Hart SANG plan to obstruct brownfield development

James Radley of CCH pulling the string of Graham Cockarill in Hart SANG plan to obstruct brownfield development

CCH calling the shots on Hart SANG plan to obstruct brownfield development

Hart Council has published a new report recommending that its own SANG land should not be used to enable brownfield development. This effectively renders the council’s SANG useless and calls into question the council’s ability to fund the repayments on the loan it has taken out to buy the SANG.

The document is sponsored by Community Campaign Hart (CCH) Deputy Leader, James Radley and not the portfolio holder for Planning, Lib Dem Graham Cockarill. This indicates that CCH is pulling the strings on important planning matters. The Hart SANG plan will be discussed at Cabinet tomorrow.

Hart SANG plan

Hart has bought its own SANG land at Bramshot Farm which lies between Ancells Farm and the link road between Hartland Village and the M3. The site has capacity to support 1,745 new houses. The new report proposes that no SANG land is allocated to the sites set out below unless signed off by both the Services Portfolio Holder (James Radley) and the chair of the Planning Committee (Graham Cockarill).

Brownfield sites affected

The following brownfield sites will effectively be blocked from development by the Hart SANG plan:

  • Bartley Wood, Hook, RG27, 9UP
  • Bartley Point, Hook, RG27 9EX
  • Cody Park, Farnborough, GU14 0LX
  • Meadows Business Park, Blackwater, GU17 9AB
  • Osborne Way, Hook, RG27 9HY
  • Waterfront Business Park, Fleet, GU51 3OT
  • Ancells Business Park, Fleet, GU51 2UJ (right next door to Bramshot Farm)
  • Blackbushe Business Park, GU46 6GA
  • Eversley Haulage Yard, RG27 0PZ
  • Eversley Storage, RG27 0PY
  • Finn’s Business Park, Crondall, GU10 5HP
  • Fleet Business Park, Church Crookham, GU52 8BF
  • Grove Farm Barn, Crookham Village, GU51 5RX
  • Lodge Farm, North Warnborough, RG29 1HA
  • Murrell Green Business Park, RG27 9GR
  • Potters Industrial Park, Church Crookham, GU52 6EU
  • Rawlings Depot, Hook, RG27 9HU
  • Redfields Business Park, Church Crookham, GU52 0RD
  • Optrex Business Park, Rotherwick, RG27 9AY

Essentially, development on every significant potential brownfield site other than Hartland Park and Sun Park (which already have SANG earmarked), will be hindered by this new proposal.

This new proposal runs contrary to the Vision outlined in the draft Local Plan which says:

The priority will have been given to the effective use of previously developed land (‘brownfield land’) so that ‘greenfield’ development will have been limited,

It also runs contrary to paras 105 and 107:

Our preference is still to deliver as much of our New Homes Left to Plan as possible on previously developed land.

many new homes will be built on brownfield sites (where possible and if they are viable)

Their new approach also goes against policy MG2 that says:

Policy MG2: Previously Developed Land

The Council will encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value.

Of course, this plan also goes against stated Government policy to encourage brownfield development. See here and here.

Financial impact of Hart SANG plan

However, all the large, controversial green field developments are being proposed with their own SANG. This includes Murrell Green, Winchfield, Pale Lane (Elvetham Chase), Rye Common and Grove Farm (Netherhouse Copse). Most of these sites are probably outside the 5km catchment area of this SANG anyway or closer to Crookham Park SANG. Of course, the new Government consultation has reduced Hart’s housing target by ~4,000 houses compared to the draft Local Plan. If this new target (plus a few extra to help out Surrey Heath) was adopted, our remaining housing target could be more than met by Sun Park and Hartland Park alone.

So, if the main brownfield sites are excluded from using the council SANG, the other brownfield sites have their own SANG and the major greenfield sites are not needed, or have their own SANG,  we have to ask what it will be used for.

Apparently, the council is about to sign an agreement with Rushmoor to use the SANG to support the delivery of approximately 1,500 new homes in Rushmoor. However, the latest Government housing target consultation has reduced Rushmoor’s allocation by ~3,000 dwellings and Surrey Heath’s by 630 houses. This calls into question whether Rushmoor will need this SANG at all.

