Hart Council missing out key information about housing options

Hart District Council Offices

Hart District Council issuing misleading information about housing options

Hart Council has just published its new Housing Options paper in relation to the Local Plan, in preparation for running a consultation from November 23 2015 to January 15 2016. We believe the information contained in that paper is misleading for a number of reasons and have some suggestions on how you might respond to the consultation.  In summary the issues are:

  1. The SHMA is currently being revised and likely to reduce the housing need, so why are we being consulted on a housing requirement that is no longer valid?
  2. The SHMA has been challenged by an independent expert who says we don’t need so many houses.
  3. Hart’s estimate of brownfield capacity is way too low, and far lower than they said as recently as October 1 2015.
  4. Government rules have been changed to encourage more brownfield development and this paper makes no mention of this.
  5. The infrastructure costs of a new town are enormous, but the paper doesn’t clearly set out the economic consequences of the choices we make on housing options.

Housing allocation out of date

The housing need assessment is based on the current version of the Strategic Housing Market Assessment (SHMA), and they do not mention in the paper that the SHMA is currently being revised to take account of new Government population and household projections.  These new projections show a big reduction in forecast population from 322K used in the SHMA to 289K for the whole housing market area and a reduction of 1,602 in Hart household projections.  It seems reasonable to assume that Hart’s housing allocation will therefore fall, but this is not mentioned at all in the consultation paper.

SHMA is invalid

The Housing Options paper does not take account of the opinion of independent expert, Alan Wenban-Smith that the SHMA says we are being asked to build too many houses.  This means that the paper is asking us to consider how we might build houses that aren’t needed and is therefore invalid.

Estimate of brownfield capacity is too low

Back in November 2014, Hart Council said we had capacity for 750 dwellings on brownfield sites. Very few or none of those sites have been granted permission since then. At cabinet on October 1 2015, the joint-CEO of Hart Council said that he thought the brownfield capacity had increased to around 1,800 units. We said at the time we thought this was a low estimate and it could be in the range of 2,400-3,688. However, the new paper says that brownfield capacity is now only 400 units.  The paper pours cold water on the notion that the former police college at Bramshill can be re-developed, but who in their right mind would want to see a Grade 1 listed building start to decay, and who would want to preserve the hideous 1970’s accommodation blocks?  This is clearly a site ripe for redevelopment, and the environmental impacts should be low compared to the prior use of the site.  So, the question remains, what has happened to the other 1,400+ units and why aren’t Hart taking account of them?

Government has made brownfield development more attractive

The Government has also just relaxed the rules about building on brownfield sites to make it more attractive.  This makes it more likely that the brownfield capacity identified in the Stonegate report can be delivered.  The Hart paper fails to mention this. The paper also fails to mention that Hart has kicked off a process to identify even more brownfield sites across the district, but the results of that study won’t be known for some time.  It does seem odd to be so definitive about the so-called lack of brownfield capacity when there are so many positive developments underway.

Astronomical Infrastructure Costs

Hart have published some analysis to show the infrastructure requirements of a new settlement.  They haven’t been definitive about how much this would cost, but it would include a new motorway junction, significant changes to existing roads and bridges, a new sewage works, 4 new schools and a new railway station.  Our estimate of the cost of this infrastructure is £300m+.  A realistic expectation of the developer contribution for 4,000-5,000 houses would be £40-50m.  Hart already have an infrastructure funding deficit of £78m.  It is clear that we cannot afford the infrastructure costs of a new town, and that existing settlements would be starved of investment if it went ahead. The new housing options paper makes very little reference to the economics of development for any of the approaches it identifies.  Surely, we should know about the economic consequences of the housing options choices we make?

It is becoming increasingly clear that the housing options paper and the associated consultation is a pig-in-a-poke, but nevertheless as it is there we must respond to it.  It looks increasingly like a faction of the council is hellbent on concreting over large swathes of our countryside, despite all the evidence that we don’t need to.

We urge you to Vote against Approach 3 (a new settlement at Winchfield).  But when asked for any other comments, use this article to ask them to think again about brownfield. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Housing targets systematically over-stating housing need

Is this what we want Hart to turn into?

Is this what we want our countryside to turn into?

A review of a sample of Strategic Housing Market Assessments (SHMAs) across the south of England has indicated that on average, local planning authorities are being asked to plan for 41.9% more houses than the needs identified by DCLG population projections. The consequence of this is it is likely that far more green field land is being allocated for housing than is necessary to meet our housing need.

Regular readers will know that for some time we have been concerned about the overall level of housing Hart District is being asked to deliver.  To this end,  we have been analysing our Strategic Housing Market Assessment (SHMA), and together with Winchfield Action Group (WAG), we have commissioned an independent look at Hart’s SHMA.

However, we have also been inspired by the work of Alan Wenban-Smith criticising the Vale of the White Horse SHMA. This has led us to take a look at a number of SHMAs around the area, comparing the starting point of the official Government population and household forecasts to the end point of the recommended housing need after taking into account a number of additional elements like additional inward migration to the area, affordable housing, changes in average household size and jobs forecasts.

