Open letter to Ranil Jayawardena, Sajid Javid and Gavin Barwell

Ranil Jayawardena Stephen Parker and Michael Fallon meet at Pyestock (Hartland Park or Hartland Village

Below is the text of an open letter sent to our Local MP, Ranil Jayawardena asking for his help to make changes to national policy to help Hart come up with a more realistic Local Plan and help fend off the threat of too many houses.

Let’s see what happens.

Dear Ranil,

To date, I have been very impressed with you as our local MP. You seem to be well in tune with your constituents and your campaign to promote more brownfield development in our area is to be commended.

I know that, quite rightly, you are reluctant to get involved in local planning matters because they are the responsibility of the local council. However, I am writing to you today to ask for your support in changing some elements of national policy that should help Hart District Council produce a more realistic Local Plan.

There are four main sections to this letter:

  • Process and outcome of assessing housing need
  • Affordable housing
  • Infrastructure contributions
  • Suggested policy changes

The links in the text take you to more in depth research, mostly from the WeHeartHart.co.uk website, which I run, to support the assertions made. I have also copied this letter to the ministers responsible for this area of policy and the leader and joint-CEO of Hart Council.

Assessing Housing Need

 

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 130-150,000 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.

However, there is increasing evidence that house builders have too strong an influence over the process that is leading to housing market assessments being artificially inflated to a level much higher than that required by the national household projections.

In Hart, the 2014 Strategic Housing Market Assessment (SHMA) is currently being revised to take account of more up to date population and household forecasts. However, I believe the process being followed will be largely the same as before.

The way it works is as follows. The raw household forecasts are subject to a set of dubious adjustments and convoluted calculations to arrive at a spurious objectively assessed ‘need’.  In the case of the 2014 SHMA, the outcome was ~7,500 houses. For the SHMA area as a whole this results in an uplift to the raw DCLG household forecasts of more than 50%.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 305,000 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”.  I did make a FOI request to the DCLG to provide the national figures, but this has been refused on the grounds that DCLG “does not hold this information”. Given the importance that is being placed on housing delivery, it is quite staggering that central Government is not collecting the data to allow it to monitor the results of its own housing policy.

The experience of the Hart, Surrey Heath and Rushmoor SHMA is by no means unique. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the baseline household projections of around 42%.

A further illustration of the absurdity of the calculations used in the 2014 SHMA is contained in its own appendix.  This clearly shows that if the more up to date 2012-SNPP number were used, the starting point for Hart would fall from 337 to 247 dwellings per annum or a fall of 1,800 units over the plan period.

Taken together, these results show that the process for producing the SHMAs is fatally flawed and cannot be justified.

There might be some justification if this process had actually 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 this year there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

It is clear that creating ever increasing housing targets is merely encouraging ‘land-banking’ by builders, who then build at a rate to maximise their own profits.

Imagine my surprise to find out that one of the outcomes from Hart’s yet to be published revised SHMA is that the housing target is going to be raised again to over 10,000 units (although this is being further examined by the council). Yes, you read that correctly: despite the starting point being based on the more up to date population forecasts described above, that should result in a ‘need’ of 1,800 fewer houses, the target is going to be raised 30% above the earlier ‘need’ and nearly 100% above the new starting point.

Apparently, there are some further arbitrary adjustments, some other sophistry and some new guidance from Government about the provision of so called ‘Affordable Homes’ that means in order to satisfy a shortfall of ~800 affordable homes, we must build over 2,000 more new houses in total because the affordable component cannot be more than 40% of the total.

The consequence of this change is that it will inevitably mean we can no longer meet our remaining housing need from brownfield sites and will have to sacrifice great swathes of our beautiful countryside to satisfy some bureaucratic pen-pushers rather than the actual housing needs of the district.

This is plainly ridiculous and cannot be allowed to stand. But that leads me on to policy improvements  around ‘Affordable Homes’

 

Affordable Homes

 

Many in Government seem to hold the view that merely calling some houses ‘”Affordable” makes them so. This is clearly an absurd position to take.

Let’s take a local example in my own village.  Recently, Bewley Homes built around 90 new houses in a new development called Hartley Row Park at a reasonably sensible add-on to the village.

The lowest price for a 3-bed semi-detached home was set at £465,000. The lowest anticipated price of the 2-bed homes that were due to be released later in 2016 was £370,000. This means that the cheapest 3-bed house is 11.5 times median income, and the cheapest 2-bed home will be 9.2 times median income.  Even with a 20% ‘Affordable’ homes discount, the cheapest new properties will be totally out of reach of middle-income families in the district.