The council is strapped for cash, and has borrowed £5.3m to fund the purchase of this SANG. It must payback this loan in instalments up to 2023/24:

Financial implications of Hart SANG plan

These new developments call into question the immediate demand for this SANG, and of course, Hart’s ability to repay the loan.

Conclusion

It is a scandal that Hart is using its powers to obstruct brownfield development. The major greenfield developments come with their own SANG, and probably aren’t required anyway. Rushmoor and Surrey Heath’s housing targets will probably be reduced. This calls into question the financial sustainability of the council’s purchase of this SANG land.

image

Hart keeps 10,185 housing target

Hart keeps 10,185 housing target

Hart keeps 10,185 housing target

At Thursday’s council meeting it became clear that Hart Council is keeping the 10,185 housing target for now. We asked a number of questions (see below) about the new Government consultation which reduces Hart’s housing target to 292 dwellings per annum, compared to the 485 dpa  in the draft Local Plan.

The basic answer from the council was that so far, this is just a consultation, so they are sticking with the ridiculous housing target. However, they didn’t give any indication that they were going to consider the lower target even as an option. We think this is a dereliction of duty.

Impact of new housing need methodology on Hart Local Plan

Impact of new methodology on Hart Local Plan

We are disappointed that this approach keeps our sensitive large green field sites at risk of inappropriate development. Sites remaining at risk include Murrell Green, Winchfield, Rye Common and Pale Lane (Elvetham Chase).

Local Plan Update

There is still no sign of the 1,200 responses to the Local Plan consultation being published. We were led to believe at Cabinet these would be shown to councillors at last week’s LPSG and published shortly afterwards. It is now nearly four months since the consultation completed, so there can be no excuses.

Hart News Local Plan update

Hart News Local Plan update

 

 

Questions to HDC 28 September 2017 about Hart Housing Target

Q1: Recently the Government launched a consultation on a new method for calculating housing need. If this new approach was adopted Hart’s target building rate would fall to 292 dwellings per annum, compared to 382 in the SHMA and 485 in the draft Local Plan. How does HDC plan to respond to this consultation?

Supplementary: Will you make the consultation response public, and if so, when?

Q2: The same consultation (Table 1 and Para 54) indicates that councils with no Local Plan should start to use the new methodology immediately. What steps have the Council taken, and what steps will you take to adopt this new method and when?

Q3: Both Rushmoor and Surrey Heath have also seen their housing targets reduced by the new methodology by 142 and 30 dpa respectively. Rushmoor have already said they will accommodate their original, higher figure. Will Hart still need to consider building additional houses for Surrey Heath?

Significant reduction in Hart Housing need

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

Q4: The consultation says (Para 46) that Inspector should work on the assumption that the approach to calculating housing need is sound, if the plan calls for more houses than the standard method would provide. What does HDC now consider to be the most appropriate housing target to plan for in the Local Plan?

New Government housing methodology - impact on planning inspectors

New Government housing methodology – impact on planning inspectors

Supplementary: The total of the Government housing targets for each planning authority amounts to ~266,000 dpa, in line with national needs identified in ONS figures. In the draft Local Plan, Hart is planning for more than twice the demographic requirement in the local ONS numbers. If this was repeated across the country, it would result in over 500,000 dpa, so what justification is there for keeping Hart’s planning target at 485 dpa, given that the new 292 dpa target already includes an affordable housing uplift to the base demographic requirement?

New Government methodology to reduce Hart housing need

Time to celebrate reduction in Hart housing need

New Government methodology reduces Hart housing need

Yesterday, the Government published a consultation (Planning for the Right Homes in the Right Places) on its proposals to simplify and standardise the calculation of housing need. The good news is that Sajid Javid’s new  methodology, if adopted, will result in a significant reduction in Hart housing need. There are also reductions for Rushmoor and Surrey Heath.

Significant reduction in Hart Housing need

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

Impact on Hart Housing Need

If this proposal was adopted, the full housing requirement for Hart would fall to 6,132 new dwellings. This compares to the Hart’s current Local Plan total of some 10,185 and the total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022. The new target of 6,132 is above the 5,144 we recommended in the recent Local Plan consultation. But, clearly, if the new figure of 6,132 was adopted, we would welcome it.