The findings are quite alarming and lead to a number of conclusions, some of which should be relevant for national planning policy.

We have looked at 6 SHMAs covering large areas of Hampshire, Berkshire, Surrey and Oxfordshire.  Overall the total “starting point need” for these areas is 272,200 houses, and the end point “need” is 386,286 houses, or an uplift of 41.9%.  This is shown in the table below:

 

SHMA AreaLoca Authorites coveredAuthorStarting year yearEnd point yearStarting point "need"Ending point "Need"% Uplift over starting pointNotes
HRSHHart, Rushmoor Surrey HeathWessex Economics20112031158002360049.4Starting point is 2011 DCLG and SNPP projections
South HampshirePortsmouth, Fareham, Gosport, Chichester, Bognor Regis, Southampton (West Centre), Southampton (East), Winchester, Eastleigh, Lymington, Totton, HavantGL Hearn201120368710513161151.1Starting point is 2011 DCLG and SNPP projections
East HampshireEast HampshireNathaniel Lichfield & Partners201120288105960518.5Start point 2010 SNPP
WaverleyWaverleyGL Hearn201120317670940022.6Start point 2011 SNPP and CLG projections
BerkshireBracknell Forest, Reading, West Berks, Wokingham, Slough, South Bucks, RBWMGL Hearn201320369577211201017.02012-based SNPP
OxfordshireCherwell, Oxford, South Oxon, Vale of White Horse, West OxonGL Hearn201120315774810006073.32011-based projections
Total27220038628641.9

 

The DCLG population and household forecasts “are statistically robust and are based on nationally consistent assumptions“, so the net effect of adjustments across all SHMAs should be close to zero.  If this sample is indicative of what is going on across the country, then councils will be planning for far more houses than we need and as a consequence will be allocating for development far more green field land than is necessary to meet our housing requirements, with disastrous consequences for our countryside. Current housing delivery is around 150K per annum, and the DCLG figures suggest an underlying need of 220K per annum. If my analysis of this sample is indicative of what is going on across the whole country, councils will end up planning for about 312K houses which would be a big waste of national resources.

We would like to see this analysis repeated on a national basis.  However, an FOI request to the DCLG has not been successful because they don’t collate this data at a national level.  For a Government that wants to focus on brownfield development, this looks to us to be a reckless omission.

The SHMAs on which this analysis is based are:

Hart, Rushmoor and Surrey Heath, here.

South Hampshire, including Portsmouth, Fareham, Gosport, Southampton, Eastleigh and Havant, here.

East Hampshire, here.

Waverley, here.

Berkshire, here.

Oxfordshire, here.

 

 

Housing allocation for Hart, Rushmoor and Surrey Heath should reduce by 6,560 according to new DCLG figures

Department for Communities and Local Government (DCLG)

Department for Communities and Local Government (DCLG)

The housing allocation for the combined Housing Market Area (HMA) of Hart, Rushmoor and Surrey Heath should be reduced by by 27.7% or 6,560 houses, taking away the risk that Rushmoor and Surrey Heath will ask Hart to build 3,000 houses for them and ensuring Hart’s own requirement can be built on brownfield sites only according to new population projections that have been released by the DCLG.

Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

Figure 1: Hart Rushmoor and Surrey Heath SHMA Appendix F

The SHMA worked by taking as a starting point earlier Government figures that showed the combined population of the HMA would be 307K (PROJ 2 circled in Figure 1 above) and this was inflated by increasing the assumptions on inward migration, average household size and jobs growth to arrive at a final figure of 322K (PROJ 5 circled in Figure 1 above).

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 1

Figure 2: Hart Rushmoor and Surrey Heath SHMA Appendix G

Interestingly, revised population forecasts were published by the Government as the SHMA was being finalised that showed that the start point population forecast should be reduced to 295K (circled in Figure 2 above), but amazingly these changes were not used to reduce the assessed housing need.  If they had been used, the total amount of housing that would be required for the HMA would have reduced by 208 per annum (see Figure 3 below), or a total of 4,160 dwellings out of a total objectively assessed housing need (OAHN) of 23,600.

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 2

Figure 3: Hart Rushmoor and Surrey Heath SHMA Appendix G

Now the latest DCLG figures (Table 426) have reduced the population forecast for 2031 for the whole HMA down to only 289K, a reduction of 6,000 people, which equates to a reduction of a further ~2,400 houses (@2.5 people per property).

Taken together these reductions in population forecasts would reduce the whole housing need for the HMA by 6,560 houses of the 23,600 or a reduction of a stunning 27.7%.

We wonder when Hart Council, Rushmoor and Surrey Heath councils will take these new figures into account in the Local Plan.

 

Petition response: Reduce the housing allocation

Discontinuity between ABI and BRES jobs data for Housing Market Area

Discontinuity between ABI and BRES jobs data for Housing Market Area

As we posted earlier, we have submitted the We  Hart petition with 2,130 responses to Hart District Council and the council have set out the process by which they will consider the petition.