This is further compounded by the lack of measurement and poor controls over the size of properties bring built. There is clear evidence that Hart is under-building 1-bed and 3-bed starter homes and over-building 4+bed properties. This is doing nothing for the younger residents of Hart, whom the Local Plan is supposed to serve, yet encouraging even more inward migration from London into properties that locals cannot afford. Clearly, the controls needed are really a matter for the local council, but there may be something that can be done at a national level to mandate new developments to meet local needs.

However, there are some national policies that need to be examined, not least the ‘Help to Buy’ scheme, interest rates and QE.

As any economist will tell you, if you subsidise the price of anything, then demand will go up and prices will follow. I find it quite amazing that a supposedly free-market Conservative Government is borrowing to use taxpayers’ money in the HTB scheme to subsidise higher house prices, especially at a time when we still have a massive budget deficit.

But the bigger impact on house prices has probably come from ultra-low interest rates and QE. This inexorable flow of cheap money has artificially raised the price of all assets and property in particular. You cannot hope to bring house-prices to reasonable levels unless and until you address monetary policy.

 

Infrastructure Contributions

 

Hart, like many other places in the country is suffering from creaking infrastructure. Our schools are full, it is difficult to get appointments at the doctors and road congestion is increasing.

According to the latest figures available Hart is running a £78m infrastructure funding deficit, and this is probably an under-estimate as it was prepared before the current, let alone the new SHMA. Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It is true that many developments attract S106 or CIL contributions towards infrastructure. However, it is also clear that both ‘Affordable Homes’ and office conversions using ‘Permitted Development Rights’ deliver no such contributions. Overall, the policy mix has delivered a massive funding gap, yet we are expected to continue to even more houses, when the funding delivered is much less than the funding required to bring the infrastructure up to scratch.

This is clearly unsustainable and must change.

 

Suggested Policy Changes

 

As I see it you can help your constituents by demanding policy changes in several key areas:

  • The Government should collect and analyse all SHMAs across the country to monitor that the total of the local ‘needs’ is in line with the overall national totals
  • There should be some greater controls put on the way that seemingly arbitrary adjustments to the starting points are made to ensure they do not go too far above those levels. 20% would seem like a reasonable level to me.
  • Encourage builders to build existing planning permissions faster by introducing a charge equivalent to council tax rates when development has not completed after a specified period of time.
  • Stop subsidising higher house prices through HTB, QE and ultra-low interest rates.
  • Introduce a ‘planning gain levy’ on land owners who make significant windfalls from selling agricultural land for development to fund infrastructure. This would be similar to the original ideas behind “Garden Cities” where landowners helped fund infrastructure
  • Introduce S106/CIL funding for all new development. Every new home has people in it and they all use local infrastructure, so all new development should include some contribution
  • Introduce ‘open book accounting’ to each development and force developers to make increased S106 contributions if they make more than planned profit on a development.
  • Increase Government funding for smaller, local infrastructure projects such as road widening, junction improvement, bridge widening, school building and surgery building. This would be a much better use of money than building white elephants like HS2.

I do hope you find this letter constructive and helpful in understanding the impact of national policy on your local area.

May I wish you and your family a Merry Christmas and a happy and prosperous New Year.

 

Yours sincerely,

 

Hart recommends Grove Farm and Bramshill planning proposals be accepted

Hart District Council recomend approval of Grove Farm Bramshill House planning applications

Hart District Council officers are recommending that the planning application for Netherhouse Copse (aka Grove Farm) and some of the applications to redevelop the former Police College at Bramshill House be granted. This has been revealed in papers recently published to go before the Planning Committee that meets on 14 December 2016. The relevant papers are available for download below.

Netherhouse Copse (Grove Farm)

The Nether House Copse (Grove Farm) application is for 423 dwellings on a green field site on Hitches Lane, Fleet in Hampshire. The controversial proposals have been opposed by a wide range of local community groups including Crookham Village and Dogmersfield Parish Councils and Fleet Town Council. But they have also been supported by various parts of Hampshire County Council and Thames Water amongst others. The planning officers have recommended that the application be granted, subject to certain conditions, and that it should go to full council for ratification. See p176 of the Agenda download below.

Bramshill House Police College

The proposals for the largely brownfield site at Bramshill House are more complex, in that there are a total of 7 applications covering various aspects of the proposed redevelopment.

Applications 2 and 3 (respectively 16/00722/FUL, 16/00724/FUL) cover the conversion of the main Bramshill House, the Stable Block and Nuffield Hall into both a single dwelling house (00722) and offices (00724).  Application 7 (16/01290/FUL) covers the provision of 14.4Ha of Suitable Alternative Natural Greenspace (SANG). The officers recommend that these three proposals be granted planning permission, subject to a number of conditions.

