Health and Safety Executive criticises Hart Council

Health and Safety Executive (HSE) Logo

Health and Safety Executive (HSE) Logo

The Health and Safety Executive (HSE) has criticised Hart District Council for not clearly marking on a map the Major Accident Hazard pipelines that pass through the district.

Regular readers will recall that the Master Plan for the proposed new settlement at Murrell Green does not refer at all to the high pressure gas main that runs through the site.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

We alerted the HSE to this and invited them to comment on the Draft Local Plan that is currently out for consultation. They have written to Hart Council and identified two further potential issues:

We have concluded that there is the potential for land allocated in your plan to encroach on consultations zones.  The land allocations that could be effected (sic) are as follows

Map 30 – Murrell Green (Proposed Strategic Housing-led Development Policies SC1-SC4)

This allocation encroaches on the Southern Gas Networks High Pressure Pipeline – HSE Reference: 7067 Gaston Wood/Murrell Green(PO65)

It also has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7069 Crockmore Farm/Bramshill(P067)

Map 7 – Eversley Centre – SC5

This allocation has the possibility to encroach on the Southern Gas Networks High Pressure Pipeline – HSE Reference 7083 Bramshill/The Devil’s Highway(P086)

The HSE then go on to spell out their recommendations for how local authorities should identify such hazards in their Local Plans (emphasis ours)

Identifying Consultation Zones in Local Plans

HSE recommends that where there are major hazard establishments and MAHPs within the area of your local plan, that you mark the associated consultation zones on a map. This is an effective way to identify the development proposals that could encroach on consultation zones, and the extent of any encroachment that could occur. The proposal maps in site allocation development planning documents may be suitable for presenting this information. We particularly recommend marking the zones associated with any MAHPs, and HSE advises that you contact the pipeline operator for up-to-date information on pipeline location, as pipelines can be diverted by operators from notified routes. Most incidents involving damage to buried pipelines occur because third parties are not aware of their presence.

Clearly Hart Council has failed to follow Health and Safety Executive Guidelines.

The full letter from the HSE can be found here.

Hart Council launches Local Plan consultation

Hart District Council Logo

Hart Council has launched a Regulation 18 consultation into the draft Local Plan. The consultation will be open until 5pm on 9 June 2017.

Drop in sessions will be running at the following dates and locations:

  • Tuesday 2 May – 2pm to 8pm – Hook Community Centre, RG27 9NN
  • Wednesday 3 May – 2pm to 8pm – The Harlington Centre, Fleet, GU51 4BY
  • Monday 8 May – 2pm to 8pm – Victoria Hall, Hartley Wintney, RG27 8RE
  • Wednesday 10 May – 2pm to 8pm – The Tythings, Yateley, GU46 7RP
  • Thursday 11 May – 2pm to 8pm – Ridley Hall, South Warnborough, RG29 1RQ
  • Monday 15 May – 4.30pm to 8pm – Hawley Leisure Centre, GU17 9BW

The consultation materials can be found here.

Once we have had chance to absorb all the materials, we will be posting our advice on how to respond to the consultation.

Does High Pressure Gas Main scupper Murrell Green proposals?

Murrell Green High Pressure Gas Main

Murrell Green High Pressure Gas Main

As regular readers will know, as part of the Hart Local Plan, the local council is proposing a new settlement at Murrell Green. However, they don’t seem to have taken the high pressure gas main that runs through the site into account in their planning.

The site appraisal makes no mention of the gas main. However, the schematic above, obtained from SGN, who manage the gas mains in this area, shows a high pressure gas main, of 24″ diameter. It is described by the Health and Safety Executive (HSE) as a Major Accident Hazard Pipeline. It appears to cut a swathe through the proposed housing and the site of the proposed school shown in the schematic below.

Murrell Green high pressure gas main

Murrell Green development with high pressure gas pipeline

After reviewing the HSE guidelines we have come to the conclusion that major housing and a school will not be allowed to be built within approximately 100m of the pipeline. This would put a major question mark over the viability of the proposed scheme.

Murrell Green High Pressure Gas Main size 24"

Murrell Green Gas Pipeline size 24″

Full analysis below. This new information comes on top of the environmental, infrastructure and coalescence issues we raised here before.

We have had a response from Hart Council:

Head of Planning at East Hants, confirms that that the pipeline was considered alongside a number of other constraints to development. It is a known constraint which will need to be taken in to account in any master plan for the new settlement along side other constraints which have been identified in the consideration of all the sites through the SHLAA process and after. It is not however seen as any form of ‘show stopper’.

It does seem odd that planning to build a school and significant housing right on top of a 24″ high pressure gas main is not considered a ‘show-stopper’. However, we can find no mention of the pipeline in the latest assessment of rural sites covering SHL136, 167 and 186.

HSE guidelines on building near gas pipelines

The HSE has special guidelines for planning near to such installations.

First, various zones around the pipeline are established. An inner, middle and outer zone.

Consultation Distance for pipelines

We don’t know the exact size of the zones for the Murrell Green pipeline, but by way of example, the zones at Upchurch were established as:

  • Inner Zone: 9m
  • Middle Zone: 95m
  • Outer zone: 110m

According to the letter from SGN, the inner zone for the Murrell Green pipeline is 8m.