We have drafted some suggestions as to how the council should respond  and sent them to Council leader, Stephen Parker.  We have a chance to put these ideas to Cabinet on 1 October at 7pm.  Please tell us if you are coming along to give us your support and please e-mail your councillors to ask them to support these proposals and incorporate them into the forthcoming consultation about the Local Plan.

The full set of suggestions can be found here.

The first suggestions relate to challenging the overall housing numbers Hart have to build.

First, challenge the SHMA to reduce the overall housing allocation for the whole HMA.  There is a strong risk that Hart will be asked to build the highest number of houses in the Housing Market Area if we don’t challenge the numbers.

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

If this is successful, then it will have a two-fold effect of reducing Hart’s own need and also reduce the risk of overflow from Surrey Heath and Rushmoor.  We believe the key arguments are around inward migration assumptions; average household size and in particular jobs growth assumptions which are at a rate nearly double what was achieved over the economic cycle from 1998-2012 and will result in unprecedented levels of participation in the labour market (rising from around 70% to around 86%) for those of employment age.

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

We gave more detail on these arguments at both the Hop Garden Road appeal and in my response to the Rushmoor Local Plan.  More detail can be found here. However, we do recognise it is difficult for the council to challenge its own document and await Rushmoor’s response to my strong challenge, but we do understand that the SHMA may be re-visited and it would be helpful if the council would commit to challenging the assumptions set out above as part of that process.

Second, in conversation with a number of professionals in the planning sector, we have been told a number of times, that it is uncommon for councils to explore fully their “policy on” options with regard to environmental and other constraints.  One of the main attractions of Hart as a district is its rural environment with associated SPA, SSSI’s, SINCs, green space and wildlife.  May we suggest that a proper environmental study is carried out to set out the value of Hart’s environment and ecology to build an argument for not meeting the full requirement of the SHMA?  We know that WAG is working on some proposals in this area with some of the rural parishes and would be keen to discuss the matter with you and offer to share the costs of preparation. 

How Hart Council should respond to the We Heart Hart petition

Vacant brownfield Block at Ancells Farm, Fleet, Hart District, Hampshire

Vacant Office at Ancells Farm, Fleet, Hampshire

As we posted earlier, we have submitted the We  Hart petition to Hart District Council and the council have set out the process by which they will consider the petition.

We have drafted some suggestions as to how the council should respond  and sent them to Council leader, Stephen Parker and they are shown below.  We have a chance to put these ideas to Cabinet on 1 October at 7pm.  Please tell us if you are coming along to give us your support.

Please e-mail your councillors to ask them to support these proposals.

 

Dear Stephen,

Thank you very much for your email.

As you know the petition is from 2,130 signatories, nearly four times the number that responded to Hart Council’s consultation last year and more than ten times the number of people who expressed a first preference for a new town and is therefore a very significant expression of local opinion.

I welcome your approach to treat the petition seriously.  My understanding is that a petition of over 1,000 signatories would trigger an automatic debate at full council.  However, I do believe a debate at Cabinet is more likely to be more productive, so I support the approach you suggest.

As you might expect, I have my own suggestions as to what the appropriate responses to the petition should be and I set them out below for your consideration, interwoven with the petition objectives:

  1. To reduce the overall housing allocation for Hart District

 I think there are two broad approaches to this.  First, challenge the SHMA to reduce the overall housing allocation for the whole HMA.  If this is successful, then it will have a two-fold effect of reducing Hart’s own need and also reducing the risk of overflow from Surrey Heath and Rushmoor.  I believe the key arguments are around inward migration assumptions; average household size and in particular jobs growth assumptions which are at a rate nearly double what was achieved over the economic cycle from 1998-2012 and will result in unprecedented levels of participation in the labour market (rising from around 70% to around 86%) for those of employment age.  I gave more detail on these arguments at both the Hop Garden Road appeal and in my response to the Rushmoor Local Plan.  More detail can be found here. However, I do recognise it is difficult for the council to challenge its own document and I await Rushmoor’s response to my strong challenge, but I do understand that the SHMA may be re-visited and it would be helpful if the council would commit to challenging the assumptions set out above as part of that process.

Second, in conversation with a number of professionals in the planning sector, I have been told a number of times, that it is uncommon for councils to explore fully their “policy on” options with regard to environmental and other constraints.  One of the main attractions of Hart as a district is its rural environment with associated SPA, SSSI’s, SINCs, green space and wildlife.  May I suggest that a proper environmental study is carried out to set out the value of Hart’s environment and ecology to build an argument for not meeting the full requirement of the SHMA?  I know that WAG is working on some proposals in this area with some of the rural parishes and would be keen to discuss the matter with you and offer to share the costs of preparation. 

  1. Demand that the Council develops a vision and strategy for Hart that retains its role as a rural, green hinterland for NE Hampshire that respects the separate character and identity of Hart’s settlements and landscapes and preserves the green spaces as amenity space for the urban settlements.