Applications 1 (16/00720/FUL), covers converting Bramshill House into 25 dwellings and publically accessible museum space. Application 4 (16/00726/FUL) covers the development of up to 235 dwellings in the grounds of Bramshill House. Application 5 (16/00727/FUL) covers the development of 14 dwellings in a different part of the grounds. Finally Application 6 (16/00728/FUL) is for 9 residential units in an area of the site known as Pinewood.

The officers have asked the Planning Committee for a ‘steer’ on these applications. The applicants have asked that Hart view the development of these additional dwellings as enabling development. This would fund the maintenance of the main Grade I listed building. The Officers have said that applications 1, 4 and 5 are opportunities to recommend the applications for approval, subject to agreeing to total volume of housing. They are not minded to recommend Application 6 for approval.

Analysis

Overall we are opposed to the Netherhouse Copse proposal as this is green field development. We believe there is plenty of brownfield land available to meet our housing needs. We agree in principle that the Bramshill site should be redeveloped. However, we recognise the sensitivity of the site. We would suggest that suitable payments are made for the provision of infrastructure and affordable housing without increasing the number of houses that are built.

We predict fireworks at the Planning Committee, especially after the recent defection of two councillors from the Tories to CCH. The full council meeting on 15 December will be interesting to say the least. As the Kaiser Chiefs might say, “I predict a riot”.

It really is a shame that more councillors and more of the various groups across the district did not get properly behind a brownfield strategy. Plus they did not heed our warnings about the poor management of the Local Plan project. If they had, we might have a brownfield focused Local Plan by now and have a proper defence against the Grove Farm proposals.

Hart Planning Committee Agenda 14 December 2016
Hart Planning Committee Paper about Bramshill House

 

 

Hart Local Plan and planning application update

Hart Local Plan and planning application update

There is a great deal of activity behind the scenes about the Hart Local Plan. The timetable for delivery is becoming clearer and there are updates on a number of planning applications that will shape the future of our district.

Hart Local Plan Timetable

We Heart Hart understands the upcoming timetable for the Hart Local Plan is as follows:

During w/c 28 November: The new Strategic Housing Market Assessment (SHMA) will be sent to councillors.

29 November 2016: Local Plan Steering Group (LPSG) Meeting, where we understand the timetable for the Hart Local Plan will be discussed and drafts of new Planning Policies will be considered.

December 13 2016: A further LPSG meeting will be held to review the draft spatial strategy. This will set out the number of houses we need to build and suggest where they will be built.

December 14 2016: We understand that the planning application for 423 houses at Grove Farm (aka Netherhouse Copse) near Crookham Village to the west of Fleet, will be considered at the Planning Committee. It is possible that some of the applications to redevelop the former Police College at Bramshill House will be considered.

January 26 2017: Draft Local Plan to go to full Council.

Upcoming Planning Applications

The long standing application for around 550 houses to the North East of Hook was finally signed off on 21 November.

The application for 423 houses at Grove Farm (aka Nether House Copse), near Crookham Village will be considered at the Planning Meeting on December 14. More details of this application can be found here and searching for application reference 16/01651/OUT.

It is possible that some of the applications for redevelopment of the former Police College at Bramshill House will be considered. There are a number of applications outstanding on this site that can be found here. The main applications appear to be 16/00726/FUL for 235 units and 16/00721/LBC for 25 units. At least this is a brownfield site, although controversial, being so close to the Thames Valley Heath SPA.

This week, Wates submitted an outline planning permission for 700 dwellings at Pale Lane (also known as Elvetham Chase). More details of this application can be found here and searching for application reference 16/03129/OUT

Conclusions

We don’t yet know how HDC are going to treat these applications, or if they have other ideas for strategic locations for additional housing. Of course, we await an application to redevelop the brownfield site at Pyestock (Hartland Village) and of course Winchfield has been mooted as a site for a new town, but we believe this has failed testing. Other strategic sites that were being considered include Murrell Green (between Hook and Hartley Wintney), Lodge Farm and West of Hook. Of course proposals are also being developed for the so called Rye Common New Village.

It is galling to say the least that we are seeing so many applications on greenfield sites instead of brownfield sites. It is imperative Hart produces the new Hart Local Plan and the new Planning Policies ASAP. This will allow us to regain control over where houses are built in the district.

 

St Edward Homes releases Hartland Village consultation material

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

Brownfield Land at Pyestock, Hartland Village Hart District, Hampshire.

