Chairman of Planning Committee). The purpose of LPSG is to advise Cabinet on Local Plan matters. It is not a decision making body. LPSG meetings are not held in public but the meetings are not secret and the minutes of each meeting are reported to Cabinet. The meetings are also open to all Councillors to attend and Stephen Parker, as Chairman, has encouraged all present to participate.

The latest meeting in December (LPSG minutes attached) tested the Policy Planners recommendation that we should support a potential option (which we called Option 3a) that included a possible small new settlement, urban extensions and a balanced distribution of new homes across the District. [We believe this included Murrell Green, Grove Farm and Owens Farm to the west of Hook. We understand Winchfield and Pale Lane (Elvetham Chase) were specifically excluded]. A site for a secondary school was also identified. In principle Option 3a would have accorded with the strategic aims agreed by the Council in October 2016. If agreed it would have resulted in a draft Plan being progressed to Council at the end of January with a view to it all going out to public consultation.

Whilst Option 3a still lies on the table the consensus from the recent LPSG meeting was that Option 3d (a larger new settlement and distribution option) [We believe this brought Winchfield back into the equation. The likely timescales would probably mean that Grove Farm and some combination of Pale Lane and Owens Farm would be required] should be revisited [We understand the driving force behind this initiative was Concrete Community Campaign Hart, who seem intent on derailing the whole process]. This was because the recent Housing Options consultation had confirmed that the public’s first preference is for future growth to be focused on the delivery of a new settlement [Actually the council stated its first preference was for brownfield development, but did not give the public an opportunity to vote on that solution].  The least preferred option was for more urban extensions. The broad cross party consensus was that we should look to avoid delivering urban extension and Option 3d would in itself be an alternative way of delivering the strategic aims agreed by the Council in October 2016.

At the moment we are reflecting upon this. We are reviewing the two options and we will consult shortly on one of them. At the time of consultation we will offer a briefing to all Parish and Town Councils. We are also testing the need for any affordable housing uplift [This is the rumoured 2,155 extra houses to meet an alleged need for 800+ extra affordable homes] which is also an new approach that is being recommended to us by the Policy Planners. It does have an implication for how many new homes that we should built but it does reflect issues that have been raised by Inspectors at recent Local Plan examinations. We need to consider it further and a policy decision made by the Council about whether it agrees to follow it. This testing may require a little additional work and re-evaluation of delivery timescales and trajectories. More information is being submitted to help us with the evaluation.

In the meantime Officers are keen not to undermine the democratic processes by engaging in a public debate [!!!!!] in advance of the District Councillors themselves having formed a view about how they wish to see the way forward [Perish the thought that councillors be involved in a debate with the public] . There is absolutely no benefit in seeking to rehearse decisions that have not yet been made and I’m sure that everyone would agree that it would not be right for Officers to engage in what is in effect political speculation.

We understand form elsewhere the delay to the Local Plan will be 4-6 weeks, or longer. Given that five of the six weeks have already all but gone by since the LPSG meeting on 13 December, we shall not be holding our breath.

Time to work together to head off new Hart housing threat

Hart Housing threat: sites under consideration

Hart Housing threat: sites under consideration

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

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

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

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

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

Impact of the Hart housing threat on sensitive sites

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

Impact of new Hart housing threat on Hart District sites

Impact of new Hart housing threat on sensitive sites

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

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

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

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

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

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

Impact of Hart housing threat on the land supply

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

Impact of new Hart housing threat on 5 year land supply

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

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

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

Conclusion

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

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

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

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