SGN Letter regarding Murrell Green High Pressure Gas Main

SGN Letter regarding Murrell Green High Pressure Gas Main

So, it is reasonable to assume the middle and outer zones will be roughly the same as those at Upchurch.

The next stage is to look at the type of development and assign a sensitivity. Housing developments over 30 units are assigned level 3.

Housing Sensitivity to gas pipelines

Housing Sensitivity

Schools, with a development size of more than 1.4Ha are assigned a sensitivity of 4.

School sensitivity zones

School sensitivity

Then a decision on whether development of various sensitivities is allowed in the various zones is made according to a matrix:

PAHDI Sensitivity and decision matrix

PAHDI Sensitivity and decision matrix

It is clear that major housing would not be allowed in the Middle Zone and a large school would not even be allowed in the Outer Zone.

Conclusion about Murrell Green High Pressure Gas Main

Our conclusion from this is that the school would not be allowed within around 100m of the pipeline, and so would have to be moved from the proposed position. It is highly likely housing would not be allowed within about 90m of the pipeline. This would create a no-go zone right through the centre of the proposed development and probably render it unviable.

Time to think again Hart Council.

 

Hartland Village Planning application submitted by St Edward homes

Hartland Village (Pyestock) Master Plan

Hartland Village (Pyestock) Master Plan

A planning application for Hartland Village has been submitted by St Edward Homes.

Details can be found at Hart’s public access system using reference 17/00471/OUT.

We are broadly supportive of this application, but would echo a number of the objections that have been made:

  1. There should be greater provision for affordable homes. The application is for 1,500 new homes in total. Provision has been made for 195 social rented units and 105 intermediate units. Given the council has increased our housing allocation to 10,000 on the basis of needing more affordable housing, the application should not go ahead unless at least 600 units are affordable or starter homes.
  2. There should be more provision for cycling and walking to Fleet station and the town centre. It would be helpful if a new bus service was also provided, perhaps along the lines of the Hartley Wintney Community bus.
  3. More investment will be required in the local road network to make this development work. We would suggest Kennels Lane needs a significant upgrade.
  4. Specific provision needs to be made for a local health centre and dental practice.
  5. We need a definitive answer from Hampshire County Council on whether a new secondary school is required in Hart or not. If so, it should be provided on this site, which is where the bulk of new children will live.
  6. As is the case with any new development in Hart, the mainline train route to London needs to be significantly upgraded, including stations and parking.

We would urge everyone to make their voice heard in this important consultation.

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.

Winchfield Neighbourhood Plan adopted

Winchfield Neighbourhood Plan adopted

Winchfield Neighbourhood Plan adopted by Hart District Council

The Winchfield Neighbourhood Plan was formally adopted by Hart District Council at their meeting last night.

Key points in the plan are shown below:

Small scale housing development

Housing is seen by the local community as best delivered by means of the following types of development:
A number of sensitive developments of up to seven houses on existing residential land, even where this may be beyond the current settlement boundaries but otherwise meet Hart DC and NPPF criteria and the policies in this Plan.

On other Brownfield sites in Winchfield, where identified, that meet Hart DC and NPPF criteria and the policies in this Plan. This would replicate the previous successful brownfield site regeneration of the former Winchfield Station Goods Yard.

One or two new unobtrusive developments of a similar size, scale and sensitive location to the existing successfully integrated Beauclerk Green (brownfield site) development, built in 1997. Such new development should not exceed the density of Beauclerk Green as it stands today.

This would seem to rule out vast new housing estates such as those proposed in the centre of Winchfield and in Murrell Green (much of which is in Winchfield Parish). However, the Hart Local Plan would take precedence over the Neighbourhood Plan.

Size and location of housing

Policy A1: Size and Location of New Developments

As a general principle new housing developments should respect the existing scale of the village and should not result in a new development of more than seven homes.

As an exception, a new housing development in excess of seven homes will be considered if on a carefully chosen site, similar in size and density to Beauclerk Green, respecting existing settlements and current local gaps which prevent coalescence with neighbouring villages.

Appropriate redevelopment of brownfield sites will be supported in preference to greenfield sites. The appropriate redevelopment of disused buildings will be supported.

Developers will be required to demonstrate that there is adequate water supply, waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water and/or waste water infrastructure.

Drainage on the site must maintain separation of foul and surface flows.

In the event that there is a water supply, waste water capacity and surface water drainage infrastructure capacity constraint the developers will be required to identify the appropriate improvements that are required and how they will be delivered.

However, the detailed size and location of housing policy adds a further barrier to large scale development. Policies A2 and A5 provide for generous parking and low density housing.

The full Neighbourhood Plan can be downloaded below.

Winchfield Neighbourhood Plan

Winchfield Neighbourhood Plan Adopted Version

 

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.

 

 

Statement to Hart Cabinet

Hart District Council and Hart Cabinet Offices, We Heart Hart. We Love Hart

Statement to Hart Cabinet

The crucial Hart Cabinet meeting to decide the spatial strategy to be incorporated in the forthcoming consultation on the Hart Local Plan will be held tonight at 8pm.

