Rushmoor leads urban regeneration push

Rushmoor leads urban regeneration push

Rushmoor leads urban regeneration push

Leader of Rushmoor Council, Dave Clifford has published an article in Get Surrey, setting out how the council is tackling urban regeneration in Aldershot. Full article here.

He acknowledges the challenges facing town centres from increased internet shopping. Their response has been to produce a prospectus for Aldershot town centre. This includes a joined up plan to support redevelopment of areas such as Westgate and the Galleries. But they have also taken a leadership position by acquiring properties on Union Street. This is part of a plan to consolidate ownership, so a redevelopment plan can be put together.

There is much to be done, but it is clear Rushmoor is rising to the challenge.

Well done Rushmoor.

Hart is missing an opportunity

Hart Local Plan to regenerate urban centres

This is in stark contrast to Hart Council. The recent Local Plan consultation acknowledged “The delivery of town centre redevelopment opportunities must be a priority”. However, no significant proposals were put forward to improve the town centres of Fleet, Blackwater, Yateley or Hook. We did put forward some ideas on this in our response to the Local Plan consultation.

It remains to be seen if the new administration has the vision and the political will to tackle these issues.

Developers battle over new settlement options for Hart District

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

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

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

  • Rye Common
  • Murrell Green
  • Winchfield

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

New settlement options for Hart District – Rye Common

The developer raised the following points regarding their presentation:

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

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

New settlement options for Hart District – Murrell Green

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

Murrell Green near Hook and Hartley Wintney Framework Plan.

Murrell Green Framework Plan with pipeline

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

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

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

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

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

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

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

New settlement options for Hart District – Winchfield

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

Winchfield Garden Community Master Plan with pylons and powerline

Winchfield Garden Community Master Plan with pylons and powerline

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

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

The main problem with this proposal are:

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

Our Response

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

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

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

 

Hart Local Plan Update

Hart District Council Logo - Hart Local Plan

Things have been quiet with the Hart Local Plan since the consultation closed back on June 9 2017. We have spoken to a number of people and have the following update:

Hart Local Plan Consultation Results

We understand that there was a strong response to the Local Plan consultation. But the results of the consultation will not be seen by anyone (including councillors) until September. There will be a Local Plan Steering Group meeting in September during which the consultation results will be discussed.

Impact of New Government rules on Hart Local Plan

There is clearly some concern about the new Government threats to councils with no Local Plan in place. Clearly, there are problems with the high pressure gas main at Murrell Green. However, if the council drops this site without also reducing the ridiculous housing target, then they will need to find new sites. These new sites may well require a further Regulation 18 consultation, which would push them beyond the deadline of 31 March 2018.

Hart Local Planning team

We understand that Hart has recruited four additional planners to the planning team to help them prepare the next version of the Hart Local Plan. The new version is supposed to be published for a Regulation 19 consultation in Winter 2017.

Government threatens councils with new housing need methodology

Government threatens council with new housing need methodology

The Government has threatened councils with a new housing need methodology if they don’t submit a Local Plan by March 2018. The threat is contained in a Government newsletter that has been reported upon by Lichfields the planning consultancy. The report can be found here.

It is of course unclear what this new methodology might entail. However, the Government is desperate to increase the level of housebuilding, so it is likely this new methodology will further increase Hart’s target.

The new deadline of 31 March 2018 gives a critical backstop date for Hart to submit its Local Plan for inspection. The target date for submission was vaguely described as Spring 2018 in the latest consultation. However, as we know Hart Council has missed every deadline it has set itself. So, it remains to be seen if the new administration can get a new plan together on time, especially as Hart has already effectively turned down an application on one of its preferred sites.

 

 

 

 

Hart Council to destroy its own Local Plan

Council Incompetent over farm home plan destroying Local Plan

Hart destroys its own Local Plan

Hart Council will effectively destroy its own Local Plan. It has taken the decision to oppose the appeal into the Cross Farm care home application by proceeding ‘on the basis that the planning application has been refused’.

This is laughable because the Cross Farm development was one of the preferred sites in the recent draft Local Plan consultation. The proposal is for a 160 unit care village and a 64-bed care home. The potential impacts of the decision to turn down the application are:

  1. Hart loses 224 dwellings from its draft Local Plan, potentially rendering it unsound
  2. The Local Plan no longer meets the specialist housing needs of older people, potentially rendering it unsound
  3. The council loses around 25Ha of valuable SANG land, constraining capacity to build new homes in the district
  4. The cost of the appeal is likely to be around £100,000, rising to over over £200,000 if Hart Council loses
  5. May lead to the introduction of a further round of consultation into the Local Plan, costing more money and losing another six months in the schedule

It is looking like the new CCH/Lib Dem administration is even worse than the previous Tory administration when it comes to planning policy. It may well be time for the Secretary of State to step in and appoint commissioners to replace this failing council.