St Edwards Homes (part of Berkeley Homes) have released the materials they used in the recent consultation sessions about the proposed Hartland Village.  You can find them on the downloads below. They include the materials used on exhibition boards and a feedback form.

Suggested feedback on Hartland Village

Our feedback would include:

  • More Emphasis to be placed on cycle paths and footpaths to access Fleet railway station and Fleet town centre
  • Improvements required to the surrounding roads to increase capacity and reduce congestion
  • Additional analysis required to help decide if we need a new secondary school in Hart and if so, allocation of some land on this site to provide it, in addition to the primary school
  • Need more detail on the healthcare facilities to be provided

A correspondent has also been in touch asking that St Edward go for a more modern and inspiring approach to the architecture of the buildings.

More detail about the proposals can be found here. We encourage everyone to download the feedback form and send to St Edward: hartlandvillage@glhearn.com.

Hartland Village Exhibition Boards
Hartland Village Feedback Form

Rushmoor seeks to protect brownfield sites from redevelopment

Brownfield sites to be protected from development by Rushmoor Borough Council

Rushmoor Borough Council is to seek to protect many of its brownfield sites from redevelopment using ‘Permitted Development Rights’. The list of sites they are seeking to protect are listed in the image above.

A paper has been submitted to the Cabinet meeting due to take place on 15 November seeking to make a non-immediate Article 4 direction to withdraw permitted development rights related to the change of use of offices, light-industrial units, and storage or distribution units to residential use within the Strategic Employment Sites and the Locally Important Employment Sites.

Our view

We agree that we should not release all of our employment sites for housing, but equally it seems rather odd to be seeking to protect most of the employment sites in Rushmoor. There are literally dozens of vacant offices and light industrial blocks.

Even though Rushmoor Borough Council have committed to met their  housing need within their own borough, this extended level of protection may mean they will seek to offload future housing needs, beyond the current plan period, on to Hart District.

Rushmoor have not sought to protect the sites below, due to their proximity to the Thames Valley Heath SPA:

Brownfield sites not to be protected from development by Rushmoor Borough Council due to proximity to Thames Valley Heath SPA. We Heart Hart

Here is a set of images showing some of the vacant buildings in Rushmoor that Bravehart found last year:

  • We Heart Hart's Mascot - Bravehart
    We Heart Hart's Mascot - Bravehart

Rushmoor says it won’t ask Hart to build extra houses

Time to celebrate we don't need so many houses

Time to celebrate we don’t need so many houses

We Heart Hart asked a number of questions at Hart Council’s 29 September meeting. We will come to those in a moment, but the most significant news came from the Leader’s announcement that he had received a letter from Rushmoor Borough Council stating that they would no longer be asking Hart to build extra houses for them.

This is good news in that it either shows that the overall housing numbers for the combined area has been reduced or Rushmoor have found extra capacity, or a combination of the two.

The significance for Hart is that there was a threat that Rushmoor may ask us to build an extra 1,800 houses, on top of our already large allocation of 7,534 houses.  We now know that our remaining requirement will not exceed the current number of around 2,350, and this number may in fact go down if the overall housing target in the new Strategic Housing Market Assessment (SHMA) reduces as we believe it should.

The other significant news from the meeting was that the council believes it will have a SANG capacity of 1,500 homes, over and above the SANG required to deliver Hartland Village (Pyestock). This means that there is now sufficient SANG capacity to bring forward more brownfield sites (of which there are plenty), so we shouldn’t need to grant permission to build on any more of our green fields before 2032 at least.

We also learned that Hart Council has no plans to introduce policy measures to restrict the redevelopment of brownfield sites in the district.

However, we share the council’s concern that if the brownfield sites are delivered as office conversions (as opposed to redevelopments), then there may be a shortage of infrastructure funding.

We await the publication of the revised SHMA, the new policies and the draft Local Plan with interest.

Hart outlines new timetable for the Local Plan

Hart District Local Plan delayed again

Hart Council has outlined a new timetable for delivery of the Local Plan after the most recent delays. The new timetable looks quite ambitious:

27 September2016 – There is to be a workshop to go through the draft overarching policies, but not the spatial distribution strategy itself.  The papers for the workshop are due to be published shortly.

17 October 2016 there will be a special meeting of the Local Plan Steering Group,  open to all councillors, to discuss the Spatial Distribution strategy and the final version of the draft Local Plan. It is not yet clear when the documents related to this meeting will be published. [Update: We now expect the spatial strategy to be released on 11 October].

