Hart CEO breaches Government guidance on housing need

Hart CEO muddies the waters on housing need

Hart CEO persists with inflated housing requirement despite breaching Government guidance

In an email to councillors, the joint-CEO of Hart Council has made a desperate attempt to justify the Council’s inflated housing requirement in the Local Plan. This justification breaks Government guidance on when to build more than indicated by the standard method.

This comes after the release of ONS figures showing reduced household growth in Hart. By our calculations, we already have sufficient housing supply to 20141 and beyond without an unnecessary 5,000 house new town at Winchfield/Murrell Green.

In summary, he uses bluster, imaginary new ONS releases, unstarted Government consultations and dodgy logic to try to justify why the housing requirement will go up, when in fact the ONS figures show it is going down.

We are in the ridiculous position of the council arguing that we should keep an inflated housing requirement and build far more than we need to.

Inflated housing requirement breaches Government guidance

This is against Government guidance on when to plan for more housing than the standard method.

When to build more than the standard method

When to build more than the standard method

  1. There is no funding in place to promote growth. No part of Hart is identified by the M3 LEP as a growth area that will attract investment
  2. There are no strategic infrastructure improvements planned. In fact Hart has a massive infrastructure funding deficit. Extra houses will make this worse.
  3. Rushmoor is already planning for far more houses than it needs. The new ONS projections mean Surrey Heath can meet its own needs in full.

So, Hart meets none of the criteria to justify building more than the standard method says.

However, the council is breaking with this guidance and planning to build even more houses in the new town. They are proposing to spend £1.5m of public money to press on with it anyway.

Below we reproduce the email in full, together with our comments in red.

Hart CEO email to councillors

Dear Councillors, last night we received questions about the implications for the local plan and the assessment of Hart’s housing needs following the sharp fall in household projections as reflected in recently published Office of National Statistic (ONS) projections on 20th September 2018.  The household projection data is a key input into the new standard method of assessing housing need, and the new figures have prompted dramatic drops in many councils’ housing need figures when factored into the standard method.

Graham Cockarill pointed out that this was of concern to the Government and that the Government had delayed the use of the new methodology for calculating housing need because the revised projections undermined the Government’s objective to boost significantly the supply of new homes through building 300,000 new homes per annum.

The Government has issued guidance on how to calculate housing need in this period. This says that although the new standard method is not mandatory, any deviation will be closely scrutinised

Planning guidance use of standard method to calculate housing need

Planning guidance use of standard method to calculate housing need

But it has emerged today that the ONS plans to publish a different version of its figures on 3 December.

Yes, but this new version apparently just puts more detail on the figures released on 20 September 2018, by breaking out the household projections by housing type. There is no suggestion that the overall figures will change.

ONS Household type projections December 2018

ONS Household type projections December 2018

The ONS is also planning to publish a set of variant based household projections in which household formation rates for younger adults (those aged 25 to 44 years) are higher.

They may well be, but we can find no evidence of this in the ONS’ schedule of upcoming releases up to 31 December 2019. If this is going to arrive, then it is beyond the timing of the Local Plan examination and thus cannot be considered.

The ONS’s willingness to publish “variant” projections reflects its acknowledgement of concerns about the new approach taken to drawing up the 2016-based figures. Unlike the 2014-based projections, which drew on data from as far back as the 1971 census, the 2016-based figures were compiled with statistics that only go back to 2001. Critics have said that the new projections thus ‘bake in’ the adverse consequences for household formation of housing under-delivery  in this century.

“Experts” have been predicting that the average household size would continue to fall in line with the experience of earlier decades. However,  the 2011 census showed that this trend had come to an end.  Actual behaviour stubbornly refused to comply with expert opinion. The ONS’ own analysis of its new numbers still shows a reduction in average household size out to 2039. However, the rate of reduction in the newer 2016-based figures is slower than the 2014-based projections. We believe that part of this is down to social change – people are getting married later than in the 1960’s and 1970’s. THe increase in house prices may have played a part, but we already know from Ian Mulheirn’s analysis that building more won’t reduce prices. Prices are mostly driven by ultra-low interest rates.