You may recognise the words above as taken from the withdrawn 2013 Core Strategy.  This was, and remains a good vision.  I would ask that as a minimum, the forthcoming Regulation 18 consultation sets out at least one potential “vision” for the district, and that one of the “vision” options includes words to this effect.

  1. To require that the housing need is met by building on brownfield sites and increasing density in our existing urban areas

Last November, the council’s estimate of brownfield capacity over the entire plan period was around 750 units (taken from parts 1 and 3 of the SHLAA as per the FOI request I made) out of the then remaining 4,000 units to build (or grant permission for) up to 2032.  Since then considerable progress has been made in identifying and in some cases granting permission on additional brownfield sites:

LocationNumber of Dwellings
Guillemont Park Phase 1 (not included as brownfield site in SHLAA) 150
Guillemont Park Phase 2320
Ancells Farm, Fleet370
Bartley Wood, Hook200
Fleet Road, Fleet220
Bramshill House350
Fleet Police Station50
Extra dwellings at Landata House28
Total1,688

All of the dwellings above were not included as brownfield sites in the SHLAA.  Guillemont Park (Sun Park) was in the SHLAA but for a lower number of units, and in Part 2, which was not considered to include brownfield locations.  Since last November revised permission has been granted at Landata House for 28 more dwellings than were included in the 5 year land supply calculation.

If the original 750 units were to be added to the 1,688 units identified above, then that amounts to a total of 2,438 potential units on brownfield.  If it were possible to increase the density (from 30dph to a still reasonable 80dph in urban areas) on the original 750 units, the total identified capacity would rise to some 3,688 units.

The remaining requirement of 4,000 has of course been reduced by the unfortunate decisions to allow development at Watery Lane (300 units) and Hawley Park Farm (126 units) leaving the remaining allocation at 3,574.

It is clear that with some creativity and energy, the gap between the remaining allocation of 3,574 and the currently identified brownfield capacity can be closed by working on a combination of reducing the overall allocation by reducing the SHMA or applying environmental “policy on” considerations, increasing density and finding more brownfield sites.

In the light of this, I welcome the paper that is to be put before Cabinet next week, signalling the more positive approach that the council proposes towards building housing on previously developed land.

I would ask though, that you consider some further steps:

  • Creating a new, formal “reasonable suitable alternative” option of meeting the remaining housing allocation solely through brownfield development.  This option should appear in the consultation paper.
  • Creating a complete database of all of the potential brownfield sites in the district, including those not in the October 2014 SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock (aka Hartland Park), Sun Park, Ancells Farm, Bartley Wood, Fleet High St, Fleet Police Station and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).
  • Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.
  • Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.
  • This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor, particularly given the massive amount of current and forecast vacant employment land and Rushmoor seeking to protect 96 Ha.
  1. To request that future housing stock reflects the needs of the changing demographics of the district.

I set out in a question to council earlier this year that Hart will need to deliver around 2,500 housing units to meet the needs of the ageing population.  I contend that a new town will simply build the wrong type of accommodation in the wrong place to meet those needs.  It would be far better if these were built on brownfield sites in more urban areas, close to amenities such as doctors, post offices, shops and so on.  When the elderly move into these types of development, their well-being improves and of course, they free up conventional housing stock for families.  Could I therefore ask that the forthcoming consultation paper contains specific proposals on how the needs of the ageing population will be met?

  1. To demand the council and government do not plan for any new settlement in Hart that will act as a sink for the unmet housing need in neighbouring areas.

Addressing points 1, 2, 3 & 4 will render a new town unnecessary particularly when you consider the:

I do hope you find these suggestions helpful.  I would be grateful if you could circulate them to planning officers and Cabinet members for their consideration.

HBF calls for Hart to meet Rushmoor’s unmet housing need

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

The Home Builders Federation (HBF) has responded to Rushmoor’s Local Plan consultation and called for Hart to concrete over its green fields to build all of Rushmoor’s unmet housing need.

Hart is the solution

To ensure that the Council is doing what it can to maximise the effectiveness of the duty to cooperate the Council must approach Hart Council to make sure that it provides land to meet the shortfall arising in Rushmoor. We note in paragraph 4.6 of Topic Paper 2: Housing Delivery that the Council asserts that the duty is not a duty to agree. This suggests a lack of zeal on the part of the Council to ensure that the unmet housing need of Rushmoor is addressed. Even if Hart and Surrey Heath are unable to provide land the three HMA authorities should engage with authorities elsewhere to persuade them to provide land to accommodate the shortfall.

It then goes on to make the silly suggestion that Hart to review its Green Belt, when in fact Hart doesn’t have any Green Belt land.

Reviewing the Green Belt in Hart

The Council must work with Hart to remove land from the Green Belt if this is what is necessary to accommodate the housing shortfall.

The HBF then call on Rushmoor to increase their housing allocation by an arbitrary 10% because the HBF believe more affordable housing should be built.