19 October 2016 – Special Cabinet to decide to go to consultation on the draft Local Plan.

20 October 2016 – Special Council to endorse Cabinet decision to go to consultation.

The dates for the Special Cabinet and Council meetings have been added to the official meeting schedule on Hart’s website.

It is not yet clear when the new Strategic Housing Market Assessment will be published, nor is it clear what the process will be if there are disagreements about the draft plan at the LPSG on 17 October.

Frustration at Local Plan delay

frustration-at-local-plan-delay-fleet-nm-7-sept-2016

Fleet News and Mail have covered our story about the further delays in the Hart Local Plan. The full article can be found here.

It is good to see the leader of the council committing to producing a robust plan based on robust evidence.  We look forward to seeing the new Strategic Housing Market Assessment (SHMA) when it is produced.

Hart Local Plan delayed again

Hart District Local Plan delayed again

Hart’s Local Plan has been delayed again. Councillors who were due to go to a Local Plan Steering Group meeting on 30 August have been told that the meeting has been deferred. The reason given is that they cannot decide the ‘spatial strategy’ until the new Strategic Housing Market Assessment (SHMA) has been agreed.

Apparently, Rushmoor are still holding out for Hart to build 1,600 Rushmoor’s allocation. This could be changed by the new SHMA, but the SHMA remains incomplete because they are changing the methodology is being changed and a new piece of work has been commissioned from the consultants, Wessex Economics. Readers may remember we were first promised the new SHMA in February, then May, and subsequently, Rushmoor have indicated the SHMA would be ready in July 2016. But now we don’t have a date for completion.

This is the latest in a long line of delays:

In October, 2013, when the earlier version of the plan was rejected by the planning inspector, the council said:

“Cllr Parker said that while the council operates under the interim strategy, it is working on an updated Local Plan.

“We expect to put this out for consultation early next year, and would look to submit it to an inspector next autumn[2014],” he added.”

In April 2014, the plan was to have a resubmission plan ready for consultation in October 2015.

In February 2015, the plan was to have a resubmission plan ready for Autumn 2015.

In April 2016, the plan was delayed yet again, with the timetable clearly stating that a draft version of the Local Plan would be published in September 2016. No revised date has yet been given for the draft to be published. The timetable they were working to was:

Full Draft Local Plan – September 2016 (Summer 2016, a couple of months slippage) [now slipped again]

Submission Plan – March 2017 (Autumn 2016, at least 3 months slippage)

Submit to Secretary of State – TBA (Winter 2016, unknown slippage)

Examination – TBA (Spring 2017, unknown slippage)

Adoption – TBA (Summer 2017, unknown slippage)

Of course, there is now a significant risk of the Government stepping in and doing the Local Plan for us.

In the light of the loss of the Moulsham Lane appeal, Hart are working hard on a revised set of policies. These will be discussed by councillors at a special meeting on 27 September, but in the meantime, developers will have a field day. because without a Local Plan and without up to date policies, Hart Council is essentially defenceless.

Don’t hold your breath.

 

Hart still not building enough smaller properties to meet local needs

Hart District Completions compared to target by number of bedrooms

Back in May we wrote about how housebuilders were not building enough smaller properties to meet local needs. We have now received the latest data for completions in 2015-16. The chart above shows that although there has been some improvement we are still not building enough 1 and 3-bed properties and are significantly over-building 4+bed properties.

The analysis to support these conclusions is shown below.

First, according to the current Strategic Housing Market Assessment (SHMA), Hart needs to build 7,534 dwellings in the plan period running from 2011-2032. The SHMA is also very clear on the sizes and types of housing that needs to be built, including the number of affordable homes for the young and specialist housing for the elderly.

Hart Surrey Heath and Rushmoor SHMA Figure 9.8

Hart Surrey Heath and Rushmoor SHMA Figure 9.8

Working through the arithmetic, and using Hart’s target of 40% affordable homes, we need to build in total the following number and proportion of properties by number of bedrooms:

Hart District Housing need by number of bedrooms

We can compare these proportions to the dwellings that have been built since 2010-11:

Hart District Completions by number of bedrooms 2010-2016

This shows that we have built around 80% of 1-bed properties that we should have done and around three quarters of the targeted proportion of 3-bed properties. We have built nearly twice as many 4+bed properties compared to the target.

Overall we think this means that Hart needs to get smarter about how it monitors planning permissions so that we get as close as possible to meeting the needs of local people set out in the SHMA, as opposed to simply building houses that will maximise developer profits. However, it does seem clear that more redevelopment of vacant offices on brownfield sites would create more opportunities for more smaller properties to help young people get on the housing ladder.