ONS impact of 2016-based projections on household size

ONS impact of 2016-based projections on household size

In its methodology document, the ONS acknowledges those complaints. It says some respondents to its consultation on the new method thought that using data from only the 2001 and 2011 censuses would be “insufficient”. It says that: “There was a view that only using the 2001 and 2011 censuses would result in a downward trend in household formation for the younger age groups, which in turn would downplay the need for housing for younger people”.

OK. So what. It seems the ONS disagrees with this view, or it wouldn’t have continued with the method it has adopted.

The government has already said that it will consult on adjustments to the way housing need is calculated so it is consistent with delivering 300,000 new homes per year by the mid-2020s and that it will do this “as soon as possible”.

The Government may well have said that, but the consultation has not been launched. In effect, the Government has set a ‘top-down’ target of 300,000 houses per annum. Now the detailed bottom-up work has shown this to be far more than we need, it is trying to find a way of fudging the numbers to arrive back at the number it first thought of. It is inconceivable that such a consultation can be launched, completed and the results analysed before the Hart Local Plan is examined. This might be a risk to the housing target we eventually adopt. However, surely the way to mitigate this risk is to demonstrate flexibility of supply, rather than increase the target. We have already shown that Hart has sufficient supply out to 2041 and beyond, without the unnecessary new town.

In effect therefore, the Government is not running with the current 2016 household projections for use with the standard methodology and as Cllr Cockarill highlighted, the Government’s objective is to boost the supply of new homes and wants to put in a methodology that does exactly that.

This is, at best, a disingenuous statement. The current Government guidance says the national household projections should be used. It isn’t clear which version should be used, but surely it makes most sense to use the most up to date figures.

Planning guidance setting the baseline using national household growth projections

Planning guidance setting the baseline using national household growth projections

The worked examples in the Government guidance are a bit ambiguous. We believe that using the new Government standard method is either:

Hart Household change 2018-2028

Hart Household change 2018-2028

a) 212 * (1+0.4) = 297 dwellings per annum using the capped 40% affordability uplift, or worst case

b) 212 *(1+0.5) = 318 dwellings per annum

Hart Housing Numbers

This compares to the 388dpa used in the Local Plan.

I think we can safely read into this that it means that the overall number of homes to be built is likely to go up rather than down.

There is no justification for this statement. There is already at least 70dpa headroom (or over 1,120 houses in the plan period) between the Government standard method and the Hart Local Plan. And even this elevated housing target does not require the proposed new town to be built. In any event, the best mitigtion for this is to demonstrate flexibility in supply

That was exactly why we included a buffer in our housing needs and until we see what they new “variant”  projections look like it is not wise to make any assumptions about not having to meet our neighbour potential unmet housing need.

The new household projections mean that Surrey Heath can meet its own need. Rushmoor is already planning for far more houses than it needs to build.

We now have the ridiculous situation of the council arguing to keep an inflated housing requirement and build more houses than we need so it can somehow justify keeping the unnecessary new town in the Local Plan.

 

Winchfield New Town torpedoed by Government figures

Winchfield New Town torpedoed by new Government figures

Winchfield New Town torpedoed by new Government figures

The Government have published new figures that further undermine Hart’s proposals for the Winchfield New Town in the Hart Local Plan.

The housing requirements for Hart, Rushmoor and Surrey Heath have been significantly reduced. Rushmoor is already planning for far more houses than it needs. Surrey Heath now has more housing supply than it will need to deliver to meet these new targets.

The impact on Hart is that we already have enough housing supply in the Local Plan to meet our needs up to and beyond 2041. This means that the proposed Winchfield New Town is not required at all. We believe it’s time to ditch the new town idea from the Local Plan. Failure to do so might result in the Local Plan being found unsound at examination.