Public participation is allowed and we have been allowed to speak. A copy of our prepared statement is shown below. Please do come along and watch the debate.

Statement to Hart Cabinet 9 February 2017

Thank you for allowing me to speak.

This is an important time for Hart – you are setting out a strategy that will impact the quality of life of Hart residents for many years to come, so it is important you do the best job you can.

Hart Council is in a perilous position and facing the threat of losing around £2m of NHB if the Local Plan is not in place on time and of course the threat of many speculative planning applications. So, it is right that you are risk averse at this time.

However, I would like to use this statement to persuade you to change direction.

I would like you to focus on reducing the housing target of 10,000 by removing the unnecessary uplift of 2,000 extra houses on top of the SHMA target of ~8,000.

The SHMA starts with the ONS population and household projections. It says the “the household projections… are statistically robust and are based on nationally consistent assumptions”. They take account of international migration and migration between districts.

On their own, these projections would point to a need for around 5,300 houses over the planning period. If, however, the SHMA used the more up to date 2014-based figures, the housing need would fall to around 4,500, compared to the 10,000 you are proposing to build.

That’s right, the latest demographic projections point to a need that is less than half of that you are proposing.

However, it is probably right that the housing target should be inflated a little to cater for what is termed suppressed household formation and concealed households.

The SHMA has done this by firstly increasing Hart’s target up to around 6,100 new dwellings to cater for households that are termed ‘can’t rent, can’t buy’ and those who can rent but can’t buy.

Secondly, it then makes a further increase of around 500 affordable homes. This brings the total target to around 6,600.

To my mind 6-6,500 houses would be reasonable overall that would mean we could meet the rest of the target from brownfield sites alone.

To emphasise: The SHMA has met the demographic need and already takes account of suppressed household formation, concealed households and affordable housing.

The SHMA then goes on to add a further 1,400 houses for economic growth, bringing the overall total to 8,000.

This ‘economic growth uplift’ does by definition mean that you are planning for additional inward migration to Hart, people whose needs are supposed to be met elsewhere. Not only that, the SHMA assumes many of these people will also work outside the district and thus put increasing pressure on the creaking transport infrastructure. This is not sustainable development.

Yet, you are now proposing to add a further 2,000 houses to the total to meet extra questionable affordable housing needs.

However, we have already established the SHMA itself has already taken account of the affordable requirement, so this extra 2,000 is double counting.  It will require us concreting over our green fields to meet non-existent housing needs. This is unsustainable over-development.

We wouldn’t need the new Murrell Green settlement if you removed the 2,000 unnecessary houses from the target. I might add the new settlement is entirely unsuitable. It is bordered by the M3 and A30. Criss-crossed by the railway, power lines and a high-pressure gas main. A big chunk of the site is former landfill. Only last year a solar farm was turned down on the grounds it would spoil the view from the Odiham Deer Park and spoil the enjoyment of walkers on the public footpaths. This proposal is far more intrusive than solar panels.

So finally, I urge you, please do the right thing and plan for a sensible housing target. Don’t blight our green fields with so many unnecessary houses. If you really want to help the concealed households, make sure you allocate some of the existing housing target to subsidised social-rented accommodation.

Is the Murrell Green new settlement viable?

Murrell Green new settlement proposal

Murrell Green new settlement proposal

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

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

Environmental concerns about the Murrell Green new settlement

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

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

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

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

SHL 167 Landfill details Beggars Corner

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

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

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

Gas Main through Murrell Green new settlement Site

Gas Main through Murrell Green Site

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

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

Infrastructure Issues

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

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

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

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

Coalescence of Hartley Wintney and Hook

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

Hook SHLAA sites in Hart District, Hampshire

Hook SHLAA sites in Hart District, Hampshire

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

In essence, we are creating Hartley Winchook.

Financial viability of the promoter

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

There are a number of pertinent facts about this company:

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

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

Accounts to Pearson Strategic can be found here.

Fixed and Floating charge document can be found here.

Conclusion

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

Time to make our voice heard again.

 

Hart Local Plan: Green fields or fictitious jobs?

 

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

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

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

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

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

[update]

We would suggest the following approach to the consultation:

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

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

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

[/update]

We set out our analysis below.

What does the NPPG say we must do?

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

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

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

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

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

SHMA 11.50 NPPG does not require housing uplift

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

What do the jobs forecasts say?

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

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

SHMA Section 5 summary range of forecasts

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

SHMA 11.1 wide spectrum of forecasts

SHMA 11.1 wide spectrum of forecasts

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

What does the SHMA say about the Employment Forecasts?

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

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

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

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

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

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

SHMA 11.56 Population growth from inward migration from other areas

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

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

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

SHMA 11.51 Excess housing supply could lead to extra out commuting

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

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

SHMA Figure 11.1 and S11.15 out commuting calculation errors

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

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

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

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

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

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

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

What does the SHMA say about economic growth?

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

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

SHMA 11.55 Better to achieve economic growth through productivity improvement

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