The Government now calculates housing need on the basis of the most up to date demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings.

This vindicates the stance we have been taking for years now: Hart’s housing target is ridiculous. The current SHMA takes out of date demographic projections and makes lots of spurious and arbitrary adjustments that don’t address the needs of the district. Then Hart Council added a further 2,000 houses to that. This new approach proposed by the Government is much more sensible.

Impact on Rushmoor and Surrey Heath

This is also good news for Rushmoor and Surrey Heath. Rushmoor’s overall housing target reduces by 2,982 houses. Rushmoor has already said it can meet it’s current target, so this leaves it with significant extra capacity.

Surrey Heath’s target reduces by 630 houses. Surrey Heath has said it will endeavour to meet its current housing target, but if it can’t, then Hart and Rushmoor would be expected to make up any shortfall. Previous estimates of their shortfall were around 1,400 houses. These new proposals make any problems Surrey Heath has much easier to solve.

Taken together, these reductions are very welcome and reduce the risk that Hart will be forced to take any overspill from Surrey Heath.

Impact on the Hart Local Plan

There is further good news. If the current Local Plan is more than five years old or if the new Local Plan is not submitted by 31 March 2018, then the new methodology must be used. This means that Hart should start considering this new methodology immediately.

Impact of new housing need methodology on Hart Local Plan

Impact of new methodology on Hart Local Plan

If the new methodology was adopted, then the Hart housing need drops and Hart would need to build far fewer houses. According to the recent Local Plan consultation, a total of 5,594 houses have already been built or planned for as of January 31 2017. This would 600-700 houses left to plan for, maybe a few more to give scope for taking Surrey Heath over spill. In round numbers, let’s assume 1,000 houses left to plan for. Planning for a few more houses than those demanded by the standard method would mean that the Inspector would have to work on the assumption that the Plan was sound.

New Government housing methodology - impact on planning inspectors

New Government housing methodology – impact on planning inspectors

This could be easily made up from brownfield sites in the draft Local Plan. Sun Park (320) and Hartland Park (1,500) would more than meet the remaining need, with plenty of room to spare. This would mean Hartland Park could be built at a slower rate.

The implication of this is that we would need no new settlement. No building at Murrell Green, no new settlement at Winchfield or at Rye Common. Furthermore, Pale Lane (Elevetham Chase) and Cross Farm wouldn’t be required. It remains to be seen whether the inspector will take account of this new methodology to save Netherhouse Copse (Grove Farm) in the current ongoing appeal.

Impact on Neighbourhood plans

In a further piece of good news, the Government proposes that the way housing need in Neighbourhood plans is calculated should be simplified. It says that it should be based on the proportionate population of the Neighbourhood planning area.

New Government housing methodology - Neighbourhood plans

New Government housing methodology – Neighbourhood plans

This is essentially the same proportionate method that we have been advocating for some time. It will finally mean that David Cameron’s promise that local areas should not simply have new housing estates dumped upon them will be met. This proposal will also effectively mean that existing urban areas should become more dense. This is another policy we advocated in the recent consultation.

Note of caution

So far, this is just a consultation and is not yet adopted. There is therefore a risk that developers will seek to water down the proposals or amend them. We have done a quick analysis of the Government spreadsheet and that shows that roughly half of Local Authorities have had their targets increased and roughly half have seen a reduction. Overall, the housing need identified by the Government is about 266,000 houses per annum, in line with previous estimates of overall national requirements. So, in our view, developers don’t have much of an argument – the proposals seem to redistribute the housing targets where they are most needed.

Moreover, there are some potential pitfalls in planning for certain groups such as the elderly and affordable housing in paras 89 & 90. However, this is really about how to get the total to add up, rather than changing the total.

Conclusion

Overall, we think that if these proposals are adopted it is very good news for Hart, Rushmoor and Surrey Heath. The new Hart housing need would be very achievable and would save many of our precious green fields that are under threat.

We would urge you to respond to the Government’s consultation and give it your support.

We also expect the council to set to work immediately to revise the draft Local Plan to take account of these new developments. This should be easy. They are already planning for far more houses than we need, so striking out the controversial green field developments should be a relatively simple task.

 

 

 

 

Hart edges towards Murrell Green development

Murrell Green near Hook and Hartley Wintney Framework Plan.