New household projections impact on housing need

The Office for National Statistics has published household projections based upon a 2016 baseline. These new figures update earlier projections based on a 2014 baseline. The projections for Hart are lower than prior estimates and should reduce the number of houses we have to build.

We are concerned the current Lib Dem/CCH coalition won’t take advantage of this opportunity to ditch their ridiculous Winchfield New Town Plan.

The new projections show the number of households in Hart rising from 37,129 in 2016 to 40,347 in 2032. The total rises to 41,744 in 2041. This works out at a rate of 201 dwellings per annum (dpa) from 2016 to 2032 and 185 dpa from 2016 to 2041.

Hart District household changes based on 2016 baseline show no need for Winchfield New Town

Hart District household changes based on 2016 baseline

The new Government methodology for calculating housing need adds an ‘affordability uplift’ to these baseline figures. In Hart’s case, this is the maximum of 40%. Adding this uplift takes our total housing need t0 4,505 upto 2032 and 6,461 up to 2041. The required build rate is 282 dpa in the period 2016-2032 and 258 dpa from 2016-2041.

Comparison to the Hart Local Plan

The Government baseline used in the Local Plan was 292 dpa using the 2014-based figures. Hart has uplifted this requirement up to 388 dpa in their Local Plan, giving a total planned build of 6,208 houses.

Hart Local Plan 2016-2032 justification

Hart Local Plan 2016-2032 housing numbers justification

Their justification of contingency against uplift doesn’t hold water as we only need to build a total of 6,461 up to 2041.

At the time the Local Plan was prepared, they had already conservatively estimated 6,346 of available supply.

Understated housing supply

Since then, they have produced a topic paper as part of the Local Plan examination process that shows housing supply of 6,401. This is just 60 short of what is actually required up to 2041. The outstanding 60 will be more than met by the 72 dwellings expected to be built at Hartland Village in 2033 (see housing trajectory here, p24).

Hart District Housing Supply April 2018 demonstrates no need for Winchfield New Town

Hart District Housing Supply April 2018

Impact on Rushmoor and Surrey Heath

The housing requirements for both Rushmoor and Surrey Heath have come down considerably. There is definitely no need to plan for any overspill from either borough.

Indeed, Rushmoor is already planning for far more houses than they actually need. Surrey Heath’s supply now exceeds their requirement.

One could argue that if future projections were to increase, Rushmoor could easily absorb this.

Impact on Winchfield New Town proposals

To sum up, the Local Plan already proposes to build more houses than we need in the period to 2032. Hart Council chose to add a Winchfield new town on top of that inflated requirement. They intend to deliver even more unnecessary new houses from the mid-2020’s. These new Government figures show we already have more than enough housing supply to meet our actual needs up to and beyond 2041, without a new town.

It simply is not credible to keep the Winchfield New Town in the plan. Time to ditch it.

 

 

 

 

Hart Local Plan Examination Update

Hart Local Plan Examination

Hart Local Plan Examination Update

It looks like quite a lot has been going on in relation to the Hart Local Plan examination. We have updates on:

  • Timing of the Hart Local Plan examination hearings
  • Early stage procedures for the Hart Local Plan examination
  • National Planning Policy Framework (NPPF) applying to the examination
  • Impact on Pale Lane (aka Elvetham Chase) appeal

Timing of the Hart Local Plan Examination hearings

Back in June, Hart Council briefed the Parish Councils about the Hart Local Plan examination. The full briefing can be found on the download below. They set the expectation that the Local Plan examination would start in late September and last 2-3 weeks.

Hart Local Plan Examination Briefing 12 June 2018 - Hearing Sessions

Hart Local Plan Examination Briefing 12 June 2018 – Hearing Sessions

We have been in touch with the Programme Officer, a man called Ian Kemp, who can be contacted here. He tells us that he has:

Provisionally scheduled hearings during the weeks of 19/11 and 3/12.