We consider that a 10% adjustment upwards should be made to the baseline demographic need.

They do not seem to consider the option of house-builders reducing their prices, nor do they mention that part of the reason house prices are so high is because interest rates have remained at 0.5% for around 6 years.

Amazingly, the HBF make no mention at all of brownfield land in their submission, despite Rushmoor seeking to protect 96 Ha of land even though there will be a surplus of around 195 Ha of employment land across the Housing Market Area at the end of the plan period.

It is simply unacceptable for an unelected industry body to seek to override the wishes of local people by asking Hart to concrete over green fields, whilst at the same time ignoring the vast opportunity presented by brownfield sites.

If you would like to make your own submission to then please download the pre-prepared feedback forms below, fill in your details and send them off to plan@rushmoor.gov.uk.  The consultation closes on 20 July 2015.

Rushmoor Local Plan Response Form
Additional Response to Rushmoor Local Plan

 

Please help Hart fend off an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

Rushmoor Borough Council has published a draft Local Plan where it proposes to build only 8,200 of its assessed need of 9,822 houses over the plan period.  It is clear that Rushmoor is seeking to offload the remaining 1,622 houses on to Hart District.

We need to oppose this move and We Heart Heart have produced some materials to help you do this easily.  Our voice will have greater weight if we can get more Hart residents to comment on Rushmoor’s plan than Rushmoor residents. Please follow the simple process below:

  1. Download the Local Plan response form from the link below.
  2. On page 3, fill in your name and contact details and type your name and date in the boxes at the bottom of the page.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to plan@rushmoor.gov.uk
  5. Share a link to this page to all your friends and family as well as any sports clubs or community groups you belong to via word of mouth, email, Facebook and Twitter and ask them to put in a response and share this page again.
  6. If you have not already done so, please sign and share our petition too.
Rushmoor Local Plan Response Form

A summary of the arguments we are putting forwards is outlined below.

Slippery slope to taking more housing than the other districts

The proposal to take an additional 1,622 houses from Rushmoor puts us on the slippery slope to accepting a further 1,400 houses from Surrey Heath such that Hart District ends up having to build the most houses in the Housing Market Area.

 

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

 

This will impact all of our districts including Blackwater and Hawley; Bramshill;  Church Crookham; Crondall; Crookham Village; Dogmersfield; Elvetham Heath; Eversley; Ewshot; Fleet; Greywell; Hartley Wintney; Heckfield; Hook; Mattingley; North Warnborough; Odiham; Rotherwick; South Warnborough; Winchfield; and Yateley adding additional pressure to an already difficult situation and make it more likely we have to accept both a new town and urban extensions on our beautiful green fields and countryside.

Hart and the rest of Housing Market Area are being asked to build too many houses

The whole Housing Market Area (HMA) should reduce the assessed need by 7,800 units which would reduce the pressure on Hart directly and remove the need for Surrey Heath and Rushmoor to ask us to build >3,000 houses for them. This is discussed in more detail here.

Rushmoor isn’t making best use of its brownfield sites

This is discussed in more detail here and here. As can be seen, if Rushmoor gets more creative with Wellesley and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need.   It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build out of this wealth of opportunity.  Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries.  It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas.  Neighbouring districts could be approached to provide SANG capacity if required.  Rushmoor should also take a closer look at all the vacant sites in the district and seek to convert them to residential use.

Rushmoor’s Employment Land Review is overblown and seeks to protect more employment land than is necessary.

This is discussed here.  It is also clear that past forecasts got it wrong as evidenced by the large number of vacant office blocks and empty shops across Hart District.  If the ELR was reduced to more sensible levels they could free up more land for housing.

Indeed, even if you accept the overblown employment forecasts, there will be a surplus of nearly 600K sq m of employment space at the end of the plan period, covering around 195 Ha.  Yet Rushmoor seeking to protect 96 Ha of land whilst asking Hart to build 1,600 houses on green fields.

Rushmoor’s infrastructure plans are not credible

We posted here that Hampshire as a whole has a £1.9bn infrastructure funding deficit, with Rushmoor’s share of that being £80m.  Rushmoor makes no mention of this deficit in its draft Local Plan.  Hart’s own numbers show an infrastructure deficit of £78m.  All of these numbers are probably an under-statement given they were all produced before the scale of development now proposed was known.  This is in contravention of NPPF para 177 that says there must be a “reasonable prospect” of delivering the required infrastructure alongside housing:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan”

Finally, they don’t even attempt to quantify the extra infrastructure Hart would need to build the extra 1,600 houses nor do they make any offer to fund any of that extra cost.

Rushmoor not planning to meet the needs of the ageing population

Figure 10.15 of the SHMA sets out the need for specialist housing and registered care places for the HMA and Rushmoor.  This states Rushmoor must build 710 sheltered and extra care units as well as provide an extra 600 registered care places. Their draft Local Plan makes no mention of the extra registered care places and sets no target for the sheltered and extra care units.  This is in contravention of NPPF para 50 which states:

“local planning authorities should…plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)”

Therefore the Rushmoor draft Local Plan runs the risk of being found unsound and should be revised.