Hart edges towards Murrell Green development

Last week’s Cabinet meeting led us to believe Hart is edging towards favouring the Murrell Green development as a new settlement option. Minutes here.

The meeting received the note of the meeting (as reported on here) that took place in August to discuss the new settlement options. These were Murrell Green, Winchfield and Rye Common. The backers of Rye Common did not leave any materials that could be published. This indicates that this proposal is not well developed and so it very unlikely to be adopted. We heard a couple of anecdotes that the Winchfield presentation did not go well. This leaves the Murrell Green development as the remaining option for a new settlement.

It was clear the councillors did not want to talk about the content of the presentations. Instead, they focused on process matters, satisfying themselves that the presentations and the note of the meeting covered all of the points raised in the meeting.

James Turner of Lightwood Strategic who are the backers of Murrell Green was at the Cabinet Meeting. He explained they have a plan to deal with the gas main issue. They plan to run a stronger gas pipe, encased in concrete along the route of the spine road. They think this will cost around £2m, and the developer will fund it.

Alternatives to Murrell Green Development

We did put to the Cabinet that the only reason they ‘need’ a new settlement is because they are pursuing the ridiculous 10,000+ housing target. Even the 8,000 figure in the Strategic Housing Market Assessment is too high. We are not confident that the council will reduce the housing target to a more sensible figure.

The results of the recent Local Plan consultation will not be published until later this month.

We do hope they take on board our representations to:

We can live in hope.

 

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.

 

CPRE slams Hart Local Plan

CPRE Murrell Green has slammed the draft Hart Local Plan

CPRE slams Hart Local Plan

The local CPRE has slammed the draft Hart Local Plan, saying it is incoherent and lacks regard for the countryside.

They say:

CPRE’s District Group for North East Hampshire are concerned that the Local Plan has no coherent strategy but is instead a series of tactics to deliver a housing and development supply without any recognition of the role of countryside and the value of the natural environment.

The rural areas seem to have been completely missed in that there is no recognition of the role or function of the countryside and rural communities in this part of the county. Hart’s Vision ignores landscape value, the value of historic or heritage assets, as well as the social and health value the countryside provides for recreation.

Employment site assessment and policies appear to be ill-considered, especially in the rural areas. There are no criteria to support the policies and this results in some sites that employ few people being designated as important for jobs yet other vibrant employment sites in the villages are allocated for housing. This is in direct conflict with the Plan’s aim to protect employment sites particularly in the rural areas.

Murrell Green, which lies close to Hartley Wintney, Winchfield and Hook, is a potential greenfield settlement for 1,800 houses and a secondary school. The site contains endangered woodland, ancient lanes and hedgerows, and lakes and ponds. The proposals show no regard for these natural features and there are concerns about water supply for the high level of proposed housing

We agree with the CPRE, and many of their ideas are incorporated in our suggested response to the draft Local Plan consultation. 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.

FOI request reveals Winchfield failed testing

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

Flood risk means Winchfield failed testing

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

In summary, the main issues were impact on:

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

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

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

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

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

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

This is our chance to shape the draft Local Plan that is currently our for consultation. Our suggested comments can be found on the link below. Please do download and review them. Please do make amendments into your own words and submit it to planningpolicy@hart.gov.uk before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation

Detail of how Winchfield failed testing

Winchfield SHLAA Sites in Hart District Hampshire

Winchfield SHLAA Sites in Hart District Hampshire

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

Winchfield Strategic Assessment - Flood Risk 1

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

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

Winchfield Strategic Assessment - Flood Risk 2

Winchfield Strategic Assessment - Flood Risk 3

Winchfield Strategic Assessment - Flood Risk 4

Winchfield fails testing – Strategic Assessment

Motion of No Confidence in Hart District Council submitted

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

Motion of No Confidence submitted in Hart District Council

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

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

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

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

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

We predict a stormy council meeting on 25 May.

[Update  – Statement from Conservative Council Leader]

Conservative Council Leader Stephen Parker commented:

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

[/Update]

[Update 2 – statement from CCH]

Statement about motion to bring about a vote for Council Leader

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

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

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

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

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

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

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

[/Update 2]

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

NE Hants Lib Dems statement about Winchfield

[/Update 3]