So, the examination is going to be 2 months later than Hart’s estimate.

Early stage procedures for the Hart Local Plan examination

In the June briefing Hart said that the Planning Inspector would issue a note in mid-July explaining the role of the Programme Officer and the status of any modifications to the Local Plan. This note was also to cover the timetable for submitting additional material and how the hearing sessions would work.

Hart Local Plan Examination Briefing 12 June 2018 - Timetable

Hart Local Plan Examination Briefing 12 June 2018 – Timetable

Ian Kemp tells us that he is:

Required to contact all representors six weeks prior to the start of the Examination to relay the details and arrangements. For the moment, the Inspector is in the early stages of his preparation.

So, it looks like we won’t know more details about how the Examination will be conducted around the beginning of October.

NPPF Framework applying to the Hart Local Plan examination

The revised National Planning Policy Framework has been released recently. Fortunately, it contains clause 214 that says:

Policies in the previous Framework will apply for the purpose of examining plans, where those plans are submitted on or before 24 January 2019.

This means that the Hart Local plan will be examined under the old framework. This might be mixed news. On the plus side, they won’t be examined on policies they didn’t know about when they were preparing the plan. On the negative side, it may well mean that the housing numbers that will apply to the examination will be those in the SHMA (8,022 or 382 dwellings per annum or so over the period 2011-2032), rather than the new figures in the Government consultation.

As a reminder, the Government figures were for 292 dpa, which results in a total of 4,672 over the shorter planning period of 2016-2032. However, Hart decided to increase this to 388dpa over the same period. We suspect the housing numbers will become a big debating point in the examination.

Impact on Pale Lane (Elvetham Chase) Appeal

The Pale Lane (Elvetham Chase) appeal hearing has been scheduled to being on 8 January 2019. This date in contained in a new schedule published on the planning inspectorate website, that can also be found here.

Pale Lane Appeal details APP/N1730/W/18/3204011

Pale Lane Appeal details APP/N1730/W/18/3204011

On the face of it, this looks like good news as it seems most likely to us that the appeal will not be upheld. Assuming the Local Plan is found to be sound in December 2018, and Pale Lane is not on the list of approved sites, then we cannot see how the inspector can uphold the appeal. However, if the Hart Local Plan examination finds the plan unsound, then Pale Lane may go ahead.

 

Hart Local Plan Submission Briefing

Parish Council demolishes Winchfield new town plan

Figure 6 Winchfield New Town Summary of Key Findings

Winchfield new town area not suitable for large scale development

The Parish Council have demolished plans for the proposed Winchfield new town in their submission to the Hart Local Plan Regulation 19 consultation. The have produced a 690-page report that can be found here. Their main conclusions about Policy SS3 that calls for the new town to be built in the area of search are (our emphasis):

Our review of the available technical evidence, with STR005 released only through a FOI request, demonstrates the highly constrained nature of the AoS, and the significant environmental and infrastructure issues that need to be overcome. A Site Appraisal prepared by Michelle Bolger Expert Landscape Consultancy is provided and this demonstrates that the AoS is significantly constrained and concludes that little land exists within the AoS which could be considered suitable for large scale residential development. We flag up the complete failure of the Draft Plan to identify the key infrastructure necessary for the provision of a new settlement, or indicate how it will be provided, by whom and when. Given the complete lack of any detailed evidence demonstrating that a new settlement is either deliverable or viable, we do not see how provision can be made for it within the Draft Plan.

Winchfield New Town Expert Evidence

The expert evidence from Michelle Bolger is a joy to behold. Her much shorter report can be downloaded from the link below, together with the appendix that contains the wonderful graphics depicting all of the constraints on the area of search.