 

In conclusion, the Rushmoor draft Local Plan contains many serious flaws and needs to be revised.

Link

 

Hart District is being asked to build too many houses

Housing Market Area Migration and housing capacity

Figure 1: Housing Market Area Migration and housing capacity

Hart District is being asked to build 7,534 houses in the planning period up to 2032 (now 9,134 as Hart is starting to plan for an additional 1,600 houses from Rushmoor).  This target is based on the Objectively Assessed Housing Need (OAHN) contained in the Strategic Housing Market Assessment (SHMA) carried out by Hart District and Rushmoor and Surrey Heath Boroughs. We believe this target is too high because the SHMA is based on a number of flawed assumptions:

  • Inward migration assumptions unrealistic
  • Average household size unreasonable
  • Jobs growth forecasts not credible
  • Overall adjustments lead to building rate higher than national requirement

These are set out in more detail below and in the submission to the Owens Farm (Hop Garden Road), Hook appeal. The overall impact of correcting these errors would be to reduce Hart District’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone and won’t need a new town at Winchfield or anywhere else.

Inward Migration Assumptions Unrealistic

Inward migration to this or any other district represents a “want” of people living elsewhere to live in Hart and not a “need”.  Many people may desire to live in Hart because it is one of the best places to live in the country, but no-one “needs” to move to live here in the strict sense of the word.  Indeed inward migration to Hart represents the unmet needs of other districts.  If Government policy is followed, then the housing, employment, education and other “needs” of the people “wanting” to move to Hart should be met by the local authorities where they currently live and thus the apparent need for housing in Hart arising from inward migration should substantially reduce.  There is no evidence presented in the SHMA to evaluate the impact of reduced inward migration to Hart from other districts as a result of those districts now being forced to meet their own needs, nor the impact of the implementation of the Northern Powerhouse.  Indeed London has now agreed to meet its own housing need in full, which should reduce the scale of inward migration to the HMA.

Notwithstanding the above, the SHMA makes a subjective judgement to cherry pick inward migration data from 2005-2010 as being the “most realistic” approach to take to future demographic modelling.  Moreover, it uses spurious statistical analysis to try to infer causation from a weak correlation (R2=~0.65) between housing completions and inward migration.  This is inherently flawed for a number of reasons outlined below.

First, of course it is self-evident that the period during which the HMA delivered most housing was when inward migration was highest.  However, as was argued above, this scale of inward migration represents unmet needs of other districts rather than the unmet needs of Hart.

Second, the period when we were building most and attracting most inward migration was during one of the longest uninterrupted periods of economic growth in history, supported by a large structural deficit in the national accounts and the biggest credit binge of all time.  Of course it ended in a spectacular bust and can in no way be described as a “normal” or “sustainable” set of economic conditions.  The economic conditions we are seeing now with more moderate growth linked to the need for the Government, companies and people to live within their means and reduce debt will be the situation for the foreseeable future and thus represent a more “normal” situation.

The period 2007-2012 includes the final year of the boom, the recession and the now more moderate pace of economic growth that surely more closely represents future conditions.  Indeed, as Figure 1 shows (data taken from Fig. 7.4 of the SHMA on p71) taking the period 2007-2012, the HMA delivered 2,942 new dwellings which at an average of 2.5 people per dwelling created capacity for an extra 7,355 people to live in the area.  Despite that, the HMA experienced an overall outward migration of 1,824 people.  It surely cannot be considered sound to base the future housing “need” on increasing inward migration projections when recent data shows that in fact the HMA is undergoing net outward migration despite creating significant capacity for more people to live here.

Accordingly, the additional 1,210 houses postulated in the SHMA arising from inward migration should be removed from the housing “need”.

Average Household Size Forecasts Unreasonable

Average Houshold Size projections for Housing Market Area

Figure 2: Average Household Size projections for Housing Market Area

 

Figure 7.7 of the SHMA (reproduced as Figure 2 above) shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. This is in direct contradiction to both the 2008-based and 2011-based CLG projections.  Yet the forward projections used in the SHMA reverse the trend shown in actual data in the census and persist with the inaccurate forecasts of a continuing fall in the average household size.

Part of the justification for this is given as “at the time of the 2011 Census, the British economy was still in recession”.  This is factually incorrect as a cursory examination of the GDP numbers on the BBC website shows that the economy came out of recession in mid-2009.  It seems the forecasting “experts” are at a loss to properly explain this reversal of trend.

Moreover, given that the starting point for the SHMA projections is DCLG sourced figures, it would be somewhat odd for the DCLG forward projections not to include its own forecasts for household size.  There is therefore a significant risk that this part of the SHMA has double counted erroneous household size projections.