The full article in the Fleet News and Mail can be found here.

Hart fails to decide Cross Farm application on time

Sad clown at Hart council fails to decide Cross Farm Appeal document 16/03400/OUT

Hart Council clowns fail to decide Cross Farm application

Hart Council has failed to decide the Cross Farm in Crookham Village planning application on time. This has led the developers to submit an appeal on the grounds of non-determination. This comes on the heels of the failure to determine the Grove Farm (Netherhouse Copse) application back in December 2016.  This is Jedi-level incompetence that makes the Council look like clowns.

The original application was made in January this year and should have been decided by 7 April. The application doesn’t seem to have been considered at all by the Planning Committee. Details of the original application for the Cross Farm development can be found here, and searching for 16/03400/OUT. The appeal documents can be found by searching for 17/00078/NONDET.

The proposed Cross Farm development in Crookham Village was one of the recommended sites in the recent Local Plan consultation. This indicates that the proposal was supported by officers.

We can only guess at why it wasn’t determined on time. Clearly,  the council is dysfunctional. The Conservatives were in charge of the council when the application should have been decided. However, Community Campaign Hart (CCH) held the chair of the Planning Committee at that time. Now the Planning Committee is chaired by Graham Cockarill of the Liberal Democrats, and the administration is jointly run by CCH and Lib Dems. Therefore, it seems none of the parties are able to get a grip on the planning process and take decisions on time.

One explanation might be that despite Cross Farm being in the draft Local Plan, CCH councillors felt unable to support the proposals. Therefore, they abdicated responsibility, so they could blame any decision on the Inspector. Of course, the appeal will be at council taxpayer expense.

[Update] Another explanation might be that it wasn’t in the interests of the Tory administration or the officers to bring this to the Committee on time. Cross Farm in Crookham Village was a preferred site in the draft Local Plan. If Cross Farm had been rejected at Committee, it would have effectively scuppered the Local Plan. [/Update]

Cost of Cross Farm, Crookham Village appeal

It is likely that this public enquiry style appeal will cost the council over £100,000 to defend. We find it difficult to understand how they expect to win the appeal given that the site is in the draft Local Plan. Therefore, we think it likely the inspector will award costs to the developer should they win. This would bring the total costs of the appeal to over £200,000.

The overall council budget is ~£10m. Surely, this appeal money could be better spent on local services, infrastructure or social housing?

 

Government to force Hart to increase housing target

Increased housing target will lead to more £1m houses like this at Hartley Row Park, Hartley Wintney, Hart District, Hampshire.

Government to force Hart to increase housing target.

The Government will force Hart to increase its housing target says Sajid Javid, the Secretary of State for Communities and Local Government, it is reported in the Telegraph today. The article says:

Families living in some of the most sought-after parts of the country will be forced to accept more homes being built near them to tackle the housing crisis, the Communities Secretary has said.

Sajid Javid said that he wants communities which have benefited from soaring property prices to play their part in solving the housing crisis.

New rules to force councils to increase their housing targets will be published in the next three weeks.

Excerpts from his speech have been tweeted. It is clear Mr Javid has in mind councils that have yet to produce a Local Plan.

We don’t agree with Government that Hart needs to build even more houses. The 10,185 target adopted in the recent Local Plan Consultation is clearly ridiculous. It is already more than twice the need identified by the Government’s own population forecasts. What we need is more social housing for those who can’t rent and can’t buy. We also need more 1 and  3-bed properties to help the young get on the housing ladder

Hart District Completions compared to target by number of bedrooms

We certainly don’t need more £1m houses like those for sale in Hartley Wintney at the moment.

Land-banking causing delays to building

We might also address the land-banking in the district, where thousands of houses have not been built, even though planning permission has been granted.

Year of grant Net uncompleted dwellings
2003 5
2005 1
2006 0
2008 1
2009 2
2010 14
2011 58
2012 591
2013 402
2014 793
2015 1,066
2016 148
Grand Total 3,081

It remains to be seen if the new Hart Council administration can stand up to this bullying from central Government. We need a lower, more realistic housing target.

 

Local Plan misses opportunity to regenerate urban centres

Hart Local Plan to regenerate urban centres

Hart Local Plan to regenerate urban centres

The consultation on the Draft Local Plan misses an opportunity to regenerate urban centres in Hart District.

This is contrary to Para 131 of the Plan that says “The delivery of town centre redevelopment opportunities must be a priority”. The National Planning Policy Framework (NPPF) indicates (paragraph 23) that planning policies should promote competitive town centre environments and set out policies for the management and growth of centres over the plan period.

This can be best illustrated by using Fleet as an example.

Fleet is the lowest density town of its size in the country. The chart below that there is significant scope for increasing development density in Fleet.