The final summary is shown on the image above. This summarises the findings of the whole report in relation to the various sites that have been put forward, concluding (emphasis mine):

All of the sites are significantly constrained and the vast majority of the area of search (AoS) south of the M3/Railway is considered to be unsuitable for large scale development (i.e. it would cause severe landscape harm that would be difficult to remedy or mitigate)…

Land within the north-western parts of the AoS…are also significantly constrained. Development here could not occur without harm to the local countryside character and this would also impact upon the character and enjoyment of the Public Right of Way network. Development may also result in visual coalescence between Hartley Wintney and Hook.

Overall this appraisal finds that the AoS identifies a landscape that is highly unsuitable for large scale residential development. The new settlement envisaged by draft policy SS3 would result in significant landscape and visual harm and be at risk of harming components within the landscape which hold high landscape, amenity, ecological and heritage value.

The build up to the final conclusion starts with the area of search:

Figure 1 Winchfield New Town Area of Search and Context

Figure 1 Winchfield new town Area of Search and Context

It then goes on to show Hart’s own landscape capacity study which shows that most of the area has low or low/medium capacity. The only area with medium/high capacity is the proposed Elvetham Chase (Pale Lane) site and it’s westward extension towards Winchfield. The Murrell Green area is shown as Medium capacity. However, this was decided before the Major Accident Hazard gas pipeline was discovered by Hart Council.

Figure 2 Winchfield New Town Landscape Capacity Study

Figure 2 Winchfield Landscape Capacity Study

The paper then goes on to identify the constraints in the area of search, starting with areas designated as SSSI’s, SINCs, tree preservation orders, ancient woodland, and listed buildings.

Figure 3 Winchfield New Town Key Constraints Designations

Figure 3 Winchfield New Town Key Constraints Designations

Then other constraints such as visual sensitivity, flooding, footpaths, unavailable land, landfill, narrow bridges, high voltage transmission lines and the gas pipeline are added:

Figure 4 Winchfield New Town Key Constraints Assessment

Figure 4 Winchfield Key Constraints Assessment

Then all of the constraints are brought together on one diagram, showing just how little land exists within the AoS that could be considered suitable for large scale residential development.

Figure 5 Winchfield New Town Key Constraints Composite

Figure 5 Winchfield Key Constraints Composite

 

All of this report is drawn from pre-existing material. One wonders why Hart Council is continuing to promote such a daft idea. Certainly, £50K is not going to cover costs of putting together a robust Winchfield new town master-plan to fulfill all of their magical promises to turn horses into unicorns. We shall see what the inspector makes of this.

The report and appendix can be downloaded here:

Winchfield Site Appraisal
Winchfield Site Appraisal Appendix

 

Winchfield landowners beg for more land in new town

Winchfield landowners beg for more land in new town area of search

Winchfield landowners beg for more land in new town area of search

The responses to the Hart Local Plan Regulation 19 consultation show Winchfield landowners begging for more of their land to be included in the area of search.

First up is Lady Henrietta Wigram begging for more of SHL 124 to be included in the new town:

Lady Henrietta Wigram begs for more land to be included in Winchfield new town area of search

Lady Henrietta Wigram begs for more land to be included in Winchfield new town area of search

Then we have Simon Jones-Parry begging for more of SHL 133 to be included in Winchfield new town. Note the block capitals – shouting just in case we can’t hear him.

Simon Jones-Parry begs for more land tobe included in Winchfield new town area of search

Simon Jones-Parry begs for more land to be included in Winchfield new town area of search

Given the controversy about this proposal, we think it crassly insensitive to include such representations in the consultation.

For context, here is a map of the sites they are bleating about:

Winchfield and Hook New Town proposal

And here is a map of the area of search:

Policy SS3 Murrell Green and Winchfield Area of search for Hartley WInchook new settlement

It seems Lady Wigram wants to include land north of the M3 to effectively join the existing St Mary’s Park to the proposed new town. Although, quite how they propose to sell houses so close to the motorway is beyond our understanding.

Mr Jones-Parry wants to extend the existing proposal covering part of SHL 133 to include land between the Basingstoke Canal SSSI and Odiham Common SSSI. This area was ruled out for development in the Sustainability Appraisal.