It is therefore inappropriate continue to assume a continuing downward trend in household size.  Surely a more prudent assumption would be to assume that the current household size is maintained and update that assumption and the SHMA as more real data comes to light.

Accordingly, the 1,500 additional houses in the SHMA related to the flawed household size assumption should be removed.

Jobs Growth Forecasts not Credible

The SHMA uses a set of jobs growth assumptions that are based on forecasts that are vastly in excess of what has been achieved in the most recent economic cycle.

The SHMA contains data on the historic rates of job growth for the HMA.  This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data.  This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%.  Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum for the 3 years in question or a CAGR of 0.05%.

Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3: Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3 shows a comparison of the BRES data and the ABI data that demonstrates the discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data.

Taking this 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum.

However, the SHMA uses as its central assumption that future jobs growth of 1,130 per annum will be achieved, equating to a CAGR of ~0.79%, nearly double what was achieved over the most recent economic cycle and far higher than that achieved during the unsustainable boom of 1998-2008.  Given the constraints on Government spending and tighter credit conditions that are likely to persist for some time due to tighter bank regulation, it is inconceivable that we will achieve an economic growth rate nearly twice that achieved during the last economic cycle. Figure 4 shows the comparison of these growth rates.

Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Figure 4: Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Little justification for this is given other than it is based on Experian forecasts. The recent job creation history (2009-2012) showed jobs growth of 67 per annum as we came out of the recession.  67 jobs per annum equates to less than 6% of the jobs that the SHMA assumes we will create. Revised figures for 2013 demonstrate a CAGR of jobs growth from 2009-2013 at 0.52%, still well below the SHMA projections at a time the UK as a whole is creating more jobs than the rest of the EU put together.  This demonstrates that the Experian forecasts are pie in the sky and it beggars belief that such unproven Experian forecasts should take precedence over the actual real world achievement.

A further illustration of the outlandish nature of the Experian forecasts is given in para 7.70 of the SHMA.  In its forecast published in 2013, Experian assumes there were 145,000 jobs in the HMA in 2011.  Whereas the 2011 Census says there were only 122,300 and the BRES data says 125,000.  How can we trust Experian to forecast the future when it can’t even get the the past right?

Even the Employment Land Review produced by Rushmoor Borough Council described the Experian forecasts as:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”

The SHMA also says at para 7.85:

“…there are many ways labour markets can adjust to an increase in demand for labour that do not require an increase in the resident workforce. In summary these are:

  • A reduction in unemployment
  • A rise in economic activity rates
  • A shift away from part time working to full time working
  • An increase in double jobbing
  • A reduction in out-commuting
  • An increase in in-commuting

None of these changes require an increase in resident population, and all of them will be stimulated if
wage and salary levels increase.

In the modelling, allowance has been made for only one of these effects…”

No explanation is given for not taking into account the other ways in which the labour market can adjust.

In addition, if one compares the jobs forecasts to the population forecasts, the overall forecasts imply a massive, unrealistic increase in the percentage of people of working age in employment as can be seen in the table below:

 

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

This shows an increase from around 70% of working age people in employment to 86-88%.  No justification for this increase is given anywhere.

From the above, it is clear that the employment forecasts are outlandishly large and the SHMA does not even take into account most of the ways in which jobs can increase without leading to a need for more housing.  It is clear we should not be basing our housing requirement on such forecasts.

Figure 4.1 of the SHMA demonstrates that Hart in particular and the whole HMA enjoy high levels of employment and unemployment levels that are below the regional and national averages.

Therefore, the number of jobs to be created in the future should at least partially be a matter of “want” rather than “need”.  The future employment targets should be based on a realistic assessment of the capacity of the economy to create jobs in the private sector as it is these jobs that will support the largely state sector jobs in education and health that will be required to support the increased population.

As noted above para 7 of the NPPG states that local communities should be involved

“from the earliest stages of plan preparation, which includes the preparation of the evidence base in relation to development needs”.

Moreover, a recent legal opinion from Peter Village QC has said:

“There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues.”

It therefore follows that the local community should be consulted upon the employment targets it wishes to set and the related scale of development required to meet that target.  No such consultation has taken place, nor is it planned which represents a significant flaw in the Local Plan process. The evidence from the petition indicates that local people are more likely to express a preference for a lower level of development.

Finally, despite enjoying high levels of employment, it is clear that we need to change the way we forecast jobs growth in the area as past methods have resulted in vast amounts of unused employment land and vacant retail outlets with examples illustrated here and here.

It is clear that past employment forecasts have been erroneous; that the future employment forecasts in the SHMA are spurious and do not represent a realistic assessment of future economic or employment growth rates; and the local communities have not been consulted upon this key issue.  Nevertheless, we can achieve enviable growth and employment rates in line with the requirement to “plan positively” without having to resort to such over-development.

Accordingly, the 5,100 additional houses in the SHMA related to the flawed employment forecasts should be removed.