Fleet housing density versus towns of similar size

Fleet housing density versus towns of similar size

 

The retail offer in Fleet is poor, the cultural facilities (e.g. Harlington Centre) are outdated and there is no proper cinema.

Fleet Health score versus benchmarks

Fleet Health score versus benchmarks

 

However, Fleet has the highest average earnings per person of comparative towns by quite a large margin (eg 9% more than Camberley). High earnings should give Fleet a significant advantage over the comparison towns.

 

Fleet earnings versus competitors

Fleet earnings versus competitors

The Local Plan Vision and Objectives fail to take advantage of the opportunity to modernise Hart’s urban centres while at the same time protecting Hart’s countryside.

We believe that the Vision for the Local Plan should be centered on the proposition that Fleet and other urban centres will be re-generated. With Hart District Council’s full and active support, a plan based on urban regeneration would achieve the following benefits:

  1. An ambitious Hart Urban Re-generation Project (HURP) would attract private investment and thus be affordable
  2. Private investment would allow for Hart’s infrastructure to be upgraded in line with the urban re-generation
  3. Good urban design principles would achieve a higher population density in the urban centres while at the same time providing an improved ‘sense of place’ and making the urban centres more desirable places to live.

A similar approach could be adopted in Yateley to provide a proper retail-led centre and improvements could be made to Blackwater. The requirement for additional retail facilities in Hook, identified in the Local Plan could also be met.

Apparently, Hart did have a plan to conduct a brownfield study to evaluate the ‘art of the possible’ in our urban centres. This project has not delivered.

 

In addition, Yateley lacks a defined centre, Blackwater is indistinct and Hook lacks good quality restaurants and shopping facilities.

The council should be setting out a bold plan to improve the retail, cultural and recreational amenities in the district. We should also develop plans for a theatre and cinema in Fleet as part of an attractive mixed-use redevelopment. There will be significant cash available from developers to fund such an ambitious plan.

Moreover, the council should work collaboratively with developers to regenerate other urban areas such as Blackwater and redevelop the centres of Yateley and Hook.

Please ask the council to think again  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

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.

Draft Local Plan has no infrastructure plans or costings

 

Hart Local Plan contains no infrastructure plans or costings

Local Plan contains no infrastructure plans or costings

The draft Local Plan contains no infrastructure plans or costings. We think this is a massive error by the council that makes the draft Local Plan unsound.

If you agree, please download from 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

Here is our analysis of the infrastructure weaknesses in the Local Plan

Local Plan contains no infrastructure plans

Paragraphs 7, 17 and 177 of the NPPF/NPPG make clear that infrastructure should be planned alongside housing. Para 395 of the draft Local Plan says there’s a Draft Infrastructure Delivery Plan (IDP) available for viewing alongside the Local Plan. However, no IDP has been made available.

Given that back in 2013, a £78m infrastructure funding deficit was identified, this is a critical omission. In particular, we think Hart Council should focus on:

  1. The requirement for a new secondary school. The Murrell Green proposal includes a site for a new school, albeit on top of a high-pressure gas main. However, no evidence has been presented to demonstrate a new secondary school is required. WeHeart Hart research shows that a new secondary school may not be required, and the sustainability assessment for Murrell Green mentions a 9% surplus of places.
  2. Railways. SW Trains have indicated that the mainline rail route to London is 20% over-crowded at present and is forecast to be 60% overcrowded by 2043. Para 58 of the Local Plan makes no mention of this, and there is no apparent plan to improve capacity.
  3. Our roads are becoming increasingly congested and generally in a poor state of repair. There is no sign that the council has carried out an overall road transport assessment to establish the level of investment required to improve our roads so they can cope with the scale of development that is being proposed
  4. Paras 65 & 66 make no mention of groundwater and surface water flood risk in Winchfield, which was identified in the Sustainability Assessment
  5. Para 68 provides no plan to fix the acknowledged wastewater capacity issues
  6. None of the plans for the strategic sites include proper plans for sports and community facilities such as allotments.

Local Plan contains no cost analysis for infrastructure requirements

Neither the Local Plan nor the Sustainability Assessment contain a financial assessment of the alternative means of providing the housing need. We think this is a very significant omission.

We already have a £78m infrastructure deficit, so this is a critical issue. The financial analysis should include:

  1. An assessment of the major infrastructure requirements generated by each of the approaches you have considered. These include new roads; road improvements such as roundabouts; railway station and parking improvement; railway line capacity improvements; schools; healthcare; fixed and mobile telecommunications, flood prevention, wastewater disposal and social infrastructure. A high level cost of each item should be provided.
  2. An analysis of the likely contribution that could be expected from developers and other providers to meet these requirements.
  3. An estimate of the likely contributions from Government such as New Homes bonus and grants to support brownfield development.
  4. A calculation of the gap between the requirement and the contributions for each development scenario

Residents should then be able to see the financial impact of the proposals and make decisions based on that.