Brass neck doesn’t quite cover it.

Hart Council budgets only £50K for Winchfield new town plan

Hart District Council sets aside laughable budget for Winchfield new town plan

Hart District Council budgets only £50K for Winchfield new town plan

Questions put to Hart Council earlier this week have revealed they have set aside a budget of only £50,000 to create the detailed development plan for the Winchfield new town. Apparently, they are hoping for additional contributions from developers.

This is quite astonishing. There have been numerous statements made by councillors saying they want the plan to be council lead and not developer led. They’ve also made statements about the amount of infrastructure that will be delivered.

We suggest that the council has set aside barely a tenth of the money that will be required to:

  • Conduct sustainability assessments
  • Infrastructure studies
  • Habitat assessments
  • Flood assessments
  • Master-planning

This revelation shows the councillors were either lying through their teeth or were completely incompetent (or both). They are clearly going to rely on funding from developers so the developers are going to be in the driving seat.

Of course another interpretation of this pitiful budget is that they are anticipating the Winchfield new town being knocked out of the Hart Local Plan at examination.

In other news, it is now expected that the Hart Local Plan examination will start in mid-November and last 2-3 weeks.

The questions and contemporaneous account of the questions and answers are shown below:

Questions about Winchfield New Town

Q1: I understand the Local Plan has been submitted and Council “commits to planning for a new settlement at Murrel Green/Winchfield” to “provide a substantial contingency to any increase in the Government figures that could, in theory, result in an unmet need arising elsewhere in the HMA” (para 108).

Accepting that the requirement for the contingency for houses needed in Hart in excess of Government guidelines may or may not materialise, as evidenced by future plan revisions, could Council reassure Hart residents that, in the event it does not, planning permission will not be given for the new settlement?

Answer:  No.  The Government is keen to have houses in addition to the basic suggested figure and there is therefore a need to boost the numbers [But not apparently on brownfield sites!!]

Supplementary:

If, as the draft local plan suggests, all Hart’s housing needs are already provided for in the current plan period to 2032 without the need for a new settlement, should not the start of any construction of the new settlement be deferred until after 2032 at the earliest?

Answer:  No.  The lead time for a new settlement is long and the future requirement for housing uncertain – the start of building can’t be left to the last minute.

Q2. The Council committing to planning for a new settlement means Hart residents will be required to fund a substantial sum for the necessary consultants’ reports etc.  Can the Council please say 1)  How much is budgeted for this and 2) how much of this will be provided by the parties who will benefit financially from the building of the new settlement?

Answer:  £50,000 is the sum that has been initially set aside in the budget.  Contributions from developers will be welcome  [This number is laughable – a proper DPD will surely run into £000,000s]

Supplementary: The area of search for the new settlement includes Murrell Green (possible 2,990 houses) and Winchfield (possible 2,400 houses).  The proposals come from separate developers.  Is the intention to pursue one or the other development, or rather to combine the two?

Answer:  It was not possible to chose between the two originally.  Hence the “area of search” idea.  The DPD will determine the answer to the question. [Despite 3 years of testing!!]

Q3: The draft plan gives no indication of the size of the proposed new settlement, other than to say it must be “viable”.  What approximate size is considered viable, recognising that this will be further examined in the DPD

Answer:  The DPD will determine

Supplementary: I am not aware of any consultation with Winchfield residents about the possible shape, size and layout of the proposed new settlement, although Members were shown a four-page artist’s illustration dated August 2017 which I found in the Local Plan examination library.  When and how will the Winchfield community be consulted if the new settlement idea survives inspection

Answer:  There will be plenty of opportunity through the DPD and the usual consultation process which has already been followed.

Q4. What is the current status and expected number of Surrey Heath’s unmet housing need and what proportion of this unmet need would Hart be expected to meet?

Answer:  Currently not known, SH haven’t yet come up with numbers