Overall adjustments lead to building rate higher than national requirement

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 5: Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Evidence presented at the examination of the Vale of the White Horse Local Plan has demonstrated that if the adjustments made to the baseline DCLG housing projections were applied on a national basis, they would increase the national output of housing to double the DCLG estimate of what is needed and triple the recent output of housing.

Applying a similar approach to the Hart, Rushmoor and Surrey Heath SHMA shows that on a national basis, we would be delivering 54% more housing than we need on a national basis, see Figure 5 above.  Surely it cannot be right that we are being asked to build at a rate that would lead to a surplus of housing.

England housing delivery actuals and projected 1946-2031

Figure 6: England housing delivery actuals and projected 1946-2031

The baseline DCLG projections for the combination of Hart, Surrey Heath and Rushmoor call for 790 houses per annum (SHMA Figure 7.3).  This equates to the DCLG projection of 220,000 houses per annum nationally (see figure 6 above).  This compares to recent performance of around 150,000 houses per annum.

The final SHMA, after taking into account past under-delivery, amount to a total of 24,413 houses (see table below), or an increase of 54.6% over the DCLG baseline figures.  The duty to cooperate might mean that Hart District has to build more houses than either Surrey Heath or Rushmoor as part of our Local Plan.

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

If the same 54.6% uplift were applied to the DCLG projection, we would be building over 340,000 houses per annum nationally, more than double recent performance.

In recent years Hart has built more houses than it has been required to do and built at a rate above regional and national averages (SHMA Table 5.11).  It is beginning to look like the total of the local SHMAs are much larger than the overall requirement as defined by the DCLG. Surely it cannot be right that we are being asked to build at rate more than 50% higher than the DCLG suggests we need to meet overall demand.

Conclusions

The overall impact of removing these errors would be to reduce the overall housing target for the combined area by around 7,800 units.  This would reduce Hart’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone.

The brownfield development tracker

Brownfield Development thermometer for Hart District

Given the recent success in quantifying the brownfield development potential in Hart District, we thought it would be good to set up a monitor to see how close we are to identifying all of the dwellings we need to meet the residual requirement of 4,000 units for the Hart Local Plan.

This of course assumes that we have to deliver the Objectively Assessed Housing Need (OAHN) in the Strategic Housing Market Assessment (SHMA).  There is a chance we might have to deliver an extra 3,100 houses for Surrey Heath and Rushmoor.  But equally there is also the potential for us to challenge the SHMA and end up with a lower housing target.

We will try and keep track of this as the process develops.

Revised submission to Owens Farm (Hop Garden Road) Appeal

The slot we thought we had been allocated to the first part of the Hop Garden Road (Owens Farm), Hook  appeal (APP/N1730/W/14/2226609) unfortunately didn’t happen due to some administrative hiccough.  However, we have now been allocated a slot at 10am on 9 June 2015.  This has presented an opportunity to improve further our submission and make it stronger.

The full details of the submission can be found here:

Revised submission to Hop Garden Road Appeal

The summary of the submission is presented below and the main challenge to the SHMA here:

This purpose of this submission by the We Hart Campaign is to oppose the specific unnecessary development proposed at Hop Garden Road in Hook and demonstrate to other developers who may wish to put forward speculative proposals for the over-development of the district that they will face formidable opposition to their plans.  Hart District is facing a scale of development that is against the wishes of its residents and in contradiction to stated Government policy to place planning decisions in the hands of local people.

Let me remind you of the Prime Minister’s words in 2012, taken from this Telegraph article:

He said: “I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control. The fear people have in villages is the great big housing estate being plonked down from above.

“Our reforms will make it easier for communities to say ‘we are not going to have big plonking housing estate landing next to the village, but we would like 10, 20, 30 extra houses and we would like them built in this way, to be built for local people’.”

Mr Cameron, who was being interviewed in his Oxfordshire constituency, denied that the reforms would lead to large swathes of the countryside being built on.

He told BBC1’s Countryfile programme: “Here we are in west Oxfordshire one of the most beautiful parts of our country, set in some of England’s finest countryside. I would no more put that at risk than I would put at risk my own family.

“I care deeply about our countryside and environment. Our vision is one where we give communities much more say, much more control.”

We Hart object to this proposed development and any future speculative proposals on the grounds summarised below:

  • The SHMA and OAN are not objective and represent a “need” that is far too high.
  • Understated brownfield capacity means green field development is not necessary
  • This proposed development will not contribute towards meeting the needs of the changing demographics of the district
  • The proposed development will make the current infrastructure funding gap worse
  • Lack of consideration of the environment

As shown in section 8, the combined effects of reducing the OAN as assessed in the SHMA to a more realistic level and taking account of brownfield development in the pipeline that is not included in the Land Supply calculation would increase the land supply to 11.7 years.

The only reasonable conclusion from this analysis is that the Hop Garden Road application should be refused as it is not required; would build the wrong type of housing in the wrong place to meet the changing demographics of the district; would make the already difficult infrastructure funding position worse and needlessly concrete over our valuable green fields and damage the environment.

We Hart respectfully requests that this application is turned down.

 

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